ML20235Y891
| ML20235Y891 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/20/1987 |
| From: | KLD ASSOCIATES, INC. |
| To: | |
| References | |
| CON-#387-4067 OL-3, NUDOCS 8707270096 | |
| Download: ML20235Y891 (23) | |
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LILCO, July 20,1987 i-1
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UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION
'87 JUL 21 P3 :13 I
"f Before the Atomic Safety and Licensing Board
' pf f In the Matter of
)
f
)
LONG ISLAND LIGHTING COMPANY
) Docket No. 50-322-OL-3
) (Emergency.' Planning)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
SURREBUTTAL TESTIMONY OF EDWARD B. LIEBERMAN 1.
Q.
Please identify yourself.
A.
My name is Edward B. Lieberman. My professional qualifications are in Attachment C to LILCO Exhibit 1.
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2.
Q.
Briefly summarize the purpose of this Surrebuttal Testimony.
A.
This testimony responds to the " 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," sub-mitted July 10, 1987. Specifically, I address the following issues, whi'.:h are raised by the State DOT witnesses in connection with KLD TR-201A:
1.
Their criticism of the estimates of background traffic data, 2.
Their criticism of certain capacity analyses and the associated rep-presentation of approach geometrics, 3.
Their contentions that incorrect signal timing was used in our ca-pacity analyses, 4.
Their criticisms concerning the treatment of ramp capacity, 5.
Their questions about our estimates of queue lengths, 8707270096 870720
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Their interpretation of Level of Service F traffic operations, and l
7.
Their concerns about the capacity of sections of highway between intersections.
This testimony also addresses topics that were raised by the State DOT witnesses in connection with my rebuttal testimony of May 27,1987:
i
'l 8.
The State's double-counting of traffic from within the Shoreham Emergency Planning Zone (EPZ),
9.
The treatment of background traffic in the State's analysis, 10.
The reduction by the State of capacity on the LIE by 7.5 percent, 11.
Traffic growth projections, and 12.
The State's representation of the physical highway system.
3.
Q.
The. State's July 10, 1987 rebuttal testimony states (pp. 4-5) that you did not use the correct background traffic at 13 intersections. Is that cor-rect?
A.
No. The fact is that machine counts use road tubes, which cannot distin-guish all turn movements. Therefore, it was necessary to take field traf-fic data with direct observations of each of the separate turn movements on all approaches to the intersections studied. Separate turn movements are needed in order to employ the procedures of the Highway Capacity Manual (HCM) to estimate intersection capacity.
When we took those data, the resulting turn movements differed from those implied by the machine counts, as would be expected. In 13 of the 28 cases, these differences resulted in lower turn volumes fo'r' evacuating traffic. In 15 of the 28 cases, they resulted in higher esti-mates. This can be seen from the State's own Exhibit 1, but the State wit ~
nesses do not acknowledge it. Thus, the subsequent field data are not bi-ased relative to the machine counts and do fairly represent the required turn percentages. These turn percentages were then multiplied by the
4,
approach-specific traffic volumes obtained from the machine counts to yield the background traffic turn volumes needed for the HCM procedures.
4.
Q.
The State testimony also expresses concerns (pp. 6-7) about intersectiori geometrics. Would you comment on that?
A.
The concern the State DOT witnesses raise is whether or not the lane next to a lef t-turn bay can also be used for lef t turns.
Note that the intersections involvexi would be under controlin the emergency situation being evaluated. The police officer on the scene would have the authority to allow and encourage the use of lef t-turners from the lane in question, in addition to those directly from the lef t-turn bay.
We must represent the reality of the situation. Visualize a situa-tion in which the lef t turn bay is filled, and the queue extends into the next lane, upstream of the beginning of the turn bay:
Lane
/XXXXXXXX B
XXXXX 3
2 1
Under such a condition there would be reduced use of lane 3 by through vehicles, particularly in view of the f act that lef t-turners (represented by the "X's" in the above sketch) would overflow the turn bay B and occupy lane 3.
