ML20247Q630
| ML20247Q630 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/14/1989 |
| From: | Saint Andre B AMESBURY, MA, KOPELMAN & PAIGE |
| To: | |
| Shared Package | |
| ML20247Q627 | List: |
| References | |
| OL, NUDOCS 8909290050 | |
| Download: ML20247Q630 (15) | |
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89 SEP 25 P2 :40 UNITED STATES OF AMERICA NUCLEAR ItEGU1ATORY COMMISSION ATOMIC SAFETY LICENSING BOARD l
In the Matter of Docket Nos. 50-433-OL; PUBLIC SERVICE COMPANY OF 50-444-OL NEW HAMPSHIRE, et al. (Off-site EP)
(Seabrook Station,' Units 1 and 2)
TOWN OF AMESBURY'S PROPOSED FINDINGS OF FACT AND CONCLUSIONS WITH RESPECT TO THE SEABROOK PLAN FOR MASSACHUSETTS COMMUNITIES TABLE OF CONTENTS'
- 3. Traffic Management Plans 3.1 Findings of Fact 3.3 Conclusions
- 8. Protective Actions for Particular Populations 8.1 Findings of Fact
- 10. Coordination of Governmental Resources and Response 10.1 Findings of Fact
' The Town of Anesbury (TOA), as a limited participant in these proceedings, submits proposed findings of fact, and conclusions only with regard to those contentions listed in its request for limited participation.
8909290050 890922 PDR ADDCK 05000443 0 PDR
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- 3. Traffic Management Plans 3.1 Findings of Fact 3.1.1 -Chief of Police Michael A. Cronin testified on behalf of the TOA. He has been Chief of Police in Amesbury since 1981, and employed by the Amesbury' Police' Department since 1976. He has extensive training and experience in law enforcement and traffic control, particularly in the TOA.
Cronin Dir. ff. Tr. 16267 at 1 - 2. He is very familiar with the layout of streets'and traffic conditions in the Town, through his experience with the Police Department and as a resident of the area. Cronin Dir. ff. Tr. 16267 at 3.
[ Appl. PF 3.1.10). The Board finds he is competent to testify on the subjects he addressed.
3.1.2 The SPMC traffic plan designed for the TOA specifies 9 TCP's staffed by 17 Traffic Guides. The Board finds that this is inadequate for this town. At least two additional TCP's are necessary, one at the intersection of Friend Street and Main Street, and one at the intersection of Friend Street and Highland Street. Cronin Dir, ff. Tr. i 16267 at 12. Moreover, all of the TCP's specified in the plan require additional traffic guides to assist disabled vehicles, remove obstructions, control the volume of I traffic, and control the traffic in and through the numerous side streets, parking lots, blind corners and cut throughs.
Cronin, Dir. ff. Tr. 16267 at 14 - 15. [ Appl. PF 3.1.34).
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3.1.3 The Board finds that the design of TCP No. B-AM-01 is. inadequate to expedite vehicular traffic for a number j of reasons. First, the diagram fails to acknowledge the .
1 existence of several streets and potential conflict points,
- These include
- Ring Street as it intersects with Elm Street
- f east of the traffic circle; the parking. lot entrance / exit on \
Water Street south of the traffic circle: Friend Street g
intersecting Route 150 from the west in the southbound. land; and the entrance / exit for. buses from the staging area which intersects Route 150 from the east in the northbound land.
All of these points should be controlled. Cronin Dir. ff.
Tr. 16267 at 5. Moreover, this TCP provides only a limited t
capacity for evacuating traffic from the Town, since it is constrained by the size of the roadway and excessive congestion from its downtown location. Tr. 16289.
