ML20205N814

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Affidavit of Eb Lieberman (Sapl 34).* Statement of Prof Qualifications Encl
ML20205N814
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 03/25/1987
From: Lieberman E
KLD ASSOCIATES, INC., PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
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~ j Dated: March 25, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )'

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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

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AFFIDAVIT OF EDWARD B. LIEBERMAN (SAPL 34)

I. EDWARD B. LIEBERMAN, being on oath, depose and say as follows:

1. I am Vice President of KLD Associates, Inc. and am responsible for the development of the Seabrook Station Evacuation Time Study, Volume 6 of the NHRERP. A statement of my professional background and qualifications is attached hereto and marked "A".
2. SAPL Contention No. 34 argues that population figures in Revision 2 of the NHRERP are erroneous. It presents, as a basis for this contention, data from prior kDy4030110870325 g ADOCK 05000443 PDR t

v . reports published either by the NRC or previous versions of-

'the NHRERP, which indicate a higher population.
3. The basis for the contention references Table'1 of f: Revision 2.'of the NHRERP plans with regard to resident summer weekend and summer midweek populations. It is l' .

assumed that this refers to Table 1 of.the. local RERP plans, 1 i

entitled " Population of. Municipalities Wholly'or' Partially 4

Within 10 Miles of Seabrook Station." 'These estimates were i .

culled from information available in Sections 2, ~5 and 6 of- ,

! Volume 6 of the NHRERP.

l 4. Paragraph 1 of the basis for,this contention states  ;

that "Rev. 2 has reduced this peak number to 142,529 for a j~ summer weekend-and 142,929 for summer midweek." This is i

l false. The peak summer weekend population for the-New Hampshire towns totals 142,569; the total peak summer 4

midweek population totals 139,929,- per Table 1 of the NHRERP

local plans.

i 5. Paragraph 2 of the basis for this contention states

! that " Table 1 in the Rev. 2 plans shows the' total EPZ peak l

population for 1986 at summer midweek at 229,726 . . . and~

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the peak summer weekend population'at 231,292."' These figures are also false. The peak summer' weekend population 1

for the EPZ totals 228,292, and the peak summer midweek

, population for the EPZ totals 225,726.

j 6. Population estimates utilized by the ETE were

$ derived from locally-procured Town Clerk estimates in early f

i 1985' based on local census activities. Compounded annual I.

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h g rctac ware calculatcd-uning Stata data for tha years 1980- .

and 1985 and are listed at pg. 2-9, Vol. 6. The 1984 population estimates of the New Hampshire towns as provided by the New Hampshire Office of State Planning were also projected to 1986 using the most recent annual. growth rate for each town. These estimates, listed on p. E-11, confirm the validity of those population estimates provided by local sources.

7. The intervenor states the "(t)he area along the coast . . . can be expected to have grown at a rate faster than the country wide average." This-statement provides no basis of fact other than the intervenor's expectation. In fact, KLD sought information regarding local " traffic counts and local business figures" from the Town of Hampton and Chamber of Commerce of Hampton Beach. KLD was informed that no such traffic counts or person counts exist.
8. The intervenor finds fault with the ETE estimated population by comparing the total estimated EPZ population-based on current 1985 local population figures with an estimated 1983 population figure which was developed in 1982. This provides no basis for making conclusions as to the extent current population should exceed an estimate of population four years dated.
9. The listed figure indicating the estimated peak summer midweek population for the Town of Hampton within Volume 18 was inadvertently mistyped. The current plan has been corrected to replace the figure "34,337" with the 1

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Q figuro "31,337."' Copics of the corrected pega are on file with the NHCDA.

10. Peak population estimates utilized in the ETE represent the total population which may be within a particular town at any one time. The ETE figures may therefore differ considerably from cumulative' traffic counts or local business figures, which may reflect activity over a duration of time.
11. No empirical basis is provided to support the Intervenor's point of view. The KLD plan details the sources of all population and vehicle estimates. All of the sources are empirical, arising from direct observation from extensive survey results, or from the files of the 23 town clerks.

ert Edward B. Lieberman STATE OF E4d 04A(

ddpAO/.M , ss. March M , 1987 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.

Before me, M

N ry Public y Commission Expires:

ROCHELLE LANDSMAN Notary Public, State of New York No. 52-4742519 Qualified in Suffok County Commission Empires March 30,1 ,

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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 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 performance on urban networks, freeways, freeway corridors

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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 throughput.

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 i 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 1

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( a 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 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 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.

4 I was also responsible for the designs of the NESIM microscopic urban traffic simulation model (formerly UTCS-1) and of the SCOT freeway traffic simulation model. The i

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l NETSIM microscopic traffic simulation model developed for 1 l

the Federal Highway Administration, enables agencies to- '

evaluate traffic operations.in urban environments. The SCOT model was developed for the Transportation Systems Center of the Department of Transportation. This program includes a j dynamic traffic assignment algorithm which routes traffic over a network.in response to changing traffic flow i characteristics to satisfy a specified origin-destination

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table. In addition, I have developed advanced traffic 4

control policies for urban traffic for the FHWA-sponsored j UTSC Project, as well as a bus preemption policy to enhance the performance of mass transit operations within urban environs.

a I designed and programmed the advanced " Third generation" area-wide, cycle-free control. policies for 4

l moderate and congested traffic flow for computer-monitored i

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 led a group of traffic engineers and systems analysts in developing a system of macroscopic traffic simulation

! models designed to evaluate Transportation Systems Management (TSM) strategies. This software system, named 4 TRAFLO, also includes an equilibrium traffic assignment model. This model has been distributed to other agencies-including FEMA.

