ML20247Q639
| ML20247Q639 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 08/14/1989 |
| From: | Saint Andre B KOPELMAN & PAIGE, NEWBURYPORT, MA |
| To: | |
| Shared Package | |
| ML20247Q627 | List: |
| References | |
| OL, NUDOCS 8909290052 | |
| Download: ML20247Q639 (16) | |
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UthhC August 1 4,-' 1 9 8 9
'89 SD) 25 P2 :41 UNITED STATES OF AMERICA-NUCLEAR REGULATORY COMMISSIOl(
ATOMIC SAFETY LICENSING BOARD In the Matter of.
Docket Nos. 50-433-OL PUBLIC SERVICE COMPANY OF 50-444-OL 12 NEW HAMPSHIRE,Let al.'
(Off-site EP)
(Seabrook Station, Units 1 and 2)
CITY.0F NEWBURYPORT'S. PROPOSED FINDINGS OF FACT AND
-CONCLUSIONS WITH RESPECT TO THE SEABROOK PLAN
-FOR MASSACHUSETTS COMMUNITIES Table of Contents' l
- 3.. Traffic Management Plans 1
3.1 Finding of Fact l
3.3 Conclusions l
4.
Evacuation of Transit Dependent Persons 4.1 Findings of Fact 4.3 Conclusions
' The City of Newburyport (CON), 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.
8909290052 890921 PDR ADOCK 05000443 O
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3.
Traffic. Management Plan 3.1 Findings of Fact 3.1.1 City Marshall Francis E. O'Connor testified on tbehalf of~the CON.
The City Marshall is the same position as Chief of Police.
Marshall O'Connor'has extensive training and experience in law enforcement and traffic l
L control, particularly in the CON.
Marshall O'Connor has been employed by the CON Police Department for 28 years, has lived in the CON all his life, and is very familiar with the layout of streets and their relationship to major regional.
L highways and access routes.
O'Connor Dir. ff. Tr. 16458 at '
'l - 3; Tr. 16472.
[ Appl ~. PF 3.1.19].
The Board finds he is competent to testify on the subjects he addressed.
3.1.2 The SPMC traffic plan designed for the CON specifies 7 TCP's staffed by 18 Traffic Guides.
The Board finds that this is inadequate for the city.
There are at least seven additional major intersections in the CON which require TCP's, and numerous intersections along the CON's main streets which should have a Traffic Guide.
O'Connor Dir. Tr. ff. 16458 at 9, 13, 15-16.
Moreover, the TCP's in the plan require additional Traffic Guides to assist motorists, remove obstructions, and keep traffic flowing.
O'Connor Dir. ff. Tr. 16458 at 6 - 14, 16 - 17; Tr. 16499-500.
[ Appl. PF 3.1.33].
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3.1.3 The Board finds that the design of TCP No. E-NP-01 is inadequate to expedite vehicular traffic.
Route 1 south from New Hampshire and Parker Street west from Plum Island are major transportation routes, and given the volume on these routes even in non-emergency conditions, the number of traffic guides, 5,
is certain to be inadequate to enforce traffic routes in an emergency situation.
In addition, there is no traffic guide positioned below the Route 1 traffic circle on Route 1 to prevent cross over traffic between south and north bound routes.
O'Connor Dir. ff. Tr.
16458 at 6 - 7.
[ Appl. PF 3.1.38).
3.1.4 The Board finds that the design of TCP No. E-NP-02 is inadequate to expedite vehicular traffic.
The traffic guides positioned on the median strip below the interchange between north and south bound lanes of I-95, and north of the interchange on the median strip between the north and south bound lanes of I-95 serve no apparent purpose to ensure flow of traffic as neither is close enough to traffic barriers to protect their integrity or facilitate the movement of re-directed traffic.
The traffic guide on Route 113 west of I-95 positioned between two traffic barriers serves two directions of traffic and is therefore inadequate.
At least one other traffic guide should be assigned there.
There should also be traffic guides on the ramp to I-95 south from Route 113 where the traffic from the two 3
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sides of. Route 113 converge,,and at least one traffic guide at the end of the ramp to facilitate traffic entering I-95.