Such conditions would encourage use of lane 3 by some left-turners, particularly under direct police control. Note that there is ade-quate capacity for through vehicles in lane 2 and, according to the State's analysis, some 31 seconds of green time per cycle is available for use by any lef t-turners from lane 3 on the SB Route 107 approach to Old Country Road.
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I am aware that lane 3 is not commonly used for lef t-turns during normal conditions, nor is such use encouraged. But the situation we are analyzing is an emergency, with police personnel present.
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S.
Q.
Dr. Hartgen and Mr. Millspaugh argue that you " created" turn lanes to
" artificially increase capacity." Are they correct?
A.
No. The geometrics used in our HCM analysis reflect real-world usage by travelers as directly observed in the field. Specifically:
The SB approach of Newbridge Road at Route 27 has a right-hand lane that is 17 feet wide and is used by traffic as a right turn bay and, concurrently, as a through lane.
Table 9-5 in the HCM specifies that any lane that is 16 feet wide, or wider, be classified as two lanes. Our analysis, therefore, reflected both actual usage and recommended HCM procedures.
No vehicles were parked at those locations when the paved shoul-ders were routinely used as right-turn bays based on direct observa-tion, contrary to the speculation by the State witnesses.
The use of a shoulder for right turns does not imply an " additional" turn lane and in f act was observed not to be the case. The concern of inadequate road capacity on the receiving leg, offered by the State, was not an issue at the locations observed.
In my opinion, ignoring the real-world usage of highway facilities in the analysis of capacity produces incorrect estimates.
6.
Q.
The State DOT witnesses express concern (pp. 9-10) about the signal timing used. Would you comment on that?
A.
The signal controllers in question are actuated controllers. That is, they respond to traffic conditions and revise their own settings, over a permit-ted range. The capacity analyses we undertook represented this respon-sive performance. Those performed by the State did not and were there-fore not reflective of the real-world control.
The State witnesses' concern about our RTOR estimates is not sup-ported by any quantitative data. Footnote 4, appearing at the bottom of
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[4-pages 8 and 9 of their rebuttal testimony, states that KLD has taken " full-advantage" of the existing phase overlap, which is impro per since the out-side lane of the WB approach is shared. Our treatment is correct: the HCM procedure properly compensates for shared lanes (see Table 9-11 on pages 9-13 and -14). Note that n_o RTOR volume is specified for the WB approach.
7.
Q.
The State witnesses assert that TR-201A implies that traffic entering the access-controlled highways will have "little impact" (p.10) or " minimal effect"(p.11) on evacuation traffic. Is that true?
A.
No. Nowhere do such implications appear. In f act, I have said that:
[elvacuating traffic is expected to encounter heavy congestion along these highways, thereby slowing their movement... (p.13, TR-201A)
It is true, of course, that some traffic outside the EPZ will enter at low rates onto these highway [s... While this effect increases evacuees' travel time,... emphasis added] (pp. 34, 35, Direct l
Testimony, 3/30/87)
In my deposition of June 23, 1987, in response to the question, "Does [ traffic entering onto a limited-access highwayj slow
[ speed of traffic on the highway] down?," I stated,"Oh, yes. That is the reason level of service F is so much slower than the other levels of service. Yes. That is one of the effects"(Transcript pp.
48-49).
The State witnesses' statement that "not all EPZ residents get on the mainlines at the ' eastern termini"'(p.10) is not correct. The eastern ter-minus of the LIE is within the EPZ, and the eastern termini of the North-ern State and Southern State Parkways a_re entered by evacuating traffic.
Note that I used the phrase "at or near" the eastern termini. The other statements by the State witnesses concerning mobilization of non-EPZ residents are unsupported, speculative, and not reasonable.
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8.
Q.
Dr. Hartgen and Mr. Millspaugh maintain (p.12) that your queue analysis is' deficient in that-you assume that queues extend upstream from the monitoring sites. Do you agree?
A.