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Sp 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 4

] entitled, " Traffic Signal Warrants." This project involved both field data collection and the application of the NETSIM model to study intersection delay ca a function of traffic volume, a type of control and geometrics. In turn, I l 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 i

myself and other KLD professionals; experts from all over

the U.S. were invited to recommend specific NHTSA research j

activities for the further development of the model. A recommended research program constituted the major output of the contract.

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, 1 Over the years I have been involved in a number of other studies to evaluate traffic operations on large-scale road l networks, using one or more of the models described above.

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' 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 4

Association of Computing Machinery and the Transportation

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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 i

Florida.

4 The following list comprises selected publicationsaof 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.

" 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 Signal Preemption Policy and a System Analysis of Bus operations," KLD TR-ll, April, 1973.

"SIGOP-II - Program to Calculate optimal, Cycle-Based Traffic Signal

Timing Patters, Volumes 1 and 2," Final
Report, Contract DOT-FH-ll-7924, KLD TR-29 and TR-30, December, 1974.

Summary report inTransportation Research  !

Record 596, 1976 (with J. Woo).

" Developing a Predictor for Highly

, Responsive System-Based Contro,"

Transportation Research Record 596, 1976 (with W. McShane and R. Goldblatt).

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"A New Approach for Specifying Delay-Based Traffic Signal Warrants,"  !

Transportation Research Special Report 1 153'- Better Use ofExisting j Transportation Facilities, 1976.

"NetworkFlowSimulktionforUrban 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).

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" Analysis and Comparison of the UTCS Second- and Third-Generation Predictor Models," KLD TR-35, 1975.

" Urban Traffic Control System'(UTCS) ,

Third Generation Cont'rol (3-GC) Policy," '

Vol. 1, 1976 (with A. Liff). /

" Design of TRAFIC Operating System 1 (TOS), KLD TR-57, 1977. y-

" Revisions to the UTCS-1 Traffic Simulation Model to Enhance Operational Efficiency," KLD TR-59, 1977 (with A.'

Wu). i tJ t

"The Role of Capacity in Computer Traffic Control," in Research Directions a in Computer Control of Urban Traffic '

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Systems, ASCE, 1979.

" Traffic Simulation: Past, Present and Potential," in Hamburger, W.S. and p Steinman, L., eds., Proceedings of the ,

International Symposium of Traffic Control Systems, University of California, Berkeley, 1979. *\

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"TRAFLO: A New Tool to Evaluate Transportation System Management /

Strategies," presented at the 59th i.

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Annual Meeting of the-Transportation l Research Board, 1980 (with B. Andrews). 1

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" Determination of the. Lateral Deployment l of Traffic on an Approach to an l Intersection," presented at the 59th '

Annual Meeting of the Transportation i j Research Board, 1980.

6 " 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).

1 I " Development of a TRANSYT-Based Traffic Simulation Model," presented at the 59th-i s Annual Meeting of tne Transportation j ' ,

Research Board, 1980 (with M. Yedlin).

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" Hybrid Macroscopic-Microscopic Traffic Simulation Model," presented at the 59th Annual Meeting of the Transportation j Research Board, 1980 (with M. C.

4 i' Davila).

"A Model for Calculating Safe Passing Distance on Two Lane Rural Road,"

presented at the 60th Annual Meeting of l

the Transportation Research Board, 1981.

' "The TRAF System - Anayltic Formulation and Logical Design of the Roadsim

Model," KLD TR-129, June, 1983.

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! ',' "PREDYN User's Guide," KLD TR-131, June, j 1983.

'i "The TRAF System - Technical Report,"

KLD TR-136, August, 1983 (with M..

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Yedlin, B. Andrew and K. Sheridan).

4 l " Application of the I-DYNEV System to

> t , Compute Estimates of Evacuation Travel Time at Nuclear Power Stations -- Four 1

' (Demonstration Case Studies," KLD TR-142, s, December, 1983.

" Users Manual for the Interactive

Dynamic Network Evacuation Model
I-DYNEV,"KLD TR-144, February, 1984.

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" Formulations.of the DYNEV and I-DYNEV Traffic, Simulation Models Used in EESE,"

KLD TR-154, March, 1984.

"PREDYN/IDYNEV Training Guide," KLD TR-155, April, 1984 (with R. Goldblatt).

" Specifications of Recommended Interactiva Graphics Hardware Configuration tnd Graphics Support Software for the Netsim Graphics Display Package," KLD TM-93, July, 1985.

" Metering of High-Density Sectors Comparison of Tr.sffic Operations Along Fifth Avenue in Mid-Manhattan: Metering

' Control vs. Existing Control," KLD

'TM-94, July, 1986.

" 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. Goldblatt).

" Evacuation Plan Update (Davis Besse),"

KLD TR-190, July, 1986 (with R.

Goldblatt).

"Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update," KLD TR-174, August, 1986.

"hi'tcing Traffic Congestion at Herald Squars," 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 Estimtaes for the Seabrook Nuclear Power Station," KLD TM-98, October, 1986.

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" Overview of the Evacuation Plan and of the Evacuation Time Estimates of.the Ginna Nuclear Power Station," KLD TM-99, November, 1986 (with R. Goldblatt).

" Overview of the Coastal Region within the Pilgrim Station Emergency Planning 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, Janu'ary, 1987 (with A. K. Rathi and M.

Yedlin).

"The Netsim Graphics System," paper submitted for presentation at Transportation Research Board's 66th Annual Meeting, January, 1987 (with B.

Andrews and A. Santiago).

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