ML20094B013

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Application for Issuance of Subpoena Directing J Waters to Testify Re Offsite Emergency Planning Contentions on Traffic Congestion in Vicinity of Valley Forge Natl Park. Certificate of Svc Encl.Related Correspondence
ML20094B013
Person / Time
Site: Limerick  Constellation icon.png
Issue date: 11/02/1984
From: Zitzer P
LIMERICK ECOLOGY ACTION, INC.
To:
Atomic Safety and Licensing Board Panel
Shared Package
ML20094A993 List:
References
OL, NUDOCS 8411060630
Download: ML20094B013 (36)
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Text

Subpoena roguented: LEA-24 c, ., John Watern UNITED STATES' NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

PHILADELPHIA ELECTRIC COMPANY ) Docket No. 50-352 (Limerick Generating Station, ) 50-353 Units 1 and 2) )

November 2, 1984 Request of Limerick Ecology Action for issuance of a subpoena to obtain the testimony of Mr. John Waters, Fire Marshall and Municipal Emergency Coordinator for Upper Merion Township on off-site emergency planning contentions on the issue of traffic congestion in l

in the vicinity of Valley Forge National Park, King '

of Prussia area (Contention LEA-24/F0E-1)

Pursuant to 10 CFR g2.720, Limerick Ecology Action hereby requests the Atomic Safety and Licensing Board in the above captioned proceeding to issue a subpoena to:

Mr. John Waters 175 West Valley Forge Road King of Prussia, Pa. 19406 (215-265-2600) requesting Mr. Waters to appear at the United States Customs Court House, Second and Chestnut Streets (Room 300) in Philadelphia, Pennsylvania on November 27th., 1984 at 9:00 a.m.

and to be on 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> phone alert standby every day thereafter until called to testify on behalf of Limerick Ecology Action and Friends of the Earth on the subject matter of contention LEA-24/F0E-1, which. states:

"There is no assurance that plans for evacuation of the 10 mile radius (EPZ) will not be impeded by traffic congestion in the vicinity of Marsh Creek State Park, Exton area (invol-ving Route 100) and Valley Forge Park, King of Prussia area.

These areas should either be included in the Emergency Plan-ning Zone or adequate plans for traffic control and direction should be made to avoid adverse effects on EPZ evacuation."

LEA 0FFERING OF PROOF Mr. Waters is the Fire Marshall and Emergency Coordinator for Upper Merion Township. Robert Anthony of Friends of the Earth has discussed this matter with him, and has informed LEA that Mr.

Waters has participated in state emergency planning meetings on Limerick. According to Mr. Anthony, Mr. Waters stated that although no consideration has been given to evacuation plans for Upper Merion Twp., he believes that residents will spontaneously evacuate in the event of a radiological emergency at Limerick.

Additional concerns have been raised about the fact that there will be supplemental buses and ambulances coming into the township 8411060630 841102 PDR ADOCK 05000352 G PDR

l A. o in the vicinity of the King of Prussia Mall, which is a transpor-8 tation and central resource staging area for the Montgomery County EPZ.

Mr. Waters has knowledge of traffic conditions in Upper Merion Township, particularly as would effect emergency operations and evacuation by the EPZ population passing through Upper Merion Township. His judgement and experience will influence any action planned or taken by Upper Merion Township in response to traffic congestion resulting from spontaneous evacuation, and as a result will to a large extent determine the workability of proposed EPZ evacuation routes passing through the township.

The specific roads in question are Route 363 (especially in the vicinity of the Betzwood Bridge), Routes 202, 76 (Pa. Turnpike),

and 276 (Schuylkill Expressway).

In addition, Upper Merion Township has commissioned a " Township-wide Traffic Study" to be prepared by the Simpson Division of Booz-Allen & Hamilton, Inc. The Phase 1-Township Overview, Interim Report has been provided as an LEA Exhibit included in this filing with materials relating to contention LEA-24 LEA provided the parties with supplemental discovery information relating to the Upper Merion Study with its Sept. 6, 1984 filing that contained the respecification of admitted emergency planning contentions.

Mr. Anthony obtained a copy of the report on Nov. 2, 1984. On page 1 the report states that the Pennsylvania Turnpike, the Schuylkill Expressway and Route 202 all experience greater than capacity volumes on their segments through the Township. The Interim Report goes on to systematically identify and pricritize traffic problems through the Township, and to recommend transportation improvements based on thorough analysis of top-ranking problem areas. Page 2 states that ...." Upper Merion's arterial and collector streets also experience traffic problems: traffic on some of these roads has more than doubled in the past 10 years, and many inter-sections operate at levels far beyond efficient capacity."

Mr. Anthony has contacted Mr. Waters to try to obtain information and testimony from him regarding this matter. Mr. Anthony prepared a list of questions to be used for the preparation of testimony for this proceeding. Mr. Waters has informed Mr. Anthony that he has answered the questions as requested, but has been advised by the Upper Merion Township Solicitor not to release the information unless a subpoena is issued by the Atomic Safety and Licensing Board requesting his testimony. Therefore, LEA hereby requests that a subpoena be approved by this Board and issued to Mr. Waters for the purposes of obtaining his testimony on contention LEA-24/F0E-1.

LEA is willing to provide any additional information that the Board may desire in regard to this request if necessary to obtain the subpoena.

