ML20148H813
| ML20148H813 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/22/1988 |
| From: | Adler T MASSACHUSETTS, COMMONWEALTH OF |
| To: | Atomic Safety and Licensing Board Panel |
| Shared Package | |
| ML20148H773 | List: |
| References | |
| OL, NUDOCS 8801270310 | |
| Download: ML20148H813 (28) | |
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4' 00CKETED UNITED STATES OF AhfERICA USNRC NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD '33 g g M .'23 Before Administrative Judges: F#C Ivan W. Smith, Chairperson f0cx[ISFo 3fCRE7M Gustave A. Linenberger, Jr.
ggjg~Envict Dr. Jerry Harbour In the Matter of PUBLIC SERVICE COMPANY OF NEW Docket Nos.
HAMPSHIRE, ET AL. 50-443-444-OL (Seabrook Station, Units 1 and 2) (Off-site EP)
January 22,1988 REBUTTAL TESTIMONY OF DR. THOMAS J. ADLER ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETFS, CONCERNING VARIOUS MATTERS RAISED IN THE "ETE" CONTENTIONS Department of the Attomey General Commonwealth of Massachusetts One Ashbunon Place Boston, Massachusetts 02108-1698 (617) 727-1090
$gg12$0cck000 $3 T
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O I. IDENTIFICATION OF WITNESS i Q. What is your name and current occupation?
A. My name is 'Ihomas J. Adler and I am President of Resource Systems Group of Norwich, Vermont.
Q. Are your professional qualifications as set forth in the testimony and attachments filed on September 14,1987 in this case still accurate?
A. Yes, they are.
II. REBU'ITALTESTIMONY Q. Have you read and analyzed the testimony related to ETE issues filed in this case by Mr. Lieberman, s.Lal, and by Dr. Urbanik?
.A. Yes, I have.
Q. Were you, in addition, present at the hearings dudng the cross-examination of those witnesses?
A. Yes, I was.
Q. I would like to ask you several questions related to information presented in the J
applicants' pre filed testimony and in the hearing panel. First, was there any new information presented in the hearings by the applicants or others related to the staffing of Traffic Control Posts (TCP's) and Access Control Posts (ACP's)?
A. Yes, there was. Specifically, a time schedule for availability of New Hampshire State Police to staff these posts was described and a prioritization for the staffing of specific posts was detailed.
Q. Is the information presented consistent with the bases used Lr preparing the ETE runs contained in Volume 6 of the Plan and/or in the revised ETE's presented by the applicants in the hearings?
A. No, they are not. With the exception of limited sensitivity runs conducted on only
AdlerfRebuttal-Testimony- i 3
'one of the scenarios, all'of the ETE analyses presented in the Plan and in the ' testimony assumed that all ACP's and TCP's would be fully staffed at the time of the beach closing.- .The State Police data indicate, however, that only a small fraction of the needed pe rr onnel (13) would be available within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of the beach closing.
Q. . What effect would this delayed staffing have on ETE's?
A. It would lengthen both the ETE's' reported in Volume 6 and
- those contained in the applicants' testimony. Specifically, delayed staffin'g of the Rt. 51/I-95 TCP would delay the capacity enhancement of two-lane outbound flow across the I-95 overpass that results from the TCP staffing. This capacity enhancement is significant in that it effectively doubles the capacity of the critical bottleneck to the EPZ's evacuation.
In what is-described as a "sensitivity" run in the applicants' testimony, a 2-hour delay in establishment of the I-95/Rt. 51 TCP is shown.as lowering ETE's. This effect, however, results from changes in other variables untelated to staffing at this location. In effect, by changing these other variables, Mr. Lieberman sends fewer vehicles.through this i critical bottleneck. Specifically, this sensitivity run routes traffic south out of Hampton into Seabrook and Salisbury. This routing assumes that neither the TCP in Seabrook (staffed with local personnel) nor the TCP on Rt. lA in Hampton (a Priority 1 location at beach closing) will
-be staffed. It also assumes that significant numbers of individuals are willing to travel closer to the plent in order to evacuate. If any one of these assumptions is false, the results of delayed staffing at the I-95/Rt.-51 TCP will be to increase ETE's, not lower them as asserted in the applicants' testimony.
j Q. Do you see any additional problems related to delayed l staffing at this location?
A. Yes, I do. Two-lane outbound flow can be safely established only after opposing eastbound traffic on Route 51 is diverted at a TCP
'l in Exeter (F-EX-04). According to the N.H. State Police Manning Sequence
! for an evacuation of the entire EPZ in the summer season, that post will .
be staffed with the 22nd and 23nd personnel that become available; i.e., '
! at an unspecified time more than 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> after the beach closing. Until that post in Exeter is staffed, safe two-lane outbound flow along Rt. 51 I
is not possible.
- Q. Would other problems result from delayed staffing of Access ;
j Control Posts (ACP's)?
i 1- -- . - - - - , -. - , _ __ . _ - - - _ _ - -- - _ - -. ._.
Adler Rebutta! Testimony 4 A. Yes. The applicants assume that no additional through traffic beyond that present within the EPZ will enter the EPZ after the time of the beach closing. Without staffing at the ACP's there would be no warning discouraging through vehicles until the order-to-evacuate was broadcast; even that warning would be heard only by those drivers listening to a radio. If vehicles continue to flow into the EPZ for any significant amount of time after the beach closing message, these vehicles could interfere with the flow of evacuating traffic. For example, queues such as those that routinely form at the I-95 toll plazas during busy summer days could reduce the flow of evacuating traffic along on-ramps.