There is a potential conflict point between traffic from' West Newbury travelling east on Route 113 and traffic-from
.Newburyport travelling west on Storey Avenue and traffic travelling south on I-95.
The cloverleaf pattern at the j
interchange must accommodate traffic narrowing and converging from I-95 north bound and is not adequately staffed to facilitate the flow of evacuating vehicles or those trying to return home to families in West Newbury or Newburyport.
O'Connor Dir. ff. Tr. 16458 at 8 - 9.
(Appl.
PF 3.1.38).
3.1.5 The Board finds that the design of TCP No. E-NP-03 is inadequate to expedite vehicular traffic.
The scale of this diagram is significantly distorted, especially the distance between the Ferry Road, Low Street / Woodman Way, and Noble Street intersections with High Street.
These intersections are each at least one quarter mile apart.
The TCP also fails to account for a new connector road between Route 113 and Ferry Road, which will have to be closed off with barricades.
The diagram shows a roadway from Route 113 to the apartments which does not exist.
i The area should be broken down into 3 TCP's instead of just one.
The TCP's should cover:
- 1) the intersection of Low Street and Route 113; 2) the intersection of Noble Street and Route 113; and 3) the 4
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int'ersection of Ferry Road, Moseley Avenue, High Street, and Route 113. ~ This is the-most heavily travelled area in the City, and also has the highest accident rate.
There must be
.significant1y'more manpower to handle the trat.2Ec flow.
Traffic guides should be assigned at each interaction with Route 113.
Finally, there is no provision for barriers or traffic guides to facilitate entrance and egress from the apartment complexes identified on or near Woodman Way and Low Street.
O'Connor Dir. ff. Tr. 16458 at 9 - 10.
(Appl.
PF 3.1.38].
3.1.6 The Board finds that the design of TCP No. E-NP-04 is inadequate to expedite vehicular traffic.
This TCP will not improve traffic flow because it fails to account for the many conflict points resulting from intersections of.
side streets with Toppans Lane, High Street, and Route 113.
These include:
Highland Avenue; Tyng Street: Carter Street; and Summit Street.
Highland Street, which intersects with Toppans Lane, is the access route to the Anna Jacques Hospital.
l This a major intersection and as such requires more than one traffic guide to control and facilitate the flow of traffic from at least 3 different directions.
The High School, Middle School, a convalescent home, and Anna Jacques Hospital are located within this area, yet there is l
no indication of barriers or Traffic Guides to facilitate i
circulation of vehicles servicing these facilities.
Traffic 5
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L guides should be assigned to all exit and entrance points to facilitate traffic.
In particular, there is no indication of the egress points, one on High Street and one on Toprans Lane, from the High School.
Because.of the above-mentioned problems there is inadequate traffic guide staffing and placement of traffic barriers in this TCP.- At least three traffic guides should be added to this area. _O'Connor Dir.
ff. Tr. 16458 at 10 - 11.
[ Appl. PF 3.1.35, 3.1.38).
3.1.7 The Board finds that the design of TCP No. E-NP-05 is inadequate to expedite vehicular traffic.
There is no traffic guide positioned on Winter Street to ensure re-directed traffic continues down the ramp onto Route 1 south.
. Additional barricades should be placed on Merrimac Street, across from the ramp from Route 1 north, to ensure all traffic turns left in an orderly fashion.
This area requires at least two traffic guides.
There should be traffic guides on Route 1 north directing traffic up the rarp to Merrimac Street and discouraging any cross-over traffic to Route 1 south.
O'Connor Dir. ff. Tr. 16458 at 11
- 12.
{ Appl. PF 3.1.38].
3.1.8 The Board finds that the design of TCP No. E-NP-05 is inadequate to expedite vehicular traffic.
The scale of this TCP diagram is inaccurate as it significantly distorts the distance between the Low Street /Graf Road intersection and the Graf Road / Parker Street intersection, which is at least one half mile.
The overall representation 6
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of the area is poor.
There is a Middle School located off of. Low Street near the intersection with Graf Road and an elderly housing developraent near that same intersection.
Neither are indicated on the maps.
The industrial park ces rs the area between Mulliken Way and Highfield Road.
There is no provision for entrances or exits from Low Street to these facilities.
