ML20235M164
| ML20235M164 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/10/1987 |
| From: | NEW YORK, STATE OF |
| To: | |
| Shared Package | |
| ML20235M147 | List: |
| References | |
| OL-3, NUDOCS 8707170087 | |
| Download: ML20235M164 (34) | |
Text
R;.
e UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'Before the Atomic Safety and Licensino Board i
)
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 CONCERNING KLD TR-201A AND LILCO'S REBUTTAL TESTIMONY OF MAY 27, 1987 I.
Introduction Ql.
Please state your names and addresses for the record.
Al.
I am David T. Hartgen, Principal Transportation Analyst with the New York State Department of Transportation, Albany, New York, 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, Albany, New York.
8707170007 870710 ADOCK 0500g 2
Q2.
State your qualifications.
A2.
Our qualifications were described in our Direct Testimony filed on April 13, 1987.
Q3.
What is the purpose of this Testimony?
j i
A3.
Our first purpose is to address the accuracy and complete-ness of LILCO's most recent study of the adequacy of roads in the vicinity of its three proposed reception center sites.
This study, dated April 30, 1987, is entitled
" Capacity Analysis on Approach Routes to the SNPS Reception Centers, Revision A" and is referenced here as KLD TR-201A
("TR-201A").
TR-201A is a revision of an earlier document, KLD TR-201.
A second purpose is to comment on LILCO's May 27 Rebuttal Testimony concerning our original Testimony filed on April 13, 1987.
Our review of the LILCO Rebuttal Testimony shows that Mr. Lieberman, LILCO's witness, has significantly misinterpreted our analysis on a number of critical points, and thus has reached inappropriate conclusions regarding our l
analysis.
In particular, Mr. Lieberman has claimed that the State's analysis suffered from allegedly double counting background traffic and allegedly directing all traffic (even background traffic) to the reception centers.
Both of these.
l'.,
j alleged errors, if true, would inflate traffic demand.
4 These assertions, however, are unfounded and appear to arise from a fundamental misunderstanding by Mr. Lieberman of the methodology employed in our analysis.
We thus offer'a response to LILCO's rebuttal testimony. This response contains no new analyses regarding Mr. Lieberman's rebuttal testimony, but, rather, addresses the methodology which he has misunderstood.
II.
ANALYSIS OF KIfD TR-201A Q4.
Have you had an opportunity to review TR-201A?
A4.
Yes.
QS.
Please describe your understanding of yR-201A.
AS.
TR-201A provides additional information on KLD's procedures and results of capacity analyses for approach routes to the Shoreham reception center sites.
Tjie document differs from earlier analyses primarily in that it purports to use updated information, expands slight /.y the number of intersections considered, and disc /$sses the entry ramp capacity problem.
I 1
1 l D
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Q6.
What specific problems have you identified as a result'of your review of TR-201A?
A6.
The' primary problems concern:
(1) incorrect use of back-ground traffic data; (2) incorrect intersection geometrics 4
datausedforcapacityanalysis;j(3) incorrect signal timing; (4) improper conclusions,regarding ramp. capacity and the relationship of ramp traffic o mainline trsffic; (5) inadequate analysis of queuesi and (6) improper analysis of the consequences of-operation et Level-of-Service F.1/
Q7.
Please describe your concerns about the use of background traffic volumes.
A7.
In analyzing the capacity of various intersections around the proposed reception centers, TR-201A continues to use incorrect background. data as input.
KLD has had counts of' turn movements taken at the intersections it has analyzed.
t 1/
We find that TR-201A contains the same critical errors made in TR-201 concerning:
1.
Inappropriate adjustments to data; 2.
Improper adjustments to intersection geometry; and 3.
Failure to analyze key intersections.
Therefore, our. earlier Testimony concerning the weaknesses of TR-201 is also completely applicable to TR-201A.
We will not repeat in this testimony those earlier points.
However, as was the case in TR-201 (agg 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) (May 27, 1987), at 3-7 ("Hartgen and Millspaugh Rebuttal")), the turning volumes used in TR-201A's capacity
. analyses differed from the volumes measured by the machine counts.
