ML20214P071
| ML20214P071 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 05/27/1987 |
| From: | Zahnleuter R NEW YORK, STATE OF |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| CON-#287-3619 OL-3, NUDOCS 8706030193 | |
| Download: ML20214P071 (46) | |
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFIL:
4 00CKLHi+2 ^ WCI-Before the Atomic Safety and Licensino BoardlMM"
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power
)
Station, Unit 1)
)
)
RENEWED STATE OF NEW YORK MOTION FOR LEAVE TO FILE REBUTTAL TESTIMONY ggg The State of New York hereby renews its request te this Board for leave to file limited rebuttal testimony, to be sponsored by State witnesses David T. Hartgen and Robert C.
Millspaugh.
The proposed testimony, a copy of which is attached hereto, is based on new LILCO data which could not be addressed in the State's April 13, 1987 Direct Testimony.
The reasons supporting the State's request are set forth in the State's original motion concerning this matterl/ and are incorporated herein by reference.
Specifically, and as explained in further detail in the proposed rebuttal testimony, KLD (LILCO's consultant) has manipulated background traffic data at 1/
State of New York Motion for Leave to File Rebuttal Testimony (April 16, 1987)(" Original Motion").
A copy is attached hereto for the Board's convenience.
8706030193 870527 PDR ADOCK 05000322 43 y
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certain intersections in order to support its contention that the approaches to the reception centers can accommodate the evacuees attempting to reach the reception centers.
In addition, KLD has calculated intersection capacities in some instances using geometrics which are not accurate.
In particular, LILCO has added left turn lanes which do not exist.
Finally, a review of the data underlying KLD TR-201 reveals that certain key q
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' intersections have not been analyzed.
l The requisite " good cause" for filing rebuttal testimony is demonstrated in the State's original Motion.
In brief:
(1) the testimony could not have been included in the State's Direct Testimony; (2) the proposed rebuttal testimony is relevant in that it will assist the Board in assessing the accuracy of LILCO's analyses and the ability of the roadway network around the reception centers to accommodate evacuation traffic; and (3) the State's rebuttal testimony will not be cumulative and will be narrowly focused.2/
2/ It should be noted that the State's proposed rebuttal testimony does not address KLD TR-201A, which the State only recently received and has not yet had the opportunity to review.
The State will oppose LILCO's proposed substitution of that analysis, which is a substantial revision from KLD TR-201, in a separate pleading. m
CONCLUSION For the reasons set forth above, and for the reasons set forth in_the State's Original Motion, the State's renewed motion for leave to file rebuttal tastimony should be granted.
Res Efully submitte$,,
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Fabian G.W alomino l
Richard J.
Zahnleuter l
Deputy Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224 Attorneys for Governor Mario M.
Cuomo and the State of New York May 27, 1987 ATTACHMENT 1 Aoril 16, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensino Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
)
~
STATE OF NEW YORK MOTION FOR LEAVE TO PILE REBUTTAL TESTIMONY The State of New York hereby seeks leave to file limited rebuttal testimony, sponsored by State witnesses David T. Hartgen and Richard C. Millspaugh, based on new LILCO data which could not be addressed in the State's April 13, 1987 Direct Testimony.
I.
BACKGROUND One of the issues in this proceeding is the capacity of the routes leading to the reception centers to accommodate the traf-fic that will be generated as a result of an advisory that some or all of the EPZ population should report to LILCO's reception I
centers.
If the approach routes to the reception centers do not
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have sufficient capacity to handle expected traffic demand, then t
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the reception centers will be unable to perform their intended function and, therefore, this Board will be unable to find that they are adequate.
,During discovery, LILCO provided the Governments with an j
analysis conduc.:ed by a LILCO consultant, KLD Associates, which purported to analyze, and then drew certain conclusions about, i
the capacity of the routes to LILCO's reception centers.
The analysis, dated September 26, 1986, shall be referred to as KLD TR-192.1/
On February 24, 1987, LILCO's expert witness on the recep-1 tion center traffic issues, Mr. Lieberman (a Vice-President of KLD Associates), was deposed, during which time KLD TR-192 and its conclusions were explored.
Mr. Lieberman also testified during that deposition that he intended to conduct a more j
detailed analysis of the routes and intersections on approach paths to the reception centers using Hiohway Canacity Manual software.
Following the deposition, counsel for Suffolk County requested that LILCO produce any further analyses conducted by Mr. Liebermann.
Egg Attachment I hereto.
LILCO responded that it was unlikely that Mr. Lieberman's analysis would be completed much before the filing date for LILCO's direct testimony (March 30, 1987).
Egg Attachment 2 hereto.
I 1/
KLD TR-192 is Attachment M to LILCO's March 30 Testimony.
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LILCO counsel's prediction was accurate; LILCO provided no further analysis to the parties until March 30, 1987, when LILCO l
filed its direct testimony on the reception center issues.
That testimony contained not only KLD TR-192, but also a new analysis, which will be referred to here as KLD TR-201, consisting of 28 pages and an appendix.2/
While KLD TR-201 purported to be a more detailed analysis of route capacity than is reflected in KLD TR-192, LILCO did not provide any of the data underlying the analysis in KLD TR-201.
Therefore, on April 2,1987, LILCO was requested to provide all of the underlying data for the analysis.
Those data, consisting of over 1,000 pages and covering many different intersections, were received by counsel on April 6, 1987, and were provided to the State's experts on April 7, 1987.
Pursuant to this Board's scheduling orders, the State's Direct Testimony on the reception center issues was due in the hands of the parties and the Board by April 13, 1987.
The State met that deadline.3/
However, given the very large volume of data to be reviewed and the short amount of time left before the Direct Testimony was due,i/ it was impossible for the State's 2/
KLD TR-201 is Attachment S to LILCO's Testimony.
3/
Sig Direct Testimony of David T. Hartgen and Robert C.
Millspaugh on Behalf of the State of New York Regarding LILCO's Reception Centers.
$/
As a practical matter, there were only 3 days available between the time the data were received and the time when testimony was required to be finalized.
Due to necessary production time and the fact that the testimony had to be processed and copied in time for it to be in the hands of the (footnote continued) ____
experts to analyze KLD TR-201 and all of the underlying data in time to incorporate all of their findings into their Direct Testimony.
Where possible, KLD TR-201 was addressed in the State's direct testimony.
This includes testimony regarding the assumptions on which KLD TR-201 is based.
Ett, 12g2, Direct Testimony of David T. Hartgen and Richard C. Millspaugh on Behalf of the State of New York Regarding LILCO's Reception Centers (April 13, 1987) at 9-10, 29.
That testimony, of course, would not be repeated in' the State's rebuttal testimony.
I Analyses of LILCO's data demonstrate that LILCO's analysis is misleading.
Without informing the Board or the parties in its j
testimony or documentation, LILCO has manipulated its data to inflate intersection capacity and levels of service artificially.
On the basis of this analysis, LILCO's expert concludes that the routes to LILCO's reception centers are adequate.
Rebuttal testimony is, therefore, required to demonstrate that the conclusions reported by KLD TR-201, and the LILCO testimony based on those conclusions, are unreliable.
II.
DISCUSSION Rebuttal testimony may be filed where " good cause" is shown.
Here, good cause is shown for the following reasons.
(footnote continued f rom previous page)
Board and the parties by April 13, all testimony was required to be in final form by Friday, April 10.,
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s First, the testimony offered by the State could not have been included in the State's April 13, 1987, Direct Testimony on the traffic issues.
KLD TR-201 was not received by the State before March 30, 1987, and none of its underlying data were pro-vided before that time.
Indeed, the underlying data were received by the State's witnesses less than one week before their testimony was due.
Because KLD's analysis consisted of over a thousand pages, it could not be properly reviewed and incor-porated into the State's Direct Testimony before the filing date of April 13, 1987.
It should be noted that the State did make a good faith effort to review the text of KLD TR-201 and to comment where l
possible on the validity of that report.
However, without the underlying data, which were received well af ter the filing of LILCO's testimony, and on which the Governments have not even had the opportunity for discovery, there was simply no opportunity to complete the analysis.
Second, good cause is demonstrated because the testimony which the State offers is relevant to the issues before the Board and important to the Board's understanding of those issues.
The State's analysis of the underlying data, when compared to KLD TR-201, demonstrate that the KLD turn movement data have been manipulated to support the conclusions drawn in KLD TR-201 and the LILCO Testimony.
In addition, in an apparent attempt to..
i increase the-level of service of various intersections on paper, i
KLD has used turn movements which do not exist at the analyzed intersections.
