ML20206M400

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Affidavit of Tj Adler Re Offsite Emergency Planning Issues. Prof Qualifications Encl
ML20206M400
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 04/13/1987
From: Adler T
SEACOAST ANTI-POLLUTION LEAGUE
To:
Shared Package
ML20206M223 List:
References
OL, NUDOCS 8704200103
Download: ML20206M400 (6)
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APR y 5g,y UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the ATOMIC SAFETY AND LICENSING BOARD

)

IN THE MATTER OF )

) DOCKET NOS. 50-443-OL PUBLIC SERVICE COMPANY OF ) 50444-OL NEW HAMPSHIRE, et al ) (Off-site Emergency (Seabrook Station, Units 1 ) Planning Issues) and 2) )

)

AFFIDAVIT OF DR. THOMAS J. ADLER My name is Thomas J. Adler, and I hereby depose and say as follows:

1. I have been retained by the Intervenors in the Seabrook Nuclear Power Plant Licensing proceeding to review and assess the evacuation time study and traffic management plan contained in Volume 6 of the New Hampshire Radiological Emergency Response Plan.
2. I have a PhD in Transportation Systems from MIT, taught at Dartmouth College's Thayer School of Engineering in the areas of transportation planning / engineering and computer-based modeling methods, and have extensive experience in planning, analyzing, and evaluating transportation systems at the local, regional, national, and international levels. A resume is attached.
3. I have reviewed the affidavits prepared by Edward B. Lieberman dated March 25,1987 which were prepared to support the Applicant's Motions for Summary Disposition, dated March 25,1987.
4. The statement in the Lieberman affidavit that there is little there is little impedance to emergency vehicles entering the EPZ is not supported because:

a) The bus mobilization survey referenced in NHRERP Volume 6 Revision 2 was not based on a formal survey instrument and written records of the phone conversations were not maintained; thus the results of the survey cannot reasonably be accepted.

b) Trips resulting from commuters returning home from work were not modeled at all in any of the evacuation scenarios described in Volume 6, even though they would add a significant amount of crossflow and counterflow traffic impeding the flow of emergency vehicles, c) The impeding effect of outgoing traffic moving around disabled vehicles has not been modeled.

d) The delays at access control points caused by identification checks, as specified in NH G7042OO103 870415 PDR ADOCK 05000443 G PDR

. . i Radiological Emergency Response Training Module 13, and at other intersections in the EPZ will cause average vehicle speeds to fall below the 40 to 50 mph range assumed in Volume 6.

5. The Lieberman affidavits indicate that sensitivity runs have been performed which indi-cate that failure to staff the access control points will reduce the total ETE.

a) At a minimum, these analyses ignore an essential function assigned in the NHRERP to TCP (traffic control personnel), which is to (p.12-3) "... report to the EOC that a

[ traffic] blockage has taken place." In the absence of this reporting capability, major roadway obstructions would likely remain for extended periods and would substantially lengthen the ETE.

b) Without more complete documentation of these sensitivity runs, it is impossible to determine how the affects ofinadequate staffing were actually modeled. For example, a major problem would occur if access control points on I-95 in Maine and Massachusetts were not staffed immediately. Heavy volumes of northbound and southbound through traffic would continue to compete with evacuating traffic for use of this key artery; if these effects are not modeled, the sensitivity analyses are not meaningful representations of the actual effects of failure to provide timely staffimg of the ACP's and TCP's.

Signed under the penalties of perjmy this 13th day of April,1987.

7% ,

Thomas J. Addr s

s .

THOMAS JAY ADLER

-WORK ADDRESS: HOME ADDRESS:

- Resource Systems Group Upper Pasture Route 5 South Norwich,VT 05055 P.O. Box 1104 802-649-1084 Norwich,VT 05055 802-649-1999 Born: August 22,1950; Portland, ME EDUCATION B.S. Cornell University (Civil & Environmental Engineering),1972 S.M. Massachusetts Institute of Technology (Transportation Systems),1975 Ph.D. Massachusetts Institute of Technology (Transportation Systems),1976 PROFESSIONAL EXPERIENCE 1986 - Present President, Resource Systems Group; Principal in Charge for transportation projects.