The numbers of vehicles used to calculate capacity l
for left, right and through movements do not generally match the machine counts.
In 13 of 28 evacuation movements, the volume of background traffic executing the turn the evacuation traffic would take to a reception center has been inexplicably reduced, thus increasing the available capacity for traffic traveling to the reception centers.
Exhibit 1 attached hereto shows the
' differences between the machine counts taken by KLD and the data it actually used in TR-201A.2/
As a result, therefore, j
TR-201A improperly overstates the likely capacity of roads
{
around the reception centers to handle evacuation traffic.
2/
In addition, we note that, in contrast to TR-201, TR-201A applies two sets of data to the analyzed intersections --
one for a.m. and one for p.m.
In other words, instead of one traffic pattern per intersection for the entire twelve hours, TR-201A now postulates two traffic patterns, each i
lasting for six hours.
However, neither traffic pattern matches the machine counts.
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j 08.
Please describe your concerns about intersection geometrics.
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L A8.
TR-201A also makes the same input error with respect to intersection lane assignment as was made in TR-201.
geg Hartgen and Millspaugh Rebuttal at 7-8.
For instance, TR-201A continues to assume that there is a double left turn for southbound traffic on Willis Avenue at the Southern LIE Service Road and for southbound traffic on Route 107 at Old Country Road.-
This, of course, serves on paper to increase capacity -- but the increase is a fiction.
Presently, there is only one lane designated for the left turns at each of these locations.
l There is simply no basis to assume that the through lane at these intersections will be used for a substantial number of left turns.
As Mr. Lieberman stated in his recent deposition, he saw only one car take a left turn from the i
through lane during field inspection of the intersections.
Egg Deposition of Edward B. Lieberman (June 23, 1987), at 31-32 ("Lieberman Dep.").
Indeed, the New York State DOT does not allow double left turns to be served by permissive phasing,3/ for obvious safety reasons:
the sight distance 3/
" Permissive phasing" refers to the situation where the motorist faces a circular green signal allowing a left turn whenever gaps in opposing through traffic permit the completion of the turn.
By contrast, in the situation of
" protected phasing," opposing through traffic faces a red signal, so the motorist need not wait for gaps in opposing traffic.
V
)
4 available to traffic in the outside left turn lane would be restricted by the queued traffic in'the opposing left turn lane.
In addition,'through traffic in the through lane would be blocked by left-turning vehicles waiting for a gap 5
in opposing traffic.
Experience has shown that this results
-in erratic stop and go operation, long delays to through traffic and an increase in rear-end. type accidents.
Moreover, it is illeoal for a driver to make a left turn from any lane other than the extreme left lane that is specifically signed to permit left turns.
Egg New York State Vehicle and Traffic Law SS 1160, 1163 (attached hereto as Exhibit 2).
Thus, the LILCO Plan fundamentally rests on at least two illegal and unsafe turn movements.
'Another example of KLD's reliance on prohibited double left turns occurs at Route 107 and Old Country Road, where TR-201A assumed that the double left turn being made by southbound traffic runs concurrently with the northbound left turn.
This can result in accidents due to mutual encroachment on the same intersection space by the outside j
(right-most) southbound left turn path and the northbound left turn-path.
For this reason, NYSDOT does not allow this Eypeofoperation.
l l )
i
Our review of TR-201A and Mr. Lieberman's deposition reveals a further unjustified practice which TR-201A has employed to increase capacity artificially.
At several intersections, TR-201A adds another lane (on paper) to the lanes actually present in the intersection by assuming that right-turning automobiles will be using the shoulders of the intersections as right-turn lanes.
Egg Lieberman Dep. at 56-57.
This is evident, for instance, at the intersection of Route 27 and Newbridge Road (Bellmore).
TR-201A assumes three lanes for southbound traffic on Newbridge Road when there are only two; TR-201 properly assumed only two lanes.
Mr. Lieberman stated that shoulders were identified as right-turn lanes wherever KLD personnel observed any instances of such use.
Id. at 57.
Of course, the effect of this creation of right turn lanes is to artificially increase road capacity.