Had appropriate input data been used by LILCO, the results of the KLD analysis would have shown substantial congestion at intersections around the reception centers -- with levels of service far below what KLD estimates.
The State's proffered testimony will thus_have a direct bearing on the relia-bility of LILCO's evidence.
Third, the State's rebuttal testimony will not be. cumulative and will be narrowly focused on those points which the State's experts were not able to comment upon in their direct testimony because of the lack of underlying data to complete their analyses.
For these reasons, the State has shown good cause to file rebuttal testimony on the narrow issues it has described, and accordingly, seeks leave f rom this Board to file such testimony.1/
5/
The State is in agreement with the proposed schedule for
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filing rebuttal testimony set forth in Suffolk County counsel's letter to the Board of April 13, 1987.
Specifically, that proposed schedule calls for the filing of testimony on May 4, 1987, motions to strike due on May 11, 1987, and responses to such motions due on May 18, 1987.
III.
CONCLUSION For the foregoing reasons, the State's Motion for Leave to File Rebuttal Testimony should be granted.
Respectfully submitted, lt Richard 2
euter Deputy Sp al Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol. Building Albany, New York 12224 Attorney for Governor Mario M. Cuomo and the State of New York April 16, 1987 1
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KIRKPATRICK & LOCKHART SOUTN ICSSY FTH PLo0R ucxApos nAcs 1800 M STMIT, N.T.
WASHINGTON, D.C. 200 4 5891 sta uraus 14M MirTRIf AW WAm n Hui TEU.FH004 000 FM80E0 009 H4412 Trux eenase itL DC UI in, a m TEUCOPER 000 T49999 ffTTSOLA0H. PA 1524HM 05uSTOPHER M. McMURRAY
- 3" 00D 7480H March 10, 1987 VIA HAND James N. Christman, Esquire Hunton and Williams 707 East Main Street Post Office Box 1535 Richmond, Virginia 20212
Dear Jim:
Edward Lieberman stated at his recent deposition that he intended to conduct additional analyses beyond those reflected in KLD TR-192.
Please provide us with all documents reflecting such additional analyses.
Yours truly, Christopher M. McMurray CMM/ mas i
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FEDERAL EXPRESS Christopher M. McMurray, Esq.
Kirkpatrick & Lockhart South Lobby - 9th Floor 1800 M Street, N.W.
Washington, D.C.
20036-5891
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Dear Chris:
I am trying to finish up some odds and ends left over from discovery.
Here is what I've found.
l.
You've asked for specifications of the collapsible storage tanks.
They are attached.
These specifications may have been provided to you previously, but I have not had time to veri-4 fy that.
2.
You've asked about the analyses or data that Dennis Mileti said he was considering.
We are still considering.
No data have been collected, and no analysis done.
3.
You've asked about the KLD reanalysis of traffic is-sues.
The reanalysis is in progress this week.
There is no re-port, draft or otherwise, and there will not be until the analy-sis has been done.
It looks to me as though the reanalysis will be done just in time to include it in our testimony, but not much before.
4.
You've asked about the information Chuck Daverio men-tioned in his deposition last Friday.
I have received a copy of that report today.
It is a March 13, 1987, report prepared by the Impell Corporation called " Review of Radiation Moni-toring/ Decontamination capabilities for the General Public in Ra-diological Emergency Plans." -It is " work product" in the classic sense, since it was prepared solely for litigation and at the re-quest of the lawyers.
Moreover, the information was gathered from public sources which I believe anyone could tap if he were to take the trouble to do it.
I shall simply have to make a judgment as to whether we are willing to turn this document over
H UNTON & WILLI AM S Christopher M.
McMurray, Esq.
March 17, 1987 Page 2 to you notwithstanding the fact that it is work product.
I will either provide it, or let you know otherwise, by the end of this week.
5.
Finally, you have asked for certain work of Mike Lindell.
As you know, some of this material was provided at his deposition.
Other material is packed away in boxes in Seattle and will be hard to find.
An additional problem is that Mike Lindell, who I believe is in Atlanta at present, has been away from his phone, and I have not been able to reach him; however, I will keep trying.
Yours very truly,
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James N.
Christman 126/6205
Attachment:
5 pages of tank specs (with certain commercial information deleted)
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DATE: April 16,1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION e
Before the Atomic Safety and Licensing Board in the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE 1 hereby certify that copies of STATE OF NEW YORK MOTION FOR LEAVE TO FILE REBUTTAL TESTIMONY have been served on the following this 16th day of April 1987 by U.S. mail, first class, except as noted by an aster!sk.
Morton B. Margulies*
Dr. Jerry R. Kline*
Chairman Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission East-West Towers East-West Towers 4350 East-West Highway 4350 East-West Highway Bethesda, MD 20814 Bethesda, MD 20814 Mr. Frederick J. Shon*
Spence W. Perry, Esq.*
Atomic Safety and Licensing Board William R. Cumming, Esq.
U.S. Nuclear Regulatory Commission Of fice of General Counsel, East-West Towers Federal Emergency Management Agency 4350 East-West Highway 500 C Street, S.W., Room 840 Bethesda, MD 20814 Washington, D.C. 20472
8 Anthony F. Earley, Jr., Esq.
Joel Blau, Esq.
General Counsel Director, titility Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suite 1020 1
Hicksville, New York 11801 Albany, New York 12210 Ms. Elisabeth Taibbi James N. Christman*
Clerk Hunton & Williams Suffolk County Legislature 707 East Main Street Suffolk County Legislature Richmond, Virginia 23212 Office Building Veterans Memorial Highway Hauppauge, New York 11783 Stephen B. Latham, Esq.
Twomey, Latham & Shea Mr. L. F. Britt 33 West Second Street Long Island Lighting Company Riverhead, New York 11901 Shoreham Nuclear Power Station North Country Road Docketing and Service Section.
Wading River, New York 11792 Office of the Secretary U.S. Nuclear Regulatory Commission Ms. Nora Bredes 1717 H. Street, N.W.
Executive Director Washington, D.C. 20555 Shoreham Opponents Coalition 195 East Main Street Hon. Michael A. Lo Grande Smithtown, New York 11787 Suffolk County Executive H. Lee Dennison Building 4
i Veterans Memorial Highway Mary M. Gundrum, Esq.
Hauppauge, New York 11738 New York State Department of Law 120 Broadway,3rd Floor Dr. Monroe Schneider Room 3-116 North Shore Committee New York, New York 10271 P.O. Box 231 Wading River, New York 11792 MHB Technical Associates 1723 Hamilton Avenue Lawrence Coe Lanpher, Esq.*
Suite K Kirkpatrick & Lockhart i
San Jose, California 95125 1900 M. Street, N.W.
Suite 800 Martin Bradley Ashare, Esq.
Washington, D.C. 20036 l
Suffolk County Attorney -
Building 158 North County Complex Richard Bachman*
Veterans Memorial Highway U.S. Nuclear Regulatory Commission l
Hauppauge, New York 1178S Washington, D.C. 20535 Mr. Jay Dunkleburger Douglas 3. Hynes New York State Energy Office Town Board of Oyster Bay Agency Building #2 Town Hall Empire State Plaza Oyster Bay, NY 11771 Albany, New York 12223 i
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t David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W. 4.1rd Street New York, New York 10036 3 /
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'.tt' hf Richard J. Zahqleuteil Esq.
Deputy Special Cou/s' l to e
the Governor Executive Chamber Capitol, Room 229 Albany, New York 12224 i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
REBUTTAL TESTIMONY OF DAVID T. HARTGEN AND ROBERT C. MILLSPAUGH ON BEHALF OF THE STATE OF NEW YORK ON KLD'S CAPACITY ANALYSIS (KLD TR-201)
I.
Names and Oualifications 0
Please statre your names and occupations for the record.
A.
I am David T. Hartgen, Director of Statistics and Analysis for New York State Department of Transportation, presently on special assignment for the Shoreham hearings.
I am Robert C. Millspaugh, Supervisor of Traffic Engineering Design Review, New York State Department of Transportation.
Q.
State your qualifications.
A.
Our qualifications were described in our Direct Testimony, filed on April 13th.
4 II.
PurDOse of Testimony i
O.
What is the purpose of this rebuttal testimony?
A.
Our purpose is to assess the accuracy and completeness of LILCO's most recent study of the capacity of roads in the vicin-ity of its three proposed reception center sites.
This study is l
dated March 30, 1987, and is entitled " Capacity Analysis on Approach Routes to the Shoreham Nuclear Power Station Reception Centers."
We will refer to the analysis (which is Attachment S to LILCO's Direct Testimony) Inr its document number, KLD TR-201.
We received KLD TR-201 on April 2nd, and its supporting data on April 7th.