There is consequently no provision for traffic guides in these areas, despite the heavy traffic generated by the industrial facilities.
Perkins Way and Malcolm Hoyt Drive intersect with Parker Street but neither are accounted for in the TCP.
The diagram indicates that traffic is to turn around on Highfield Road, but there is no traffic guide or barrier to facilitate this.
Given the distorted scale of this diagram and the actual distance between traffic control points there should be provisions for at least three additional traffic control points in the area covered by this diagram.
O'Connor Dir, ff. Tr. 16458 at 12 - 13.
[ Appl. PF 3.1.38).
3.1.9 The Board finds that the design of TCP No. E-NP-05 is inadequate to expedite vehicular traffic.
The Plum Island Turnpike is the only route off of Plum Island for vehicles.
Most of the summer residences on Plum Island have been converted in recent years to year round residences, so there is heavy traffic flow all year.
There are from six to l
eight thousand year-round residents, and another eight to l
ten thousand on a summer weekend.
Given the traffic volume 1
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- i on Water ' Street and Plum Island Turnpike there should lx?
more than one traffic guide at this intersection to insure west-bound traffic en Plum Island Turnpike turns south on
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Ocean Avenue.
Cones'and the single traffic guide assigned to this intersection are also inadequate'to ensure restricted traffic flow and prevent west bound traffic to Plum Island Turnpike for those attempting to return home to' Plum Island..
In.the past, the CON has had to station two or more police officers at this intersection to expedite traffic flow when large numbers of people exit the Island at the same time.
O'Connor Dir. ff. Tr. 16458 at 13 - 14; Tr.
16495-96; 16514; 16521-22.
[ Appl. PF 3.1.38).
3.1.10 The use of traffic cones as traffic control devices, rather than wooden barricades or concrete barricades, is inadequate to redirect traffic along the desired route, as set forth in the SPMC, and to discourage traffic from taking an undesired route.
Cones because of their height may not be visible to drivers.
Cones are also ineffective because they are easily removed and can be driven over.
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.
For these reasons, the CON does not use cones when redirecting 4
traffic, but only wooden or concrete barricades.
O'Connor 8
- )
t Dir. ff. Tr. 1645F at 4; Tr. 16487-89; 16516-17;-16520-21.
L
- { Appl. PF 3.1.41).
3.1.11 Applicants' contention that wooden barricades are as easily moved as cones misses the point.
While either wooden barricades or' cones may be moved by a driver who stopsLhis vehicle, gets out, and moves it, cones.can be.
driven over and therefore are less likely to discourage drivers since they can be circumvented without the driver having to stop or leave his vehicle.
O'Connor Dir. ff. Tr.
16458 at 4; Tr. 16516.
[ Appl. PF 3.1.20).
3.1.12 The SPMC fails to provide for an adequate number of personnel to staff the TCP's in the CON.
There should be at least one traffic guide to accompany any traffic control barrier restricting or redirecting traffic flow.
This person would ensure that emergency vehicles could pass through, discourage drivers from disregarding the barrier, and restore the barrier if it is disrupted.
O'Connor Dir. ff. Tr. 16458 at 15; Tr. 16488.
[ Appl. PF 3.1.38).
3.1.13 The Board finds that additional TCP's are necessary in order to increase the efficiency of the evacuation of traffic from the CON in comparison to an evacuation in the absence of any plan.
O'Connor Dir. ff.
Tr. 16458 at 15 - 16.
[ Appl. PF 3.1.33).
3.1.14 In addition to the additional TCP's identified in CON PF 3.1.5 and 3.1.8, there should be at least one 9
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4 traffic guide'for every intersection which egresses onto a main thorough fare.
A number of traffic guides are also needed along the bus routes.
One of the additional TCP's needed is State and High Streets.
This is a crucial intersection and one of the busiest in the city.
It is also the point of passage for four'out of the five Bus Routes cited in the plans.
The intersection of Merrimac Street, Moseley
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Avenue and Spofford Road also should have a TCP.
This is another major intersection, servicing the north end of the City and' Route 110.
It also creates a potential " choke-point" as these three major thorough fares merge into a narrow, two lane road that spans an old suspension bridge.