In reality, however, shoulders cannot be relied upon as right turn lanes because of:
(1) obstacles such as parked and/or incapacitated vehicles which will preclude the passage of right-turning traffic (agg id. at 57); and (2) inadequate road capacity on the receiving leg to receive vehicles from an additional turn lane.1/
l 1
1/
Another example of KLD's incorrect expansion of road capacity can be foun'd at the intersection of South Oyster Bay and Old Country Road.
KLD takes full advantage of an l
overlap where the westbound right turns can be made during the phase for northbound and southbound protected left (footnote continued) 1 l l
As we' pointed out in'our Rebuttal Testimony, these errors significantly favor KLD's analysis, leading-to apparent V/C ratios less.than 1.0.
When they.are' corrected, as we did in our Rebuttal, the V/C ratios increase sharply, and many are, over 1.0.
This means.that-the intersections will'n21-operate during an emergency.
Q9.
Please describe your concerns about signal timing.
A9.
TR-201A.still'uses incorrect signal-timing data.
In' part'icular, TR-201A consistently. assigns more green time to evacuation movements than the current signal operation does.1/
By assigning more green time,-TR-201A inflates the a
L road capacity available for evacuation traffic.
At'several locations, KLD assumed that a significant amount of right turns on red will be made from lanes that are shared with through traffic.
This assumption is insupportable.
If the first car in line is not turning L
.i
)
l (footnote continued from previous page) turns.
However, the right-most lane from which these turns would be made is designated as a shared lane in their analysis.
As is the case with right-turn-on-red ("RTOR"), a
'through' car can block the lane and negate the benefit obtained from an overlap.
Thus, the effect of KLD's assumption is to artificially expand road capacity.
5/
Of the intersections analyzed, the only one where TR-201A used the' existing timing was at Route 107 and Old Country Road.
l _-_-_-_-___ _____ _____.
1
right, there will be no rights on red during that cycle.
While there will be some RTOR, we feel that TR-201A is too l
liberal in that regard.
010. What are your concerns about the discussion of ramp capacity and the relationship between mainline traffic and ramp traffic?
A10. Pages 12-13 of TR-201A discuss the relationship of the traffic on the major arterials (" mainline traffic") to traffic attempting to enter those roads from ramps.
We agree with TR-201A's observation that " vehicles attempt-ing to enter these congested highways will be serviced at low rates" and " traffic attempting to enter these highways will also encounter heavy congestion on the entry ramps and on the street systems upstream".
Egg id. at 13.
- However, TR-201A is incorrect in implying that traffic from outside the EPZ will have little impact on evacuation traffic from the EPZ as a result of these factors.
The assumption that l
EPZ traffic will be on the mainline before non-EPZ traffic
-- which would thereafter be required to make its way slowly onto the mainline -- is unfounded because: (1) not all EPZ residents get on the mainlines at the " eastern termini";
9 10 -
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e (2) evacuees mobilize over time ~and some non-EPZ residents may mobilize before EPZ residents; and (3) as EPZ evacuees mobilize, it is likely they will mix with background traffic l
i and'non-EPZ evacuees.
1 In addition, to the extent that non-EPZ-traffic does attempt f
to enter the congested mainline from the ramps, TR-201A is incorrect in implying that such traffic will have only a minimal effect on the freeway mainline flow.
Egg TR-201A at 13.
In reality, congestion on the ramps will have a signi-ficant effect on the rate of flow of the' freeway mainline leading to substantial delays for those on the mainlines.
This is supported by the Highway Capacity Manual (pp. 3-10 and 5-2) which indicates that on-ramp traffic will either force its way into the mainline flow or will be allowed in I
by' mainline traffic.
In either instance, it will slow mainline traffic significantly.
011. What concerns do you have about KLD's analysis of queues?
f i
All. TR-201A asserts that the available queue storage capacities are adequate to avoid any queue from one path interfering with evacuation flow traveling on another path.
Sgg TR-201A at 27.
Mr. Lieberman posits that even if some of the queues i __
exceed storage capacity, the resulting interference with evacuating traffic streams will be transient.
We disagree with this conclusion.
We agree with Mr. Lieberman that queued vehicles will take-road space.
As he notes later, Mr. Lieberman assumes that-the queues will extend upstream from the monitoring sites.
