ML20235M827

Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Concerning Contention JI-4 (Traffic Mgt Plan).*

ML20235M827
Person / Time
Site:	Seabrook
Issue date:	02/21/1989
From:	Adler T MASSACHUSETTS, COMMONWEALTH OF, RESOURCE SYSTEMS GROUP
To:
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Download: ML20235M827 (19)

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' UNITED STA'ES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges:

Ivan W. Smith, Chairperson Dr. Richard F. Cole Kenneth A.McCollom In the Matter of -

PUBLIC SERVICE COMPANY OF NEW Docket Nos.

HAMPSHIRE, ET AL.

(Seabrook Station, Units 1 and 2) 50-443-444-OL (Off-site EP)

February 21,1989

'mSTIMONY OF DR. THOMAS J. ADLER ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OFMASSACHUSETTS, CONCERNING CONTENTION JI-4 (TRAFFIC MANAGEMENT PLAN .

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C=p.rwt of the Attorney General mwealth ofMassachusetts One Ashburton Place Boston, Massachusetts 021081698 (617)727 2200 8902280445 890221 FDR T ADOCK 05000443 I PDR

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SUMMARY

OF TESTIMONY In his testimony, Dr. Thomas Adler, who testified for the Mass AG on ETE issues in the NHRERP hearings, analyzes the issues raised in JI-4 about the adequacy of the SPMC's evacuation traffic management plan. His evaluation is structured around the five basic requiremerLs for traffic control that are listed in the Manual on Uniform Traffic Control Devices (MUTCD). The MUTCD is the publication of the Federal Highway Administration which contains traffic control standards that are required by federal law to be adopted by the states to ensure a uniform and safe national highway system.

He finds that these five basic requirements are not met by the SPMC's evacuation traffic management plan in numerous respects. As a result, he concludes that there is no reasonable assurance that an evacuation conducted using the strategies set forth in the SPMC's traffic management plan will result in an evacuation of the Massachusetts EPZ that occurs j any faster than an uncontrolled evacuation (i.e., one which  !

occurs without staffing the TCPs) would take. In fact, the SPMC's traffic strategies actually will increase the evacuation times for vehicles in the Massachusetts beach areas by about two hours. Dr. Adler further concludes that the SPMC's traffic .

management plan is generally poorly designed, inadequately staffed, and fails to employ numerous traffic control standards that are in conformance with best professional practice, as embodied in the MUTCD.

In a short second part of his testimony, Dr. Adler describes several IDYNEV runs he did to assist Dr. Robert Goble l in the preparation of his testimony.

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1. IDENTIFICATION OF WITNESS Q. What is your name and current occupation?

A.

My nr.me is Thornas J. Adler and I am President of Resource Systems Group Norwich, Vermont.

Q. . Are your professional qualifications as set forth in the testimony and attachments filed on September 14,1987 in this case still accurate?

A. Yes, they are.

Q. Would you please summarize your qualifications as they relate to this testimony.

A. - My educational background includes a B.S. degree in Civil and Environmental En,gineering from Comell University and a M.S. and PhD in Transportation Systems from M.I.T.

For ten years I was a professor ir, the engineering school at Danmouth College, teaching courses in transportation planning, transportation engineering, modeling and statistics and conducting reseaxh sponsored by the U.S. Department of Transportation and others. For the past two and one half years, I have served as President and Principal in-Charge for Transportation Projects at Resource Systems Gro4p in Norwich, Vermont. Our current pmjects include approximately forty independent transportation modeling/ planning studies and traffic impact assessments. Over the past several years, I have authored reports and provided expert testimony on traffic flow and safety for over fifty regulatory prMan at the federal and state levels.

IL TESTIMONY Q. Have you .ved Appendir/ of the New Hampshire Yankee Seabrook Manfor Massachusens Communides ("SPMC")7 A. Yes, I have It is the Tndic Management Manual Q. Have you also reviewed SPMC contention JI-4, Traffic Management Plan?

A. Yes, I have.

Q. Would you please read that contention and its basis?

A. "The evacuation plan contained in the SPMC is so poorly designed and so

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Adler114 Testirnony 3

. , i inadequately staffed that, even if State and local officials are assumed to make a best effons response, there is no reasonable assurance that either the permanent residents or the transients can or will be evacuated as efficiently as possible, therefore, the SPMC does not a provide reasonable assurance that adequate protective measures can and will be taken, and -

l it fails to comply with 10 CFR 50.47(a)(1),50.47(b)(10),50.47(c)(1), and NUREG 0654, Rev.1 Supp.1,Section II.J.

