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Category:AFFIDAVITS
MONTHYEARML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20237A0631998-08-0606 August 1998 Affidavit of TC Feigenbaum Re Length of Fuel Cycles at Seabrook Station & of Future Plans for Fuel Cycle Length. W/Certificate of Svc ML20236M5181998-06-27027 June 1998 Affidavit.* Affidavit of J Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4871998-06-27027 June 1998 Affidavit.* Affidavit of K Conrad Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5091998-06-27027 June 1998 Affidavit.* Affidavit of Sn Haberman Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5231998-06-27027 June 1998 Affidavit.* Affidavit of SA Parker Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M4971998-06-27027 June 1998 Affidavit.* Affidavit of D Bogen Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5061998-06-27027 June 1998 Affidavit.* Affidavit of C Nord Re 980506 License Exemption Request from Operator of Seabrook Station ML20236M5401998-06-27027 June 1998 Affidavit.* Affidavit of Eh Mecklejohn Re 980506 License Exemption Request from Operator of Seabrook Station ML20216E0351998-04-13013 April 1998 Affidavit of FW Getman (Great Bay Power Corp) Requesting That NRC Withhold Util Response to NRC RAI Re Proposed Acceleration of Decommissioning Funding for Ownership Share of Seabrook Station ML20140B9711997-06-0404 June 1997 Affidavit of FW Getman Per 10CFR2.790,re Great Bay Power Corp'S Filing of Suppl to Petition for Partial Reconsideration of Exemption Order ML20073E1641991-04-19019 April 1991 Affidavit of J Hausner.* Discusses Facility Offsite Radiological Emergency Planning.W/Certificate of Svc ML20065K3421990-11-0202 November 1990 Affidavit of Cole.* Discusses Issue of Whether Commonwealth of Ma School Teachers & Day Care Ctr Personnel Perform Roles Contemplated in Spmc ML20065K3451990-11-0101 November 1990 Affidavit of Mc Sinclair.* Responds to Questions Posed by Aslab in ALAB-937 Re Whether Spmc Provides Adequate Supervision & Care of Children Evacuated to School Host Facility at Holy Cross College.W/Certificate of Svc ML20062C2781990-10-19019 October 1990 Affidavit of a Callendrello Addressing Issue Re Staffing of Seabrook Plan for Massachusetts Communities School Host Facility as Discussed in Aslab 900918 Decision.W/Certificate of Svc ML20062C2651990-10-18018 October 1990 Affidavit of Ds Mileti Addressing Issue Whether Massachusetts School Teachers & Day Care Ctr Personnel Would Respond to Assignments in Emergency to Escort Children on Buses ML20059M6201990-09-24024 September 1990 Affidavit of GL Iverson.* Responds to Statements Made in Mc Sinclair 900907 Supplemental Affidavit.W/Certificate of Svc ML20059B0021990-08-22022 August 1990 Affidavit of RW Donovan Re Staffing Adequacy for Implementation of New Hampshire Radiological Emergency Response Plan for Plant.W/Certificate of Svc ML20059A9981990-08-21021 August 1990 Affidavit of Jc Dolan Re Adequacy of Staffing for Implementation of New Hampshire Radiological Emergency Response Plan for Plant ML20059B0281990-08-21021 August 1990 Affidavit of GL Iverson Re Position of Governor Media Ctr representative.Twenty-second Initial Vacancy Was New Hampshire Public Utils Commission Lead Engineer ML20059A8911990-08-16016 August 1990 Affidavit of GL Iverson Re Adequate Staffing at New Hampshire Radiological Emergency Plan in Event of Radiological Emergency at Seabrook.W/Certificate of Svc ML20056B2251990-08-0606 August 1990 Affidavit of Mc Sinclair.* Affidavit Re Offsite Radiological Emergency Response Planning for State of Nh & Spmc ML20081E2431990-07-31031 July 1990 Affidavit of a Desrosiers Re Evacuation of Advanced Life Support Patients ML20081E2471990-07-31031 July 1990 Affidavit of B Cohen Re Evacuation of Advanced Life Support Patients ML20081E2401990-07-31031 July 1990 Affidavit of Rl Goble Re Preparation of Advanced Life Support Patients for Evacuation ML20081E2511990-07-31031 July 1990 Affidavit of Sj Plodzik Re Evacuation of Advanced Life Support Patients ML20055G6521990-07-11011 July 1990 Affidavit of T Urbanik Re Licensee Motion for Summary Disposition of Advanced Life Support Patients Issue.* Addresses Issues Re Preparation of Advanced Life Support Patients.W/Certificate of Svc ML20058K8011990-06-25025 June 1990 Affidavit of Am Callendrello.* Addresses Issues Defined by ASLB in LBP-90-12 Re Preparation of Advanced Life Support Patients for Evacuation & Impact on Special Population Evacuation Time Estimates.W/Certificate of Svc ML20058K7811990-06-25025 June 1990 Affidavit of J Bonds.