ML20195H023

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Confirms General Agreement Reached as Result of Meetings W/ Berkowitz Re Surveillance of Nuclear Power Plants Operating in State of Nj.State Officials May Attend,As Observers,At NRC Enforcement Conferences & Meetings W/Licensees
ML20195H023
Person / Time
Site: Pilgrim
Issue date: 07/13/1987
From: Russell W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To: Dewling R
NEW JERSEY, STATE OF
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Download: ML20195H023 (17)


Text

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/g NUCLEAR REGULATORY COMMISSION

'4 REGION I 631 PARK AVENUC J

KING OF PRUS$lA. PENNSYLVANI A 19400

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\\.....f July 13, 1987 Richard T. Dewling, P.h.D.,'P.E.

Commissioner Department of Env'ironmental Protection 401 East State Street CN 402 Trenton, New Jersey 08625

Dear Commissioner Dewling:

c This letter is to confirm the general agreement reached as the rescit of our meetings with Dr. Berkowitz and his staff regarding the surveillance of th nuclear power plants operating in New Jersey.

that there was a need to have a more formal way of coordinating NRC and Stat" activities related to plant operations and that the Department of Environmental Protection's Bureau of Nuclear Engineering (BHE) will be the interface with the NRC on a day-to-day basis.

The areas addressed by th.is letter are:

State attendance at NRC meetings with licensees relative 1.

to licensee performance, including; enforcement conferences, plant inspections and licensing actions.

NRC and BNE exchanges of information regarding plant cone 2.

ditions or events that have the potential fcr or are of safety significance.

We agree that New Jersey officials' may attend, as observ Licensee Performance (SALP) reviews, with respect to nuclear power plants We shall give timely notification to operating in New Jersey (PSE&G, GPUN).the BNE of such meetings Although I do not expect such cases to arise frequently, we must reserve the right to close any enforcement conference that deals w

' gation by the NRC Office of Investigation (01), where the premature disclosure In such cases, vo of information could jeopardize effective regulatory action.

would brief you or your staf f after the enforcement conference and would l:

expect the State to maintain the confidentiality of the briefing.

With regard' to NRC inspections at nuc1 ear power plants in New Jersey, we agree

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Te the that the ONE staf f may accompany NRC inspectors to observe inspections.

extent practicable, NRC will advise the State suf ficiently in advance of our In inspections such that State inspectors can make arrangements to attend.

order to assure that those inspections are effective and meet our mutual needs, I suggest the fullowing guidelines:

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The State of New Jersey will make arrangements with the licensee to have New Jersey participants in NRC inspec-tions trained and badged at each nuclear plant for unescorted access in accordance with utility requirements, s

2.

The State will gi,ve NRC adequate piior notificacion when planning to accompany NRC inspectors on inspections.

3.

Prior to the release of HRC inspection reports, the State will exercise discretion in disclosing to the public its observations during inspections. When the conclusions or observations made by the New Jersey participants are sub-stantially different from those of the NRC inspectors, New Jersey will make their observations available in writing to the NRC and the licensee.

It is understood that these communications will become publicly asallable along with the N,RC inspection reports.

With regard to communications, we agree to the followir.g:

1.

The NRC shall transmit technical information to ENE relative to plants within New Jersey concerning operations, design, external events, etc.; for issues that eithcr have the potential for or are of safety significance, 2.

The NRC shall transmit all Preliminary Notifications rol:.ted to nuclear plant operations for New Jersey f acilities to the BNE routinely.

3.

The SNE shall communicate to the NRC any concerr. or :;uestion regsrding plant conditions or events, and any State ir. fort.wtien about raclear power plants.

Please let me know if these agreements are satisfactory to you.

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Origi:uil Sirned 17 WILLIAM T. RussgtL William T. Russell Regional Administ%ter

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THE COMMONWEALTH OF MASSACHUSETTS p.th )e; I n EXECUTIVE DAPARTMENT Q

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Ro8ERT J. BoVLAY MICH AEL s. DUKAKLs otatcfca oovtRNon September 18, 1987 Hr. Raloh Bird Senior Vice President Boston Edison Company 800 Boylston Street Boston, Massachusetts

Dear Mr. Bird:

My staff has reviewed the August, 1987 "Study to Identify Potential Shelters in EPZ Coastal Reolon of the Pilnrim Nuclear Power Station," which was prepared for you by Stone and Webster.