Therefore, it was not possible for us to analyze the 4
study sufficiently to include a complete evaluation of it in our April 13th Direct Testimony.
l Our preliminary analysis of KLD TR-201 demonstrated that its results were based on unrealistically low assumptions and failure to account properly for the queues extending from the reception centers.
Those points were made in our April 13 Direct Testimony and we will not reiterate that testimony here.
Rather, this testimony will focus on our further analyses of the data underly-ing KLD TR-201.
Specifically, we offer this rebuttal testimony to apprise the Board that KLD TR-201 is based on data which have 4
been used in a misleading fashion in order to support LILCO's conclusions.
2-
a III.
NYSDOT Analysis of KLD TR-201 Q.
Please describe your further analyses of KLD TR-201.
1.
ImoroDer "Adiustments" To Data f
A.
Given the sheer volume of. computer generated material provided to us, we have not analyzed every intersection examined in KLD TR-201.
However, we have reviewed KLD TR-201's treatment of a selected group of intersections, including the three " target intersections" which were the focus of our Direct Testimony.
The three target intersections are:
Hicksville - NYS Route 107 and Old Country Road Bellmore - Route 27 and Newbridge Road Roslyn - Willis Avenue and LIE Service Roads.
KLD TR-201 states that in analyzing the capacity of the intersections on paths leading to the reception centers, traffic counts on all approaches to the intersections were acquired via automatic recording equipment.
LILCO Direct Testimony, Attach-I ment S at 12.
This was done to determine the level of background traffic on the approaches to the reception centers; the higher the level of background traffic, the less roadway capacity is available for evacuees attempting to reach the reception centers.
However, in analyzing the data provided to us by LILCO, we dis- __
e covered that the counts which KLD actually obtained in the field do not match the counts that were used in the capacity analysis supporting KLD TR-201.
Instead of using the actual counts on a specific movement, KLD took the total approach volume at each intersection and -- from what it appears -- arbitrarily distributed it among the various movements (left, through, right).
This inappropriate juggling of the traffic demand served in all cases to reduce background traffic on the key evacuation movements, thus resulting in more favorable conditions, on paper, for evacuation traffic.
To demonstrate how KLD TR-201 misapplies the data, let us look at the intersection of Route 107 southbound and Old Country Road.
This is a key approach to the Hicksville reception center.
Exhibit 1, obtained from LILCO, is a printout of the turn move-ments counted in the field by KLD's contractor.
For the 3-hour period from 7 a.m.-10 a.m.,
Exhibit 1 reflects that 456 vehicles (175 + 146 + 135) took a left-turn from Route 107 onto Old Country Road.
This is one of two key movements for evacuation traffic at this intersection.
As seen in Exhibit 2, also obtained from LILCO, the average hourly left-turn volume for the 7 a.m.-10 a.m. time period is 152 vehicles / hour (456 divided by 3). -
However, as demonstrated in Exhibits 3 and 4, LILCO did not use the 152 vehicle / hour figure to calculate intersection capacity and level of service for that time period.
Rather, it chose (for reasons which are nowhere explained) to reduce the hourly average volume of left-turning background traffic to 77 vehicles / hour -- more than a 50% reduction (remember that the analysis purports to be based on 100% of background traffic being on the roads).
To this reduced background traffic, KLD adds 339 vehicles / hour to represent expected evacuation traffic (assuming 30% of EPZ residents proceed to reception centers).
Thus, the total average left-turning volume for the 7 a.m.-10 a.m. period is assumed by LILCO to be 416 (77 + 339).
Eeg Exhibits 3, 4.
In fact, assuming for the sake of argument that the estimate of 339 evacuating vehicles / hour is correct, the proper left-turn volume is 491 (152 + 339).
LILCO then plugs the inappropriately-reduced 416 vehicle /
hour figure into the HCM software which calculates a volume /
capacity ("V/C") ratio of.566 and a level of service rating of "C".
Sgg Exhibit 4 at 1, 7-8.
This indicates little congestion and adequate traffic flow.
These results, however, are inaccurate because LILCO has misused its own data.
When the proper data are applied, as we did in the analysis reflected in Exhibit 5, with 491 vehicles / hour used as the proper left turn volume for the 7 a.m.-10 a.m. period, the same software r,
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calculates'a 1.019 V/C ratio with a level of service rating of F (reflecting total breakdown of service).1/
This is a dramatic difference in results, which KLD would have obtained itself had the proper data been used.
There is no reason given for the adjustments KLD made to its data and, in our opinion, none is justified.
As an additional example, let us look at the northbound approach of Route 107 to Old Country Road.
KLD's field counts show that between 7 a.m. and 10 a.m.,
an hourly average of 114 northbound cars turn right onto eastbound Old Country Road (the other of the two key evacuation movements at this intersection) and 885 either go straight through or turn left, for a total of 999. cars per hour.
The data used for KLD TR-201 assumes the same total volume of 999 cars, but with only 80 cars making right turns.
Indeed, for all four of the three-hour periods between 7 a.m. and 7 p.m.,
KLD determined turning counts by distributing 24% of the total approach volume to the left turn, 68% to the through movement and 8% to the right turn.
In every time period, this resulted in the northbound right turn volumes used for the.
capacity analysis being less than the right turn volumes actually recorded by the machine counts.
Of course, this led to artifi-cially decreased V/C ratios and enhanced levels of service.
lb/
iAs stated in our Direct Testimony, a V/C ratio of more than one means that demand exceeds capacity.
It is indicative of severe congestion.
Long queues will form at many intersections upstream and in the networks causing gridlock..-
Exhibit 6? summarizes discrepancies between the' field data i
collected by KLD and the arbitrary data used.in KLD TR-201 for the 7 a.m.-10 a.m. time period at our three target intersections.
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l It demonstrates that by adjustingfthe data to reduceLthe.back-
- ground volume at the key turns, more intersection capacity became available for evacuation traffic.
Then, when'the limited evacua-tion. traffic assumed in KLD TR-201 was added:to the movement,-it i
. was'able to fit within the available capacity.
While this LILCO i
device makes it appear that the intersections around the recep-tion centers can accommodate.the demand, proper use of.the data, i
as reflected in Exhibits 5 and 7, shows that they cannot.
l 2.
.Inacoropriate Adiustment to Intersection Geometry In addition, our analysis has determined that KLD has,arti-
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ficially' inflated the capacity available for-some evacuation turn movements.
In at least two cases (and there may be-more), KLD altered the existing lane configuration to favor the evacuation bovement by designating a straight-through lane.as a shared left turn and straight-through lane, thus permitting afdouble left s
turn, evenLthough the geometrics and cigail operation at the.
intersections do not include such s ovr This " technique" was.
used on the southbound ~ approach of Willis Avenue to the LIE South Service Road (Roslyn) and tiie southbound approach of Route 107-to 4
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Old Country Road (Hicksville).
In effect, it substantially increased the capacity available for evacuation movements -- but it is not grounded in reality.
Exhibit.4, which is LILCO's analysis of the southbound approach to the intersection of Route 107 and Old County Road, is an example of LILCO's improper procedures. -Page 2 of Exhibit 4 shows that the southbound leg of the intersection consists of four lanes.
That is true; however, Lane 2 is incorrectly identified as permitting a left turn, when in fact it is a through-only lane.
The effect is to greatly increase left-turning capacity which, when combined with the reduced traffic volumes described above, results in a V/C ratio of.566 and a level of service rated as "C".
Again, Exhibit 5 sets forth the calculation as it should have been done.
Using the actual geometry of the intersection, and the proper average hourly demand figure of 491 vehicles / hour (see above), the V/C ratio is 1.019, with a level of service rating of "F".
This means that the approach will be extremely congested and could lead to significant delays for evacuees attempting to reach the reception centers.
Q.
Have you identified any other problems as a result of your analysis of the data underlying KLD TR-20l?
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A.
- Yes,: we have discovered several additional' problems which -
while' not as significant as the problems noted above, neverthe -
-less demonstrate a disregard for accuracy in KLD TR-201.. First, at.two locations,,KLD uses' departure volumes from'the inter-section as acoroach volumes to the intersection. 'For instance, t
the counts used for the capacity analysis.of the<EB approach-of Old Country Road to Route 107;were taken at detector H3, which is already east of the intersection and' records EB traffic departing from the intersection.
There were no counts taken on the EB j
approach to the intersection. -The same is true.for the SB approach of Newbridge Road to Route 27.
