ML20205P663

Affidavit of Eb Lieberman (Toh Iii).* Statement of Prof Qualifications Encl

ML20205P663
Person / Time
Site:	Seabrook
Issue date:	03/25/1987
From:	Lieberman E KLD ASSOCIATES, INC., PUBLIC SERVICE CO. OF NEW HAMPSHIRE
To:
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References
OL, NUDOCS 8704030339
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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 (TOH III)

I, Edward B. Lieberman, being on oath, depose and say as follows:

I. I am the Vice President of KLD Associates, Inc. and am responsible for the development of the Seabrook Station Evacuation Time Study, Volume 6 of the NHRERP.

II. In response to the Town of Hampton Contention No. III, I submit the following response and comment:

A. Population Estimates. Basis A to the TOH Contention No. III is based upon incorrect statements which lead to misrepresentation of the contents of Volume 6 of the NHRERP.

Each of these will be addressed in turn:

C704030339 870325 PDR ADOCK 05000443 O PDR _.

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1. "KLD computes beach population capacitie's by examining only t$e beach above the high' tide line, Vol. 6,

p. 2-12."

Nowhere on page 2-12, or elsewhere in the ETE, is there a statement that comes anywhere near the quote cited above. In fact, on page E-6, it is shown that detailed examination of large-scale photos of the beach consisted of "a-count of people" [ emphasis added] where virtually all blankets were on dry sand above the high tide line. This dry beach area was measured and used to calculate person density -- not capacity. (Note that if we had measured the beach area to the low tide area, the value of density would have been commensurately lower.)

2. "[KLD] counts parking spaces rather than motor vehicles, including vehicles in transit, Vol. 6, p. 2-1."

Nowhere on p. 2-1, or anywhere else in the ETE, does there appear a statement that even remotely approximates i ..

l the above quote. To estimate the maximum number of vehicles (and people) that could occupy the beach areas, "we relied on i

empirical examination of the number of vehicles which can physically be accommodated within the beach area," p. 2-1. We-also counted parked vehicles (see pp. E-4, E-5 and 2-10) and -

vehicles in transit (see p. 10-16).

3. "[KLD] counts beach blankets rather than t

people, Vol. 6, p. 2-12."

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Nowhere on page 2-12,_or anywhere_else in the ETE, is there a statement resembling the above quote. See the response to number 1, above.

4. "[KLD] utilizes a vehicle occupancy rate of 2.4 based upon two " field surveys" performed on weekends of frequent rain and poor beach weather, Vol. 6, p. 1-10."

This quote is a complete fabrication, bearing no resemblance to any statement on p. 1-10, or anywhere else in the ETE. In actual fact,

• There were 36 surveys of vehicle occupancy --

not 2 -- as listed on 4-7.

• The estimate of 2.4 persons per vehicle was based upon the 6 surveys taken during fair weather and on crowded beaches during July 4th and 5th, 1986. See page 4-8.

• The counts taken during rainy weather which led to average occupancy rates of about 2.2 persons (p. 4-6) were discarded.

5. "[KLD] counts beach populations using a limited number of photographs, of unspecified date or time...,

Vol. 6, p. 2-10."

Nowhere is it stated that a " limited number" of photographs were used by the ETE. In fact:

• 9 sets of color slides of the entire coastal

• area were examined with each set consisting of about 55-slides (page-E-4) -- hardly a

" limited" number.

• The data representing the most crowded situation was that "on Sunday, August 11, 1985 [taken] in the early afternoon,"

page E-5.

6. "[KLD]... concedes the beach populations vary-widely depending on weather, time of day, and day to day.

Vol. 6, p. 2-10."

This conclusion is an outcome of "our studies"...,

hardly a " concession." Further on this page, it is noted that, in reference to beach population, "on a sunny day it generally peaks at about 2 p.m.," which is about the time the aerial photos used to determine parking analysis, were taken.

7. "[KLD] thereby unreasonably reduces the actual population for the Town of Hampton and distorts this

" critical" factor in computing ETE. Vol. 6, p. 2-1.

No evidence is presented to-support-this erroneous statement:

• The purported " actual population" is not provided by this statement, nor is any value suggested that is supported by empirical data; o

• The extent of the purported " reduction" is-not detailed;

• The " distortion" is not explained;

• Nowhere is it said that there is a " critical factor in computing ETE." Instead, it is stated that " estimates of demand constitute a critical element in developing an evacuation plan" (emphasis added).