* Addresses Issues Defined by ASLB in LBP-90-12 Re Advanced Life Support Patients & Consideration of Preparation Time for Evacuation Under State of Nh Radiological Emergency Response Plan.W/Certificate of Svc ML20058K7841990-06-25025 June 1990 Affidavit of D Albertson.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20058K7941990-06-25025 June 1990 Affidavit of Kj Callahan.* Addresses Issues of Advanced Life Support Patient Preparation for Transport.Certificate of Svc Encl ML20012C6701990-03-15015 March 1990 Affidavit of Rd Pollard.* Advises That Deficiencies Cited in INPO & Other Repts Demonstrate No Basis for Finding That Reactor Complies W/Nrc Regulations or Can Be Operated Safely ML20012C7121990-03-13013 March 1990 Affidavit of Be Beuchel.* Addresses Intervenors Allegations & Whether Significant Safety Issue Present Re Rosemount Transmitters.Supporting Info,Including Beuchel Prof Qualifications & Certificate of Svc Encl ML20006G1151990-02-26026 February 1990 Affidavit of Gc Minor Re Rev of Rosemount Transmitters at Seabrook.* Discusses Potential Safety Impact of Rosemount Transmitter Problems & Need for Changing Faulty Transmitters Before Plant Proceeds W/Power Ascension & Operation ML20011F1291990-02-16016 February 1990 Affidavit of WT Wallace.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan.Supporting Info Encl ML20011F1281990-02-16016 February 1990 Affidavit of GL Iverson.* Discusses Oct 1988 Amends to State of Nh Radiological Emergency Response Plan ML19351A7051989-12-0606 December 1989 Affidavit of TC Feigenbaum.* Advises That Further Delay in Obtaining Full Power License for Plant & Reaching Commercial Operations Caused by Further Litigation Will Be Very Costly & Unnecessary.W/Supporting Info & Certificate of Svc ML19332F9701989-11-30030 November 1989 Joint Affidavit of Gc Minor & Sc Sholly.* Opposes Issuance of Full Power OL Until Problems Noted Resolved,Consistent W/ NRC Finding in Confirmatory Action Ltr CAL-RI/89-11.Addl Info & Certificate of Svc Encl ML19332D7011989-11-22022 November 1989 Affidavit of AA Kelsey.* Discusses 1989 Edition of Arbitron Radio County Coverage Rept for Essex County,Ma.Few People in Geographic Area Listen to Whav & Wlyt.W/Certificate of Svc ML20006C4371989-11-21021 November 1989 Affidavit of AA Kelsey.* Discusses Radio Coverage in Merrimac Valley.W/Supporting Info & Certificate of Svc ML19332D5701989-11-17017 November 1989 Joint Affidavit of Gc Minor & Sc Sholly Re New Hampshire Yankee 890921 OL Amend Request (Plant Instrument Air cross-connect to Containment Bldg Air sys,NYN-89116).* Proposed Amend Considered Illogical & W/O Technical Merit ML19332D5301989-11-14014 November 1989 Affidavit of Am Callendrello.* Refutes Intervenors Allegations That Util No Longer Able to Provide Emergency Info to Public as Result of Withdrawal of Agreement Between Util & Wcgy.W/Supporting Info ML19332D5441989-11-14014 November 1989 Affidavit of Gr Gram.* Confirms Util Adherence to 870914 Commitment to Provide Certain Svcs & Equipment for Planning & Implementation of Alerting Sys.W/Supporting Info & Certificate of Svc ML19332D5361989-11-13013 November 1989 Affidavit of Gj Catapano.* Denies Intervenors Allegations That Util Incapable of Providing Prompt Emergency Instructions to Public in Light of Withdrawal of Certain Agreements.Supporting Info Encl ML19354D5121989-11-0909 November 1989 Affidavit of R Boulay Re Voiding of Emergency Broadcast Sys Ltrs of Agreement.* Since Wcgy Voided Ltr of Agreement W/ Util & Withdrew from Emergency Plan,Broadcast Sys for Merrimac Valley Cannot Be Activated.Related Info Encl ML19354D5141989-10-30030 October 1989 Affidavit of R Sawyer Re Voiding of Emergency Broadcast Sys Ltr of Agreement.* Marked-up Affidavit Discussing Impact of Wcgy Voiding Ltr of Agreement W/Util & Withdrawing from Participating in Emergency Planning.W/Certificate of Svc ML19327B7021989-10-27027 October 1989 Affidavit of Jf Bassett Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Fact That Applicant Has Never Followed Through on Commitment to Provide Ebs Equipment,Per 870914 Ltr of Agreement.Supporting Info Encl ML19327B7061989-10-26026 October 1989 Affidavit of Dj Rowe Re Voiding of Emergency Broadcast Sys (Ebs) Ltrs of Agreement.* Discusses Applicant Refusal to Live Up to Commitments to Commonwealth of Ma Ebs.W/ Supporting Info & Certificate of Svc 1999-01-19
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] |
Text
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!+
> lt s Dated: March 25, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
).