Si rely, '

P yll s Zit er LEA President cc: Service List Subpoena forms sent only to Board

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UPPER MERION TOWNSHIP TOWNSHIP-WIDE TRAFFIC STUDY l

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PHASE 1 - TOWNSHIP OVERVIEW l INTERIM REPORT ll l

!I prepared by

'Simpson & Curtin Division BOOZ ALLEN & HAMILTON INC. i JULY 6,1984 l

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. u TABLE OF CO!! TENTS l Page i

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1. INTRODUCTION l

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2. DATA COLLECTION l

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3. EXISTING CONDITIONS I

Traffic Volume and Congestion 6 10 ,

Traffic Accidents Public Transit 12 l h

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4. FUTURE DEVELOPMENT Proposed Private Developments 14  ;

Programmed Transportation Improvements 15

5. PROBLEM AREA PRIORITIZATION AND SELECTION 17 Prioritization and Selection Process 17 Upper Merion Traffic Problem Area Selection 20 APPENDIX A: PROBLEM AREA

SUMMARY

. . . FOLLOWING 20 f

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. 11 LIST OF EXHIBITS t

Exhibit Following No. Page 1 Upper Merion Township Major Routes and Roads 6 2 '

Existing Average Daily Traffic Volumes 7 3 Morning Peak Hour Traffic Volumes 7 4 Afternoon Peak Hour Traffic Volumes 7 5 Annualized Traffic Growth Rates 7 6 Levels of Service for Signalized Intersections 8 7 -Level of Service Summary Map 9 8 Traffic Accidents (January through May 1984) 10 9 Transit Routes 12 10 Potential Traffic Generators 15 11 Projected Traffic Generation at Proposed Developments 15 12 Potential Traffic Improvements 16 l

13 Proposed Traffic Improvements 16 14 Traffic Problem Identification Matrix 17 15 Intersection Conditions Summary Table 20 16 Intersection Traffic Conditions Summary Map 20 ii -

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1. INTRODUCTION .i l

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This interim report 1s aimed at identifying and prioritiz- l' ing traf fic problem sites in Upper Merion Township. It con- ,  !.

v tains the documentation of the Township overview tasks. Fol-I j

lowing a discussion of findings and recommendations with j Township of ficials (and some possible adjustments to the list j of problem sites for further analysis), the second phase of the study, the Traffic Improvement Program, will begin.

Unlike other recent traffic studies in Upper Merion Town-ship, this study ekamines traffic conditions and needs for the Township as a whole, rather than for a small area around a specific proposed development. By"taking this broad perspec .-

tive, . the + Township hans .,besta.. guarantee

- - ~ -

, that m;e tra,nsporta,

v. .> s. tion improvements" are coordinated, ;: ando that the greatest traf fic ,

problems achieve the highest, priority.

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'1 The study comes at .a time when pressures are high for i transportation imp roveme nts. Accessibility - -

the factor responsible for much of Upper Merion's tremendous growth - - l l

is approaching the point where it is more a liability than an asset. For more than 20 years, the Pennsylvania Turnpike, the Schuylkill Expressway," and Route 2202 made the Township an excellent location for commercial and retail development, and a convenient spot for residents. Today , . .all; . three of < these .

highway,s rexperience greater than capacity volumes . on their#

ctgments:cthecugh :the~ Township. Upper Merion's arterial and O

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collector, streets also experience traffic problems: i '

on some oi -- these roads has more than doubled in the past 10 l

years, an'd many intersections , operate at levels far beyond 3

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E" officient ? capacity. Moreover, accident rates on Township roads are'1 up 20 percent since 1981. , g

' , 4 The objectives of the study are to systematically identify ll$

and prioritize traffic problems throughout the Township, and l to recommend transportation iimprovements based on thorough analyses of top-ranking problem areas. This interim report .

documents the study team's efforts regarding the identifica- j g tior. and prioritization of problem areas. Following this l introduction, the report is in sections as described below:

. Section 2, Data Collection, describes the data e lements used in the review of Township traffic conditions;

. Section 3, Existino Conditions, defines the Town-ship's current traffic volumes, accident statis-tics, and transit service;

. Section 4, hiature Development, complements Sec- '

tion 3 by identifying pro- posed transportation .

improvements, and committed and potential -

Township developments; and

. Section 5, Problem Area Prioritization and Selec- l tion, presents an analysis of potential traffic problem areas, and our ranking of the areas according to selection criteria.

A listing of problems and deficiencies at specific, high rank-ing traffic problem locations is included in an appendix.

A presentation and review of these task efforts are ini-l tial steps of the phase two efforts. Input from the Township in the ' form of comments and the identification of any other i

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key problem areas is also being sought to complement the con-sultant work efforts. Where supplemental data collection efforts are necessary to better define or select problem areas, mechanisms for obtaining such data will be determined.

As such, the next steps of the study will be to refine the problem area statements so that all key locations are included.

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2. DATA COLLECTION  :

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l this study is on the Phase 2 The major emphasis or As efforts, development of a Traffic Improvement Program.

such, the study team sought to maximize the use of previously I Reports .

collected, pertinent data during the initial phase.

and observations made in connection with the numerous private l The and public development projects facilitated this effort.

full range of data elements used in this portion of the study  :

were obtained as follows:

I Average daily traffic data for most of the major roads through the Township were supplied by the Commission l

~

De laware - Valley Regional Planning (DVRPC).

The Pennsylvania Department of Trans-portation (PaDOT) office at St. Davids, and the Upper Merion Township Traffic Safety Unit sup-Traffic plied supplemental traffic mostly count data.

from 1982 to 1984 volumes- useil were a tcw cases, earlier counts were i counts. In  !

used, but with an adjustment to account for traf- l f ic growth.

i Peak hour turning movement counts were Township. available l for about 40 intersections in the J

Traffic impact studies for proposed developments, were the and t.ransportaton improvement reports Data col-main sources for this information. Associates for the lected by Orth-Rodgers &

Reconstruction Project were ScF'tylkill Expressway this study.

also made available and used in '

Township-initiated turning movement counts were Data l also available for 'a few intersections.

were only used f rom actual peak hour counts taken i since 1981.  !

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'N . Proposed private developments were identified from lists comp iled by the Montgomery County .

., ?. ? Planning Commission and by Upper Merion. The  :--

current use of development sites was determined

-Q from site observations and from 1980 aerial  :

,1 - ~ photographs obtained from DVRPC. Traffic impact -

projecting traffic to and from the o..' (' studies developments were available for some of the pro-

. f. '. # posed developments. Rates from the Institute of =

ig 1; ." Transportation Engineers Report " Trip Genera-tion", 1982 edition were used to estimate future _

"A 4- volumes where impact studies were unavailable.

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N.[ . Traffic accident data on roads within the Town-

,. J ," ship came from Upper Merion Police Department f}.y accident reports. The Township's Traffic Safety S. Unit provided detailed accident data covering the _

period January to May 1984. A total of 678 re-k.J ...n J' '. ported traffic accidents was considered.