B. Weather Conditions. This section, similarly to (A) above, is comprised of misquotations and otherwise incorrect and unsupportable statements.

• Nowhere on the cited page 3-1 is there a statement that weather represents a " major factor" affecting ETE. Weather is listed as one of many major factors which control capacity. We don't quarrel with the statement - just with the incorrect quoted attribution.

• Nowhere is it stated on the cited page 3-1 that KLD has " limited empirical data on the effect of adverse weather conditions to reduce ETE." In fact, KLD does provide the  ;

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results obtained from limited data, on the effect of rain on capacity -- not ETE.

Highway capacity reductions of 20 and 25 percent for rain and snow respectively were utilized in the ETE. These figures are responsive to the guidelines established by the 1985 Highway Capacity Manual. See p. 3-11, Volume 6. Nowhere does the Plan state that ETE are reduced in the presence of rain and snow. In fact, the calculations of ETE reveal that rain and snow increase ETE relative to clear weather (compare the ETE for Scenario 2 with those of Scenario 1, and the ETE of Scenario 7 with those of Scenario 5).

• This basis contends that the ETE " fails to provide any data on the impact of fog on ETE, Vol. 6,

p. 3-11." This cited page, however, provides three paragraphs of discussion regarding fog.

Public officials indicated that ocean fog is an unusual occurrence during the summer months, and when it does appear, generally dissipates at 9 a.m. or may appear after sunset, both times of 4

the day when beach population is significantly below capacity. Thus, Scenarios 1 and 2 are more severe than a scenario with early morning fog. l l

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Furthermore, the inclement weather scenario for rain can be used for widespread foggy conditions.

• The effect of ice storms on the ETE can vary l

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i-widely depending on the conditions of-ice on the pavement and on the temperature. The friction factor offered by an icy surface varies with temperature, increasing as temperature decreases below freezing. In the temperature range between 28 and 32 degrees F, the heated tire surface can ride on a film of water and traction is at a minimum. Under these circumstances, travel would be slowest.

An exhaustive literature search revealed no estimate of the effect of ice on highway capacity. In the absence of such data, a 25 percent reduction in capacity as used for snow, appears acceptable for the following reasons:

• Highway capacity during an ice storm may be less than that during.a snowfall, thus tending to increase travel time relative to Snow.

• There is no need to shovel a driveway in an ice storm, in general, thus tending to reduce trip generation time, relative to snow.

While we have no data to quantify these opposing trade-offs, it is reasonable to expect that the net effect is limited. Note, however, that under severe ice conditions, in the absence of sanding, some highway sections with extended upgrades may become virtually impassible.

Thus, sanding may be necessary to assure adequate traction on such highway sections. It is my understanding that sanding is a prevalent procedure in the area.

e C. Ro'ad Capacities

1. Nowhere does the ETE state that "all roads will remain passable during an evacuation." The cited page does state that "it is assumed that all roads are passable."

It is noted in responding to this basis that one intent of protective action decision making is to consider as many offsite conditions as is possible in the determination of the best course of action resulting in the least radiological exposure to the public in the event of a radiological release to the atmosphere. It is my understanding that the NHRERP provides for the maintenance of plume EPZ roads in order to ensu're that these roads are passable. (See Vol. 5, Letters of Agreement with towing companies.)

2. This basis complains that the ETE assumes traffic control measures are in effect. This assumption is based on the high probability that there will be sufficient time between official notification to man TCPs and the public Order to Evacuate, for the traffic control personnel to be mobilized and positioned.

Sensitivity runs have been performed to quantify the effects on ETE of traffic control measures not being in j l

effect. These tests indicate a reduction of about one hour in j ETE within 2 miles of the station, a smaller reduction in ETE for thor,e within 5 miles of the station and no change in ETE for l l

the EPZ as a whole during the summer. Those reductions in ETE reflect the fact that some evacuees from the beaches to the south of the station will use Route 1, southbound; under'the controlled evacuation, these evacuees are, restricted to use i

I-95. This restriction, in turn, is responsive to requests made by police chiefs in Newburyport and Newbury to maintain Route 1 as free of evacuating traffic from the north, as is.possible.