We find that this study is deficient in several resoects and that additional work is required to provide information to local officials which is sufficient to support develcoment of implementable shelter utilization plans.

I have attached a copy of a memorandum orepared by my staff which details our specific concerns regarding this study.

If you have any questions or observations reoarding our evaluation, please contact Buzz Hausner of my staff.

Thank you for your cooperation in this matter.

Sinc,

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obert ulay Director

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Assistant Secretary, Peter W.

Agens, Jr.

Deputy Director, John L. Lovering Mr. Buzz Hausner 1

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ATIi;k THE COMMONWEALTH OF M/.SSACHUSETTS

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EYECUtlVE DEPAf1TMENT 7.*

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no0Erli J. 00UL AY MICHAEL s. DUKAKis ointcion covinNom TO:

DIRECTOR BOULAY FROM:

BUZ USNER

'IN RE:

SHELTER SURVEY OF PILGRIM EPZ PREPARED BY BOST0ft EDISoll COMPANY DATE:

SEPTEMBER 11, 1987 i

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We have made a preliminary review of the shelter survey of the Pilgrim EPZ which was nreparad by the Boston Edison Company and its consultants.

While this document enmpiles some very useful data, we feel that more work must be done to estimate the effectiveness of shelter as a protective action.

Our principal concern is that we must be able to put data in 1.he hands of local officials which are sufficient for the develnpment of shelter utilization plans for all areas of all five communities within the Pilgrim EPZ.

With this in mind, we have the following comments.

The survey only covers an area aroroximately one mile wide along the coast.

The shelter capabilities of the entire EPZ must be surveyed and reported.

The survey does not separate out those structures which could "most reasonably" be used as shelters from those where shelter is less appropriate.

For instance, it would help to have a separate list nr public buildings and facilities for each town, including an estimation of the actual useable shelter space and protective factors for shelter under government authority.

Hany of the shelters listed, such as jewelry stores and pharmacies are clearly not suitable for public j

shelter.

In a severe emergency, every available i

resource will of course be put to use.

Howevet, to develop an implementable shelter utilization plan, local officials must be able to match estimated needs with the most appropriate resources available.

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O Director Boulay Page 2 Regarding protection of the beach oonulation, the survey identifies shelters within.a mile of the coast but does not indicate the distances that beach goers would have to travel to find shelter.

In addition, the survey must demonstrate that adequate proximate shelter is available for the total population at the individual beaches.

For instance, Duxbury beach is about seven miles lona and the survey should indicate the distance peonle at Saquish Head are required to travel to reach adequate shelter.

Further, an implementable shelter utilization plan must demonstrate that the nearest shelter would not be full to capacity before the people at the most remote' oints of the beaches arrived.

The survey must identify adequate shelter which is handicapped accessible.

The survey does not distinguish between available space and usable space.

For instance, residents of Plymouth have indicated to us that some basements listed in the survey are no more than crawl spaces.

Crawl spaces cannot be considered for public shelter.

Further, in most buildings, a good deal of floor area will be occupied by machinery, counters, office furniture, et cetera.

The survey must identify accurately the actual useable shelter space available in each structure.

Stone and Webster uses a FEMA nuclear attack value of ten sauare feet per person to estimate the potential population which can be sheltered.

Local Civil Defense Officials may wish to allocate mare space -- uo to twenty square feet per person -- in their utilization plans.

The value used in the survey overestimates the potential capacity of various buildings.

We doubt that 17,000 pecole can be sheltered at Duxbury High Schon1, or that 89,700 can be sheltered at the 5 Cordage Pcrk Buildings.

The survey must demonstrate that public shelters are free from asbestos and other environmental hazards.

The report _ estimates residential "sheltering capability" in individual communities as between 53%

and 81%.' These figures indicate that a significant number of residents do not have adequate domestic shelter and emphasize the need for a full study of public shelter capacities throughout the entire EPZ.