Q. Do the aglicants' direct testimony, revised analyses or the testimony of Dr.
Urbanik adequately address the effect of commuter flows on ETE7 A. No. Dr. Urbanik stated in his pre-filed testimony that (p.10) "...no additional consideration of background traffic is appropriate, beyond that considered in the KLD study." And yet, the evacuation times for the Seabrook EPZ were estimated using a traffic model that included directly only a small fraction of the possible commuter trips that would be generated during an evaceation.
Q. How many commuting trips would there be during an evacuation and how many of these were modeled in KLD's analyses?
A. The only commuter trips included in the model are those made by people who work in the EPZ, but live outside the EPZ. No commuter trips made by commuters who live within the EPZ were directly included. It is apparent, however, that KLD is and was aware of the potential
! volume of commuter traffic that will exist during an evacuation. De First Market Research survey j of 1,300 EPZ households conducted for KLD provided the following information:
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. from the households surveyed, there are 1,664 commuters (tabulation of columns l A18 to A21 of the KLD survey);
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- 1,592 of those commuters rely on cars either as drivers or passengers (tabulation of rows 4,5,6,7 of columns A18 to A21 of the KLD survey);
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Adler Rebunal Testimony 5
+ 1,112 of those commuters would return home before evacuating (tabulation of row 1 of columns A42 to A45 of the KLD survey);
- 207 of those commuters "don't know" whether they would return home (tabulation of row 3 of columns A42 to A45 of the KLD survey).
These data indicate that:
96% of the commuters rely on cars (1,592+1,664);
e 67% of the commuters would return home (1,112+1,664);
79% of the commuters might retum home ([1,112+207]+1,664).
This information can be expanded from the survey population to the EPZ population using the following information: 1,300 households were surveyed and there are 49,545 households in the EPZ (Vol. 6 p. 4-4). Thus, 63,400 EPZ residents commute (1,664*49,545+1,300);
60,900 residents commute in cars (63,400*96%);
40,800 residents would commute home (60,900*67%);
48,100 residents might commute home (60,900*79%).
Using KLD's commuter vehicle occupancy factor of 1.16 commuters per car yields the following results:
35,200 EPZ resident commuter trips home will occur;
- 41,500 EPZ resident commuter trips home might occur.
For the mid-week evacuation scenarios, when employment is at 100%, only the 24,200 commuter trips by people working in the EPZ but living outside the EPZ have been included. The 35,200 to 41,500 commuter trips by residents of the EPZ have not been included. Thus, the effect of 59% to 63% of the commuter vehicles has been left to the overly optimistic speculation of KLD.
O Adler Rebuttal Testimony . 6 Q. You said earlier that the effects of trip: by commuters who live within the EPZ have not been directly represented in the analyses. What do KLD's ETE analyses assume about these trips?
~A. He analyses include assumptions about when the evacuation occurs for households who rely on the vehicles used by retuming commuters. nese evacuation departure time distributions were generated assuming "commute home times" that exist under normal aftemoon peak hour conditions, his is based on an unsupported assumption about the comparability of normal commuter flow to evacuation scenario commuter flow. Mr. Lieberman states in his direct testimony that:
ne use of estimated return times for commuters under "normal circumstances" represents peak hour conditions when other commuters are occupying the roadways over the same time frame as those who are retuming to their homes within the EPZ. :
The very existence of a peak period of traffic during normal circumstances in the late afternoon reflects the fact that the majority of workers leave their places of work and enter the highway system within a narrow time frame. (p. 78-79)
Indeed, the Evacuation Plan does include the assumption that commuters will "enter the highway system within a narrow time frame." Volume 6 states (at p.4-9) that 95% of the commuting population willleave work within 30 minutes of the evacuation order. However, this hardly resembles "normal circumstances." Data from Social Data Analysts survey shows that, under normal conditions, only one-third of the EPZ's resident workers leave work in the afternoon peak i one-hour period (4:00 to 5:00 p.m.). Bus, "normal circumstances", defined by Mr. Lieberman as "peak hou: onditions", reflects a tmffic condition brought about by only 33% of the commuting
- populatice.@.itile t$$ Evacuati PI' n awimes that 95% of the commuting traffic will be generated during a 30 minute period. In raw numbers, the Evacuation Plan assumes that generating up to 39,400 commuter tripsi over a k minute period is comparable to generating 17,500 commuter i trips 2 during the normal rush hour. This is simply not a reasonable assumption.
1 41,500 possible commuter trips X 95% = 39,400 trips commuter trips j 2 60,900 commuters + 1.16 commuters / car X 33% - 17,500 commuter trips l
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Adl'or1 Rebuttal Testimony 6A
-By assuming that commuters return home earlier than could
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realistically be expected.-the KLD-analyses use trip generation. times
- for-evacuating' households that are shorter than will actually occur.
This has the effect of lowering ETE's, particularly'for winter scenario evacuations. In addition, because of the sudden surge of commuter-traffic, workers will not be able to reach home before heavy flows of evacuating traffic begin. As I will explain further, the effect of-this
. commuter traffic will be to increase ETE's for all scenarios.
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Adler RebuttalTestimony 7 To model the effects of the commuter traffic on evacuation capacity of the roads, KLD assumed that a 10% counterflow of commuter trips would exist and would result in lower two-way undivided road capacities. In determining whether this is a reasonable approach, it is important to observe that commuter trips fallinto one of three categories:
- 1) trips that flow opposite to the evacuating traffic;
- 2) trips that flow with the evacuating traffic; and
- 3) trips that flow across the evacuating traffic.