In the absence of control, evacuating traffic will exploit the capacity available on Route 1 and will be able to evacuate tie inner region of the EPZ to the south of the Station, more rapidly. The computed analyses of non-compliance cases reveal that the ETEs are not adversely impacted by any absences of guides at TCPs, providing that TCP F-EX-94 and TCP D-HA-02 are manned;The TCP's are assigned the highest priority. In conducting this study, it was assumed that evacuees generally travelled away from the Power Station.

This basis complains that the assumption that traffic control measures are in effect is unsupported due to  ;

referenced RAC Review comment which questions the State's ,

ability to provide adequate evacuation transportation. This reference within the basis is not supportive'of the original complaint, and is therefore without merit.  ;

3. The TOH contention number-III complains about the number 3000 in reference to "through" vehicles. On page 2-27 it is clearly stated that these are external-external trips which are already on the highways at the time of the ,

i accident, and page 10-3 notes that these vehicles are not I l

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otherwise counted. The contention exhibits a lack of understanding of the' distinction between " peak hourly flow," and the estimated number of through vehicles-on the network at the time of the order to evacuate. (Note that this estimate is-not "at the time of notification of an emergency" as claimed in the contention.)

Peak hourly flow is the maximum number of vehicles that can reasonably be expected to traverse a point (or uniform section of) a lane or roadway, over one hour, under prevailing I

roadway traffic ~and control conditions, and has the units vehicles per hour. The cited estimate of 3000 vehicles is with regard to the number of vehicles on the highway system at a

, specified point in time, and has the units vehicles. There is

no relation between " peak hourly flow" and this estimate.

l The primary routes servicing external-external trips through the Seabrook Station EPZ are the Interstate Routes 95 and 495. All other routes within the EPZ, which could be interpreted as through routes (e.g., Routes 1, 107, 108), are i

two-lane roads which are not relatively attractive to through travelers. About 230 lane-miles are provided by these express routes:

• I-495: 2 miles @ 4 lanes; 5 miles @ 6 lanes

• I-95: 21 miles @ 8 lanes; 4 miles @ 6 lanes

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The calculations of ETE for the summer scenarios assume that the accident takes place when the beaches are at

1 maximum usage, roughly at 2:00 p.m. When developing the inputs to the IDYNEV model, it was estimated that 3000 through ,

i vehicles, not otherwise counted, would be on the network at this time. This estimate was based on observations made while traveling the network. Specifically, it appeared that volumes 1 on I-95 and on I-495 were traveling at Levels of Service (LOS) that did not exceed LOS B or C. The associated range of density is 13-30 passenger cars per mile per lane. Thus, the total number of vehicles on these highways is between 2990 and 6900, many of which are not through vehicles.

Of course, this estimate of 3000 through vehicles represents those who entered the EPZ prior to the implementation of access control and have not as yet completed their travel through the EPZ by the time the Order To Evacuate (OTE) is given. At that time, the number of through vehicles within the network could be substantially less than the number which occupied the network at the time the access controls are applied. Thus, it is seen that the number of external-external vehicles on the EPZ network at the OTE should not exceed the 3000 estimate, and may be substantially less.

Direct observations of traffic flow on these major routes provided by aerial films taken on July 4 and 5, 1986 at approximately 2:00 p.m. (after the ETE calculations were undertaken), indicate that traffic volume is very low - LOS A and B. The associated range of traffic density is less than 20 passenger cars per mile in each lane. ,

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Thus, based on these later observations, the total I

number of vehicles on these highways at this time is less than I or equal to approximately 4600 passenger cars (20 x 230). Many i

of these cars, of course, belong to EPZ residents, tourists and employees who have already been counted. It is seen, therefore, that the estimate of 3,000 through vehicles -- not already counted -- is realistic.

Traffic on these highways during the off-season generally does not exceed the volume associated with LOS C, regardless of time of day. Thus, the estimate of 3,000 through vehicles is applicable throughout the year.

The NHRERP calls for access control points to be established at the periphery of the EPZ which will divert traffic from entering the EPZ from points outside except, of course, those vehicles which will participate in the evacuation (Vol. 1, 2.6-16).

4. Nowhere does the ETE " admit" that the estimtes of highway capacities would generate "an unreasonably low ETE".

In fact, the detailed discussion in Section 3 of Volume 6 testifies to the care and conservative posture used to properly estimate capacity.

