ML20214N561
| ML20214N561 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/22/1987 |
| From: | Urbanik T NRC, TEXAS A&M UNIV., COLLEGE STATION, TX |
| To: | |
| Shared Package | |
| ML20214N501 | List: |
| References | |
| OL-3, NUDOCS 8706020213 | |
| Download: ML20214N561 (6) | |
Text
>*
UNITED STATES OF AMERICA
.s NUCLEAR REGULATORY COMMISSION
~
DEFORE TIIE ATOMTC SAFETY AND LICENSING BOARD In the Matter of
)
)
LONG ISLAND LIGIITING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
REBUTTAL TESTIMONY OF DR. THOMAS URBANIK II ON DEHALF OF TIIE NRC STAFF ON CAPACITY ANALYSIS IN TIIE VICINITY OF RECEPTION CENTERS Q.1.
State your name and occupation.
A.I.
My name is Thomas Urbanik II.
I am an Associate Research Engineer associated with the Texas Transportation Institute of the Texas A&M University System, College Station,
A copy of my professional qualifications was previously submitted as an attachment to my direct written testimony filed on April 13, 1987.
l Q.2.
What is the purpose of this rebuttal testimony?
A.2.
The purpose of this rebuttal testimony is to address new i
issues raised in the direct testimony of David T. Ilartgen and Robert C.
i l
Millspaugh on behalf of the State of New York regarding LILCO's Reception Centers, which was filed on April 13, 1987.
l l
8706020213 870522 hDR ADOCK 05000322:
'b
- 2'-
t Q.3.
What is the CARS system used by Roger Creighton Associates, (Incorporated on behalf of the New York State Department of Transportation?
].
A.3.
CARS. is an acronym for the Comprehensive Assignment and Routing ' System developed by Roger Creighton _ and Associates Incorporated of Delmar, N.Y.
The computer software was released in
.Tanuary, 1987, so there is little reported experience with the program.
- However, the documentation suggests it-is largely a
traditional transportation planning model implemented - on a microcomputer.
The purpose of transportation planning models is to assess land use impacts of i
l proposed developments.
Traffic assignment models in general and CARS in particular is NOT a traffic operational tool.
Traffic - assignment algorithms can be used to identify alternatives at a broad scale, but they I
can NOT accurately predict driver behavior on a link specific basis, l
although they are often misused in that manner.
The minimum path i
algorithms used in transportation planning models do NOT have a good history of predicting route specific behavior.
Furthermore, the commute to work situation which occurs daily during the work year is NOT j
analogous to an evacuation.
Drivers commuting to work can adjust routes.
to work based on experience.
Evacuees 40 miles from home are unlikely I
to have experience ' with local roadways in the vicinity of reception 1
centers.
To suggest that traffic assignment can accurately predict route choice better than manual techniques is NOT correct.
Furthermore, to I
suggest that traffic assignment algorithms will perform better under evacuation conditions is not supportable.
Q.4.
The New York State Department of Transportation analysis indicates that many roadways have' volume to capacity ratios (V/C Ratio) over 1, indicating unacceptable delay and gridlock.
Do you agree with
)
this assessment?
A.4.
I agree that congestion will be extensive and that delays are substantial.
However, gridlock is unlikely and the whole notion of level of service is largely irrelevant.
The Level of Service on the Long Island Expressway every day is F
(i.e.,
V/C ratios over 1.
See Ilartgen/Millspaugh testimony, p.40) in many places for substantial periods.
I have personally heard the Long Island Expressway described as the world's longest parking lot.
Nevertheless, tens of thousands of people use it every day.
T.evel of service F only means we wish it was better, but massive numbers of people nevertheless make it to work everyday.
i 1
1 Q.5.
Are the New York State Department of Transportation four l
levels of analysis consistent with the FEMA guidance concerning EPZ population for planning at reception centers?
1 A.5.
No.
Three of the levels exceed the FEMA planning guidance concerning EPZ population to be accommodated at reception centers by 250 to 500 percent.
The fourth level is the same as LILCO's which exceeds the FEMA guidance by 50 percent.
Q.8.
Does the New York State Department of Transportation Analysis differ in other ways?
3 A '. 6.
Yes.
The New York State Department of Transportation analysis in all but one case also includes Evacuation Shadow traffic of 26 percent and 50 percent of Suffolk County non-EPZ traffic evacuating.