Commuter trips that flow opoosite to the evacuating traffic will have the effect of reducing the capacity of undivided roads due to ' frictional' interactions between lines of vehicles moving in opposite directions. This effect has been approximated in the evacuation traffic model by basing appropriate road capacities on an assumed 90% - 10% split of evacuating vs. retuming traffic.
Commuter trips that flow with the evacuating traffic will have the effect of reducing the amount of roadway capacity that can be used by evacuating traffic. This latter effect is not Included at allin the evacuation traffic model. Instead, commuters whose trips home originate towards the center of the EPZ and terminate at some point farther out (implying that they must travel home with the flow of evacuating traffic) are assumed to magically show up at their home to begin their evacuation trip, without ever interacting with the flow of evacuating traffic. Commuter trips that flow across the flow of evacuating traffic at crucial intersections in the EPZ will have the effect of reducing the effective amount of' green time' available to evacuating traffic, if the evacuating traffic is forced to
'give up time' to cross flows of commuter traffic. These emeial intersections have not been identified by KLD, nor have the effects of cross-flows of commuter traffic been included in the evacuation traffic model.
These effects hhve not been included in the applicants' analyses, and as I point out in my j pre-filed direct testimony, the potential effects on ETE's are substantial. Tne way to take these effects into account in an ETE analysis is to include these trips directly into the I DYNEV model.
l The work trips origins and destinations could be determined directly from the survey that was I
l conducted by Social Data Analysts for the Massachusetts Attorney General's Office. Without I
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Adler RebuttalTestimony 8 taking these steps, the applicants have not offered their "best effon" to calculate realistic ETE's.
Instead, they have provided an analysis that biases, to the low side, the effect of commuter traffic on ETE's. In my opinion, the failure by KLD to include the full effect of commuters in their analysis has seriously compromised the reliability of their ETE's. Based on the evidence concerning commuter traffic provided through these hearings, I cannot exclude the possibility that commuter traffic flows, if fully included in the KLD baseline analysis, would extend the ETE's by several hours.
Q. The applicants' prefiled testimony indicates that a "more accurate representation of through traffic" has now been introduced to the I DYNEV coding for the Seabrook EPZ. Did you review the coding to determine whether that was donc correctly?
A. Yes.
Q. What observations do you have on this revised approach?
A. De IDYNEV inputs to the evacuation model have been revised to include through trips on Interstates 95 and 495 at the beginning of the evacuation scenarios. Mr. Lieberman represents in his direct testimony that these 3,000 or so through trips always were included (p. 73) and that now "...a more accurate representation of through traffic (that is, external-extemal trips) along the Interstate Highways within the EPZ has been introduced into the input streams for the ,
IDYNEV model." (p. 40) In fact, those 3,000 through trips never were included in the original input stream. De additional 3,000 or so trips that Mr. Lieberman refers to on p. 73 of his testimony were not through trips at all Rather, they represent an amount of traffic pre loaded onto the road network to achieve an "input-output equilibrium" (p. 4-4 of the IDYNEV user's guide)
I prior to performing a simulation. In other words, the model assumes that there will be some amount of traffic spread across the entire road network at the beginning of a simulation. De initial amount of traffic is based on the inputs for the first time period of a simulation. So, roadways over which vehicles will travel in the first time period are pre-loaded with some initial amount of traffic.
This seems realistic, since the road network is never likely to be completely empty. However, the manner in which KLD added "...a more accurate representation of through traffic..." was to insert l
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Adler Rebutta! Testimony 9 a new first time period,in which trips are loaded only onto the Interstates. Thus, at the beginning of a simulation, the entire road network, with the exception of the Interstates, is completely empty.
Given that the total mileage ofI 95 in the EPZ is but a small fraction of the total roadway mileage in the EPZ, this "...more accurate representation..." is less accurate than the original runs which failed to include any through traffic at all. This, too, is not a "best effort" approach to obtaining n:alistic ETE's. Instead, KLD should have included all traffic that would exist at the start of an evacuation; especially, traffic on the beach area roads and through traffic on the Interstates.
Because the KLD revised analyses do not include all of these vehicles, nor the additional vehicles that will enter the area before the establishment of ACP's, the KLD ETE's are simply too low.
Q. Do you agree with the applicants' revised estimate of peak beach area vehicle population?
A. No. The applicants have prepared new "peak" beach-area parking estimates which are approximately 15% higher than those included in NHRERP Volume 6. In addition, these new estimates are only the number of cars which the applicants believe were likely to havebeen parked in this area at 2 p.m. on July 18,1987. This basis for estimation is an important departure from that used in Volume 6, in which the "parking capacity" is used to determine p eak parking accumulation. This parking capacity was measured in Volume 6 as a total of observed parked cars plus unoccupied spaces. In fact, Volume 6 argues that this is the appropriate methodology for the purpose of this plan, stating (p. 2-10):
It must be emphasized that these parking capacities limit the number of people who occupy the beach areas at anypoint in time (emphasis in original), The evacuation plan must consider the peak traffic that could occupy the beach area at any point in time (emphasis added).
Our pre-filed testimony (High, Befort, Adler) replicated the Volume 6 methodology using 1987 data and determined that the current beach area parking capacity is in excess of 39,000 vehicles.