The cited quotation, " estimates of available capacity may overstate the actual accessible ~ capacity," pertains l

only to the entries in column 6 of Figures 10-10, " Evacuation Capacity per hour," which are responsive to Appendix 4 of l NUREG-0654. The earlier paragraphs on page 10-10 describe how

these values were computed. These entries are largely of general interest $ only, and are not used in the calculation of the ETE.

Specifically, these entries of capacity in Tables 10-10 indicate the potential aggregate capacities of all outward-bound highways which are intersected by arcs of 2, 5 and 10-mile radii, respectively, centered at Seabrook Station. This potential capacity can only be partially exploited, since network topographical constraints limit the access of traffic to some of these routes. It is primarily for this reason that these entries are of limited interest.

In contrast, the calculations of ETE are based upon a rigorous analysis of traffic demand interacting with actual link-specific capacity constraints, using the IDYNEV model developed for FEMA. These calculations do not utilize the aggregate potential capacity values entered in Tables 10-10.

5. This basis complains that the ETE assumes estimates of 25% for Hampton employees who work at the beach "by simple guess work," and therefore lacks adequate data to compute road demand for Hampton employees during evacuation.

The use of the cited 25 percent figure to indicate  !

employees who work at the beach within the Town of Hampton (and Rye) was actually used to estimate the number of employees who work away from the beach area since, as stated on page 5-6, the vehicles of employees who work at the beach have already been accounted for. The ETE states that the estimate of beach 1

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m population is based on parking capacity and on vehicle occupancy.

The values assigned to these percentages are based on the seasonal employment picture shown in Table 5-2 which documents the significant summer employment in Hampton and Rye, and by observations made during a survey of the EPZ. The net effect of applying these estimates is to assert that about 845 vehicles of employees during the summer months who live outside the EPZ (out of some 25,059), are subsumed within the beach population (see difference in sums of last two columns of Table 5-4). This estimate of 845 employee vehicles at the beach, which amounts to about 3.4 percent of the total number of employee vehicles, and 0.8 percent of the total vehicle population within the EPZ, appears to be reasonable.

Furthermore, the application of these percentages is limited to the summer scenarios. This is seen by comparing the last two columns of Table 5-4. In the last column, the off-beach (i.e., inland) employees are used for the summer scenarios by applying the percentages of 25 for Hampton and Rye, and 10 for Seabrook, Salisbury and Newbury. The employees at the beach are indistinguishable from the tourists there, who will also be evacuating. In the off-season (next-to-last column), all employees are treated as such, since there are few 1 tourists at that time.

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6. Nowhere is it stated that disabled " vehicles will simply be pushed aside by evacuees, without-impacting on ETE."

A car parked on a shoulder, with no activity associated with the processing of an accident vehicle, would have a negligible effect on traffic flow. For example, the narrowing of a lane, due to maintenance or construction i

purposes, to 10 or 11 feet widths, provides a capacity of about 4

1800 vehicles / hour / lane as described on page 6-13 of the Highway i Capacity Manual. This figure compares with the value of 1728 selected for the ETE study (see page 3-10).

Even if a vehicle is stored at a point on a highway where there is little or no shoulder room, there is still sufficient room for the traffic to move around the disabled vehicle even if it means encroaching, somewhat, into the oncoming lane of travel on a two lane road. In situations like this, the dominant flow of evacuating traffic which would t

l be in the outbound direction would effectively "take over" that ii section and traffic would move past the obstruction. The

" minor" traffic flow in the inbound direction'would take J

advantage of any gaps in the evacuation traffic.

In the HCM chapter on Intersection capacity, the impact of a lane of parked, motionless cars can reduce capacity by up to 10 percent (Table 9-8 in HCM); a single parked car should produce a lesser effect. The conservative estimates of capacity by KLD, coupled with a 15 percent further reduction in I

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capacity during congested conditions, takes into account any

-short-term disruptions.

The ETE has reasonable expectations that, under 4 emergency conditions, there could be produced somewhat' uncertain responses on the part of the evacuating public. For example, it l

must be anticipated that some vehicles will exhaust their' fuel' supply and will have to be pushed to a shoulder or driveway.

4 Such short-term disruptions also serve to reduce- capacity for:

short periods of time, and justify the conservative posture we have adopted. We believe that this posture is prudent and j responsive to the intent of NUREG-0654.