.l d. . Projected transportation improvements came from Program for DVRPC's Transportation Improvement I((,

. fiscal years 1984, as amended through October 27,

%!/ 1983, and from various traffic impact studies VM where improvements at off-road sites were recom-mended. A list of proposed, temporary and per-w d. y manent improvements in relation to the Schuylkill -

2; ',' Expressway Reconstruction was also obtained from I ji# PaDOT. ,,

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?# . Pu blic transit information for general and para-s cs; transit service through Upper Merion was supplied

"d by the Montgomery County Platming Commission and

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by the Southeastern Authority (SEPTA).

Pennsylvania- Transportation

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From this information, the study team was able to develop p..

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a fairly comprehensive understanding of Township traffic con-

, ' ~.' ditions, and of factors which could affect those conditions in t W. the future.

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3. EXISTING CONDITIONS J
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Upper Merion Township is well traversed by state highways g-

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which provide major access routes within one mile of all Town- j ship destinations. The Pennsylvania Turnpike and three major i

.j state highways - - the Schuylkill Expressway (I-76), Route '

f 202, and the County Line Expressway - - serve local origins or destinations, but primarily carry interregional traffic pass-i ing through the Township. N l 3 i

About 25 otheb roads serve the Township as arterials or  ; ;3 collectors with a wide range of traffic uses. The major roads through Upper Merion, including all state highways, are shown i in Exhibit 1. Those hoads on the Township system which serve I as major arterials are also presented. l  ![

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',0 Traffic.Volum'e and Congestion -J l

As would be expected, traffic volumes on Township roads  !

are largely a fungtion of interregional traffic and local 7, Octivity patterns. Follow ing the two expressways, the Turn- r pike and Route 202, the six Township roads with the highest f' average daily traf fic volumes are, in descending order. g 3

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i 1 i North Gulph Road u

26,200 1} 9 .

. South Gulph Road 20,500 ) 1

. West Valley Forge Rcad 17,800 1 1

. 3outh Henderson Road 16,200

. /irst; Avenue 14,600

. Conrad Drive ,14,300 The high count on North Gulph was made where the road abuts the Valley Forge Golf Course and puts the road segment tn the same range as , Route 2D2 .in terms ' of' number of vehicles i

corried. The high volume can be attributed to commercial

activity at the King of Prussia Industrial Park, the malls, and at offices on the east side of North Gulph. These~ traffic l generators are also major f actors in the high volumes found at ,

First Avenue, Conrad Drive, and other area roadways. Average ,

A daily, morning peak hour and evening peak hour traf fic volumes '

for key Tow nsh i'p. roads are presented respectively in Exhi-bits 2, 3, and 4. For the two peak hour periods, the total volumes passing through various intersections are also depicted. This graphically shows the magnitude of traffic passing through each intersection. .

The annualized rates of traffic growth experienced by 1

Township roads at periods between 1972 and 1984 are shown in Exhibit 5. On this exhibit, it is significant .to note that l

traffic volumes on all four of the major interregional high-wcys grew during this period, and that at least 14 of Upper Marion's other major roads grew - at annual rates higher than seven percent. This is a rate at which traffic volumes double every ten years. Roads which declined in traffic volume were '

mostly along the eastern edge of the Township by the Schuylkill River. The closing of the Allen Wood Steel Plant, and the general decline of other River area commercial and industrial activity is a probable cause.

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. u As indicated, intersection approach volumes are also shown on the peak hour maps, Exhibits 3 and 4. From a traffic ,

oporations perspective, the traffic volume passing through an intersection is normally more critical than the volume at a midblock location. Traffic congestion is more likely experi- -

onced where traf fic must stop for a signal or stop sign, than when it can otherwise flow freely in midblock. A road which narrows, such as at a bridge crossing, is a possible exception.

The degree of traffic congestion at an intersection can be ranked according to six letels of service, ranging from "A"

- free-flowing traffic, to "F" - forced movement. The six levels, as they apply to a signalized intersection, are more fully defined in Exhibit 6. The generally accepted industry (

standard is that intersections experiencing Levels of Service A, B, and C during peak hours are ~ acceptable, D is marginal, and E and F are unsuceptable.

Several quantitative methods exist for objectively deter-mining levels of s'ervice at signal-controlled and stop sign-controlled intersections. For this initial intersection  ;

screen.ing a frequently used method involving the identifica-  ;

tien of an intersection's "c'ritical -lane volumes" (based on through traffic, turning movements, intersection configura- ,

tions, and signal phasing) was used to estimate existing j levels of service. This procedure is described in Transporta- '

tion Re search Board Circular 212, " Interim Materials on High-

  • way Capacity". l The critical lane approach was used to calculate levels of g service at those intersections where turning movement counts j were available. These intersections are located along major {

Township roads and are, therefore, likely candidates to be i

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. u EXHIBIT 6 I

LEVELS OF SERVICE FOR SIGNALIZED INTERSECTIONS i

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. Level of Service A - Typically, the intersection ap- j proaches appear quite open, turning movements are easily )

made, and nearly all drivers find freedom of operation, -

their only concern being the chance that the light will be i red, or turn red, as they approach. No approach phase is fully utilized by traffic and no vehicle waits longer than one red indication.

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. Level of Service B - An occasional approach phase is fully utilized and some are approaching full use.

Level of Service C -

Occasionally, drivers may have to  !

wait through more than one ced signal indication, and queues may develop behind turning vehicles. Most drivers feel somewhat~ restricted, but not objectionably so. This is the level of service typically associated with design practice, although many urban areas accept level of ser-vice D as a standard. >

. Level of S e r v i c e' D -

Delays to approaching vehicles may  !

f occur during short perfods within the peak hour, but j enough cycles with lower demand occur to permit periodic j clearances of developing queues, thus preventing excessive backups.

. Level of Service E -

Maximum capacity occurs at this level. It represents the largest number of vehicles that i any particular intersection can accommodate. At capacity, j there may be queues of vehicles waiting upstream of the -

intersection and delays may be great (up to several signal .

cycles). l

. Level of Service F -

This level represents jammed condi- '

tions. The intersection operates erratically under forced flow and maximum congestion exists. l 2

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Il experiencing unacceptable or marginal levels of service.