No. As stated on page 26 of KLD TR-201A, the source of all queueing is a direct consequence of the fact that the monitoring service rates within the reception centers limit the flow rate at which evacuating vehicles can travel along the access roads toward the reception center. Under the assumption that 30% of the EPZ traffic will travel to the reception cen-ters, evacuation demand volumes on the approaches to the reception cen-ters are less than the intersection capacities but exceed these monitoring rates. Thus, the monitoring rates constitute the controlling bottlenecks in the system. As a result, the dominant queues will form at all the recep-ll tion centers and extend upstream along these paths. This conclusion is not an " assumption," but rather the outcome of the imbalance between supply (M, the monitoring service rates) and traffic demand within the reception centers. This imbalance, as noted abt e, is most pronounced at the reception centers, as is shown in Tables 3-5,3-6, and 3-7 of TR-201 A.
9.
Q.
Are the monitoring rates provided to you by LILCO reliable?
A.
Yes, based on my observation of a training session conducted by LILCO on June 8,1987. LILCO set up Area B at Hicksville as it would be set up in a radiological emergency and cycled cars through it for monitoring using the primary monitoring method des 6ribed in our written direct testimony.
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The LERO personnel who performed the monitoring were some of the same ones who would do it in a real emergency. Cars were moved through as they would be in a real emergency; thus the effect of moving them into the monitoring bays in groups of two or three was taken into account, as was the time to stop and start, pull away from tha monitoring station, l
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e.
I was present at this training session. Also, I was able to use a vid-eotape of the session to get data on how long it took to monitor the cars.
By counting the number of cars processed in one hour of the session, I was able to calculate the following mean times for monitoring a vehicle:
Micksville Area "B"
Channel 1
mean time 84.0 sec
=
2 88.2 3
86.7 4
104.3 The higher tline for Channel 4 reflects lower demand: Channel 4 was used for oversized vehicles, and there were not enough of them to keep the monitors continuously busy. Thus the 104.3-second mean reflects time spent waiting for the next car to arrive. The timing data are shown in Attachment A.
For the purposes of a preliminary estimate of service times, the first three numbers in the above table can be used. The fourth (104.8 sec-onds) cannot, because it is service time plus idle time, since there was not a continual queue of demand in this particular channel. It can be seen, l
therefore, that the average service rate per vehicle is under 90 seconds.
4 10.
Q.
The State witnesses maintain (p.12) that queues will take up space in the
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intersections. Do you agree?
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A.
No. As stated on page 33 of TR-201A, I have recommended that LERO ask the police to be stationed at all major intersections (see Table 3-10) along the routes to the reception centers. The primary benefit of these police personnel, attendant to their traff'ic control functions [is'to main-tain clear intersections.
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11.
Q.
The State witnesses maintain (p.12) that you assume that no background traffic is " mixed in" with evacuation traffic. Is this true?
A.
No. Nowhere in TR-201A is such an assumption made. In deriving esti-mates of queue lengths we considered the following factors:
The use of more than one lane by evacuating traffic; The mixing, to some extent, of background and evacuating traffic; and The expected decline and redistribution of background traffic vol-umes arising from the increased congestion.
These three separate effects have opposing influences on queue lengths. Specifically, the fact that evacuation traffic will c.;e more than one lane on the approach paths to the reception centers will tenf a re-duce queue length. The fact that evacuees will mingle, to some extent, with background traffic within the same queue structure will tend to in-crease queue length. The expectation that background traffic will be somewhat less than normal because of the congestion will tend to reduce queue length.
Capacity constraints on background traffic are f ar less severe than they are on the evacuation traffic because the latter traffic is limited by the monitoring service rates that are the source of the queuelqg process.
Therefore, the throughput of background traffic will exceed that of evac-uation traffic; this f actor should limit the number of background vehicles contained within the same queue as evacuation traffic.
I believe that by using the approach I have used, namely to confine evacuation traffic to one lane h1 stead of to more than one lane, to assume that background traffic will travel in other lanes, and to make no allow-ance for any reduction in background traffic, I have conservatively esti-mated the real-world situation.
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1 12.
Q.