Finally, the assumption that vehicles will be 4 pushed to the side of the road is supported by historical i

j record. " Evacuation Risks -- An Evaluation," Publication

, No . 235, 344, Joseph M. Hans, et al, June, 1974, is an analysis i

of over 50 emergencies requiring the evacuation of a total of

! 1,142,336 persons. Page 51 of this document states that'" cars j with mechanical breakdowns were pushed off the road and their i occupants were absorbed in other evacuating vehicles." Page 45

of this document references the publication entitled " Images of Disaster Behavior

Myths and Consequences," Quarentelli and -l Dynes, 1972. Based on this report, Hans et al-references people within disaster situations as being "neither devoid-of I initiative nor passively dependent or expectant that others, especially relief and welfare workes, will take care of them and i

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( f their disaster created needs. . In fact,I $haster victims / l r , ( ' . i, .

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- sometimes . insist on acting on their own. " ' / ' 1, . V, 4A )

D. ETE Preparation Time Appendix 3, NUREG-0654 providas, as the initial-minimum acceptable design objective for coherage by the public '

notif1' cation system the capability for,providing an alert signal '

y "throughout the 10-mile EPZ within 15 minutes." Thik design e

criteria provides basis for the S3 percent plume EPZ population:

notification within 15 minutes. >

g The assumption of an average 30'-minute walk time from beach to car is reasonable considering normal distances 4

s 3 traveled by beach goers from their cars to resting areas upon the beach. The entire sentence quoted under this basis reads

.t "While we have no empirical data to support '

this distribution,

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we do know the physical domain of the beach area and the ,

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r activities involved." Further, this section of the ETE reads N' A. 4

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i that "since we know tnat congestion will occur on the beach

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areas during the summer (>and that evacuation time will exceed

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Trip Generat' ion time, any inaccuracies in trip distribution will ,

not influence the ETE. Thus, an approxmate, reasonable i

distribution will satisfy our needs."

A delay of 15 minutes preparation time at the

transportation staging areas was assumed for the movegent of j Il vehicles in and out of the areas. (Volume 6,'p. 11-20). The

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'N3 r ETEprovibesforonehourpreparationtimeforthe transportation staging areas to be ready to receive vehicles.

The contention references p.4-9 when complainirg the ETE

• grossly underestimates the impact of 95% of workers L

re' turning home within.30 minutes. The references page clearly states that the distribution shown represents " time to prepare to;1ea've work." Figure 11-1 on page 11-17, the appropriate A \

refeydace for this concern, indicates that 70-75% of commuters would arrive home within 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of the evacuation order, under t

normal rush hour conditions. Commuters returning home against the flow of evacuating traffic will experience reduced i

resistance due to minimized traffic, while commuters evacuating with $h'e traffic will.be initiating the first step of the evacuation process. The net effect on the ETE would be limited.

This basis fails to identify the precise area whereby the impact

to the ETE is " grossly underestimated."

. E. Growth

! There exists no current regulatory requirement to 1

project into the future when formulating ETE. In accordance with NUREG-0654, Appendix 4 which states that the " evacuation

.r time estimates should be updated as local conditions change,"

the ETE will be subject to the continuous planning process as an j element of the entire NHRERP.

Moreover, this basis falsely states in reference i

toemhloymentgrowththat"incomputingtheETE,however,:KLD

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- has wholly failed to account ^for this reasonably anticipated and '

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substantial growth in population and motor' vehicles within the EPZ." The page cited under this basis, however, reads: "it is very tenuous to project employment figures for 1986 since employment is usually sensitive to the general health of the nation's economy and, of course, the regional economy.

Nevertheless, age have projected these figures forward to 1986, using...the mean annual growth rate over 4 years, for the New

' Hampshire towns. These projections are also given in Table S-1."

F. Choice of Host Locations _

This element complains that the ETE assumes evacuees will choose to evacuate to assigned host communities, which this basis states is particularly unsupportable due to the large numbers'of beach goers and transients during the summer months who may be unfamiliar with host communities. Several elements within the ETE and NHRERP in' general must be raised in response to thi s basis.

1. The precautionary early closing of'the beaches does not consider the immediate opening of reception and mass care centers for this population-segment. The EBS message for beach closing directs these persons to leave the area l l

immediately lVol. 4, p. G-13). There is no need for this population sewment to report to host communities until and unless the order to evacuate.is given. At that time, EBS l

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messages will provide direction for all evacuees to travel to theLappropriate reception centers and TCPs will be established to provide route guidance.

