ML20235T499
| ML20235T499 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/23/1987 |
| From: | Lieberman E SUFFOLK COUNTY, NY |
| To: | |
| References | |
| CON-#387-4044 OL-3, NUDOCS 8707220160 | |
| Download: ML20235T499 (67) | |
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'11MNSC1&L m
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OF PRCCEEDIGL UNITED STATES OF AMERICA; OR GIRAL NUCLEAR REGutATORY COmuSnN.
p BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of:
Docket No. 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning)
(Shoreham Nuclear Power Station, Unit 1)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x DEPOSITION OF EDWARD LIEBERMAN Hauppauge, New York Tuesday, June 23, 1987 ACE-FEDERAL REPORTERS, INC.
Stenotyy' Pqvrters 444 North Capitol Street
..,)
Washington, D.C. 20001 l
(202)347-3700 l
Nationwide Coverage 3
)
800-336-6646 50 8707220160 870623 PDR ADOCK 05000322 l
T PDR i
A ga 1
-l
~
1-
-1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 2
BEFORE THE ATOMIC SAFETY & LICENSING BOARD j
3
-In.the Matter of:
4 LONG ISLAND LIGHTING COMPANY i
51 (Shoreham Nuclear Power. Station, Unit 1).
6 9:30 a.m.
7 8
DEPOSITION OF EDWARD LIEBERMAN, a 9
witness herein, taken by the County of Suffolk, at 10 the offices of the~Suffolk' County Attorney,. Veterans 11 Highway, Hauppuuge, New' York, on Tuesday, June 23, 12 1987, before Debra Stevens, a shorthand reporter and-13 notary public, within and for'the State of New.
14 York.
15
'36 17 4
38 19
'20~
TANKOOS REPORTING COMPANY, INC.
21 150 Nassau Street 223 Jer!cho Turnpike New York, N.Y.
20038 Mineola, New York 11501 22 (212)349-9692 (516)741-5235 O
COMPUTER AIDED TRANSCRIPTION / keyword index i_______:-_.________
! ^ 9,.
-2 l'
b..E E.1.A &_h..)L Q.R A-.1.
2-
'KIRKPATRICK'-& LOCKHART, Attorneys' f or: Suffolk-County.
3 South - Lobby - 9th Floor 1800'M Street, N.W.
.4 14ra sh i ng t o n,
D.C.
20036-5891 5
.SY: ~ CHRISTOPHER McMURRAY, E S O.,
RONALD.R. ROSS, ESO.
t.
'7 HUNTON.&' WILLIAMS, ESOS.
~ Attorneys for LILCO
'8 P.O.
Box 1535-Richmond, Virginia 23212
.9 BY:
JAMES N.
CHRISTMAN, ESO.
10 ALSO'PRESENT:
Jeff Sobotka.
11 12
'13 14 l
15 36 17 1
18 19 20
~
21 22 l
O COMPUTER AIDED TRANSCRIPTION / keyword index a
b 3
1 Whereupon, 1
2 EDWARD L I E 6 F.R M A N,
3 having been first duly sworn, was examined and k
4 testified as follows:
~
5 EXAMINATION BY MR.
McMURRAY:
l 6
O.
State your name for the record?
7 A.
Edward B.
Liebermen.
8 O.
Mr.
Lieberman, my name is Chris McMurray 9
and I will be asking you some questions today about 10 your analysis, which we will call KLD TR-201A, the 11 official title of which is " Capacity Analysis on 12 Approach Routes to the SNPS Reception Centers."
13 If you have any questions about my 14 questions or if my questions are unclear, please let 15 me know.
16 A.
Fine.
l 17 O.
Mr. Lieberman, let's please turn to page l
18 fivt.
You do have KLD TR-201A in front of you?
19 A.
I do.
2D Q.
Turn to page five of that document.
21 There you speak about certain revisions which were 22 made to a previous document, TR-201; ' correct, at the O
COMPUTER AIDED TRANSCRIPTION / keyword index
.4 i
O
'l top of the page?
2 A.
Yes.
3"
'O.
Can you tell'me, please: why.you decided 4
to makeKrevisions to the: original ~ analysis TR-2017 5
A.
Well, basically we--TR-201 was 6-
- undertaken under, a ' ti ne~ constraint and, while I think 7
-we-did a thorough job.under'those conditions, we 8
decided to' review what we had done.
Part.of that'
'9 motivation.for review was based on photographs which 10 we.took which' indicated that there was'some'new RTOR 11-signs which--
12 O.
New RTOR signs?.
13 A.
Right.
14 O.
Right-turn-on-red signs?
15 A.-
Right.
We decided to just review 16
.everything,we had done.
We also took some additional-
'17 data.
'Since our original'201, we took turning. data 18 in the morning, not in the afternoon, we decided that, 39 we had to augment that with counts taken in theEp.m.,
r L2O order'to more properly represent the turn movements 21 during the p.m.
period.
-22 We also decided to go out and measure O
COMPUTER AIDED TRANSCRIPTION / keyword index
5-
-(
1
.the: lane. widths more occurately than we had done and 2
refinements of t hat. nature.
4
.3 I don't think--I was going to say,
.I
- 4
.think this fol-lowed hard on the heels of the.other 5
one.
I don *t think there is a~1erge amount of time 6
between publication of the two documents.
7 O.
Can you recall any other refinements?-
8-You listed the right-turn-on-red, taking additional 9
counts and measuring the lone widths.
-Can.you.think1 10 of any others?
11 A.
You mean in terms of field data?
I 12 think we took additional signal timing data a l s o~.
'13 Q.
So, 201A.did not rely at all on any of 14 the counts taken in TR-192, which-was the original.
15 analysis that you did?
16' A.
Oh, certainly it did.
17 Q.
It did?
18 A.
Sure.
19 Q.
Do I understand you to say that-TR-201A
.2O was based on counts that were taken back in '86 for j
21 TR-192 and also on counts that were taken, I guess, 22 around March for TR-2017 1
COMPUTER AIDED TRANSCRIPTION / keyword index
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A.
I don't' recall whether we took any.
2 counts per se.
We had to take counts'in order to get.
3.
turning movements, but they were_specifically-for the-
~ '4 purpose'of'getting turning movements rather then.
5' volumes as such.
-6 Q.
You are talking'about for 201A7
~7 A.
Well, for both, actually.
8 O.
201 and 201A7 9
A.
Right.
201 we took counts in the a.m.,
10 as it turned.out.
And when I reviewed that.-saw it.
11 was limited to the a.m, I then decided'it had to be 32 done for-both a.m.
and p.m.
13 G.
So when you used the term " counts," when 14 you say you took counts in.the morning for 201--
l 15 A.
Right.
16 Q.
You were taking turn movement counts?
17 A.
Well--
18 O.
Not volume?
19 A.
Well, you have to take volume in order 20' to get the t urri movement percentages, so essentially 21 you count the cars by turn movement and then you back 22 out the percentages.
O COMPUTER AIDED TRANSCRIPTION / keyword index
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-1
-Q.
Didn't you also take' turn movements for 2
'1927' 3
A.
That's possible.
I don't recall i
4 precisely, but in order to check.on' the' data taken by
't i
5 the tubes, we had to'co.out and take counts.
6 In some cases, the tubes.'can break 7
down-say lef t ' turn counts,- if there is.a separate 8
turn' bay.
There is no w a y.
of separating'the
'3 9;
right-turris and the.through's.and there is also no-
. 10 way of determining whether, in fact, the tubes which.
\\
11 were laid.out for the' turn counts did not also pick-
'l 12
-up some through-vehic,es, car tires running over the 13
' tube, t
14 So, you have to go out and take_a 15 consistent set of traffic data in order to'come-up 16 with turn movements.
17 Q.
Do you know whether any of the turn
-18 movements originally taken for 192 were used in your 19.
subsequent analyses, 201 and 201A7 20 A.
I really. couldn't'say.
21
'O.
Would it surprise you if they were?
22 A.
Not part icularly.
(
COMPUTER AIDED TRANSCRIPTION / keyword index
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J
. :e.
-EV 1.
Q.
For 201A, did you take any a.m.
counts l'
2 at all?
3 A.
It's.possible we did, i
4
.Q.
But you don't recall for which l
5 intersections?
6 A.
No.
I just told the people who were 7
.actually running.it to flesh out-the counts that-we 8
had taken previously.
9 Q.
Were the p.m.
counts 1taken for 201A 10 provided to the State, to the best of your knowledge?
11 A.
I don't think explicitly, no.
I
' 12 MR. McMURRAY:
Mr. Christman, I don't 13 know whether they were provided or not, but we.had 14 expected they would have been and we never found I
15 them.