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Director Boulay Page 3 Further, even if it can be e'stablished that the vast majority of residences offer adeouate shelter, local officials must be prepared to offer public shelter of a known protective capability to residents who demand assistance.

This report makes no definitive statement of what constitutes adequate shelter to orotect peoole from the effects of a radioloolcal release from Pilorim Station.

This is necessary to determine what facilities are most appropriate for a local shelter utilization plan and to determine the public shelter needs of each community.

In summary, we w'ould say that this survey is a useful beginning but that much more work is required before we can assess nur ability to develop implementable shelter utilization plans consistent with the public safety concerns in Secretary Barry's report to the Governor, cc:

Assistant Secretary Peter W.

Agnes, Jr.

Deputy D1 rector John L. Lovering e

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APPENDIX SIX

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m by1a?Y//ttttbfhthe ff State Police, Troop "D",lleadquarters Middleboro, Massachusetts September 30, 1987 To:

Captain Charles F. llenderson, Commanding Troop "D" From:

Lieutenant Edward 11. Begin #908

Subject:

Review of and Recommendations for Man Power and Equipment Needs relative to Evacuation Time Estimates and Traffic Management Plan Update Final Draft prepared by KLD Assoc., Inc. for Boston Edison Co., Emergency Operations Facility, Plymouth, Mass. dated August 18, 1987.

1.

On August 19, 1987, I attended a meeting at Secretary Charles V.

3arry's of fice relative to the proposed traf fic management plan update re an evacuation within the Emergency Planning 7one (EPZ) at the Pilgrim Nuclear Power Station (PHPS) located in the Town of Plymouth. At that time, a copy of the final draf t for review prepared by KLD Associates. Inc. for Boston Edison Company was presented to me for review and recommendations relative A.

Location of traffic control posts, B.

Evacuation routes, C.

Personnel resources and D.

General review.

2.

Based on personal knowledge of traffic patterns within the area to be affected and traffic intensity data provided by sources mentioned in the plan submitted by KLD, which I assume to be correct, the following re-commendations are being submitted for your approval.

3.

The traffic control posts (TCP) and access control posts (ACP) sub-mitted by KLD appear to be essential in order to complete full evacuation, llowever, I do have reservations relative to ACP BR-1 and BR-2.

(See attached Table L-1. L-51 and L-52) n is location, with its close proximity to Boston, would create massive gridlock in the area thus preventing any emergency re-sponse from agencies coming from or through that area.

It would also deny access to residents of the EPZ who wish to return home for their families.

4.

h is ACP could be used more effectively if information could be transmitted to motorists traveling in the area, ne information could be provided by the radio media and also electronic message signs erected near ACP BR 1 and 2.

An additional four to six police officers on motorcycles would be required in that area in addition to the four recommended by KLD to handle the traf fic problems in the area in addition to the above additional requirements. A medium sized mobile communications van manned by at least three officers would be utilized at ACP BR 1 and 2 to better handle traffic and other related problems in the area. This van should have the capability to communicate with all State Police agencies as well as local police.

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Capt. C. F. Nenderson September 30, 1987 1

4. Continued should also have the capability to utilize the telephone communication system via a cellular mobile unit contained within the van. A large 10 KW hour

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mobile generator would be needed to handle all power requirements at that ACP. This equipment would be stored and maintained at State Police Norwell to better facilitate implementation.

5.

Another area of question is ACP E0.1.

This area, due to its close proximity to PHPS and large volume of traf fic, requires a large mobile commun-ication vehicle capable of communicating directly with all State and local agencies involved in the evacuation and in addition PNPS itself.

It should also have three cellular mobile telephones to handle the additional commun-ication needs that would arise from such an incident. This vehicle would be set up at a prearranged area at the Sagamore Rotary which would have been prepared with a power module which could accommodate the electrical and communication hookups necessary to power the communication vehicle. A large mobile generator would also be heeded in the event of a power outage.

Additional manpower requirements to properly operate the communication vehicle would be needed.

6.