Other intersections were also identified as possibly having  !

poor levels of service, but the lack of turning movement counts precluded a quantitative analysis. From observations of peak hour conditions at these intersections, a very conser- 4 vative estimation of levels of service was made; unless an intersection had clearly acceptable or clearly unacceptable i l

conditions, it was considered to have a marginal level of ser-vice.

l A summary map in Exhibit 7 shows the results of the level  !

of service analysis for those intersections examined at either the morning or evening peak hour, whichever is worse. This shows the intersections as either acceptable (Level A, B, or C), marginal (Level D) or unacceptable (Level E or F).  !

I The bulk of 'the Township's major congestion problems are along Route 202, North ~and South Guiph Roads, and at intersec-tions. .by . the. . King . of . . Prussia Industrial Park. Other spots identified as having poor level of service conditions include: I I .

. Goddard at Wills  !

Wills at Allendale l

. Keebler at Valley Forge  !

. Henderson at Church

. Church at. Crooked

. King of Prussia at^Croton South Warner at Croton

. Goddard'at Court.

Congestion at these locations was determined from lev-l of l

service analyses where data were available and from supplemen-tal field observations.

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these improvements are likely to have been planned several years ago and address a critical traffic needs. However, the availability of limited public funds restricts the number of projects which can be scheduled at any given time. The siz- j able allotment of funds to the Schuylkill Expressway recon-struction project over the next few years imposes another con- ,

i straint on how many other projects can be publicly 'unded.  !,

Major publicly funded transportation improvement projects a progranened for the next four years as well as other improve- I; ments under review for private developer implementation are ;j i listed in Exhibit 12 and mapped in Exhibit 13. These latter improvements are those required of developers to insure ade- l! '

quate site access and traffic flow through adjacent intersec-tions. Tnese are a result of the Township's zoning and site plan approval , processes , PaDOT's highway access and other  ;

reviews. ,,

While developer contributions are negotiated on a site-by-site basis ;and are dependent upon a developer's con-struction schedule, the Township is moving towards formalizing i a highway improvement fund. This would specify the developer's share of of f-site imp rovement costs and more im- c, portantly provide a mechanism for Upper Merion to fund highway (

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l S. PROBLEM AREA PRIORITIZATION AND SELECTION Phase 2 of the Township-wide Traffic Study will involve the development of recommendations to improve conditions at

cpecific traffic problem areas. To ensure that the most cri-tical problem area 5 are addressed, a prioritization and selec-tion process was developed. The process involves the selec.-

tion of locations based on four dif ferently weighted criteria, and the ranking of results to permit prioritization. The i mechanisms of the process and the application to Upper Merion traffic locations are, described below. ,

Prioritization anu Selection Process E

The primary tool used in this process is the Traffic Prob-lem Identification Matrix.- This matrix, presented in Exhi- i bit 14, graphically portrays the relationship of the four criteria used in determining the traffic problem locations.

4 These criteria, representing both existing and future traffic conditions are deccribed below. l l

. Level of Service -

Industry standards are the basis for evaluating traffic congestion condi- _

tions. Peak hour levels of service are rated as follows.

Acceptable "A", "B", or "C" Marginal "D" l -

Unacceptable "E" or "F" l

-*-' -- --.,,c.---.,- - - - , ,,,_ .__,,_ , __ _

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The level of service receives the heaviest weighting of the four criteria. All . traffic locations experiencing- unacceptable levels of service are automatically prescribed for Phase 2 a na ly's i~s . Most marginal level . of service loca-tions and some acceptable level of service loca-tions are also to be analyzed in Phase 2, depend-ing upon the presence of certain other traffic >

conditions. '

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. Accident Frequency - Lack of adequate traffic data prevents the calculation of accident rates at many intersections in designation of high, medium, and low accident the Township. The ll '

locations is, therefore, made on the basis of 1 accident frequency, or where' available on acci-dent rates, (i.e., accidents per million vehicle miles). Specifically, the designations are defined as follows:

Low -

less than five accidents between January and May 1984 Medium - 5 to 7 accidents High -

8 or more accidents, or locations I with more than three accidents per million vehicles t To match s tudy', aims , accidents are weighted slightly less than level of service in ranking traffic problem locations. However, similar con-ditions apply for determining whether a traffic location merits Phase 2 analysis. All locations with high levels of. accidents are to be evaluated in Phase 2, as are some medium ~ ano low accident depending upon other traffic conditions.

Traffic Volumes - Traf fic volumes, level of ser-vice. and accidents are all performance measures which independently describe characteristics and '

operation of intersections. Values for designat-ing traffic volumes into three categories were selected based on distributing the available data 4

into three general categories. As such, they are ,

I not an indication of the intersection's ability to accommodate the traffic volumes. However, {

l they:. ,do indicatq, those -locations - where traf fic improvements. would .. affect large numbers of ,

drivers.' The three categories are defined below.

Low - intersection peak hour traffic volumes of less than 1800 vehicles Medium - 1800 to 2800 vehicles High - More than 2800 vehicles While high traffic ' volumes are not, in them-selves, indications of traffic problems, they are useful in determining priority among two loca- i tions with relatively equal. levels of service and i numbers of accidents.

. Projected Traffic- Growth -

Traffic locations experiencing marginal or even acceptable traffic i conditions at present, may face deteriorating conditions in the future. This criterion re-flects the changes in traffic volumes prompted by regional growth and by specific proposed develop-ments. The actual anticipated traffic growth is not quantif.ied. Rather, roads and intersections are assigned a relative growth factor depending upon the degree of interregional traffic handled, and on projected nearby development. The three growth designations are as follows: I Low -~ average or no growth Medium - high growth i High - very high growth  !

This criterion does not address proposed tr a n-s -

portation improvements. Because of the

  • T.wi6 o' current transportation problems and t ras s: tx%: - <2 tainty of proposed developments, projected trei> r, fic growth is a low weighted factor.

