ML20236A729
| ML20236A729 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/23/1987 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#387-4138 OL-3, NUDOCS 8707280197 | |
| Download: ML20236A729 (184) | |
Text
-
OTGINK-UNITED STATES O
NUCLEAR REGULATORY COMMISSION IN THE MATTER OF:
DOCKET NO: 50-322-OL-3 LONG ISLAND LIGHTING COMPANY (Emergency Planning)
(Shoreham Nuclear Pow;tr Station, Unit 1)
O LOCATION: HAUPPAUGE, NEW YORK PAGES: 18763-18946 DATE:
THURSDAY, JLLY 23, 1987 1
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ACE-FEDERAL REPORTERS, INC.
O Official Reporters 444 North Capitol Street V/ashington, D.C. 20001 S}728019797o,93 MWM
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L 82800000 187'63 marysimons 1
UNITED STATES OF AMERICA j.s
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2 NUCLEAR REGULATORY COMMISSION 3
4 3EFORE THE ATOMIC SAFETY AND LICENSING BOARD l
5 6
X 7
In the Matter of:
8 LONG ISLAND LIGHTING COMPANY
- Docket No. 50-322-OL-3 9
(Shoreham Nuclear Power Station, 10 Unit 1) 11
___________________________________x 12 Court of Claims 13 State of New York 14 State Office Building 15 Third Floor Courtroom 16 Veterans Memorial Highway 17 Hauppauge, New York 117 88 18 Thursday, July 23, 1987 19 The hearing in the above-entitled matter 20 reconvened, pursuant to notice, at 9:03 o' clock a.m.
21 BEFORE:
22 MORTON B. MARGULIES, Chairman 23 Atomic Safety and Licensing Board 24 U.
S.
Nuclear Regulatory Commission 25
- Bethesda, Maryland 20555
'.(
1
-82800000 18764 j
marysimons
-l 1
JERRY R.
KLINE, Member
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'/
2 Atomic Safety and Licensing Board 3
U.
S.
Nuclear Regulatory Commission 4
Bethesda, Maryland 20555 5
FREDERICK J.
SHON, Member 6
Atomic Safety and Licensing Board 7
U.
S.
Nuclear Regulatory Commission 8
Bethesda, Maryland 20555 9
APPEARANCES:
10 On Behalf of Long Island Lighting Company:
11 JAMES N.
CHRISTMAN, ESQ.
12 STEPHEN W. MILLER, ESQ.
13 Hunton & Williams 14 707 East Main Street 15 P.
O.
Box 1535 16 Richmond, Virginia 23212 17 On Behalf of Suffolk County:
18 CHRISTOPER M. McMURRAY, ESQ.
19 RONALD ROSS, ESO.
20 Kirkpatrick & Lockhart j
21 South Lobby, 9th Floor l
l 22 1800 M Street, N. W.
23 Washington, D.
C.
20036-5891 24 25
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_________O
82800000 18765 J
marysimons j
1 On Behalf of the State of New York:
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2 RICHARD J.
ZAHNLEUTER, ESQ.
3 Special Counsel to the Governor 4
Executive Chamber 5
Room 229 6
State Capitol 7
Albany, New York 12224 8
On Behalf of the NRC:
9 RICHARD G. BACRMANN, ESQ.
10 U.
S. Nuclear Regulatory Commission 11 7735 Old Georgetown Road 12 Bethesda, Maryland 20814 13
.s R) u 15 16 17 l
18 l
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20 21 22 23 24 25 l1(:)
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82800000 18766 marysimons I
1 CONTENTS
_,_4
(
)
Voir 2
Direct _C,ross Redipect Recrosp Dire Board (Panel of Witnesses) i 3
ROBERT C. MILLSPAUGH and 4
DAVID T.
HARTGEN 18769 18778 18937 5
EXHIBITS 6
Identified Admitted Suffolk County Exhibits 7
Exhibit No. 13 18769 8
Exhibit No. 16 18769 9
LILCO Exhibits 10 Exhibit No. 28 18780 18890 Exhibit No. 29 18799 18890 11 Exhibit No. 30 18811 18890 Exhibit No. 31 18816 18890 12 Exhibit No. 32 18816 18890 Exhibit No. 33 18817 18890 13 Exhibit No. 34 18817 18890 Exhibit No. 35 18823 18890
\\_j r
a
/
Id Exhibit No. 36 18857 18890 Exhibit No. 37 18860 18890 15 Exhibit No. 3 8 18932 (Exhibit No. 3 8 was not furnished to Reporters.)
16 Exhibit No. 39 18935 18937 17 New York State Exhibits IB Exhibit No. 5 18771 18777 Exhibit No. 6 18772 18777 19 Exhibit No. 7 18772 18777 20 NRC Exhibits Exhibit No. 1 18915 21 Exhibit No. 2 18917 22 23 Morni ng Rec e s s................................ 18 8 0 3 Luncheon Recess...............................
18854 24 Afternoon Recess..............................
18886 25 if
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1 l
82800101
-18767 suewalsh' tl l
.d 1
PROCEEDINGS 7-k 2
(9:03 a.m. )
i 3
JUDGE MARGULIES:
Please come to order.
I d
understand counsel for Staff has a statement to make, j
5 MR. BACHMANN:
Yes, Judge Margulies.
Yesterday 6
the Board granted the Staff permission to file written 7
comments or testimony from Dr. Urbanik concerning the latest 8
round of rebuttal and surrebuttal testimony that has been 9
filed here.
10 I discussed this at length with Dr. Urbanik 11 yesterday.
It is the Staff's position -- and I will state 12 it on the record; I have informed counsel for the State and 13 the County already -- that Dr. Urbanik will not be filing a 14 separate document.
However, his testimony and his rebuttal 15 testimony should be considered to encompass all testimony 16 filed through July 10th.
17 In other words, if he refers to KLD TR-201, you 18 should consider that to also refer to 201.A.
Also, comments 19 he may have had concerning the State's submittal would also 20 encompass the State's testimony filed through July 10.
21 It does not necessarily at this point reflect 22 Dr. Lieberman's latest surrebuttal testimony; however, I 23 anticipate that he will consider it that way also.
He 24 hasn't had an opportunity to see that yet.
. 25 So, we will just assume from here on out that
!d
)
82800101 18768-suewalsh q.
1 anything that Dr. Urbanik has said in his direct testimony g
V 2
or can be elicited on cross-examination will include all of 3
the testimony.
But, we will not be changing the written 4
direct testimony.
5 MR. McMURRAY:
Judge Margulies, I also have one 6
small matter.
In a recent filing filed by LILCO, LILCO 7
indicated that they were not going to cross-examine Dr.
8 Harris on his testimony.
9 As you recall, Suffolk County's testimony was 10 admitted into the record with the qualification that Dr.
11 Harris had to be sworn in and cross-examined on his 12 testimony.
Well, at this time I would like to move, since 13 he is not going to be cross-examined, that the 14 qualifications with respect "to Suffolk County's testimony 15 and Dr. Harris' participation in it be lifted.
16 JUDGE MARGULIES:
Is there any obj ection?
17 MR. CHRISTMAN:
No obj ection.
18 MR. BACHMANN:
No objection.
19 MR. ZAHNLEUTER:
No objection.
i 20 MR. McMURRAY:
If the Board is looking for the 21 exhibit numbers, we can get them for you quickly.
22 JUDGE MARGULIES:
I should have them here.
My 23 record shows that is Suffolk County's Exhibit Number 13 and 24 Suffolk County's Exhibit Number 16.
25 MR. McMURRAY:
That's correct.
O I
82800101 18769 f
.suewalsh L
i
_,4.
JUDGE MARGULIES:
The condition previously 1
i -
2 imposed as to those exhibits is lifted, and they are 3
admitted unconditionally as Exhibit Number -- Suffolk County 4
Exhibi t Number 13 and Suf f olk County Exhibit Number 16.
5 (The documents previously marked as 6
Suffolk County Exhibit Number 13 7
and Suffolk County Exhibit Number 8
16 are admitted into evidence.)
9 JUDGE MARGULIES:
Is New York State-ready to 10 proceed with their panel?
11 MR. ZAHNLEUTER:
Yes, sir.
Dr. Hartgen and Mr.
12 Millspaugh are at the witness table.
i 13 JUDGE MARGULIES:
I would like-to have the 14 witnesses sworn in.
Would you please stand and raise your 15 right hands?
16 (The witnesses are sworn by Judge Margulies.)
I 17 Whereupon, 18 ROBERT C. MILLSPAUGH 19 and
?0 DAVID T.
HARTGEN 21 were called as witnesses by and on behalf of the Intervenor, 22 the State of New York, and having first been duly sworn, 23 were examined and testified as follows:
24 DIRECT EXAMINATION 1
25 BY MR. ZAHNLEUTER:
l
i i
l suewalsh 82800101 18770 1
Q Gentlemen, would you please state your name and
~
2 business address?
3 A
(Witness Millspaugh) Robert Millspaugh, 533 1
4 Wayne-Place, Delmar, New York 12054.
And, I'm with the 5
Department of Transportation, New York State Department of i
6 Transportation, 1220 Washington Avenue, Albany, New York.
7 (Witness Hartgen) I'm David T. Hartgen, and I'm 8
with the New York State Department of Transportation, same 9
address.
10 Q
Do you have before you a document which is 11 entitled " Direct Testimony of David T.
Hartgen and Robert C.
I 12 Millspaugh on Behalf of the State of New York Regarding l
13 LILCO's Reception Centers," dated April 13,- 19 87 and an
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14 accompanying document which is entitled " Exhibits to Direct 15 Testimony of David T.
Hartgen and Robert C. Millspaugh on 16 Behalf of the State of New York Regarding LILCO's Reception 17 Centers," also dated April 13 th, 19877 18 A
Yes, we do.
19 MR. ZAHNLEUTER:
I think it would be helpful to 20 note at this point, Judge Margulies, that prior to the I
21 beginning of the hearing today I distributed a more readable 22 copy of Exhibit 11 to the document that I just referenced, 23 which is the State's exhibits to the direct testimony.
I 24 I think it would also be helpful to note that 25 Exhibit 25 to this document is a videotape.
~
82800101:
18771 suewalsh' l.
_,s,.
I would like to have the direct testimony and 1
~
2 the accompanying exhibits identified as New York State's 3
Exhibit 5.
4 JUDGE MARGULIES:
For purposes of the record, 5
can you tell us what are the numbered exhibits to the 6
Appendix in terms of the total number because they are not' 7
in a single document, so I want it clear on the record?
8 It is Exhibit 1 through what, inclusive?
I l
9 think the videotape has a different number.
10 MR. ZAHNLEUTER:
Okay.
The exhibits are 11 Exhibits 1 through 36.
And, within those exhibits Exhibit 12 11 is the map of traffic volumes that I just referenced.
13 And, within those exhibits Exhibit 25 is the videotape id showing portions of the approaches to reception centers.
15 JUDGE MARGULIES:
At this point, we will mark 16 the document for identification.
17 (The document referred to is marked 18 as New York State Exhibit Number 19 5 for identification.)
20 BY MR. ZAHNLEUTER:
(Continuing) 21 Q
Gentlemen, do you also have before you a 22 document which is entitled " Rebuttal Testimony of David T.
23 Hartgen and Robert C. Millspaugh on Behalf of the State of 24 New York on KLD's Capacity Analysis (KLD TR-201)?"
25 A
(Witness Hartgen)
Yes, we do.
1 i
i
2 82800101 18772 suewalsh 1
MR. ZAHNLEUTER:
And, Judge Margulies, may we 2
please have this docunent marked for identification as ne 3
State of New York's Exhibit 6?
4 JUDGE MARGULIES:
It will be so marked.
5 (The document referred to is marked i
6 as New York State Exhibit Number 7
6 for identification.)
8 BY MR. ZAHNLEUTER:
(Continuing) 9 Q
And, finally do you have before you a document to which is entitled " Rebuttal Testimony of David T.
Hartgen 11 and Robert C. Millspaugh on Behalf of the State of New York 12 Concerning KLD TR-201.A and LILCO's Rebuttal Testimony of 13 May 27th, 1987?"
()
14 A
-(Witness Hartgen)
Yes, we do.
15 MR. ZAHNLEUTER:
May we please have this 16 document marked for identification as the State of New 17 York's Exhibit 7?
18 JUDGE MARGULIES:
It will be so marked.
19 (The document referred to is marked 20 as New York State Exhibit Number 21 7 for identification.)
22 BY MR. ZAHNLEUTER:
(Continuing) 23 Q
Gentlemen, were these exhibits, that is the 24 State of New York Exhibits 5, 6,
and 7, prepared by you or 25 under your supervision?
l l.-
82800101 18773 suewalsh L
-l
_ ja 1
A (Witness Hartgen)
Yes, they were..
i'/
2 Q
Do you have any corrections to make to any of 3
these materials?
i 4
A.
Yes, we have a number of corrections.
l I
5 Q
Would you please read them into the record at 6
this time?
7 A
Referring to the direct testimony, that is the 8
small red document --
1 9
Q That's Exhibit 57 10 A
Exhibit 5.
On Page 18, the last paragraph, 11 first line, should read "the analyses were conducted."
12 On Page 19, the first large paragraph there, 13 third line, the word " analysis" should read " analyses."
. 4
'k,/
14 On Page 27, the large paragraph at the bottom, 15 the second line, the reference to KLD TR-102 should read TR-16 201.
17 18 19 20 21 22 23 24 25 l f's
'O
-82800202 18774
. j oewalsh I
Q A3.1 right.
~
2 A
(Witness Hartgen)
On Page 29, the middle 3
paragraph, ninth line down, should read " capacity of 4
roads."
And, further over on that same line " sites is 5
avail able. "
6 On Page 31, the first word should be 7
" construction," no "S."
8 On page 34, Footnote 13, under the indent to the 9
Roslyn approach, it should read " Node 830" rather than 803.
I 10 1
On Page 35, the first paragraph, last line, 11 should read, "which are Exhibits 12 and 21.B hereto."
l 12
'Q Dr. Hartgen, in the line above should the word 13
" table" be modified?
I) 14 A
Yes, " tables."
On Page 38, the first large 15 paragraph, the first line should read, "However, as noted."
16 Page 39, under DOT scenaria, "I.a" should read 17
" DOT 1.A" and then continuing, "same as DOT 1, but 26 18 percent.
19 JUDGE MARGULIES:
Can I have that again?
20 WITNESS HARTGEN:
Yes, sir.
On Page 39, the 21 second block there starts off with DOT I.a.
It should say l
1 22 DOT 1.a.
And, then continuing in that same sentence, it 23 should say "same as DOT 1."
24 Page 42, Footnote 17, the word " scenarios" 25 should read " scenario 2."
l l
82800202 18775
- joewalsh
<1 1
And, for that same footnote, the sentence should
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('
2 end after the parentheses.
In other words, strike the 3
phrase "are as fo31ows."
d BY MR. ZAHNLEUTER:
(Continuing) 5 Q
Dr. Hartgen, is there a correction that you need 6
to make on the fifth line on Page 427 7
A Yes.
I'm sorry.
The last line of the text 8
there should read "in a network are at or over the v/c of 9
1."
10 Page 48, second paragraph, second sentence, the 11 phrase "v/cv" should read "v/c."
In other words, remove the 12 last "v" there.
13 Page 49, the last line the word " worst" should
/^%
'V 14 be " worse."
15 Page 51, second line, the reference to Exit 41-5 16 should be Exit 41-S.
17 Page 58, second paragraphe the third line, 18 should read " exiting do," d-o.
19 Page 60, last paragraph, the third 1dne up from 20 the bottom shou;.d read " Area A and B falls."
21 Page 64, middle paragraph, next to the last 22 line, the word " decontaminated" should read " contaminated."
23 Page 69, under the heading Number 1, the second 24 line, should read " vehicles per hour."
25 Page 72, middle paragraph, the third line should J
82800202 18776
' j oewalsh 1
-read "at only a five percent shower rate."
2 And, on Page 73, the last paragraph, the word i.,
- t 3
"Roslyn" is misspelled.
ifN 4
Q Do you have any other corrections to make?
5 A
Yes, several others.
Referring to the document, 4
j x-6 that is the large red document --
7 Q
That again is the State of New York's Exhibit 5.
8 A
Yes.
Exhibit 13, the next to last line should 9
read " DOT 5.A, 150*, 50 rather than 62, 50 rather than 57, 10 50 rather than 56, and " minimum path" rather than " plan."
11 Exhibit 22, the last column, that is the column 12 headed "1.3+,"
the entries in the column should read as 13 follows:
0, 0,
10, 6,
0,_ 24, 22, and 33.
)
14 With respect tc. Exhibit 25, the video, strike 15 references to level of service.
16 Q
Does that complete your list of corrections?
17 A
Yes.,
18 s
s 19 20 21 22 23
. 24 25 (O
82800303 18777 marysimons 74 1
Q Gentlemen, given these corrections, are these 2
documents, that is the State of New York's Exhibits 5, 6 and 3
7, true and correct to the best of your knowledge?
4 A
(Witness Millspaugh)
Yes.
l 5
A (Witness Hartgen)
Yes.-
6 MR. ZAHNLEUTER:
Judge Margulies, I offer these 7
three exhibits, the State of New York's Exhibits 5, 6 and 7, 8
into evidence.
9 JUDGE MARGULIES:
Is there any obj ection?
10 MR. McMURRAY:
No obj ection.
11 MR. CHRISTMAN:
No.
12 MR. BACHMANN:
No objection.
13 JUDGE MARGULIES:
They are admitted as New York 14 State's Exhibits Nos. 5, 6 and 7.
15 (New York State Exhibits 5, 6 and 16 7,
inclusive, previously marked for 17 identification, were admitted into i
18 evidence.)
19 MR. ZAHNLEUTER:
Judge Margulies, as we 20 discussed earlier this morning, Exhibit 25 to the State of 21 New York's Exhibit 5 is a video tape.
22 In the event that you haven't had a chance to 23 review it, we have it here available with a VCR, and if you 24 would like to see it, we are prepared to show it to you, or 25 if you would rather not see it, we won't show it to you, but v
'82800303 18778 marysimons
-l I
.,e I would recommend that the Board take advantage of the b
2
' opportunity to. review it.
3 It lasts 11 minutes and it contains two 4
sections.
The first section deals with the roads that 5
approach the intersection at 107 and Old Country Road and 6
the latter half of the video tape deals with the 7
intersections in the area of the Roslyn Reception Center and 8
the service roads and Willis Avenue.
9 JUDGE MARGULIES:
We will proceed without 10 viewing it at this time.
11 MR. ZAHNLEUTER:
In that event, these witnesses 12 are ready for cross-examination.
13 JUDGE MARGULIES:
You may proceed with cross-14 examination.
15 MR. CHRISTMAN:
Thank you, Judge Margulies.
16 CROSS-EXAMINATION 17 MR. CHRISTMAN:
IB Gentl emen, let me ask you some questions about 19 one of the intersections we have been talking about for the 20 last few days and are discussed in your testimony, and I'm 21 referring now to the intersection at Route 107 also called 22 Broadway and Old Country Road.
23 That's the intersection that KLD refers to as 24 H-4 in its various analyses, and I'm going to have someone 25 hand you a couple of documents so we can talk about this
)
!(L)
82800303 18779 marysimons 3
1 intersection and these documents at the same time.
d 2
The first one of these I would like, Judge, to 3
have marked as LILCO Exhibit 28 for identification.
It is a 4
document consisting of eight pages.
At the top it says 5
"1985 HCM:
Signalized Intersections" and underneath that 6
identifying information with come information and a table of 7
traffic volumes at the bottom.
8 (The document referred to is distributed to the 9
parties and the Board.)
10 This document has reference to the Old Country 11 Road and Broadway or Route 107 intersection and deal with 12 the time period analyzed of 0700 through 10 o' clock in the 13 morning.
)
The second document I want people to have is 14 15 already in evidence.
It's called Suffolk County Exhibit 16 27.
It's a number of axle counts and reads at the top in 17 the center "15-Minute 2-Channel Axle Count - Correction 18 Factor 1.00."
It also refers to the southbound Broadway and 19 Old Country Road.
So it's the same intersection I've been 20 discussing.
21 It's two pages long.
It's a table of traffic 22 counts taken by the company ATI with a handwritten sheet 23 attached tc it with some summary data taken from the front l
24 sheet.
25 JUDGE MARGULIES:
The first document referred to O
82800303 18780 marysimons l
1 will be marked LILCO's Exhibit No.:28 for identification.
2 It bears the first line "1985 HCM:
Signalized 3
Intersections."
d MR.-CHRIS7 NAN:
Thank you.
5 (The document referred to was 6
marked LILCO Exhibit No. 28 7
for identification.)
B BY MR. CHRISTMAN:
9 Q
Gentlemen, if you would just look at that 10 document that the Judge just described, the "1985 HCM:
11 Signalized Intersections," LILCO Exhibit 28 for 12 identification.
13 Do you recognize that?
14 A
(Witness Millspaugh)
Yes.
15 Q
And can you describe what it is?
16 A
This is a computer analysis using the software 17 from the Highway Capacity Manual for this intersection of 18 Old Country Road and Route 107.
19 The name of the analyst, "B.
G."
is Bruce 20 Guynup, one of my assistants.
21 0
So he works for the State?
22 A
Yes.
He works for me.
23 Q
And the hours analyzed here are 7 in the morning 24 till 10 in the morning; is that right.
25 A
Yes.
i 1
82800303 18781 marysimons
'l Q
Are you familiar with Suffolk County Exhibit 27
' g' l
~
2 as"well, the second document you have there?
Those are the 3
axle counts by the ATI that KLD had done.
4 A
Yes.
5 0
You used some of these axle counts that KLD had 6
done in your analysis using the HCM software, did you not?
7 A
In doing this problem?
8 0
Yes, that's what I mean.
9 A
Yes.
10 0
If you would look at the HCM printout that B. G.
l '1 analyzed or was responsible for, look at the next to the 12 last page, which is page 7, although you can't tell it from 13 this copy, and if you would look at the southbound approach 14 labeled "SB" at the bottom, and I want to focus on the left-15 turn movement on that approach.
16 A
I want to be sure I'm on the right page here.
17 Is that with the heading " Capacity Analysis Worksheet"?
1B Q
Correct.
The southbound approach at the bottom 19 there and.the left-turn movements, do you see those?
20 A
Yes.
f 21 Q
Now the left-turn movements there on the 22 southbound approach refers to the turn from Route 107 going 73 south onto Old Country Road towards the Hicksville Reception 24 Center, does it not?
25 A
Yes.
c0 m
- i 82800303 18782
.marysimons I
1
- -,)
_ Q Now over in the " Lane Group Capacity" column,
'V 2
which is the next to the last column, can you give me the 3
capacity for the left turn movement southbound at that 4
intersection?
5 A
Would you scy that again.
6 Q
Just give me the left-turn protected capacity 7
first.
8 A
You want the number?
9 Q
Yes.
10 A
262.
11 Q
Okay.
So that's the capacity for the left-turn 12 protected, correct?
13 A
For the left-turn lane, yes.
's-14 Q
What I want first is the left-turn protected 15 capacity, if you could.
16 (Witnesses conferring and reviewing document.)
17 All I want to know is the capacity for the left-18 turn protected.
19 A
For the protected it's 262, but you have to 20 understand that the program internally considers the 21 permissive part of the move.
22 Q
What is the capacity for the permissive left 23 turn?
24 A
229.
25 Q
Shouldn't that really be 229 divided by 1.019 f C l
l
82800303 18783 marysimons I
which comes out to 2257 2
A (Witness Hartgen)
No.
The 1.019 refers to the 3
division of 267 by 262.
1.019 is the ---
4 Q
Yes, sir, I understand that, but don't you also l
)
5 have to apply the 1.019 and f actor the 229 in order to get 6
your lane group Capacity for the lef t-turn permitted?
7 A
There is only one lane in the group.
8 Q
What is the total then for both lef t-turn 9
protected and left-turn permitted?
10 A
The methodology of calculation capacities for 11 each of these movements, the permitted movement is included 12 in the phasing of the signal which allows for other 13 movements as well.
So its capacity would be calculated as llh 14 part of the capacity of other movements.
It's not here.