3.1.4 The Board finds that the design of TCP No. B-AM-02 is inadequate to expedite vehicular traffic. It fails to account for the probable heavy traffic volume and flow along the routes through the TCP and the conflicts that will occur with cross-over traffic. There are too few traffic guides assigned to this TCP to regulate and direct traffic along these established routes. Given the heavy volume of traffic that will pass through this TCP, cones will not be effective for re-routing traffic. The probable heavy volume of traffic along Route 110 (Haverhill Road) heading southwest is likely to cause motorists to change 3
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I direction and cross-over to the Route 150 connector towards Route I-495. This TCP'is poorly designed and ill-equipped to handle the volume of traffic likely to pass through this.
section of Town. Cronin Dir. ff. Tr. 16267 at 5 - 6: Tr.
16317; 16318 [ Appl. PF-3.1.34).
3.1.5 The Board finds that the design of TCP No. B-AM-03 is inadequate to expedite vehicular traffic. It fails to account for the heavy volume of traffic likely to be present along these routes. Hillside Avenue will have at least two lanes of traffic in the north and southbound lanes that must merge onto the southbound ramp of Route I-495. There will also be three lanes of traffic from Route I-495 north bound.
forced to merge on to a ramp, and traffic from Hunt Road that will merge with the two lanes of traffic north bound on Hillside Avenue. The inadequate number of traffic guides assigned to this TCP, and the use of cones instead of barricades are the most significant defects in this TCP.
Cronin Dir. ff. Tr. 16267 at 6; Tr. 16336 at 8 - 15. [ Appl.
PF 3.1.34).
3.1.6 The Board finds that the design of TCP No. B-AM-04 is inadequate to expedite vehicular traffic. This TCP fails to acknowledge the existence, and therefore the impact, of intersections, (that is, entrance / exit points),
from businesses and institutions in the area. These include: the Mr. Donut restaurant intersecting Main Street in the north bound lane south of the Macy Street 4
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intersection and intersecting Macy Street in the east bound lane east of-the Main Street intersection; the Cumberland u
Farms store intersecting Main Street in the south bound lane
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south of'the Macy Street intersection and intersecting the east bound lane of Macy Street west of the Main Street k
l intersection; the bank intersecting the west bound land of Macy Street west,of the Main Street intersection and
. intersecting Main Street in the south bound lane north of the Macy Street-intersection; the existence of the Middle School off of Main Street north of the Macy Street I intersection; and the existence of the gas station and kindergarten buildings located on Macy Street west of the Main Street intersection with entrance / exit points intersecting with the east bound lane of Macy Street. The diagran also fails to acknowledge the existence of the nursing home and hospital north of this TCP but certainly influential in the volume of traffic through this TCP.
l The absence of the above-mentioned intersections represent a substantial defect in the TCP because of the great potential that motorists will circumvent the traffic barriers and traffic flow restrictions on Main Street in north and south bound lanes, and the west bound lane on Macy Street.
This increases the likelihood of traffic accidents due to notorists cutting into lanes of traffic, which will impede evacuation. Cronin Dir. ff. Tr. 16267 at 6 - 7; Tr.
16341; Tr. 16341 - 16342. [ Appl. PF 3.1.34).
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3.1.7' The Board finds that the design of TCP No. B-AM-05 is inadequate to expedite vehicular traffic. The diagram is.particularly misleading to a Traffic Guide trying to establish the TCP as recommended by the SPMC because it misrepresents the location of Main and Sparhawk Streets.
L Additionally, it fails to acknowledge'the existence and
_ therefore the impact of intersections with Main and School- ,
Streets. These include: the entrance / exit points of the bank on the corner of Main Street where Main Street changes direction from north'to east; the entrance / exit points for the library which intersect with Main Street in the west bound lane east of the School Street intersection, and intersects School Street in the north bound-lane north of the Main Street intersection; the entrance / exit to an
. elderly housing complex which intersects with the east bound
- lane-of Main Street east of the School Street intersection;
~and the entrance / exit to St. Joseph's Church and parish hall intersection with the south bound lane on School Street north of the intersection and with the west bound lane of Sparhawk Street west.of the intersection.