It is also necessary tc equip each officer assigned to duty at the various ACP and TCP's with hand held radios. This equipment should be com.

parable and compatible with equipment currently in use within the Division of State Police.

7.

I further recommend that telephone equipment be installed in specific vehicles in use by personnel within the Division so that communication could be provided without further straining the radio communication system which would be taxed to the maximum in the event of any evacuation at PNPS.

This equipment should be available to the 1) Deputy Superintendent, 2) Com-manding Of ficer of Field Operations, 3) Bureau Commander of Eastern Fields,

4) Troop Commander and 5) entire command staff at Troop "D".

Protective clothing and beathing apparatus should be supplied to officers assigned within the five mile radius of PNPS EPZ. Personal radiological monitoring devices should be issued to all personnel assigned and training should be provided periodically in its proper usage. All ACPs and TCPs should be equipped with a power module mentioned earlier so that if necessary, emergency lighting and telephone communication could be brought into service if the need became evident. Telephone communication is o.Bvious because of information which.

should not be monito, red by private citizens and news media.

3.

I also recommend that a contingency of State Police officers be trained and maintained on a twenty-four hour basis to respond to the various ACP's and TCP's in the event of an emergency at PNPS. This could be accom-plished by expanding the "55" Team now deployed in Troop "D".

An additional seven troopers and two NCO's would bring the total strength to twenty-five This contingency of officers in addition to available personnel would men.

be able to respond to the various ACP's and TCP's within one hour of noti-fication of an ALERT condition.at PNPS.

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,Capt. C. F. Henderson September 30, 1987 9.

It must be noted that the personnel requirements can only be met at the ACF's and TCP's located on major limited access highways, Route 6 Route 3, Route 495,. Route 128, Route 25, and their immediate approaches.

This is due to the availability of manpower at short notice and also the need for minimum manning requirements - one desk officer and two patrols at the five troop mainland substations and at least one commissioned of ficer, one patrol supervisor and one civilian State Police dispatcher at the troop headquarters. These minimum requirements are absolutely necessary due to excess activity which would be generated as a result of any evacuation order.

10.

If the emergency lasted for an extended period (days), additional manpower would be solicited f rom other areas (District Attorney's of fices, neighboring Troop "A" and other sobrees) so that assistance could be pro-vided to local agencies at the remaining ACP's.

11.

The equipment and manpower needs described above are in addition to recommendations of ferred by KLD and are minimum requirements.

It may be that additional manpower and equipment may be necessary in the event of an emer-gency.

I do believe however that the State Police can provide the services necessary at the described locations if the equipment and manpower requests are made available.

12.

In addition to the aforementioned personnel and equipment require-ments, an adequate supply of printed handouts explaining evacuation routes, reason for evacuation and other perintent data should be available for dis-tribution at ACP's and TCP's.

This would expedite any need for instructions to evacuees thus allowing a smoother flow of traffic at these points.

W(

EDWARD H. BEGIN

  1. 908 Lieut., Mass. State Police DHQ, Middleboro EHB:dv Enes.

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APPEllDIX 1 Drief Explanation of llanpower Availability within Troop "D" Total llanpower availability of Troop "D" A/O 9-21-87 164 This figure describes the total strength including six officers assigned to the island stations at flantucket and llartha's Vineyard.

6 Six officers are currently on extended sick leave. Three are currently ansl ned temporary duty within the Bureau of Investigative Services.

6 One officer in unavailable for duty due to a suspension. This leaves a 10 total working strength of 148 officers currently available for assignment on the mainland.

Typical working troop strengu,not counting the personnel mentioned above, varies during each 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> period from 55 uniformed officers working during ihe day 11onday thru Friday to between 17 and 25 uniformed officers working on the remaining two shif ts llonday thru Friday and weekends.

!!inimum manning requirments are one doek officer and two patrols at each of fivo mainland stations. In addition to the above, one commissioned officer and an 1100 is assigned duty at the troop headquarters. One civilian State 7

Police Dispatcher is also assigned on a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> basis at the to,op headquarters.