15 Q
Well, can't you simply add the 262 and the 292 16 and get the total capacity?
17 A
(Witness Mil'lspaugh)
No.
IB Q
So your total capacity f or the lef t-turn 19 movement you're saying is, what, 262?
20 A
For the protected phase only.
You don't add the 21 two figures to get the capacity for that protected left turn 22 with the arrow.
23 24 25
i E87dC9C9' 0000}&OO-18784 suewalsh G
1 O
What is the total left turn capacity then for
.,s I)
\\-
2 that intersection going southbound?
3 A
(Witness Millspaugh)
During this phase?
We 4
already answered that.
5 Q
What I really want to know is how many cars get
{
6 through on the lef t turn in an hour?
7 HOW many Cars get through a ball green in an 8
hour?
Can you tell me that?
9 MR. McMURRAY:
Excuse me.
I'm confused about 10 the question.
Is the question how many get through on the 11 ball green in an hour or how many total get through in an 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?
13 MR. CHRISTMAN:
How many get through in an hour.
f 14 WITNESS HARTGEN:
This is an analysis of the 15 demand of the intersection against the capacity of that 16 intersection, as identified by the geometrics and the lane 17 structure there.
18 Our analysis shows that there is not enough 19 capacity to handle the left protected movement; therefore, 20 the intersection will not operate under the conditions 21 described by this analysis document which is a planning 22 document.
The intersection would break down if this amount 23 of traffic were attempting to squeeze through it.
24 BY MR. CHRISTMAN:
(Continuing) 25 Q
What do you mean " break down?"
!d
9'?%COVUV
-00000000 18785 1
suewalsh r
N 1
A (Witness Hartgen)
The left protected turn would I
(\\
2 be level service F, forced flow.
3 Q
I still don't think I've got an answer to the 4
question, though.
How many cars can get through this 5
intersection in an hour from a left turn phase?
6 A
I believe we have answered that question.
This 7
is a planning analysis.
We Compared the Applicant's, KLD's a
traffic numbers with the capacity of the intersection.
- And, 9
our conclusion was that the left protected turn was over 10 capacity.
11 Those cars could not get through.
12 Q
So, you are saying that the capacity is less 13 than 260, less than 262?
()
14 A
The capacity is 262 for the left protected turn.
15 Q
And, how about the lef t permissive turns, no 16 cars get through on the left --
17 A
We answered that already.
We indicated that 18 that movement is included as a part of other phases.
19 Q
But, how many cars get through on that phase?
20 A
We answered that also.
We said this was a 21 planning analysis and our estimate was that under the 22 scenario described here the intersection would not work.
23 JUDGE MARGULIES:
Are you saying you don't have 24 a number?
25 WITNESS HARTGEN:
In planning analyses, you are
'O V
YZ8CCYoy
-G0000 N 18786 suewalsh 1
given the demand and your j ob is to compare with the
(
2 supply.
And, so your assessment then can only stop when you 3
have those two compared.
4 And, that's what this model did.
And, in order 5
to answer his question further work would have to be done.
6 And, it is not on this assessment.
7 BY MR. CHRISTMAN:
(Continuing) 8 Q
Do you have a copy of the Highway Capacity 9
Manual, 1985 with you?
10 A
(Witness Hartgen)
I can get one.
11 MR. ZAHNLEUTER:
I can show him a copy, Mr.
12 Christman.
13 (The witness is provided the document.)
14
.BY MR. CHRISTMAN:
(Continuing) 15 0
Would you look at Chapter 9 on Urban Streets I 16 guess or Signalized Intersections, Page 9-6?
17 (The witness is complying.)
18 Doesn't that describe the methodology that went 19 into this HCM software package?
20 A
(Witness Millspaugh)
Yes.
21 Q
Doesn't that say operational analysis at the top 22 of that page right under methodology?
23 A
Yes.
24 Q
But, you are testifying that this -- using that 25 HCM software package you do not produce an operational
((0 18787 suewalsh
-1 analysis at all; is that right?
(3/
2 A
(Witness Hartgen)
To study the operation of the 3
intersection, but it's a futuristic scenario.
We are trying 4
to se whether or not a future situation can be accommodated 5
by the lane structure and the signalization at this 6
intersection.
7 Q
Well, you used actual real world background data 6
in this analysis and plugged it into the HCM software 9
package, did you not?
10 A
Well, part of that data was background accounts t
11 as adjusted by the State, and part of it was assumptions 12 about the future evacuating traffic in the event of an 13 emergency.
I believe 30 percent was assumed here.
14 So, it's a futuristic situation.
15 Q
Well, notwithstanding the fact that the HCM says 16 operational analysis when it describes its methodology, your 17 testimony is that this isn't an operational analysis at all 18 because it's futuristic?
19 A
(Witness Millspaugh)
This is using the 20 operational part of the manual.
I'm assuming we used the 21 same software that KLD did.
22 O
Well, what does flow adjusted rate mean in the 23 first column?
24 A
(Witness Hartgen)
Excuse me.
Are we off the 25 manual now?
- Mo((((
n 18788 suewalsh 1
Q For the moment, yeah.
y's
\\b 2
A Okay.
3 Q
Look at the first column of the document we have 4
been talking about, adjusted flow rate.
What does that 5
mean?
6 A
I believe I need to refer back to a previous i
7 page or two on your exhibit.
8 O
Feel free to do that.
9 (The witnesses are looking through a document.)
10 A
I'm looking at page -- I can't see it on your 11 copy.
I'm sorry.
12 (Witness Millspaugh)
It looks like 5.
13 (Witness Hartgen)
It's the page that is
.(T 14 entitled " Volume Adjustment Worksheet."
15 Q
Yes.
16 A
Are you still referring to southbound left?
17 Q
Yes.
18 A
Under southbound lef t, the number 491 is the --
19 some of the traffic volume in the assumed future scenario on 20 the 30 percent evacuation.
And, that's adjusted for a 21 number of considerations, the peak hour factor which is 22
.99.
We had a long discussion on that yesterday, the day 23 before I believe.
The adjusted lane group volume is 496.
24 Q
Doesn't the software tell you then that 491 or 2$
496 in that neighborhood get through on the left turn phase
$$[00-18789 suewalsh 1
in an hour?
Isn't that what the software is telling us?
.f 2
A No.
The software is not saying that at all.
S The software is not saying that'at all.
4 The analyst is making the adjustment for the 5
demand side, the volume side of the analysis first. 'And he 6
does that by beginning with 491 and adjusting it to 496.
7 He then continues on with the supply side of the e
capacity analysis side of the assessment, and then in the 9
last two sheets which you referred to earlier he compares to the two.
There is no assumption here ab'out 491 going 11 through anything.
12 Q
Well, there is no aEsumption but the output 13 tells you that it's in the neighborhood of -- the numbers
()
14 are in the neighborhood of 490, does it not?
15 A
I'm confused by your question.
16 Q
Let me ask you this.
What's the definition of 17 flow rate or rate of flow?
18 A
Which one is it, adjusted flow rate or flow 19 ratio?
Which item in particular?
20 Q
Try rate of flow.
21 A
I'm sorry.
I'm looking on -- what page are you 22 on, sir?
23 Q
Well, I'm looking at the next to the last page 24 again, and I want to know what flow rate is to traffic 25 engineers using the HCM?
O
l i
7210sHpy G0000007 10790 suewalsh-1 1
What does f2ow rate mean, or rate of flow?
74 b'
2 A
The flow rate is the rate at which the vehicles 3
approach this particular movement.
And, the analysis here 4
says that that flow rate is 491.
It's usually expressed as 5
vehicles per hour.
6 Q
Okay.
I'm looking at Page 1-5 of the Highway 7
Capacity Manual.
It says. rate of flow is ' the equivalent 8
hourly rate at which vehicles pass over a given point or 9
section of a lane or roadway during a given time interval 10 less than one hout, usually 15 minutes.
11 Is that what we are talking about?
12 A
All cf these numbers are in hourly adjusted 13 rates.
I believe I said that.
,M) 4 14 JUDGE MARGULIES:
For purposes of the record, g,
15 could you describe the volume that was read from a little 16 more fully?
17 MR. CHRISTMAN:
Sure.
It's Page 1-5 of a 1985 18 Highway Capacity Manual.
And, it is the definition there, 19 in the definition section.
And, the definition is of rate 20 of flow.
The definition I read was:
The equivalent hourly 21 rate at which vehicles pass over a given point or section of 22 a lane or roadway during a given time interval less than one 23 hour2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br />, usually 15 minutes.
24 JUDGE MARGULIES:
Thank you.
l 25 BY MR. CHRISTMAN:
(Continuing)
.I,'h V
a
TA300YD V
-00000000-18791
-suewalsh 1
Q Let me make sure I get this right.
Your
,s I.
2 testimony is that given the input you used to the standard 3
HCM software there will be only 229 vehicles that can turn 4
left there in an hour?
5 (The witnesses are looking at a document.).
6 A
(Witness Hartgen)
No, absolutely not.
7 Q
What is the number, the total, left turn, 8
southbound at that intersection in an hour based on this --
9 A
I believe that's the third time that I've heard 10 that question.
11 Q
Let's try it again.
12 A
Let me say my response one more time.
This is 13 an analysis of whether or not the intersection specifically I) 14 that you are-referring to, the southbound left protected 15 turn, can handle the movement that 's proj ected to move 16 towards it.
That movement is 267.
17 The analysis says that that movement cannot be 18 handled because the capacity is only 262.
19 Q
Isn't it the case that this printout --
20 A
Excuse me. j ust one second.
21 Q
Sure.
22 (The witnesses are conferring.)
23 A
I'm sorry, go ahead.
24 JUDGE SHON:
Could I make some sort of a --
25 WITNESS HARTGEN:
Yes, sir.
't
)
i 1
53Bc0VOY
-00000004 18792 j
suewalsh j
? f 1
.,4 JUDGE SHON:
Dr. Hartgen, I think the difficulty
{#\\
'~
2 that we are arriving at here is that all of us laymen, 3
myself included, have the feeling that if you count only the d
protected portion of a green ball leading arrow left turn i
5 signal, you haven't counted all the cars that get through I
6 the intersection during a light cycle, because some others 7
will, perhaps a difficult to estimate amount, get through 8
during the green ball phase.
9 Now, what you appear to have calculated here,' as 10 far as I can see -- I've been following it with my hand 11 calculator -- the 262 is the number of cars that would get 12 through on the green protected portion, that is the left 13 turn arrow portion of the signal at this signalized
,~
4 14 intersection.
And that 267 of the cars that have to get 15 through total, according to the flow that comes into the 16 thing, and it appears I'm sure to Mr. Christman and to me, 17 too, that that extra five cars just might on the average be 18 able to pop through in a blank space in the opposing 19 traffic.
20 Why is that not true?
Is that what you were 21 driving at, Mr. Christman?
22 MR. CHRISTMAN:
Yes.
23 WITNESS HARTGEN:
Anything is possible.
With 24 all such computer models, you make assumptions about the 25 input and then you are handed the output essentially by the
F M oc w Y O M 00000-'
18793 3
suewalsh i
r~
I computer and you have to interpret it.
2 The computer is saying here that given these 3
very high turn volumes, in other words 267 versus the 4
intersection capacity for this turn of 262, it looks like 5
the level of service is going to be over F.
I'm sorry, F or.
6 higher than 1.0.
It's not saying that the signal won't work 7
occasionally for those five vehicles, and it might work in 8
fact for other cycles in the hour.
9 But, on the average it's a congestion.
10 JUDGE SHON:
So that essentially you are 11 defining what you had called the breakdown of the 12 intersection or failure of the intersection as a failure to 13 accommodate, in this case, the left turn vehicles during the D)
(
14 protected left turn portion of the signal cycle; is that 15 right?
16 WITNESS HARTGEN:
The intersection has other 17 movements.
And, this particular movement is the one that is 18 critical.
And, we are saying that this movement will fail 19 under the scenario described by LILCO.
20 JUDGE SHON:
Thank you.
That's all I wanted to 21 es tablish.
22 MR. CHRISTMAN:
Thank you.
23 BY MR. CHRISTMAN:
(Continuing) 24 0
What does " movement fail" mean in the context 25 you just used it?
'O
l 18794 suewalsh 1
_e-4 1
A (Witness Hartgen)
Thht tile movement will k.)
2 operate at level service F which is forced flow.
The queue 3
will lengthen.
Vehicles will not get through in one cycle.
4 Wait times will be very long, genera 13y over a minute.
)
5 That's all.
6 7
8 9
10 11 12 13 i,,J 14 15 16 17 IB 19 20 21 22 23 24 25
!O
82800505 18795 j oewalsh f
1 Q
Okay.
D 2
A Remember now, this is -- what we are describing 3
here-is what LILCO purports to be the average set of 4
circumstances for a six hour evacuation.
5 We are saying on the average for that period 6
this movement will not,m rk.
7 Q
D>es the Eighway Capacity Manual anywhere refer 8
to movements failing or an intersection not working at level 9
of service F?
10 A
Does the Highway Capacity Manual -- excuse me, 11 do what?
12 Q
Does the Highway Capacity Manual talk in terms 13 of movement of an intersection not working or a movement 14 feiling?
15 A
The Manual discusses levels of service for 16 different environments, including signalized intersections.
17 Q
Yes.
Does it use the terms you've used for 18 level of service F which is that the movements will fail or 19 the intersections will not work or will not operate?
20 Does it say that in the Highway Capacity Manual?
21 A
I have no idea.
It's a very thick document.
22 I'm trying to describe it in the terms that I understand it.
23 Q
Oh, you are using your own paraphrasing?
24 A
Yes.
25 (Witness M113 spaugh)
The Manual does define 1]
~
82800505 18796 l
j oewalah I
1
.,a these levels of service and describes how they will operate.
/ )\\
2 Q
Well, let me read you one definition of level of 3
service F from Page 9-5 of the Highway Capacity Manual.
4 This is under a section called " Level of Service for 3
Signalized Intersections."
l 6
And, it says:
Level of service F describes 7
operations with delay in excess of 60.0 seconds per 8
vehicle.
This is considered to be unacceptable to most 9
drivers.
This condition'often occurs with over-saturation, 10 i.e.,
when arrival flow rates exceed the capacity of the 11 intersection.
It may also occur at high v/c ratios below 12 1.00 with many individual cycle failures.
Poor progression 13 and long cycle lengths may also be major contributing causes
. c) i, 14 to such delay levels.
15 That doesn' t say anything about the intersection 16 failing or the movements not going through, does it?
17 A
(Witness Hartgen)
It says cycle failures.
1B Q
Well, what do you mean by cycle failure?
19 A
I believe we answered that question, but to 1
20 reiterate it expresses a condition largely described here.
21 Queues will be long.
Vehicles will not get through on one 22 cycle.
There will be significant levels of congestion at 23 this turn.
24 As traffic engineers, we evaluate intersections 25 on the degree to which they perform the task that we are Ir1
~
l.
82800505 18797 joewalsh 1
expecting them to perform.
Our assessment is that this
'.h 2
intersection, and particularly this turn, will not perform 3
the tasks being asked of it; that is, to clear 30 percent of 4
the evacuation traffic in conjunction with the back-on 5
traffic.
6 Q
If you look at that other document for me, which 7
is Suffolk County Exhibit Number 27, tell me the average 8
hourly number of vehicles turning lef t at that intersection 9
southbound for the hours 7, 8 and 9?
10 I think you can get that from either the first 11 or the second page of that document.
12 A
I believe it's on your page 152.
13 0
152, right?
()
14 A
I believe so.
Incidentally, that's not.my 15 number; that's your number.
16 Q
Well, do you want to calculate the number 17 yourself from the --
18 A
I checked it.
It is -- 152 is the average of 19 the three numbers circled on the first page.
20 0
Right.
So, you aren't contesting that 152 is 21 the average of the three numbers for the hours 7, 8 and 9.
22 The numbers are 175, 146 and 135 which averages to I believe 23 152, correct?
24 A
They do so average, yes.
1 25 Q
Now, this intersection is along what KLD calls O
82800505 18798 joewalsh 1
1 Paths 1.C and 1.E, evacuation paths 1.C and 1.E, isn't it?
2 A
I believe so.
3 (The witness is looking through a document.)
4 Q
Did I interrupt you?
5 A
I said I believe so.
That's right.
6 0
I thought you were checking.
What is the 7
monitoring rate associated with that path, do you know?
8 If you have a copy of KLD 201.A, it's on Page 9
23.
10 (The witnesses are looking through documents.)
11 A
Page 23, did you say?
12 Q
That's what I said.
Let me see if that's right.
13 A
Is it possibly Page 77 Id Q.
It may be on Page 7, too.
What I was looking at 15 was Page 23.
If you can get the monitoring rate from Page 16 7,
that's all I want to know.
It doesn't much matter.
17 Do you see on page 23 at the left, there is 1.C s
IB
' d nci E, and the intersection H.4, southbound turning left?
19 And, you have a monitoring rate column, next to the last 20 c o2 umn.
21 The monitoring rate is 274 for that path, is it 22 not?
23 A
That's under the assumptions described in other 24 testimony I believe, the assumptions concerning the average 25 monitoring time and the number of monitors and so on.
82800505 18799 joewalsh 1
Q I'm not asking you to endorse that number.
That 2
is simply the number as reported by LILCO and KLD, is it 3
not, the monitoring rate that they used?
4 A
That's the assumption for this analysis, yes.
5 MR. CHRISTMAN:
Let me hand out another document 6
if I may.
And, I would like to ask that this be marked for 7
identification as LILCO Exhibit 29.
8 This is another of these HCM printouts.
It's 9
labeled -- I'm sorry.
It's eight pages long.
It is labeled 10 "1985 HCM:
Signalized Intersections" at the top.
Under 11 that is " Identifying Information."
The intersection is 12 identified as Old Country Road and Broadway, Route 107.
The 13 analyst is again BG.
This time, the time period analyzed is
)
14 the next one which is 10 to 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />, 10 o' clock in the 15 morning to 1 in the afternoon.
16 Now, Judge Margulies, would you mark that LILCO 17 Exhibit 29 for identification?
18 JUDGE MARGULIES:
It will be so marked.
19 (The document referred to is marked 20 as LILCO Exhibit number 29 for 21 identification.)
22 BY MR. CHRISTMAN:
(Continuing) 23 Q
If you would, once again look at the next to the 24 last page which is Page 7 and again the same approach, the 25 southbound approach at the bottom?
82800505 18800 joewalsh I
,a-1 (The witnesses are complying.)
t 2
Now, can you give me the lane group capacity 3
~from this document for the left protected?
4
~A (Witness Hartgen) 262.
5 Q
And, how about lef t permissive or permitted?
6 A
I would respond here exactly the way I responded 7
previously to the previous time period.
8 Q
Zero?
9 A
No.
I did not say zero.
10 Q
Well, repeat it for this, too, if you don't 11 mind.
12 A
I will repeat then that this is a planning 13 analysis document, and the signal analysis shows that the
.q S
l'd traffic which is assigned to the left protected, that is 15 241, is slightly below the capacity available for the left 16 protected which is 262.
17 Q
So, the v/c ratio in the last column is.918, 18 correc t?
19 A
Yes, that's right.
20 Q
Which corresponds to level of service E?
21 A
Yes, 1 believe so.
I'm sorry, D on the next 22 page.
I'm sorry, you are right, it's E.
23 Q
Yes.
24 A
It's E, yes.
25 0
Okay.
O
82800505 18801 joewalsh 1
A That describes a situation which is slightly 2
better than the one we looked at a minute or two ago, but 3
sti13 significant3y congested.
4 Q
Well, what's your best estimate of the total 5
number of people -- I'm sorry, the total number of vehicles 6
that could get through on the left turn in an hour under 7
those conditions?
8 A
Under what conditions?
9 Q
Well, the level of service E, the conditions 10 being analyzed here.
11 A
As I said earlier, it would be the capacity of 12 this left protected turn plus some additional traffic which 13 could get through on the permitted phase, and the --
i 14 Q
Right.
I'm sorry, go ahead.
15 A
-- analysis does not identify that number.
16 0
It doesn't identify that number, okay.
17 A
The analysis does say that the demand for that is number is 244.
In other words, 244 vehicles would be asking 19 for such service.
Whether they could make it through is 20 another question.
21 Q
And, that's what the adjusted flow rate means 22 then to you, is the demand?
23 A
Yes.
I believe we said that, absolutely.
24 Q
Okay.
If you would now go back to Suffolk 25 County Exhibi t 27, and can you tell me based on that, those l
b
82800505 18802 joewalsh I
1 axle counts if you will, the average number of vehicles
.a Ih 2
counted for lhft-turners for the hours 10, 11 and 12?
3 A
Well, your estimate is 141 I believe if I read 4
your document correctly.
But, I have not verified that 5
number.
6
-Q Well, it's not an estimate.
Isn't it just an 7
average of the counts?
8 A
If you represent to me that it is, I will accept 9
that.
10 0
Well, why don't you verify it for me so that the 11 record will be clear?
We add up 115, 120 and 187, don't we, 12 and divide by three?
13 A
Rounded off, it is 141.
b 4
14 O
Okay.
In your previous answer, did I understand t
15 the -- you' told me what you take to be the demand here, but 16 when I asked you what your best estimate was of the number 17 of people who could -- the number of cars that could get 18 through in an hour on that left turn phase during these 19 three hours, what was your answer, your best estimate, 20 tota:?
21 A
I'm sorry.
There were several questions in that 22 I think.
I'm not sure.
23 (A fire dri31 is being announced.)
24 JJDGE MARGULIES:
Do the parties want to take a 25 recess at this point?
!c i
1
82800505 l'8803 joewalsh 1
t' MR. CHRISTMAN:
Maybe we ought to until things f-2 settle down.
3 JUDGE MARGULIES:
Let's take our 15 minute 4
recess at this point.
5 (Whereupon, a recess is taken at 10:10 a.m.,
to 6
reconvene at 10:28 a.m.,
this same day.)
7 JUDGE MARGULIES:
Back on the record.
8 MR. CHRISTMAN:
Let's see, I had a question on 9
the floor when the bells went off.
Let me try it again.
10 BY MR. CHRISIMAE:
(Continuing) 11 Q
We are looking at LILCO Exhibit 29 for 12 identification, and in the next to the last page there are 13 some numbers for the southbound approach.
14 And, I think my question was, what is your best 15 estimate, Dr. Hartgen, of the number of vehicles per hour 16 for that whole lef t turn movement during this period to 17 which this analysis applies?
18 A
(Witness Hartgen)
Just to be very sure I have 19 the right document in front of me, sir --
20 Q
Sure.
It's your HCM analysis for the hours of 21 10 to 1, 10 a.m.
to 1 p.m.
And it's, of course, Old Country 22 Road and Broadway.
23 A
Okay.
24
,Q The next to the last page.
And, the question i
25 was not just for the protected but for the whole movement, l
[/h
\\.
's iB28005'05 18804 i
$oes41sh 1
I what is the flow of cars for that whole movement per hour I
2 through that intersection?
3 A
Are we still 3ooking at southbound left?-
4 0
Yes.
5 1"9n-Let me see if I can explain this again, describe 1
6 tije' situation a little bit here.
There is a left' protected J
-s 7
phase in the signal.
And, as the Judge asked earlier and as 8
I think we clarified, the demand for service on that phase
{
9 at this time period is 241.
That's what the number, 10 adjusted flow rato, means.
11 There is also demand for service at the 12 intersection for the ae movement on the permitted phase, 13 and that is in thr Aumn also, and it's the number 244.
A 14 That traffic has to compete.with opposing traffic in making 15 the left turn.
And, the opposing traffic with which it must 16 compete is the northbound through traffic which is in the I. " b 17 line above it.
I believe that number is 612.
l 18 So, the circumstances that we have here, to 19 clarify for the Judge, is that on the protected phase this 20 planning analysis is saying that 241 sahicles are asking for 21 service and the capacity to handle them is 262 v/c of.918.
22 On the permitted phase, 244 vehicles are asking 23 for service but they must compete with road space with that
/4 612 which is on the opposite traffic.