So, if you could turn them over please.
16 MR. CHRISTMAN:
Let me check for a 17 minute.
18 (Witness and counsel confer.)
19 MR. CHRISTMAN:
As for as we know, we 20 have turned over all the underlying documentation.
21 We will go back and check that when we get back to 22 the office.
i COMPUTER AIDED TRANSCRIPTION / keyword index
= _ _ = - _ - _ _ _ - _
9 9
1 4R. McMURRAY:
Okay.
2 Q.
What sort of signal timing data did you 3
take to augment your 201 en na l y s i s ?
4 A.
Essentially, observers went out to the l
1 5
site, with a stop watch, and recorded the phase
]
l 6
durations as well as the phase sequencing of the l
l 7
signal heads--from the signal heads.
8 Q.
Was this to all intersections analyzed 9
or just certain ones?
10 A.
I had asked them to do all of them.
11 O.
You did receive some signal timing data 12 from the State before this nnalysis was completed.
13 Correct?
14 A.
Before 201A was completed.
We got it a 15 few days, I think, before the publication of 201, but 16 it was too late to use them.
17 O.
But you received it before 201A7 18 A.
Yes, that's correct.
1 19 Q.
Now, did that have the same sort of data 20 in it that ycur people subsequently went out and got 21 in the field before 201A was published?
22 A.
No, not really.
O COMPUTER AIDED TRANSCRIPTION / keyword index
10-I' 1
Q.
Can you tell me-the difference between 2
what the state gave you and.what you went out'and got 3
in the field?
+4 A.
The state gave.us such things as' maximum 5
times.
That data was not as clear as we would.have 6
-liked. because the term " maximum time" can have 7
several meanings de'pending upon how it's used.
So, 8
we,had to guess at it, essentially.
9 They also gave us some data as to the.
10
-number of timing plans that they had.
11 Q.
Sorry.
Timing what?
.k -
.12 A.
Timing plans.
13 Q.
Could you explain what you mean by that?
14 A.
Yes.
It's possible to design'different 15 timing plans by time of day, so that if there is an 16 internal clock--and there usually is--they can switch 17 from one timing plan to another depending upon time 18 of-day, because traffic patterns vorc with time of 19
' day.
20.
Q.
Is this all included under the rubric
.21
" dial settings." which I take it is what they gave 22 you?
COMPUTER AIDED TRANSCRIPTION / keyword index
' 11' 1
A.
No, they didn't give me ' dial' settings as-
~
2.
'such.
If :they' had it would have been better.
But 3
-they just gave us a table showing. for each phase, 4'.
What the maximum times"were.
That is the data that I 5'
focused on.
I was less interested 1,1 phase 6
durations.
7 Q.;
In finally running your analysis in 8
201A. which ultim,v.ely generated various computer 9
. pri ntouts f oi-the intersections, was the input date 10 pou used the State-provided data or the data 11.
collected in the field by your people?
.D..
12 A.
You don't use signal timing data
-- 1 3 as--well, as I said, the signal timing d a t' a consisted 14 of maximums.and we used signal timing data'that 15-evolved during the course of the analysis.
16' In other words, it's an iterative 17 proceedure and signal timino data is on input to that 18 process.
19' As you go through the procedure, you 20 very the signal timing parameters to satisfy your 21 objective of properly representing actuating 22 controllers, which is to equilibrate the V over C O
1
- COMPUTER AIDED TRANSCRIPTION / keyword index
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1:
l' ratios for the competing 1 flows.
2 Then.what you do is you check what you 1
4 3
wind up with against the. maximums which the State
.A
" 4 gave: you.
'S We did have some problems with that'date
[
Lbecause if you add up all the maximuma, you don'tiget 7
the cycle lengths.-so there is clearly-something 8'
missing in what the State gave us.
.r When. :{du use the term " maximum," what do 9
O.
10.
-you mean?
11 A.
I don't know.
There are different kinds
'O'-
12 of' maximums.
Maximum green' time, maximum green-13 extension, there is maximum initial intervals =and s of 14 on.
.}
15 Q.
You used the term maximum in your 16 report.
I can't find it immediately, but how did you 17 use it in there?
18 A.
In there, we used what we thought 19 represented maximum green phase, but we didn't know i
20 whether the numbers given to us by the State 21 represented maximum green phase or some subcomponent 22 of the maximum green phase.
COMPUTER AIDED TRANSCRIPTION / keyword index i
13.
- O U
1 So, I can't testify as to the accuracy 2
-of the State's data.
All I can tell you.is that when 3
. we added up'the maximums, they didn't add up to the 4
cycle lengths.
So, either their' data was incomplete 5
or it meant something other than maximum green phase.
C L.*
6 Q.
These were cycle lengttw as you measured-
,J 7
them?-
8-A.
No.
Cycle lengths as the State 9
ipecified.in their tables.
10 Q.
I see.
11 Let me go back to something which I 12 didn't understand earlier.
And I believe you said 13 that the signal timing data is not really an input
-14 into the HCM software.in figuring out' intersection
~
15 capacity?
16 A.
I don't think I said that.
I said the 17 State data is not necessarily input.
Signal timing 18 is' input.
19 Q.
Signal timing is input?
20 A.
Yes.
21 O.
Okay.
iQ A.
Well. let me be more careful.
It is e
l>
?! e
- t
-t i
COMPUTER AIDED TRANSCRIPTION / keyword index
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~inputfinto thejprocess but it represents an outcome isw
'2 oflthe process.
3 In-other words, I said it is an 4
iterat'ive procedure You go in with a set: of signal
- q' V identify how r
'5 timing, you'look at the.results, you I_h i>
those results depart from the behavior-of an actuated 7
control.
You go back and. modify your signal' timing 8-necordingly until'it'"is' settles down.
A i
9 ? l O.
Whatithe.' State gave you, at least i n', i t s
-10
' raw form, was not suitable as input: for'the HCM
.1 1 '
software?
~32 A.
No.
That*s~ correct.
.It: -i s not.
13 Q.
It was not?
14
'A.
It is a bound--you are really asking for 15 bounds.
16 Q.
In there any way it could have been 4
1 17i massaged to be used as input?
{
18 A.
No.
It's Just-something you check 19 against when you finish.
,2D O.
Okay.
k 21 We have mentioned refinements an right 22 turn on red, some additional counts, you measured LO 1
r COMPUTER AIDED TRANSCRIPTION / keyword index
o n;
15; 1
lane widths and you took s.ignal. timing. data.
.g 2
. Con you recall'any other. refinements as 3
far as'. field data goes?
4 A..
Well','we took a look at the 5
channelization.
That is part of the lane width 6
calculation, but-it. is also a look a t' the traffic 7
movements.-
8 O.
How did you do that?
i-9 A.
Just-by observation.
.10 Q.
Where did you do that?
11-A.
Well, one has to do it at'all' approaches-
'12 to al'1 intersections.
13 Q.
Was that in~ order to check out which i
~
Intersections had left-turn l a n e s, and which had 14 15 right-turn-only lanes, things like-that?
16 A.
Yes.
That was presumably done for 201.
17, This was a check on that.
38 Q.
In doing the analysis TR-201A, did you
'19 use a set percentage for right-turn-on-red or was.it l-
-20'
. based on actual counts at each intersection?
'21 A.
No.
We didn't take counts of 22 right-turn-on-red.
You'd have to be out there much
!O' l
COMPUTER AIDED TRANSCRIPTION / keyword index
1
.26
-(
S 1
longer'than we were.
No.
These are estima'tes based-
'2 on the right-turn volume and, of course, on whether 3
RTOR was permitted.
4 These estimates were-derived from a 5
study we hed done for DOT some years moo which.was-6 the technical-foundation for'the new law vhich L
7 Congress passed which made RTOR a uniform permissive
~ B' characteristic.of' traffic in the United States.
9
-0.
Did'you apply a certain equation to the 10 right-turn counts?
.11 '
A, It'is not an equotion so much as results N
12 we obt ained from simuletion.
'So, we have some' charts 13 that.we'used.
They are not charts; they are 14 graphical representations.
Used that as a basis.
15 O.
Is there a' base percentage that you used 16 for determining right-turn-on-red and apply it to
-17 right-turn counts?
I 18 A.
We didn't use that, no.
19 Q.
Was Generally the same percentage of
. 5 20 right-turn-on-red used for every intersection?
21 A.
No.
I said we didn't use a percentage.
22 O.
Can you describe in ei little more O
COMPUTER AIDED TRANSCRIPTION / keyword index
17 O
1 detail, then, how you c ts m e out with--and if you want, 2
we can go to the excample you h ea v e in the b ric k of 3
201A.