Basis A. The number of traffic control personnel relied upon by the SPMC is inadequate.

B. Insufficient capacity enhancing measures and other poorly conceived traffic control strategies are utilized by the SPMCs traffic management plan. 'Ihe SPMC has not adequately addressed the problems that will occur during an evacustion in the event that the Gillis Bridge is closed to traffic in order to facilitate the passage of boats.

C. The traffic control diagrams contained in the SPMC m not sufficiently clear to allow the SPMC's traffic management plan to be implemented." 'l i

Q. Have you evaluated this contention? i A. Yes. I structund my evaluation amund the dve basic requirements for traffic control that are listed in the Mamal on UnVorm Trq0fc ControlDevices (MUTCD). That manual is published and updated by the U.S. Department of Transportation, Federal Highway Administration and the standards that it details are requimd by federal law to be adopted by each state, including Massachusetts. 'The five requirements listed in the irrtroductory sectierr of the MUTCD are that traffic control devices should:

1. Fulfillaneed.

2. Command attention. '

3. Convey a simple, clear meaning.

4. Command respect of road users.

5. Give adequate time for proper response. (p. l A 1)

Adlet114 Testimony o 4 Five basic considerations are listed as elements to insure that these requirements are me placement, operation, maintenance and uniformity. While the MUTCD is primarily used for the design and placement of devices to be used under normal highway operating conditions, the basic requirements and considerations are also applicable to the design of an evacuation traffic management plan. I have used these requirements both as yardsticks for evaluating the SPMC and as a way of organizing my comments within this testimony.

Q. Have other professionals recommended that traffic concol devices used in nuclear power plant area evacuations be consistent with MUTCD standards?

A. Yes. The Applicants' consultants, KLD Anociates,in Volume 6 of the NHRERP, state in se section on Access Control Posts, "It is essential that these control devices, installed singly or in combination, satisfy the specifications of the Manual on Uniform Traffic Control Devices (MUTCD)."(p. 916)

Q. Will you please detail your evaluation of the SPMC against those requirements?

A.

Yes. I will start with the most fundamental issue: does the traffic management plan, as currently designed, " fulfill a need"? My evaluation of the SPMC evacuation traffic managemen plan indicates that there is no reasonable assurance that either the permanent residents or the transients can or will be evacuated as efficiently as possible. In fact, my analyses indicate that the Plan as currently designed will facrease the amount of time required for evacuation of the Massachusetts population noticeably above the level that might be achieved without traffic guid actively re-directing the traffic flow.

Q. Would you explain why the SPMC Plan actually slows the Massachusetts evacuation?

A. Yes. The Plan calls for re. routing af traffic at two m$r intersections. Traffic Control Post (TCP) B SA-06 in Salisbury is ineended to re direct traffic at the intersection of Lafayette Rd. (Rt.1), Beech Rd. (Rt. l A), Ehn St. (Rt.110), Madnock Rd., Bridge Rd. (Rt.1, 1 A) and Pleasant St. All of the evacuation traffic from Salisbury Beach (Beach Rd.) and from Lafayette Rd. (Rt.1) southbound is routed west onto Elm St. (Rt. I10). Only " light" traffic from

Adler JI-4 Testimony 5

i Mudnock Rd. is routed onto Bridge Rd. (Rt.1) southbound. In effect, the capacity of Bridge Rd.,

which passes south away from Seabrook Station, through Newburyport and Newbury and out of the EPZ is substantially'underutilized by this muting.

j At another key location, TCP B-AM-06 in Amesbury, the two lanes of westbound traffic from Salisbury traveling along Rt.110 are both routed onto I-95. The right lane of traffic uses the normal on ramp, while traffic in the left lane (except large vehicles)is directed to make a U tum to .

enter the Rt. I10 eastbound I 95 on ramp. In my opinion, and according to the Joint Stipulation Regarding ETE Issues, this U turn maneuver will reduce capacity to 50% of the normal on ramp capacity. However, an I 495 on ramp approximately one mile to the east along Rt.110 has surplus capacity which goes unused in the later stages of the evacuation.

Q. In Appendix J, the TCP diagram for the I 95/Rt.110 intersection states (Description Note 3): " Facilitate U turn by westbound traffic on Rt.110 at Elm St. for those who elect to travel on southbound I 95 orif westbound Rt.110, west of Elm St. is congested." Will this instruction insure that the capacity of the I-495 on-ramp is used optimally?  ;

A. No. Given that I 95 will be, for beach evacuees, the first high speed, free flowing i

traffic route that they encounter, most will, in fact. " elect to travel on southbound I 95." '

Particularly in the later stages of the evacuation, most of the evacuees will have been trapped in stagnant traffic queues for long periods of time. Behaving rationally, they will certainly choose to enter 195 over traveling one mile to the east to an I-495 ramp area with uncertain levels of l

congestion.  !