Now, as I looked at 25 this i believe it was a 39 secono permitted phase on the I !C )
1 u
1
'82800505-18805 joewalsh-1 southbound lef t turn, so wha,t the analysis.is saying is that y
()-
' 2.
in 39 seconds, over an hour or whatever that turns out to be 3
or whatever the proportion of the hour is, 30 percent of the 4
hour, in roughly 20 minutes 612 vehicles and 244 vehicles 5
must intersect.
6 And, the analysis on this sheet does not conduct 7
that assessment.
It does not tell you whether or not that 8
intersection will or will not operate.
I cannot answer the 9
specific question on how many vehicles can get through in 10 the hour.
The. computer methodology does not do that.
11 And, incidentally I might point out that this is 12 the same methodology as was used by LILCO and their analysis 13 of it did not refer to this movement either, as I recall.
14 Q
Well, if you don't know how many cars get 15 through how do you calculate a v/c ratio?
16 A
That v/c is calculated for -- as I say, the 17 planning assessment which is the projection of how much 18 traffic is demanding service against how much traffic is --
19 against how much supply is there.
20 Q
V/c is flow rate over capacity, isn't it?
21 A
That's what I said, yes.
Demand over supply.
22 Q
But, you don't know -- isn't it service over 23 flow rates?
Service flow rate over capacity of the lane 24 group?
25 A
Those are the terms in the Highway Capacity (O
m
87800505 18806 l
joewalsh 1-1 Manual.
In economics jargon, it's demand over supply.
y-(/
2 That's how we study it.
l 3
Q If you don't know the number of cars going 4
through there, you can still calculate a v/c?
5 A
Yes.
In fact, that's precisely what planning 6
assessment is all about.
Your job is to figure out whether 7
the supply of road space, that is the capacity at that 8
intersection, can handle the demand for it.
That's 9
precisely what you are trying to assess.
10 Q
Dr. Hartgen, have you used this HCM software 11 before this particular analysis?
12 A
The software has only been recently released.
13 There were earlier versions -- we call them beta versions --
14 that were released for testing purposes and for debugging 15 pu rpos es.
And, our agency had those versions as well as 16 this one.
i 17 Q
Did you ever use any of these versions to do an I
18 analysis yourself?
19 A
I personally have not, but my staff has and I've 70 Jooked at those assessments.
21 Q
Where did you get -- how did you get the beta 22 versions?
23 A
As part of the testing, as I recall, the federal 24 government released a number of interim versions and asked 25 the DOTS and other interested individuals, consultants and Ir 4
I
--___-________N
t 82800505 18807 joewalsh 1
other public sectors as well as university professors to h'
2 work with the computer program and to identify problems in 3
it, if there were such problems, and to report back, of 4
course.
5 Q
Did you-all find any problems, anyone in your 6
agency with the beta versions?
7 A
I really don't recall.
We were not one of the 8
primary evaluators.
We received a copy and worked with it.
9 Others received a copy.
10 I don' t believe that anyone from New York was 11 represented on the Committee that sponsored the preparation 12 of the Manual.
13 But, I will say it was in beta stage for a long I) 14 time.
It was originally planned for release in as I recall 15 late 1985 and then late 1986 and ultimately was not released 16 until I believe March of
'87.
17 0
Who developed the software?
18 A
As I recall, different modules were developed by consul tants and university professors under contract to the iv 20 National Academy of Sciences.
21 Q
Now, this time period that we are talking about 22 in the document we have been discussing which is the 10 to 1 23 p.m.,
10 a.m.
to 1 p.m.,
time period the monitoring rate 24 associated with Paths 1.C and 1.E as provided by LILCO now 25 is still 274 vehicles per hour, is it not?
O
1 82800505 18808 joewalsh I
l 1
A-Well, as I read Table 3-7 and juxtaposing that 2
with Table 3-1, I believe it is on Page 7, the monitoring 3
rate at the Area A station is 504, not 274.
And, there is 4
no distinction in that station between those individuals 5
arriving from paths to the west and paths to the east, as I 6
recall.
7 8
9 10 11 12 13 r -,.
14 15 16 17 18 19 20 21 22 23 24 25
!O 1
I 82800606 18809 I
marysimons 1
O But if you look at page 23, that table still
(- )
4 L
2 gives for that path, 1-C and 1-E, intersection H-4 is 274 j
l 3
vehicles per hour monitoring rate, does it not?
i i
4 A
Well, that's LILCO's assumption, as I.said.
5 There are 504 vehicles worth of capacity at that location, 6
as I recall.
7 Q
Let me get a few more facts on the record, if I 8
may, about this particular intersection.
The same 9
intersection, but thinking about the northbound approach 10 now.
11 Look at LILCO Exhibit 28 again, if you don't 12 mind.
That's the printout HCM Signalized Intersections, is hours 7 through 10 again.
And on the next to the last page, r~
's_)%
14 which is page 7 again,.look at the northbound approach this 15
- time, "NB".
16 A
Sir, I want to be very clear I've got the rignc 17 one here.
These all look very, very similar as you know.
18 0
Yes.
19 A
This is the one in which the numbers on the 20 northbound approach read downward, the first column 153 89, 21 720 and 286.
22 Q
If you're looking at the Icft-hand column, I'm 23 reading 17171 and 685.
So we nay be looking at the wrong 24 document.
25 A
Okay, thank you.
O
82800606 18810
{
marysimons I
I Q
I'm talking abou t the adjusted flow rate a
2 northbound reading down 171 and so forth.
3 A
I'm very sorry.
I don't seem to have that page 4
right in front of me.
These are so similar.
5 0
Why don't you see if you can find the document, 6
the front page that has a handwritten "4"
I believe on the 7
front.
You Can kind of spot that, and then it says 7 to 10 8
underneath that.
9 A
Okay.
Now I've got it.
10 0
Now go to the next to the last page.
11 A
Okay, 17171 and 6847 12 Q
That's the one.
13 Okay, talking about northbound, what is the lane y_,
s_)'
14 group capacity for right turns?
15 A
According to this analysis it's 442.
16 MR. CHRISTMAN:
Now let me hand out another 17 document, if I may, that I would like to have marked LILCO 18 Exhibit 30, and let me describe it now.
19 It's another one of these ATI sets of axle 20 counts, but this time we are talking about northbound 21 Broadway at Old Country Road.
22 This document, which I would like to ask be 23 marked LILCO Exhibit 30 for identification, has at the top 24 "15 Minute 2 Channel Axle County Correction Factor 1.00."
25 It indicates that the location is northbound Broadway at Old l,4
'U)
82800606 18811 marysimons 1
Country Road and has a date of Thursday, July 17, 1986.
O 2
Attached to it is a handwritten summary of some of the data 3
on the first page.
This corresponds to the Suffolk, County 4
Exhibit 27, except that Suffolk County Exhibit 27 was 5
southbound and this one is northbound.
6 JUDGE MARGULIES:
The document will be marked 7
LILCO's Exhibit No. 30 for identification.
8 (The document referred to was 9
marked LILCO Exhibit No. 30 for 10 identification.)
11 JUDGE MARGULIES:
It might be helpful if the 12 witnesses would also mark their copy with the No. 30 for 13 identification.
14 WITNESS HARTGEN:
Yes, sir.
15 BY MR. CHRISTMAN:
16 Q
These are once again, I take it, the axle counts 17 for that intersection?
18 A
(Witness Hartgen)
They represent to me as such.
19 Q
Can you tell me the nunter of right turns there 20 are for the hours 7, 8 and 9?
21 A
According to the second page, the average l
22 calculated is 114.
I have not verified that, but it looks l
23 hbout right.
24 Q
Well, let's go ahead and verify it.
If we add 25 up 91, 135 and 115 and divide by 3 I think we can 114; is
)
82800606 18812 marysimons l
1
.ex 1
that right?
(-)
2 A
Rounding off, yes.
3 Q
Now let me ask you to go back one more time to 4
what we called LILCO Exhibit for Identification 28, and I'll 5
describe it for you.
That's the one that has the 6
handwritten "4"
on the front and it refers to the hours of 7 7
through 10, 8
Look at the next to the last page which is page 9
7 again, and lock at northbound, and we said that that was a 10 right turn lane capacity of 442.
Now if the capacity is 442 11 and the average background 114 vehicles per hour, if you 12 subtract 114 from 442 you get 328 vehicles per hour, and I 13 take it those would be available for other people other than
,5
'fCl 14 the background actually counted, for example, evacuees; is
~
15 that right?
16 A
Well, actually I think the number is 320.
You 17 were using adjusted flow rates, and the previous number, the 18 114 was the unadjusted lackground traffic.
19 Q
So instead of my number 328 you would use what 20 number?
21 A
114 is the background traffic you are assuming l
22 320 the total.
23 Q
It's not really an assumption, is it?
Those are 24 actual measurements?
25 A
The 320 contains an assumption about the T. q.)
r_-_--
'82800606 18813 marysimons 1
evacuation flow.
I believe it's 30 percent.
2 Q
Well, you were talking about my assumption of 3
114, and 114 was an average of actual data, was it not?
4 A
114 was an average of movement at this time.
5 Q
Okay.
Now tell me if you subtract that
)
1 6
. background from the actual measurements from.the capacity as 7
you see it, what number do you get?
I said 328, and you 8
said it was slightly different.
What is your number?
I 9
A 114 from 442, is that your request?
10 0
I want you to subtract the background which is 11 114 from the capacity that you think should be used.
12 A
It's 328.
13 0
328?
.e la A
Yes.
15 0
Now if you will look at page 6 of KLD TR-201A 16 you'll see that this path, this northbound route and the 17 right turn onto Old Country Road is listed as path 1G; is 18 that correct?
19 A
Yes, I believe so.
20 Q
And again on page 23 of 201A what is the 21 associated monitoring rate for path 1G at that 22 intersection?
Well, it's not at that intersection.
It's 23 the monitoring rate associated with that path and that 24 intersection.
Do you see that?
25 A
Well, as I said earlier, you assumed that it was D
82800606 18814 i
marysimons
)
I
.e4 1
230, but as I understood the monitoring environment, there
( )
I 2
was no distinction between the traffic entering from 3
different paths.
They all mixed together in the 4
entranceway, and so the total monitoring capacity of that 5
area, area "A"
I believe is 504, and that is shown on Table 6
3.1 I believe it is on your page 7 of 201A.
Yes.
7 O
Mr. Millspaugh, when you did some of the 8
analyses for your rebuttal testimony, you did take some of 9
these axle counts or the ATI data and used it in the 10 standard HCM software, did you not?
11 A
Yes.
12 Q
Thank you.
13 Let me ask you about another intersection.
This dw/
14 is Wi13is Avenue and that LIE service road which is 15 designated Intersection R-2 in the KLD work.
I belicve you, j
16 Mr. Millspaugh, you did analyze that intersection yourself 17 for the testimony, didn't you?
18 A
(Witness Mi13spaugh)
This was done by my 19 assistants under my supervision.
20 Q
Mr. B.
G.
again?
21 A
Well, it could have been either Charles Reidel 22 who is my direct assistant or Mr. Bruce Guynup.
1,ooking at 23 a particular analysis would have their initials on it.
2d Q
Okay.
I'll give you a particular analysis if I 25 may.
j 1
l
82800606 18815 marysimons 1
Let me hand out four documents and I would like
(
2 them'to be marked for identification as LILCO Exhibits 31, 3
32, 33 and-34 and,I'll describe them for the record.
4 The first which should be marked LILCO Exhibit 5
31 for identification ---
6 JUDGE MARGULIES:
Before you go ahead, it would 7
be easier if they are distributed first so we can look at 8
them and handle it in that manner.
9 MR. CHRISTMAN:
That's a good idea.
10 (Documents were distributed to the parties and 11 the Board.)
12 JUDGE MARGULIES:
Let's mark and identify each 13 one individually.
,rx
\\_)
14 MR. CHRISTMAN:
That would be fine.
15 The first document which I would like to have 16 designated LILCO Exhibit 31 for identification is a two-page 17 document.
At the top it says "ATI, American Traffic 18 Information, Automatic Traffic Recorder Count Details."
It 19 has a date of 7/17/86 and, as with the others, there is 1
20 attached a handwritten summary of some of the data on the 21 first page.
1 22 JUDGE MARGULIES:
That will be marked as LILCO 23 Exhibit No. 31 for identification.
24 25 JC3)
1 l
82800606 18816 I
marysimons.
q I
-A(
2 (The document referred to was 3
marked LILCO Exhibit No.-31 for i
4 identification.)
5 MR. CHRISTMAN:
The remaining three documents 6
are once again all computer printouts from the HCM-software, 7
and in particular computer printouts coming from the State's 8
analysis.
9 The first which should be designated as LILCO 10 Exhibit 32 for identification says at the top "1985 HCM 11 Signalized Intersections."
It's eight pages long and you'll 12 see that it's for the intersection EB, that's eastbound, LIE 13 service road and Willis Avenue.
The analyst's name is BG p
(
14 and the time period analyzed is 7 through 10 in the morning, 15 and that would be LILCO Exhibit 32.
f6 JUDGE MARGULIES:
It will be so marked for 17 identification.
18 (The document referred to was 19 marked LILCO Exhibit No. 32 for 20 identification.)
21 MR. CHRISTMAN:
LILCO Exhibit 33 is another 22 printout again of eight pages in length, the same 23 intersection and the same analyst.
The time period though 24 is 10 o' clock to 1300.
25 JUDGE MARGULIES:
That will be marked as LILCO's
82800606 18817 marysimons 1
Exhibit 33 for identification.
O 2
(The document referred to was 3
marked LILCO Exhibit No. 33 for 4
identification.)
5 MR. CHRISTMAN:
And, finally, LILCO Exhibit 34 6
for identification should be another computer printout, 7
01985 HCM Signalized Intersections," the same intersection 8
and the same analyst.
The time, however, is now 1300 9
through 1600.
10 JUDGE MARGULIES:
It will be so marked for 11 identification.
12 (The document referred to was l
13 marked LILCO Exhibit No. 34 for I) 14 identification.)
15 BY MR. CHRISTMAN:
16 0
Look at the first of those documents which is 17 th'e vehicle counts by ATI.
I want to kind of go through the 18 same exercise as we did earlier on the southbound Old County 19 Road and Route 107 and the northbound and get the average 20 vehicle counts for three 3-hour periods.
l 21 First, I wonder if you can tell me the average 22 vehicles per hour for 7 to 10 from this document?
You can 23 look at either the second page or the first page, either 24 one.
25 A
(Witness Hartgen)
You're referring to the left O
i 82800606 18818 marysimons 1
' movement?
2
.Q Yes, I am.
Well, to shorten it, if I may, if 3
you go to the handwritten summary on the second page you d
find that the left movement for 7 to 10 a.m. was 271 5
vehicles per hour, 10 to 1 p.m. was 246 and 1 to 4 p.m. was 6
207.
Does that look right?
Can you verify that for me?
7 (pause while the witnesses review the document 8
referred to and confer.)
9 A
They look okay.
10 Q
Now if you wouldn't mind going to the HCM 11 printout which I have called LII.CO Exhibit 32, but what it 12 is is the 7 to 10 a.m. analysis for the EB LIE service road 13 and Willis Avenue.
Again, this is part of the State's 14 application of the HCM software.
15 Then going to the ne:tt to the last page, which 16 is labeled page 7, I again want to know the lane group 17 capacity for lef t turns.
I'm godng to tell you that I think 18 that capacity for the entire left turn movement should be 19 290 plus about 85 or 375, but I think you are going to tell 20 me that is not your opinion; is tnat right?
21 A
(Witness Millspaugh)
Would you mind repeating 22 that once again?
23 Q
Well, let me just ask you what the lane group 24 capacity for the entire left-turn movement southbound is for 25 that time period?
!d
82800606 18819
- .marysimons
-1 A
(Witness ' Hartgen)
This is a circumstance that 1
i i
2 parallels the discussion we just had.
It's a planning 3
analysis and the demand for the service on these two left-4 turn portions, and one is protected and one is permitted, 5
the demands are shown there of 149 and 508.
The road space 6
available for the protected turn is only 290, and the 7
analysis says that almost twice as rany cars would demand 8
left. turn at that time than could be accommodated by that 9
left protected turn.
10 il 12 13 O
i4 15 16 17 18 19 20 21 22 23 24 25
82800707 18820 suewalsh I
_,-t 1
Q Okay.
So, you are saying that only 290 can make J}
2 the left turn and not 37 5 as I suggested, right?
3 A
(Witness Hartgen)
No.
I said 290 could make d
the left turn on the protected phase.
5 Q
And, you don't know how many could make it on 6
the --
7 A
Well, that deals with the same subject that we 8
also discussed with reference to the other intersection.
To 9
make that assessment one would have to look at the conflicts 10 between the traffic on the permitted phase, which is 149, 11 and the approaching traffic which is the northbound through 12 of 1,250.
13 And, the computer analysis does not make that 14 assessment.
15 0
Okay.
Doesn't the HCM software -- isn't cne of 16 its purposes to do that for you, the flow rate for the 17 movement?
18 Won't it do that for you?
19 A
The flow rate for the movement?
20 Q
Yeah.
21 A
The software is a tool.
It's intended to be 22 used by the analysts intelligently in figuring out what's 23 going on with an intersection.
It's a general piece of 24 software.
It's used by analysts all over the country.
25 Obviously, its developers did not anticipate its O
82800707 18821 suewalsh 1
use at this intersection or specific applications here.
It
~'
2 is like any such tool, it helps us understand what's going 2
on.
4 In that sense, it is intended to be used and it 5
is intended to help you.
But, it can't give you all answers 6
to all questions.
7 Q
If you would go to the next one of those 8
printouts which I call LILCO Exhibit 33 and go to the next 9
to the last page on that, and again you would give me a 10 similar answer to the questions I've asked about these other 11 intersections.
12 I'm now interested in the left turn on the 13 southbound approach, and you are saying the left protected
)
14 lane group capacity is 493.
And, your answer if I asked 15 ibout the entire lane group capacity for the entire left 16 turn movement, it would be the same answer as beforer is 17 that right?
18 A
Yes.
Yes.
l 19 O
And, if you would go to LILCO Exhibit 34 for 20 identification, going to the next to the last page which 21 would be Page 7, the same turn, southbound left turn, I see 22 that the left protected is a lane group capacity of 455.
23 If I asked the entire capacity for the left --
24 the entire left turn movement, the same answer as before, 25 right?
O
82800707 l'8822
.suewalsh I
.f-1 A
Yes.
s 2
Q Thank you.
This particular turn is on what KLD 3
calls Path 3. A, is it not?
In KLD 201.A, Page 6.
4 A.
I believe so.
Let me just open up this and see.
5 (The witness is looking at a document.)
6 Yes, that's right.
7 0
If we checked the associated monifpring rate as 8
LILCO and KLD have it on Page 21 of that 201.A report, we 9
would find a monitoring rate of 360 I believe, that's 360 10 vehicles per hour; is that right?
11 (The witness is looking at a document.)
12 A
On 24?
Page 247 13 Q
Page 21 on KLD 201.A.
And, I see that as giving 14 us a 360 vehicles per hour monitoring rate.
15 A
Well, once again that's the LILCO assumption 16 about the monitoring capacity of the site as they have 17 described it, the monitoring rate that they assume.
I 1B believe it's 100 seconds and number of monitors and so on.
19 MR. CHRISTMAN:
Let me hand out one more of your 20 computer printouts if I may, and I would like to ask that 21 this be marked LILCO Exhibit 35 for identification, but I 22 will wait until it gets passed out.
23 (The document is distributed.)
24 Judge Margulies, I am describing a document 25 eight pages in length, another in the series of 1985 HCM 1
1
82800707 18823 suewalsh 1
Signalized Intersection Analyses.
This time, however, the
~
2 intersection is Sunrise Highway and Newbridge Road.
The 3
analyst is once again the State's analyst, BG.
The time 4
period is 7 to 10 a.m.
5 JUDGE MARGULIES:
That will be marked LILCO's 6
Exhibit Number 35 for identification.
7 (The document referred to is marked 8
as LILCO Exhibit Number 35 for 9
identification.)
10 BY MR. CHRISTMAN:
(Continuing) 11 Q
Now, if you don't mind, let 's go to Page 3 of 12 this rather than Page 7.
13 (The witnesses are complying.)
v"T
\\/
14 Instead of being numbers of v's and c's and so 15 forth, this is something called signal settings - design 16 analysis.
Have you got that, Page 3, the third page in?
17 A
Yes, I think we are all set here.
18 0
We are all looking at the page that's headed 19
" Signal Settings - Design Analysis."
Look at the east / west 20 phasing, if you will.
It looks to me like -- and those 21 little x's there describe how the signals work, I take it.
22 Phase 1 shows that you had a protected left turn 23 both eastbound and westbound, correct?
24 (The witnesses are looking at a document.)
25 A
(Witness Millspaugh)
Could you say that once
82800707 18824 suewalsh I
I again?
c
'~'
2 Q
Sure.
I'm just looking at east / west phasing now 3
at the top, not the bottom.
4 A
Okay.
5 0
And, I'm trying to -- I want you to describe 6
what happens here.
I take it this describes how the signal 7
controller works, and first you have a Phase 1 where you 8
have a protected left turn phase going both eastbound and 9
westbound; is that right?
10 A
Yes.
As I recall, my assistant made me aware 11 that the phasing for this intersection seemed a little 12 strange, so we decided we would analyze it the same way as 13 LILCO did in the phasing part of it.
Lij 14 0
Now, you have Phase 2 there which -- after Phase 15 1 is over you get Phase 2 and that allows left, through and 16 right turns?
17 A
Yes, at the same time.
IB Q
Now, if you turn to the next page you get 19
" Effective Greens - Design Analysis" again.
20 A
Yes.
21 Q
Now, for tne eastbound traffic the protected 22 left turn, effective green time is 13 seconds; is that 23 right?
{
24 A
Again, that's the effective green.
i 25 O
That's what I said, effective green.'s 13
)
?'\\
a m_ _ _
82800707 18825
.'suewalsh i
1 seconds, isn't it?
o 2
A But it's into the actual green, is what I'm 3
pointing out.
4 0
I wi13 let you explain that in a minute.
5 Effective green is 13 seconds.
6 A
Yes.
7 O
And, right below that the westbound ---
8 (A fire drill is announced at this time.)
9 JUDGE MARGULIES:
That means us.
We will recess 10 for the fire drill and reassemble at the time the drill is 11 over.
12 (Whereupon, a recess is taken at 11:08 a.m.,
to 13 reconvene at 11:25 a.m.,
this same day.)
()
14 JUDGE MARGULIES:
Back on the' record.
15 BY MR. CHRISTMAN:
(Continuing) 16 0
I was asking you about a document which has been 17 designated LILCO Exhibit 35 for identification.
We were 18 looking at Page 3 I think, sorry.
Page 4.
19 And, you told me that the effective green time 20 for the protected left turn was 13 seconds.
And, I think I 21 was abou t to ask --
I 22 A
(Witness Millspaugh)
Wait.
What page are'you 23 on?
24 Q
I think it's the fourth page.
It's the same cne 25 we were on before.
First, we' looked at the picture with the LO l
{
82800707 18826 suewalah I
1 X's.
The title is " Effective Greens - Design Analysis."
~O 2
A Okay.
3 Q
You had told me that the left turn protected 4
eastbound was -- the ef f ective green time was 13 seconds I 5
believe.
And, right below that for the westbound movement 6
the protected left turn is 21 seconds long.
7 That seems anomalous.
Can you explain that?
8 A
I would ha're to refer to the timing sheets.
9 (The witness is looking at documents.)
10 0
You don't have enough information in this 11 exhibit to answer that?
12 A
No.
I would have to refer to the timing sheets.
13 0
okay.
Well, let's pass that by.
Maybe we can
_i i
!kf 14 come back to it a little bit later.
[
15 If you look at the permitted left turn 16 eas tb ound, you find that the effective green time is 64 17 seconds and for westbound the permitted lef t turn is 72 18 seconds.
Can you explain that?
19 A
Well, you would have to look at the opposing or 20 the -- we are still talking abou t the left turns, right?
21 O
Yeah.
4 22 A
To get the -- looking at 72, you would have to l
23 look at what the opposing traf fic is doing, the opposing 24 through traffic.