There is also a concern expressed by the State witnesses regarding your characterization of Level of Service F, as reflected in pages 12-14 of l
their testimony. Would you comment on that?
A.
The State testimony indicates that we assumed that the traffic will flow i
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 />. I never characterized the movement as steady or smooth, nor did I state that evacuation traffic would flow over a 12-hour period. In fact, the estimate for the " arrival period" was 6-9 hours (p.13 of TR-201A).
Anyone who has driven in heavy traffic on a freeway knows that Level of Service F is characterized by stop-and go operation, and that the driver is sometimes stopped completely and somekimes moving aheaci at a good speed, only to be stopped again. As J. have explained at various points in my deposition of June 23,1987, or in my earlier written testimo-ny in this proceeding:
Speeds at points along a highway operating at Level of Service F can be lower than 17 mph.
Vehicles can move from a queued state to higher speeds until the next queue is reached.
The traffic environment is highly variable.
Traffic from entry ramps will forcibly merge into gaps in the mainline traffic stream.
Stop-and go operation along the entire route was assumed for the access-controlled highways.
The point is n7t whether the trip is steady and smooth -it is not, and I did not represent it as such. The point is that the average speed is on the order of 17 mph. The State witnesses do not address this, the main point. The fact is that such an average speed is a conservative estimate of Level of Service F operations on an access-controlled highway.
m
In midtown Manhattan, the range of speeds lies between 9 and 14 mph. This is for a grid of at grade signals, spaced approximately 260 feet apart on the north-south streets. In contrast, the Long Island Expressway j
is an access-controlled freeway with no traffic signals. Our estimate of 17 mph is conservative and in accord with generally accepted estimates.
Specifically, Figure 2-17 on page 2-23 of the 1985 HCM is a plot showing the results of a study of flow on four, six, and eight-lane free-ways on New York area parkways under ideal conditions. Shown on this figure are data points in the forced-flow regime. Those data points for
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the six-lane facility, which is the Southern State Parkway, show tha+
speeds in the forced-flow regime change from roughly 20 mph to almost 30 inph.
Note also that in a paper entitled " Understanding Forced Flow,"
published in the ITE Journal of October 1986 by Dr. Urbanik, an empirical study of traf fic flow in the forced flow regime on I-35 in Austin, Texas, was described. He presents two plots of data, both including conditions in the forced-flow regime (Level of Service F). In both plots the range of speeds of traffic on this highway in the forced-flow regime ranges from 20 to 30 mph.
It is also important to realize that we took a conservative view in assuming Level of Service F throughout the corridor. We did not try to argue that Level of Service D or some other level holds in some or all of the corridor, even though this might well be justified.
13.
Q.
There is a concern expressed by the State witnesses (p.14) that you did not look at roadway capacity between intersections. Is this so?
A.
No. We did field inspections of the entire corridor, and determined that
there are no midblock conditions that would be capacity-limiting points on any link.
Note that the discharge lanes on an intersection approach can only produce vehicles during the green phase. But the upstream lanes can pro-cess vehicles at all times, as they arrive.
As cited in Chapters 9 and 11 of the 1985 Highway Capacity Manu-al, the capacity of a lane group at a signalized intersection may be ap-proximated by 1600(g/C)N; that is, by.1600 vph times the fraction of green for the movement times the number of lanes. The procedures of Chapter 9 may also be used for a more precise estimate of the capacity.
For a lane group with (g/C) = 0.50 and two lanes, the capacity of the lane group is approximately 1600 (0.50) (2) = 1600 vph. If at least enough vehicles can be stored directly upstream of the discharge point so that the entire green phase can be used efficiently, then it does not mat-ter whether there are one or two lanes further up the approach link, be-cause one upstream lane is sufficient to deliver all the traffic that two discharge lanes on the approach to the intersection can process, in this example.
Thus, the fact that there are fewer lanes at some location up-stream does not automatically mean that the location is a capacity re-striction. So long as the upstream section can process at least as many vehicles as the approach lanes to the intersection can use efficiently, then there is no issue. We did field inspections with this in mind, and paid particular attention to the production of vehicles at the intersections of potential problem locations. We did not observe any midblock capacity constraints.