Q. Have you conducted analyses to determine the effect of the TCP operations as described in SPMC Volume 67 i A. Yea, I have 'Ihe attached Figurea 1 arx12 display the results of ETE calculations conducted with the I DYNEV simulation model developed and used by the Applicants' consultant. l Q. Would you please describe the assumptions made in these I DYNEV runs?

A. The runs are based on the fHes used as inputs to the most recent " base" ETE runs submitted by the Applicants in the New Hampshire P!ar hearings. These inputs were modified to

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' Adler11-4 Testimony 6 I reflect the conditions written into the Joint Stipulation Regarding ETE Issues and were further modified, for a subset of the runs, to reflect non staffing of TCPs D HA 02 (I 95/Rt. 51 in Hampton analyzed only for comparative purposes), B SA-06 (Rt.1/Rt. I A/Rt. I10 in

, Salisbury) and B-AM 06 (I-95/Rt.110 in Amesbury). The only major item in the ETE Stipulation not reflected in the runs is the inclusion of retuming commuters, which will increase the evacuation times above those shown here.

Q. Would you describe the results as depicted in Figures 1 and 27 A. Both figures show the number of vehicles and amount of time required for evacuation of a specific population to a certain location under conditions with and without staffing of the three control posts listed earlier. *Ihe evacuation scenario is the same (summer weekend) as that used as the full evacuation planning basis in the Applicants' ETE analyses. Figure 1 shows the numbers of vehicles remair.ing within a three-mile radius of Seabrook Station (in both New Hampshire ans Massachusetts) at the different points in the evacuation timeline, for the two staffing conditions. Because the evacuation of the three-mile ring is constrained by conditions at the I-95/Rt. 51 interchange in Hampton, New Hampshire and because the New Hampshire Plan includes substantial capacity enhancement at that location, the evacuation time for this two-state population is decreased by over one hour by this staffing.

Figure 2 shows the evacuation progress ofjust the Salisbury Beach population, with and without staffing of the Massachusetts control posts. As this figure illustrates, the evacuation is increased two hours by the imposition of the SPMC's TCPs. Thus, as stated in Basis B of Contention JI-4, the SPMC does not provide assurance that "either the permanent residents or the transients can or will be evacuated as efficiently as possible."

Q. Are there other elements of the SPMC that similarly fail to " fulfill a need" and/or work against an efficient evacuation?

A. Yes. The Access Control Posts (ACPs), particularly those along I-95 (GT-2) and I 495 (HA-4) are poorly designed and are more likely to disrupt rather than expedite the evacuation.

'4 Aser J14 Testimony 7

Q.' Would you explain in what ways theirdesign is inadequate?

A.

There are two problems that must be addressed by the design: the problem establishing the ACPs at the start of the evacuation and the problem of m them throughout the evacuation. Establishing the ACPs along I 95 and I 495 will r

,former case, intercepting four lanes of traffic on an 8 lane highway and, in the latter case lanes of traffic. Both of these highways are very heavily trafficked facilities with speed limits 55 mph. A typical police procedur: for stopping traffic on facilities like this under heavy tra

, conditions involves the use of two or more cruisers side by side with lights flashing ac

" pacer" cars initially, then slowing and finally stopping in the highway travel lanes. Wami flares m placed well upstream of the diversion point, and additional flares are placed leu than twenty feet apart at a shallow angle across the highway, leading to the diversion area. These pr ocedures for attempting to divert high speed traffic still involve a potential risk to both the officers and to the motorists; however, the risk is substantially less than that incurred using a le rigorous procedure.

While the diagrams in Appendix J indicate that both barricades and traffic cones will be used at the major ACPs,in fact, the Applicants now admit that only traffic cones will be supplie for ACPs.1sg Applicants' response to Intmogewy No.11 of the Mass AG's First Set of Interrogatories to Applicants. The notion that two civilian traffic guides, equipped only with shor (28 inch) orange traffic cones, will be able to re direct the flow of four 55 mph traffic streams distributed across a fifty foot width of asphalt travel lanes (at ACP GT-2) is one which assumes substantial safety risk at best and most likely is simply unworkable. The problems would be compounded if the ACP is to be established outside of daylight hours or during inclement weather I

conditions. Under any conditions, the results of this type ofinadequate staffing and planning range fmm serious accidents to a simpfe inability to carry out the ACP portion of the SPMCat these most criticallocations.