25 0
It looks like from the drawing on the previous
82800707 18827 suewalsh 1
page that they should be the same times, but that's.not true 2
I take it?-
3 It kind of looks like the protected left turn eastbound and westbound shou' d be the same protected green J
4 5
time.
6 A
You are trying to say that the Phase 1 and the-7 Phase 2 time out together, and I don't think that's true.
8 Q
No.
I was just looking at Phase 1.
It looks to 9
me like that -- that's a protected-left turn.
It looks to 10 me like the protected left turn effective green time ought 11 to be the same for both of those movements, shouldn't they?
12 Should the eastbound protected left and the 13 westbound protected lef t be the same times?
()
14 A
I don't agree with that.
15 Q
Why not?
16 A
Because the phases can time out separately, one 17 before the other, depending on the time setting in the 18 controller.
19 Q
I see.
So, when the two X's line up on the 20 previous page, that is Page 3, that doesn't mean that those 21 time --
22 A
That does not mean that they time out together, 23 Do.
24 JUDGE SHON:
It just means that there is such a 25 phase; isn't that what it means?
82800707 18828 suewalsh
-I I
WITNESS MILLSPAUGH:
Yes, that's all'it means.
- .s.
/ }~
2 JUDGE SHON:
The X just means yes, it has that
~'
3 connotation.
4 WITNESS MILLSPAUGH:
Yes, it occurs during that 5
time period.
6 JUDGE SHON:
But it doesn't say anything about 7
thu time.
B WITNESS MILLSPAUGH:
No, sir.
9 BY MR. CHRISTMAN:
(Continuing) 10 0
Can you illustrate how this particular cet of 11 signals works in practice if I give you a pad of paper up i
12 there?
Could you describe or explain how it works with a 13 drawing?
14 A
(Witness M111spaugh)
I can describe how it 15 ought to work, yes.
16 0
Would you do that?
I 17 A
When I get something to refer to.
18 (The witness is looking at a document.)
19 Now, I have to show something that will be 20 comparable -- I have to show you something that will be 21 comparable with the way we analyzed it, because we are not i
I 22 sure -- this is not the normal way this controller would i
l 23 work.
And, we both -- LILCO and the State, because there i
24 was some missing information in there, we analyzed it the i
25 same way.
!d
82800707 18829 suewalsh 1
(The witness is at the blackboard.)
O 2
I'm not going to make any attempt to show how 3
many lanes here I think, just the movements.
4 So, the way this was analyzed in the capacity 5
analysis was basically three phases, actually four phases.
6 And, I will point out what they are.
You have B-1, B,
sub-7 1; and B, sub-2, this one.
Now, in the timing plan they a
have a set timing on the controller, and that's basically 9
why they don't time out together.
One can time out sooner 10 than the other.
11 Again, this is not the typical operation for 12 this controller.
And, then we have two phases, one in the 13 -
westbound direction and one in the eastbound direction which
()
14 includes the eastbound through and the eastbound lef ts and
'S rights, and then in a reverse direction the westbound 16 through and right and left.
17 These left turns I've shown here is that IB permissive we have been talking about all morning.
- And, 19 then the side road phasing for Newbridge Road is only one 20 phase.
21 But, again the question is why are these set for 22 different effective greens and the reason for that, if you 23 go to the signal time sheet for that particular time of the 24 day and whatever timing plan -- I'm not sure if we are 25 dealing with -- this particular time, I think it's 7 to 10, O
1
82800707 18830 cuewalsh I
_J^
1 and it would probably be timing plan Number 1.
U 2
O How did you get the information about the number 3
of phaces and the information you have illustrated there?
d A
It was included in the packe.ge along with the 5
signal timing.
We had received a whole package of signal 6
timing,' including a number of other intersections on the 7
State system.
8 Q
You have received them from where?
9 A
Well, as I' understand we received it 10 approximately about the time that LILCO received theirs from 11 our region office.
12 O
Oh, you received the same timing data that LILCO l
13 received from the regional office?
l 1
14 A
Yes.
15 0
Okay.
But, you said there were some items 16 missing from that package.
Why is that?
17 A
Well, the problem -- would you repeat that 1B question again?
19 0
I think you said a few moments ago that there 20 were some gaps or something missing from that package of 21 data, and I want to --
22 A
The nomenclature was just -- a couple of the 23 phases were opposite from the usual to be expected for this l
24 type of a controller.
So, then when we got LILCO's analysis l
25 we decided we wou3d go along with whatever phasing they had id
I 82800707 18831 suewalsh
/~3..
1 in that respect.
l l
~/
2 Q
Okay.
3 JUDGE SHON:
Mr. Christman, could I ask one 4
question before Mr. Mi13spaugh gets away from there?
5 MR. CHRISTMAN:
Please.
Sure.
6 JUDGE SHON:
Sir, it_has been my own j
i 7
observation, again as a layman, that there are traffic 8
signals wherein various phases are controlled not by a 9
setting but by how much traffic is waiting at some sort of 10 traffic defector.
How does this get allowed for in the 11 program?
12 It may not be a lef t turn phase if there are no j
=
13 cars there.
i
()
14 WITNESS MILLSPAUGH:
I guess sinply to say the 15 signal is set at a cycle lane.
Maybe you've heard mention
{
l 16 of this word " cycle lane."
And, I don't know what it is for 17 here but it 's probably 120 seconds that the signal goes 18 around and serves all of the approaches to the intersection I
I I
19 in 120 seconds.
And, that's repeated every 120 seconds, or j
20 if it's an actuated signal it doesn't run through these 21 maximum settings on a controller.
It could be something i
I 22 less than 120, but it's constantly moving.
23 And, this 120 seconds is a maximum time.
- Now, j
74 the timing could be lower than that.
25 Now, most of our intersections have detectors in l
l i
82800707 18832 suewalsh 1
l the pavement that detect the vehicles as they pass over or
-,-(
b' 2
they are present just sitting there in the lane.
For 3
instance,=in.m Jeft turn lane we would use a long loop which 4
is abou t 50 to 7 0 f eet in length and it -- not to get into
- 5 the mechanics of it, but it's called an inductance 3oop and 6
it registers if the Car is there or not, and the signal is 7
timed in accordance with that.
8 JUDGE SHON:
Well, that's what I meant.
I 9
understood and have seen these things, inductance loops and 10 such, sometimes bumpers and things on that order, switches, 11 and I wondered how your calculation allows for this 12 variability when it seems as if the input data to this 13 particular bit of sof tware ha.s definite lengths of time in
'4 it, and it doesn't say that they vary.
15 How does your calculation allow for the fact 16
'that in the real world these things could vary?
17 WITNESS MILLSPAUGH:
Well, as we scid, we are in 3
a p3anning thing here, so we look at the -- we don' t just go N
'9 to the computer and push a button, put the input in and push 70 a button.
We go through it and we may ' spend hours on a 21 trial and error basis going from the beginning to end 22 balancing the green times to serve all the approaches in the 23 best manner we can and then backing off from that.
i 2s 25 I
9
-82800808 18833
-joewalsh 1
JUDGE SHON:
All right.
a s
~
2 WITNESS MILLSPAUGH:
I don't know if I'm 3
answering your question, but the settings I'm talking about 4
are the maximum time for that particular phase.
And, that --
5 it will allow the traffic to move in that particular phase 6
until that -- up to that limit, that time.
7 JUDGE SHON:
I think that's the answer I was 8
looking for.
9 WITNESS MILLSPAUGH:
Okay.
10 JUDGE SHON:
The settings you use are all maxima 11 for the particular phase --
12 WITNESS MILLSPAUGH:
That's correct.
13 JUDGE SHON:
-- and they are not adjusted for I
14 presence or absence of traffic in your computer model?
15 WITNESS MILLSPAUGH:
That is correct.
They are 16 maximum green times set on the controller out there at the 17 intersection.
18 JUDGE SHON:
Thank you.
19 BY MR. CHRISTMAN:
(Continuing) 20 Q
I'm not sure I understood one thing you said, 21 Mr. Millspaugh.
How did -- you said you balanced the green 22 times.
How did.you do that?
23 That's what you said first.
And, then --
24 A
(Witness Millspaugh)
I'm talking about the 25 total analysis, not any particular individual moves.
/G V
_____.___.____________J
J l
82800808 18834
)
joewalsh 1
1 Q
Okay.
So, for a particular intersection you 2
wouldn't run the software iteratively to take account for 3
actuated controllers?
d A
Oh, our analysis does recognize the actuated 5
controllers, yes.
6 Q
How?
7 (The witnesses are conferring.
8 A
Wou3d you repeat that question, please?
9 Q
Sure, I will try.
The last question -- you said 10 you balanced the green times, and you said that you used 11 maximum green times.
And, I'm having trouble understanding 12 what exactly you do.
13 So, the question was how do you go about 14 balancing the green times?
What do you do in your analysis 15 to balance the green times?
16 What is the criteria or the criterion that you l
17 use to balance the green times?
I 18 A
I guess what I'm trying to say is that we look 19 at this, we go through this and we see the critical moves.
p l
20 For instance, a left-turner against the opposing through 21 traffic.
We have been talking a lot about that particular 22 move.
23 And, these are the so-called critical moves.
24 And, then we look -- we go through the analysis and we see, 25 well, it came out level E or F, real bad for a particular
82800808 18835 joewalsh
. i.
I move.
So, we look at all the phases and try to, if you 2
wi13, steal some time from some of the other phases.
That's 3
what I mean by reapportioning the time.
4 But, there is a limit, a maximum setting on the 5
controller for each of these phases which we cannot exceed.
6 JUDGE KLINE:
Could we clarify something at this 7
point?
When you started this discussion, you started to 8
draw a distinction between the actual green time and 9
effective green time.
And, I'm not sure I understood the 10 difference.
11 Could you just give us a definition at this 12 point?
13 WITNESS MILLSPAUGH:
The effective green time by 14 definition is equal to the clearance, the yellow clearances, 15 the all reds, meaning that there would be an all red 16 appearing on all the approaches to the intersection, minus a 17 so-called lost time which is in this Highway Capacity Manual 18 method.
19 And, the loss time, a part of it is you are 20 sitting at the intersection waiting to start up, and there 1
21 are some delays in that time period.
And, we have allowed 22 maybe two seconds for that.
23 And, then there are lost time, the intersections 24 closing down for the other roadways or other phases, and we 25 allowed two seconds for that, for the one highway.'
)
i 1
82800808 18836 joewalsh i
I Is that satisfactory?
l 2
JUDGE KLINE:
Yes, thank you.
l I
3 BY MR. CHRISTMAN:
(Continuing) 4 Q
It sounded a little bit imprecise the way you 5
described the balancing process.
Do you have a criterion 6
you use for the balancing?
7 (The witnesses are conferring.)
1 8
A I'm going to try to answer your question.
l l
9 Again, we looked at the results -- and this may have been l
10 trial and error of several times -- and what we did is, 11 again we tried to give as much time to these critical moves, 12 the left against the through, and we looked at the phases where we might steal some tin.e f rom.
And, maybe we went 13 Id through the program once again setting their v/c's to 15 approximately one.
In other words, it would be almost 16 congestion in all the phases that are involved, trying to 17 give as much time to the-critical moves but at the same time IB not exceeding the maximum green time settings on the 19 controller.
20 Q
Do you know how -- what the definition of 21 saturation ratio is?
22 A
That's the adjusted flow rate to the adjusted 23 saturation flow rate, also known as v/s.
2d Q
One possible criterion would be to balance the 25 saturation ratios.
Have you -- you didn't do that, did you?
,t
82800808 18837 joewalsh 1.
A I didn't persona 13y do this, so I don't know if O
2 they did or not.
3 Q
Okay.
Let rte ask you another definitional, a 4
different type of definition.
5 Dr. Hartgen, when traffic experts talk about 6
medians how do you define that, a median in a road?
7 A
(Witness Hartgen)
Are you referring to a e
statittics or --
9 O
No, I'm sorry, not like a median mean or mode 10 but rather like something out in the middle of a roadway, a 11 physical median to separate two parts -- you know, the 12 northbound from the southbound lanes, something like that.
13 A
Well, we use that term in a number of ways.
I'm N) 14 not sure it has a single technical mea'ning.
15 In conversation, we often refer to it when we 16 are referring to a portion of the roadway, usually in the 17 center that's raised, or in 'the cases we've looked at here, 18 painted, often in such a way as to prevent vehicles from 19 moving onto it.
Medians, of course, can be raised.
In 20 interstate systems, they have grass on them quite often and 21 guardrails and other protective devices.
I 22 You occasionally have signals or other roadside 23 furniture, as we call it.
24 Q
As you travel south on the Long Island 25 Expressway along that Route 107 but before you get to O
82800808 18838 joewalsh I
1 y9 Intersection H.4 at Old Country Road, you come to a sort of
\\
2 a fork here 106 goes off to the'right, don't you?
3 A
I believe one of the movements of 106, 4
southbound movement of 106 goes off to the right.
But, the 5
northbcund movement of it is further down.
I think I recall 6
where that fork ii.,
it 43 7
Q Doesn't the right side of that fork go on to 8
cross Old Country Road just a few blocks to the west of that 9
Intersection H.4?
10 A
Yes.
11 Q
If you had an evacuation and there were a lot of 12 people heading for the reception center down that left fork, 13 don't you think the local background traffic might very well 14 avoid that congestion by travelling down the right fork to 15 get where they are going?
16 A
Not at all.
The local traffic would be 17 interested in engaging in activities along Old Country Road 18 and 107.
Just below there, there is a very dense strip of 19 development, parking on both sides as I recall, a number of 20 shops and businesses.
That traffic would mix with the 21 evacuation traffic.
22 If anything, the intersection that you referred 23 to, the Gore, as we would call it, is almost straight for 24 the 106 path.
Although we did not do any calculations to 25 it, it occurred to me that a fair portion of the evacuation
!O
l l
82800808 18839 joewalsh 75 traffic would simply head south on 106 and miss the center 1
\\)
2 completely, wind up in Jones Beach perhaps.
3 0
People who aren't going to the reception center, l
4 might not they just take 106 which just goes to about the 5
same location in Hicksville and avoid that 107 traffic?
6 A
Well, abou t the same location is not the same 7
location.
If you are going to a store, you are going to a 8
store.
9 Q
A lot of that development is commercial, isn't 10 it?
Stores, as you say, retail shops?
11 A
As I recall, there is a section of about two 12 blocks long that's commercial.
And, then beyond that it's 13 primari3y residential on the lef t and on the right I believe 14 it remains commercial.
15 Q
Most shopping trips are discretionary, aren't 16 they?
That is, you can put them off if you want to in most 17 cases.
18 A
We don't use the term " discretionary travel" to 19 describe shopping.
20 Q
Let me put it another way, then.
If people were 21 going down to those commercial establishments to buy 22 something and they learned that there would be a lot of 23 evacuees coming along 107, don't you think they would 24 postpone the shopping trip?
25 A
They might just as easily be stocking up for m
1.
82800808 18840 joewalsh
.p I
needed items.
2 O
Why would they need items?
3 A
They might think that the evacuation might later d
relate to them.
5 Q
Forty miles away from the plant?
6 A
When announcements.are made for hurricanes, it's 7
typical for citizens to clean out milk and bread.
I can see 8
circumstances in which such behavior might occur here.
9 0
Well, just about any kind of behavior might 10 occur, but don't you think it's more likely that people 11 would simply avoid all that congestion and not go to the 12 store?
13 A
No, I don't.
I think it's more likely people
(
14 would travel on paths that they are familiar with.
The 107 15 path has, as I recall, about three times more traffic than 16 the 106 path.
17 Q
But, if people are familiar with the 107 path 18 they are probably familiar with the 106 which runs along 19 close to it, aren't they?
20 A
By the time 106 gets to Old Country Road, I 21 believe there are four intersections between 106 and 107, 22 and I think that's close to half a mile.
It's a fairly 23 3arge distance.
The angle is about 30 degrees, as I recall 24 there, and we are talking about a mile and a half of 25 distance.
!d
l 82800808 15L41
.joewalsh 1
0 Do you think people would go ahead and run right 2
down 107 with the hundreds of evacuee vehicles'even though 3
there is another road four intersections away that they 4
could take?
5 A
My po4nt is that 106 is not a parallel road to 6
107.
106 joins 107, but it provides a different set of 7
accesses.
It provides access to residential areas to the 8
west of 107; therefore, it doesn' t substitute for 107 at 9
all.
10 Q
Do you think people from the emergency planning 11 zone will be familiar in advance with the routes to the 12 reception centers?
13 A
No.
)
14 Q
Well, you used a minimum path algorithm in some 15 of your analyses.
Don't minimum path methods include the 16 assumption that people are familiar with the various paths 17 and so they can find the minimum paths?
18 A
There are different minimum path algorithms.
19 Q
Well, as a general methodology don't they --
20 isn't it implicit in them the assumption that people are 21 familiar with the various paths?
22 A
Yes, generally, particularly in urban simulation 23 systems.
24 Q
Let me ask you a little -- something about 25 traffic congestion.
Isn't the Long Island Expressway O
82800808 18842 j oewalsh
.I 1
congested frequently, just about everyday?
2-A Portions of it certainly are.
3 4
5 6
7 8
9 10 11 12 1
15 16 17 18 19 20 21 22 23 24 25 0
$b?W0000f m0000000 18843 marysimons 1
Q Doesn't demand on that road exceed design 2
capacity frequently?
3 A
Operational demand can exceed the capacity of 4
the road.
5 0
You don't mean that D over C can never exceed 6
unity, do you?
7 A
In operations, yes, that's correct, it cannot.
8 Q
But isn't the actual demand for that road 9
greater than the design capacity frequently and more cars 10 seek to use it than the design ---
11 A
Well, we frequently see congestion on the road, 12 levels of service "F".
13 Q
Well, it continues to attract and service
()
14 traffic under those conditions, doesn't it, the LIE now?
15 A
Those portions which are congested would not be 16 able to service any more traffic, and in fact on the 17 occasions when I have been on it under those circumstances I 18 have observed and occasionally have engaged in exiting 19 behavior for the express purpose of avoiding perceived 20 bottlenecks downstream.
21 Q
People do avoid congestion?
22 A
They try to, and that is one of the reasons why 23 we thought that minimum path algorithms might be worthy of 24 some review here.
25 0
Your Exhibit 23, that is the attachment to your O
00000000 18844 marysimons I
.,4 1
testimony, has a list of queue lengths, calculated queue U
2 lengths that is, and I think on the LIE you show something 3
like 42 to 73 miles long.
I guess that is starting at the 4
county line.
5 A
Okay, I've got that exhibit in front of me now.
6 Q
I think the question was you show a queue 7
length, taking into account the several lanes, of 42 to 73 8
miles for some of the DOT scenarios, don't you, the 4's and 9
5's I think?
10 A
Yes.
For scenario 5 we show an equivalent queue 11 length of 42 miles for the LIE and for the southern.
12 O
You say equivalent queue length.
Now the road 13 between the county line and the EPZ isn't even that long.
, r 14 So those queues if they were actually there would be on the 15 arterials leading to the highway, wouldn't they, to the LIE, 16 for instance?
17 A
That's exactly what we meant by the word 18 equivalent.
In the next column over it says " Lane Miles."
19 Once again, in this planning analysis we are comparing the 20 amount of demand there is for the road space with the amount 21 of road space that there is available, and your example 22 there, I'll stay on it.
We are estimating that the hourly 23 demand of 7770 is much greater than the hourly capacity of 24 5520 in over a 12-hour period which is the time for which 25 this analysis was conducted.
That.is the equivalent of an
!d
'00000'000 18845 marysimons 1
1 access demand of 26,000 and change here vehicles.
2 And being' conservative of 25 feet a vehicle, 3
which is I think very conservative, and if these vehicles 4
are moving at all, they going to need more than 25 feet 5
between them.
So that's 126 lane miles of road space that 6
would be required to hold that kind of a demand.
7 Q
Are you familiar with the Grumman facility 8
somewhat to the south of'the Hicksville Reception Center?
9 A
I have been by it once.
I have never been on 10 the facility.
11 Q
Do you know what it is?
12 A
It's one of their major operations.
I believe 13 they make aerospace items, planes, rockets, and that's as 14 much as I know about it.
15 Q
A lot of employees work there, don't they?
16 A
I believe so.
17 Q
Isn't it true that a lot of the traffic in that 18 area consists of commuting trips to that facility by 19 employees?
20 A
I can't say.
I would assume so, but I don't 21 know if there are any houses on the property or residences.
22 Q
Do you think if the Grumman Corporation were to 23 say dismiss its employees early so they could go home in 24 advance of evacuees arriving that it would eliminate a lot 25 of the background traffic?
O
00000000 18846 marysimons I
1
.g; A
I don't understand your question.
Could you e
2 repeat it?
3 Q
Well, if there is a lot of employees traveling 4
to.that particular facility, one cou3d ask the facility to 5
let the employees go home if you knew that there were going 6
to be evacuees coming to the neighborhood and that would 7
alleviate a lot of the background traffic, wouldn't it, if 8
people cleared out?
9 MR. ZAHNLEUTER:
I obj ec t to this speculative 10 question.
11 MR. CHRISTMAN:
It's a hypothetical.
12 JUDGE MARGULIES:
We'll let-the witness answer 13 if he can.
i i
14 WITNESS HARTGEN:
Well, wi;h the understanding 15 that it is speculative, I don't know how many employees work 16 there, I don't know in what directions they might leave, I 17 don' t know their present shif ts and I don' t know how rapidly 18 they could leave if directed to do so.
Therefore, I have no 19 information that I could use to judge the answer to that 20 question.
21 It's conceivable that a request by Grumman to 22 clear its facilities could take a considerable period of 23 time.
24 BY MR. CHRISTMAN:
25 Q
What's a considerable period of time?
1
00000000 18847 marysimons 1
A (Witness Hartgen)
Wel3, a priori, I have no way
('_'s) l l
^
2 of knowing whether that traffic might congest with traffic 3
attempting to get to the reception centers or might not.
If 4
an evacuation were to occur in such a way that it overlaps 5
either exiting or entrance schedules for the plant, then the 6
traffic would certain conflict with it.
7 Q
You've done a number of analyses of traffic for 8
this case.
Have either of you ever done any analysis of 9
traffic for reception centers at any other nuclear plant in 10 New York or any other State for that matter?
11 A
No, just Shoreham several years ago, and that 12 was limited to the EPZ.
is Q
I don' t mean evacuation ti; e estimates out of 14 the EPZ.
I meant to the reception centers.
There are 15 reception centers at other plants in New York.
16 You haven't analyzed the traffic for any of 17 those?
18 A
No.
19 Q
Have you been asked to do that?
20 A
No.
21 Q
Has anybody in the Department of Transportation 22 done that for other reception centers in New York?
23 A
I haven't.
I don't know about other people.
2d Q
Do you know of anybody in DOT who has to 25 reception centers and not evacuation time estimates.
O n
00000000 18848 marysimons
'O 1
A I'm not aware of any, but I honestly cannot say 2
whether anyone has.
It's a very large depcrtment.
3 0
Yes, I know you've said that.
Don't you think 4
you would be aware if anybody had?
L 5
A I believe I would be, yes.
6 Q
And you know of none?
7 A
I know of none.
B Q
Let me ask you about the road construction just 9
a little bit.
10 When the State or I guess other jurisdictions 11 make plans for road construction proj ects, the plans aren't 12 always fully realized, are they?
Sometimes plans don't get l
13 implemented.
Is that true of the road construction project
~
14 field, too?
15 A
It occasionally happens.
It's more likely as a 16 second situation that road construction may be delayed and 17 put off a season, but even more likely than either of those 18 two combined is that road construction continues on 19 schedule.
20 Q
Someoro from the State testified a few years ago 21 I think that there was a plan to upgrade Route 25A.
Am I 22 right that there was such a plan or a project?
23 A
I believe so. I'll have to refer to my notes if 24 we want to get into these specifics since I'm not directly 25 responsible for this program on Long Island.
00000000 18849 marysimons 1
Q Do you know'if that proj ect has been t3
~#
2 accomplished?
- 3 A
No, I don't, but let me just check my notes for 4
a second.
5 Q
Please do.
6 A
Was there a specific project in mind?
7 Q
I take it there was more than one project for 8
the upgrading of Route 25A?