Q. 7.
Do any of the New York State Department of Transportation analyses' have similar assumptions to the LILCO analysis?
A.7.
No.
All except one of the analyses have significantly higher traffic volumes than the LILCo analysis.
One analysis had less traffic and essentially showed no problems.
Q.8.
Does the New York State Department of Transportation's analysis change your conclusions regarding the KLD analysis?
A.8.
No.
The KLD analysis represents a rational approach to the analysis of the capacity of roadways to accommodate reception center
)
traffic that is consistent with FEMA planning guidance.
l l
h, C0C KE TEP U5NRc UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
~87 ffAY 28 P2:10 BETORE TIIE ATONIC SAFETY AND LICENSING BOAR.Il hd.
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning) l (Shoreham Nuclear Power Station,
)
Unit 1)
)
CERTIFICATE OF SERVICE I
hereby certify that copies of "NRC STAFF MOTION TO FILE REBUTTAL TESTIMONY" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class or, as indicated by an asterisk, through deposit in the Nuclear Regulatory Commission's internal mail system, this 22nd day of May,1987.
Morton B. Margulies, Chairman
- Jocl Blau, Esq.
Administrative Judge Director, Utility Intervention Atomic Safety and Lice'nsing Board Suite 1020 U.S. Nuclear Regulatory Commission 99 Washington Avenue Washington, DC 20555 Albany, NY 12210 Jerry R. Kline*
Fabian G. Palomino, Esq.
Administrative Judge Richard J. Zahnleuter, Esq.
Atomic Safety and Licensing Board Executive Chamber U.S. Nuclear Regulatory Commission State Capitol Washington, DC 20555 Albany, NY 12224
{
Frederick J. Shon*
Jonathan D. Feinberg, Esq.
Administrative Judge New York State Department of Atomic Safety and Licensing Board Public Service U.S. Nuclear Regulatory Commission Three Empire State Plaza Washington, DC 20555 Albany, NY 12223 Philip McIntire James N. Christman, Esq.
Federal Emergency Management Donald P. Irwin, Esq.
Agency Hunton & Williams 26 Federal Plas:a 707 East Main Street Room 1349 P.O. Box 1535 New York, NY 10278 Richmond, VA 23212 Douglas J. Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771
l 4 Stephen B. Latham, Esq.
Twomey, Latham a Shea Christopher M. McMurray, Esq.
Attorneys at Law -
David T. Case, Esq.
33 West Second Street -
Kirkpatrick & Lockhart Riverhead, NY 11901 South Lobby - 9th Floor 1800 M Street, NW Atomic Safety and Licensing Washington, DC 20036-5891 Board Panel
- U.S. Nuclear Regulatory Commission Jay Dunkleberger Washington, DC 20555 New York State Energy Office Atomic Safety and Licensing Agency Building 2 Appeal Board Panel
- Empire State Plaza U.S. Nuclear Regulatory Co:amission Albany, NY 12223 Washington, DC 20555 Spence W. Perry, Esq.
Martin Bradley Ashare, Esq.
General Counsel Suffolk County Attorney Federal Emergency Management H.. Lee Dennison Building Agency Veteran's Memorial Highway 500 C Street, SW Hauppauge, NY 11788 Washington, DC 20472 Dr. Monroe Schneider Robert Abrams, Esq.
North Shore Committee Attorney General of the State P.O. Box 231 of New York Wading River, NY 11702 Attn: Peter Bienstock, Esq.
Department of Law Ms. Nora Bredes State of New York Shoreham Opponents Coalition Two World Trade Center 195 East Main Street Room 46-14 Smithtown, NY 11787 New York, NY 10047 Anthony F. Earley, Jr.
William R. Cumming, Esq.
General Counsel Office of General Counsel Long Island Lighting Company Federal Emergency Management 175 East Old Country Road Agency Hicksville, NY 11801 500 C Street, SW i
Washington, DC 20472 Dr. Robert Hoffman Long Island Coalition for Safe Docketing and' Service Sectiona Living Office of the Secretary P.O. Box 1355 U.S. Nuclear Regulatory Commission Massapequa, NY 11758 Washington, DC 20555 Mary M. Gundrum, Esq.
Barbara Newman New York State Department of Law Director, Environmental Health 120 Broadway Coalition for. Safe Living 3rd Floor, Room 3-116 Box 944 New York, NY 10271 Huntington, New York 11743 1
Yd Richard G. BR'ft1fiann Counsel for NRC Staff '
_