The absence of the above-mentioned represents a substantial defect in the TCP because of the great potential that motorists will circumvent traffic barriers and flow restrictions north on School Street and both south and east on Main Street. Cones would be ineffective at this l i
I intersection where there is just one traffic guide and there i 6 I l
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[' such a great potential for variance from intended routes by use of the.abrve mentioned driveways and side streets.
Cronin Dir. ff. Tr. 16267 at 8 - 9; Tr. 16349 - 16352.
[ Appl. PF 3.1.34].
3.1.8- The Board finds that the design of TCP No. B-AM-06 is inadequate to expedite vehicular traffic. It fails to account for the existence, and therefore the impact, of l several intersections with Elm Street, Clarks Road, and Macy Street (Route 110). These include:. the entrance / exit l- points from the Burger King restaurant intersecting the east-
-bound lanes of Macy Street in two places west of the Clarks Road / Elm Street intersection, and intersecting Clarks Road in the south bound lanes in two places south of the Macy Street intersection; the entrance / exit points from the gas station at the corner of Macy and Elm Streets which intersects Macy Street in the west bound lane in two places west of the Elm Street /Clarks. Road intersection and intersecting Elm Street in the south bound lane north of the Macy Street intersection. The absence of the above mentioned intersections represents a substantial defect in-this diagram because of the great potential that motorists will circumvent the traffic barriers and the traffic flow restrictions on Clarks Road south bound, Elm Street north bound and Macy Street east and west bound.
An even greater defect is the unnecessary stopping and splitting of traffic flows which will certainly u.
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..- ( g cause delays and probably create choke points in this TCP.
The stopping of traffic on Route 110 to allow for southbound Elm Street traffic to merge with westbound Route 110 traffic, and the stopping of east bound Route 110 traffic to allow the merge of traffic from Clarks Road and from traffic reversing direction (u-turn) on Route 110 will certainly cause traffic to back up and stop in all directions. -
The splitting of westbound traffic on Route 110 sending one lane south on Route 95, and the other west to either turn on Route 110 to head east on Route 110, then south on Route 95, or continue west on Route 110 until reaching Route 495 south is an ill-conceived and wholly impractical plan. Drivers wishing to use I-95 will resist this re-direction, causing both conflicts with traffic guides and unauthorized cross-overs which will result in further delays in traffic flows. Cronin Dir. ff. Tr. 16267 at 9 - 11; Tr. 16362 - 16364. [ Appl. PF 3.1.34).
3.1.9 The Applicant has failed to address the numerous deficiencies in the design of the TCP's for the TOA.
3.1.10 The Board finds that Appl. Exh. 44, titled "Amesbury Comprehensive Energency Management Plan", is of no assistance in evaluating the adequacy of the SFMC traffic plan for the TOA. The plan is based largely on a generic 1
state emergency management plan, and was prepared solely by the Town's Civil Defense Director and state civil defense 1 j
employees. Tr. 16752-3; 16780. No other town boards or 8
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officers reviewed the plan, nor do they rely upon it.
Neither the Board of Selectmen, Town Manager, or Town Meeting have accepted it. Tr. 16760-1; 16773; 16781; 16832.
There are numerous errors and omissions in the plan on important issues such as the location of the emergency operations center, the availability of bus and taxi companies for evacuation, and the location of the two main traffic control points. Tr. 16791; 16796; 16808; 16830. It is clearly incomplete, out of date, and inadequate for use in conducting a wholesale evacuation of the Town in the event of a radiological incident at Seabrook Station. The Civil Defense Director indicated the plan is unworkable for use by anyone but himself. Tr. 16803; 16833. The map showing the TCP's is of unknown origin, but apparently was drawn up by the Town's Civil Defense Director with the assistance of a state employee. Tr. 16811-12. The police chief, who has jurisdiction over such matters, had never seen it prior to it being shown to him when he was on the witness stand. Tr. 16380; 16389. Even the Civil Defense Director admits that the evacuation map does not show an adequate number of TCP's and is inaccurate. Tr. 16812; 16813; 16817-19. The Board, for all these reasons, attaches no weight to the contents of the plan. [ Appl. PF 3.1.34).