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL
) Off-site Emergency (Seabrook Station, Units 1 and 2) ) Planning Issues
)
)
AFFIDAVIT OF EDWARD B. LIEBERMAN (TOH REVISED CONTENTION IV)
I, Edward B. Lieberman, being on oath, depose ard say as follows:
- 1. I am Vice President of KLD Associates, Inc. and am responsible for the development of the Seabrook Station Evacuation Timd Study, Volume 6 of the NHRERP. A statement of my professional background and qualifications is attached hereto and marked "A".
- 2. Volume 6, pages 11-19 and 11-20 of the NHRERP ,
provides a detailed description of inbound travel time.
This section indicates that little impedance to vehicles ,
l l
1 0704020205 870325 PDR ADOCK 05000443 ,
O PDR l
1
entering the EPZ following an order to evacuate would be anticipated due to the following reasons:
- a. The first buses will not depart their points of origin until approximately 30 minutes following the order to evacuate,
- b. Some 70% of returning commuters will have reached their homes within the EPZ one hour following the evacuation order, t .
and over theref re willN not e SI $ wbe.= c9n&ributing
<ht tok w n M e h *" $ly (See also Vol. 6, Figure 11-1). -/de Ef f-inbound traffic flow)
- c. Other inbound traffic would be limited due to 2hh{f discouraged entry via EBS and other media messages, and by l
people's concern over the potential risk to their health and
- safety.
- d. Access control points established at the perimeter of the evacuated area would also discourage non-essential inbound traffic.
- 3. For the above reasons, it is reasonable to anticipate that incoming buses along at-grade primary highways (e.g., Route 1) may average 40 mph and those that travel along access-controlled highways may average 50 mph.
Edward B. Lieberman i
O STATE OF NEW YORK
[vFF044 , SS. MarchA M, 1987 1
l The above-subscribed Edward B. Lieberman appeared before me and made oath that he had read the foregoing affidavit and that the statements set forth therein are true to the best of his knowledge.
Bafore me, 0 ,/0 Y
No,W ry Public' b
Mp Commission Expires:
ROCHELLE LANDSMAN Notary Public. State of New YorA No. 52 4742519 Qualified in Suffnth Cou a Commission Expires Marer % 19If 4
PROFESSIONAL QUALIFICATIONS EDWARD B. LIEBERMAN Vice President KLD ASSOCIATES, INC.
My name is Edward B. Lieberman and my business address is KLD Associates, Inc., 300 Broadway, Huntington Station, New York 11746. I am presently Vice President of KLD Associates, Inc.
I received the Bachelor of Science degree in Civil Engineering in 1951 from Polytechnic Institute of Brooklyn.
I was awarded the Master of Science degree in Civil Engineering in 1954 from Columbia University and in Aeronautical Engineering in 1967 from Polytechnic Institute of Brooklyn. I am currently working on a Doctorate degree in Transportation Planning at the Polytechnic University, i am a member of the Chi Epsilon Honorary Fraternity.