Detector B3 was used for the southbound approach when in. fact it'is located' south of the intersection and recorded-SB departure volumes.
j l
Second, KLD's estimates of traffic turning right.on' red are.
too generous, especially in cases where traffic will be turning l
right from a lane that is shared with through traffic.- Cases in' point are both approaches of Newbridge Road'to Route 27 (Sunrise Highway) (Bellmore), the westbound LIE Service Road approach to i
Willis Avenue (Roslyn), the eastbcand LIE. Service Road approach to Willis Avenue (Roslyn) and the northbound Willis Avenue.
i i
approach to the eastbound LIE Service Road (Roslyn).
When an=
intersection-is operating at or near~ capacity, there are very few-opportunities for right turns on red.
Accordingly, when we conduct: capacity analyses, we usually do not consider lright turns I
on red; this results in an appropriately conservative analysis.
l
~
't a
4 :
t p
+
Third, KLD used'as input signal timing that in some cases provides more green time to the evacuation movement than.the existing traffic signal operation does.
This artificially
. increases-the capacity of those movements.
For example, at the intersection of, Route 27'(Sunt'ise Highway) and Newbridge Road
~
~
incorrect green' time was given to'the protected left~ turn from westbound Sunrise Highway onto southbound Newbridge Road and to
.the Newbridge Ro.ad movements.
In the.7 a.m. to 10 a.m. time period KLD used effective green times of 27. seconds for the protected westbound left turn and 35 seconds for Newbridge Road.
The existing operation provides'a maximum green of only 20 seconds to the protected westbound left turn and 25 seconds for Newbridge. Road.
i Similarly, at the eastbound LIE serv' ice road intersection with Willis Avenue between 7:00 a.m. and 10:00 a.m., KLD used an effective green of 24 seconds for the protected left turn from southbound Willis Avenue onto the eastbound LIE service road.
i The existing signal operation only provides a maximum of 12 seconds.
1 Finally, KLD may have underestimated the percentage of trucks on the roads.
Region 10 (Long Island) usually uses a 10 percent estimate.
In contrast the 2 percent often used in f
KLD's analysis is-'the default value selected by the computer program. -KLD also used a peak hour 1 factor of 0.99 on the i-
. l l
~,... _ _ _ _
evacuation approaches and a few others..This is definitely favorable to their analysis.
_A peak hour factor of 0.99 is very
-unlikely during normal traffic conditions, even during peak periods.
Q.
Have you determined the effect of all of the errors you discovered in KLD TR-20l?
A.
Yes, we performed our own capacity analysis correcting some of the above mentioned errors.
The major changes were to the turn movement volumes, signal timing and lane assignments.
Right turns on red were also adjusted, but that did not have a signifi-cant effect.
KLD's peak hour factor and truck percentages were not changed.
Exhibit 7 is a comparison of our analysis with KLD's.
The analysis is based on 100% background traffic and 30%
evacuation traffic, spaced over a six-hour time period, as was KLD's.
Only the movements to be used by evacuation traffic are shown in Exhibit 7.
The results of our analysis show significant differences from KLD's conclusions regarding the expected operating condi-tions at the three target intersections in the event of a Shoreham accident.
KLD used improper and/or unrealistic input and obtained favorable results.
We used actual background move-ment counts, actual lane assignments and actual signal timing as input, and obtained results that point to conditions much worse L_
'l 1
than those predicted by KLD.
Indeed, of 24 turn movements, 14 are over capacity.(i.e., V/C ratios greater than 1.0), including four that have V/C ratios of 1.3 or more.
Q.
What is the significance of your findings?
A.
When the analysis purported to have been conducted by KLD is done appropriately, the results demonstrate that the intersec-tions analyzed will not operate even under the unrealistically low assumptions (i.e., 30% EPZ traffic, 100% background traffic and no shadow traffic) utilized by KLD.
Q.
Did you analyze scenarios for these intersections using lower demand estimates?
A.
Yes.
We analyzed a 100% background /20% evacuation /6 hour time period scenario.
Q.
Please describe your results.
A.
Exhibit 8 shows the results, which not surprisingly show less congestion than the 100%/30% scenario.
Of 24 movements analyzed, six are over capacity (V/C greater than 1.0), including two that have V/C ratios of 1.3 or more.
1 Q.
Does this mean that the plan will operate at 100%/20%?
A.
No.
It means that, on the averace, conditions will be bet-ter than at a 100%/30% scenario.
However, there is still a sig-nificant amount of congestion at the key approaches to the Bellmore and Roslyn sites, particularly during the morning and afternoon peaks.
Q.
What can be said about the sensitivity of KLD's results to assumptions about the input?
l A.
Our tests show that KLD's assumption about the percentage of
}
evacuees that wish to use the sites is a critical one.
Basi-cally, the number of intersection movements expected to be over capacity will more than double, as one goes from 20% evacuation to 30% evacuation.
In other words, there is very little room for error in KLD's numbers:
if the percent of evacuees turns out to be just slightly higher than 20%, congestion will mushroom rapidly.
Even at 20%, certain movements will show major delays.
Given the uncertainty of this number, and its sensitivity, LILCO's Plan is inadequate.
LILCO has essentially assumed that an evacuation will be mild (less than 30% of the EPZ population arriving at reception centers) and will occur at favorable times (off peak) but has not taken into account (from a roadway i
l 1
capacity standpoint) worse scenarios.
This is imprudent.
The chance of error is too great, and the impacts of that error too severe, to ignore a thorough analysis.
i l
Q.
H, ave you analyzed any intersections other than the three
" target" intersections?
1.
Meadowbrook Parkway and Route 27 A.
Yes.
In reviewing the data underlying KLD TR-201 we noticed that there was no analysis of the intersection of the southbound Meadowbrook Parkway exit ramp to eastbound Route 27 (Sunrise Highway).
This is an important intersection for evacuees seeking to reach the Bellmore reception center.
The off ramp is con-trolled by a stop sign and there is no acceleration lane for traffic entering Route 27 from the parkway ramp.
Thus, we feel that conditions at this intersection are best analyzed by the Highway Capacity Manual procedures for unsionalized intersec-tions.
Our analysis is summarized in Exhibit 9 hereto.
It indi-cates that even in the presence of only 20% EPZ evacuation traf-I l
fic and 100% of the normal background traffic, the resulting-volumes on the ramp will be well over capacity between the hours of 1 p.m. and 7 p.m.
There will therefore be significant queueing on the ramp, backing up onto the Parkway mainline.
If a six-hour, lq% evacuation is assumed (one of LILCO's assumptions in KLD TR-201), in the three-hour period between 4 p.m. and 7 p.m. the demand on the off ramp will be an average of 693 vehicles over capacity eaqh hour.
Thus, at the end of the three-hour period a queue of 9.8 miles would result.- This demonstrates that this intersection will significantly impede traffic attempting to reach the Bellmore reception center, ulti-mately leading to delays in monitoring evacuees.
2.
Old Country Road and South Ovster Bay Road We also reviewed the intersection of Old Country Road and South Oyster Bay Road.
.This is a key intersection on a primary approach to the Hicksville reception center.
We analyzed this intersection for 100% background traffic, 30% EPZ, and 6 hour6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> arrival.
Exhibit 10 summarizes our analysis for the key movement (westbound through).
It is well over capacity for all four time periods.
This means'that evacuation traffic will back up, with the queue extending east, steadily at this location.
i.
g.
Q.
Please' summarize your testimony.
A.
Our review of KLD TR-201 demonstrates that KLD's purported ahalysis is misleading.
In particular, the input data utilized in the analysis have been adjusted without justification to favor LILCO's conclusions.
When proper input data are utilized, even taking LILCO's
~ basic assumptions regarding traffic demand, the results demon-strate-that' traffic congestion will be far worse than is indi-cated-in LILCO's testimony.
Key approaches of-the intersections analyzed will be at or over capacity, leading to increased delays and the lowest levels of service.
Q.
Does that complete your testimony?
I A.
Yes.
i l
J i..
EXHIBIT 1 o
15 M!hU7E. E CHA M(L AIL ( COUN7
REFERENCE:
HI COERiti!ONFACTOR: 1.00 LOCAi!0N: SOUTH 90VNO BROADWAY AT OLO COUNIFY RD. (HI) flL(NAM ( H1716 W(ATHIR: GOOD IWURSDAY JULY 17. 1936
..........O.MP.A.TO.P..:.L.U.C.A.S..............................................................................
HOUR Ltfi HOUR OTHER HOUR COMBINED 8(0!NS 0
15
- 0 45
!0TAL 0
13 5
13 1
3 41 40 31 44 1
8 8
4 4
24 38 24 23 115 1*1 2
3 5
1 9
23
- 6 18 20 20 34 107 6
2 1
10 10 8
11 14 4;
5; i
4 3
2 5
4 14 14 23
~5 73 37 I
5 1
5 6
7 21 24 27 30 10; 124 6
16 21 40 43
- 5 34 64 72 113 20' 40?