2. Public Information flyers are to be provided to restaurants, hotels, motels, rooming houses,-schools, camps, health care facilities, parks and State forests (Vol. 1,

p. 2.3-2).

3. The NH public information program also includes posters prepared by NHCDA for display in public places and' state lands (Vol. 1, p. 2.3-2).

4. Emergency public information will be contained on dedicated pages in plume EPZ telephone books (Vol. 1, p. 2.3-2).

5. Touris+s that enter an area with'which they are particularly unfamiliar will, in all likelihood, have in their possession maps of the area to avoid getting lost during their vacation.

6. The traffic control points are established to

" facilitate evacuating traffic movements which serve to expedite travel out of the EPZ along routes which the analysis has found to be most effective." (Vol. 6, p. 7-1) Hence, direction is provided throughout the E?Z along designated routes.

7. Once outside of the ETE, there is no mandatory requirement placed on individual citizens to report to a host community. Reception centers are established for.the evacuating public to provide " services for any evacuated

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population in need of public assistance (Vol. 1, p. 1.6-6). The EBS messages which advise evacuation provide information as to what services are available at the reception centers (Vol. 4,

p. G-31 and p. G-37). However, it is an option for evacuating.

persons to refer to reception centers for assistance.

8. The NHRERP calls for Strip maps to be available at all transportation drivers in reaching their designated destinations.

It is reasonable, based on the foregoing ETE and other NHRERP elements, to assume that both permanent resident and transient populations will have adequate access to information regarding appropriate evacuation routes. However, sensitivity tests conducted using IDYNEV to examine non-compliance with the recommendad routing have found that the ETE for the entire EPZ was not affected, so long as'the general direction of evacuating traffic was away from the Power Station.

Additional Contentions (11/19/86)

C.7 a. Nowhere in the ETE or RERP are provisions made for access or traffic control managers "to question each vehicle driver." Please refer to Section F, " Choice of Host Locations,"

of this submission, for a detailed account'of information dissemination strategies.

b. This basis is false. Traffic control is applied i

at all intersections where there are competing flows of j

evacuating traffic and where downstream capacity constraints may.

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not prove to be the limiting factor. For example, no control was specified at nodes 1 and 2 since the constraining factor on service flow (i.e., the rate at which traffic can be serviced along the path 1 - 100 - 99 ...) is limited by the capacity of link (100,99).

It would be inappropriate to specify a control at, say, node 1. In a real-world emergency, the traffic guide at TCP E-NB-01, located at node 1, would move traffic through that intersection in a manner that fully utilizes-the capacity of that intersection. Even if no traffic guide were there, traffic would certainly not queue at a red signal indication if there were no conflicting demand.

The contention that this treatment lowers ETE is not correct. As indicated on Figures 10-2, the links servicing traffic from Plum Island through node 1 are congested for at least 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> while servicing some 3060 vehicles. Link (1,100) is considered a " Low design" highway section with a one-way capacity of 1167 vehicles per hour, as shown on page 3-9 of the ETE. On this basis, assuming no downstream impedance, link (1,100) would have been able to clear in [3067/1167]=2.63 hours7.291667e-4 days <br />0.0175 hours <br />1.041667e-4 weeks <br />2.39715e-5 months <br />, regardless of the specifics of control applied at node 1. In fact, it actually took well over 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> to clear this link due to impedance at points downstream on the evacuation path.

Thus, it is seen that the ETE is realistic and that the contention is without merit. l 4

c. The effects of " light" traffic patterns, representing traffic counterflow to the evacuating traffic, are included in the capacity calculation of the roadway system.

Vol. 6, p. 3-9 assumes a directional split of traffic on all two-way road sections of 0.9; that is, 90% of all traffic is outbound and 10% inbound averaged over the time frame of the entire evacuation; the outbound traffic.is evacuating while the inbound traffic is the " light" counterflow traffic. These data are used explicitly in the calculation of capacity of the outbound sections of roadway. Therefore, the effects of inbound flow is included in the ETE calculations through the capacity calculations process.

d. The issue of the impact of disabled vehicles on the ETE is discussed under Item 6 of Section C abnve.

e. As detailed in Section 2, the ETE calculation is based on empirically derived estimates of trip-generation time distributions. Nowhere in the ETE does it say that evacuees leave "promptly."

Sensitivity tests have been conducted using IDYNEV to examine non-compliance with the recommended routing. It was found that the ETE for the entire EPZ was not affected.