With almost 30 years of professional experience, I have managed a number of major projects. I pioneered the development and application of traffic simulation models, making major state-of-the-art innovations in the traffic engineering profession. I have also been responsible for l
many engineering studies involving data collection and analysis and design of traffic control systems to expedite traffic flow and relieve congestion.
I have developed simulation models to study traffic l j
performance on urban networks, freeways, freeway corridors
/'i 4
)
1
i O
and two-lane, two-way rural roads. These programs include consideration of pedestrians, interaction with vehicular traffic, truck and bus operations, special turning lanes, and vehicle fuel consumption and emissions; both pretimed and actuated traffic signal controls are represented.
I was the Principal Investigator for the development of traffic signal control strategies for congested conditions in mid-Manhattan. These strategies were implemented and evaluated in the field. Field tests indicated substantial reductions in delay combined with increased vehicle 4 throughput, j I was the Principal Investigator in the development of an interactive computer graphics (ICG) software system for displaying traffic simulation results generated by the NETSIM model. I designed the overall structure of the software for implementation on PC AT computers and,
- subsequently, on larger ICG work stations. This work was sponsored by FHWA.
I was responsible to a large extent for the theoretical
, development of DYNEV, a Dynamic Network Evacuation model.
! The DYNEV model consists of two major components: an j equilibrium traffic assignment model and a macroscopic dynamic traffic simulation model designed for all types of roadway facilities (urban streets, freeways, rural roads).
DYNEV is designed to be used as a tool to develop and
, organized evacuation plans needed as part of general l
i
! i e
-. = ..
'O disaster preparedness planning. DYNEV was used to analyze an existing evacuation scenario at the Con Edison Indian Point Nuclear Power Station and is currently being used to develop an extensive evacuation plan for the LILCO Shoreham Nuclear Power Station on Long Island, New York.
In developing this evacuation plan for the Seabrook Nuclear Power Station, my activities include definition of evacuation scenarios, definition of the evacuation network, development of traffic control treatments and of traffic routing patterns, analysis of trip tables, analysis of simulation results, optimization of evacuation strategies and the preparation of formal documentation.
I was responsible for the development of the I-DYNEV q model, an interactive version and enhancement of the DYNEV
- model, under contract with the Federal Emergency Management Agency (FEMA). I-DYNEV, in turn, was integrated into the Integrated Emergency Management Information System (IEMIS),
developed by FEMA. I-DYNEV was applied to estimate the evacuation times for the Emergency Planning Zones (EPZ) for 8
eight nuclear power stations.
I developed course material and conducted training for emergency planning personnel at the National Emergency Training Center (NECTC) in Emmittsburgh, Maryland.
I was also responsible for the designs of the NESIM j
] microscopic urban traffic simulation model (formerly UTCS-1)
{ and of the SCOT freeway traffic simulation model. The i i i !
NETSIM microscopic traffic simulation model developed for the Federal Highway Administration, enables agencies to 4
evaluate traffic operations in urbt.n environments. The SCOT model was developed for the Transportation Systems Center of the Department of Transportation. This program includes a dynamic traffic assignment algorithm which routes traffic over a network in response to changing traffic flow
- characteristics to satisfy a specified origin-destination table. In addition, I have developed advanced traffic
) control policies for urban traffic for the FHWA-sponsored i
UTSC Project, as well as a bus preemption policy to enhance 1
the performance of mass transit operations within urban environs.
I designed and programmed the advanced " Third generation" area-wide, cycle-free control policies for moderate and congested traffic flow for computer-monitored real-time systems. I also developed a cycle-based, off-line computational procedure named SIGOP-II, to optimize traffic signal timing patterns to minimize system "disutility."
i I led a group of traffic engineers and systems analysts l
in developing a system of macroscopic traffic simulation I
models designed to evaluate Transportation Systems Management (TSM) strategies. This software system, named TRAFLO, also includes an equilibrium traffic assignment l i
model. This model has been distributed to other agencies l l
including FEMA. l i
-<- 1 l
1
I designed an " Integrated Traffic Simulation System,"
named TRAF, which will eventually incorporate all the best traffic simulation models available. Using structured programming techniques, TRAF integrates: NETSIM, TRAFLO, and ROADSIM, a microscopic rural-road simulation model.
I served as Principal Investigator on NCHRP Project 3-20 entitled, " Traffic Signal Warrants." This project involved both field data collection and the application of the NETSIM model to study intersection delay as a function of traffic volume, a type of control and geometrics. In turn, I developed and documented new signal warrants, some of which will be incorporated in the next version of the Manual on Uniform Traffic Control Devices (MUTCD).