1984 - 1986 Research Associate Professor of Engineering, Thayer School of Engineering, Dartmouth College. Coordinator of Master of Science Program in Resource Systems at the Resource Policy Center. Graduate and undergraduate instruction in transportation, resource policy, systems modeling, and engineering sciences.

Principal investigator on numerous sponsored projects.

1982- 1984 Acting Director, Resource Policy Center, and Associate Professor of Engineering, Thayer School of Engineering, Dartmouth College; Adjunct Associate Professor of Policy Studies, Dartmouth College.

1976 -1982 Assistant Professor of Engineering, Thayer School of Engineering, Danmouth College.

1975 - 1986 Independent transportation consultant for state, regional and local agencies.

Transportation consultr.nt for Cambridge Systematics, Inc., Kendall Square Bldg., Cambridp, MA; consulting on various national transportation research projects. -

1975 - 1976 Research Fellow, Joint Center for Urban Studies of Harvard and M.I.T.

Involved in interdisciplinary program of urban studies.

1973 - 1976 Research and teaching, Transportation Systems Division, M.I.T. Primary research on U.S. DOT contract to M.I.T. entitled " Experiments to Clarify Priorities in Urban Travel Demand Forecasting Research and Development."

1972 - 1973 Research Assistant, Transportation Systems Division, M.I.T. Research on U.S.

DOT (Transportation Systems Center) contract to M.I.T. to study the computer requirements of a transportation research agency.

1971 - 1972 Civil engineering consultant, Carrol E. Taylor and Associates, Auburn, ME.

1 Responsible for the development of computer software for the analysis of structural and waste water collection systems.

2 PROFESSIONAL ACTIVITIES Transportation Research Board. Member and Incorporator, International Network of Resource Information Centers (INRIC). Member, American Society of Civil Engineers, American Society for Engineering Education.

AWARDS AND HONORARY SOCIETIES Chi Epsilon, Civil Engineering Honorary Society Sigma Xi, Scientific Honorary Society Catherine B. Wurster Fellow, Joint Center for Urban Studies of Harvard and M.I.T.

PUBLICATIONS

" Formulation of Travel Demand Modeling Requirements", with J. Bottom. Working Paper DOT-WP-1, Transportation Systems Division, M.I.T.,1973.

"A Joint Choice Model of Social-Recreational Travel", with M.E. Ben-Akiva. Working Paper DOT-WP-10, Transponation Systems Division, M.I.T.,1975.

" Comparison of Two Travel Demand Modeling Systems: The M.I.T. Disaggregate Behavioral Models and the Urban Transportation Model System", with M.E. Ben-Akiva.

Working Paper DOT-WP-13, Transportation Systems Division, M.I.T.,1975.

Experiments to Clarify Priorities in Urban Travel Forecasting Research and Development:

Summary Report, with M.E. Ben-Akiva and J. Jacobson. Prepared for U.S. DOT contract with M.I.T., DOT-OS-30120,1976.

Modeling Non Work Travel Patterns. Center for Transponation Studies (CTS) Report, M.I.T., Cambridge, MA,1976.

" Joint-Choice Model for Frequency, Destination, and Travel Mode for Shopping Trips",

with M.E. Ben-Akiva. Transportation Research Record #369, Transponation Research Board, Washington, D.C.,1976.

"Disaggregate Models of Trip Distribution", with S.R. Lerman, in Behavioral Travel-Demand Models. Lexington Books, D.C. Heath and Co., Lexington, MA,1976.

"A Theoretical and Empirical Model of Trip Chaining Behavior", with M.E. Ben-Akiva, Transportation Research, Series B, Methodology,13B, pp. 243 - 257,1979.