This means that they will take up road space in the intersections.
This will cause a breakdown of the func-tioning of.the intersections, which in turn, will further reduce capacity.
l Mr. Lieberman also assumes that queues on the approaches to the proposed reception centers will not have any background 1
vehicles mixed in with them.
That is unlikely, for reasons stated above in Answer 10.
Instead, the lines might be considerably longer, further slowing access to the sites.
Q12. What are your concerns about Level-of-Service F operation, as defined by Lieberman?
)
i A12. TR-201A assumes that Level-of-Service F operation will per-mit traffic to flow at a rate equal to the maximum capacity and at a mean speed of 17 mph steadily and smoothly, for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
The 17 mph assumption is too high for the stop-and-go traffic that will occur at Level-of-Service F.
This is highly unlikely and constitutes a misleading interpretation of the term " Level-of-Service F".
According to the Highway 1
Capacity Manual (page 3-10), Level-of-Service F is described as follows:
Level F describen forced or breakdown flow.
Such conditions generally exist within queues forming behind breakdown points.
Such breakdowns occur for a number of reasons:
a.
Traffic incidents cause a temporary reduction in the capacity of a short section, such that the number of vehicles arriving at the point is greater than the number of vehicles that can traverse it.
b.
Recurring points of congestion j
exist, such as merge or weaving a
areas and lane drops, where the number of vehicles arriving is greater than the number of vehicles traversing the point.
c.
In forecasting situations, any location oresents a oroblem when thq oroiected Deak hour for other) flow rate exceeds the estimated capacity of the location.
4 It is noted that in all cases, breakdown occurs when the ratio of actual arrival flow rate to actual capacity or the forecasted flow rate to estimated capacity exceeds 1.00.
(Emphasis added).
The Highway Capacity Manual further shows I
(Figure 3.4, page 3-5) that the maximum V/C ratio for Level-1 of-Service F is 1.0, and that through volume can drop sub-stantially as vehicles maneuver and engage in stop and start behavior.
In view of these factors it is insupportable to 1
1 o
assume that Level-of-Service F operating conditions will consist of smooth flow at 17 miles per hour for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> total.
In fact, the rate of flow could be much lower.
Q13. Do you have other concerns about the analysis in TR-201A?
A13. Yes, we have.a number of additional concerns as follows:
There is still no analysis of the capacity of highway sections between intersections.
The entire analysis is based on the assumption that intersections control the movement of traffic and provide minimum espacity.
In fact, however, certain narrow links may control capacity.
In addition, a number of key intersections have still not been analyzed.
For instance, in reviewing the map at page 9 of TR-201A, one will note that the key off-ramp from the LIE westbound to Route 107 southbound is not analyzed.
Neither i
is the key off-ramp from the LIE to the South Oyster Bay
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Expressway.
Likewise, at page 11, the key off-ramp from the Meadowbrook Parkway to eastbound Sunrise Highway has not l
been analyzed.
This ramp will significantly reduce flow to
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the Bel'lmore reception center.
Egg Hartgen and Millspeugh Rebuttal at 14-15.
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Q14. Please summarize your concerns about TR-201A.
A14. In summary, the analysis in TR-201A does not deal with any of the concerns we raised concerning TR-201 and raises further concerns.
It is our belief that the scenario being described here is essentially one of gridlock, chaos between background traffic and evacuation traffic, and substantial reduction of highway system performance.
The effect of all of these factors is that evacuees will not be able to reach the sites and be monitored within the requisite time period.
We believe that the resulting queues will cause localized (and perhaps areawide). gridlock in the system, both in and around the sites and on the approach paths.
The evacuation plan, as proposed, will not work.
III. RESPONSE TO REBUTTAL TESTIMONY OF EDWARD B. LIEBERMAN Q15. Please summarize your conclusions regarding the Rebuttal Testimony of Edward B. Lieberman on the Suitability of Reception Centers.
A15. Our review of the rebuttal testimony prepared by Mr. Lieberman concerning our prefiled testimony of April 13, 1987, shows that Mr. Lieberman has significantly
misinterpreted our analysis on a number of critical points, l
and thus has reached inappropriate conclusions concerning our assessment.