You do have, in appendix A,
page one, 4
right-turn-on-red counts.
5 Can you tell me in a little more detail, 6
so I c ra n understand, how these numbers were derived?
7 A.
Again, they were taken from tisese l
8 estimates which I mentioned earliec.
9 Q.
What I need to know is, what is the 10 formula or the basis on which the estimates are 1
11 based?
12 A.
They are based upon these graphs which I 13 described earlier.
Essentially what they show is the 34 benefits of RTOR versus no RTOR.
From that you get 15 an estimate of how many vehicles per hour would 26 oct uall / utilize the RTOR feature.
17 O.
Where would these graphs be found?
18 A.
They are in a t echni en.1 report that we 19 provided as part of that contract.
20 C.
This is to the Federal Depart ment of 23 Transportation?
22 A.
This is actually 1o the prime O
COMPUTER AIDED TRANSCRIPTION /keywo.-d index
18
,+
'l 1
contractor.
We had a team arrangement.
'And they,. in 2
- turn,
't u r n e d i t over to DOT, 3-O.
Do.you know the.name of.the publication 4'
where these graphs would b e. found?-
5 A.
I don't know if that' pu'b11 cation has
~
6 ever been published in open-literature.
It is a l
7 techni cal--what we' call ! techrlical report, similar to 8
'201 but it has a different number.
9 MR. McMURRAY:
Mr. Christman, I will put 10 this'in writing, but I would like to request' copies 11 of the graphs on which.the right-turn-on-red
\\
12' estimates are based for 201A.
- 1. -
l l
13 Q.
Item number two on pnge five, where1you 14 discuss revisions, states that " Route 1-D was-altered L
15
'to separate evacuees and autos from those'in buses, 16 thus beriefiti ng the operational performance of'both 17 traffic streams."
1.
l' R
18 Can you explain in a little more detail 19 what your objectives were there in separating those i
20 two streams?
'2 1 A.
Well, the primary--we had two 22 objectives.
One is to improve the operational O
l COMPUTER AIDED TRANSCRIPTION / keyword index
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b
19
.p1 A_
1-performance;of both traffic' streams.
That was the 2
primary objective.
3-Essentia11y'what we did is, instead o,f 4
sending buses--sorry--Route 1-D down South Oyster Bay.
5 Road, which is an arterial with at-grade 6
intersections, we did a little ennlysis which.showed' 7-they. would. perform better. if we sent them.down South-8
. Oyster--Sorry--Seaford Oynter. Bay Expressway, which 9
is an access controJ1ed highway.
'10 Seaford' Oyster Bay Expressway or New 11 York 135 is'essentia11y' para'11e1 and close to South 12 Oyster Bay Road.
We-just felt that.it represented'n 13 better route.
14 In.the process of doing that, you do 15 separate the autos from the buses and I think there 16 is some marginal benefit to doing that because the 17 buses would thereby encounter somewhat less traffic-18 in the process and, therefore, be benefited as a 19 result.
20 O.
On page 18 of your report., this is table 21 3-3--do you see that?
22 A.
Yes.
COMPUTER AIDED TRANSCRIPTION / keyword index
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.. {
20 h
1l
.Q.
Underneath the path column, in comparing 1
2 the secon'd item, path 1A, B D.
F with-201, I notice-JF that path D was added?
4 A.
'Right.
5, G.
Looking over in the estimated vehicles-6 column,-I notice t hes t the number of estimated-7 vehicles did not change from 201.
Is that an. error?
8 A.
No.
9 O.
Okay.
10:
A.
You have to remember that the title of 11 this table is "Available. Storage." which has nothing
- 12 to ~do with the demand.
It is just the number of-cars 13 that could be physically accommodated in one lano-34' over a' distance of 1.11 miles.
15' O.
That number does not change.with the 26 addition of the path 1D?
17 A.
No.
That is a number which is related 28 to geometry.
19 Q.
Let's back up a second.
Let me ask you, 20 then, to explain the point that table 3-3 is trying 21 to make?
22 A.
Well, essentially what it does is N
COMPUTER AIDED TRANSCRIPTION / keyword index
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A 1
identify the length of segments of highway extending-2 upstream from the indicated reception centers and'the-3 scaled' distance ~between tho' indicated points and the l
'4' number of lanes which-could reasonably be occupied by 1
-5 evacuees.
6 We then translate that into estimated 7
number of vehicles, and I believe we used 150 8
vehicles per lane per mile.
I think that is
'6 9'
indicated on the top of page 16.
10 Q.
Okay.
Il So, the column " Estimated vehicles" is 12 the number of. Vehicles in.the queue or in the queues?'
13 Is that correct?
- 14 A.
That may.well be in the queue, yes, 15 given that the queue originating et the reception 16 center extends that far, which in this case it 1
17 probably will.
- 18 O.
Now, if there is a queue on path ID, 19 won't that add to the number of cars in the total 20 queue on this path?
21 A.
Well, I tnink it's more precise to say 22 t he t.
the cara queued on this section of the four 0;
COMPUTER AIDED TRANSCRIPTION / keyword index
22 0
1 paths would be comprised of vehicles which had taken 2
paths A,
B, D and F.
3 Q.
Could you, then, explain to me in more 4
detsi1 why the addition of 3D doesn't add any more 5
vehicles to the total queue length or total number of 6
vehicles in the queue on this path?
7 A.
I didn't say it didn't.
8 O.
Oh.
Okay.
Why is it, then, that there 9
is no change in estimated vehicles in the queues from 10 201 to 201A7 11 A.
Well, let's try it again.
12 I didn't say there was no change in the 13 queue lengths.
What I am saying is that the number 14 of vehicles that could be accommodated over 1.11 15 miles is 167.
You have to understand the distinction 16 between demand and supply.
Think of this as a 17 storage supply, if you will.
Demand is something 18 else.
19 O.
90 the est imat ed vehicles column, then, 20 is an estimate of the supply available?
21 A.
An estimate of the availab]e storoge.
22 Q.
Do you have any data in here that 9
COMPUTER AIDED TRANSCRIPTION / keyword index
23 i
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1--
reflects the demand that would be placed on that 2
storage?'
3 A.
'Yes, we do.
4 O.
Is that in this table?
5 A.
No, it is not in this table.
That would' l
6 be in table 3-8.
7 Q.
On what page?
8 A.
28.
9 O.
What would be the consequences'if-demand 10 exceeded the supply that is represented in the column.
11 headed " Estimated vehicles *?
12' A.
Well, under those conditions, the queue 13 would extend upstream of this particular section.
14 Q.
What would be the traffic consequences 15 of such a queue?
16 A.
It depends on the circumstances, if any.
17 Q.
Well, can you give me an upper and lower 18 bound?
19 A.
It depends upon, really, whether there 20 is interference between queues which take different 21 paths, geometrically, in the sense that their paths 22 intersect; and, given they intersect, whether or not
(
COMPUTER AIDED TRANSCRIPTION / keyword index
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'1
.that in'tur'n is going-to creat'e problems.
It may or 2
.may.not.
3:
Q.
Did: you conduct en analysis of whether 4
the queues would intersect traffic' going to.different 5
paths?
6 A.
Yes, we did.
7 Q.
And that analysis is reflected 11n'this 8-document, 201A7 9
A.
It should be.
10 0.-
-Okay.
l
'11 A.
That nomin refers back'to table 3-8.
V '
.11 2 O.
O n l'y four of the queues approach 13 available' storage. capacity; is that correct?
14 A.
Yes, that is what it says.
Let's see.
'15 That would be--
16 M R.. CHRISTMAN:
Can we clarify which 17 arrival period you are talking about?
l l
18 THE WITNESS:
That is a good point.
19 O.
In the six-hour arrival period?
20 A.
Where are you looking?
21 Q.
Page 27.
22 A.
Right.
1 hat would be I A, 1B, D,
1C, E O
COMPUTER AIDED TRANSCRIPTION / keyword index
7 I N4 l'I e
4f 25' O
1
.and 28.
2.
Q.
Let's so back to.the additional-field
.5
' data'you took.
I think that.you said your people 4.
went out and looked at the channelization of Ithe 1:
5 roads, basically the'geometrics of the road, l
6' Correct?
l'l L
1 7
A.
Right.
I i
'l 8-Q.
I think you will-recall that'at the i
I intersection'of Route 107 and Old Country Road, in-L 9-1 10 Ithe southbound approach, the State witnesses had i
L 11 stated:that it was their understanding that-there was.
'12 not a left turn allowed from the through-lane.
i 13
'Did'your people take a look at that to-
-24 see whether-that was true or not?
15 A.
Right.