Applicants' and NRC witnesses, when examined, have argued that the parking capacity count that we submitted is essentially irrelevant for two reasons:
Adler Rebuttal Testimony . 10
- 1) ne day used by the ap)licants, July 18,1987, represents either the highest or near the highest accumu ation of vehicles that could be expected in the beach area and thus estimates of parking capacity are not necessary (Lieberman); and
- 2) There are constraints on the influx capacity of the area that limit parking accumulation to levels below the 39,000 capacity that we estimated (Urbanik).
He basis for the first point, as described by Mr. Lieberman under cross-examination, is that press and area businesses reported very high attendance in the beach area on that day, and that generally it is assumed that a good Saturday in July is most likely to represent the largest seasonal attendance. In pre filed testimony, Mr. Lieberman implicitly argues that July 18,1987 is likely a peak day by noting, using data from HMM reports, that the "peak population" in 1983 occurred on Saturday, July 16 (i.e. a Saturday in mid July).
Q. Do you agree that July 18,1987 most likely was the day of peak pa-king accumulation in the Seabrook EPZ beach areas?
A. No. In fact, the HMM report to which reference is made indicates only that total daily traffic counted at 6 automatic counter stations peaked on July 16,1983. Dere is a fundamental and critically important difference between daily traffic levels and total vehicle accumulation in an area. Traffic counters can be used to measure net daily influx to an area which can then be summed across a season to determine total vehicle accumulation. However, when the daily peak traffic level occurs is not necessarily when total vehicle accumulation peaks. As an illustration of this concept, consider a sink or bathtub which is being filled with water from a spigot and which is being emptied at the same time by a leaky plug. The time when i the sink has the most water in it (i.e. the most cars parked in the Nach area), does not necessarily
- correspond to the time when water from the spigot is flowing the fastest (i.e. the traffic at a counter is highest). Rather, the amount of water in the sink is determined by the net inflow minus outflow, accumulated over time.
De HMM traffic count data, collected over the summers of 1982 and 1983 could, in theory, be used to detemiine the actual accumulation of vehicles in the Seabrook EPZ beach area s over the course of a full season. In practice, however, because of the inherent error rate of the
Adler RebuttalTestimony 11 recorder technology used (pneumatic tube-type), the accumulation of errors that occurs in that type of analysis obscures the actual trends 3. This can be seen in Figure 1, which is a graph showing the seasonal vehicle accumulation 4 data generated by HMM's pneumatic tube type counters. De trend indicated by these data is that net vehicle accumulation decreased over the course of the summer, a trend which cannot be true if 1983 was reasonably warm and sunny. Rese data come from those HMM data stations which define a "cordon" around the designated beach area. In fact, the continually growing net outflux shown is due to accumulated errors from the counters themselves.
It is possible, however, to determine with HMM's 1982 and 1983 data the daily net beach area inflow rates without the measurement errors confounding relevant comparisons.
Figures 2 and 3 show, for each day in the summers of 1982 and 1983: 1) the daily vehicle accumulation 5 on the lower line; and 2) the total traffic level 6 for the same day on the upper line.
The important thing to note on these graphs is that the days with the highest daily traffic levels do not generally correspond to the days with the highest daily accumulation; the former occur earlier in the season (early to mid July) and the latter occur later (late July to August). De periods of peak daily traffic likely correspond to the times when the day tripper population peaks. He periods of peak daily accumulation likely correspond to times when the populations of seasonal, weekly, and ovemight visitors peak. Since these peaks occur at different times and since day trippers comprise only approximately one half of the total beach visitor population (NHRERP Volume 6, p. 2-12),
these data show that the day with peak total accumulation is more likely to be in late July or August than it is to be in early to mid-July, as asserted by the applicants.
3 Pneumatic tubes sense changes in pressure caused by tires passinF over them. A passenger car should result in one such pressure "spikes" as the front tires pass over the tube and one spike as the rear tires pass over. Most counters thus simply divide the number of recorded pressure spikes by two to determine vehicle counts. However,if the tube is mis-alignea or a vehicle passes very slowly over the tube, three or four spikes may be recorded and the cotmt will be in error.
4 Defined as the sum, accumulated across the days of the season, of the number of vehicles entering the area minus the number leaving the area.
5
, Defined as the total daily inflow minus the total daily outflow for the ISB1 counter stations which form a cordon I around the designated beach areas.
6 Defined as the total daily traffic (inbound plus outbound) recorded at the IBBf counter stations which form a cordon around the designated beach areas.
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Adler RebuttalTestimony 12 Q. Given this uncertainty about when peak parking accumulation occurs, what should an ETE analysis assume?
A. . If the ETE analysis is to include a scenario which repitsents the highest likely accumulation of vehicles in the beach area (Scenario 1 "Beach area population at capacity" -
Volume 6, p.10 2), then, as asserted in Volume 6,"[t]he evacuation plan must consider the peak traffic that could occupy the beach area at any point in time." Since there has never been a rigorous effort undertaken to determine exactly or generally when the number of parked vehicles reaches its peak in the beach area, the only prudent approach is to use parking capacity as an indicator of maximum vehicle accumulation. This is the approach that is used in Volume 6, and the approach that we employed which indicated a beach area parkmg capacity of over 39,000 vehicles based on 1987 aerial photographs.
Q.- You mentioned earlier that Dr. Urbanik rejected the 39,000 vehicle estimate that you prepared. Would you please give your understanding of his objection and your response to that objection?
A. Dr. Urbanik, testifying on behalf of the NRC, indicated that it was unreasonable to assume that 39,000 vehicles could ever accumulate in the Seabrook EPZ beach areas because of two interrelated constraints; 1) the roads leading into and through the beach areas have capacity constraints which prevent an influx r:ite sufficient to accumulate 39,000 vehicles, and 2)in actual practice it is difficult to achieve a parking occupancy rate close to 100%.