His most critical errors concern:
i
-1.
Misinterpretations of assignment of background
, traffic to the highway network; I
2.
Misinterpretation concerning the meaning of V/C
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ratios greater than 1.0; and 3.
Use of misleading information concerning truck traffic and growth of background' traffic on Long Island.
Q16. Mr. Lieberman suggests at page 25 of his testimony that the State misrepresented traffic demand by double-counting.
Is he correct?
A16. No, in our analysis, we used field data (average annual daily. traffic)6/ to estimate the average 12-hour background traffic (in a manner similar to what was done by LILCO in TR-192).
Background traffic was simply assumed to be present on each of our highway links, just as it was assumed to be present at each of Mr. Lieberman's intersection approaches.
In a manner similar to Mr. Lieberman's j
methodology, evacuation traffic on each route was then added to the background traffic, and the total compared with the
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Accordingly, Mr. Lieberman's assertion that the State's analysis was not based on field data is inaccurate.
I l.._ _ ___ _ _ - _-_ - - -__ -
u available capacity for the particular location.
Where the V/C ratio approached or exceeded 1.0, we drew conclusions about the level of congestion and resulting delays.
Since background traffic is not moved along the highway network at all, but is simply assumed to be present, there is no double counting of background traffic on any of our highway links.
Mr. Lieberman has failed to understand that background traffic in our analysis is nqt assigned over the highway network from Jink to link, but is simply attributed to each highway section as traffic which must be accounted for in the event of an evacuation.
Q17.
Mr. Lieberman also asserts that you moved all background traffic to the reception centers.
Is this correct?
A17.
No.
Again, background traffic was not moved in our analysis.
Rather, the background traffic measured on a link was simply assumed to be there.
By knowing the capa-city of the road and adding the evacuation traffic to the background traffic already on each link, we could determine whether road capacity was exceeded.
Q18. f4r. Lieberman criticizes your analysis for considering V/C ratios of greater than 1.0.
Do you agree?
1 _ _ _ _ _ _ _
A18. No.
Mr. Lieberman asserts that V/C ratios cannot be greater than 1.0.
Yet again, Mr. Lieberman's criticism stems from his fundamental misunderstanding of how we treated back-ground traffic.
He also confuses two concepts.
The Highway Capacity Manual specifically allows for analysis of V/C ratios greater than 1.0.
Egg Highway Capacity Manual, at 3-10.
Mr. Lieberman is confusing operational V/C ratios with projected V/C ratios.
1 Q19.
On page 29 of his rebuttal testimony, Mr. Lieberman asserts that you have violated flow conservation laws in your net-work analysis.
What is your response to this criticism?
i A19.
Mr. Lieberman is incorrect for the same reason described above -- he has misunderstood the way background traffic was analyzed.
Flow conservation laws apply only when all traffic on a network is actually assigned over it.
In our case, only evacuation traffic is assigned.
As stated previously, background traffic is simply present on each link.
Therefore, flow conservation for total traffic is j
unnecessary.
When one reviews our assignment outputs, it is apparent that flow conservation la maintained for EPZ l
evacuating traffic.
I Q20. Mr. Lieberman also f'aults your analysis for reducing LIE capacity by 7.5%.
Is his criticism appropriate?
1 l
A20. No.
Mr. Lieberman suggests that such a reduction is 1
inappropriate in the absence of upgrades.
He overlooks the 1
I fact that such a reduction of capacity la appropriate to i
reflect the presence of trucks.
We applied the 7.5% reduction of capacity to traffic on the LIE only to account for the high percentage of trucks on that. facility.
We did not make further adjustments to account for grades or curves; therefore, our approach is conservative.
The Board should recognize that Mr. Lieberman's assumption concerning truck' traffic volume f
-- only 2% overall -- is unrealistic.
The State's own data shows that the percentage of truck traffic can be as high as 20% on the LIE.
The Highway Capacity Manual software uses 2% as a default value; Mr. Lieberman's use of this number indicates that he has no better information.
021. Mr. Lieberman criticizes your projections for growth on Long i
Island.
Are his criticisms accurate?
A21. No.