9 (Pause while the witness searches through 10 documents.)
11 A
I'm confused here.
I asked you a question and 12 you asked me a question.
I believe there is only one.
13 0
Oh, there is only one, and that's the one I want 14 tp know about.
15 (Pause.)
16 A
I'm sorry.
I'm going to have to try to find 17 that.
Is it possible for us to do this when I get that item 18 out.
I can't seem to locate it.
19 Q
Well, maybe you're right.
Let me ask you a 20 couple more quJstions and you may need to do the same thing.
21 Was there a situation a few years ago when the 22 State put out a construction project or proj ects for bids 23 but got no bids?
24 A
That can happen.
25 Q
Has it happened?
l
)
00000000 18850 marysimons l
.hs 1
A I believe so.
I'm not familiar with the t]
2 details.
3 0
Do you recall a situation in which a yhole d
construction season was lost for a lack of bids?
5 A
Oh, no.
A whole construction season would never 6
bc lost.for the lack of bids.
It might possibly be lost for 7
other reasons, Federal aid from Washington, but that has 8
never occurred either.
9 Q
What other reasons besides lack of Federal aid 10 might cause construction to be delaye'd?
11 A
Are you referring.to a whole season?
12 O
Well, not really so much a whole -- well, sure.
13 You said lack of funds from Washington could cause a whole
- ,il}
14 season to be lost.
Are there other things that could cause 15 a whole season to be lost?
16 A
State matching funds for that, but that has 17 never occurred either.
18 Q
How about other factors that might cause a 19 particular proj ect to be postponed or cancelled other than 20 lack of funds'or lack of bids?
21 A
We occasionally redo designs of proj ects, but I 22 think primarily lack of funds is the primary reason why we 23 delay proj ects, if at all.
But, as I said earlier, most of 24 our program is moving forward quite well.
25 The Rebuild New York program has adequate funds g
L%)
00000000 18851 marysimons I
and the Federal fun?s are available and the program is k_
2 moving forwa2d.
3 0
What is the purpose of the Rebuild New York 4
program?
What is the concept behind that?
l 5
A The concept is to focus on the quality of our 6
infrastructure which is our highway and bridge systems.
We 7
have been concerned that over the years that the condition 8
of that infrastructure has declined and that in order to 9
remain competitive economically and provide mobility to 1
10 citizens that the State must reinvest in that infrastructure 11 and maintain it at the high quality it was when it was 12 constructed.
13 (Witnesses confer.)
I
(
14 Q
Do you want to add anything?
15 A
No.
16 Q
When a road construction proj ect is done, don't i
17 they make every effort to return the lanes to service at 18 peak periods or when the work is done for the day?
19 A
Well, we always try to maintain as much of the i
20 traffic flow as we can.
The nature and extent of the j ob l
21 often prevents that from happening.
On several proj ects we 22 are planing on the Long Island Expressway we'll be doing 23 those proj ects at night, and then late at night then we will 24 be removing the barriera and returning the lanes to service.
25 This is very expensive for various reasons.
l l
l l
1
i 00000000 18852 marysimons I
i Nighttime work is very expensive, plus the whole system has
)
7)4 t
1 2
to be very mobile and you have to be able to take down the 3
barriers and put them up and so on, and the equipment must d
be moved away and only small portions of the pavement can be 5
' worked on at any'given time.
6 It is therefore not the kind of action that we 7
typically engage in.
If we can possible do so and the 8
traffic will allow it, we wi]1 block off lanes and do all 9
the work while we have the facility protected.
And during 10 such times of course the capacity of the facility will be 11 reduced.
12 O
How does the State address the problem of 13 growing population with respect to the demand for roads?
Do 14 you have a continuing planning process that looks to the 15 future?
16 A
Yes.
We're partners with the local governments l
17 in urban areas through organizations called the Metropolitan 18 Planning organizations.
These are bodies of elected and 19 appointed officials who make decisions on needed 20 improvements, and it's through that process that we develop 21 the schedules for construction.
22 Q
I take it your intent is to provide adequate 23 highways for the people of New York as it grows?
24 A
We would certainly like to be able to achieve 25 that goal.
We have found that it is not possible for us to
00000000 18853 marysimons 1
provide all the capacity that is desirable.
We j us t don ' t iD 2
have the funds, and local governments also do not have the 3
wherewithal to provide all of that service.
In rapidly 4
growth areas like Long Island it's particularly difficulty.
5 Q
Let me ask you'about the signalized 6
intersections in the vicinity of the three ---
7 JUDGE MARGULIES:
Before you get started into 8
that area, would it be appropriate to break at this time?
9 MR. CHRISTMAN:
This would be a good time.
10 JUDGE MARGULIES:
We will recess until a quarter 11 of 2.
12 (Whereupon, at 12:15 p.m.,
the hearing recessed, 13 to reconvene at 1:45 p.m.,
the same day.)
(
14 15 16 i
17 18 19 20 21 22 23 24 25
)
'O
M i
82801010 18854 L
suewalsh i-1 AFTERNOON SESSION O
2 (1: 45 p.m. )
3 JUDGE MARGULIES:
Back on the record.
You may 4
continue.
5 Whereupon, 6
ROBERT C. MILLSPAUGH 7
and l
8 DAVID T.
HARTGEN l
9 resumed as w3tnesses called by and on behalf of the 10 Intervenor, New York State, and having previously been duly i
11 sworn, were further examined and testified as follows:
12 CROSS EXAMINATION 13 BY MR. CHRISTMAN:
(Continuing)
I 14 Q
Mr. Millspaugh, when you illustrated how that 15 intersection at Newbridge Road and Sunrise Highway worked, 16 did you actually go out and observe that?
17 A
(Witness Millspaugh)
No.
18 Q
Now, as I understand it -- tell me if I'm wrong 19 here -- there are two kinds of controllers.
One of them is 20 called a NEMA controller which I guess stands for National 21 Electrical Manufacturers Association; and, the other is 22 something called a 170; is that right?
23 A
That's correct.
24 Q
Could you describe both of those two kinds of 25 controllers and how they differ?
4 i
_------_---_-- _ J
82801010 18855 suewalsh I
.c4 1
A They are very similar in operation.
They both d
2 have up to eight phases in the controller.
I'm not even 3
sure I could detaal the dif f erences in the two, because 4
that's not my expertise.
5 Q
One of them uses a microprocessor, doesn't it?
6 A
Well, they both use a microcomputer type base.
7 Q
Any differences between the two that you can 8
think of?
9 A
Basically, the operations are similar.
10 MR. CHRISTMAN:
Let me hand out the sheets with 11 the signal timing information that you mentioned earlier 12 today.
This has already been admitted into evidence as 13 Suffolk County Exhibit 26.
14 (A document is distributed.)
15 BY MR. CHR.~ STMAN :
(Continuing) 16 Q
On the first page and following sheets, there is 17 a term there called " max" time, m-a-x.
Can you define for 18 me what that means?
19 A
In the left column you are referring to?
20 Q
Yes.
l 21 A
Max time?
22 Q
Yes.
23 A
That is the maximum time of green.
24 Q
The maximum amount of green time?
25 A
Yes.
!O l
L_ -
l
-82801010 18856 suewalsh 1
Q And, that's for each phase?
(
2 A
- Yes, j
3 Q
Now, isn't there -- aren't there two ways of 4
referring to maximum green time?
Can't you refer to maximum 5
green time in terms _of the total green time or'in terms of 6
the vehicle extension limit?
7 A
No, sir.
8 Q
No?
9 A
No.
10 MR. CHRISTMAN:
Let me hand out another document 11 and this is an excerpt from a book by a man named James 12 Kell.
And as soon as it is handed out, I will describe it 13 for the record.
()
14 The cover page says " Manual of Traffic Signal 15 Design."
16
( A document is distributed.)
17 MR. CHRISTMAN:
The document that I've just 18 handed out is excerpts from a book by the Institute of --
19 well, it's published under the aegis of the Institute of 20 Transportation Engineers.
It 's the book that is called 21
" Manual of Traffic Signal Design."
And, the first author is 22 James H. Kell.
23 What I have handed out is that cover page, Pages 24 75, 150, 152 and 153, which tend to have to do with some 25 definitions that I want to talk about.
)
1
82801010 18857 suewalsh I
1
.q I would like to ask that this be marked LILCO 2
Exhibit 36 for identification.
3 JUDGE MARGULIES:
It will be so marked.
d (The document ret' erred to is marked 5
as LILCO Exhibit Number 36 for 6
identification.)
7 BY MR. CHRISTMAN:
(Continuing) 8 Q
Are you familiar with this publication?
I 9
realize I've only given you part of it.
10 A
(Witness Millspaugh)
I'm not familiar with this 11 one, no.
12 Q
Oh, you are not?
Dr. Hartgen, have you seen 13 this?
4 )
14 A
(Witness Hartgen)
I believe I've seen it, but I 15 would not say I'm familiar with it.
16 Q
Do you know if it's authoritative in its field?
17 A
I can't say.
I'm sorry, I was looking at James 18 Kell's name.
I thought it was a publication by him.
You 19 are talking about this manual put out by the Institute?
20 Q
Yes, put out by the Institute of Transportation 21 Engineers, correct.
l 22 A
Okay.
I just thought it was a paper by Kell.
l 23 Q
No.
It's an excerpt from a book.
Have you --
24 are you familiar with the book?
25 A
Somewhat, yes.
l l
l l
82801010 J
18858 suewalsh 1
Q Do you know if it's authoritative in its field?
O, 2
A Well, it's published by the ITE.
I 3
Q Something that traffic engineers turn to and o
4 rely on?
5 A
Transportation engineers, yes.
6 Q
If you would, turn to Page 152.
At the bottom 7
of the text, right above the figure it says,' "The maximum 8
green interval. limits the time a phase can hold the green.
9 It may be in terms of total green time or it may be in terms 10 of vehicle extension limit."
11 Now, what I asked I think a minute ago was 12 whether the maximum green time might not be defined in terms 13 of total green time or in terms of vehicle extension (f
14 limits.
Now, am I -- and you said no.
15 Are you disagreeing with this statement?
16 A
(Witness Millspaugh)
No.
I'm looking at this 17 graph here, right under what you are reading.
And, I'm 18 looking at the minimum green period extended with this 19 extension period that you referred to, this vehicle 20 extension.
21 0
.Well, when you talked about maximum green time 22 with reference to the maximum time figure on these sheets 23 that I've just handed out, which of those two are you 24 talking about, total green time or in terms of vehicle 25 extension limits?
O
~
'82'801010 18859 suewalsh
--l 1
A From the timing sheet?
7{
2 Q
Yeah, from the timing sheet.
We said -- you 3
told me'the maximum time means maximum amount of green time, d
and I'm wondering if that means total green time or green 5
time in terms of vehicle extension limit?
6 (The witnesses are conferring.)
7 A
Well, I would still hold to my previous 8
statement that what you see on the sheet is the maximum 9
green time.
10 Q
But, my question is when you say maximum green 11 time, do you mean in terms of total green time or in terms 12 of vehicle extension limit?
13 A
It would include the extension.
4()
14 0
It would include the vehicle extension limit?
15 So, if it included the minimum green period and the vehicle 16 extension limit, is that what that means?
17 A
If it's set for an extension, yes.
18 MR. CHRISTMAN:
Let me pass out another document 19 which is just a letter with some definitions in it.
It's a 20 letter from counsel for the State to me, as a matter of 21 fact.
And, I want you to have it in front of you.
We are 22 going to talk about definitions.
23 (A document is distributed.)
24 MR. CHRISTMAN:
This is a three-page letter of 25 Ap rl.*i 16, 1987.
He is defining severa] of the terms in 17-
up 82801010 18860 suewalsh 1
Suffolk County Exhibit 26.
l 2
And, I will ask that this three-page letter be I
3 marked for identification as LILCO Exhibit 37.
R;g 4
JUDGE MARGULIES:
It will be so marked.
5 (The document referred to is marked
'6 as LILCO Exhibit Number 37 for 7
3 identification.)
B BY MR. CHRISTMAli:
(Continuing) 9 Q
Let me ask you another definition.
On these 10 timing sheets that we looked at first, Suffolk County 11 Exhibit 26, there is a term " initial green" abou t four lines 12 down in.the tsble.
~
13 Cin its.I define initial green for me?
14 A
(Witness Millspaugh)
It's the initial interval
- 5 to get'the traffic started.
16 I Q
Okay.
And, then the letter that I've just 17 handed out it says, " Initial green is the time it takes for 18 the vehicles between the detector and the signal to. start 19 moving."
20 A
Yeah, that's right.
Just to get them started 21 out.
And that usually is set by the distance to the 22 detector.
23 Q
Does that initial green correspond to another 24 term that is sometimes used in your profession called the 15
" initial interval?"
o o
m
82801010 18861 suewalsh I
1 A
I guess they are somewhat interchangeable, but
,yf4) t' 2
there is some variance depending on manufacturers.
3 0
Let me refer you to Page 150 of that " Manual of d
Traffic Signal Design" by the Institute of Transportation 5
Engineers.
6 At the bottom of the page under " Initial 7
Interval" it says -- there are two sentences, and ti.en a 8
sentence that starts, "With this form of detection, the 9
initial interval is established to permit those vehicles 10 stopped between the detection point and the stop bar to get 11 started and move into the intersection."
12 So, does your, what you've called the initial 13 green include the time to move into the intersection?
'M)
S 14 A
I think it 's j ust to get them up to the m
15 intersection, yes.
'6 Q
Oh, up to the intersection?
17 A
And into it.
IB Q
And into it?
19 A
Yes.
20 0
Okay.
So, that sounds consistent with Kell's 21 use of initial interval, then; is that right?
22 A
Yes, sir, I believe so.
23 Q
Now, if you would look at these timing sheets, 24 timing data which I call Suf folk County Exhibit 26, because 25 that's how it was entered into evidence, and go to the third IA
.v
82801010 18862 suewalsh I
1 page.
At least, on my copy someone has written in the page g~
2 number so you can see a Page 3 number at the upper right-3 hand corner, with some more of the rignal timing data for 4
Newbridge Road and Route 27.
That's Newbridge Road and 5
. Sunrise Highway I believe.
6 (The witnesses are complying.)
7 Now, take a look at those timing data if you 8
would.
I want to ask you some questions about computing the 9
minimum'and maximum times for several phases there.
Using 10 that sheet which is Page 3 of this exhibit, can you compute 11 the minimum and the maximum times for the left turn phase?
12 A
Which left turn phase did you want to look at?
13 Q
That first one that we talked about earlier?
14 A
B.17 15 (Pause.;
16 Q
Are you waiting for more information from me?
17 A
I was, yes.
Is that what you meant?
18 Q
Can you compute the maximum and minimum times 19 for the left turn phase?
20 A
(Witness Hartgen)
Excuse me.
I think there are 21 two lef t turn phases.
I think if you are referring to these 22 3 eft turn protected phases --
23 Q
Let's do that first.
24 A
-- B.1 and B.2 --
25 0
Yes.
'h
82801010 18863 suewalsh 7
.J 1
A Which one?
2 Q
Either one.
3 A
(Witness Millspaugh)
Well, the maximum phase is d
based on an analysis of the complete intersection and what 5
the timing was required for the particular traffic move.
6 And fitting that into the total picture of the timing for 7
the intersection.
8 Q
You can't give me maximum or minimum times from 9
this sheet?
10 A
I would have to -- the maximum times ought to be 11 adding up to the cycle length plus any clearances.
12 O
Well, for the left turn phase, either one, is 13 this sheet enough to allow you to calculate the maximum and Id minimum green times?
15 A
Yes.
I believe I've already done this in my 16 analysis if you will give me time to find it.
17 (The witness is looking through documents.)
18 Just give me a moment to do some computations.
19 Q
That's fine.
Take your time.
20 (The witness is doing a computation.)
21 MR. ZAHNLEUTER:
Judge Margulies, it appears 22 that this calculation will take some minutes, some time.
23 May I request that we break?
24 JUDGE MARGULIES:
Let's take a short recess.
25 MR. ZAHNLEUTER:
Five minutes?
!d
82801010 18864 suewalsh b
1 JUDGE MARGULIES:
Yes.
l 2
MR. ZAHNLEUTER:
Thank you.
)
l 3
MR. CHRISTMAN:
Well, I was also going to ask if i
4 he could give me similar information for the north / south 5
phase and the east / west phase.
6 JUDGE MARGULIES:
Did you hear that, Mr.
7 Millspaugh?
Mr. Christman said he was going to ask you to 8
do some other calculations.
Why don't we hear what other 9
calculations he wants and then we will take a short recess 10 so you can do the calculat' ions.
11 BY MR. CHRISTMAN:
(Continuing) 12 0
The maximum and minimum green time for that 13 protected left turn phase, for the north / south phase, and V
14 for the east / west phase.
15 A
(Witness Millspaugh)
The north / south and the 16 east / west?
17 Q
Yes, sir.
18 JUDGE MARGULIES:
Will 10 minutes be enough for 19 you, Mr. Mil]spaugh?
20 WITNESS MILLSPAUGH:
I will try, yes, sir.
21 JUDGE MARGULIES:
We will take a 15 minute 22 recess.
23 MR. ZAHNLEUTER:
Thank you.
24 (Whereupon, a recess is taken at 2:04 p.m.,
to 25 reconvene at 2:24 p.m.,
this same day.)
O
r 82801111 18865 marysimons 1
JUDGE MARGULIES:
Back on the record.
2 CROSS-EXAMINATION (Resumed) i 3
BY MR. CHRISTMAN:
i 4
O Mr. Millspaugh, I asked for the max and min 5
times for the left-turn phase, the north / south phase and the 6
east / west phase.- Do you have that information?
7 A
(Witness Millspaugh)
I'll have to get up here 8
to demonstrate ---
9 MR. CHRISTMAN:
Whatever you like.
It would be 10 helpful if you put the numbers on, too, I suppose.
11 (Pause while the witness goes to the easel and 12 proceeds to draw.)
13 WITNESS MILLSPAUGH:
I didn't plan ahead too f)
(/
14 well.
I ran off the top of the sheet, but this is generally 15 what we go through to time the signal, and hopefully I'll be 16 able to explain it to you.
17 BY MR. CHRISTMAN:
8 18 Q
To make it I hope easier, can you just give me 19 the minimum and maximum times for each of those three phases 20 that I asked for?
21 A
(Witness Millspaugh)
Okay.
It seemed to cone 22 out strangely, this whole time table here seems to be 23 somewhat strange because we have a 120-second cycle in the 24 signal system, and yet our timing on this, I think it's for 25 an isolated operation is what it looks like.
O
7 82801111 18866 marysimons i
7~l 1
l
., J It's strange to me that it would come out wit.h t
i 2
an odd 74.5 cycle length, and the reason for that decimal 3
~
there is be,cause of the all red interval of 1.5 in that one 4
location there under the A-1 phase.
5 Q
Could you give me the minimum and maximum time 6
for each of those three phases?
7 A
For which phases?
8 Q
Well, just one at a time.
We talked about the 9
left turn and then we said the norch/ south and then 10 east / west.
II A
For the left turn, the B-1?
12 Q
yes.
13 A
I can give you the maximum time, but are you
)
Id talking abou t the initial green?
15 Q
The minimum phase duration of B-1.
16 A
Well, that's depending on what your detectors 17 look like, if they are present or if a point detection.
IB Q
But you can' t tell me the minimum ---
19 A
I can't from this, no.
20 Q
How about maximum?
21 A
I can give you the maximum timing for B-1 is 20 22 seconds plus your clearances.
23 Q
Plus your clearances?
24 A
yes.
25 0
What are those?
m
82801111 18867 marysimons
..~
1 A
I can show you up there.
It's 20 seconds here,
+
t) 2 plus the three seconds for amber, plus the two seconds for 3
an al] red, as you see on the sheet.
4 Q
So you think that taking the 20 maximum time 5
plus the three and and the two below -- I'm sorry, I 6
misstated.
Twenty seconds plus three plus two?
7 A
Yes.
Twenty seconds, plus three seconds yellow, 8
plus two seconds all red.
9 Q
Right.
So that's 25 total?
10 A
Twenty-five for this, yes.
That includes your 11 clearances though.
You're looking for maximum greens, i
12 O
Well, actually what I asked was maximum phase.
13 A
That all depends what your term is.
()
14 Q
That.does include clearances, doesn't it?
15 A
Well, the 25 seconds includes your clearances.
16 0
All right.
So we've got 25 seconds, including 17 clearances for maximum, and for minimum we can't tell.
18 A
It depends on your detectors.
19 Q
How about the north / south?
20 A
That's one phase and it's B-3, and it has a 21 maximum I should designate as a vehicular time because you 22 do have pedestrian crossing there.
When it's actuated it 23 would be a little more time.
24 0
What are the answers?
25 A
That's the north / south phase and it's got 25 O
82801111 18868' l
marysimons l
l
.e4 I
seconds of maximum green, plus 4 seconds of amber or yellow, l
I
(-
2 plus 2 seconds all red.
3 Q
For a total of 31?
4 A
For 30 -- I'm, sorry, 31, you're right.
5 Q
And minimum on that, is that also -- can you 6
tell the minimum on that?
7 A
Again, that depends on where the detectors are.
8 0
How about the third one, the east / west?
I guess 9
that would be A-1 and A-2.
10 A
Can I finish on this one.
One the north / south 11 there is a pedestrian crossing, and that has a walk of 9 and 12 then a c3earance of 18 seconds.
So that would make it-3 longer than the vehicu3ar timing so the pedestrians can 14 safe 3y get across the street.
ss 15 Q
Doesn't pedestrian clearance continue on through 16 the anber and the all red?
You don't add the latter two on 17 to that, do you?
IB A
The pedestrian clearance is timed out 19 concurrently with the yellows and the all reds.
20 Q
Okay.
That's two of the three I guess phases.
21 Are you through with the ---
22 A
Did you want the other moves, the artery?
23 Q
Sure.
24 A
Here is what happens with this timing.
We have 25 what we call rings, and this is the westbound left turn and Ith O
82801111 18869 marysimons I
this is the eastbound, that familiar conflict between the
?
left and the'throughs, and the'same thing on the other ring 3
there.
4 So you designate the time for each one of these 5
phases, and the way these signal controllers operate is -- I 6
mean they are like computers and they add up these seconds 7
real quick and decide which -- in the meantime these are 8
running together and then one times out before the other and 9
they then run concurrently, depending on which one is not in 10 conflict, with one that complements that move.
In other l
11 words, they combine, and then the timing for that cycle 12 could be up here or it could go this route.
There are two 13 possibilities.
Then in the next cycle it could go the other r(_)
14 direction, and it's doing this in milliseconds, making these 15 decisions how these changes are going to be.
16 But the east / west in this case goes across the 17 top here and you add these phases and these clearances and la this phase and these clearances and I came out with 44.5.
19 MR. McMURRAY:
What phase was that for?
20 WITNESS MILLSPAUGH:
The east / west street.
21 BY MR. CHRISTMAN:
i 22 Q
Can I have the east / west times for the east / west 23 through movement?
24 A
(Witness Millspaugh)
For the through movement.
25 Which direction would you like?
They're different.
A-1, h
l l
l 1
82801111 18870 marysimons I
I
.,, g according to this, is 15 seconds and A-2 is 14 seconds.
(_/
2 O
Is that just the green part?
Did you have to 3
add the clearances?
d A
Oh, I'm sorry, that's just the green, yes, and 5
they had to add the clearances in.
6 Q
What is the clearance that you add to those two 7
numbers?
8 A
Well, the first one, A-1 had this strange.5 in 9
it, but that adds up to 4.5.
10 0
The clearance is 4.5.
So you add'that to the 11 15?
12 A
Yes.
13 Q
Making 19.57
. ry i
k-Id A
Yes.
)
15 0
And what about A-2, 14 seconds ---
16 A
That would be 14 plus 6.
17 Q
For a total of 20.
Can you give me maximum and 18 minimum cycle lengths?
19 A
Maximum and minimum cycle lengths?
20 Q
Yes.
21 A
Well, from what I can figure, my total I came up 22 with and then the maximum is 120 which would be set by the 23 signal system, what we call the background cycle.