7 33 47
- 2 53 17, 98 107 103 110 418 54:
8 46 29 34
- 7 146 1
139 90 83 1:0 4;
573 h
133 114 104 12 47; 6'03 9
35 30 41 29 10 2:
26 29 38 115 112 145 143 139 5;9 6!4 11 26 31 25 33 1:0 126 135 14 122 525 645 PM 12 47 45 4
5;
64 36 43 49 117,
187 147 19:
158 684 '
881 -
2 47 38 42 42 te? -
175 165 158 143 641 -
810 -
3 34 15 35 52 1;6 -
174 225 201 209 609 -
945 -
4 45 61 56 50 01 -
192 215 288 254 949 -
1161 -
5 53 53 66 67 244 -
297 274 279 261 1111 1355 i'
6 51 51
- 5 24 bl 209 196 149 766 -
i:7 -
7 41 23 24 113 139 125 150 1:0 544 6e:
8 33 27 20 23 10; 130 103 116 102 451 554 9
20 15 22 18 75 98 81 111 104 394 469 10 15 15 9
19 53 69 83 67 80 099 357 10 28 27 14 71 34 86 64 36 270 349 TOTALS 2665 107:4 1;;44 AM PEAK HOUR IS 10:15 TO 11:15 VOLUni LIFT :
119 OTHER:
553 COMBINED:
672 DIRECTIONAL SPLIT 181 821 PEAK HOUR FACTOR 0.78 0.95
?.95 1
l l
PM P(AK HOUR IS 5:00 TO 6:00 l
VOLUME L(FT:
244 OTHER:
it!!
COMBINED: 1355 i
DIRECTIONALSPLIT 181 821 P(AK HOUR FACTOR 0.91 0.94 0.97
EXHIBIT 2 4
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EXHIBIT 3
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EXHIBIT 4 l
1985 HCM: SIGNALIZED INTERSECTIONS Page-1 IDENTIFYING INFORMATION
==3==EE====2E===================E=EEE=E=====2=====3=====3==E
NAME OF THE EAST / WEST STREET........ 01d County Road NAME OF.THE NORTH / SOUTH STREET....... Broadway (Route 107)
AREA TYPE...........................
0THER PEDESTRIAN WALKING SPEED............
0 (feet /sec)
NAME OF THE ANALYST..................R.
Goldblatt DATE OF THE ANALYSIS................ 3/8/87 TIME PERIOD ANALYZED................ 0700-1000 OTHER INFORMATION:
30 percent evacuation; 100 percent background TRAFFIC VOLUMES
==========================================================
EB WB NB SB LEFT 106 110 240 1416 THRU 592 934 679 415 RIGHT 186 206 363 101 RTOR 80 40 80 80 (RTOR volume must be less than or equal to RIGHT turn volumes.)
f l
L
+
1 INTERSECTION GEOMETRY Page-2 E=EE=3ES=23=====2:2EEEEEEE=E=3EEE25332EE=E3=E3=EEEEE=E==E3EE====E223E2 j,
NUMBER OF LANES PER DIRECTION INCLUDING TURN BAYS EASTBOUND = 4 WESTBOUND E 4 NORTHBOUND = 4 SOUTHBOUND = 4 EB WB NB SB LANE TYPE WIDTH TYPE WIDTH TYPE WIDTH TYPE WIDTH 1
L 10.0 L
10 0 L
10.0 L
10.0 2
T 12.0 T
12.0 T
12.0 k
3 T
12.0 T
12.0 T
12.0 T
12 0 t
4 R
12.0 R
12 0 R
12 0 R
12.0 5
12.0 12.0 12 0 12.0 6
12.0 12.0 12.0 12.0 l
1 L
- EXCLUSIVE LEFT LANE T - EXCLUSIVE THROUGH LANE LT - LEFT/THROUGH LANE TR - THROUGH/RIGHT LANE LR - LEFT/RIGHT ONLY LANE R - EXCLUSIVE RIGHT LANE LTR - LEFT/THROUGH/RIGHT LANE ADJUSTMENT FACTORS
====================================E=======EE======E=====
GRADE HEAVY VEH. ADJACENT PKG BUSES
(%)
(%)
Y/N (Nm)
(Nb)
PHF EASTBOUND 0.00 2.00 N
0 0
0.79 WESTBOUND 0.00 2.00 N
0 0
0.97 NORTHBOUND 0.00 2.00 N
0 0
0 99
}
SOUTHBOUND 0.00 2.00 N
0 0
-0 97 Nm = nusiber of porking maneuvers /hri Nb = number of buses stopping /hr CONFLICTING PEDS PEDESTRIAN BUTTON I
(peds / hour)
(Y/N)
(min T)
ARRIVAL TYPE l
EASTBOUND 50 N
24.0 3
WESTBOUND 50 N
24.8 3
1 NORTHBOUND 50 N
24.8 3
i SOUTHBOUND 50 N
24.8 3
i l
min T = minimum green time for pedestrions c
i l
SIGNAL SETTINGS - DESIGN ANALYSIS Page-3
==============_-===========================================
ACTUATED LOST TIME / CYCLE = 9.0 CYCLE LENGTH = 120.0 EAST / WEST PHASING PHASE-1 PHASE-2 PHASE-3 PHASE-4 EASTBOUND LEFT X
X THRU X
RIGHT X
PEDS X
WESTBOUND LEFT X
X THRU X
RIGHT X
PEDS X
NORTHBOUND RT SOUTHBOUND RT NORTH / SOUTH PHASING PHASE-1 PHASE-2 PHASE-3 PHASE-4 NORTHBOUND LEFT X
X THRU X
RIGHT X
PEDS X
SOUTHBOUND LEFT X
X X
THRU X
X RIGHT X
X PEDS X
X EASTBOUND RT X
WESTBOUND RT X
i 9
9 0
4
'j..'
=.1 L'
~ EFFECTIVE GREENS - DESIGN ANALYSIS Page-4
~
EEEEEESEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEEE -
EFFECTIVE GREEN, g EASTB0UND-l LEFT s
Permitted 44.00 Protected 12.00 "THRU
,44.00 RIGHT t
Permitted 44.00 Protected 12.00 t
WESTBOUND LEFT Permitted 44.00 Protected 12.00 THRU 44.00 RIGHT Permitted 44 00 Protected 12.00 NORTHBOUND LEFT
?
Permitted 33 00 Protected 12.00 THRU 33.00 RIGHT Permitted 33.00 Protected 0.00 SOUTHBOUND LEFT 3
Permitted 33.00 Protected 22.00 THRU 43.00 i
RIGHT
?
Permitted 33.00 Protected 0.00 r
'4 a
1 t
VOLUME ADJUSTMENT WORKSHEET Page-5 333333=333333333333333333333333333333333333333333333333333333333333333 LANE LANE ADJ.
MVT.
ADJ. LANE GRP. NO. UTIL. GROWTH GRP. PROF PROP VOL. PHF VOL.
GRP. VOL. LN FACT. FACT.
VOL.
LT RT EB LT 106 0.79
'134 L
134 1 1.000 1.000 134 1.00 0.00 TH 592 0.79 749 T
749 2 1 050 1.000 787 0.00 0.00 RT 186 0.79 134 R
134 1 1.000 1.000 134 0 00 1.00 WB LT 110 0.99 111 L
111 1 1.000 1 000 111 1.00 0.00 TH 934 0 99 943 T
943 2 1.050 1.000 991 0.00 0.00 RT 206 0.99 168 R
168 1 1.000 1.000 168 0 00 1.00 I
NB LT 240 0.99 242 L
242 1 1.000 1 000 242 1.00 0.00 TH 679 0.99 686 T
686 2 1.050 1.000 720 0.00 0.00 RT 363 0.99 286 R
286 1 1.000 1 000 286 0.00 1.00 1
SD LT 0.99 420
- L 420 1 050 1.000 441 1.00 0 00 TH 0.99 419 T
419 1.000 1.000 419 0 00 0.00 RT 101 0 99 21 R
21 1 1.000 1.000 21 0.00 1.00 l
- Denotes o'Defocto Left Turn Lone Group i
d i
s 1
i
}
f 6
SATURATION FLOW ADJUSTMENT WORKSHEET Page-6 22F=RE=3333333E=3222=233333=33332E=323333E=3E==2333333===33N=23:3323322 ADJ.
IDEAL SAT. No.
f f
f f
f f
f f
SAT.