The intersection of Low Street, Route l'and Pond Street _ requires at least three traffic guides.
This is a lighted intersection with several major routes converging at this point.
It is a major intersection of traffic heading south on Route 1 from Salisbury and southern New Hampshire and re-routed traffic from Merrimac Street as well as traffic from State and High Streets.
This intersection has the potential for major traffic flow and thus creates the possibility of backing traffic into designated TCP's.
O'Connor Dir. ff. Tr. 16458 at 15 - 16.
[ Appl. PF 3.1.33).
3.1.15 The TCP's also fail to show or take into account institutions which could have a major impact on traffic flow, such as hospitals and schools.
The evacuation 10
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of a school when in session or a hospital will add a a
significant number of vehicles which, without a traffic guide, can lead to traffic backups which will impede the existing TCP's.
O'Connor Dir. ff. Tr. 16458 at 10 - 11, 12.
The High School, Middle School, Anna Jacques Hospital as well.as elderly housing are all within approximately one
. quarter to once. half mile of each other.
These institutions are also locat4d near one of the City's busiest intersections, High Street, Broad Street, and Toppans Lane.
In the event of a radiological emergency, even if additional personnel were assigned to these institutions, it would be difficult to interrupt heavy traffic to allow buses to safely enter and exit these facilities.
O'Connor Dir. ff.
Tr. 16458 at 17.
[ Appl. PF 3.1.35).
3.1.16 Applicants have failed to address the need for additional TCP's and Traffic Guides in the CON.
[ Appl. PT 3.1.33).
3.1.17 The failure of the SPMC to identify sufficient TCP's, and to adequately design and staff those it has identified, will lead to traffic queues and impedance rather than expedition of traffic.
The failure to account for breakdowns in TCP's, conflicts between motorists, disabled vehicles, injuries, and motorist inquiries will cause further delays.
Drivers faced with queues will use available traffic Innes, cut throughs, or drive through cones to attempt to escape.
This type of behavior occurs 11
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1 even under normal conditions, and would be exacerbated during an emergency evacuation.
O'Connor Dir, ff. Tr. 16458 at 16 - 19; 14-15; Tr. 16321; 16330-32; 16516-17.
[ Appl. PF 3.1.34, 3.1.37, 3.1.18].
3.3 Conclusions 3.3.1 The Board concludes that the traffic management plan in the SPMC is inadequate with regard to the CON.
4.
Evacuation of Transit Dependent Persons l
l 4.1 Findings of Fact 4.1.1 The Board finds that the SPMC bus circulation plan in the CON.is inadequate to retrieve and evacuate the L
transit dependent population is a cafe, timely, and efficient manner.
The bus routes do not properly service large centers of the City's population, only skirting densely populated areas requiring residents to walk significant distances to designated waiting areas.
Delays in commencing the retrieval and evacuation process because of the unavailability of buses, traffic congestion after the onset of a radiological emergency, and the failure to have adequate TCP's along the bus routes, would all defeat the objective of a safe, timely, and efficient evacuation of residents by bus.
O'Connor Dir. ff. Tr. 16458 at 19 - 20.
[ Appl. PF 4.1.16).
4.1.2 The Board finds CON Bus Route No. 1 to be inadequate for expediting the retrieval of transit dependent persons.
There is no TCP at <ne intersection of Water 12
C Street, State Street, and Merrimac Street, and there are no TCP's on Water Street, which the bus is supposed to travel on buses are supposed'to cross State and High Streets but l
there is no TCP at that intersection.
Buses will then have 1
to turn left onto Pond Street, again without benefit of a traffic guide.
Buses are supposed to cross the intersection at Low Street, Route 1, and Pond Street, but there is no TCP at this intersection, either.
Buses are supposed to pass through the poorly_ staffed Ferry Road, High Street, and Moseley Avenue _ intersection, as well as other inadequately staffed and equipped TCP's.
There should be traffic guides at the major intersection s along the route, including Low Street /Toppans Lane; Turkey Hill Road and Storey Avenue; Ferry Road and Spofford Street.
This route, through heavily traveled roads and intersections without traffic guides or TCP's, will result in delays in evacuating transit dependent persons.
O'Connor Dir. ff. Tr. 16458 at 20 - 21.