Under NHTSA sponsorship, I directed a research study to evaluate a Driver Vehicle Evaluation Model named DTRVEM.
This model simulates the response of motorists to hazardous events. This effort included analysis of the model formulation and software and sensitivity testing. A workship was designed, organized, scheduled and conducted by myself and other KLD professionals; experts from all over the U.S. were invited to recommend specific NHTSA research activities for the further development of the model. A recommended research program constituted the major output of the contract.
Over the years I have been involved in a number of other studies to evaluate traffic operations on large-scale road networks, using one or more of the models described above.
Prior to 1960 I applied my skills to the areas of stress analysis, vibrations, fluid dynamics and numerical analysis of differential equations. These analyses were programmed for the IBM 7090 and System 360, CDC 6600 and 7600, G.E. 625 and UNIVAC IIOB digital computers in assembly languate, FORTRAN and PLI. I also designed the logic and real-time programming for a sonar simulator built for the Department of Navy and monitored by a PDP-8 progess-control digital computer.
I am a member of the American Society of Civil Engineers, the Institute of Transportation Engineers, the Association of Computing Machinery and the Transportation Research Board (TRB). I am also a member of the Traffic Flow Theory and Characteristics Committee of the TRB. I am a licensed Professional Engineer in New York, Maryland, and Florida.
The following list comprises selected publications of my studies and findings:
"DYNET - A Dynamic Network Simulation of Urban Traffic Flow," Proceedings, Third Annual Simulation Symposium, 1970.
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" Simulation of Traffic Flow at Signalized Intersections: the SURF System," Proceedings, 1970 Summer Computer Simulation Conference, 1970.
" Dynamic Analysis of Freeway Corridor Traffic," SME paper, Trans. 70-42.
" Simulation of Corridor Traffic: The SCOT Model," " Highway Research Record No. 409, 1972.
" Logical Design and Demonstration of UTCS-1 Network Simulation Model,"
Highway Research Record No. 409 , 1972 with R. D. Worrall and J. M.
Bruggerman).
" Variable Cycle Signal Timing Program:
Volumes 1-4," Final Report of Contract DOT-FH-11-7924, June, 1974.
i I " Traffic Signal Warrants," KLD TR-51, Final Report on NCHRP Project 3-20/1,
- December 1976 (with G. F. King and R.
Goldblatt).
" Rapid Signal Transition Algorithm," Transportation Research Record No. 509 , 1974 (with D. Wicks).
- "Subnetwork Structuring and Interfacing for UTCS Project-Program of Simulation Studies," KLD TR-5, January, 1972.
! " Development of a Bus !iignal Preemption Policy and a System Analysis of Bus
, Operations," KLD TR-11, April, 1973.
"SIGOP-II - Program to Calculate Optimal, Cycle-Based Traffic Signal Timing Patters, Volumes 1 and 2," Final Report, Contract DOT-FH-11-7924, KLD TR-29 and TR-30, December, 1974.
Summary report inTransportation Research Record 596, 1976 (with J. Woo).
J " Developing a Predictor for Highl Responsive System-Based Contro," y Transportation _Research Record 596, 1976 (with W. McShane and R. Goldblatt).
i e
"A New Approach for Specifying Delay-Based Traffic Signal Warrants,"
Transportation Research Special Report 153 - Better Use ofExisting Transportation Facilities, 1976.
" Network Flow Simulation for Urban Traffic Control Systems," Vols. 1-5, PB230-760, PB230-761, PB230-762, PB230-763, PB230-764, 1974 (with R.
Worrall), Vols. 2-4 updated 1977, KLD TR-60, TR-61, TR-62 (with D. Wicks and J. Woo).
" Extension of the UTCS-1 Traffic Simulation Program to Incorporate Computation of Vehicular Fuel Consumption and Emissions," KLD TR-63, 1976 (with N. Rosenfield).
" Analysis and Comparison of the UTCS Second- and Third-Generation Predictor Models," KLD TR-35, 1975.
" Urban Traffic Control System (UTCS)
Third Generation Control (3-GC) Policy,"
Vol. 1, 1976 (with A. Liff).
" Design of TRAFIC Operating System (TOS), KLD TR-57, 1977.