Together, the four criteria permit a quantitative ranking of i

locations by overall traffic conditions. Moreover, they define the combinations of traffic conditions which warrant the Phase 2 analysis of traffic problem areas. On the matrix, r

_ _ _ . . . . . . L

_ - - - - ---__ - _ -_______________ - - - - - - - - ~ - _

f f ,

- if designated by those boxes below and to these conditions are Box 54,. for example (repre-the right of the diagonal line. low accidents, medium.  ;

service, conting marginal level of volume, and high growth), would be subject to Phase 2 a na ly-

, l' cis.

Box 63, with low volumes but otherwise similar condi-

'The lower i

tions, would not be selected for Phase 2 analysis. j the box number, the higher the priority of traffic problem  !-

The matrix is designed so that problem locations locations. 2 analysis.

falling in boxes 1 to 60 are selected for Phase  !

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Upper Marion Traffic Problem l Area Selection ,

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specific Township loca-A summary of traffic conditions at l tions is presented tabularly in Exhibit 15 and graphically the Town-in  ;

Exhibit 16.

As is ' evident from the two exhibits, t I

chip's unacceptable traffic conditilons industrial are along parkRoute and mall 202, i i

the North and South Gulph Roads, East' Church  !

arocs, and at certain ~1ntersections ' on Henderson, A narrative description of problems at and South Warner Road.  !

locations is provided in Appendix A. This appen-  !

unacceptable improvements for these dix also includes preliminary suggested  !

More definitive improvement programs for the un-locations. 2.  !

acceptehle locations will be developed in Phase l

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EXHIBIT 14 ,

TRAFFIC PROBLEM lDENTIFICATION MATRIX , l i

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i LEVEL OF SERVICE i

ACCEPTABLE MARGINAL UNACCEPTABLE  !

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$ 5 E' o 5 9 o 5 2 a w = a w = a w =

N%e 2 2 2 i i 81 79 76 72 67 61 54 46/ 3T' l LCW .

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3 80 77 73 68 62 50., 4T + 38: - . 29N j h$. #)5W M6 3

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78 74 69 63 S&r, 48 L, 3Bw; 30m 22:0 i HIGH , ,, $1 4GE Wiy ,("; -

ny x;,n >;y9 e w;:+ n$ {

f 64 400. 3bi 75 70 57m 44 23:e 1F tow "

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45 6 36W 280 21.9 15" : 10-w S+n 3-- 1 HIGH FM yifQg Cj 9, $ ,M'I;J +R - ;A 4 4.

.hn ve- c (x s$ ..  ; ; , v. - -

~ s . ,.

LEGEND j l

/ PH ASE 2 NO FURTHER s ANALYSIS ,, j # ANALYSIS 1.

)

iff EXHIBIT 15 INTERSECTION CONDITIONS

SUMMARY

TABLE  !

l 5 MONTH MAK  !

LEVEL OF PROJECTED

^CC DENTS H '

SERVICE GROWTH H OLUA1E TRAFFIC Q ACCEPTABLE O04 O <i800 O AVERAGE PROBLEM I Q MARGINAL Q 5-7 Q 1800 2800 Q HIGH RE 8

INTERSECTION CCEPTABLE $ fgAN 3 M L-10N VEHS.

INTERSECTION MEETING CRITERIA FOR PHASE 2 .

ANALYSIS:

l N. GULPH/C000ARO $ h h h I l N. GU LPH/GUTH RIE h h h h '1 H EN D ERSON/202 h h h h 2 N. GULPH/IST . e e e O 2

]

S. GULPH/202 e e e O 4 S. GULPH/ UPPER GULPH h $ h h 5 MOORE /VF RO.

~

he G e O "

GUTH RIE/DEKALB g h h g 12 S. GULPH/8ALLIG h h h h 17 202/ ALLEN 0 ALE G e e O is N. GU LPH/N. WA R N E R e O e e 22 G000AROMILLS G G G O 2s CHURCH /CROOKEO G e O G 27 ALLENDALE/IST G e O G 27 S.WARNE R/DEK ALB e O Q e ao '

S. WARNE R/ CONTIN ENTAL e O G e ao S. WAR NE R/HE R RING h h h h 30 N. WARNER /SWEDESFOR D h h h 33

.l ll

. if I EXHIBIT 15 INTERSECTION CONDITIONS

SUMMARY

TABLE (Continued) i LEVEL OF PROJECTED ACCIDENTS HOUR GROWTH SERVICE HISTO RY VOLUME TRAFFIC pa08 tem O ACCEPTABLE O 0-4 O <1800 O AVERAGE <

Q MARGINAL Q57 Q 1800.- 2800 Q HIGH CORE UN- I g ACCEPTABLE $ >8 OR MORE $ > 2800 $ VERY HIGH INTERSECTION THAN 3 MILL-10N VEHS. '

INTERSECTION MEETING CRITERIA FOR PHASE 2 ANALYSIS (Continued) _

WILLS / ALLEN 0 ALE G G O O 34 MATSON FOR O/MONTGO e O G G as S. GULPH/ SHOEMAKER e O G G 38 202/ KING'S CIRCLE G G G O 40 G000ARO/COU RT BLVO. G G G O 40 202/ TOWN CENTER

'O 4 e O 43 .-

202/G000ARD O e e O 43 i 202/LONG O G G O 4' HENDERSON/FV RD. O 9 G G S. GU LPH/ GYPSY e O G O 48 HENDERSON/ CHURCH e O G O 48 S. GU LPH/HO LSTEIN e O G O 47 l

IST/ MOORE h h h 48 -

202/8RAN0YWINE O G G O 52 G000AR0/CONRA0 0 9 O O 52 S. GULPH/HENDERSON O G O G 53 S. GU LPHICR00KE0 e O O O a S. WARNER /CROTON 9 O O O a l

l

- l EXHIBIT 15 INTERSECTION CONDITIONS

SUMMARY

TABLE (Continued)

^" PROJECTED LEVEL OF H UR ACC10ENTS GROWTH -

SERVICE VOLUME HISTORY TRAFFIC O ACCEPTABLE Oo4 O <isoo O Avea^Ge pA08tEu -

Q MARGINAL Q57 Q i800 2800 Q HIGH C RE 8

INTERSECTION CCEPTABLE $ fgAN 3 M L-

  • 10N VEHS.