Assaming the ACPs could be established, the problems of operating and maintaining ther will be equally daunting. No pmvision has been made for guides to take breaks within their 12- '

AdlerJI 4 Testimony r

g hour shifts to eat, rest or accommodate other bodily functions. Given that there is only one traf guide stationed at each of the diversion points along the Interstates 0 9f and I-495), even a momentary absence of one of these critical pides could cause disruption of the control function sustained absence would almost certainly lead to breakdown of the function.

The " Access Control Point Traffic Guide Procedure" included in the SPMC's Tra Management Manual requires ACP guides to "Do thr, following":

a. Qg' agggg persons from passing the peripherd ACP sung for:

. Federal, State and local emergency response personnel;

. emergency response vehicles with specific missions and destinations (i.e., buses, ambulances, tow trucks);

. employees of the utilities responding to the plant, who have appropriaw.

idennfication; and 'l

. commuters returning to EPZ to gather heusehold members for evacuation.

b. Advise persons that they may be subject to radiation exposure if they proceed beyond the ACP. Also advise persons to listen to the local Emergency Broadcast System station for specific information on the emergency.

c. Time permitting, expedite the flow of traffic leaving the controlled area, but not at t the expense of access control functions. Do not a. low lines to form at the ACPs entering the EPZ. (emphasis added)(p. J-5)

This procedure, in practice, wi11 involve contradictions. At the Interstate ACPs, the initial traffic volumes will be too high for a sitsgle individual determine whether a vehicle should be allowed or

" discouraged" access without allowing " lines to form." For example, at the I 95 ACP in Georgetown, almost one vehicle per second will arrive at the northbound O during normal msh hour conditions. Over the course of the evacuation a total of over 5,000 vehicles will be genersted at this point by retuming commuters. Even assuming that these are evenly spread over the first four hours of the evacuation, the guide will have to process one such vehicle every three seconds.

Given that there will have to be some form of verbal enmmunica% wi:h each such vehicle to determine " eligibility" according to Procedure a., the screening task will be impossible to perform without lines forming at the ACP. Yet,if no screening is performed, the basic purpose of the ACP 'i is defeated and the design does not fulfill the stated purpose. If, on the other hand, screening is rigorously applied, the efficiency of the evacuation will suffer significantly for those delayed in the

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Adler114 Tesmov ' 9 queues.

An additional problem at the ACPs is that there will be'no signs indicating the nature of the emergency or of the diversion routing, so the guides will almost certainly be called upon to answer questions regarding these matters. This will add to the competing demands already faced by traffic guides.

Q. Moving on to the second MUTCD criterion, do the controls specified in the SPMC traffic management plan, " command attention"?

A. In several critical areas, no. Of particular concem is the exclusive use of cones rather than barricades at key ACPs and TCPs. KLD Associates,in the NHRERP recommended the use of Type III barricades for road closures, consistent with the MUTCD. NHRERP, Volume 6, p. 916. They further recommended mounting AREA CLOSED signs to the barricades and lights on every barricade and every third cone at all ACPs and TCPs. Finally, they recommended that "[altrow panels and advance waming lights should be used on approaches to all ACPs and TCPs located on Expressways so as to inform drivers that traffic will be channelized onto an exit ramp." NHRERP, Vol. 6, p. 9-16.

Q. Do you believe that banicades for road closures, signs, lights and advance waming devices, as recommended by the Applicants' consultants in the NHRERP, are necenary to

" command attention" at the ACPs and TCPs in the SPMC7 A. Yes. Type III barricades are 5 feet high,4 feet wide and have three reflectorized faces, so that they are clearly visible from a reasonable distance day and night. By contrast, the cones substituted in the SPMC are only 28" high,less than a foot wide and are not reflectorized.'

l The complete absence of supplementary lighting and of advance waming signs on expressway appmaches to ACPs and TCPs are signi5 cant deficiencies. In total, the SPMC deviates substantially from the standards for cwisc41ng auention specified in the MUICD.

Q. Do the traffic controls specified in the SPMC " convey a simple, clear meaning"?

A. No. There are numerous ambiguities both in instructions to the traffic guides and in cues that will be received by motorists that will ultimately result in confusion and inefficiency in the 1 i L

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Adict114 Testimony evacuation.

Q. Would you give some exampics of these problems?

A. Yes. One example given earlier is the basic contradiction between access control screening and avoiding queue formation at ACPs. Other specific examples can be found in many of the ACPs and TCPs specified in the SPMC. At severallocations, traffic guides will be directing traffic below operating traffic signals (red, yellow, green). Should the traffic guides ignore the signal indications and wave cars through on red s.!gnals? The SPMC commands traffic guides as follows: "Do not ta nper with traffic signals" (Appendix J, p. J 2), but it does not indicate whether they may direct traffic independently of the signal indicadons. If the guides elect to direct traffic contrary to the signal indications, the motorists will, in effect, be asked to break the law in deference to an un uniformed civilian.