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14.
Q.
The State witnesses argue (p.14) that "a number of key intersections" have not been analyzed, citing ramps. Is this correct?
A.
No. It must be emphasized that ramp-street interf aces are not necessari-ly " intersections." None of the cases cited by the State DOT witnesses is an intersection. We d_i_d analyze them at an appropriate level of detail prior to the publication of KLD TR-201. We have also more recently for-malized an analysis of the Meadowbrook ramp, which I will now detail.
The statement in the State's testimony (p.14) that the ramp from the Meadowbrook Parkway "will significantly reduce flow to the Bellmore reception center" is not correct. The statement is based on an analysis treating the ramp-highway interface as an "unsignalized intersection,"
which is an improper approach, for the following reason. On page 5-16 of the HCM it states:
Ramp-Street Interf ace This chapter does not address the subject of ramp-street system interfaces. Chapter 9 contains detailed procedures for the analysis of signalized junctions. A procedure for the analysis of unsignalized intersections is included in Chapter 10.
Where the ramp-street interface is itself a merge or diverge ramp junction of high-type design, the procedures in this chapter may be approximately applied. (Emphasis added.]
The traffic on the ramp from Meadowbrook Parkway approaching EB (eastbound) Sunrise Highway can only merge into the Sunrise Highway traffic. This interface is of a high-type design and is certainly not an in-tersection. Consequently, the procedures of Chapter 5 of the HCM apply, not those of Chapter 10. We have provided our analysis of this interface to the Interveners; this analysis shows a ramp capacity wellin excess of demand, and certainly far above the monitoring service rate at the Bellmore reception center.
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Similarly, the ramp from the LIE onto SB (southbound) Route 107 is a cloverleaf that services traffic merging into the traffic along SB Route 107. The ramp from the LIE to the Seaford Oyster Bay Expressway, Route 135 (n_ot the South Oyster Bay Expressway cited in the State testimony)is o
an expressway-to-expressway interface, which again services merging traffic. In any event:
The ramp from the LIE to Route 107 services Path IC traffic (see Table 2-1 in TR-201 A) with total expected evacuation traffic of 0.3 x 2500 = 750 vehicles, distributed over a minimum of 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. This expected demand of 125 vph is so far below ramp capacity as to make a formal calculation unnecessary.
The ramp from the LIE to Route 135 services traffic along Paths 1B and ID with an expected evacuation volume of 0.3 x (4040 + 1789) =
1749 vehicles over 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />, or 291 vph. This figure is also well below ramp capacity. Using the State's data, the AADT for NY 135 is 55,220 vehicles, which translates into 1725 southbound vehicles per hour. Thus, 1725 + 291 = 2016 vph, well below the checkpoint capacity of 4000 vph, according to Table 5-1 of the HCM.
15.
Q.
The State witnesses argue (pp.16-17) that they have not erred by double-counting vehicles. Are they correct?
A.
No. Here I address only their error in double-counting vehicles from with-in the EPZ that are represented twice: once as evacuating traffic and again as background traffic. That is, these same vehicles from within the EPZ are summed as though they are different vehicles from different ori-gin points.
This double-counting persists throughout the network, albeit at decreasing levels as the distance from the EPZ increases. Specifically, some proportion of the background traffic based on the AADT data, on every highway section, includes vehicles originating from within the EPZ.
But these vehicles, as noted above, are evacuating; they cannot simulta-neously be counted as background traffic. Thus, their total volumes are, to the extent noted above, overstated on the network.
__...___.__...___L__t
Previously I h?ve documented this double-counting at the western 1
boundary of the EPZ in my Rebuttal Testimony at 25. As shown there, the l
State added background traffic from within the EP4 of some 46,000 vehl-cles to the evacuation traffic of some 58,000 vehicles, when, in fact, there could be no backstround traffic at all, if everyone was evacuatinst.
16.
Q.