There~is nothing.which prohibits 4
16 left turns from that lane, although the 17 general--under normal conditions there would be no 38 reason for cars to--for left-turners to discharge 19 from that lane, unless things got congested and
'20 pressured.
'21 Then I think that opens up the 22.
opportunity for cars--left-turnars to use that lane, 6
COMPUTER A1DED TRANSCRIPTION / keyword index
i',
2 6 --
)
(
'l
.since there-are two lanes'on'the receiving lane--that 2
is..on Old Country Road.
3
'Left-turners from the bayLandefrom that 1
4
-lane could turn in parallel without conflict.
5 Q.
There is=no arrow indicating that a left
.i L^
l'l 6
turn is permissible for that through-lane, is there?
i 1
7 A.
There is no arrow at all.
8
-Q.
In there a channel for the left-turn-9 traffic?
l L
10 A.
Yes.
There is a turn-bay there.
7 a
11-O.
So, your analysis in 201A assumes that l
12' people will'take a left turn from'the through-lane 33 next to that' turn-bay, even-though there is no sign i
14 or anything indicating that a left turn is i
15 permissible from that lane; correct?
1 16 A.
There is no sign prohibiting the left-17 turn from that lane.
It is generally not used, but 18 it's known that vehicles will do that.
It's been 19 observed elsewhere.
I don't know if it's been 20 observed there.
I don't know whether the left turn 21 is saturated to the extent which would encourage 22 people to do that.
L' p
COMPUTER AIDED TR..';SCRIPTION/ keyword index
27 1;
Q.
What' is your basis for saying it has.
2.
'been observed elsewhere?
s' 3'
A.
We'll.it has.
. Cars will doLthat.
' Q.
In what circumstances?
'he'left
'5 A.
Under'the circumstances that t
6 turn bay is' saturated and that the adjoining lane has 7
an excess of green time.
8 Q.
Is it a certain percentage of those who 9
wish to turn left will turn left.from.that lane, or 10 all.those who' desire.to turn left will turn left from 11 that lane?
4
-32 A.
It really depends upon the motivation of
=13 the~ driver.
'If they are strongly motivated,'if they 14 are in a rush, if they are pressured, then they will
'15 do so.
16 Q.
-You assume in your analysis, don't you, 17 that all those who wish to take a left turn from that 16 through-lane will do so?
19 A.
No.
That is not the way we analyze it.
4>
4
'20 Essentially what we say is that the left turn is 21 shared by through-and left-turners, and the act of a 22 left-turner to make a turn from that lane is rather l O COMPUTER AIDED TRANSCRIPTION / keyword index
2b*
lr ;
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1-complicated.
It depends upon many factors.
2 Q.
Well,'will a person be able to take a'
3
.left. turn from that lane unhindered by anyLopposing 4'
flow?
5.
A.
It depends upon the phase.
If he has'a 6
protected left-turn phase, then that's true.
. If he.
7 has what i s ' c a '. l e d a permissive p h a s e,' then that is 8
not true.
9 Q.
Protected is what? _ Where-there is an' 110 a r r o w ?..
11 A.
That's correct, t
. 12 Q.
There is no arrow there 'right?
I i
33 thought you.fust said that.
14 A.
I didn't say.that.
i 1E Q
- Okay, Is there an arrow there?
16 A.
Yes, there is.
17 Q.
And that arrow points at-the.Ieft turn 18 channel; right?
19
-A.
Well, it's mounted over the channel.
20 Right.
I can't tell you what the alignment is.
I 21 haven't looked at it that carefully
-22 Q.
In the permissive phase--that is, when
.o I
COMPUTER AIDED TRANSCRIPTION / keyword index
1.
1 L
29 j
M'
,' \\( / '
showing, there is'the-1' there is just tne green light i
i 2
possibi3ity of hindrance from the. left. turn traffic j
i 3
from the northbound traffic;-right?
'i i
4 A.
That's correct.
l 5
O.
Did you make that into account in your j
i I
6 analysis?
7 A.
That is taken into account by-the HCM i
8 procedure.
9 O.
How is-that?
10 A.
~Through the analysis-procedure.
l
~
l 11 Q,
In other words, the software takes care I
12 of that?
i 13 A.
Well, it'sLreally the underlying.
l 14 procedure es represented by the software.
l l
15 O.
Did you take the some assumption'for the i
16 intersection of Willis Avenue and the South Service i
17 Road for the LIE 7 18 A.
That's right.
'Again, because there are 19 two Innes on receiving lanes.
You couldn't do it if 20 there is only one lane on receiving lane.
21 O.
Are there any other intersections you' j
22 can recall where that assumption was made?
I l
COMPUTER AIDED TRANSCRIPTION / keyword index
p,
((
i
.30' W
e
.O 1
A '.
Not offhand, no.
2
'O.
While you.may.not be able to.narae an 3
l intersection, was it done.at any other intersections?'
~
4 A.
I'd have to go:back over the' listing to 5
check it.
6 O '.
Do you recall any publications at: all'
/
7 that discuss traffic taking a left-hand turn ~from'a-8 "lare that.would normally be consi.dered a 9'
throughalene?
10 "A.
I.will;take exception'to the; terminology 11~.
.of a lane normally considered to be a through-lane.
/"
12 If.the lane is unchannelized and.there is no 1 31 prohibition'.to any movement fro'm that l a n e.,
there is 34 certain sensible provisions.
15 You won't. generally make a.right. turn 16 from a second lane if a curb lane is available.
I 17 don't know.
.It is something that I will make a note 18
.to look into.
19 But I can tell you, f i r s.t ha nd, that they 20 have just changed the channelization ~ on southbound
'22 County Line Road 'near my home, which heretofore in 22 the last couple weeks or so had a single left-turn
. O.
COMPUTER AIDED TRANSCRIPTION / keyword index
_ =______ __ ____ _
1 31 l
l j
9 1
bay which continually over-flowed and where cars did 2
that maneuver.
3 They have.just established a second 4
left-turn bay--lane, by paint.
This was, I am sure, 5
motivated by the fact that they were getting these 6
parallel turns and the channelization was improper.
7 O.
Do you know of any laws that would 8
prohibit a left turn from a lane that is not 9
designated as a left-turn lane where there is a turn 10 bay for left turns?
i l
11 A.
I personally don't know.
But I do know
'O 12 what people do.
13 O.
Is this something that you studied 14 yourself, other than casual observation?
15 A.
Not as a separate project, no.
16 Q.
Did your people in the field observe 17 this behavior at all?
18 A.
I think one fellow mentioned he saw it 19 happening b e c.a u s e when I sent him out, I asked him to 20 check that.
21 Q.
Who was it who observed that?
22 A.
A fellow by the name of John.
O C OMf'U T E R AIDED TRANSCRIPTION / keyword index
j
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17, u
)
>1 32 k
l A/
is his last name?
J 1
w ll O.
Did John--what
~2 A.
Incorvain.
3 Q.
Did he give you any numbers at all, or j
i 4
did he just say he observed it happening?
i a
5 A.
No.
He said it happened'during the: day 6
that he went out there, the. time.that he was there, 7
he said it happened once.
8 I asked;him if the left turn bay was 9
overflowing and he'said it was not; so, at'least for i
i 10
.the day that he was out and the time he was out, the 11 left turn bay was not over-saturated.
r
'I
"\\
12 Q.
Let's go to page nine of your analysis.
13 Thisis figure 3-1, which is titled " Approach roads 14 to the Hicksville Reception Center," et cetera.
15 This is o rcuch diagram of the major 16 roads going to the reception centers; correct?
17 A.
Right.
I don't think this changed from 18 201.
I think it is the same one.
19 Q.
But in 201A you were trying to be a 20 little more refined, right, than in 2017 21 MR. CHRISTMAN:
Objection.
In what 22 sense?
l.
O I
COMPUTER AIDED TRANSCRIPTION / keyword index
33
(\\ l AJ 1
THE WITNESS:
Not as far as this diagram 2
is concerned.
It is the same diagram.
3 O.
I understand that.
Let me just ask my 4
next question, then.
5 There are several--well, let me point 6
out four intersections here that were not analyzed 7
and ask you why, in your further refinement of 201, 8
these intersections were not analyzed?
9 Those are the intersections of the LIE 10 and the--is it Seaford Oyster Bay Expressway?
11 MR. CHRISTMAN:
I will object on the
(~)\\
\\
12 grounds that since nothing changed in this respect v
13 from 201A--from 201 to 201A, it seems to me this is 34 outside the proper scope of this deposition.
l 15 However, at tivi s point. I won'!
t ask the 16 witness not to answer.
17 However, I think we are now beyond our 18 agreement and outside the scope of the deposition 19 permitted by the board.