24 JUDGE SHON:
Your arrows there, I noticed that 25 on the left side the turn arrows indicate on the top in
82801111 18871 marysimons
/
1 phase B-1 an eastbound car turning left to go south, right?
2 Is that correct?
3 WITNESS MILLSPAUGH:
This one here?
4 JUDGE SHON:
A westbound car turning lef t to go 5
south.
6 WITNESS MILLSPAUGH:
Yes.
7 JUDGE SHON:
Well, then why is phase A-1, which 8
on the sheet is marked westbound represented by an arrow 9
pointing to the right?
10 WITNESS MILLSPAUGH:
I think I mentioned this.
11 They have the nomenclature -- they have it headed wrong.
I 12 think they made an error in the headings.
13 JUDGE SHON:
Oh, on the sheet there is a I
14 mistake?
15 WITNESS MILLSPAUGH:
Yes.
16 JUDGE SHON:
Oh, I see.
Thank you.
17 WITNESS MILLSPAUGH:
This is the way it normally 18 operates.
19 JUDGE MARGULIES:
You may proceed, Mr.
20 Christman.
21 BY MR. CHRISTMAN:
22 Q
Mr. Millspaugh, I'm trying to make sure we get 23 the record clear.
I'm searching for something called a 24 maximum cycle length, which I gather is the sum of the phase 25 duratious.
Have we gotten that on what that maximum cycle 1
1
82801111 18872 marysimons I
- J l
is from the sum of the phase durations?
. (~h
\\,_)
2 A
(Witness Millspaugh)
The maximum cycle length, 3
apparently this signal is in a signal system from the sheet, d
and that would be 120 seconds.
5 Q
This system along Sunrise Highway, is it a fixed 6
system cycle with a cycle length of 120 seconds then?
7 A
I suspect it is, yes.
8 Q
And how can you tell that from this sheet?
G A
We13 it does say what appears to say " standby 10 cycle," which is that background cycle that I was 11 mentioning.
12 Q
Okay.
The standby or packground cycle you say 13 tells you that this is part of a fixed system cycle.
p_,
14 Now define for us what a, standby cycle is, if 15 you would.
16 A
I'm not sure what that term means here.
17 Q
Isn't a standby cycle a cycle that ---
18 (Counsel confers with consultant.)
19 Isn't it true that the maximum cycle length is 20 the sum of the maximum phase durations?
We ought to be able i
21 to get the maximum phase durations.
22 A
It really should have added up to that, yes, j
23 Q
Can you do that for me?
l 24 A
Pardon me?
l l
25 Q
Can you add those up for me for this signal?
I
____o
'82801111 18873 marysimons 1
A I just did, and it didn't add up to 120.
2 Q
So that is the source of the confusion?
3 A
Yes.
4 0
It should add up to 1207 5
A Yes, it should add up.
6 Q
And it should add up to 120 because this is part 7
of ---
8 A
Well, I should say -- I think what we have and 9
what we are looking at here is we're looking at a table for 10 isolated control and it adds up to a strange cycle length of 11 "5.5.
Then the signal at times is in a signal system with a 12 120-second cycle.
13 0
Can you tell from this sheet when it's isolated r())
14 and when it's part of the system?
15 A
Not from this sheet, no.
16 Q
How would you know, or how would you find out?
17 A
You would have to go out there and see what the 18 controls look like.
19 (Witnesses conferring.)
20 Now what you see on here, I should backup, that 21 there are three programs here.
I don't know the times from 22 this sheet.
They show the offsets for three different 23 programs.
24 Q
In calculating those minimum and maximum that 25 you did -- well, let me stay on the same controller or same 1
l 1
82801111 18874 marysimons
-l
.p_4 intersection and ask you another question about the
]
1 2
east / west phase.
3 Do you know if the vehicle recall is on for the 4
east / West phase?
5 A
- yes,
.6 Q
And what does the vehicle recall mean so that we 7
will all understand?
8 A
That puts you on the system, the vehicle recall.
9 Q
It puts you on the system?
10 A
Yes.
i 11 JUDGE SHON:
I don't understand what that means, 12 puts you on the system.
13 WITNESS MILLSPAUGH:
When the controller is set'
,j k
14 on recall it puts it on the system.
That's the control for 15 it.
16 BY MR. CHRISTMAN:
17 Q
Mr.'Millspaugh, excuse me, Judge Shon, and maybe 18 it will help.
In that letter that I gave you and it's LILCO 19 Exhibit 37 for identification, it says VR means -- I'm 20 sorry, it's page 2 three-quarters of the way down the page +-
21 VR means vehicle recall.
That says "VR ensures that an 22 initial green occurs in every cycle."
Is that correct?
23 A
(Witness Millspaugh)
Yes.
That's what puts it 24 on the system.
l 25 Q
This says that "VR ensures that an initial green l
i
!d
82801111 18875 marysimons 1
. occurs in every cycle."
That sounds like it's different h' -
2 from putting it on the system.
3 A
What it means is it's on a system and if you 4
have this call in, it will always return to the artery.
5 Q
Return.to the what?
6 A
To the artery, the main artery, which is the 7
system.
8 JUDGE SHON:
Is it correct that page 75, which 9
is the second page of LILCO Ex-36, the Manual of Traffic 10 Signal Design by Kell, is the. description given in the first 11 two paragraphs of that page the functioning of the recall 12 correct?
13 It says "If the recall is off the controller At,_)
14 operates in a full actuated mode and rests in the phase last 15 served, providing there has not been a serviceable demand on 16 a conflicting phase."
17 And it goes on, that if it is on, there are two 18 forms of operation and they are all ones that involve these 19 auxiliary portions of the cycle.
Is that a correct l
20 description there?
l 21 i;ITNESS MILLSPAUGH:
Yes.
What I'm saying is 22 when that switch is off, then it's an independent control 23 which I've been figuring that strange cycle length up there, 24 and when it's on for vehicle recall it allows instead of the 25 signals staying in the last phase served, the last phase to I
82801111 18876 Inarysimons I'
_J I
get a green, it will revert back to the artery each time
.(y 2
-rather than staying on the side road, for instance.
3 4
5 6
7 8
9 10 11 12 13 ij 14 15 16 l
'17 18 19 20 21 22 23 24 25
(
r 82801212 18877
~i j oewalsh' 1
Q Well, in the very next paragraph from the one
_'U, 2
Judge Shon was reading it says, "If the vehicle recall is on 3
there are two forms of operation, minimum recall _and maximum 4
recall."
5 Did either of those concepts, minimum recall or 6
maximum recall play any part in your calculations of minimum 7
and maximum times?
8 A
(Witness Mi113paugh)
No.
It's just a setting 9
on the controller to put it in the system ~or off the system.
10 (The witnesses are conferring.)
11 JUDGE MARGULIES:
Tell us what you are trying to 12 establish here, Mr. Christman.
13 MR. CHRISTMAN:
I'm trying to find out how much A
(,/
14 information we can derive from these timing sheets.
15 BY MR. CHRISTMAN:
(Continuing) 16 Q
Is there anything on these sheets that tells us 17 whether to use minimum or maximum recall?
18 A
(Witness Millspaugh)
Well, the table you are 19 Jooking at describes the independent operation of the 20 signal.
The bottom part of the page is describing of fsets, 21 in this case A, B and a D, three dif f erent prog rams which 22 are applicable during a signal system, when it's on.
- And, 23 that's the normal way this is shown.
It's shown as an 24 independent signal first and then it's shown in the system.
25 O
Let me ask you something about the other typ.e of l
l
82801212 18878 Joewalsh
-I 1
controller which you called a - Type 17 0.
I take it -- well,
_~a b'
2 let me refer you to about three pages further on.
It's Page 3
6 of this document, but it reads Sheet Number 4 of 8 at the d
pop.
I'm sorry, I think I've got the wrong one.
I think I 5
want the south service road rather than the north service 6
road.
7 A
The south service road?
8 Q
Yeah, Page 11.
It's Page 12 in this document.
9 Now, does this sheet and the others like it in this document 10 describe or show data for the Type 170 controller?
I 11 A
Yes.
12 O
Okay.
Now, the 170 controller acts like an 13 actuated controller again, doesn't it?
14 A
It acts very similar to what I drew up there.
15 Q
Okay, which means that the phase durations can 16 vary with the traffic demand.
17 A
Up to a maximum --
IB Q
Yes.
Look at Timing Plan 1 which is at the top 19 right-hand --
20 A
What page are you on again?
21 Q
It's Page 12 of this document, Sheet Number 4 of 22 some nunber, 4 of 8 I guess.
It says Model 17 0 traffic 23 signal microcomputer near the top, and it is for the LIE 24 south service road at Willis Avenue, the intersection we 25 have discussed quite a bit over the last couple of days.
82801212 18879 joewalsh 1
A Did you state a question?
\\/
2 O
Have you found it?
3 A
Yeah, I have it.
l 4
Q I wanted you to look at Timing Plan Number 1 and 5
I would ask you what the maximum phase length for Phase 1 6
under that timing plan is?
7 A
For Phas:e 17 8
Q Yes.
9 A
35 seconds.
10 0
35 seconds is a max.
Now, that --
11 A
That includes the clearances.
12 Q
Including the clearances?
Now, how do you know 13 that that's a max?
It says decimal value of, but it doesn't 14 say max.
15 A
Well, if you went through the same procedure I 16 did here you would find that the total -- let me see if I 17 can find it.
If you go back to Page 11 -- well, it's 70 18 seconds when it's on Timing Plan 5.
Now, I have to look --
19 it's right on the same sheet, I'm sorry.
It's on Page 12, 20 And the cycle length here is 85 seconds.
If you 21 look under that column headed DEC meaning decimal, the 22 second to the last column, it's 85.
That 85 1s the cycle 23 length.
24 Q
Okay.
And, so how is it from that that you know 25 that 35 seconds is the maximum?
B2801212' 18880 joewalsh
.I 1
A For Phase 1.
2 Q
How do you know that's a maximum rather than 3
some other figure?
it doesn't say maximum anywhere near d
that number.
I'm wondering how you are supposed to know.
5 A
I guess I'm just familiar with it.
6 Q'
Tell me, then.
Is there a manual instructing 7
people on either how to fill these sheets out or how to 8
interpret them?
9 A
Yes.
10 Q
And, was that --
11 A
You mean for the 170?
12 0
Yes, for the 170.
Who wrote that manual?
13 A
My department.
I,.
'(,
14 Q
I see.
15 A
Several people.
16 Q
What's it called?
17 A
The 170 is sort of an invention of the New York 18 State Department of Transportation and the State of 19 California.
20 0
And, how does one get hold of that manual?
21 A
I guess you could write us and you could get a 22 copy of it.
23 Q
But you didn't think it was necessary to include 24 that with the signal timing data as the necessary reference 25 for using --
1 l
l
.l l
82801212 18881 J oewalsh 1
A Well, I wasn't the one that supplied the
'7m
- g 2
information on the timing, so I --
3 Q
Who did supply the information?
4 MR. ZAHNLEUTER:
I will vouch for that, that I 5
supplied the information as the letter indicates.
6 BY MR. CHRISTMAN:
(Continuing) 7 Q
So, the information came from the regional 8
office to counsel and from counsel to you at the same time?
9 A
Yeah, I got it about the same time you did.
10 Q
Do you think you need that manual to help you 11 interpret these sort of sheets?
12 A
It would be helpful, yes.
13 Q
Okay.
Still talking about that Phase 1, the
)
14 Timing Plan 1 --
15 A
Are you still on Page 12?
16 Q
The same -- yeah, the same page.
What's the 17 minimum time for that phase?
18 A
I think you have to go to Page 11 to get that 19 type of information.
20 Q
Okay.
21 A
And that's where you pick up the information on 22 the clearances also.
23 Q
Okay.
But, that says Timing Plan 5 on page 11, 24 and we are talking really about Timing Plan 1, so how --
25 A
Well, these are the basic information for the LO
82801212 18882 j oewalsh
)
I l
intersection when it acts independently.
..J
/. \\
2 Q
So, you just have to know that Timing Plan 5 --
3 A
Yeah, they all work together.
4 0
You just have to kind of know that because --
5 A
yes.
6 Q
Okay.
7 A
I might say that these forms were put together 8
by a contractor, and the forms are somewhat -- slightly 9
different than what we normally use but similar, using 10 decimals and so forth.
11 Q
Now, if you go two pages further on to 14, it 12 says Sheet 6 of 8, it's also Page 14 of this document, again 13 it's an assignment of timing plans for various days of the i
,q
\\j 14 week.
And, that appears to be a schedule for when these 15 various timing plans go into effect; is that right?
16 A
Yes.
I 17 Q
Okay.
When do those timing plans' change?
I 18 mean, what time of day?
19 A
The first one, if you know the code -- if you i
20 look in the column with the heading " Hex-VAL" and come down 21 that column to where it says -- in that row where it says 22 Change 1, and it says 406, that happens to be 6 a.m.
23 O
And, how do you know the code?
24 A
From the Manual.
25 Q
From the Manual, okay.
Well, 402 I see -- did i,,13 l
L
l 82801212 18883 joewalsh I
each of these change then at.6 in the morning everyday of t0 -
\\'-
2 the week?
You've got a Monday, a Tuesday --
3 A
You also have for different days of the week, 4
too.
5 Q
When does TP Number 1 come on?
6 A
TP Number 17 7
Q Yes.
8 A
It comes up at 6 a.m.
9 Q
Okay.
So, if you know the code you can --
10 A
Yes.
6 a.m.
is the end of TP Number 2 and the 11 beginning of TP 1.
12 Q
Okay.
By the way, these pages we have been 13 looking at, starting with Page 11 it says Timing Plan 5 and i) 14 then the next sheet is Sheet 4 of 8 I think and then Sheet 5-15 of 8.
What happened to Sheets 1, 2 and 37 16 A
I'm -- where are you again now?
17 Q
Go back to Page 11.
18 A
Page 11.
19 Q
You have got a Timing Plan 5 and then you start 20 with Sheet Number 4 of 8 I believe it is, 5 of 8, 6 of 8.
21 Why are we missing Sheets 1, 2 and 3 of 87 22 A
I'm not sure I know, because these aren't our 23 normal forms.
I don't know what information might be 2A missing.
25 Q
Okay.
On Page 12, which is 4 of 8, look at O
i 82801212
'18884
[
j oewalsh
.I j
1 Phase 8 of Timing Plan 1, and the maximum time is what, 12 J
.pkl 2
seconds?
l 3
A 12 seconds.
4 0
Okay.
Now, on Page 10 of your rebuttal 5
testimony, the first rebuttal and not the second, you 6
mentioned about mid-page thut KLD used a figure of 24 7
seconds and actually it should be 12 seconds at this same 8
intersection, the Willis Avenue and south service road 9
intersection; is that correct?
10 MR. McMURRAY:
Could I have that page number 11 again?
12 MR. CHRISTMAN:
Page 10 of the first rebuttal 13 testimony I think.
I
().
14 BY MR. CHRISTMAN:
(Continuing) 15 Q
It says that KLD used an effective green of 24 16 seconds and the existing signal-operation only provides a 17 maximum of 12 seconds.
18 A
(Witness Millspaugh)
That's right.
19 Q
Now, do you get the 12 from this Sheet Number 4 20 of 8, Page 12 of this document?
21 A
Yes.
l 22 Q
Okay.
And, whera exactly is that?
That's the 23 12 we talked about?
24 A
In that last column there, yes.
25 Q
Timing Plan 1?
82801212 18885 L j o'ewalsh -
s 1
A Yes.
pt]~
-2 Q
That's your 12 seconds.
Now, if we could go 3
back to LILCO Exhibit 33 for identification, on Page 4 of 4
that document which is headed " Effective Greens" and -- it's 5
33 for identification, but it's one of the HCM printouts, EB 6
LIE service road and Willis Avenue, the hours 10 to 1.
- And, 7
again I'm talking about the fourth page in, " Effective B
Greens - Design. Analysis."
9 Now, there under southbound left, for the 10 protected movement you use an effective green time 6f 24 11 seconds I believe, right?
12
-A But you are talking about a different time 13 period than we were.
(
14 Q
Well, I was going to ask where you got the 24 15 seconds for this protected left turn southbound movement?
16 A
I have to check to see which timing plan was --
17 Q
Would you check?
I want to know what the source 18 of that 24 seconds is on LILCO 33.
19 (The witness is looking through documents.)
20 A
If we look at Page 14, that will give you the 21 timing plan in effect.
And, it's from 10 to 1 o' clock, and 22 that would be Timing Plan Number 2.
1 23 0
Okay.
Timing Plan Number 2, which would be over 24 on Page 12 I guess?
25 A
Yes.
i
-~ _-_--
l 82801212' 18886 joewalsh
-i 1
Q And, Phase 8 there looks to be 18 seconds.
j 7Ag
( /-
2 A
- yes, l
3 0
All right.
We've got_now 12 seconds and 24 d
seconds and an 18 seconds.
Which would you use?
5 A
you have to remember, we are looking at 6
effective greens here.
It's not -- so you can't compare the 7
green time on the controller with what is being tabulated in 8
the respective green column there.
9 Q
The effective green is the last number, the 10 lower number, right?
11 A
Generally, yes.
12 Q
Isn't there a discrepancy here?
13 A
I will have to do some calculations.
I haven't 14 done this myself.
15 Q
How long will it.take to do that?
16 A
A few minutes.
17 O
I've only got a couple of more cuestions.
I 18 guess we could take another break for you to do the 19 calculation.
Several minutes, you say?
20 A
Five or 10 minutes.
l 21 JUDGE MARGULIES:
Let's take a 10 minute break.
22 (Whereupon, a recess is taken at 3:05 p.m.,
to 23 reconvene at 3 :17 p.m., this same day.)
24 25
82801313.
18887 suewalsh 1
JUDGE MARGULIES:
Back on the record.
O' 2
WITNESS MILLSPAUGH:
This is -- looking again at 3
Page 12 of the timing sheet there, and we see for Phase 8 4
which is that southbound left turn, the maximum time on that 5
is 18 seconds including the clearances.
And that was a.
6 little distracting to me, because it came out the left turn 7
was shown as an effective green of 24 seconds.
8 And, I found out the reason for that is we 9
decided we wanted to -- as I said before during the day 10 about trying to maximize the greens for these critical 11 moves, and that's what we did.
We looked at the northbound 12 through movement which opposes this left turn for the sake 13 of analysis.
M(_)
14 The 24 seconds'is not the maximum time of the 15 signal 18 seconds is, including the clearances.
And, what 16 we did is we took the southbound through time, which was 48 17 seconds, and subtracted the northbound -- the ef f ec tive 18 greens and subtracted the northbound 24 seconds and came out 19 with 24 seconds.
20 BY MR. CHRISTMAN:
(Continuing) 21 Q
Did anybody actually go out there and time that 22 to see if that was accurate?
23 A
Well, this is for the sake of analysis.
24 Q
Did anybody go out there and look at what the 25 signal was really doing?
O
\\\\
i.'
S 18888 82801313 suewalsh l
1 A.
That's almost impossible to do when you have the s
_)
l' 2 'm.Lmulti-type coiltrol,, because you never know which ring it's 3
in.
d Q
_Do you know -- these things are dated April 18, 5
1985.
Has anybody gone out.since that time, do.you suppose, 6
to' verify any $f t.hese data?
7 A
We13, these, as far as I know, are the records 8
for the Department.
And the controller has one of these I
?
assume right at the -
inside the controller door.
I'm 10 assuming these are the latett.
11 Q
Would you send LILCO a copy of that manual you 12 mentioned on how to read these sheets?
13 A
Do.you want me to send you one?
~()
14 Q
Yeah.
15 A
Sure.
16 Q
I will pay for it.
Can you Federal Express it?
17 A
No.
We will send it to you.
18 Q
Did you folks meet with Suffolk County counsel 19 while you were preparing to testify today?
20 A
Yes.
21 0
Did ya'll meet with your counsel and Suffolk 22 County counsel I suppose in preparing to testify?
i 23 A
Yes.
24 h Q
More than once?
25 A
Yes.
82801313 18889.
suewalsh 7
1 MR. CHRISTMAN:
I believe that's all the I
k.
l 2
questions I have of this panel.
3
. JUDGE MARGULIES:
Mr. McMurray.
Excuse me, 4
before you start.
You didn' t of f er any of those exhibits 5
for identification.
6 MR. CHRISTMAN:
Yes, and you know why, it's 7
because the fire bell went off in the middle of it.
a I would like to offer all of them, 28 through 37 9
I believe into the r cord.
4 10 JUDGE 2MARGULIES:
Are there any objections?
11 MR. BACEMANN:
No objection.
12 MR. McMURRAY:
No obj ection.
13 MR. ZAHNLEUTER:
Yes, I have an objection to one 14 of those which is the letter from me to Mr. Christman.
I 15 think there is no reason to put a letter from counsel 16 produced during discovery into the record when the same 17 information was elicited during the cross-examination.
18 That letter is from counsel.
It's not 19 evidence.
The best evidence is from the mouths of these 20 witnesses, and they have given that testimony.
21 And, I object to what has been marked as LILCO 22 Exhibit 37 going into evidence.
23 MR. CHRISTMAN:
Let me respond.
Number one, I 24 see no harm in having it in the record.
Number two, some of 25 the questions depended on that particular letter and.the f)
'%)
82801313 18890 suewalsh I
i definitions in there.
2 And, I believe it should go in the record.
3 JUDGE MARGULIES:
Mr. Bachmann, did you want to 4
express an opinion?
5 MR. BACHMANN:
It appears tc me that there were 6
certain, as I recall, variances between what the witnesses 7
said and what the -- what was said in the letter.
And, I 8
think that to that extent I believe it should be admitted.
9 JUDGE MARGULIES:
All right.
It will be 10 admitted solely to the extent that the definitions were used 11 in examining the witness.
12 Exhibits 28 through 37 for identification are 13 admitted into evidence as LILCO exhibits.
14 (The documents previously marked as 15 LILCO Exhibits Numbered 28 through 1
16 37 for identification are admitted 17 into evidence.)
IB CROSS EXAMINATION 19 BY MR. McMURRAY:
20 Q
Mr. Hartgen, do you recall some questions 21 earlier from Mr. Christman regarding traffic travelling 22 southward on 107 towards the Hicksville reception center?
23 A
(Witness Hartgen)
Yes.
24 Q
Do you recall the discussion about background 25 traffic there possibly consisting of shoppers?
!O
1 1
82801313 18891
- suewalsh 1
A Yes.
,3
'%)
2 O
In your opinion, will the background traffic 3
there consist mostly of shoppers?
4 A
I don't think so.
That's a major commuting 5
route, north and south.
In fact, it's one of the major 6
routes that serves the Grumman plant that was referred to 7
earlier.
I would expect most of the traffic, particularly 8
in the a.m. and the p.m. peaks, would be commuters going to 9
work.
10 Q-It might also consist of commuters leaving that 11 area and going to other places to work, correct?
12 A
Yes.
13 Q
Mr. Millspaugh, I would like to refer you to
)
Suffolk County Exhibit 26 which is the signal timing data 14 15 that you have been asked so many questions about.
I promise 16 everybody I'm not going to ask for any calculations.
17 I just want to establish on the record that with 18 respect to the timing sheets, signal data sheets, for the 19 LIE south service road at Willis Avenue which are Pages.11, 20 12, 13, 14, 15, 16, you used the data in those pages for 21 your analysis of the intersection at the LIE south service 22 road and Willis Avenue, correct?
23 A
(Witness Millspaugh)
Yes.
24 Q
Can you obtain accurate signal timing data from 25 field observations?
82801313 18892 suewalsh l
1 A
Well, we've been talking about these s
[j' s
2
- microcomputer and the so-called solid state which is an 3
older generation controller, and as I've demonstrated it can 4
be rather. complicated figuring the timings.
And, depending 5
on how many phases you are talking about, if it's only a two-6.
phase signal, of course, it would be very simple to do field 7
measurements and measure the green peri ds; and, maybe three 8
or four phases might also be -- you might be able to do that 9
in the field, but when you get to the eight phases where 10 there are certain -- any number of possibilities where these 11 stages can combine and run concurrently, various 12 combinations and every cycle might be different from the 13 next cycle.
i 14 It'n virtually impossible to measure these in 15 the field when they get to be an eight phase, which would be 16 the full capacity of that controller.