FLOW LNS W
HV G
p BB A
RT LT FLOW EB L
-1800 1 0.930 0 990 1.000 1.000 1.000 1.000 1.000 0.950 1574 T
1800 2 1 000 0.990 1.000 1 000 1.000 1.000 1.000 1.000 3564 R
1800 1
1.000 0.990 1.000 1.000 1.000 1.000 0.838 1 000 1493 WB L
1800 1 0.930 0.990 1.000 1.000 1.000 1.000 1.000 0.950 1574 T
1000 2 1.000 0.990 1.000 1.000 1.000 1.000 1.000 1.000 3564 R
1800 1
1.000 0.990 1.000 1.000 1.000 1.000 0.838 1.000 1493 NB L
1800 1 0.930 0 990 1.000 1.000 1.000 1 000 1 000 0.950 1574 T
1000 2 1.000 0.990 1.000 1 000 1.000 1.000 1.000 1.000 3564 R
1800 1
1.000 0.990 1 000 1 000 1.000 1.000 0 026 1 000 1472 SD 1800(][))0.970099010001.000100010001.0000.9203181 L
T 1800 1
1.000 0.990 1.000 1 000 1.000 1.000 1.000 1 000 1782 R
1800 1 1.000 0.990 1.000 1.000 1 000 1.000 0 826 1 000 1472 l
CAPACITY ANALYSIS WORKSHEET Page-7 3333333322=232333333333E3225E23=E232 3322E23333333333=23E3333333EEEEEW ADJ.
ADJ. SAT. FLOW LANE GROUP FLOW RATE FLOW RATE RATIO GREEN RATIO. CAPACITY v/c (v)
(s)
(v/s)
(g/C)
(c)
RATIO EB Lperm.
69 Lprot.
65 1574 0.041 0.100 157 0.413
- T 787 3564 0.221 0.367 1307 0.602 R
134 1493 0.090 0.467 697 0.193 WB Lperm.
67 Lprot.
44 1574 0.028 0.100 157 0.281 T
991 3564 0.278 0.367 1307 0.758
- R 168 1493 0 113 0.467 697 0.241 i
NB Lperm.
153 Lprot.
89 1574 0.057 0.100 157 0.568 T
720 3564 0.202 0.275 980 0.735
- R 286 1472 0 194 0.275 405 0.706 l
SB Lperm.
111 Lprot.
3181 0.104 0.103 583 ( 0.544 * )
T 41 1782 0.235 0.358 639 9.ede -
R 21 1472 0.014 0.275 405 0.052 l
Cycle Length, C = 120.0 sec.
Sun (v/s) critical = 0.625 Lost Time Per Cycle, L = 9.0 sec.
X critical = 0.676 l
D t
s
, ' \\'
.~
4 i
LEVEL-OF-SERVICE WORKSHEET Page-8 3233333333333333333333333333333333335233332235233325E33333333333333335 i
DELAY LANE DELAY LANE LANE DELAY LOS v/c g/C CYCLE d
GROUP d
PROG. ORP. GRP. BY BY RATIO RATIO LEN.
1 CAP.
2 FACT. DELAY LOS APP. APP.
i EB L
0.413 0.467 120.0 16.1 157 10 1.00 17.1 C 19.0 C i
T 0.602 0.367 120.0 23.5 1307 0.6.0.85 20 4 C R
0.193 0 467 120.0 14.3 697 0.0 0.85 12.1 B UB L
0.281 0 467 120.0 14 9 157 0.3 1.00 15.2 C 21.0 C T
0 758 0.367 120.0 25.3 1307 1.0 0.85 23.1 C R
0 241 0 467 120.0 14.6 697 0.0 0.85 12.5 B NB L
0.568 0.375 120 0 22 6 157 35 1.00 26.1 D 27.3 D T
0.735 0.275 120.0 30 0 900 2.0 0.85 27 3 D R
0.706 0.275 120.0 29.7 405 38 0.85 28.5 D i
SD i
L 0.566 0.458 120 0 18.1 583 1.0 1.00(590 A5) 20.6 C T
0.656 0.358 120 0
'.6 639 1.7 0.85 22 3 1:
R 0.052 0.275 120.0 29.3 405 0.0 0 85 20.7 C i
Intersection Delcy = 22.2 (sec/veh)
Intersection LOS = C i
4 i
l i
1 i
I i
+
A i
1 l
l 1
1
EXHIBIT 5 1985 HCM: SIGNALIZED INTERGECTION's
- i
++% +++o
++++++.4 u +o u n
+++++.+.++*+++o u n +++u n w u u
+4+,
ICENTIFYING ! 'TOPN AT Mb'
=..======.====-:=======.======-==2:
.===========a=--========
NAME OF THE EAST / WEST STREET.........OLD COUNTR'/ ROAD NANE OF THE NCP'H/ SOUTH STREET....... BROADWAY AT 107 AREA TYCE.
,.........................OTHER PEi94TRI aN nA' KING SPEED.............
O (feet /sec)
NAME OF T:-!E ANALYST..................BG DALE OF THE ANALYSIS................E'24/87 TItaE PERIOD ANALYZED.................0700-1000 OTHER INFORMATION:
F6ie 206 F' 00% Evacuation TRAFFIC VOLUME 3
- -==,_-=============,===========-:ama=====:===u=:-=================,.
2 E3 WO NS S3 LEFT l '.' c 110 240 491
- g. 7j
-n-o'o 64'5 240 R.GH" l'
206 397 101 R:OR 50 40 80 40 (PTOR volume must be less than or equal to RIGHT turn volumes.)
i
nc w. E:.
.m.,e.
,.,:.e. _.y r.7 p.,f
.t 2 3 2 "S 2* 1 T2 3 3 2 3 *;' 3 **.13 2 M M 131 *2 3 2 2 4 43 2.4 'S 31 '2 0 ?.J 42f24
- 3 J 12 22 2.4 3 *J 2 Z = 2 *2 3 4J 2 *.' 7:; U 3.* ". a '. a NUM2 ER OF ANES PER D;FECTION INCLUDING TURN B A /'3 :
".A.373CUND 4
WE3TBGUND = 1 NCR THB0UND = 4 SOUTHECUN7
= a Q
W5 NB SD
' / n."
TYPE inI DTH TYPE in I DT ei TYPE WIDTH TYPE W ID Ti l 1
L 10.0 L
10.0 L
10.0 L
10.0 g
CT 12.c)
Y 14.0 7
12.0 T
i ;.:. 0 O
T l'.0 T
1 ;.. O 10.0 T
10.0 4
R 11.0 R
12.0 R
12.0 R
12.0 12.0 10.0 12.0 12.0 12.0 12.0 12.0 12.0 L
- EXCLUSIVE LEFT LANE T
- E"CLUSIVE THROUGH LANE LT
- LEFT/THRCUGh LANE TR - THROUG9/RIGHT LANE LR
- LE!T/RIGHT ONLY LANE R
- E.;CLU3!VE RIGHT LAl.E LTR - LEFT / TWRCUGr- / H I GFT '_ At lE l
t~,m; MEN, eimiORS
=., = = = = = = = = 2 a = = = = = = a = =, 2.s e = = i n a.i a a, = = = = - w a i n 3 2, n u a = u = =. a u n., :...
n 2.1.:
3RADE HEAV / V~H.
ACJACENT PUG EUSE3
('.
(%)
Y/N
( Nrn )
(Nb)
PHF D OT T.C L3 0 0.00 0.00 14 0
0 0.79 mEITEOUND 0.00 2.00 N
0 0
0.99 NOATHr;0UND 0.00 2.00 N
O O
0.99 SOUTHCCUND 0.00 C.00 N
O O
0.99 Nrn s n urnb e r of p ark i n.3 inaneuver s / hr Nb
- n urnb e r of buses stoppin3 l
CCNFLICTING PEDS PEDESTRIAN DUTTON
'09ds/ hour)
(Y/N)
( rn i n T )
APRIVAL 17 1
l l
EAC~20UND 50 N
10.8 J
E.3T50UND 50 N
20.9 3
NOF"HOOUND 50 N
00.G 3
SCUTAG0UND 50 N
20.9
?
t 1
ra i ri T a ra i n raure. P 2en t i :n > for rs492 eiana l
l
.GIGNAL SETTINGS - DES!GN ANALYSIG Fv.
======an=======,==2n=======n===n============u======n=====ananen=e,m-l
[
t ACTUATED LOST TIME / CYCLE e G.O CYCLE LENGTH = 100.G E,WT/ WEST PhAS dig PHASE-1 PHASE-2 PHASE-3 PHASE-4 EA3iDOUND L2FT X
1(
TPFU
)(
R:GHT X
t FEDS X
WESTDOUND LEFT X
X THRU X
RIGHT X
PEDS X
I NCRTHDOUND RT 3OUTHDOUND RT NCRTH/3OUTH FHAEING t
PHASE-1 FHASE-2 PHASE-?