The State witnesses contend (p.17) that you and they have used the same basic methodology. Is this correct?
A.
Yes, with some important distinctions. They say at page 16:
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.
The statement on background traffic is correct, with the important dis-tinction that we did field work to obtain actual representative turn per-centages, as already explained above.
17.
Q.
Is there any other distinction between your respective methodologies?
A.
Yes. The State witnesses have also said (pp.16-17) "In a manner similar to Mr. Lieberman's methodology, evacuation traffic on each route was then added to the background traffic, and the total compared with the available capacity for the particular location."
Again, we have in common the assumption that 100 percent of the background traffic is present, with the addition of the evacuation traffic.'
However, the addition must be done with some sense of balancing the net-work, for there will be redistribution of the background traffic in the face of such significant additions of new (la, evacuation) traffic.
,This redistribution of background traffic, which is responsive to the substantial influx of evacuation traffic, is the basis for my argument that
background traffic volumes could decline on the access roads to the re-ception centers below the 100 percent level. My argument was presented in the preliminary analysis documented in KLD TR-192 and in my earlier Rebuttal Testimony at page 8.
We used 100 percent of the background traffic for our analyses documented in KLD TR-201A, however, in the spirit of conservatism (see KLD TR-201A at page 20).
Also, while the State and I have the basic methodology in common, we differ in actual volumes (particularly near the EPZ) because of the fitate witnesses' double-counting of some of the traffic.
1 18.
Q.
Should the background traffic also be assigned to the network, just as the additional traffic was?
A.
Yes. Ideally the combined traffic should be assigned in toto. There are practical reasons (such as the amount of data available) why neither I nor the State did so.
I chose to use a manual assignment of the additional traffic to bal-ance the totals and to keep track of the detailed paths f or reasonableness.
j The State witnesses chose to use a computer package to achieve the same end.
It must be mentioned that the State witnesses' most recent rebut'tal testimony is the first time the State witnesses have clearly stated that they are not attempting to assign all traffic but are assigning only the ad-ditional traffic. Indeed, even a very careful reading of their earlier testi-mony would not reveal that they were doing this.
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l 19.
Q.
The State witnesses contend in their testimony that you are confusing op-erational V/C and projected V/C and therefore made the mistake of i
stating that V/C cannot exceed 1.0. Is their contention correct?
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A.
No, it is not. In fact, they themselves demonstrate that they do not fully l
understand the difference between the two concepts, and they therefore come to erroneous conclusions regarding queueing.
The State witnesses tried to gain in:4ht into the queueing in the l
l immediate area of the reception centers based upon their projected V/C l
ratios, which are useful only for the planning analysis. They gave no con-sideration to the upstream metering effects of the approach routes.
Our analysis, which does a planning estimate of the demand cou-pled with the operational consideration of the metering effect of tne net-work (particularly the major access routes) is much more realistic and better depicts the queueing effects near the reception centers, based upon realistic arrival patterns and service rates.
20.
Q.
The State witnesses have stated (p.18) that you are incorrect in saying that they violated flow conservation laws. How do you respond to this?
A.
I did indeed raise the question of flow conservation, and probably put undue emphasis on it. This was due to my understanding at the time that the State witnesses were actually assigning all traffic. As I stated in the preceding response, the first time the true nature of their assignment was rcported was in their latest rebuttal testimony.
Had they been doing an assignment of all traffic, the conservation of vehicles would have been essential, for the flows cannot arbitrarily dis-appear or grow as they travel from origin to destination.
As it is, we minimizad the problem of such growth in our field data work by taking data on a given day along paths through the network. This is reflected in our background traffic, and makes it, in my judgment, more realistic.
When you have a montage of data, such as AADT data, collected at different points in the network at different times (indeed of ten in differ-ent years when you are depending upon data on file), the problem of flow continuity becomes more important.
The State's background traffic data are a montage in the sense that different short-term counts were taken at different locations over an ex-tended period and pieced together. Because this is a montage, the bound-arles do not match; that is, the vehicles do not satisfy continuity of flow.