The LILCO rebuttal selectively excludes growth in the i
Suffolk County population.
Recent data for Suffolk County i
populatl'n show that it grew 2.9% during the period 1980-85, o
or more than 3 times faster than Nassau County.
$ rom the i
period 1985 to 2010, Suffolk County is projected to increase in population by 22.18%.
Because traffic grows even more _ _ _ _ - _ _ _ -
's rapidly than population or households, a realistic projec-tion would be that road traffic on Long Island is likely to be considerably greater in the future than in the present.
Q22.
On pages 23 and 24 of his rebuttal testimony, Mr. Lieberman identifies six alleged errors in the DOT network.
Is he correct?
A22.
Of the six purported errors, Mr. Lieberman is correct in two cases.
He is incorrect in the other four.
The errors correctly identified are:
(1) Link (3,4), a portion of the Northern State Parkway, should be Link Type 73, capacity 4,000.
We had assumed 3,600.
(2) Link (113,780), a portion of the Sunrise Highway, should be Link Type 79, capacity 6,000.
We assumed 4,000.
Contrary to Mr. Lieberman's assertions, however, the two
[
revisions have no significant effect on our analysis or our i
conclusions.
On the other hand, Mr. Lieberman is incorrect i
with respect to four of the six alleged errors in the DOT network:
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a
(1) Link (320, 3) is Route 347 from Route 25A to the Northern State Parkway.
Its narrowest portion is 4 lanes; a portion is 6 lanes.
Link Type 70 is Correct.
(2) Link (2, 310) is Route 25 from Route 347 to Route 25A.
It narrows to 2 lanes -- one in each direction.
Link Type 61 is correct.
(3) Link (780-118) Sunrise Highway is 3 lanes partially.
access controlled in one direction.
We properly assigned it a capacity of 3,200 to approximate that situation.
(4) Link (7, 206) Route 107 is 2 lanes in the southern direction at the narrowest point.
Our designation was correct.
Q23. Does that conclude your testimony?
A23. Yes. (
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F'YHTBIT 1 Comparison of Field Counts and Counts Used By MLD in the capacity Analvnis of TR-201A l
Location.
Movement Time Period Machine Counts Counts Used 107 at Old NB 7-10AM L % 885 i
. Country Rd 7/17/86 T --
679 R
114 80 l
1 SB 7-10AM*
L 152 77 441 1
Willis Ave at WB 7-10AM*
L
'683 183 LIE North 7/10/86 T-1107 Syc Rd R/
227
' Route 27'at WB 7-10AM*
L 85 30 Newbridge 7/11/86 142 1397 3
Willis Ave at SB 7-10AM*
L 271 271 LIE South 7/17/86 T
668 Svc Road R
0 i
- Indicates critical evacuation movement.
4 L
i s
Location Movement ' Time' Period Machine Counts Counts Used I.
~Old Country Rd EB 7-10AM
.L 359 94 at Seaford' 3/16/87 T
815 1080 Oyster.
R Bay Expwy NB ramp WB 7-10AM L
1126 NB 7-10AM*
L 334 3/16/87 T
654 R
320
119 155 7/18/86
-T R
191 155.
EB 7-10AM L
3/16/87 T
873 R
256 WB 7-10AM L
305 234 3
3/16/87*
T 985 1068 i
R
)
I l
e g
l 1 1
s Location Movement Time Period Machine Counts Counts Used Old Country Rd EB 7-10AM L
248 312 l
at Manetto Hill 3/16/8 T --
484 Rd R
280 l
l WB 7-10AM L
242 158 3/16/87*
T 588 1
R -
141 l
l NB 7-10AM L
276-365 j
3/16/87 T
298 8
R 82
.l SB 7-10AM L
117 141 l
472 2
i Old Country Rd EB 7-10AM L
88 at Park Ave 7/10/86 T
884 796 R
WB 7-10AM L
20 7/10/86 T
980 950 R
10 NB L
No O
T Counts O
R 0
SB 7-10AM L
64 3/12/87 T
214 17 R
133 5
1 l
l I
I i
l 3-
{
l
l
\\
s Location Movement Time Period Machine Counts Counts Used Old Country Rd WB 7-10AM*
L 59 114-at New South Rd 3/13/87*-
T-910 R /
10 i
EB 7-10AM L
17 9
3/13/87 865 NB 7-10AM L
62 3/13/87 T-214 47 R
105 SB 7-10AM L
107 89 3/13/87 T
115 R
33 Round Swamp Old Country Rd WB 7-10AM*
& LIE 7/10/86 101 EB 7-10AM L
T R
NB 7-10AM L %.