PHASE-4 NCRTHDCUND LETT X
X THRU X
l RIGHT X
PEDE X
l SCUTHDOUND L
LEFT X
X X
THRU X
X RIGHT X
X PEDS X
X EASTDQUND RT X
WEST 3OUND RT X
i I
i
.m
O-t ECFECTIVE GREEtt'.3 - DESIGN AriALV3IS F :=, c.
=s==a.====a==========naa==========a=========u====-===============2m i
EFFECTI'/E GREEN, o EASTC3UND
. 5EI P e r ra i t t a d 44.00 Protected 12.00 TbRU 44.00 R*.GHT P a ren t t ted 44.00 4
Protected 12.00 WESTEOUND LEFT i
Permitted 44.00 Protected 10.00 THRU 44.00 RIGHT P?rmittod 44.00 Protoc.t9d 20.00 i
NCisTHROUND LGFT 1
Fermitted 43.00
(
Frotected 10.00 THRU 36.00 PIGHT i
F?rmitted 36.00 Protected 0.00 SGUTHBOUND i
LEcr Fe mittad 36.00 Protected 20.00 THRU 43.00 RIGHT Permitted 43.00 j
Frotected 0.00 t
4 4
I l
}'
VOL!)ME AD JtJSTMENT WORK 9 FEET Pv
================-:=======-;========3===r:--:z=-:ns-a=======-=;:=.==u===;
LANE LANE ADJ.
MVT.
ADJ.
LANE GRP. NO. UTIL.
GROWTH GRP.
P90o F:
VOL.
PHC VOL.
Gf9.
VOL. LN FACT.
FACT.
VOL.
LT E3 LT 100 0.7'e 134 L
134 1
1.000 1.000 134 1.00 6.
TH 592 0.79 740 749 2
1.050 1.000
~787 0.00 RT 196 0.79 134 R
104 1
1.000 1.000 134 0.00 1
WG LT 110 0.o9 111 L
111 1
1.000 1.000 111 1.00 0.
TH
?29 0.99 9'38 T
938 2
1.030 1.000 965 0.00 0.
RT 206 0.99 168 R
168 1
1.000 1.000 168 0.00
- 1. 4 NB LT 240 0.99 242 L
242 1
1.000 1.000 242 1.00 0.~o TH e.45 0.99 652 i
oS2 2
1.050 1.000 684 0.00 0
RT 397 0.90 320 R
320 1
1.000 1.000 320 0.00 LT 0.99 4 0 ".
L 496 1.000 1.000 1.00 0.<
TH
.:. v 0.99 343 T
34?
2 1.C30 1.000 Sol O.00 3..e RT 101 0.**
62 R
62 1
1.000 1.000 62 0.00 1.
- Denotes a Defacto Left Turn Lane Group
') -
SATURATION FLOW ADJUSTMENT WORKSHEET
========-========--=r===-2:==u:u2====.-==========================.--z, IDEAL A.\\..
SAT.
NO.
f f
f F
f f
f f
Sa-FLOW LNS W
HV G
p BB A
RT LT
.P.
EB 1800 1
0.930 0.990 1.000 1.000 1.000 1.000 1.000 0.960
'."2 T
1800 2
1.000 0.900 1.000 1.000 1.000 1.000 1.000 1.000 t u r-R 1800 1
1.000 0.9O 1.000 1.000 1.000 1.000 0.888 1.600 '. wi WD L
1800 1
0.030 0.990 1.000 1.000 1.000 1.000 1.000 0.9'50 15' T
1800 2
1.000 0.990 1.000 1.000 1.000 1.000 1.000 1.000 J'
R 1800 1
1.000 0.990 1.000 1.000 1.000 1.000 0.888 1.000 1r -
NB L
1800 1
0.930 0.990 1.000 1.000 1.000 1.000 1.000 0.950 UC -
T 1800 2
1.000 0.990 1.000 1.000 1.000 1.000 1.000 1.000 T.ie R
1500 1
1.000 0.990 1.000 1.000 1.000 1.000 0.?26 1.000
'1"_
3B L
1900 0.020 0.c90 1.000 1.000 1.000 1.000 1.000 0.950 M.
T 1800 1.000 0.990 1.000 1.000 1.000 1.000 1.000 1.000
-M A
1500 t
. 000 0.990 1.000 1.000 1.000 1.000 0.826 1.000 1t
4.
I o.~,-
CA?ACITY ANALYS!S WOFK9HIET n.
-: = = = =. ;2. = = = = = : = = = -2, 2 = = =.::,2===;=========-=====================,===-
ADJ.
ADJ. SAT.
FLOW LANE GROUP TLOW RATI FLOW PATI RATIO GREEN RATIO CAPACITY v/c (v)
(s)
(v/s)
(g/C)
(c)
RATIO e :s:.
m
'Loerrn.
70 Lorot.
65 1574 0.041 0.100 157 0.411
+
T 757 3564 0.221 0.367 1307 0.602 9
134 1493
- 0. 0 '0 0.467 697 0.193 WG L p e r rn.
67 Lprot.
44 1574 0.028 0.100 157 0.231 T
965 3564 0.276 0.367 1807 0.75a R
168 1493 0.113 0.533 797 0.211 NG L o e r rn.
171 Lprot.
71 1574 0.045 0.100 157 0.452 T
694 3564 0.192 0.000 1069 0.640 *-
R 320 1472 0.217 0.000 442 0.725 SD
/
L o e r rn.
220 Lprot.
167 1574 0.170 0.167 T62 1.010 T
361 3564 0.101 0.353 1_/(
O... : -
R 62 1472 0.042 0.358 528 0.110 0.679 120.0 cac.
Surn (v/s) critical =
C -/ c i e L o n g t n. C
=
t.
- : T i rn e P c. c C'ycle. L5 3.0 sec.
- -( critical = 0.728 9
917-LEVEL-OF-SERVICE WORK 5 FEET
====-====u_===_,===============a=====.4=,22===.:======================:
DELAY LANE DELAY LANE LANE DELAY LOC v/c g/C CYCLE d
GRCUP d
PROG. GPP.
GRP. BY 3Y RATIO RATIO LEN.
1 C Ac'.
2 FACT. DELAY LOS APP.
AP:.
EB L
O.411 0.467 17.0.0 16.0 157 1.0 1.00 17.1 C
19.0 C
7 0.602 v.367 120.0 20.5 1307 0.6 0.85 20.4 C
R 0.193 0. 47 120.0 14.3 697 0.0 0.85 12.1 B
WB L
0.291 0.467 120.0 14.9 157 0.3 1.00 15.2 C
20.5 C
T 0.754 0.367 120.0 25.3 1907 1.8 0.85 23.0 C
R 0.211 0.533 120.0 11.2 797 0.0 0.80 9.5 B
NB L
0.452 0.459 120.0 16.9 157 1.4 1.00 18.3 C
24.0 C
T 0.640 0.300 120.0 27.7 1069 0.9 0.85 24.3 C
R 0.725 0.300 120.0 29.5 442 4.0 0.85 27.7 D
SC L
1.019 0.467 120.0 24.7 262 40.2 1.00 72.o F
47.5 E
T 0.282 0.358 120.0 20.9 1277 0.0 0.85
- 17. :.
C R
0.'.13 0.358 120.0 19.6 529 0.0 0.85 16.7 C
26.6 (sec/veh)
Intersection LOS = D In orsection Delay
=
EXHIBIT 6 ItLD DATA USED FOR TR-201 ANALYSTE Machine Counts Used In Location Movement Time Period counts canacity Analysis Route 107 at NB 7-10 a.m.
Left 240 885 Old Country Road Thru 679
- R1ght _111
__S.Q 999 999 SB 7-10 a.m.
- Left 152 77 Thru 415 Right 111 101 593 593 Route 27 at WB 7-10 a.m.
- Left 85 30 Newbridge Road Thru 1423 1397 Right
_ 12 1482 1483 Willis Avenue SB 7-10 a.m.