If it goes on too long, we 20 are going to have to object.
1 21 MR.
McMURRAY:
I don't agree with your 22 characteriantion of yesterday's agr.rement but as long l(
COMPUTER AIDED TRANSCRIPTION / keyword index
34 1.L
'.as you are'not telling him not to answer, wel don't 2
have to go'any further.
3 MR. CHRISTMAN:
.Not so far.
4' Maybe you ought to repeat the question.
5' O.
.There is'en intersection of the--is'it 6
Seaford-Oyster Bay'Expre'ssway?
Is that-the correct--
7 A.
_Right.
l 8
'O.
Intersections of that road and the LIE 9
and theENorthern State Parkway.
Any reasons why 10 those intersections weren't onelyzed?
11 A.
Well, they'are not intersections.
They
\\
J32 are--first'of all, there is, a ramp from the LIE onto
'13 135.
14:
O.
135 being what on here?
15 A.
Seaford Oyster Bay Expressway.
And that-36 i t, a ramp, actually.
It is an off-ramp for~ the LIE, 17 an on-ramp for 135, so it is not an intersection.
.2 8 The capacity of that ramp and of'the
'19 intersection with 135 is well above the capacities of 20 the intersections further down on the path, so it
- 21 wasn't necessa: y to do that.
22 The intersection--there is no connection O
COMPUTER AIDED TRANSCRIPTION / keyword index
~
.O.
35-1L
'between' westbound Northern State Parkway and j
i 2:
southbound 135.
l l
3 Q.
Let's go, then, Northern 1 State' Parkway
<4
'and'the road marked SOBR,'which i s-.w h a t ? '
.i 5.
A.
That is South Oyster' Bay. Road.
Only.the l
6 buses use that, according to 201A.
Bus: volumes.are
.i 7
not'such.that--well. the ramp that is shown from-l 8-Northern'Stete is not'used.
There.is no need'to 9
enelyze.it.
10'
.The ramp from LIE to South Oyster Bay-l 11, Road is'not shown, but it is only used--it would'only
..-E/ -
12 be used.to service'the buses, and the-volume there-is-
. 13 not enough-to be e concern.
14 Q.
Again, you are assuming that no evacuees 15~
will use'that exit off the LIE?
16 A.
Well, I suppose some may use it, but 9:
l 17 that is not along a recommended path.
L 18 O.
The final one I have a question about is l
.19 the intersection of the LIE and Route.107, and also
.20 Northern State and Route'107.
21 A.
Right.
Again, those are not 22 intersections.
They are ramp street interfaces.
l 7/
i-l 1
I COMPUTER AIDED TRANSCRIPTION / keyword index
I'li '
l
-- 3 6 -
a:
(
1:
Their capacity'ia af-function of t h e 'b a c k g r o u n d ',.
_i/
_o i
2 1
' traffic 1there.
'I adjudged the capacities of
.t h e r
3 intersections downstream to be'more_.. restrictive'than
' he ramp-street interface.
S o,
I'
~4
.thel capacities of t
5 didn't see any need to oo throught a formal analysis'.
6-O.
Was this just based on sort of 7
eyeballing' it, or did you do a' calculation of some 8
sort?
9 A.
I did, in fact,
.e y e b a'1 1 it, as.you.say.
10 I took some photographs there.
'And then I looked: st 11.
the procedures of chapter five of the HCM, ' roughly 12 estimated that the capacities ~were in fact.hioher 13 than that of the intersections downstream.
14 Q.
Did you keep.your calculations?
15 A.
I don't eve,. know if I actually 16 generat,ed numbers.
I just looked at the procedures.
17 Q.
Let's go to page 11.
I have basically 18 the same question for the intersection of the Sunrise 19 Highway and the Meadowbrook Parkway, which I take it j
20
-is also a ramp.
Is that correct?
'21 MR.
CHRISTMAN:
Same objection.
This 22 document hasn't changed at all since 201 and these O
C O M Pl.lT E R AIDED TRANSCRIPTION / keyword index
37
('
O T-1 clu e s t i o n s could well have oeen asked--they have no 2
relationship to the purpotie of this deposition.
3 MR.
McMURRAY:
The purpose of the
/
4 deposition is to find out what the further 5
refinements are and, it was discussed yesterday, I
- 4 6
should be eible to talk cibout why, if this was a l
7 further analysis and certain refinements were made, 8
why certain
- t. h i n g s weren't done.
9 I am asking why was this particular ramp i
10 was not analyzed.
11 MR.
CHRISTMAN:
Not analyzed when 201A 12 was done?
13 MR.
McMURRAY:
That's right.
14 MR. CHRISTMAN:
All right.
1S A.
Well, for the same reasons.
I looked at s
16 the ramp-street interface, looked at the HCM
. g 37 procedures, came up with a rough estimate, decided 18 that it was not a p r o b.L e m.
19 O.
Again, your ent imate was not based on 20 generated numbers but.fust looking at procedures and 21 the--
22 A.
Looking at the procedurea in a O
COMPUTER AIDED TRANSCRIPTION / keyword index
i
.38.
{
q t
i W...
j 1.'
l quantitative light.
Looking~at. numbers.here.
2:
O.
Have you at any. time'run. numbers onLthat' 3
. p a r t i c u l a r.' r a m p to determine'the capacity?
l 0
4 A.
Not at this. time, no.
I may weil do-i 5
that,. though~, because it is-~
6
'O.
Do'you have'an'y intention of doing that?
7.
A.
Yeah, I think we will-do. that.
-8 Q.
-.Do you have a schedule for'doing that?'
9
'A.
~Well, certainly before I get on the
'10 stond.
II O.
Any more refined schedule.than that?
i'
-12 A.
We may get.to it this week.
If n o t,.
13-next' week, 14 MR. McMURRAY:
Let's take a five-minute 15'
- break, i
16 (Brief recess.)
,17 Q.
Let's turn to page 12.
In the fifth 18 full paragraph down, I am just puzzled by a term you 19 have used, "the platoon of interest."
'20 Can you tell me what you mears by that
-21 term in the context of that paragraph, page 127 1
1 22 A.
- Okay,
- Ol COMPUTER AIvED TRANSCRIPTION / keyword index
z i,.'
M
'39
.e i
e,f 1?
MR. CHRIsrMAN:
Third paragraph from the 2-
. bottom.
THE WITNESS:
Okay.
'I think I'added 3'
L4 this in this. document.
!L Q.
'I have it as nn-addition.
6 A.
I'Just wanted to explain that dispersion.
1
.7' doesn't occur only for traffic along 8
access-controlled roads but also occurs for trafficL 9-in urban. streets as well.
10'
'When you address the'urbanistreet 11' environment, we t a l'k' o b o u t p'latoon dispersion.
I 12-thought --
13' O.
Is a platoon a group o f' cars?'
- 14 A.
Yes.
It'is'when you release _a' queue 35
.from the approach to en intersection, the light turns 16 oreen.
As it proceeds downstream, it is-called a 17 platoon.
That pintoon sprends out as it moves.
18 Q.
Right after that paragraph, you.begin a 19' discussion that goes on into the next page regarding lC 20 ramp capacities.
Do you see that?
' 21 A.
Right.
22 Q.
What was your purpose in adding this l LO COMPUTER AIDED 1 TRANSCRIPTION / keyword index
\\,.
J
'O
~
y}
t o
i _ *',i (
.\\
- 1
_.particular analysis ~to?201A7-
'2' A.
Okay.
This was'in response to the fact
[
-3
.that'nowhere in;the'other document.did.we talkfabout 4:
the movem$nt.of.' traffic f r om.: t h e EPZ boun'dary to t t$e y
l 5:
a r e a s',o f-tho, reception centers in any detail, and: I 6
wanted to expand on that.
7 I !,3 h o u l d say at this point, one of.the 8
reasons'that led to the publication ~of 201A was not
[
9 only to document the refinements to the-analysis,- b u t-l' 20 10 also;to expand the discussion, and this.is on example 2
11 of the letter.
- t-j.?
12 Essentially, what I was tryinoito-13 pr ovide to the reader is how traffic' performs on an 14 access-contro'lled facility and what the relationship l
l 15 is between traffic already on the facility and 1
16 traffic trying to enter the facility.
And'that is l.
17 what all this discussion is about.
l l
L 18 Q.
The point being what?
19 A.
The point being that the ramp capacity-20 is a function of what's going on11n the main line.
21 This is a concept which is treated in 22 chapter five of the HCM and I thought it of value to LOL COMPUTER AIDED TRANSCRIPTION / keyword index
.i.