The underlying rationale for this result is that a scenario of reasonable non-compliance does not constitute a disturbance of the fundamental traffic demand-supply relationship. It is this relationship which determines the ETE.

Thus, as documented by the computed results, non-compliance l

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which is undertaken in a manner which reflects-the evacuees

objective of protecting their health and safety does not lengthen the ETE within'the Seabrook EPZ.

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f. The cited speed estimates for buses are those for-traveling toward the-EPZ and are used to calculate inbound travel time. These estimates are mean speeds (see page 11-19) which are selected to account for higher speeds outside the EPZ (see Figure 2-14 of the 1984 HCM) combined with lower speeds within the EPZ. Thus, virtually all traffic within the EPZ, ,

with the exception of those vehicles ~on.the Interstate system, j will be traveling relatively slowly.

Nowhere is it stated that "all" accidents will occur at low speed. On page 12-1, the Plan states that "most l

accidents involving vehicles traveling at low speeds will not

result in vehicle disablement."

g. Sensitivity tests have been conducted, each of which postulates 10 road blockages at different locations throughout the EPZ. This number reflects. current accident rates, nationwide, applied to the vehicle population within the EPZ in the summer. These tests indicate that such-blockages, of l

various durations, could extend the Scenario 1, Region I ETE by amounts which range up to 1:00 beyond the 6:15 value cited in l

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the ETE. 3. Based on the foregoing, it is my opinion that the Evacuation Time Estimate, Revision 2, Volume 6, is based upon accurate and unbiased factual data and reasonable assumptions, and complies with appropriate NRC regulations.

"Y ~

Edward B. Lieberman STATE OF NEW YORK d F # O / A:' , ss MarchJ2k 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 herein are true to the best of his knowledge.

Before me, 8

,i - j,q e

j M 6)

N W ry Public f

My Commisison Expires:

ROCHELLE LANDSMAN Nowy Public, State of New York No. 52-4742519 Qustified in Suffo!k Co aty Commission Expires March 30.19 i

l

e 'e 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 Er.gineering in 1967 from Polytechnic Institute

of Brooklyn. 1 am currently working on a Doctorate degree j in Transportation Planning at the Polytechnic University. I I am a member of the Chi Epsilon Honorary Fraternity.

With almost 30 years of professional experience, I have i .

] 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 1

analysis and design of traffic control systems to expedite traffic flow and. relieve cutgestion.

I have developed simulation models to study traffic performance on urban networks, freeways, freeway corridors 4

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 g 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 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 equilibrium traffic assignment model and a macroscopic dynamic traffic simulation model designed for all types of roadway facilities (urban streets, freeways, rural roads).

l DYNEV is designed to be used as a tool to develop and '

organized evacuation plans needed as part of general e

~

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 useo 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 1

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 j 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.

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

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NETSIM microscopic traffic simulation model developed for 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 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 UTSC Project, as well as a bus preemption policy to enhance 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 led a group of traffic engineers and systems analysts in developing a system of n.acroscopic traffic simulation models designed to evaluate Transportation Systems

. Management (TSM) strategies. This software system, named TRAFLO, also includes an equilibrium traffic assignment .

model. This model has been distributed to other agencies including FEMA.

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I designed an " Integrated Traffic Simulation System,"

- 1

' named TRAF, which will eventually incorporate all the best  !

i traffic' simulation models available. Using structured l programming techniques, TRAF integrates: NETSIM, TRAFLO, 4

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 l

j model to study intersection delay as a function of traffic volume, a type of control and geometrics. In turn, I i developed and documented new signal warrants, some of which 1

will be incorporated in the next version of the Manual on Uniform Traffic Control Devices (MUTCD).

1 Under NHTSA sponsorship, I directed a research study to i

evaluate a Driver Vehicle Evaluation Model named DTRVEM.

l This model simulates the response of motorists to hazardous i

events. This effort included analysis of the model i  !

formulation and software and sensitivity testing. A J

workship was designed, organized, scheduled and conducted by myself and other KLD professionals; experts from all over i

the U.S. were invited to recommend specific NHTSA research activities for the further development of the model. A i recommended research program constituted the major output of the contract.

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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.

! l 1

1 i

" Simulation of Traffic Flow at Signalized Intersections: the SURF System," Proceedings, 1970 Summer Computer Simulation Conference, 1970.