333 3/12/87 T
543 R
0 SB 7-10AM L
0 3/12/87 634 5
6 o
.s Location Movement Time Period Ma hine Counts Counts Used Newbridge Rd SB 7-10AM L'
93 131 at Merrick Rd 3/18/87 T
160 R #
71 NB 7-10AM L
252 257 l
o 151 3g EB 7-10AM L
49 83 3/18/87 4
640 WB 7-10AM L
43 86 1101 0
EB LIE Svc Rd EB 7-10AM L
110 l
at Roslyn Rd 3/17/87 T
324 117
)
R 97 NB 7-10AM L
0 3/18/87 842 67 SB 7-10AM L
104 104 3/18/87 85 854 1
l j
i l
J I 4
___-_ _D
.t.
Location Movement Time Period Machine Counts Counts Used Hicksville Rd NB 7-10AM L
56 22
,(107) 3/13/87*
T 92 1052 at New South Rd R
144 SB 7-10AM L
12 7/11/86 T
169 139 R
19 EB 7-10 AM L
101 125 290 6
WB 7-10AM L
77 83 3/13/87 T
77 71 R
0 Hicksville Rd NB 7-10AM L
187 222 (107) 3/11/87*
T 506 Hempstead Tpk R
208 (24)
106 101 3/11/87 T
298 297 EB 7-10AM L
145 45 762 00 WB 7-10AM L
44 69 1106 g
I -_______________j
t Location Movement Time Period Machine Counts Counts Used I
Broadway (107)
SB 7-10AM L
0 at Newbridge 3/13/87*
T 666 666 (106)
R 0
NB 7-10AM L
0 3/13/87 T
751 751 R
0 EB 7-10 AM L
3/13/87 2
733 WB 7-10 AM L
0 3/13/87 T
826 0
R 0
Willis Ave at NB 7-10AM L
115 NSP 7/10/86 T
876 SB 7-10AM T
839 600 3/13/87 R
6 245 EB 7-10AM*
L 76 76 7/11/86 i
s _
Location Movement Time Period Machine Counts Counts Used Sunrise Hwy &
EB 7-10AM L
31 90 Bellmore Ave
.3/11/87 4
1098 5
WB 7-10AM L
42 129 2109 0
NB 7-10AM L
47 3/11/87 T
358-265 R
47 SB 7-10AM L (No Counts.
107 3/11/87 T Only PM 173 R Counts shown.)
88 l
I Sunrise Hwy EB 7-10AM L
65 13 l
A. Babylon Tpk 3/12/87*
T-1164 g y 1119 7
WB 7-10AM L
145 40
/ /87*
1876 f
NB 7-10 AM L
176 164 3/12/87 T
215 223 SB 7-10AM L
90 104 3/12/87 256 2
a 5
i 4
.i Location Movement Time Period Machine Counts Counts Used Sunrise Hwy EB 7-10AM L
142 74
{
at Merrick 3/11/87*
T 99 gg WB 7-10AM L
93 22 f
0 2088 0
NB 7-10AM L
42 68 3/11/87 T-248 R
43 SB 7-10AM L
99 100 3/11/87 T
18 2M S. Oyster Bay Rd SB 7-10AM L
59 115 at Woodbury Rd 3/9/87*
T-548 R #
155 NB 7-10AM L
166 166 755 EB 7-10 AM L
126 155 8
317 9
WB 7-10AM L
182 196 4
450 82 d
8 f
_g_
_=
0 t
1 Location Movement Time Period Machine Counts Counts Used So. Oyster Bay.
WB 7-10 AM L
135 139 Rd at Old 3/12/87*
T 937 County R
445 R
510 219 107 at' SB 7-10AM L
66 k
Scott St.