Several further examples of ambiguous instructions to guides and cues to motorists can be found in the SPMC design for the major intersection of Rts.1/1 A/110 in Salisbury (TCP B SA-06). In that diagram, as in most others, arrows are used to indicate traffic flow to be facilitated, and arrows with bars to indicate tmffic to be discouraged. However, in this diagmm cones are used to block certain movements, but no arrows at all are shown to indicate how this traffic is to be treated. For example, there is no arrow indicating the contml intentions for westbound Rt. lA traffic turning left opposite the post office onto Mudnock Rd. This traffic stream would be relatively benign, if allowed. There is, however, also no arrow on the TCP diagram indicating i how traffic exiting Mudnock Rd. across School St. toward the post office should be nested. This movement would disrupt a majorevacuation flow,if allowed. Finally, there is a curved, dashed arrow on Rt.110 for eastbound traffic, accompanied by a set of barricades with the legend, " Block Traffic Flow." The intention of the TCP diagram appears to be to totally exclude westbound Rt.

110 from entering the intersection, and this makes sense in the context of the intended diversion of heavy westbound evacuating traffic across the double yeBow lines into the castbotmd lane at this location. But, does the instruction, " Block Traffic Flow," apply to all vehicles, and how is this instruction to be interpreted in the context of the geners1 traffic guide instmetion, "DO NOT

Adla JI 4 Tenimony 3)

POSITION CONES OR BARRICADES TO COMPLETELY BLOCK PASSAGE THROUGH ANY INTERSECTION"? Appendix J, p. J 2.

Evacuating motorists will be faced with additional ambiguities at this ma,ior Salisbury intersection. Approximately one half of the westbound traffic will be directed by a traffic guide to

, cross the double yellow line through the intersection. Have they then been given license, west of the intersection, to cross the double yellow line again, given the " light" oncoming traffic streams?

If they do cross cgain, they will seriously disrupt retuming commuters and emergency vehicles attempting to use this route.

Similar ambiguities to those in the TCP design for the Salisbury Rts.1/l A/110 intersection are found throughout the SPMC. In short, the Plan, as presently designed does not " convey a simple, clear meaning," but is fraught with contradictions and ambiguities.

Q. Will the traffic control plan " command respect of mad users"?

A. In several key areas, no 'Ihe use of un uniformed traffic guides and of insubstantial traffic cones as control devias in panicular simply are elements not likely to

command respect." I agree with Salisbury Police Chief Frank Beavers (see his testimony) that the drivers will not perceive un-uniformed traffic guides as having any authority, and the drivers will simply not be dete:Ted by traffic cones alone.

Q. Finally with respect to the AfUTCD requirements, do the SPMC control devices "give adequate time for proper response"?

A. Particularly on the high speed roadways, no. The absence of advanced signage, the absence of lighting for nighttime or inclement weather conditions, the use of small cones without reflectors and the placement of cones along very short taper sections are contrary to MUTCD guidelines.

Q. Do you have an overall opinion with respect to the adgwi of the SPMC's Traffic Management Plan and specifically with respect to the assertions in Contention JI-47 A. My opinion is that there is no reasonable assurance that the residents or transients in the Massachusetts portion of the EPZ will be evacuated as efficiently as p"'!* that the Plan is

AdlerJi 4 Tesdmony

. g poorly designed and inadequately staffed and it specifically does not employ traffic control strategies that are in conformance with best professional practice, as embodied in the Mand UnVorm Treffic ControlDevices.

Q. . Were you asked to perform additional runs with I DYNEV to evaluate ETEs under other evacuation scenarios?

A. Yes, and I have provided the results of those runs to Dr. Robert Goble to assist in the preparation of his testimony.

Q. Would you please describe those runs?

A. The additional runs att all similar to those described earlier as Figures 1 and 2 in that they use the JI 1BI 2 stipulations as the base for analysis, and simply represent different evacuation scenarios. Figure 3 shows the vehicles remaining within 3 miles for a beach evacuation with 50% resident evacuation, and Figure 4 shows the results from the same scenario, for the Salisbury Beach area. Both Figures 3 and 4 show results for staffed and unstaffed TCPs. Figures 5 and 6 show the results of a 50% beach evacuation with 50% resident evacuation.

Q. Does this conclude your testimony?

A. Yes, it does.

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