{ Appl. PF 4.1.16].
4.1.3 The Board finds that CON Bus Route No. 2 is inadequate for expediting the retrieval of transit dependent persons.
Buses are supposed to travel west along High Street.
There is no provision to sweep through connecting streets, thereby leaving large numbers of persons who need transportation in Newburyport's heavily populated north end to leave the shelter of their residences and walk a considerable distance to either Merrimac or High Streets to 13
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wait at bus pick-up stops.
There is no TCP at the High Street / State Street intersection, which this bus route passes'through, or along Water Street or Merrimac Street.
O'Connor Dir. ff. Tr. 16458 at 21.
[ Appl. PF 4.1.16).
4.1.4 The. Board finds that CON Bus Route No. 3 is inadequate for expediting the retrieval of transit dependent persons._ This route passes along a major population center, the City's south end, without any provision for pick up points within short distances from residences.
It is required to pass through the High Street / State Street intersection twice, which does not have a TCP.
O'Connor Dir. ff. Tr. 16458_at 21.
[ Appl. PF 4.1.16).
4.1.5 The Board finds that CON Bus Route No. 4 is inadequate for expediting the retrieval of transit dependent persons.
This is also a perimeter route which circles the north end and south end population centers with no cross over or neighborhood pick ups.
Buses are supposed to travel through the intersection of Merrimac Street, Moseley Avenue, and Spofford Street, a busy intersection with no TCP, as well as the High Street, Storey Avenue and Moseley Avenue intersection.
O'Connor Dir. ff. Tr. 16458 at 22.
[ Appl PF 4.1.16).
4.1.6 The Board finds that CON Bus Route No. 5 is inadequate for expediting the retrieval of transit dependent persons.
It fails to serve densely populated areas, and passes through busy intersections which have inadequate or 14
I no traffic control.
O'Connor Dir. ff. Tr. 16458 at 22.
(Appl. PF 4.1.16).
4.1.7 The Board finds that the CON transfer point if l
unsuitable as a transfer point.
The open area on the site is estimated at 25,000-30,000 square feet, much cf which is covered by equipment and other debris, which is a limited space for persons to gather.
The area is diminished further when buses enter the area.
Areas to disembark the buses, and clearance for turning radius and unencumbered access significantly reduce the already limited standing space in the open area.
There is poor turning access for buses coming into and out of this staging area.
Bus drivers who are not familiar with the area and must rely simply on SPMC maps and diagrams will have difficulty locating the site.
The transfer point is located in a densely populated neighborhood where residences are built close to the street.
Water Street is a narrow street, especially by the transfer point at the intersection of Charles, Franklin, and Salem Streets.
There is only one point of entrance or exit from the transfer point.
The bus turns into and out of the transfer point will be extremely difficult, if not impossible, given heavy traffic on Water Street, and there are no TCP's or traffic guides on Water Street to regulate traffic flows or assist in the dispatch of buses into and out of the transfer point.
O'Connor Dir. ff. Tr. 16458 at 23 - 24; Gaines Dir. ff. Tr. 16552 at 4 - 5.
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- 4'. 1. 8 In addition,.the site is within the City's
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designated flood plain because of its proximity to the
.Merrimac-River and the tidal basin, its elevation, and its traditional' susceptibility to flooding especially during and after storms and high tides.
This area is designated as an A2 zone which means it is within the 100 year flood plain on' the official Federal Emergency Management Agency'(FEMA)
Flood Insurance Rate Map (" FIRM")..The elevation hbove mean sea level is listed at only nine. feet.
The Merrimac River at this point is tidal.
The site floods on an average of once every three to four years, usually in conjunction with
- high tides in combination with storms.
Gaines, Dir. ff. Tr.
16552 at 3; Tr.-16591; 16600-601.
[ Appl. PF 4.1.6, 4.1.7.
4.3 Conclusions 4.3.1 The-Board concludes that the bus routes and transfer station for CON are inadequate for the evacuation of transit dependent persons.
Respectfully submitted, t
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{~M A7
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3 B'ahbara J Saint Andre
Kopelman nd Paige, P.C.
77 Frank in Street Boston, MA 02110 (617)451-0750 I
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