3/6/87 T
1661 1512 l
R 83 NB 7-10AM L
105 188
)
1773 107 at SB 7-10AM L
43 29 W. John St.
3/6/87*
T 682 R
22 i
NB 7-10AM L
480 513 3/6/87 T
1125 1
i e
I
! 1 1
-__=___ _-_-
McKIXXEY'S 1
CONSOLIDATED LAWS 0F NEW YORK ANNOTATED Book 62A Vehicle and Traffic Law 600 to End i
With Annotations From State and Federal Courts i
and State Agencies j
ST. PAUL, MINN.
WEST PUBLISHING CO.
(
Exhibit 2 x
/
ARTICLE 28-TURNING AND STARTING AND SIGNALS ON STOPPING AND TURNING Section 1160. Required position and method of turning at intersections.
1161. U turns in certain areas prohibited.
1162. Starting parked vehicle.
1163. Turning movements and required signals.
1164. Signals by hand and arm or signal lamps.
1165. Method of giving hand and arm signals.
1166. Required position for turning at alley, driveway, private road or onto property off the roadway.
g 1160. Required position and method of turning at intersec-tions The driver of a vehicle intending to turn at an intersection shall do so as follows:
(a) Right turns. Both the approach for a right turn and a right turn shall be made as close as practicable to the right hand curb or edge of the roadway.
(b) Left turns on two way roadways. At any intersection where traffic is permitted to move in both directions on each roadway entering the intersection, an approach for a left turn shall be made in that portion of the right half of the roadway nearest the center line thereof and by passing to the right of such center line where it enters the intersection and after entering the intersection the left turn shall be made so as to leave the intersection to the right of the center line of the roadway being entered. Whenever practicable the left turn shall be made in that portion of the intersection to the left of the center of the intersection.
(c) Left turns on other than two-way roadways. At any intersec-tion where traffic is restricted to one direction on one or more of the roadways, the driver of a vehicle intending to turn left at any such intersection shall approach the intersection in the extreme left hand lane of the roadway lawfully available to traffic moving in the direction of travel of such vehicle and after entering the intersection the left turn shall be made so as to leave the intersec-tion, as nearly as practicable, in the left hand lane lawfully available to traffic moving in such direction upon the roadway being entered.
(d) When markers, buttons, signs, or other markings are placed within or adjacent to intersections and thereby require and direct that a different course from that specified in this section be traveled by vehicles turning at an intersection, no driver of a
- vehicle shall turn a vehicle at an intersection other than as directed and required by such markers, buttons, signs, or other markings.
Q 1163. Turning movements and required signals (a) No person shall turn a vehicle at an intersection unless the vehicle is in proper position upon the roadway as required in section eleven hundred sixty, or turn a vehicle to enter a private road or driveway, or otherwise turn a vehicle from a direct course or move right or left upon a roadway unless and until such movement can be made with reasonable safety. No person shall so turn any vehicle without giving an appropriate signal in the manner hereinafter provided.
(b) A signal of intention to turn right or left when required shall be given continuously during not less than the last one hundred feet traveled by the vehicle before turning.
(c) No person shall stop or suddenly decrease the speed of a vehicle without first giving an appropriate signal in the manner provided herein to the driver of any vehicle immediately to the rear when there is opportunity to give such signal.
(d) The signals provided for in section eleven hundred sixty four shall be used to indicate an intention to turn, change lanes, or start from a parked position and not be flashed on one side only on a parked or disabled vehicle, or flashed as a courtesy or "do pass" signal to operators of other vehicles approaching from the rear.
(e) The driver of a vehicle equipped with simultaneously flashing signals as provided for in subdivision eighteen-a of section three hundred seventy five shall use such signals when the vehicle is stopped or disabled on a public highway, except when such vehicle is stopped in compliance with a traffic-control device or when legally parked. The driver of a vehicle so equipped may use such signals whenever necessary to warn the operators of following vehicles of the presence of a traffic hazard ahead of the signaling vehicle, or to warn the operators of other vehicles that the signaling vehicle may itself constitute a traffic hazard, taking into account traffic and highway conditions. No person shall use such signals ~
for any other purpose.
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