NTERSECTION NOT MEET-NG CRITERIA FOR PHASE 2 MIALYSIS:

N.LENDALE/CROSSFIELO G O G G $2 E GULPH/ORCHAR D G O G O 87 L GULPH/CWEDELAND G O O G $8

i. GULPH/8 ROOKS G O O O 72

< CB u R/vFRO. g O o o 72 t GU LPHm. CHURCH g O O o 72 tGULFH/CROTON e O O O 72

( OF P/CROTON G' O. O O 72 i

LLLENDALE/KEEBLER O O G G 77 h0UDANN NOGE O O G O is (F RO./N. GULPH O O G O 7s uRD;8aDuR O O O e 80 WF R0]ALLENDALE O O O G so

'o 4LLENDALE/ELLIOT O O O G LEIOLER/HENDERSON O O O 9 so EULPH/MATSONFORD O O O G so

'o IIVER/SWEDELAND O O O G  !

puNTHituSWEDEuNO o O O Q so SWEDELAN0/ HOLSTEIN O O O G co cH U RCH/F u NT Hilt O O O O Si  !

CR0v0NmR00xS o O O O Si

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" LEA EXHIBIT "

p*rafc General Management Plan, Valley Forge National Park, Nov. 1981 Table 1. Park Visitor Day Use (Typical Peak Summer Month) g N -

1 Projected I Total  % of  % Change Annual Con tacts Total From 1978 Visits g =-

Activity 1978 1978 1979 9

1980 (1981) g 4.

g Observation Tower Use 24,620 5.2 -6 - 37 107,649 Model Airciane Flying 3,150 0.6 -58 - 17 16,820  ;

Horseback Riding 730 0.1 -23 + 63 6,728 Bicycling 5,685 1.2 [

-33 - 15 33,640 -

Dog Walking 1,653 0.3 +6 + 62 16,820 r-Jogging 3,241 0.6 +70 + 78 40,368 _?

Fishing 763 0.1 +42 + 92 10,092 Boating N t Bus Riding 813 11,205 0.1 2.5

+33

+73

+ 80

+195 10,092 225,391 y y Kite Flying 140 0 +58 +241 3,364 Picnicking 12,375 2.7 +2 +129 195,115 5 Visitor Center Use 25,318 5.3 +48 + 41 242,211 Betzwood Area Use 24,060 5.1 Pleasure Dr:ving 243,360 51.5

+21 + 38 228,755  :

-18 -

6 1,547,460 -

i Visits to His:oric Facilities 115,869 24.5 NA* NA* 824,191

, [

Total 472,982 100% 3,508,696 C

  • Not applica:le because certain historic sites have been removed from the y tour route. '
11c I I Visitation figures included in this section are based on several sources, -

the most cc lorehensive of which is the park's monthly public use report. _3  ;

Another sc rce includes a visitor use survey that was conducted during ~

the s umme'- of 1979 to provide data for this plan and to analyze a park -

bus transk system. Staff and planning team observations were also tapped for general visitation characteristics and trends.

The total s ciume of park-related use has greatly increased since 1975.

The comme- wealth of Pennsylvania estimated 1.7 million visits in 1975; there were 3.1 million visits in 1979 and 3.3 million in 1980. Traffic counts for '979 totaled over 11 million.

Of all tra";c through the park, 25 percent is estimated to be park visitors; c' this percentage, about 25 percent has historical interest.

The heavies visitation occurs from April thrcagh December, with peak concentraticms on holidays and weekends during special attractions such as fall colc and dogwood flowering , in 1978 during the peak period ,

there were soproximately 317,000 visitors per month compared with 93,000 visitors per month during the off-season (January-March). The 317,000 visitors per month is 11 percent of the theoretical capacity of the park's 25

g

]

1 i

. ..- l i

vehicle parking l spaces. <

Since the state a aco V -- N ~ES, th I

' bicentennial, and the park's recent national it.st s. -,'r visitation has_ increased dramatically. In 1W'i .ar "

rientet

ts wer-(

d-tallied at both Washington's headquarters and :ne .ase::- "'

Whereas week, nearly historically 40 oriented visitation is spreaa eveniv * - . . pout th.~

between 10:30 a.m. percent of all recreational use ccca . -

-. ee kend:

on Sundays. Almost and 3:30 p.m. on Saturdays and 1 :,g . ; i : 30 p .m these peak hours. On70 a percent of all Sunday - visits tav<- , 4:e durint e

typical peak Sunday, 90 percent ,- i visitor:

- use private automobiles; ~ the remainder use other forms of *-r .cortation 3 such as tour bus, horse, bicycle, or foot.

in 1979 therequired visitors) 25 percent of Sunday visitors with historical .c .s est (2,32.'

580 vehicle parking spaces at

. isnington':

headquarters, Memorial Chapel.the - visitor center, Varnum's quarters, arc o ashingto >

The remaining 75 percent of Sunday recreational interest (6,967 visitors) required 1,742 autos 1: :* 3marked  : ors witt a

outlying areas as well as major historic sites. >

At present the 1,333 parking spaces serving historic sites .s cars with a 30-minute turnover during peak hours. The ,old 241 16,00:

space:

serving recreation areas will hold 7,400 cars with a tur :ve minutes. every 4' the weekend Based on the visitor use survey, the typicai , erg r Of stay or of the historically oriented visitor is 7 - .es each a three sites; the visitor interested in weekena recreat::- s:a.s about 3' minutes at one site.

Total daily park capacity at the c - e t turnoves ,

rate is theoretically about 93,600 historical and recreat.cr a

  • .Ie visitors ,

4 Assumptions can be made about the various use patterns '

on visitors their proximity to the park and how frequently tnes . 's as .torsNationa basec 1

(those living more than 50 miles away ano rece ,g lodgint somewhere twice during in their thelifetime. vicinity) will visit infrequently, mayce :Piy once or I .