3.1.11 The Board finds that additional TCP's are necessary in order to increase the efficiency of the evacuation of the traffic from the TOA in comparison to an 9
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evacuation in the absence of any plan. Cronin, Dir. ff. Tr.
16267 at 15. Twelve TCP's are used by the police department to clear only one section of Town during Amesbury Days, _
using wooden barriers and police officers at each barrier.
Tr. 16416-17. Even with twelve TCP's, it takes one and one-I half hours just to clear the traffic out of one section of the Town. Tr. 16418. [ Appl. PF 3.1.33).
3.1.12 Two additional intersections along heavily travelled evacuation routes should be designated as TCP's for the TOA. The intersection at Friend and Main Streets is at a 45 degree angle that proceeds up on incline to the -
right hand side. It is 3ccated near TCP B-AM-01 and the entrance / exit point for the buses from the staging area.
Cronin Dir. ff. Tr. 16267 at 5, 12; Tr. 16288. The intersection of Friend Street and Highland Street also needs a TCP. Due to the proximity to the High School, elementary school, nursing home, and apartment complexes, a TCP is needed to prevent the heavy volume of traffic along this route from proceeding into the downtown area. Cronin Dir.
ff. Tr. 16267 at 12. [ Appl. PF 3.1.33].
3.1.13 The Applicant has failed to address the need for additional TCP's in the TOA. [ Appl. PF 3.1.33).
3.1.14 The use of traffic cones as a traffic control device, rather than concrete barriers, is inadequate to redirect traffic along the desired route as set forth in the SPMC, and discourage traffic from taking an undesired route.
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Cones are adequate only in limited instances when there is light traffic, sufficient time for the cones to be safely i placed in the road way and at least one person in place to l
assist in the re-direction of traffic. Due to the expected heavy volume of traffic and lack of adequate traffic guides, -
f this will be impossible. Also cones, because of their height, may not be visible to drivers. Cones are also ineffective because they are easily disregarded as a barrier. Persons can simply drive over the cones or around then. Once the cone barrier has been interrupted by traffic it is very difficult, and potentially hazardous, even in light to moderate traffic, to re-establish. Concrete barricades are obviously not as easily stored or noved as cones, but they are far better for enforcing traffic restrictions. Concrete barricades are by far the nost effective means to enforce traffic restrictions, and re-direct noderate to heavy traffic. Cronin Dir. ff. Tr. 16267 at 13; Tr. 16321; Tr. 16334; Tr. 16404. [ Appl. PT 3.1.41].
3.1.15 Even if concrete barricades are used, however, the SPMC traffic plan will still be unable to expedite the flow of traffic out of the TOA. Concrete barricades are cumbersone and rust be transported by crane and flat bed trucks. They cannot be installed in energency situations unless they are stored within a reasonable distance from the site where they are needed, and there is enough notice to obtain equipment necessary to nove and install them. Even 11
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2 if the barricades bre stored near the TCP's, however, it will not' cure the problem. There is no provision in the SPMC for advance warning to public safety officials and traffic guides of a radiological emergency. These barriers would be difficult to establish under normal, non-emergency traffic conditions, and nearly impossible under emergency situations. With the onset of heavy traffic following the announcement of a radiological emergency it would be extremely difficult as well as hazardous to interrupt and re-direct traffic. Unless public safety personnel or traffic guides are pre-positioned with their equipment, , and have advance warning of an emergency and evacuation, the pre-positioning of concrete barriers will prove as useless as if they were stored a great distance from the TCP. Even under optimum-conditions, it would take up to two hours to position the barricades. They could also impede emergency vehicles. Cronin Dir. ff. Tr. 16267 at 13 - 14; Tr. 16337; Tr. 16370-71; Tr. 16402. [ App]. PF 3.1.41).