- Left 683 182 at LIE North Thru 1107 Service Road 883 Right 227 1516 1516
- Evacuation Movement a
EXHIBIT 7 COMPARISON OF CALCULATIONS FOR KEY MOVEMENTS 100% Background /30% Evacuation /6-hour Time Period KLD NYSDOT Anproach Timg 2/C Delav-LOS E/C Delav-LOS Old Country Road at Route 107
'SB Left 0700-1000 0.566 19.0 sec-C 1.019 72.9 sec-F 1000-1300 0.538 17.2 sec-C 0.918 46.1 sec-E 1300-1600 0.634 20.2 sec-C 0.966 57.0 sec-E 1600-1900 0.788 27.5 sec-D 1.069 91.7 sec-F NB Right 0700-1000 0.706 28.5 sec-D 0.725 27.7 sec-D 1000-1300 0.673 27.1 sec-D 0.719 26.1 sec-D 1300-1600 0.633 25.2 sec-D
.775 28.7 sec-D 1600-1900 0.558 21.7 sec-C 0.825 32.4 sec-D Route 27 at Newbridae Road WB Left 0700-1000 0.713 15.5 sec-C 0.693 9.9 sec-B 1000-1300 0.742 17.3 sec-C 0.695 10.0 sec-B 1300-1600 0.936 42.1 sec-E 0.848 21.2 sec-C 1600-1900 0.722 25.5 sec-D 1.201 NA F
NB Thru 0700-1000 0.724 27.9 sec-D 1.068 80.8 sec-F Right 1000-1300 0.741 28.5 sec-D 1.090 88.5 sec-F 1300-1600 0.828 33.8 sec-D 1.141 110.0 sec-F 1600-1900 0.793 29.7 sec-D 1.216 NA F
Willis Avenue at North LIE Service Road (WB)
WB Left 0700-1000 0.885 28.1 sec-D 1.508 NA F
1000-1300 0.721 16.6 sec-C 1.179 116.3 sec-F 1300-1600 0.703 16.1 sec-C 1.069 58.4 sec-E 1600-1900 0.880 27.3 see-O 1.409 NA F
Willis Avenue at South LIE Service Road (EB)
SB Left 0700-1000 0.716 9.7 sec-B 1.753 NA F
1000-1300 0.660 8.6 sec-B 0.993 41.6 sec-E 1300-1600 0.721 11.4 sec-B 1.032 55.3 sec-E 1600-1900 0.912 26.1 sec-D 1.394 NA F
i
EXHIBIT 8 e
s NYSDOT Analysis of-KLD's 100% Background traffic and 20% evacuation 6 Hour Time Period Old Country Road at Route 107 Approach 11mg ylg Dglav-Los SB Left 0700-1000 0.772 29.0 sec - D 1000-1300 0.722 25.8 see - D 1300-1600 0.763 28.3 Sec - D 1600-1900 0.839 34.9 sec - D NB right 0700-1000 0.556 25.1 sec - D 1000-1300 0.616 26.2 sec - D 1300-1600 0.658 27.2 sec - D 1600-1900 0.667 27.4 sec - D Route 27 at Newbridge Road Approach ling yA Delav-Los WB Left 0700-1000 0.454 4.4 sec -'A 1000-1300 0.473 4.6 sec - A 1300-1600 0.557 5.9 sec - B 1600-1900 0.929 33.5 sec - D NB T+R 0700-1000 0.877 41.5 sec - E 1000-1300 0.899 43.9 sec - E 1300-1600 0.951 51.3 sec - E 1600-1900 1.026 67.6 sec - F Willis Ave. at North LIE Service Road (WB) i Acoroach ling y],g Delav-LOS WB Left 0700-1000 1.334 N/A
-F 1000-1300 1.028
-44.6
-E i
1300-1600 0.976 32.4
-D 1600-1900 1.240 NA
-F Willis Ave. At South LIE Service Road (EB)
Anoroach 11Eg ylg Delav-LOS i
SB Left 0700-1000 1.413 N/A
-F 1000-1300 0.920 30.6
-D 1300-1600 0.896 27.6
-D 1600-1900 1.123 98.9
-F
EXHIBIT 9 t
INTERSECTION OF SUNRISE HIGHWAY AND SOUTHBOUND MEADOWBROOK PKWY OFF RAMP 6 Hour Evacuation /100% Background /20% Evacuation Reserve Time Period Ramn Volume EHE EER caoacity capacity LQh 0700-1000 438 vph
.90 537 671 vph 135 vph D
1000-1300 543 vph
.92 590 647 vph 57 vph E
1300-1600 658 vph
.95 693 578 vph
-115 vph F
1600-1900 899 vph
.91 988 503 vph
-485 vph F
6 Hour Evacuation /100% Background /30% Evacuation Reserve Time Period Ramn Volume EHE SEE caoacity capacity LQE 0700-1000 672 vph
.90 747 671 vph
-75 vph F
1000-1300 732 vph
.92 796 647 vph
-149 vph F
1300-1600 487 vph
.95 891 578 vph
-313 vph F
1600-1900 1088 vph
.91 1196 503 vph
-693 vph F
PEF = peak hour factor SFR = Saturation Flow Rate I
EXHIBKT 10 e
+
OLD COUNTRY ROAD AND SOUTH OYSTER BAY ROAD 1004/30%/6 Hours Movement Time Period EfC Delay
- LQ3 WB-Thru 7-10 a.m.
- 1. 14 5 F
10 a.m.-l p.m.
1.288 F
1 p.m.-4 p.m.
1.322 F
4 p.m.-7 p.m.
1.351 F
- Cannot be calculated when V/C is greater than 1.2
30}KILP May 27, 1987 UNITED STATES OF AMERICA 1g JE -1 A11 :22 NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board G F F N ~, o ".
i.
" /tf 00 Chi p my
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-3
)
(Emergency Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of the RENEWED STATE OF NEW YORK MOTION FOR LEAVE TO FILE REBUTTAL TESTIMONY have been served on the following this 27th day of May, 1987 by United States mail, first class, except as otherwise noted.
Morton B. Margulies, Esq., Chairman
- Joel Blau, Esq.
Atomic Safety and Licensing Board Director, Utility Intervention U.S.
Nuclear Regulatory Commission N.Y. Consumer Protection Board Washington, D.C.
20555 Suite 1020 Albany, New York 12210 Dr. Jerry R. Kline*
William R. Cumming, Esq.*
Atomic Safety and Licensing Board Spence W.
Perry, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W., Room 840 Washington, D.C.
20472
7 T 4_
Mr. Frederick J. Shon*
Anthony F. Earley, Jr., Esq.
Atomic Safety and Licensing Board
. General Counsel U.S. Nuclear Regulatory Commission Long Island Lighting Company Washington, D.C.
20555 175 East Old Country Road Hicksville, New York 11801:
Ms. Elisabeth Talbbi W. Taylor Reveley, III, Esq.**
Clerk Hunton and Williams Suffolk County Legislature Post Office Box'1535 Suffolk. County Legislature 707 East Main Street Office Building Richmond, Virginia 23212 Veterans Memorial Highway Hauppauge, New York 11788 Mr. L. F. Britt Stephen B..Latham, Esq.
Long Island Lighting Company-Twomey,.Latham & Shea.
Shoreham Nuclear Power Station 33 West Second Street-North Country Road.
Riverhead, New York 11901~
Wading River, New York 11792 Ms. Nora Bredes Docketing and Service Section Executive Director Office of'the Secretary.
i Shoreham Opponents Coalition U.S. Nuclear ':egulatory Comm.
195 East Main Street 1717 "H" Street, N. W.
Smithtown, New York 117.87 Washington, D.C.
20555 Hon. Michael A. LoGrande Mary M. Gundrum, Esq.
Suffolk County _ Executive New York State Department of Law 120 Broadway, Third Floor H. Lee Dennison Building Room Number 3-116 Veterans Memorial Highway New York,-New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite "K"
Post Office-Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley.Ashare, Esq.
Lawrence-C. Lanpher, Esq.*
Suffolk County Attorney Christopher M. McMurray, Esq.
Bldg. 158, North County Complex David T. Case,~Esq.
Veterans Memorial Highway Kirkpatrick & Lockhart Hauppauge, New York 11788 1800 "M" Street,.N. W.
Ninth Floor - South Lobby Washington, D. C.
.20036-5891 Mr. Jay Dunkleburger Richard G. Bachmann,-Esq.*
New York State Energy Office U.S. Nuclear Regulatory Comm.
Agency. Building 2 Washington, D. C.
20555 Empire l State Plaza Albany, New York 12223 i-
4 David A.
Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick and Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 West 43rd Street New York, New York 10036 Douglas J.
Hynes, Councilman Town Board of Oyster Bay Town Hall Oyster Bay, New York 11771
, ~ j_
t
(',l{,/
Richard J.
Zdhnleuter, Esq.
Deputy Special Counsel to the Governor of the State of New York Executive Chamber, Room 229 Capitol Building Albany, New York 12224
- Via Hand Delivery
- Via Federal Express May 27, 1987