! " Dynamic-Analysis of Freeway Corridor i

Traffic," SME paper, Trans. 70-42.

! " Simulation of Corridor Traffic: The-SCOT Model," " Highway Research Record No. 409, 1972.

e l " Logical Design and Demonstration of-UTCS-1 Network Simulation Model,"

' Highway Research Record No. 409 , 1972 j with R. D. Worrall and J. M.

Bruggerman).

i j " Variable Cycle Signal Timing Program:

Volumes 1-4," Final Report of Contract i

DOT-FH-11-7924, June, 1974.

i

" Traffic Signal Warrants," KLD TR-51, Final Report on NCHRP Project 3-20/1, 1 December 1976 (with G. F. King and R.

! Goldblatt).

4 i " Rapid Signal Transition

! Algorithm," Transportation Research

' Record No. 509 , 1974 (with D. Wicks).

i

! "Subnetwork Structuring and Interfacing I for UTCS Project-Program of Simulation l Studies," KLD TR-5, January, 1972.

" Development of a Bus Signal Preemption Policy and a System Analysis of Bus Operations," KLD TR-11, April,~1973.

i I

"SIGOP-II - Program to Calculate f optimal, Cycle-Based Traffic Signal l l Timing Patters, Volumes 1 and 2," Final l i Report, Contract DOT-FH-11-7924, KLD l i TR-29 and TR-30, December, 1974.  !

l Summary report inTransportation Research l

Record 596, 1976 (with J. Woo).

l

! " Developing a Predictor for Highly l Responsive System-Based Contro,"

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

i 1 i .

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

Transportation Research Special Report 153 - Better Use ofExistinq

! Transportation Facilities, 1976.

l

" Network Flow Simulation for Urban i Traffic Control Systems," Vols. 1-5, PB230-760, PB230-761, PB230-762, PB230-763, PB230-764, 1974 (with R.

4 Worrall), Vols. 2-4 updated 1977, KLD TR-60, TR-61, TR-62 (with D. Wicks and 4 j J. Woo).

J

" Extension of the UTCS-1 Traffic d

Simulation Program to Incorporate i Computation of Vehicular Fuel Consumption and Emissions," KLD TR-63, j 1976 (with N. Rosenfield).

I

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

i i

{ " Urban Traffic Control System (UTCS) i Third Generation Control (3-GC) Policy,"

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

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

" Revisions to the UTCS-1 Traffic j Simulation Model to Enhance Operational  ;

i Efficiency," KLD TR-59, 1977 (with A.

Wu).

i "The Role of Capacity in Computer Traffic Control," in Research Directions in Computer Control of Urban Traffic i Systems, ASCE, 1979.

l j " Traffic Simulation: Past, Present and

Potential," in Hamburger, W.S. and 1 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

/

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• Annual Meeting of the Transportation i

Research Board, 1980 (with B. Andrews).

" Determination of the Lateral Deployment of Traffic on an Approach to an Intersection," presented at the 59th j Annual Meeting of the Transportation

! Research Board, 1980.

j " Service Rates of Mixed Traffic on the 1 Left-Most Lane of an Approach,"

presented at the 59th Annual Meeting of

the Transportation Research Board, 1980 j (with W. R. McShane).

" 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 4

Simulation Model," presented at the 59th

! Annual Meeting of the Transportation l Research Board, 1980 (with M. C.

l 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.

i

! "The TRAF System - Anayltic Formulation i and Logical Design of the Roadsim Model," KLD TR-129, June, 1983.

l I

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

i "The TRAF System - Technical Report,"

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

i Yedlin, B. Andrew and K. Sheridan).

" Application of the I-DYNEV System to Compute Estimates of Evacuation Travel

! Time at Nuclear Power Stations -- Four  !

l Demonstration Case Studies," KLD TR-142, l l December, 1983.

I " Users Manual for the Interactive

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

I I

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I

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

KLD TR-154, March, 1984. 1 "PREDYN/IDYNEV Training Guide," KLD f TR-155, April, 1984 (with R. Goldblatt).

l

" Specification of Recommended )

Interactive Graphics Hardware j 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. 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.

" 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, 4

TRB, National Research Council,

. Washington, D.C., 1986, pp. 49-57 (with I

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.

" 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, January, 1987 (with A. K. Rathi and M.

Yedlin).

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

Andrews and A. Santiago).

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