To accumulate 39,000 vehicles in the beach area, it is necessary only for the roads to
! handle in one day the inbound day-trippers (which, as noted earlier, amount to only one-half of the
! total weekend beach population) plus some fraction of the overnight visitors. Some of the j overnight visitors stay in the area for the entire season, some stay for several weeks, some for a single week, and some for only a few days. Their arrivals are staggered over a sufficiently large number of weeks and days that the accumulation of 20,000 overnight visitors would not be constrained by roadway capacity. On Sundays, very few overnight visitors are likely to arrive to l
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J- - -s- s- - e _54-. .J & L m -e-Adler RebuttalTestimony 13 begin their stay in the beach area, so it would be necessary for only a little over one-half of the 39,000 (the "day-trippers" plus a small number of overnight visitors) to arrive during the morning J
and early aftemoon hours to reach an accumulated 39,000 vehicles.
Q. Is the roadway. capacity sufficient to handle an influx of approximately 20,000 day-trippers in the morning and early aftemoon hours of a single day?
A. We assert, confidently, that it is. The 1983 HMM data show, on peak days, gross influx rates into Hampton, Seabrook and Salisbury beaches alone equivalent to over 4200 vehicles / hour along the four major roads into the area (Rts.1 A cast into Salisbury,286 east into ,
Seabrook, $1 cast into Hampton, I A south into Hampton). Within this area, the data submitted in the High, Adler and Befon pre filed direct testimony show approximately 30,000 parking spaces.
To fill the day tripper half of these spaces (15,000) would take less than four hours of the six hours between 8AM and 2PM, at the observed peak inflow rates. Since there are at least five east-west roads serving the remaining 9,000 parking spaces (4,500 day trippers), highway capacity will similarly not constrain accumulation into these areas at a level below this estimated parking capacity.
Q. So you believe, based on a study of actual traffic observed traffic levels, that an accumulation of at least 39,000 vehicles is possible in the Seabrook EPZ beach areas?
A. Yes, certainly.
Q. Is the possible accumulation limited to below 39,000 vehicles because of the practical difficulty of realizing close to 100% occupancy of available parking spaces?
A. In many other contexts such as in decked parking garages and urban curbside areas, the continual tum-over of parking spaces, and the difficulty that motorists have in immediately
, finding the scattered vacancies that are created by that turnover, reduce actual achievable average J
occupancy levels of legal, marked spaces to below 100%. However, as is noted in the High, .
Adler and Befort pre-filed direct testimony, the 39,000 parking spaces counted in the Seabrook EPZ beach areas account for those that appear to be used regularly, but up to double that number of spaces could conceivably be used for parking. Given the prevalent practice of parking along 1
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- l Adler RebuualTestimony 14 j roadsides and in areas other than those officially designated for parking, the 39,000 spaces do not
- represent full capacity of the beach area in the same way that the capacity of a parking deck is defined. Therefore, on a busy beach day this number of spaces could be filled simultaneously..
Q. Are there any other reasons why the 39,000 vehicle estimate that you developed 1'
would be a more reasonable basis for ETE analysis than the revised estimate prepared by the applicants?
A. Yes. Even if the applicants' new methodology of counting only the cars present in the beach area on a "peak" day rather than estimating "a reasonable upper bound" to capacity (as in Volume 6)is accepted, the translation of this methodology to I DYNEV ETE analyses is flawed in ways that systematically underrepresent actual vehicle populations. First, as noted in the above discussion of how through traffic is represented in KLD's revised I DYNEV runs, the vehicles which are on the roads in the beach area (and which are excluded from the new vehicle counts) have been totally ignored in these new I DYNEV runs. The High, Adler and Befert pre filed direct testimony notes that over 2,100 vehicles were counted moving in traffic along roads in the beach area, and even the applicants noted nearly 1,500 moving vehicles in their Avis photos; yet these vehicles have been effectively excluded from KLD's revised analyses.
Q. But won't these vehicles be cleared from the area before substantial evacuation '
I flows begin?
A. No. The applicants' revised Scenario 1 ETE runs show congestion beginning 5 minutes after the beach closing and substantial congestion after 10 minutes, even without these j vehicles that are on the road at the minute of the beach closing.
j Q. In what other ways are the applicants' revised use of vehicle count data flawed?
j A. The applicants completely ignore vehicles which are hidden from vertical aerial photography such as in under-building parking areas and garages. Based on field observations taken in the area (see rebuttal testimony of Beverly Hollingworth and Thomas Moughan), we know now that there are in excess of 2,200 such spaces in the beach areas of the EPZ. Even if 10% of these vehicle spaces were unoccupied, almost 2,000 vehicles undetected in the KLD counts
Adler Rebuttal Testimony 15 would remain.
Q. Mr. Callendrello, representing the applicants, testified under cross-examination that
- he would use the Scenario 1 ETE (beach population at capacity) if an evacuation were ordered in the early evening of peak weekend day in the summer. Would this ETE accurately describe the -
evacuation as it would likely proceed at that time?
A. No. By early evening, the beach area vehicle population would be substantially smaller than the amount assumed in the Scenario I analyses. Much of the day-tripper population would have already left the beach area by early evening, and, correspondingly, the ETE for the remaining population would be substantially lower than the one calculated for Scenario 1.