17 I might say that if you had the information on is the paper, it really makes no sense to go in the field and 19 measure it if you had the data.
20 Q
That's because the data give you the actual 21 setting --
22 A
And, so I guess the answer --
23 Q
Excuse me.
24 A
Excuse me.
25 O
That means that's because the data on the paper
!d
i 82801313 18893 suewalsh I
1 gives.you the actual settings for the microcomputer, g,s
'd 2
correct?
3 A
Correct.
4 Q
And, if you go out in the field you have to make-5 estimates of what maximum green times would be, correct?
6 A
That would be very hard to get, as I say, on an 7
eight phase controller, fully actuated, to determine what 8
the maximum greens are, the settings.
9 O
Now, I would like you to get in front of you 10 please LILCO Exhibit 32 which is the State's analysis of the 11 eastbound LIE service road.
l 12 And, also Suffolk County Exhibit 24, which is 13 KLD's analysis of the LIE service road and Willis Avenue.
I 14 A
You will have to excuse us, because we have a 15 pile here to sort out.
16 (The witnesses are complying.)
17 Q
Okay.
Do you have those both in front of you?
18 Suffolk County Exhibit Number 24 is the intersection of the 19 eastbound LIE service road and Willis Avenue.
The name of 20 the analyst is R. Goldblatt.
The time period is 7 to 10.
21 Do you have that in front of you?
22 A
Yes, sir.
23 (Witness Hartgen)
Yes.
24 Q
And, LILCO Exhibit 32 is the same intersection, 25 the name of the analyst is BG, and it's also the same time
82801313 18894 suewalsh
-I 1
g period.
^l\\~')
2 Do you have that in front of you?
3 A
Yes.
4 Q
Okay.
Now, let's go to Page 7 of both documents 5
please where it says " Capacity Analysis Worksheet."
6 Now, this morning there was a lot of discussion 7
about whether or not the lef t permissive phase was included 8
in the analyses.
And, I just want to try and clear up this 9
question.
10 Looking first at Suffolk County Exhibit 24, 11 which is KLD's analysis, okay, for the southbound movement 12 there is no entry for lane group capacity for the lef t 13 permissive phase there, correct?
14 A
(Witnes.s Millspaugh)
Yes.
15 Q
I'm correct?
16 A
You are correct.
17 Q
And, the lane group capacity of 861 there is 18 calculated for the left protected movement; isn't that 19 correct?
20 A
Yes, that's right.
21 Q
Okay.
And, the v/c ratio is based on the left 22 protected movement, correct?
23 A
Yes.
24 Q
Okay.
So, that is also the same methodology, 25 although you came up with different numbers, as used in the
82801313 18895 suewalsh i:
1 State analysis, correct?
2 A-Yes, that's right.
3 Q
In other words, the v/c ratio is based on the 4
left protected movement in a southbound direction?
5 A
Yes.
6
. Q Just so we all understand, did I-understand 7
correctly that the Highway Capacity Manual software will not 8
print out or generate as shown here the left permissive lane 9
proup capacity?
10 A
Yes, that's right.
It does not put that out on 11 either analysis.
This is the same sof tware that is being 12 used by each group.
13 Q
Okay.
So, in order to take that into account, I) 14 what the analyst has to do is compare the demand for that 15 movement with the opposing movement; isn't that correct?
16 A
Yes, that's right.
That was the substance of 17 our testimony this morning.
18 Q
Okay.
And, looking at -- step back a second.
19 Just so we are all clear here, the adjusted flow rate is the 20 traffic demand, correct, not the supply?
21 A
That's right.
22 Q
Okay.
And, I take it that in comparing the 23 amount of left turning traffic in the permitted phase i
24 against the northbound traf fic, we see right above there 25 there is an entry of 1,250 cars, those are the numbers that fD s/
L
i
.82801313 18896.
suewalsh I
.J 1
you would compare, correc t?
(/.)
\\-
2 A
Yes, that's right..
3 Q
Okay.
And, in making that comparison does that
)
d change your opinion at all regarding the v/c ratio that 5
would exist at that intersection?
6 A
No.
The reason the v/c's are so different here 7
is that the KLD analysis assumes two left turn lanes and 8
ours assumes one.
And, that essentially accounts for our 9
conclusion that this intersection will not operate and I 10 assume it accounts for their conclusion that it will.
11 We have argued that the lane configuration there 12 is one lane assigned left and that is how drivers will 13 behave when approaching it.
We believe that one lane is the i
()l 14
-- that's the field picture and that's the way that it will 15 operate.
16 17 IB
'19 20 21 22 23 2A 25 I
(~
l
82801414 18897 joewalsh 1
Q So, in essence, tLat is where you and KLD differ
,.\\')
?
2 in your analysis of this intersection?
3 A
(Witness Millspaugh)
That 's by f ar the maj or 4
difference, yes.
5 O
Let's turn to your original rebuttal testimony, 6
Exhibit 9 which is your analysis of the intersection of 7
Sunrise Highway and the southbound Meadowbrook Parkway off-8 ramp.
9 A
Okay.
I have that.
10 Q
There you give the results of your analysis of 11 that ramp.
Could you please describe the characteristics of 12 the intersection of Meadowbrook Parkway and the Sunrise 13 Highway?
I) 14 A
Yes.
The Meadowbrook Parkway is a divided 15 freeway, basically north / south operation.
And, this 16 particular movement is the southbound Meadowbrook to 17 eastbound Sunrise Highway.
It is a one-lane ramp off the la Meadowbrook to the right.
It's a down-grade.
In other 19 words, the Sunrise is below the Meadowbrook.
20 The bottom of the ramp is controlled by a stop 21 sign, and there is no merge lane as you would normally find 22 in higher type interstate standards.
And, the presence of 23 no-merge lane and the stop sign is critical here because l
24 traf fic must come to a complete stop.
25 The Sunrise Highway is a six lane arterial, O
82801414 18898 joewalsh I
I three lanes in each direction.
And, for a very short I
i N-2 portion around this interchange, it has a divided appearance j
I 3
and it has a freeway type appearance.
But, just upstream d
from this location there are a whole series of 5
interconnected signals.
And, a quarter of a mile downstream 6
there are a series of signals including the one that we 7
talked about a few minutes ago, the one at Newbridge Road 8
and Route 27.
9 So, it is not a freeway to treeway interchange 10 at all but rather a stop sign of an entry road which allows 11 traffic to enter onto an urban arterial.
12 Q
Evacuation traffic, at least according to 13 LILCO's analyses, is routed southbound on the Meadowbrook
\\j 14 Parkway onto the eastbound Sunrise Highway via this ramp, 15 correct?
16 A
Yes, that's right.
17 Q
And, in your analysis you come up with various 18 levels of service ranging from D to F, mostly F.
Do you see l
19 that?
20 A
Yes.
21 Q
Mr. Lieberman, in his most recent submittal, 22 appears also to have analyzed this intersection.
Have you 23 read his analysis?
24 MR. CHRISTMAN:
Obj ec tion.
Beyond the scope of 25 the cross.
A
82801414 18899
-joewalsh l
r 1
MR. McMURRAY:
This is cross.
l j,
l
'2 MR. CHRISTMAN:
Abusive cross.
3 MR. McMURRAY:
I haven' t been abusive at all, f
4
. Judge Margulies.
5 MR. CHRISTMAN:
This is an attempt to supplement 6
the record and get in additional rebuttal testimony that 7
wasn't filed.
8 MR. McMURRAY:
I'm talking about data that were 9
put in two days ago.
These gentlemen should be able to 10 respond it they have an opinion.
11 MR. CHRISTMAN:
It's yet another phase of sur-12 surrebuttal.
13 JUDGE MARGULIES:
It's something that the Board 14 would like to hear.
15 WITNESS MILLSPAUGH:
Would you repeat the 16 question, please?
17 BY MR. McMURRAY:
(Continuing) 18 Q
Mr. Lieberman did an analysis of the same 19 intersection, correct?
20 A
Yes.
21 Q
Okay.
He came up with substantially higher 22 levels of service, did he not?
23 A
Yes.
24 Q
How do you account for the differences in your 25 results?
~O
\\
i 828014:4-18900 joewalsh 1
i 1
A Well, to answer that question I think I need to I
2 discuss this a little bit more.
First of all, while it 3
looks like a ramp, the stop sign is such that the o
4 intersection is, in fact, controlled by the stop sign.
5 We believe that the procedures for a ramp 6
analysis are not appropriate for this intersection at all 7
because it is a stop sign.
And, in fact, under the chapter 8
in the Highway Capacity Manual on ramps, the very first 9
paragraph says that the analysis is appropriate for merging 10 environments.where stop signs are not present, and 11 specifically told not to use it if there are stop signs 12 there.
13 Secondly, as I said earlier, the Sunrise Highway 4
14 is not a freeway but an urban arterial.
And, so the ramp 15 analysis methodology which is basically an analysis of 16 freeway to freeway connects is not appropriate.
17 And, so for those two reasons we used the 18 methodology in the unsignalized intersections portion of the 19 Manual.
When -- excuse me.
We began with the same traffic 20 numbers that KLD began with; that is, an entry volume of 21 672.
When we calculated the performance o'f that 72 intersection we treated it as an entry of 672 cars entering 23 onto a three lane one-way urban arterial, which is the 24 circumstance as described there.
25 Our analysis is shown on this exhibit, but d'
82801414 18901 joewalsh 1
basically we concluded that the movement would be way over 7Qi 2
capacity.
It would not be enough capacity to handle it at 3
any of the four time periods.
4 Looking at Lieberman's analysis, we discovered 5
that he analyzed it as a ramp and estimated the volume in 6
the lane closest to the stop sign using the procedures in 7
the ramp portion of the Manual.
When we looked further, we 8
concluded that the nomographs which were used for this 9
analysis may have been not appropriately applied.
10 The nomograph which was used specifically says 11 that the volume on the freeway has to be above 2,400 cars 12 and the volume on this arterial, which is not a freeway, is 13 only 1,100 cars, way out of the range of reasonableness for
()
14 the use of the methodology.
15 We then applied the methodology in a parallel 16 nomograph, Figure 5.7, and we got from that calculation a 17 number almost identical to ours of 799 vehicles in the left 18 lane.
I'm sorry, the right lane, n
So if, in fact, the right nomograph had been 20 used and then the analysis had proceeded into the stop sign 21 chapter, they would have reached the same conclusion we 22 have.
These three differences, the existence of the stop 23 Sign, the fact that it isn't a freeway at all, and the 24 possible misuse of the nomograph produced the very large 25 difference in results.
l O
i
82801414 18902 j oewalsh i
1 We stand by our methodology.
We believe we
_7-4
\\_h 2
calculated this in a way which is accurately descriptive of l
3 what's out there.
4 Q
Dr. Hartgen, you in your testimony criticized 5
LILCO for not using as input data in their analyses of the 6
intersections the actual traffic counts that they took and 7
which are reflected on some of the traffic count data that l
8 have been introduced as exhibits in the last couple of days.
9 Do you recall your testimony on that?
10 A
(Witness Hartgen)
Yes.
11 Q
Okay.
Now, it's true, isn't it, that in order 12 to run the HCM software you have to have input data 13 regarding the various movements at the intersection,
)
14 correct?
15 A
Yes.
You need movements for the full 16 intersection picture.
17 Q
Okay.
And, it's also true, isn't it, that the 18 traffic count data that LILCO took generally consisted of 19 the evacuation movement and then all other traffic; is that 20 generally correct?
21 A
Yes, I think that's generally true.
22 Q
Let me, for instance, refer you and the parties l
23 to Suffolk County Exhibit 27.
These are the count data for 24 the southbound Old Country Road and Route 107, correct?
25 A
Yes, that's right.
l J
l 82801414 18903 joewalsh 1
O Okay.
And, the data taken were for the left j
O 2
turn which is the main evacuation movement, correct?
3 A
Yes.
4 Q
And, then also the other traffic going in, 5
either straight or to the right, correct?
6 A
Yes.
7 Q
Now, those data don' t contain then breakdowns 8
for all the movements taken at that intersection in that 9
direction, correct?
10 A
That's right.
The through and the right are 11 combined under the term "other."
12 Q
If you needed to run the HCM software and you
, 13 are confronted with a situation where you had actual data n
(..)
14 for one movement but more general data volume for the other 15 movements, what would you do to go about getting the proper 16 turn movement percentages?
17 MR. CHRISTMAN:
I obj ect to this line of 18 questioning.
It's improper sweetheart cross-examination 19 that has been disapproved by the Board in the past.
20 MR. McMURRAY:
v'dge Margulies, this is a main 21 point of contention between the parties, and I think that we 22 have these gentlemen here on the one hand saying that LILCO 23 erred not using actual data.
We have Mr. Lieberman on the 24 other hand who has used percentages taken from counts on 25 other days.
l L
82801414 18904 joewalsh I-1 There-is the question of how should it have been
. -4 2
'done, and I think these gentlemen are willing to offer their 3
opinions on that li the Board wants to hear it.
4 JUDGE MARGULIES:
Because of the complexity of 5
the issues involved, the Board would like to hear it.
6 BY MR. McMURRAY:
(Continuing) 7 Q
Dr. Hartgen, please go ahead.
If you need to 8
use the easel, do so.
9 A
First of all, looking at this Exhibit 27 the 10 Board will see that there is a considerable amount of data 11 here, and for the three time periods involved there is 12 detailed data for each of the 15 minute intervals, for each 13 of the three hours.
And that data is repeated for the other G-Q d
14 time periods.
s 15 Since the critical piece of information being 16 sought at this intersection is the volume of background 17 traffic on the left turn, that is appropriately the top item 18 on the priority list.
And, KLD appropriately counted that 19 movement very extensively.
I believe this is just one page 20 of four days of tube counts that were taken at that 21 location.
l 22 The other count information is considerably of 23 less interest.
Rather than apply a percentage back to the 24 good number, which was obtained from a very detailed set of 25 information on this turn, the percentage I referred to is a
!O
82801414 18905 j oewalsh '
1 1
percentage based on a very short time period, I believe in q
2 the Spring of 1987 and I believe it was for less than an 3
hour of time.
4 Had this been my responsibility, I would have 5
supplemented the left turn count with' additional road tube 6
counts of the other movements at a later time.
I would not 7
have reduced the value of the left turn count by replacing 8
it with another number based on a much shorter period of 9
time.
I would have essentially led from my strength and 10 would have added to the good data which I had already-11 collected.
12 I do not understand, and I have not been able to 13 understand, in this proceeding why it is that that process
()
14 was not followed.
It seems to me that additional counts.
15 expanding the detail of the other turns should have been 16 added to the very extensive data that was originally 17 collected which we believed was accurate and, in fact, which IB we used.
19 So, that's how I would have gone about it.
20 Q
It's your understanding, isn't it, that LILCO 21 took observations of the same intersections at some later 22 time to determine the percentage of all turn movements; is 23 that correct?
24 A
Yes.
25 Q
Okay.
And, at the particular intersection we 1
1 1
l 82801414.
18906 Joewalsh I.
--J l
are talking about, 107 and Old Country Road, approximately 2
how long d2d that observation take?
3 A
I believe it was approximately an hour on a d
weekday in March.
But, I do not remember the exact date.
5 March of87.
l 6
Q And, when you say lead with your, strength, you 7
are saying when you have a larger volume of data you should 8
not alter it with a smaller set of data; is that --
9 A
Yes, that's right.
The larger volume of data is 10 likely to have less variation and be more accurate.
- And, 11 the data based on the smaller time period is likely to be 12 more questionable.
13 And, in this particular case, as I recall, the 14 change was very substantial.
The change was made from an 15 average of 152 down to an average of only 77 or slightly 16 more than half or approximately half of the traffic.
It 17 seems to me that the original number of 152 should have been 18 allowed to stand.
And, if more counts were needed on the 19 other turns they should have been obtained.
20 0
There has been discussion about the intersection 21 of Willis Avenue and the eastbound LIE service road.
22 Yesterday I believe it was Mr. Lieberman discussed the 23 sensitivity analysis he conducted regarding that 24 intersection.
25 Do you recall that?
82801414 18907 joewalsh 1
A Yes.
I(
2 O
Okay.
Have you conducted any analysis of any 3
sort to-determine how much evacuation traffic can be handled 4
or the percentage of evacuation traffic that can be handled 5
given the background traffic at that intersection and the 6
assumption that traffic would be turning left only from the 7
left-hand turn bay?
8 MR. CHRISTMAN:
Objection.
I have a suspicion 9
this is talking about some sort of new analysis that we have 10 not yet seen.
If so, it's an improper attempt to supplement 11 the record.
12 MR. McMURRAY:
It's no different from Mr.
13 Lieberman's sensitivity analysis yesterday which we hadn't.
(
14 seen.
1 15 MR. CHRISTMAN:
If what's meant is the 16 calculations he did on the stand, that's altogether 17 different I think from this.
18 MR. McMURRAY:
I think Dr. Hartgen is perfectly 19 ready to explain his calculation.
The only question is, 20 given the background there how much room is lef t for 21 evacuation flow.
That's what I would like Dr. Hartgen to be 22 able to explain.
23 MR. CHRISTMAN:
If this refers to an out-of-24 court analysis that has not been subject to discovery and 25 has not been produced to the parties, I obJ ec t.
82801414 18908 joewalsh I
1
.y; MR. McMURRAY:
It's no different from Mr.
'k' 2
Lieberman.
3 JUDGE MARGULIES:
Well, when did you make this
'd analysis, Mr. Hartgen?
5 WITNESS HARTGEN:
We began this about a week ago 6
and have discovered it's very complicated.
The conclusion 7
was reached yesterday.
8 MR. CHRISTMAN:
I do object.
This is a 9
su rprise.
And, I don't know what Mr. McMurray is referring 10 to, but we had discovery almost right up to the hearing on i
11 Mr. Lieberman's analysis.
The ramp analysis were turned 12 over to the County.
13 MR. McMURRAY:
Judge Margulies, if you recall,
- r 14 when I asked Mr. Lieberman, have you done a sensitivity 15 analysis regarding that intersection of Willis Avenue and i
16 the LIE service road eastbound, he said yes, he had.
And, I 17 said when.
Yesterday.
18 Okay.
I didn't inquire further into that.
- But, 19 then Mr. Christman asked about that very sensitivity 20 analysis yesterday.
The situation is no different here.
21 MR. CHRISTMAN:
I think there is a significant 22 difference.
What Mr. Lieberman did was simply in preparing 23 to testify the day before.
What's gone on here sounds like 24 a week -- work over a week that no on knew about until now.
25 (The Board members are conferring.)
'l'(
_-----__-_:_L________--_TL
.82801414 18909 j oewalsh 1
JUDGE MARGULIES:
We have been very liberal in 2
our rulings, but we have to draw the line some time.. We 3
.wil) draw it here and not permit the question on this new 4
analysis.
5 MR. McMURRAY:
Judge Margulies, I would like to 6
make an offer of proof that if Dr. Hartgen were permitted to 7
state what his analysis was he would say that in comparing 8
the background traffic and then evaluating how much capacity 9
was left that there would be capacity only for 3.5 percent 10 of the EPZ traffic to go to the reception centers.
11 That's a significant number, in that it shows 12 that only 3.5 percent of the EPZ could travel to that 13 reception center and, therefore, that LILCO's traffic plan I) 14 would not work.
15 JUDGE MARGULIES:
Your offer of proof is on the 16 record.
.17 18 19 20 21 22 23 24 25
82801515 18910 suewalsh q
~
i 1
MR. McMURRAY:
I have no further questions.
_f'.'
2 JUDGE MARGULIES:
Mr. Bachmann.
(
3 MR. BACHMANN:
The Staff has a few questions, 4
but may I request that we have about a 10 minute recess so I 5
can organize some of these documents?
6 JUDGE MARGULIES:
Let's take a 10 minute recess.
7 (Whereupon, the hearing is recessed at 4:00 8
p.m.,
to reconvene at 4:13 p.m.,
this same day. )
9 JUDGE MARGULIES:
Back on the record.
10 CROSS EXAMINATION 11 BY MR. BACHMANN:
12 Q
I will address my questions to the panel, but L
13 whoever feels they can -- they are the proper person'to ir~
1 14 answer it, will you please just answer it.
15 Referring to your rebuttal testimony filed on 16 May 27 -- and this is sort of a general question, so I don't 17 think you necessarily need the testimony in front of you.
18 As I understand it, in your rebuttal testimony 19 you reanalyzed the analyses done by Dr. Lieberman in KLD TR-20 201; is that correct?
Or, at least part of his analysis?
21 A
(Witness Hartgen)
If you are referring to the 22 signal aralysis, yes.
23 Q
I'm sorry, if I'm referring to which?
24 A
Are you referring to the signal analysis here, 25 or are --
L
l 82801515 18911 suewalsh p-1 Q
I'm talking about -- you have, starting on Page 2
- 3. of your May 27 rebuttal testimony, a section of New York 3
State Department of Transportation analysis of KLD TR-201.
/
Now, that's essentially a capacity analysis, is it not, that 5'
you did?
6 A
Yes, essentially.
7 Q
And, you did it on part of what had been done in 8
TR-201?
In other words, three_ target intersections plus the 9
Meadowbrook Parkway one?
10 A
Yes, I believe that's right.
11 Q
And, in doing that analysis you -- so, you 12 didn't reanalyze everything that was done in TR-201; is that 13 correct?
I 14 A
Yes, that's right.
15 Q
Now, in doing that analysis in the May 27 th 16 testimony, you used HCM techniques; is that correct?
17 A
YeJ, we used the software based on the HCM.
18 Q
But you did not use HCM techniques in your 19 original analysis in your direct testimony, the so-called 20 CARS model.
That is not an HCM model; is that correct?
21 A
We all used the same methodology which is based 22 on the HCM.
That document came out quite some time ago.
23 The software, which allows you to do it easily and rapidly, 24 came out much later.
25 And, I frankly don't recall whether some of AV
_m
l 82801515 18912
)
suewalsh i
, -q I
..a 1
those earlier calculations were done by hand or whether they sd
?
were done with, as I said earlier, beta versions of the 3
software or possibly even the final version.
4 Q
Now, we are talking about the CARS model now.
5 A
Well, the CARS model is a different methodology.
6 Q
Than the HCM technique; is that correct?
7 A
Yes.
It has some similarities in the 8
intersection area.
9 Q
Do you -- now that you have the HCM software, do 10 you intend to continue to rely on your findings made by the 11 CARS model?
12 A
This portion -- the portion of this document 13 which refers to the use of the CARS network, as opposed to 14 the intersections, we would rely on.
In 201, we redid the 15 calculations that we had done earlier for the intersections 16 which are in the initial testimony.
And, for that we used 17 the HCM software since it was much more efficient to do so.
IB Q
It's true though that none of the scenarios that 19 you analyzed using the CARS model were the same as the 20 scenario postulated by Dr. Lieberman; that's true, isn't it?
21 A
Yes, that's right I believe.
22 0
I would like to refer you to the Page 9-5 of the 23 Highway Capacity Manual.
It was referred to earlier.
This 24 page was also referred to earlier.
25 A
9-5?
l 1
q
- 82801515 18913 suewalsh
~
b 1
Q Yes.
'~'
2 A
Okay.
We are with you.
3 Q
Fine.
Now, the chapter is entitled " Signalized 4
Intersections;" is that correct?
5 A
Yes.
6 Q
And, Mr. Christman earlier had quoted from this 7
page concerning level of service F; is that correct?
e A
Yes, he did.
9 Q
You did agree with that statement that was 10 quoted previous, the statement that Mr. Christman quoted-11 about the level of service F?
12 A
Certainly.
13 0
Okay.
Now, if you look at the next section 14 which is entitled " Relating Capacity and Level of Service,"
15 where they talk about, in the second paragraph, where they 16 could have high delays with v/c ratios less than unity; and, 17 then the third paragraph says that you could get a v/c ratio 18 equal to one and still "may have low delays if (1) the cycle 19 length is short and/or signal progression is favorable for 20 the subj ect movement.
Thus, the designation of level of 21 service F does not automatically imply that the intersection 22 approach or lane group is overloaded."