41
_(
i :-.
a 1 -:
represent'that treatment in a.descript'ive form here i
J
..:u ^ e 2
.an'd.to show that the ramp capacity does decline'as
- f(g(,
3 the. volume along the main line.. increases.
4
'O.
f As shown in f icures ' 3-4 and 3-S?
v 5-A.
Wei.1.
3-4 is.the one that shows the 6
relationship between ramp volume end the main.Eine 7
volume.
3-5' exhibits the other two-variables in 8.
demand'for' capacity analysis--namely, V1 is the, 9
estimated. volume of traffic in lane one upstream of i
10 the mer ge' ' poi nt.
And VM is what is called the merge i
11 volume.
It is the volume of traffic in lane one-i 32-
' downstream of the merge point.
VM remains l
l 13 essentially constant witn ma'in'line volume.
1 14 So, effectively, what happens is that l
L 75 there is a trade-off between VR and V1.
l
~16 Q.
You said you wanted to do an analysis of M' -
'17 some of the traffic between the EPZ and the reception i
18 centers?
.1 9 -
Is that what ~you said earlier, that this
?O' was part of that?
21 A.
It reuJ1y wasn't an ana3ysis as much as i
22 it was a short discussion on the way traffic behaves O
i COMPUTER AIDED TRANSCRIPTION / keyword index
}
i 42~
y i
1 on eccess-controlled highways.
2 My opinion is.-there i s no need ~'f or 'an l
3 analysis.
What we did -was stipulate level-of service 4'.
set. of - condi tions', which is the force flow 5
conditions.
1" 6
Since we. don't.have'very good handle'on-l 1
7 what'it would be--there is4a lot of speculation as t.o -
l l:
8 what traffic conditions would be;on the freeways-*so 9
.we just assumed, as a conservative posture, that-it' would' be as worse > as ' ycit} could imagine.
'10 11 0.
Let me-back up.
Other then your jt 12 discussion of ramp capacity, did.you perform any 13 other analyses of the limited access highways leading q.
14 to the approach routes'?
15 A,-
By " approach routes," you mean the--
16 Q.
I-mean the--
17 A.
In the area of the reception i-18 Q.
Yes.
19 A.
The only other thing I did, I think I 20 sent in a piece of paper on which I indicated the 21 speed--an expected speed of somewhere between-17 and 22 20 miles en hour and showed hou I got that.
But that O
1 I
s COMPUTER AIDED TRANSCRIPTION / keyword index l
43
<si 1
is the extent of it.
2 Q.
Did the State get that, your analysis?
3 A.
It was sent in--I am sure it was sent in 4
some time ago.
5 Q.
Was this for 201 or 201A7 6
A.
This was done quite awhile ago, before 7
this was a gleam in my eye.
It had to do with a 1
8 request mede to LILCO counsel for such a document, l
9 and I put it together and sent it out.
10 MR.
CHRISTMAN:
If that is the case, it 11 was turned over to the intervenor's, and my 12 recollection, dim though it may be, is that it was j
'l 13 turned over to the intervenor's.
I 14 Q.
Can you explain for me how the highway l
15 capacity manual procedures were used to develop 16 figures 3-4 and 3-57 I have a highway capacity 17 manual here if you need to look at it.
18 A.
No.
We just used the HCM software to do 19 this.
There is a separato module for chapter five.
20 And you have to i t e r e t. e wit h it ire order to come up 21 with this because V sub R,
which is the ramp volume, 22 is not en explicit dependent variable.
O COMPUTER AIDED TRANSCRIPTION / keyword index
l l
44 i
'1 1
So, what you do is you go in with level 2
of service, you ask the system to assume level of 3
service E,
which is capacity level, on the ramp, And 1,
i 4
then you. simply--you,actually solve for V1 as a H
l t
1 5
function of main line. volume, and out of that comes l
6.
the associated value of V1R at-level of service E.
I 7
Effectively, what you do is'just step.
8 along main line volume and come up with these 9
' numbers, 7
10 0.
Did the State receive the. output from l
l 11 this iterative process that you used to derive 12 figures 3-4 and 3-5?
l 11 13 A.
Probably not.
I don't eveti know'if we b
14 actually printed it out.
Probably didn't.
15 The print is an option.
You don't have i
.)
16 to print it out.
17 Q.
To the extent that anything was i
{
18 generated on paper. I think we would like to make a i
i 19 request for that.
We will put that in writing, of j
20 course.
21-I am confused by something you said 22 earlier.
I think you assumed that on the main line l
l l
COMPUTER AIDED TRANSCRIPTION / keyword index
45' l
LO'-
1 1
there would be level of service F,
I think you said.
2 Right?
l l
3 A.
Right.
l 1
1 4
Q.
And you assumed that the traffic would 5
'be going along at a maximum of 17' miles on hour?
6 Something like that?
L 7
A.
I think I used--I may have used a range 8
of 17 to 20.
.I don't recall exactly.
9 Q.
At the top of page 13, you say that the 10 le, vel of service, at least on the ramp, was level of 11 service E7 12 A.
Right.
13 Q.
I am wondering why you use level of 14 service E for this discussion and level of service F 15' in the assumptions that you made about traffic on the 16 limited-access highways?
17 A.
Well, level of service E is defined as 18 capacity.
And certainly if there is a queue backup, 19 then the ramp would be operated at level of service 20 F,-which would probably reoresent a lover figure of 21 service volume.
22 So, in order to be, quote, os generous
.O.
1 COMPUTER AIDED TRANSCRIPTION / keyword index l
46 0
1 as possible, give as high a volume as possible to the 2
reimp service flow, I used E instead of F.
3 Q.
On page 13, the second paragraph, first 4
line, you see the figure 3-4 shows that ramp I
i 5
capacity, et cetera.
Should that word be volume?
j I.
6 Volume is used throughout the rest of l
7 the paragraph.
I am confused enough as it is between 8
volume and capacity without having to deal with typos 9
or whatever.
10 A.
Okay.
Capacity is synonymous with 11 volume at level of service E.
They are defined as 9
12 one and the same.
13 Q.
So, when those terms are used in 3-4 and 14 3-5, they are also used synonymously?
Is that right?
15 A.
Now, be careful now.
3-5 doesn't use 16 the word capacity at al).
17 Q.
It does--it says " ramp capacity"--
18 A.
Analysis.
That is just a title of the 19 figure.
Actually, the title of the figure is ramp 20 capacity analysis, which was done by the plotter, and 21 then for 3-4, we added in "at ramp voJume" and for 22 3-5, we added in "at main line volumes."
O COMPUTER AIDED TRANSCRIPTION / keyword index
47 1
L
.,e 1
Did that answer the question?
l I
'2 Q.
I guess you answered the_ question by 3
saying-that ramp volume at level of' service E, equals' 4
capacity.
5 A..
Right.
6
.Q.
And that is why the ramp capacity 7
analysis'on"3-4 shows volumes on the X and Y axis.
8-Is that right?
9 A.
Right.
Capacity is a volume.
10 O.
On the third paragraph down on page 13, il you make the statement that "The heavy volume of f12 evacuating traffic gain access to the major westbound 13 access-controlled highways at or near their 14 respective eastern terminal.
Do you see that?
15 A.
Yes.
36 O.
That is not true for the LIE.
Isn't it.
17 correct that the eastern terminal for the la LIE--terminus for the LIE is in Riverhead?
Someplace 19 like that?
20.
A.
There may be one exit outside to the 21 east of the EPZS but what I say here--at or near.
22 Q.
The EPZ traffic, let's say, that is 10 COMPUTER AIDED TRANSCRIPTION / keyword index
i a
48 1
generated on the western edge of the EPZ. obviously, l
2 doesn't gain access near the eastern terminus of the i
3 LIE.
Correct?
4 A.
It depends how you use the word "near."
5 O.
Is one of the points that you're trying s
6 to make in this discussion of rump capacities that 7
traffic from outside the EPZ would generally be 8
inhibited from entering the limited-access highways fd 9
because the main line would already be full and they a
10 couldn't get onto the road?
Is that one of your 11 points?
F 12 A.
Stated more accurately, they would be
/
13 able to get on the road but at lower service volumes.
/
14 I am trying to make the point here that the ramp 15 capacity is a function of the volume on the main 16 line.
It is not--it is not a capacity which i t--
a 17 property of a geometric section of highway.
It 12 18 depends upon volume elsewhere.
19 O.
LJhat effect does traffic attempting to 20 insert itself onto a limited-access highway from a 21 ramp have on the, let's say, on the speed of the 22 traffic on the limited-access highway?
Does it slow O
COMPUTER AIDED TRANSCRIPTION / keyword index
49
(
\\
1 it down?-
2 A.
Oh, yes.