" Revisions to the UTCS-1 Traffic Simulation Model to Enhance Operational Efficiency," KLD TR-59, 1977 (with A.
Wu).
"The Role of Capacity in Computer Traffic Control," in Research Directions in Computer Control of_ Urban Traffic Systems, ASCE, 1979.
" Traffic Simulation: Past, Present and Potential," in Hamburger, W.S. and Steinman, L., eds., Proceedings of the International Symposium of Traffic Control Systems, University of California, Berkeley, 1979.
"TRAFLO: A New Tool to Evaluate Transportation System Management Strategies," presented at the 59th
Annual Meeting of the Transportation Research Board, 1980 (with B. Andrews).
" Determination of the Lateral Deployment of Traffic on an Approach to an Intersection," presented at the 59th Annual Meeting of the Transportation Research Board, 1980.
" Service Rates of Mixed Traffic on the Left-Most Lane of an Approach,"
presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with W. R. McShane).
l l " Development of a TRANSYT-Based Traffic
( Simulation Model," presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with M. Yedlin).
" Hybrid Macroscopic-Microscopic Traffic Simulation Model," presented at the 59th Annual Meeting of the Transportation i Research Board, 1980 (with M. C.
Davila).
"A Model for Calculating Safe Passing Distance on Two Lane Rural Road,"
presented at the 60th Annual Meeting of the Transportation Research Board, 1981.
"The TRAF System - Anayltic Formulation
, and Logical Design of the Roadnim Model," KLD TR-129, June, 1983.
"PREDYN User's Guide," KLD TR-131, June, 1983.
l "The TRAF System - Technical Report,"
KLD TR-136, August, 1983 (with M.
Yedlin, D. Andrew and K. Sheridan).
" Application of the I-DYNEV System to
. Compute Estimates of Evacuation Travel l
Time at Nuclear Power Stations -- Four Demonstration Case Studies," KLD TR-142, l December, 1983.
l
! " Users Manual for the Interactive l Dynamic Network Evacuation Models i I-DYNEV,"KLD TR-144, February, 1984.
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3
" Formulations of the DYNEV and I-DYNEV Traffic Simulation Models Used in EESF,"
KLD TR-154, March, 1984.
"PREDYN/IDYNEV Training Guide," KLD TR-155, April, 1984 (with R. Goldblatt).
" Specifications of Recommended Interactive Graphics Hardware Configuration and Graphics Support Software for the Netsim Graphics Display Package," KLD TM-93, July, 1985.
" Metering of High-Density Sectors Comparison of Traffic Operations Along Fifth Avenue in Mid-Manhattan: Metering Control vs. Existing Control," KLD TM-94, July, 1985.
" Description of an Integrated Traffic Assignment and Distribution Model (TRAD) for the IDYNEV System," KLD TR-187, April, 1986.
" Evacuation Plan Update (Robert G. Ginna Nuclear Power Station)," KLD TR-189, May, 1986 (with R. Golablatt).
" Evacuation Plan Update (Davis Bosso),"
KLD TR-190, July, 1986 (with R.
Goldblatt).
"Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update," KLD TR-174, August, 1986.
" Reducing Traffic Congestion at Herald Square," ITE Journal, September, 1986, pp. 27-31 (with A. K. Rathi).
" Congestion Based Traffic Control Scheme for High Traffic Density Sectors,"
Transportation Research Record No. 1057, TRB, National Research Council, Washington, D.C., 1986, pp. 49-57 (with A. K. Rathi and G. F. King).
" Overview of the Evacuation Plan and of the Evacuation Time Estimtaen for the Seabrook Nuclear Power Station," KLD TM-98, October, 1986.
r I
e
" Overview of the Evacuation Plan and of
, the Evacuation Time Estimates of the
! Ginna Nuclear Power Station," KLD TM-99, l November, 1986 (with R. Goldblatt).
" Overview of the Coastal Region within the Pilgrim Station Emergency Planning l Zone," KLD TM-100, November, 1986.
" Enhanced Freflo Program: Simulation of Congested Environments," paper submitted for presentation at Transportation Research Board's 66th Annual Meeting, January, 1987 (with A. K. Rathi and M.
Yedlin).
"The Netsim Graphics System," paper submitted for prosentation at Transportation Research Board's 66th Annual Meeting, January, 1987 (with B.
Andrews and A. Santiago).
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