The Direct and Indirect Costs of Transporting Wood Chips to Supply a Wood-Fired Power Plant, with M. Blakey and T. Meyer; report submitted to the U.S. Department of Energy Solar / Biomass Division under Contract EG-77-C-0204487, DSD #103, February 1978.

" Directions for Improvements in Urban Travel Forecasting Procedures", with M. E. Ben-Akiva and S. Lerman; in Conference Sanmary and White Papers, U.S. Department of Transponation,1979.

Techniquesfor Analyzing the Performance ofRural Transit Systems, Vols. I & II, with S.R. Stearns and Y.J. Stephanedes, prepared for U.S. Department of Transportation, Research and Special Project Administration under Contract DOT /OS/80006, September 1979.

3 "ENTRANS: A Model of the Interactions Between Energy Supply and Transportation Energy Use," in Proceedings of the Summer Computer Simulation Conference,1979.

"Disaggregate Models for Decisions Other Than Travel Mode Choice," in New Horizons in Travel-Behavior Research, W. Brog and P. Stopher, eds.,1980.

" Forecasting Experiments for Rural Transit Policymakers," with Y. Stephanedes, Transponation Research Record #718, Transportation Research Board, Washington, D.C.,

1979.

Interactions Between Energy Supply and Transportation-Related Energy Use, Vol. I, with J. Ison and J. Geinzer, final report submitted to U.S. DOT under Contract DOT /RC/82003, DSD #182, January 1980.

Interactions Between Energy Supply and Transportation-Related Energy Use, Vol. II Technical Appendices, with J. Ison and J. Geinzer, final report submitted to U.S. DOT under Contract DOT /RC/82003, DSD #183, January 1980.

" Analysis of Long-Term Transportation Energy Use," with J.W. Ison, Transponation Research Record #801,1981.

Analvsis of Transportation Energy Conservation Policies Using the ENTRANS Model, with 1.W. Ison, Solar Energy Reseamh Institute report, January 1981.

Guide to Forecasting Travel Demand with Direct Utility Assessment, with G.A. Kocur and others, U.S. DOT, Urban Mass Transit Administration, Report UMTA-NH-11-0001-82-1, September 1982.

Transportation of U.S. Coal Through Eastern Ports, with F.W. Lipfett and others, Report prepared for U.S. DOE under contract DE-AC01-81FE-20036, September 1982.

TechnicalReview of the ORNL Highway Gasoline Demand Model, report DE-AC01-81El-11976, U.S. Department of Energy, Energy Information Administration, February 1982.

"Long-Term Effects of Auto Fuel Efficiency Regulation," presented at TIMS/ORSA Joint National Meeting, Detroit, Spring 1983.

"Use of Microcomputers for Resource Planning," presented at Second Annual Meeting of the Balaton Group, Csopak, Hungary, September 1983.

Paratransit Planning System PARAS Cost Model Description, with H. Hazard, DSD #495, U.S. DOT Report UMTA-NH-06-0002-1, January 1983.

Low Density Transit Planning Package, with S. Tahmosh and M. Burton, turnkey i PASCAL software system, distributed by U.S. DOT UMTA, February 1984.

" Review of Recent Advances in Travel Demand Analysis," Transportation Science, V.18, N. 3, August 1984.

An Analysis of Wood Transport Systems: Costs and ExternalImpacts, USDA Forest Service Report 23-729, March 1985.

A Review ofFORECASTS, with D.L. Meadows, prepared for Defense Communications Agency, September 1985.

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4 COURSES TAUGHT DARTMOUTH COLLEGE:

GraamreLevel Transportation Systems Analysis

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Transportation Engineering Travel Demand Forecasting Models in the Policy Process Probability and Statistics Optimization Modeling Consumer Choices Resource Models UndergraduateLael Introduction to Computer Science Engineering Economics and Optimization Optimization Applied to Environmental Engineering Modeling Complex Systems MASSACHUSETTS INSTITUTE OF TECHNOLOGY:

Travel Demand Forecasting (Summer course for practicing professionals)

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