That'is the reason level of 3.
service F is so much slower than the other levels of l
4-service.
Yes.
That is one of the effects.
5 Q.
Can a level of service--can the speed 6
drop below 17 miles an hour?
7 A.
Oh, yeah.
I think there are points--17 i
8
' miles an hour is an average over time and over 9
distance.
10' There are points, by definition, along-11 the main line where if you are operating at level of t~
r 12 service F you enter a queue state.
You might pull 13 along the queue state awhile and as you exit from the 14 queue state, you probably will attain speeds well in 15.
excess of 17 miles an hour until you encounter the 26 next queue, which may be, in fact, at the next merge 17 point.
18 So, it is a highly--I shouldn't say 19 volatile--but highly variable traffic environment.
20 Q.
Is this something you have analyzed, 21 what the speeds would be nions the different sections 22 of the LIE or the other limited-access highways?
/
k COMPUTER AIDED TRANSCRIPTION / keyword index
'a 50 t
1 A.
Well,.the analysis.was confined to that 2
macro analysis which we discussed earlier, in which I,
'3 simply looked at data'to' determine for level of 4
service F what the density woul'd be.
We know roughly
'5 what the. volume is; we can back out the speed from j
6 the equation of the State.
7 No attempt was made by myself to L
8
'actually compute the detailed fluctuations in speed l-
~
9 along the LIE.
That la highly variable.
i' 10
_O.
Let's turn to page 19.
This is o' sample b
A 11 printout of the traffic counts that were taken on v (
12 March 10th at Hempstead Turnpike and Hicksville Road.
l
[
13 Correct?
The westbound direction?
14.
A.
Correct.
15 O.
Keeping your place on page 19, let's go 16 to page 40, which is the first page of appendix A.
17 Do,you have that?
18 A.
Right.
19 O.
This is the first page of the output for 20 the HCM sof tiware for that same intersection; isn't 21 that correct?
22 A.
Right.
Looks that way.
- O COMPUTER AIDED TRANSCRIPTION / keyword index
51 O
i Q.
The time period analyzed there is from 2
7:00 to 10:00 a.m.
Right?
I l
3 A.
Yes.
4 O.
On page 40, let's look on the first page 5
where it gives the westbound volume inputs.
You see 6
the through volume input there in 1,012, westbound?
7 A.
Right.
8 Q.
Now, when we 90 back to page 19 and we 9
do--let's look at the column under, on the left-hand 10 side of the printout here, where it says "through,"
11 look under the column " Hour total" for the hours 7:00 12 through 10:00.
I get an average for those three 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> of 1,106.
You can do the math if you want to 14 or you can take my word for it.
15 I am wondering why there is a difference 16 between that number, 1,106, which would be the 17 average hourly traffic for that 7:00 to 10:00 time l
38 period based on these traffic counts, and then the 19 input that is used for the HCM software, wnich says 20 1,012.
21 MR.
CHR I Sl '1 AN :
I will object unless 22 this is related to the difference between 201A and S
COMPUTER AIDED TRANSCRIPTION / keyword index
i a
52-
- /
1 201.
'I-don't b e l i e v e 11 t.' i s.
'2 MR.-McMURRAY:
.This analysis was'done on 3-
' April 7th.. 1987, after 201 was done.
1 4
1 4
MR. CHRISTMAN:
But the. number you.are j
5 referring to didn't change, I don't believe.
6 MR."McMURRAY:
It is a new printout.
We 7
are entitled to ask about.it.
.8 MR. CHRISTMAN:
Newness in the paper is 9
not really-relevant if.the-date on.the paper.isn't.
10 MR. McMURRAY:
This is e.new analysis.
- s 11 If you want to instruct the witness no to answer the e
fi 12 question, go ahead and we will go to the board.
I am 13 entitled to ask this question and I t'hink Mr.
i 14 Lieberman can easily answer it.
I think he is--
15 MR. CHRISTMAN:
You are over the i
16 permissible bounds both of our agreement and of the 17 board's ratification of that agreement.
I am not 18 going to tell the witness not to answer right nos,
[
19 but we will see where this goes.
However, the 20 question is improper and the objection stands.
l
-21 A,.
Okay.
What is called "through" here 22 includes r i gh t-- t ur n e r s.
We only had one tube across
- O.
COMPUTER AIDED TRANSCRIPTION / keyword index
- _ = _ - _
53
!Jd 1
the' lanes for.all lanes other than the left turn ~ bay.
13 2
To' break down.the.Iflow'by turn 3
movements, it Was necessary to'go out there and 4
ac t ua l'l y. get the turn percentages.
So, I'think.that 5-
.i f you add up the left, through end right volumes 6
shown on page 40--
7 Q.
You mean the through, right', and 1 8~
right-turn-on-red?
9 A.
No, no.
Right-turn-on-red is'a subset 10 of right-turners.
11 O.
Sorry.
Go ahead.
I interrupted you.
32 A'
Let's do that and see what we get.
13 Okay.
What we get is i,150.
I have 14 added tne 59 plus the 1,012 plus the 69.
15 If you take-the 1,106, which'is your 16 average for through's end.edd it to the average of 44 17 for left turns, you get a total flow'of 1,150.
28 Q.
Okay.
19 A.
44 being the average of 40, 48 and 44, 20 So, that is where the total volume compares.
21 Now, since we have no way, from looking
- 22 at the record output, to distinguish between O.
COMPUTER AIDED TRANSCRIPTION / keyword index
- l.. '
54L i
l r -,
{}).
l 1
'through's and right's, and since we have to have a'
L g 2
consistent set of turn percentages--namely, they have 3
to add.up to'100--we were ob'liged to go out and take 4
traffic counts, as we talked about earlier.
5 And in taking these traffic counts, we 6
camefout with the turn movement specific > values you 7
'see here on page 40.
They-add up to the same total 8'
" low, but based upon field observation, in this.
9 particular case, we'have'slightly more left-turners 10 than was recorded in the field and breakdown between 11
.through's and right's, which could not be obtained 12 from the field.
13 Q.
The data, then. that is reflected on 14 page one: here'of appendix A is based partly, then, on 15 some of the new field. observations that were taken 16 subsequent to 2017 Is that right?
'17 MR. CHRISTMAN:
Which data are you 18 referring to?
We need e clarification.
19 MR.
McMURRAY:
Any of the data.
20 MR.
CHRISTMAN:
Are you asking if any of 21 the data-were based on the field observations 22 MR.
McMURRAY:
That's right.
O COMPUTER AIDED TRANSCRIPTION / keyword index
55"
-1 THE WITNESS:
That certainly i s - l i k el'y.
2 Some of'it'may be based on turn percentage movements 3
taken' earlier.
Remember I did say we'took.a.m.
turn-4 movements. earlier.
It may be only the p.m.
turn 5
movements.were changed on the-basis of data taken,
'6 betWeen the two publications.
7 Q.
Again, the right-turn-on-red here on 8-page.one.of appendix A'are estimates based on'the 9
graphs we'had discussed earlier?
10 A.
Right.
I think other factors which 11 enter-into it--there~is also--other-factors which 12'
. enter.into it are the probability that. cars will in 13 fact'be queued on red.
14 For example, you-notice that.where you 15 have a low right-turn volume, a smaller percentage of 16 RTOR was estimated than where you have a'high 17 right-turn-on-red volume.
18 See, the right-turn-on-red volume 19 depends upon, again, as it always does, relationship 20 between demand and capacity.
Under pressured 21 conditions, where there is a high volume which is not' 22 completely satisfied by the green, drivers become j
COMPUTER AIDED TRANSCRIPTION / keyword index
56 l1 more aggressive'in using the RTOR.
'So,Leven though t
2 there.may be a lesser capacity for RTOR:as volume
-3'
. increases, so long as that capacity is not. breached, 4
there'are.more people using'-it.
5 fAs a matter of fact, the benefits of-
\\,
6
~RTORlbecome more pronounced as;you approach capacity-D 7
conditions because effectively, what'RTOR provides is p
l' S
en increase in.available capacity.
L 9
O.
As long as we are on appendix A,
let's b
1 10 turn to the next page.
Under the heading " Number of.
l 11 lanes " where it says." eastbound," that number was l
(~Y
\\s' 12 increased from four to five as you went from 201 to 13 201A.
What was the basis for that change?
14 A.
Probably what happens there, as in other 15 places, what is intended as's shoulder becomen a de 16-facto right-turn lane.
Apparently,- this was observed 17 at this point.
i 1
18 O.
Can you tell me any other intersections 1
i I
{
19 that'you know of where shoulders are considered 20 right-turn lanes in your analysis?
3
)
21 A.
It's based upon observation 5.