Q. Which ETE from NHRERP Volume 6 or from the applicants' revised submissions should be applied to an evacuation which began in early evening?
A. There is no information provided in the relevant chapter of Volume 6 (chapter 10) or in the revised submissions which would help a decision-maker to select an accurate ETE for this situation. The beach area vehicle population varies widely throughout the summer season, among "peak" days and, importantly, even over the course of a single day, Rese variations are not described in Volume 6 in ways that could be used by decision makers to reliably determine the relevant vehicle population and the corresponding ETE. It is likely that the beach area vehicle population varies over the course of the summer from a low of 5,000 vehicles (very rough estimate) to a high of approximately 40,000 vehicles. For a summer weekend evacuation, the corresponding range in ETE's is from less than 6 hrs. to 9 hrs. 25 min., assuming all other parameters in the KLD analysis are left unchanged. Clearly, it is critically important for a decision-maker to have reasonably reliable information on beach vehicle population in order to reliably determine the ETE.
Q. What additional information should be provided in the NHRERP, then, to allow a decision-maker to reliably determine the ETE on a given day, at a given time on that day?
A. Two new sets ofinformation would be required, ne first would give data and general guidance for detemuning the likely beach-area vehicle population at a given point in time
Adler RebuttalTestimony 16 and the second would be a set of ETE's calculated for the full range oflikely beach area vehicle populations. Some information on the influx and outflux of beach area vehicles over the hours of a "peak" day is included in Volume 6, but these data are not sufficient nor in a form that is useful for this purpose. There are many ways that better information on vehicle population at a panicular point in time could be obtained for evacuation planning. The most accurate information could be obtained from a real time link with automatic traffic recorders located on each of the area's access roads. These could be located as in the HMM studies conducted in 1982 and 1983, but should have inductive loop detectors for greater accuracy and the data should be transferred either continuously or at regular intervals (e.g. by telemetry) to a centrally located microcomputer for storage and analysis. The result would be an accurate estimate of beach-area vehicle accumulation at any point in time.
There are other, less sophisticated, methods which could provide much better information on beach area vehicle pop'ilation than can be obtained from Volume 6 or from the applicants' revised submissions. For example, a table could be prepared that shows the percent variation in beach vehicles that occurs over the hours of, for example, a typical "good weather" summer day, a "mediocre weather" day and a typical "poor weather" day. In addition, estimates of maximum vehicle population could be prepared for selected typical days such as good / mediocre / poor weather weekday / weekend days in June / July / August. To illustrate, the time-of day table might indicate that, at a particular early evening hour, the vehicle population is typically at 60% of maximum and that the maximum beach population would be 25,000 vehicles. These two data would be used to 1 determine that the evacuating beach area population would be 15,000 vehicles (= .60 x 25,000).
As I mentioned earlier, there are many other methods intermediate between these two that could provide progressively better information oa actual vehicle populations present at a panicular point in time. Contemporaneous information on variables which serve as "indicators" of traffic influx could be maintained and these indicators could be statistically correlated to actual observed vehicle populations in past summers. For example,information on the numbers of vehicles admitted into each of the beach area state park parking lots could be maintained, and these could be
4 Adler Rebuttal Testimony 17 entered into a statistically-estimated equadon to calculate likely total beach area vehicle accumulation. Such a method could involve only a relatively modest effort including, initially, analysis of a dozen or so aerial overflights (35mm oblique-angle photography, counting only visible vehicles would be sufficient since we have already estimated the area's parking capacity) -
and developing a protocol for obtaining the state park vehicle admissions data at the onset of an emergency.
Of course,it would also be necessary to re structure the ETE tab!cs presented in Volume 6 so that that ETE's were shown for different beach area vehicle populations for the summer scenarios. Currently, the tables do provide for an evacuation of the entire EPZ (Region 1) a Scenario 1 A and IB ETE for 80% and 60% occupancy of beach area parking capacity. But, for Regions 2 to 9, only one ETE is provided for a summer weekend and one for a summer weekday, and each is for 100% of vehicle capacity. This is hardly enough information to be called a "best effort" approach.
Q. Would it also be imponant to accurately determine the number of workers who are in the EPZ at a given time, but who live outside?
A. Yes, this is an analogous issue. Currently, Volume 6 distinguishes between weekday and weekend conditions in terms of the worker population, but it does not identify the variations that occur across the hours of a day. For example, the number of such workers is much lower at 8PM than at 2PM on a given weekday. Fortunately, the worker population varies less significantly across different weekdays than does the beach population, so only an analogue of the "time-of-day factor" table would need to be prepared to adequately quantify these worker vehicles.
However, since the longest evacuation times occur on weekdays with commuter traffic (even ignoring the retum commuter effects discussed earlier), it is important that this factor be applied and that appropriately indexed ETE calculations are presented.
Q. 'Ihe applicants and Dr. Urbanik have suggested that identification checks at access control points be removed from the Plan. Does this relieve the concem that you have about potential delays and queues developing at these points?
- I Adler RebuttalTestimony 18 A. Only partially. Dr. Urbanik also stated that the location of cones and barricades ,
need not be altered at access control points. My pre filed direct testimony noted that the placement of barricades (as opposed to the cor,es used at other locations) at the access control points, as shown in the diagrams in Volume 6 Appendix L, either completely or substantially obstructs the flow of vehicles retuming to the EPZ (see, for example, diagrams GT-2, HA 4, NW-2, and KI 5).