3.1.16 Due to the inherent problems in using either traffic cones or concrete barricades to redirect traffic, the Board finds that the Applicant has offered no acceptable traffic control devices to redirect traffic to expedite the flow of traffic out of TOA. Accordingly, the SPMC is inadequate in this respect. Tr. 16337. [ Appl. PF 3.1.41].
3.1.17 The TCP's also fail to show or take into account institutions which could have a major impact on 12
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1 I traffic flow, such as hospitals and schools. The evacuation of a school when in session or a hospital will add a significant number of vehicles which, without a, traffic guide, can lead to traffic backups which will inpede the existing TCP's. TCP L-AM-01 does not even indicate where the nearby entrance / exit of the SPMC's own transfer area is located, despite the fact that the buses entering and exiting will affect traffic flow. Cronin Dir. ff. Tr. 16267
. at 5,f7, 15. [ Appl. PF 3.1.35).
3.1.18' The failure of the SPMC to identify sufficient TCP's, and to adequately design and staff those it has t
L identified, will. lead to traffic queues and impedance rather l
, than expedition of traffic. The failure to account for j breakdowns in TCP's,. conflicts between motorists, disabled I
vehicles, injuries, and motorist inquiries will cause further delays. Drivers faced with queues will use available traffic lanes, cut throughs, or drive through cones to attempt to escape. This type of behavior occurs even under normal conditions, and would be exacerbated during an 6mergency evacuation. Cronin Dir. ff. Tr. 16267 at 11, 14-15; Tr. 16321; 16330-32. [ Appl. PF 3.1.34, 3.1.37).
3.1.19 The TOA population is approximately 16,000 year-round residents. During the summer that number increases to over 21,000. Moreover, during Amesbury Days, which covers from ten to thirteen days during the summer, 13
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-a the population swells further to between 25,000 to 30,000 during certain events. Cronin Dir. ff. Tr. 16267 at 4. The
. failure of the SPMC to take this increase into account seriously flaws its ETE analysis. [ Appl. PF 3.1.61).
3.3 Conclusions 3.0.1 The Board concludes that the traffic management plan in the SPMC is inadequate with regard to the TOA. -
- 8. Protective Actions for Particular Populations 8.1 Findings of Fact 8.1.1 The SPMC fails to include two major facilities for the elderly in TOA, the Heritage Towers and the Park Side nursing home. The omission of Heritage Towers especially signifies a substantial defect in the SPMC because the result is a failure to account and plan for 150-to 200 elderly persons housed in 100 units. In addition to the special facilities for the elderly, the SPMC also fails to acknowledge the approximately sixty Family Day Care providers' located throughout town which are licensed by the Massachusetts Department of Children. Each of these facilities has an average of 5-6 children of pre-school age.
Cronin Dir. ff. Tr. 16267 at 18 - 19; Tr. 16408-9. [ Appl.
PF 8.1.44).
- 10. Coordination of Governmental Resources and Response 10.1 Findings of Fact 10.1.1 There is no evidence that the TOA is equipped, even with a best efforts response, to accomplish a wholesale 14 1
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.s , t emergency 1. evacuation of the Town in the event of a radiological emergency.- The only emergency plan in the i
Town, Appl.- Exh.-'44, is usable only by the-Civil Defense
' Director, due to its numerous errors and lack of review by any other town official, yet the' Civil Defense Director is e admittedly'not in charge of emergency response. The deficiencies in the plan were exhaustively reviewed underl cross examination of Civil. Defense Director Richard Clark by TOA's counsel. Tr. 16783 - 16833. See also TOA PF 3.1.10.
Clearly,'no reliance can be placed on TOA's ability ~to adequately respond to an emergency at Seabrook Station.
[ Appl. PF 10.1.14, 10.1.15).
Respectfully submitted,
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Barbara J/ Saint ' Andre Kopelman(and Paige, P.C.
H 77 Franklin Street Boston, MA 02110 (617)451-0750 l
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