Typical day strength lionday thru Friday 55 + or-5 Typical Eve strength Sunday thru Saturday 25 44 - 8 Typical flid strength Sunday thru Saturday 20 +5 - 3 Typical weekend Day strer th 25 +5 - 8 e

The remaining personnel are on time off (days off, Vacation, holidays owed, sick leave, personal days) but are available for re-call on an overtime basis.

hanpower requirments in the event of an evacuation at PHPS LFZ.

KLD Inc.

28 State Police 45 Persennel available for service less minimum manpower requirments.

Typical day Honday thru Friday 30 Typical eve Sun, thru Sat.

0(+4)

Typical mid Sun, thru Sat.

3(+5) by supplementing the existing Troop "D" 55 team with an additional 7 troopers and 2 Nco's bringing the total compliment to 27 officers. This group of officers would be trained and equipped to respond within one hour of notification of an emergency at PNPS. The remaining 18 officers needed would be drawn from existing manpower and so trained and equipped.

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o APPENDIX 2 Equipme nt Requirments

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1. Fif ty portable radioo which would supplement existing equipment currently in use within the division at Troop "D".

P. Four 10 KW generators to be used at access control points described..

( ACP-BR-1,BR-2, BO-1, SA-1,)

3. Nine mobile cellular telephones to be utilized as described.
4. Two mobile communice.tions vano, one large, one medium to be equipped as described.

(DR-1&2 DU-1)

5. One hundred sixty four dosimeter /one per man.
6. Six air packs to be used by personnel asoigned within the 5 mile radius of TNPS.

(TCP P.-4, P-7, P-8, P-15)

7. six suits of protective clothing to be used by personnel assigned within 5 mile radius of PUPS.

(Same as 6)

6. Sufficient power modules'to provide a source of power and telephone communications toDfrected at described sites.

a A power module would be a percenentlyerected, all weather source of electrical power sufficient to handle any lighting requirments at that site. It vould also be equipped with telephone jacks so that communication by telephone could be easily implemented.

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APPENDIX SEVEN 1

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i 0 Park Ptal. uibe 21 TAAN;2POATATION Boston, MA. 02116 3968 (617) 973-71M PLANNING STAFF l

November 19, 1987 Mr. Buzz Hausnor Civil Defense Agency Executive Department The Commonwealth of Massachusetts 400 Worcester Road P.O. Box 1496 Framingham, Massachusetts 01701-0317

Dear Mr. Hausner:

As requested in your letter of September 28, 1987, I have Adler testimonies of Avishai Ceder and Thomas J.

reviewad the (ETEs) to regarding the Seabrook Station evacuation time estimatessee if th Station ETEs.

Dr. Ceder focuses specifically on the behavioral assumptions and parameters of the I-DYNEV traf fic simulation model, and concludes that the model can not provide realistic ETEs within a (i 10%) of accuracy.

Furthermore, he believes reasonable degree likely to produce ETEs which err on the low side.

that the model is Dr. Adler concentrates on the input data to the simulation model, and concludes that the ETEa were underestimated, especially for the summer scenarios, and that the complete set of ETEs should be redone.

the ETEs Each cite a number of reasons for believing that First, there are Seabrook-specific ones.

were underestimated.

from them relates to the estimation of evacuation traffic One of the beach area.

Dr. Adler testifies that the ETEs for s'imme r -

weekend scenarios should reflect the times required to evacuate 100% of capacity, not at 2/3 capacity (as was beaches which are at done by KLD Associates, having observed 2/3 capacity to be typical of actual use).

This and other Seabrook-specific issues will not be commented on here.

Second, there are also a number of technical assumptions which may not be agreed upon among all people in the profession.

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for Dr. Ceder recommended 2.7 seconds /ge hea way One of these assumptions vehicle, based intersections.

on an observation of 80 vehicles (R. J.

Salter, Highway Traffic Analysis and Design, Addison Wesley, 1974), while KLD used 2.4 3

t' A. Cooperative Transportation Planning Effen of tee Esecut've Office of Transportation and Construction. Massachusetts Bay Tra Authority. MBT A Mosory Roerd. Massachusetts Decerterent of Pubhc Worst, Massachuseds Port Authority. Metroponta 3

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Mr. Buzz Hausner Novembsr 19, 1987 seconds / vehicle, taking the high end of the range from a low of 2.1 to a high of 2.4 documented in the Highway Capacity Manual (Transportation Research Board, 1985).