The problem raised in my pre filed testimony that it is not possible to place the number of cones and barricades as shown in the diagrams without obstructing traffic has not been addressed at all, e Q. Mr. Lieberman suggested that average national traffic accident statistics be used to determine the likely number of traffic accidents to occur during an evacuation. Do you believe that this is an appropriate use of those statistics?
P A. No. In most respects, the operating conditions that are represented in these data are far more favorable than will exist during an evacuation of the Seabrook EPZ. As Dr. Cedar pointed out in the hearing, drivers will have high levels of frustration and will be beyond the normal limits of their ability to concentrate on driving tasks after the several hours of navigating through extreme congestion required to clear the EPZ Additionally, the numerous cones and I
barricades are placed in ways that do not erm conform to the minimum specifications for taper length in construction work zones, as specified in the MUTCD (Manual on Uniform Tragic !
ControlDevices, U. S. Federal Highway Administration). Since many of these are placed along arterials where vehicles will approach at speeds of 55-mph or greater (e.g. I 95), the importance of appropriate advanced waming/ taper areas to safe operations is amplified. At some locations, barricades are apparently intended to prevent head-on conflicts (e.g. TCP B-AM-06 Rt. I10/195, F-EX-04 Rt. 51/101C/101D) whereas at many locations such as at the ACP's, such barricades are apparently intended only as a warning against entering the EPZ. This lack of consistency is antithetical to the purposes of the MUTCD, which are to pmvide for "... orderly and predictable f movement of all traffic...." (p. I A 1). Given these relatively unfavorable operating conditions,it is likely that accident rates will be much higher during an evacuation than those experienced normally in the U. S. '
i r
Adler Rebuttal Testimony 19 Q. Mr. Lieberman suggested that the problem that you identified in your pre Gled testimony of evacuating traffic being routed the wrong way onto an interstate off ramp over a median at the I-95/Rt. I10 intersection was in part due to an ambiguously-drawn TCP diagram.
Do you agree?
A. No. The routing assumed in the I-DYNEV runs presented in Volume 6 and in the applicants' revised runs, which I have received and reviewed in detail, is that, as shown in the Volume 6 diagram, about one-half of the Rt. I10 traffic is routed onto I-95 via the legitimate on-ramp and about one-half is routed via this "wrong way" ramp.
Q. Two possible altematives to '.ne routing onto the I 95 off-ramp were suggested by Mr. Lieberman and Dr. Urbanik in the nearing. One is to simply have the Rt. I10 westbound vehicles continue past the ramp to an opening in the median and make a U turn to access the eastbound I-95 on-ramp. Would this routing be feasible?
A. No. The eastbound lanes of Rt. I10 are only 32 feet wide from curb to median and this provides insufficient room for a passenger car in the left lane westbound to make a U-turn into the eastbound lanes, let alone for a truck or camper to perform this maneuver (a "design" passenger car requires 48 feet of road width and a single un.t truck or small bus requires over 80 feet for a U-turn).
Q. The other routing suggestion made by Mr. Lieberman and Dr. Urbanik at the hearing was to direct traffic in the left lane of Rt. I10 to continue west to the I-495 on-ramp. Is this a workable solution?
A. No. The note at the bottom of the Volume 6 TCP diagram for this intersection suggests that traffic along Rt. I10 be permitted to continue eastbound to I-495 if the I-495 approach is not congested. However, this routing is contradictory to the evacuation routing instructions given in Volume 6 Appendix J, which direct all evacuees from Salisbury to go to a decontamination center in Peabody7 via I 95. A routing to this center along I-495 is not described in the Plan and is, at best, extremely circuitous Many,if not most, of the evacuating drivers 7
The Utility plan for Massachusens directs Salisbury direct evacuees to Beverly via I 95, causing the same problem.
-9 Adler Rebutta! Testinony 20 would find it so difficult to get to Peabody from westbound I-495 that they would be deterred from going there. If prudent plamastruly wanted this reception / decontamination center to be utilized by evacuees, they would not route evacuees onto westbound I-495. Further, it is unlikely that evacuating drivers approaching I 95 in the left lane of westbound Route 110 would be persuaded to continue west on Route 110 through unknown traffic conditions to I-495 when they are within seconds of accessing high-speed free flow traffic conditions on I 95 by merging right onto the I 95 southbound on ramp. This is the "tragedy-of the-commons" type of situation that was described in my pre filed direct testimony for the I-95/Rt.51 intersection. While it would be bette; for the overall evacuation (the "commons")if one-half of the drivers continued west past the I 95 intersection, each individual driver would be far better off immediately accessing the interstate and getting him/herself out of th: area more quickly.
I
Seasonal Vehicle Accumulation as Calculated from HMM Data Hampton, Seabrook and Salisbury Beaches 1983 m .
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Comparison of Roadway Traffic Levels and Daily Vehicle Accumulation Hampton, Seabrook and Salisbury Beaches 1982 100000 July 4 Weekend S
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Comparison of Roadway Traffic Levels and Daily Vehicle Accumulation Seabrook and Salisbury Beaches 1983 80000 -
saturday, July 16 Sunday, July 3 Saturday, July 23 70000 -
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Figure 3
i e-DOCKETED UNITED STATES OF. AMERICA NUCLEAR REGULATORY COMMISSION W m 26 N1:23 0FFICE Of !!CfiETAdY 00CKE11NG J. SERVICl:
BRAliCH
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In the Matter of )
)
PUBLIC SERVICE COMPANY OF NEW ) Docket No.(s) 50-443/444-OL HAMPSHIRE, ET AL. )
(Seabrook Station, Units 1 and 2) )
)
)
CERTIFICATE OF SERVICE I, Allan R. Pierce, hereby certify that on January 22, 1988, I made service of the within Rebuttal Testimony of Edwin J. Olivera, Rebuttal Testimony of Thomas F. Moughan and Rebuttal Testimony of Dr. Thomas J. Adler, by mailing copies thereof, postage prepaid, by first class mail to, or by Express Mail to those individuals as indicated by *, or by Hand Delivery as indicated by **:
Ivan Smith, Chairman Gustave A. Linenberger, Jr.