The full range of visitor ir.f: mation anc orientation, plus all interpretive facilities, picnic areas, anc ails, coult -

i' be used survey in association with seeing the historic resources. Tr e visitor us indicated and 33 percent were that 27 percent of the respondents were 'irst-timers

] .

of national or regional origin. .' me heavies percentage of national visitation occurs during summer montns.1 Regional visitors live from 25 to 50 miles away, which mears they mig seek accommodations in the area.

I several times a year though not as often as local users.

They would likely W s't the pari j would particularly attract regional visitors. R,ecial event .

i relatives from out of the region on subsequent visits.They might ec g friends or orientation, j regional visitors would likely concentrate Afte-

- their initia

! programs and historic resources of interest to them. The: nterpretive -

.se would be spreadprobably would more evenly engage in some recreational throughout the year than national visit: s, and thet 4

pursuits dur+; their visit 4

Local users live within a 25-mile radius of the park, the suburban Philadelphia area. a crity in the These visitors woulo use .e park for l historical would purposes visit the park more frequently about like their regional counterparts:  :*ever, the!

! for recreationa, .rposes. Tc j

26 p

'l continually reach this audience, interpretive programs would need to change witn time or be more specialized, e.g., seminars, lectures ,

themes.

. A

! General Development Existing Visitor Use Facilities.

facilities within the park. Table 2 inventories existing visitor use h

"The Plan, General Development" section, Table 4, which is included at the end of theb j shows a comparison of existing i and restrooms ) . proposed visitor use facilities (parking spaces, picnic tables, and .,

l Access / Circulation.

! transportation Various geographic barriers have forced the regior:al 9 routes through Valley Forge. The Pennsylvania Turnpike

( (I-76) and County Line Expressway (PA 363) are man-made barriers, all i

of which have limited access to the park. Over the years increased traffic from housing developments has importance. reinforced their utilitarian l

The primary mode of access to Valley Forge is by private vehicle. Local residents sometimes ride horseback, walk, or bicycle into the park. 6

! Direct access by public transportation is limited.

} Three state rou tes --23, 252, and 363--lie within the boundaries of the park. PA 23, south of the Schuylkill River, carries commercial and i commuter traffic. PA 252, on the western edge of the park, carries a ,

heavy volume of truck traffic between PA 23 and US 202. PA 363 serves as an extension of PA 23 and as access to the park from the east.

g--

Traffic at the Valley Creek Bridge exceeds 14,000 vehicles a day, with t-9,000 vehicles on PA 23, 4,000 on Gulph Road, and 1,200 on PA 252. =

! Peak hour volumes on 23 are at 7:00-8:00 a.m. and 4:00-5:00 approximately 1,000 vehicles per hour in both directions.

p.m. witn st c

At present PA 23 and PA 252 are important to both external l.- t through-traffic and to park visitation. Generally, park visitors tend to ~.

drive at or below the speed limit, whereas commercial and commuter h traffic often forces traffic flow to exceed posted speed limits. The intersection of these roads, which is at the bottom of a steep grade, is the main entrance to the park from the west.

conflict particularly when visitors are focusing This creates considerable on park than traffic. features rather

(

Much of the commercial and commuter traffic on PA 23 is between Phoenixville and the western fringes of Philadelphia, including King of Prussia.

a To alleviate traffic congestion on secondary roads in this area, %p

' four-lane now under contract. limited access expressway known as the Pottstown bypass is constructed later. The A spur from this route to Phoenixville will be Park Service also supports construction of access 4 ramps at Pawling Road. y reduce nonpark-related through-traffic These facilities combined on PA 23. should significantly L 27

  • M u.

n J. Environmental Assessment, Draft General Management Plan, June 1980 i Valley Forge National Historical Park p h\

~

j- " LEA EXHIBIT "

L h

'f .%

! park, carries a heavy volume of truck traffic and connects with PA .M '

i 23 m the north and US 202 to the south. PA 363 serves as an j cxtension of PA 23 and as a park access road from the east. *l i 7

I_

Traffic counts taken at the Valley Creek Bridge indicate a volume l

.; cxceeding 14,000 vehicles daily. The distribution of east-west  ;

9,000 vehicles on PA 23,

's traffic through the park is as follows:

p 4,000 on Gulph Road, and 1,200 on PA 252. Peak hour volumes on s 23 are at 7:00-8:00 a.m. and 4:00-5:00 p.m. with approximately

} c 1,000 vehicles per hour in both directions.

{

At present PA 23 and PA 252 are important to both external and 3

through-traffic movement and to park visitation. The commuter or i
commercial vehicle travelincj east or west on PA 23 has no i !
reasonable alternative but to pass through the park. Thus, the ,
visitor frequently finds vehicles crowding behind him, encouraging  ! y
him to proceed faster, and lessening his opportunity to enjoy the j g
The park visitor should observe Valley Forge at a slow, park. 1
unheeded pace. In contrast, commercial and commuter vehicles view 1 .. i T the park as the shortest route to their destinations and are in turn ,';

f 3

frustrated by the slow-moving park visitor. Generally, the park visitor tends to drive at the speed limit or less, but the pressure {,k

j ky

( of the commuter traffic sometimes forces traffic flow to exceed -

[ posted speed limits. All travelers must remain alert to avoid ,:

O

., potential accidents.  ;

. JP k One may enter Valley Forge National Historical Park at Washington's '

Td 2 headquarters at th'e western end, at the visitor c?nter at the 8

$ castern end, or indirectly from the south on PA 252, Yellow lih$

l- Springs Road, or Gulph Road. The park is crisscrossed by a 3 network of roads that ultimately connect to major transportation .. rb;*g 1 arteries. The variety of park entrances and the abundance of l internally penetrating roads make it relatively easy for external  !! 3 j traffic to cut through the park from any direction, using minor roads as shortcuts to the arteries, U $

). p!

, .J The intersection of PA 23 and PA 252 at the western entrance to . !4 ,

3 the park creates considerable conflict between commuter traffic east ' [1MI

] and west on PA 23 and heavy truck traffic' traveling north and {#;

i south on PA 252. To compound this problem, the intersection lies  %

at the bottom of a steep grade and is also a visitor entrance /

N M

intersection in traveling to Washington's headquarters, a heavily visited attraction in the park.

h..