No attempt will be made here to recolve differing views about these technical assumptions.

However, there are some major issues raised in the testimony which have direct bearing on your consideration of the Pilgrim ETEs, and thich are addressed here.

Simulation of Normal Behavior The Seabrook ETEs are the result of simulation of normal travel behavior.

Effects of potential abnormal or unstable travel behavior in highly congested and stress f ul situations were not taken into account.

Dr. Ceder points out that only one driver needs to behave in an unstable manner to create a significant disturbance for a long line of vehicles (e.g.,

a single impatient vehicle occupying part of an intersection and thereby reducing intersection capacity significantly for the cross-flowing traffic).

Dr. Ceder also points out that more traffic accidents are likely to occur during an evacuation, because the traffic safety circeistances during the evacuation process are, in his view, analogous to the circumstances which commonly exist during roadway construction / maintenance work, and that traffic incidents such as vehicle breakdowns due to overheated engines, empty gas tanks, or mechanical failures are very likely to occur during the evac-uation.

Dr. Ceder concludes that these traffic accidents and traffic incidents will cause additional delays for the evacuating traffic.

Dr. Adler goes one step fur t.her and raises the question of whether people will stay with or abandon their cars if circumstan-ces make auto travel considerably slower than walking.

It is likely that at least some of the events described above would occur during an evacuation.

However, there are no empirical data to quantify the probability of their occurrence and the severity of their impacts.

Therefore, a "what-if" analysis is appropriate.

It is suggested that KLD Associates develop Pilgrim ETEs for a range of reductions in roadway capacity for a selected scenario.

Trips from Work to Home The return-home-from-work trips by employees who reside in the Evacuation Planning Zone (EPZ) were not included in the trip assignment / simulation models for the ETEs.

The effects of these trips were implicitly considered by assuming that the capacity of j

two-way road section will be reduced to a level corresponding to a 90%/10% split of evacuating vs. returning traffic.

Dr. Adler j

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~ ME'. Buzz Hausnor Novembar 19, 1987 suggests that these work-to-home trips should be explicitly modeled.

As you may recall, this topic is discussed in my September 8, 1987, memorandum to Dr. Michael D.

Meyer of the MDPN.

l s' It is recommended that a sensitivity analysis be performed by including these trips in the trip assignment / simulation process l

for one of Scenarios 3 through 7, to determine the effect of these tr ips on the ETEs.

-Apparent Errors Dr. Adler points out two apparent errors in the modeling pro-

cess, one error is in the calculation of the capacity of freeway ramps under congested flow conditions (service volume at level of service F).

While the documentation says that the volume at level of service F is assumed to be 85% of the volume at level of ser-Vice E, the actual volume used is approximately 94% of the volume at level of service E.

It is suggested that a sensitivity analy-sis be performed by running the model with corrected capacities for a scenario, and that the ETEs for all scenarios be manually adjusted according to the findings of that sensitivity analysis.

A second error relates to the interpolation method.

The I-DYNEV model produces the number of vehicles that have passed through a given area (e.g.,

the edge of the EPZ) at half-hour intervals.

An adjustment procedure is necessary to determine when, during the last 30-minute interval, the area actually cleared.

KLD Associates performed the interpolation for all exiting roads combined instead of interpolating individual roads separately and choosing the maximum value.

As a result, the ETE computations are biased on the low side by as much as 25 minutes.

The Pilgrim ETEs should be corrected.

The correction work does not require running the model.

Concluding Remarks The recommendations made here are focused on (a) correcting apparent errors, (b) refining the modeling process where the model may have been over-simplified, and (c) performing li mi ted wha t-i f analyses for uncertainties during the evacuation.

It is suggested that any time and effort available beyond what is spent on the above recommendations would be best utilized in refining the Pilgrim traffic-management plan.

Sincerely,

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N Yong B.

Chang Technical Director YBCapak cc:

Dr. Michael D.

Meyer, MDPW Matthew Currie, MDPW

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