(As a practical matter, as was done by the State, the pieces are of ten not matched to attain consistency.)
21.
Q.
The. State witnesses also question (p.17) your assertion that they moved all the background traffic to the reception centers. How do you respond?
A.
Given that I believed they were doing a total assignment, this was the only logical conclusion. Now that they have clearly stated the nature of their assignment, I would no longer make the same statement.
22.
Q.
The State witnesses argue (pp.18-19) that your criticism of their 7.5 per-cent reduction f actor on the LIE is not appropriate. Do you agree?
A.
No. First, they mischaracterize my criticism. My criticism (see my earli-er Rebuttal Testimony at page 3) addressed their inconsistency in first citing a 30% capacity reduction estimate and then applying the 7.5 per-
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cent figure. At no time did I suggest that a capacity reduction to account for truck traffic was " inappropriate."
l The State's most recent testimony also says that truck traffic can rise to 20 percent of the total. Applying the HCM equivalent, E, for this T
condition, and using Table 3-3 on page 3-13 of the HCM for Level Terrain (characteristic of portions of the LIE), we calculate a capacity reduction j
I factor of:
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[ 0.2 x 1.7 + 0.8 ]-1 = 0.88 That is, a 12 percent reduction in capacity, using the State's upper bound of 20% trucks, is obtained ' sing the HCM procedure. My complaint, then, is that the State witnesses cite a 30 percent capacity reduction, then use a 7.5 percent reduction, then cite 20% trucks, which figure yields a 12%
capacity reduction by the HCM. We therefore are presented with three different estimates for the same factor.
Nowhere in my calculations do I assert a 2% capacity reduction for heavy vehicles in estimating capacity on the LIE. In fact,I do not formal-ly calculate capacity on the LIE because I stipulated a very conservative Level of Service for the entire period. However, note that a 7.5 percent capacity reduction brings the LIE capacity used by the State to 5550 vph, which is higher than the 5400 vph nominal capacity and 4590 vph conges-tion capacity used in the Shoreham Evacuation Plan (Appendix A).
23.
Q.
The State witnesses (pp.19-20) argue that you should not have excluded growth in the Suffolk County population. Do you agree?
A.
No. First, I have argued (in my earlier Rebuttal Testimony at page 9) that consideration of growth is not relevant, since planning is an ongoing pro-cess and plans change to meet changing conditions. Second, the analysis for TR-201A addresses traffic flow in Nassau County only. Hence, our re-buttal testimony at page 10 only pointed out that the State's direct testi-mony on this subject, in addition to being irrelevant, was misplaced in considering growth elsewhere, and I offered data specific to Nassau Coun-ty.
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24.
Q.
The State witnesses, citing (at pp. 20-21 of their testimony) your rebuttal testimony on pages 23 and 24, maintain that four of the six errors you de-tected in the State's network are incorrect. Do you agree?
A.
No. The State's testimony does not dispute our statement that "many...
arterials increase in width on the approaches to intersections to accom-modate additional lanes and turn bays. This increases capacity. The State's analysis does not account for this." The State's response is to note the " narrowest" point or portion of three of the four contended sections.
However, the State witnesses' capacity estimation is premised on an as-sumed green ratio of 50 percent (see their Exhibit 10) on the approaches to the intersections - n_ot at the narrowest point. At no time have they estimated section capacity. Thus, capacity estimates based on the nar-rowest section of a link may be too low. Also:
If a highway section has two subsections, each with a different width, then it must be represented as two network links in series --
one for each subsection.
The State witnesses acknowledge that link (780,118) is three-lane
" partially access-controlled," yet insist they are correct in as-signing it the capacity of an 8-lane arterial (LT of 56).
In their " Discussion of Capacity Values" in their Exhibit 10, the State witnesses say that the capacity values for Sunrise Highway "were increased by one-third to account for the high design stan-dards on this roadway including turn!ng lanes at intersections." But Sunrise Highway is not the only facility with such high design stan-dards in Nassau County. Route 107 and Old Country Road also dis-play high standards, with turn bays at all major intersections. Also, Routes 25 and 347 in Suffolk County have similar high design stan-dards. Why weren't the capacities of these facilities increased as well?
o, l
l 25.