Atomic Safety & Licensing Board Atomic Safety & Licensing Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building East West Towers Building 4350 East West Highway 4350 East West Highway Bethesda, MD 20814 Bethesda, MD 20814 Dr. Jerry Harbour *Sherwin E. Turk, Esq.
Atomic Safety & Licensing Board Office of the Executive Legal U.S. Nuclear Regulatory Director Commission U.S. Nuclear Regulatory Commission East West Towers Building 15th Floor 4350 East West Highway 11555 Rockville Pike Bethesda, MD 20814 Rockville, MD 20852
- H. Joseph Flynn, Esq. Stephen E. Merrill Assistant General Counsel Attorney General Office of General Counsel George Dana Bisbee l Federal Emergency Management Assistant Attorney General i Agency Office of the Attorney General
( 500 C Street, S.W. 25 Capitol Street Nashington, DC 20472 Concord, NH 03301 i
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.1; Docketing and Service Paul A. Fritzsche, Esq.
U.S. Nuclear Regulatory' Office of the.Public Advocate
' Commission State House Station 112 Washington, DC. 20555 Augusta, ME 04333 Roberta C. Pevear Diana P. Randall State Representative 70 Collins Street Town'of Hampton Falls- Seabrook, NH 03874 Drinkwater Road Hampton Falls,'NH 03844 Atomic Safety & Licensing Robert A. Backus, Esq.
Appeal Board Panel Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106
- Atomic Safety _&_ Licensing Jane Doughty Board Panel Seacoast Anti-Pollution League U.S. Nuclear Regulatory 5 Market Street Commission Portsmouth, NH 03801 Washington, DC 20555 Paul McEachern, Esq. J. P. Nadeau Matthew T. Brock, Esq. Board of Selectmen Shaines & McEachern 10 Central Road 25 Maplewood Avenue Rye, NH 03870 P.O. Box 360 Portsmouth, NH 03801 Sandra Gavutis, Chairperson Calvin A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City Hall Rte. 107 126 Daniel Street E. Kingston, NH 03821 Portsmouth, NH 03801 Senator Gordon J. Humphrey Angelo Machiros, Chairman U.S. Senate Board of Selectmen Washington, DC 20510 25 High Road (Attn: Tom Burack) Newbury, MA 10950 Senator Gordon J. Humphrey Edward G. Molin 1 Eagle Square, Suite 507 Mayor Concord, NH 03301 City Hall (Attn: Herb Boynton) Newburyport, MA 01950 Donald E. Chick William Lord Town Manager Board of Selectmen Town of Exeter Town Hall 10 Front Street Friend Street Exeter, NH 03833 Amesbury, MA 01913
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Brentwood Board of Selectmen Gary W. Holmes, Esq.
R?D Dalton Road Holmes & Ellis1 Brentwood, NH 03833 47 Winnacunnet Road Hampton, NH 01841 Philip Anrens, Esq. Diane Curran, Esq.
Assistant Attorney General Harmon & Weiss-Department of the Attorney Suite.430 General 2001 S Street, N.W.
State House Station 46 Washington, DC 20009 Augusta, ME 04333
- Thomas G. Dignan, Esq. Richard A. Hampe, Esq.
R.K. Gad-III, Esq. Hampe & McNicholas Ropes & Gray 35 Pleasant Street 225 Franklin Street Concord, NH 03301 Boston, MA 02110 Beverly Hollingworth Edward A. Thomas 209 Winnacunnet Road Federal Emergency Management Hampton, NH 03842 Agency 442.J.W. McCormack (POCH)
Boston, MA 02109 William Armstrong Michael Santosuosso, Chairman Civil Defense Director Board of Selectmen Town of Exeter Jewell Street, RFD 2 10 Front Street South Hampton, NH 03827 .
Exeter, UH 03833 Robert Carrigg, Chairman Anne E. Goodman, Chairperson Board of Selectme. Board of Selectmen Town Office 13-15 Newmarket Road Atlantic Aver.ue Durham, NH 03824 North Hampton, NH 03862 Allen Lampert Sheldon J. Wolfe, Chairperson Civil Defense Director Atomic Safety and Licensing Town of Brentwood Board Panel 20 Franklin Street U.S. Nuclear Regulatory Exeter, NJ 03333 Commission Washington, DC 20555 Dr. Emmeth A. Luebke Charles P. Graham, Esq.
5500 Friendship Boulevard McKay, Murphy & Graham l Apartment 1923 Old Post Office Square Chevy Chase, MD 100 Main Street Amesbury, MA 01913 l
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3 Judith H.-Mizner,'Esq.
'Silvergate,1Gertner,. Baker, Fine , ' Good .&: .Mi::ne r p;c 83 Broad ~ Street.
Boston, MA- 02110-u .
Allan R. Fierce Assistiant Attorney General Nuclear Safety. Unit'.
Department of the' Attorney. General .
One Ashburton Place-Boston, MA 02108-1698 (617) 727-1090 Dated: January 22, 1988 P
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