Immediately to the southeast of the park the Schuylkill Expressway l; and the Pennsylvania Turnpike converge. Traffic from this location g];

j is routed up PA 363 past the Upper Merion industrial / commercial ,,

development to the eastern entrance of the park. At this major l.

( intersection PA 363 joins PA 23, and Outer Line Defense Drive joins ]'}

[ Valley Forge Road. Commuters on PA 363 and Valley Forge Road xg

'(; **e;

, 61 c

.r '

W4 w

3 $

Ei r

p.

4 usually continue north to PA 23. The visitor, however, must D make a dangerous left turn into the park across the path of heavy commuter traffic.

M Another transportation facility in Valley Forge is the one-lane' .a 1

Betzwood Bridge across the Schuylkill River. This dilapidated but j.[, picturesque bridge handles one-way traffic from the Betzwood picnic 2.p and boat launch area. The Knox Covered Bridge, which crosses

%'A .o-Valley Creek, is also one lane but serves two-way traffic. The M bridge, a historic structure, is the property of the Pennsylvania 9 Department of Transportation and is in some danger of destruction from flooding of Valley Creek. Two other bridges span Valley guk Creek:

M One carries PA 23 traffic near Washington's headquarters ns and appears adequate; the other serves very limited utilitarian traffic between Lafayette's quarters and Yellow Springs Road, i

b.'. Se 4 Two railroad lines pass through the park. The Reading Railroad ijni line follows the south side of the Schuylkill River, .and trains stop g at the Valley Forge Park train station. The station has recently C.

  • been renovated, and the parking lot has been improved. A former i&T station located near Washington's headquarters is no longer a scheduled stop along the Reading route.

4 1 3f in 1976, SEPTA initiated increased train service to the Valley Forge Fl station from central city Philadelphia for a period of three months. ,

?

do;g ' The state park also initiated fringe parking at the Valley Forge Idoa Service Plaza of the Pennsylvania Turnpike System, with shuttle bus service into the park. Although this has not been repeated, Vol!

.Sw trains stop at the Valley Forge Park train station every day.

5,ud

'1. #

  • Another railroad, the Penn Central, is located immediately north of

.h the park and serves industrial areas.

kic.f ip r

Because of the large area covered by the park and the nature and

'gj placement of historical exhibits, it is essential that vehicles be used in touring the park. The circulation of vehicles, ease of the

  • 5 visitor to guice himself, safety of the route, and interpretation of '

esto ad the park are all critical factors to internal traffic flow. Many P exhibits or points of interest are in full view from the road; consequently, distractions are common. Many of the two-way roads are narrow, steep, and curved. There are times when decisions must be made as to which route' to take or which attraction to visit.

Many routes are deceiving and disorienting, and the visitor is frequently confused by the abundance of alternate paths and may even miss a portion of the park unintentionally. Routes such as 23 and 252 are extremely hazardous to cross because of heavy traffic.

Numerous internal roads are frequently used as shortcuts to arrive at either end of the park. Some routes tend to destroy the 7 interpretive and aesthetic value of park sites. Traffic along Gulph and Baptist roads crosses through the Grand Parade grounds; I)1 , . . .

62 g

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, L.[ v~ $ ,_

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$,ER'TIFICATE'0F SERVICE I-hereby certify that I have served Limerick Ecology Action's testimony on admitted of f-site emergency planning contentions

')' g and request for subpoenas for witnesses to all parties on the service list below this 2nd. day of November, 1984 by deposit in the United States Mail, postage prepaid, expect for those parties marked (*) who were served by hand on Nov. 2, 1984.

\

(e) Chairwoman Helen Hoyt , (2) ( *). Nathene Wrigh t , Eso.

Administrative J u'd g e Office of the Executive Legal Director U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, DC 20555 Washington, DC 20555  :

(*) Benjamin Vogler, Esq.

4*) Dr. Richard F. Cole Office of the Executive Legal Director-Administrative Judge U.S. . Nuclear Regulatory Commission U.S. Nuclear Regulatory

Washington, DC 20555 (*) Troy B. Conner, Jr., Esq.

Conner and Wetterhahn

(*) Dr. Jerry Harbour 1747 Pennsylvania Ave., NW Administrative Judge Washington, DC 20006 U.S. Nuclear Regulatory Commission (*) Philadelphia Electric Company Washington, DC 20555 Attn: Edward G. Bauer, Jr.

VP and General Counsel DocketingandServiceSectidn} , 2301 Market St.

Office of the Secretary Phila., PA 19101 U.S. Nuclear Regulatory Commission ~,

Thomas Gerusky, Director Washington, DC 20555 Bureau of Radiation Protection, DER 5th fl, Fulton Bank Bldg.

Atomic Safety and Third and Locust Sts.

Licensing Doard Panel Harrisburg, PA 17120 U.S. Nuclear Regulatory Commission (*) Spence W. Perry, Esq. Mike Hersch)

Washington, DC 20555 Associate General Coun(sel FEMA Atomic Safety and Room 840 Licensing Appeal Panel 500 C St., SW U.S. Nuclear Regulatory Washington, DC 20472 Commission Washington, DC 20555 (*) Zori Ferkin, Esq.

Governor's Energy Council P.O. Box 8010 1625 Front St.

Harrisburg, P' 11105

9 Jay M. Gutierrez, Esq. Robert Sugarman, Esq.

U.S. Nuclear Regulatory Commission Suaarman and Denworth Region 1 631 Park Ave. 101 Broad Street, 16th. Floor King of Prussia, PA 19406 Philadelphia, Pa. 19107 Director, PEMA (Ralph Hippert)

Basement, Transportation and Safety Building liarrisburg, PA 17120 Angus Love, , Esq./M7pt,g37 Cgy3) 107 East Main St Norristown, PA 19401 Robert Anthony 103 Vernon Lane Moylan, PA 19065 Martha W. Bush, Esq.

Kathryn S. Lewis, Esq. Timothy Campbell Solicitor's Office Chester County Dept.

City of Phil-adelphia f Emergency Services Municipal Services Building 14 East Biddle Street Phila., PA 19107 West Chester, Pa. 19380 November 2, 1984 Phy(fis Zitzer, LEA President L .__ _

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