Q.
We have discussed the analysis in great detail. What is the point of all of I
this analysis?
l A.
Much of the analysis is directed to answering the question "can the ex-1 pected evacuation traffic demand travel to the reception centers and be monitored within about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?" The answer is "yes."
l
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l 26.
Q.
Does this complete your testimony?
j A.
Yes.
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LILCO, July 20,1987
. n; rg u 87 JJL 21 P3 :13 CERTIFICATE OF SERVICE cr:
D0i>
In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)
Docket No. 50-322-OL-3 I hereby certify that copies of SURREBUTTAL TESTIMONY OF EDWARD B.
LIEBERMAN were served this date upon the following by hand or telecopier as indicated by one asterisk, by Federal Express as indicated by two asterisks, or by first-class mail, postage prepaid.
Morton B. Margulies, Chairman
- Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20555 East-West Towers, Rm. 407 4350 East-West Hwy.
Atomic Safety and Licensing Bethesda, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline
- Washington, D.C. 20555 Atomic Safety and Licensing Board Richard G. Bachmann, Esq.
- U.S. Nuclear Regulatory Commission George E. Johnson, Esq.
East-West Towers, Rm. 427 U.S. Nuclear Regulatory Commission 4350 East-West Hwy.
7735 Old Georgetown Road Bethesda, MD 20814 (to mallroom)
Bethesda, MD 20814 Mr. Frederick J. Shon
- Atomic Safety and Licensing Herbert H. Brown, Esq.
- Board Lawrence Coe Lanpher, Esq.
U.S. Nuclear Regulatory Commission Karla J. Letsche, Esq.
East-West Towers, Rm. 430 Kirkpatrick & Lockhart 4350 East-West Hwy.
South Lobby - 9th Floor Bethesda, MD 20814 1800 M Street, N.W.
Washington, D.C. 20036-5891 Secretary of the Commission Attention Docketing and Service Fabian G. Palomino, Esq.
- Section Richard J. Zahnleuter, Esq.
U.S.14uclear Regulatory Commission Special Counsel to the Governor 1717 H Street, N.W.
Executive Chamber Washington, D.C. 20555 Room 229 State Capitol Albany, New York 12224 I
i l
i
, 1 I
0 3
Mary Gundrum, Esq.
Jonathan D. Feinberg, Esq.
Assistant Attorney General New York State Department of 120 Broadway Pubile Service, Staff Counsel Third Floor, Room 3-116 Three Rockefeller Plaza
)
New York, New York 10271 Albany, New York 12223 Spr.nce W. Perry, Esq.
- Ms. Nora 1 redes William R. Cumming, Esq.
Executive Coordinator Federal Emergency Management Shoreham Toponents' Coalition Agency 195 East Maihitreet 500 C Street, S.W., Room 840 Smithtown, New York 11787 1
Washington, D.C. 20472
)
Gerald C. Crotty, Esq.
J Mr. Jay Dunkleberger Counsel to the Governor New York State Energy Office Executive Chamber Agency Building 2 State Capitol
]
Empire State Plaza Albany, New York 12224 j
Albany, New York 12223 Martin Bradley Ashare, Esq. **
Stephen B. Latham, Esq. **
Eugene R. Kelly, Esq.
Twomey, Latham & Shea Suffolk County Attorney 33 West Second Street H. Lee Dennison Building P.O. Box 298 Veterans Memorial Highway Riverhead, New York 11901 Hauppauge, New York 11787 Mr. Philip McIntire Dr. Monroe Schneider Federal Emergency Management North Shore Committee Agency P.O. Box 231 26 Federal Plaza Wading River, NY 11792 New York, New York 10278 James N. Christman Hunton & Williams 707 East Main Street P.O. Box 1535 i
Richmond, Virginia 23212 DATED: July 20,1987 I
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