The j
22 people who went out there are instructed to observe l
i i
COMPUTER AIDED TRANSCRIPTION / keyword incex
[,
57.-
-u J 1
whether in fact the shouldere.are used as such.
O 2
Based upon t!hese. observations, we code the 3
channelization according1).
b
'4 Q.
Can you tell me which intersections were 14 5-treated that way in your analysis?
6 A.
I couldn't'tell you offha'nd,'no.
7
-O.
Is there any way that somebody looking 8
at-the.sdata that you sent out to the intervenor's 9
would be able to tell where shoulders were used as 10 right-turn lanes, other than going out an'd comparing 11 your data with the intersections?
i-.
. 0" 12 A.
I don't think so.
We did sketch up some 33 of the intersections showing the lanes,-but not all 14' of them.
So.the only way they*could determine that 15 is ectually go out there and look at it.
16 Q.
Was this a common. practice in your 17 enelyses of the intersections, to consider shoulders 18 as being available for right turns?
19 A.
If, in fact, they are used by 20 right-turners.
Of course, parking would have to be 21 prohibited in order for them to gain access to it, 22 either prohibited or not used.
If the right-turner O
COMPUTER AIDED TRANSCRIPTION / keyword index
58 o
1
. sees en._open shoulders I
he will use it,'particular19
'2 Ei f.t h e'r e is' heavy traffic.
t 3
Q.
In your analyses, were shoulders 4
' considered available.for right turns even where there 5
was the opportunity for parking along that shoulder?
6
-A.
We really asked them to focus on whether s
7 it was'used as such.
8 0.
During the time period of the' 9
observation?
10 A.
During the time period of the 11 observation.
Right.
L'
.22 Q.
In 201A, did you analyze I think what
'13 you have referred to as mid-section blockages on 24 arter$als?
i 15 A.
No.
We analyzed that earlier.
16 Q.
That was analyzed earlier?
17 A.
Yes.
18 Q.
And it was'not. refined at all in 201A7 19 A.
Well, we didn't do a formal analysis.
'20 We effectively looked at' sections which could act as 21 candidates for controlling the capacities of a 22 section of highwey relative to the capacity offered LO COMPUTER AIDED TRANSCRIPTION / keyword index
59 1
at the intersection itself.
2.
And again, there is one that the State 3
identified, which is' northbound Route.107 Just' north 4
of Southern State Parkway where'it narrows:to one 5'
lane.
And in our opinion, that did not~ represent thes 6
controlling factor.
7 O.
That was something that you looked at 8
after 201 came out, though, right?
l 9
A.
No.
l 10 Q.
That particular stretch of road?
Is 11 that something you looked at.before?
t.
Lk l
12 A.
No.
I drove the entire system before 1
13 201.
14 Q.
Did you reanalyze that particular r o e'd 15 at all after 2017 l
26 A.
I did not go back to it, no.
l-l 17 Q.
-In your rebuttal testimony, Mr.
28 Lieberman, you do say, on page six--and I will shou 19 it to you if you want to see it.
"Accordingly, as 20 part of our work document in KLD'TR-201A, we did l
l
'21 analyze the roadways and found no such special 22-mid-block restrictions to alter our conclusions.~"
O COMPUTER AIDED TRANSCRIPTION / keyword index
J 60 O
'1 But you are saying you didn't conduct 2'
any special-mid-block rest riction' analyses between 3
201 and'201A7 4
A.
No, I didn't.
I sent some people'out to 5'
.take another look at it, but I didn't.
6' O.
Can you tell me what ~ their analysis 7
consisted - of?
8 A.
They didn't do an analysis.
Again, they 9
surveyed-the roadway system and indicated to me that-10 there was no obstructions or any factors which would 11-make the roadway itself a factor.
12 Q.
Is this documented in any way?-
13 A.
No.
14 Q.
Do you know which roadway sections they 15
' observed?
16 A.
Well, I told them to look at this 17 one-lane roadway.
I had done it myself; I wanted 18 their opinion.
So, they went out and did that.
19 The only time that the roadway offers a 20 controlling factor is if something like North Country 21 Road or lower Rocky Point Road, where you have a 22 rather narrow, twisting, hilly road, which is going O
l.
COMPUTER AIDED TRANSCRIPTION / keyword index t.
61-(
1.
to affect the capacity of that highwav section to the l-2 extent where that capacity is lower than the approach
^3 to the' intersection.
The highway system in Nassau County is very flat end.doesn't offer that problem.
l 5
Q.
Were there any other candidates for 6
mid-block restrictions that your people looked at, 7
other than that section on.1077 8
A.
,Well, as11 say, we drove the entire 9-system.
.The_only other place where I thought was a-10 candi'date was on Rout'e 107 southbound in the area of 11 the retail areas.
I thought there might be 'some-12 mid-block constraint associated with 13 entering--traffic enter'ing and leaving Mid-Island' 14 Plaza.
Again, it was my feeling that that :was not 15 the~ case.
16 Let's s'e e.
17 Q.
Was that based on any particular 15-18 analysis, or Just based on your observation on a-19:
single day?
20 A.
I have driven by that place more than 21 one day.
No.
Knowing what I know about a section of 22 highway and the fact that it generpily accommodates COMPUTER AIDED. TRANSCRIPTION / keyword index
_ _ = _ _ _ _ _ _ _ _ _
62
' f9
' V 1-vehicle flow'at up to-1,500 vehicles'per hour.per 2
lane, comparing that with the capacity of the paths 3
of interest.to me, it wasn't even.close.
4 Tna only'other--no, that wouldn't apply.
1
'o say the short link between the north 5
LI was going c
6 and south service road, along Willis is another 7
concern, but this has to'do, again, with the 1
8 intersection constraints.
l 9
O.
'Have you determined that those i
L 10 ~
intersections along Willis Avenue'are limited-
{
?.
11 factors?
12 A.
Right.
(
13 Q.
This is Willis Road and LIE south l
14 service road?
15 A.
South to north.
There is a little
-16 section--it is actually an overpass--overpass or i
17 underpass?
I don't remember now.
l 18 Q.
I think it is an underpass, isn't it?
19 A.
I think so, yes.
20 Q.
Did you do a delay analysis as part of 1.
21 201A at the intersections?
22 A.
The delay enalysis is automatically done o
COMPUTER AIDED TRANSCRIPTION / keyword index
[____________
l.
l h
"63 l:
1.
1.
1 sm I
1 by the HCM software.
I see here that--yes, here it' 2
is.
Page~47 should have it, but I,think it's 3
academic.
It is really not representative'of. the l
l 4
environment that would be there.
5 O.
In your testimony you say thatLthe 6
delays have been accounted for in KLD TR-201A.
How 7
have they been accounted for?.
l 8'
A.
'You better'give me.a-context.for that.
l 9
O.
Do you have a copy of the testimony?
30 MR.
CHRISTMAN:
No, I don't.
11 0.
Read this paragraph.
t 12 (Document handed to witness.)
13 A.
Yes.
Okay.
The delays we are talking 14 about are those associated'with the queueing process, 15 not the delays printed out by the HCM.
16 The HCM, you understand, cannot--cannot 17 address the environment which is actually going to 18 happen there.
19 Yes.
The way we do that is to calculate 20.
the queue lengths as shown in table 3-8 and then the 21 total service times which are shown in 3-9.
That is 22 what I had in mind when I wrote that.
O l
i i
COMPUTER AIDED TRANSCRIPTION / keyword index
~64 t.,
1 Q.
I see.
2 MR. McMURRAY:
Mr. Lieberman. I.have no 3-more questions.
- Thank-you.very much.
4 MR. CHRISTMAN:
<I have no questions.-
5-
.(Time-Noted:
11:18 a.m.)
6 7
8-s 9
10 11 12-13 14 i-13 16-17 18-
. 19 20 21 22 COMPUTER AIDED TRANSCRIPTION / keyword index
65 0
1 C ER T I F _I C A T I O N 2
3 I,
DEBRA STEVENS, a shorthand reporter 4
and n o t. a r y public, within and f o '^ the Gtate of New 5
York, do hereby cortify:
6 7
That EDWARD LIEBERMAN, the witness whose 8
examination is hereinbefore set forth, was first duly 9
sworn by me, and that transcript of said t e s t. i mony is 10 a true record of the testimony given by said witness.
11 I further certify that I am not related 12 to any of the parties to this action by blood or 13 marrince, and that I am in no way interested in the 14 outcome of this matter l
15 16 IN WITNUSS WHEREOF, I have hereunto set 17 my hand this,
day of M
1987.
V 38
- 4 1 __
19 e
20 DEBRA STEVENS, I
21 St sort hand Reporter 2
22 O
E J