23 Do you agree with that statement?
24 A
Yes, but the two caveats I think both apply 25 here.
The first one says under conditions of short cycle
(,
m
l 82801515 18914 i
suewalsh j
'I I
1 length, and that is not the case here.
We have
/
2 intersections of long cycle lengths.
{
3 And, the second caveat says s'idnal progression 4
is favorable.
There is no signal progression at all at 5
Willis Avenue.
And, signal progression is only partial on 6
the Sunrise Highway operating at various times, and signal 7
progression on Old Country Road and 107 is a minor portion 8
of the total focus on the intersection there, as I recall.
9 We believe we analyzed the intersections 10 cbrrectly, given that they did not have significant 11 interconnection.
This paragraph is I think describing a 12 circumstance in which a progression series of signals has 13 been timed, tuned if you will, as a series in such a way (t~k
)
14 that it produces a very, very high throughput volume at or 15 just below level of service F.
16 That requires great skill on the part of drivers 17 and traffic engineers to build and operate those devices.
18 MR. BACHMANN:
I would like to hand out a 19 document at this point.
I ask that this be marked for 20 identification as Staff Exhibit 1.
21 (A document is distributed.)
22 JUDGE MARGULIES:
The four-page document with l
23 the heading " Planning Division, New York State Department of 24 Transportation, Transportation Analysis Report" will be 25 marked Staff Exhibit Number 1 for identification.
1 l
't l
l
c02801515 18915 suewalsh 1
(The document referred to is marked 5
~
2 as Staff Exhibit Number 1 for 3
identification.)
4 BY MR. BACHMANN:
(Continuing) 5 Q
Dr. Hartgen, could you identify this document 6
for the record, please?
h-7 A
(Witness Hartgen)
Yes.
This is several pages 8
from a report I wrote several years ago on the procedures 9
for improving the way that New York State collects and 10 processes traffic count data.
I am one of the authors and 11 so is John Lemmerman.
12 Q
Going to Page 12, numbered Page 12, which is the 13 second page of the document, they are referring to trucks at 14 that point; is that correct?
Or, you are referring to 15 trucks as the case may be?
16 A
Yes.
17 Q
Would you read the first full sentence, please?
18 A
"Although FHWA provides standard formulas for 19 the computation of such factors, New York DOT has not 20 traditionally undertaken such corrections unless the percent 21 is large, e.g.,
above 20 percent multi-axle vehicles."
22 Q
Do you still agree with that statement?
23 A
We undertake such corrections now for other 24 accounts.
The technology has evolved in the last four 25 years, but we still do not do it regularly.
A l
18916 82801515
~
suewalsh I
1 Q
All right.- Would you read under the section 1
y4 2
where it says " Accuracy of Raw Counts" the --'would you read 4
the first two sentences, please?
4 A
"It is well known that various mechanical 5
devices and manual counts will not always yield identical 6
results.
Differences in clock time, sensitivity of 7
recording devices to vehicle pass-over, multi-axle vehicle l
W proportions,'and mechanical equipmentsfailure or malfunction 9
all combine to introduce error."
10 Q
Do you still agree with that statement?
11 A
,Certainly.
I might point out that portions of 12
-titiis document which are not shown here quantify the h ' _,
13 magnitude of those differences which, as I recall, was in
~.
'I 14 the range of about three percent.
'l 15
.O The second line from the bottom on Page 12,
);
16 numbered Page 12, has a reference number of 19.
Do you see I
17 that?
18 A
yes.
29 0
And, I think I've included the references.
20 A
Yes.
21 MR. BACHMANN:
I have another document here that 22 1 will ask be mazked as Staff Exhibit Number 2 for 23 identification.
24 (The document is distributed.)
25 JUDGE MARGULIES:
The one page document headed j
! [)
C
/x i'f.
82801515 18917.
suewalsh
,,y 1
" Planning Division, New York State Department of p_b 2
Transportation, Transportation Analysis Report 7" with a 3
date of March 1982 will be marked Staff Exhibit ljumber 2 for 4
identification.
5 (The document referred to is marked 6
as Staff Exhibit Number 2 for 7
identification.)
B BY MR. BACHMANN:-
(Continuing) 9 Q
Dr. Hartgen, is this the document that was 10 referred to in your paper as Reference Number 19?
11 A
(Witness Hartgen)
Yes, it is.
12 Q
Going back to the Page 12 of Staff Exhibit 1,-
13 that sentence that refers to Staff-Exhibit 2, does that
()
14 indicate that the Staff Exhibit 2 is a study of counting the 15 same trsffic at the same location for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
16 A
Yes.
17 0
Now, in the abstract, which is essentially all is you have of Staff Exhibit 2, it is a13 you have, just one 19 page -- it is the abstract, is it not?
20 A
Yes, that's right.
21 Q
Now, is there a sentence in that abstract where 22 they talk about for an hour the variation may be as much as 23 20 percent, daily variation as much as two percent?
24 A
Yes.
That's in the middle of the abstract.
25 Q
So, would you say that one of the things in this Gb
-A
82801515 18918' suewalsh I
I study would be that the variation between two means of
(' %
2 counting the same data may vary as much as 20 percent in a 3
single hour?
4 A
As much as means exactly that.
It means that's 5
the range.
The average variation in the methodologies, as I 6
recall, is about six percent for the hour data and 7
considerably less than one percent for the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> data.
8 Q
Okay.
Based on that, would you say that if you 9
counted the traffic volumes at the same place on two 10 different days by two different methods you could have maybe 11 even more than a 20 percent difference?
12 A
Now you've introduced another fcctor.
This 13 study was very carefully controlled to determine the effect
]
h( )
14 of the accuracy of the devices themselves.
15 Traffic from day to day would easily vary by 15 16 percent.
And, if the two days you were referring to were a 17 Friday and a Sunday, the variation could be very, very IB large.
It might be as much as 80 percent.
So, if you used 19 different methods on two different days you could not sort l
20 out the effect of the methods versus the effect of the days.
21 22 23 24 l
25
..:-a-._- _ -
..._.-.A
l 828016,16 18919 Joewalsh 1
Just continuing my answer a little bit here, O'-
2 these two studies are a portion -- describe a portion of the 3
work I have conducted relating to the accuracy of traffic 4
systems, and I believe they underscore my points earlier 5
about the importance of getting data for as long a period of 6
time as you can possibly afford to do so, so that short 7
variations in those statistics will, in fact, be damped out 8
over time.
9 That is why we try to do as much mechanical 10 counting for long periods of time as we possibly can.
11 Q
Earlier you asked about the stop sign, the 12 Sunrise Highway /Meadowbrook Parkway exit.
13 A
Yes.
()
14 Q
I think that is even referred t'o starting on 15 Page 14 of your May 27, 1987 rebuttal testimony.
It is not 16 necessary.
We all know what was said.
17 A
Yes, sir.
18 Q
What would be -- let me rephrase that.
Isn't it 19 correct to say that if there were a traffic guide such as a 20 Nassau County Policeman stationed at intersection directing 21 the traffic through the stop sign, and otherwise controlling 22 the traffic on Sunrise Highway that that would greatly 23 increase the capacity of that particular intersection?
24 MR. ZAHNLEUTER:
I obj ect to this speculative 25 question.
O i
i l
82801616 18920 joewalsh I
1 MR. BACHMANN:-
I think this is an expert who can f-)
i
/
2 give his opinion.
3 MR. ZAHNLEUTER:
The question assumes Nassau 4
County Police Officer at that intersection, and there is 5
nothing in the record for us to substantiate that 6
assumption.
7 JUDGE MARGULIES:
We will permit the question.
8 WITNESS HARTGEN:
As I recall, our calculations 9
at that intersection, we had a traffic volume coming down 10 the ramp of 672 I believe it was, and a crossing volume of 11 about 7 80.
12 The result was that our analysis showed that the 13 ramp would be very substantially over capacity.
That is 14 1400 or 1500 cars through what is essentially a T-15 intersection in an hour.
16 That is too far above capacity to be 17 substantially assisted by any individual.
18 BY MR. BACHMANN:
(Continuing) 19 0
I thought your testimony earlier this af ternoon 20 was the big problem with that intersection was the fact it 21 was a stop sign rather than a merging type of freeway 22 situation.
23 A
(Witness Hartgen)
Well, my problem was it had 24 not been analyzed correct]y in our view.
It should have 25 been analyzed as a stop sign, and when done so, showed to be
82801616 18921.
Joewalsh 1
over capacity.
2 That means Level Service F.
We can't change the
.3 geometrics of the intersection.
The stop sign is-there.
4 You have to analyze it according to how it now is operating 5
in the field.
6 Q
I guess my question was, though, if the stop 7
sign was overridden by some sort of traffic control, that 8
would increase the capacity, would it not?
9 A
As I understand the import of your question, it 10 is that if the stop sign were overridden, the movement would 11 function as a freeway ramp.
12 O
Well, more like a freeway ramp than a T-13 intersection with a stop sign.
In other words, someone
-( )
14 could direct the traffic on Sunrise Highway to allow cars to 15 flow freely off the Meadowbrook Parkway ramp, and that would 16 '
Ancrease the capacity, would it not?
Over that of just a 17 plain, bare stop sign?
18 A
If the stop sign were removed, without the 19 individual being present, you might.get an increase, and I 20 think if you went through calculations you would show that.
21 I can't say what the effect of an individual 22 there would be.
There is no merge lane.
It is a very, very 23 constricted intersection, with almost no sight distance in 24 either direction.
25 Q
Okay.
Referencing Rebuttal No. 2, the second l
L=____-_-.___-____
18.
82801616 18922 J oewalsh I
_/-(
l sequel, the answer on Page 14, Question and Answer 13.
Yl 2
(Witnesses peruse document.)
3 Q
(Continuing)
Looking at the first paragraph of 4
your answer, where you state:
The problem with the KLD 5
analysis is there is no analysis of the capacity of highway 6
sections between intersections.
7 Ernphasis on, "between."
8 Can you specliy any particular locations on 9
these routes where you think that mid-block capacity would 10 control the route capacity?
11 A
One that comes to mind certainly is 107 between 12 Old County Road and Southern State Parkway.
13 There is a two lane portion of that road there 14 which has maximum capacity somewhere in the range of 1500 15 vehicles in the northbound direction.
16 The northbound movement of the key intersection 17 at Old Country Road.
Also, I believe from our own analysis 18 showed a total intersection capacity of something very close 19 to that.
If you will give me a second, I could actually 20 look that number up, but I think it was also in the range of 21 1500 and there was a case where we were concerned that it l
22 could very easily be that the link capacity controlled 23 access to that northbound right.
24 Q
Are there any other locations you considered?
25 A
Not that I am immediately aware of, but there L
82801616 18923
'joewalsh I
are a number of other sections of two lane road throughout Q
2 the Island that-are used for evacuation approaches to Long 3
Island Expressway.
4 We also looked at other routes, Route 25, 25-A, 5
and those routes typically widen out at intersections 6
substantially.
Many of the intersections have three, four 7
bays.
8 Essentially, you have got a big interchange, and 9
a small pipe feeding it.
We believe that prudently that 10 should have been carefully analyzed.
11 MR. BACHMANN:
I have no further questions.
12 (Board confers.)
13 JUDGE MARGULIES:
This panel was examined by Mr.
I) 14 McMurray on Mr. Lieberman's analysis pertaining to the 15 Meadowbrook and Sunrise Highways intersection af ter Mr.
16 Christman had conducted his examination.
17 So, he has not had an opportunity to cross 18 examine on that aspect.
Do you wish to cross examine the l
19 panel in that area.
20 MR. CHRIbTMAN:
On the Meadowbrook Ramp?
Yeah.
21 JUDGE MARGULIES:
You may.
22 OROSS EXAMINATION b
23 BY MR. CHRISTMAN:
24 0
With regard to the traffic coming onto that ramp 25 onto that Meadowbrook Parkway ramp, don't the upstream
{
~
82801616 18924' Joewalsh l
I signals create gaps in the traffic before the traffic --
_O s)-
2 well, create gaps in the traffic along Sunrise Highway?
3 Aren't there gaps in the traffic along Sunrise d
because of signals upstream?
5 A
(Witness Hartgen)
Well, there are gaps in all 6'
traffic.
Signals tend to platoon traffic, but as traffic 7
moves downstream from such signals, it tends to spread out 8
again, thereby making the gaps more uniform and smaller.
9 Q
Right.
Right at that ramp there are substantial 10 gaps in the traffic ordinarily, aren't there?
Have you been 11 there?
12 A
Yes.
13 Q
Aren't there substantial gaps in the traffic 14 along that -- right at that point?
15 A
I am not sure what you mean by the word, 16
" substantial."
I have only been there once, and it was a 17 very short visit.
IB Q
Did you see gaps in the traffic?
19 A
Yes.
But I see gaps in all traffic.
20 Q
Isn't that Meadowbrook ramp traffic onto Sunrise 21 merging into the traffic stream rather than crossing it?
22 A
It is combining with the traffic stream.
23 Q
It is an acute angle, isn't it?
I mean, it is 2d not anything like a T-angle.
It is an acute angle.
25 A
We believe that intersection operates like a T,
.1
82801616' 18925 joewalsh 1
because the stop sign is there, and requires the vehicles to
(_s 2
stop individually and observe the traffic flow from the 3
left.
4 0
I understand that, but it is a very acute angle 5
isn't it?
It is not anywhere near a T in reality as far as 6
the geometry?
7 A
I don't believe the angle is less than 35 8
degrees.
It is a blunt angle as far as ramps go for sure.
9 Q
Let me show you a picture of it.
Just pass it 10 all the way around.
11 A
Okay.
12-(Mr. Christman passes photo to the witnesses.)
13 Q
Do you call that a blunt angle?
()
14 A
You can't see the bluntness of the angle.
It is 15 hidden behind the red car, but I will stand by my 16 statement.
It looks very blunt to me, and it looks like 17 more than 35 degrees.
That was one of the most amazing 18 ramps I have ever been on.
19 0
If you wouldn' t mind just passing it around the 20 room and we will get it back to us.
I don't have enough to
\\
21 put in the record.
22 (Photo is shown to Board and to counsel) l 23 Q
(Continuing)
Have you observed whether the j
24 traffic coming off that ramp uniformly stops at that stop 25 sign, or on the other hand whether they sort of slide l
L.
A
___________a
82801616 18926 j oewalsh 1
J l
-e through, as people sometimes do?
I 2
A We stopped.
3 Q
A lot of cars don't come to a full stop at that d
stop sign, isn't that true?
5 A
I am not aware of any studies of the stopping 6
behavior at that location.
Cars are required to stop at 7
stop signs under New York State law.
8 Q
I know that.
But you have been there.
Didn't 9
you observe the cars frequently don t come to a full stop at o
10 that stop sign?
11 A
No, I did not observe that.
12 O
You didn' t observe that.
How long were you 13 there?
i~N.
k_),
.A I observed cars stopping.
We were there several 14 15 minutes.
16 Q
Several?
How many minutes?
17 A
I don't recall.
IB Q
Don't recall?
Was it fewer than ten minutes?
19 A
Yes.
20 Q
It was fewer than ten minutes.
Was it fewer 21 than five minutes?
22 A
1 believe so.
23 Q
Was it fewer than four minutes?
24 A
I would say approximately four minutes.
We
'25 pulled off on the shoulder and observed.the situation I,-t.
'82801616 18927 joewalsh 1
there.
Several cars went by us.
2 Q
Several cars?
How many?
3 A
Less than a dozen certainly.
4 Q
Thank you.
And you say that every one of them 5
m'de a full stop at that stop sign, is that right?
Is that 6
your testimony?
7 A
No.
I said earlier that I had not done a stop 8
sign analysis -- an analysis of car behavior at that 9
l oc a t i.on.
10 Q
Isn't it true that the Highway Capacity Manual, 11 Chapter 10 procedures --
12 A
Excuse me, but in any case, it would be highly 13 imprudent for any analysis to be based on the assumption
()
14 that cars would not stop.
15 0
Well, it would be prudent to base an analysis on 16 what actually happens in the real world, wouldn't it?
17 A
I will stand by my statement.
l 1R Q
Isn't it true that the Highway Capacity Manual 19 Procedures, Chapter 10, are limited to two lane approaches?
20 That is, two lanes in one direction?
21 A
Two lanes in one direction.
Yes, we accounted 22 for that.
I might point out here that the Applicant also 23 used the same methodology.
24 Q
Sunrise Highway is three lanes isn't it in one 25 direction?
Ds
'V
f:
I 1
\\
l 82801616.
18928 i
joewalsh j
I I
l I
1 A
Yes.
The Applicant's input was based on one 1
.e4 b
2 lane crossing volume, which he. computed from the ramp i
3 analysis.
We used a two lane crossing volume, which we 4
computed from the directional flow, times a factor of two-l 5
thirds.
6 Q
Isn't it true that the Lane 1 volume on Sunrise 7
Highway, right hand lane, going toward the East, in the 1.
I 8
presence of heavy on-ramp traffic at that ramp, would be a 9
lot less than one third the total volume for all the lanes 10 on Sunrise Highway?
11 Lane No. I has less than one-third of the 12 traffic, doesn't it?
13 A
As I said in my testimony, this is a very short
)
14 piece of three lane divided road, interspersed along a 15 signalized urban arterial.
16 I have no reason to think that the distribution 17 of traffic at that point is -- will be any different than 18 the distribution of traffic at the signals, and if anything, 19 that distribution would favor the Lane 1 volume, and 20 increase it rather than reduce it as you are suggesting..
21 Q
You said short.
How short?
i 22 A
Quite short.
23 Q
Specify, please?
24 A
Could you read that back.
25 Q
Could you read the answer back?
t
o 82801616 18929 Joewalsh I
1 (Reporter reads-last answer back.)
("N
\\~
2 Q
(Continuing)
Can you quantify that, "very 3
short" in terms of some commonly accepted --
4 A
I believe it is less than 3,000 feet from the 5
upstream intersection signal to this particular stop sign.
6 O
Okay.
Now, I am going to show you four computer 7
printouts.
I don' t_ have copies for everybody.
I didn't 8
anticipate this, but these are the same HCM printouts, again 9
done by analyst BG.
This is for the east / west street, being 10 Route 27, and the north / south street being Meadowbrook 11 Parkway, southbound ramp.
The date is 4/21/87.
That is 12 April 21,
'87, and since I have four printouts, one for the 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> 7 to 10, one for 10 to 1300, that is ten in the
)
14 morning until one in the afternoon, one from 1300 to 1600, 15 and one from 1600 to 1900.
If you look at the third page of 16 each of those, you will see a capacity and level of service 17 analysis generated by the HCM software.
18 You will see Minor Street, northbound left, and 19 a right turn, which I take it is this merge onto the ramp, 20 and you will see a column called called:
Actual Movement 21 Capacity, in passenger cars per hour, I believe.
l 22 I want you to read into the record for me that 23 actual movement capacity of that ramp according to your 24 analysis for each of those four time periods, if you don't 25 mind.
82801717 18930 suewalsh 1
1
., - 4 (The witnesses and Mr. Zahnleuter are looking at
%)
2 a document.)
3 A
(Witness Hartgen)
The numbers are, for the 7 to 4
30 a.m.,
671.
For the 10 to 1 time period, 647.
For the ]
5 to 4 time period, 578.
6 Am I reading the right numbers?
7 Q
You are doing fine.
8 A
Thank you.
And, finally, for the 4 to 7, 503.
9 Q
The units there are vehicles per hour, passenger 10 cars per hour, something like that, aren't they?
11 A
Yes, I believe that's right.
12 O
Now, let me show you a document which is another 13 one of these.ATI traffic counts for that same location.
14 It's a ramp from Neadowbrook Parkway.
It is once again a 15 two-page document with the raw data on the, in this case, 16 second page of the handwritten analysis on the first page.
17 MR. CHRISTMAN:
Judge Margulies, I'm trying to IB figure out how to get these data into the record.
I don't 19 have a xerox machine close by, and I only have one copy of 20 this.
21 But, it's simply the traffic counts based on the 22 ATI measurements for that particular ramp.
I would like to 23 have this in evidence and I can, of course, make copies and 24 mail them to people or have them available this af ternoon or 25 whatever.
But, that's the only thing I can do right now.
l l
82801717 18931 suewalsh 1
JUDGE MARGULIES:
Well, will'there be any
~'
2 objection to its admission?
3 Let other counsel see it.
4 (The parties are looking at the document.)
5 MR. ZAHNLEUTER:
May I confer with my witnesses 6
for a moment?
7 JUDGE MARGULIES:
Certainly.
8 (Mr. Zahnleuter is conferring with the 9
witnesses.)
10 JUDGE MARGULIES:
Let's mark it for 11 identification.
12 MR. CHRISTMAN:
Good idea.
Let's ask that this 13 be Inarked LILCO Exhibit 3 8.
r i
14 JUDGE MARGULIES:
And, would you describe the 15 document?
16 MR. CHRISTMAN:
Sure.
It's a two-page 17 document.
In this case, the first page is handwritten and 18 it says " Location, ramp from Meadowbrook Parkway and Sunrise 19 Highway," dated 7/11/87.
That's July lith, 1987, a Friday.
20 The second page is the typical table of 15 21 minute, two-channel axle counts by ATI, done at the ramp 22 from Meadowbrook Parkway and Sunrise Highway giving the --
23 for the ramp in particular, the hour totals and the combined j
24 totals for a series of hours from midnight through 11 p.m.
25 on Friday, July 11, 1986.
82'801717 18932 suewalsh 1
JUDGE MARGULIES:
You may examine on it.
g s
s' 2
(The document referred to is marked 3
as LILCO Exhibit Number 38 for
'd identification.)
5 BY MR. CHRISTMAN:
(Continuing) 6 Q
I will have to give you my only copy of this.
7 IEn't it true that some of those axle counts exceed your 8
calculated capacity from the ramp?
9 (The witnesses are looking at the document. )
10 A
(Witness Hartgen)
I'm not sure any of them do.
11 They are high, in the afternoon.
12 O
What are -- well, they are higher than your 13 calculated actual movement capacities, aren't they, in some 14 cases?
15 A
They are high.
I think that would support our 16 position that in the afternoon movement -- if an evacuation 17 were to occur in the afternoon, this ramp would already have 18 a lot of traffic on it.
19 Q
What are the three highest figures there?
20 A
618 is the highest one, from 4 to 5.
The next 21 one I see is 596, and then it drops off very substantially.
22 The next one is 430.
Those are all afternoon movements.
23 Q
Well, if it exceeds your capacity analysis 24 calculations, does that tell you anything abou t the validity 25 of the calculations?
I
82801717 18933 suewalsh 1
A Absolutely not.
And, I think we established.
. '\\-
2 that the Highway Capacity Manual is a general document that 3
is based on national methodologies.
4 It looks to me like this data supports the 5
analysis.
It shows that the traffic is operating at or_near 6
Capacity during this time period, and it further shows that 7
there is no more room for evacuation traffic during this 8
time period.
9 Q
How do you know it's operating at or near 10 capacity from reading those axle counts?
11 A
The best estimate capacity I have are the 12 numbers that I've calculated.
13 0
In other words, you think it's near capacity
()
14 because you calculated the capacity and some of those 15 numbers are higher; therefore, it follows I take it in your 16 reasouing that the actual measured counts must be near 17 capacity; is that right?
18 Is that what you just said?
19 A
It's possible that th 2 intersection has a little 20 more capacity than what we have estimated using this 21 national methodology.
22 MR. CHRISTMAN:
Judge Margulies, I would like to 23 move this document into evidence as LILCO Exhibit 3 8.
24 JUDGE MARGULIES:
Is there any objection that it 25 La offered and admitted at the next session?
1 1
t 1-
r.
L a
l 82801717 18934 suewalsh m1 1
g
-a MR. McMURRAY:
No objection.
V 2
MR. BACHMANN:
No obj ection.
3 MR. ZAHNLEUTER:
No objection.
d JUDCE MARGULIES:
Rather than moving on your 5
offer at this time, please renew your offer at the next 6
session and have sufficient copies to serve on all the 7
parties.
8 MR. CHRISTMAN:
I had another question that came 9
up after I had cross-examined.
It doesn't have to do with 10 this ramp.
It had to do with the HCM software.
I'm not l
11 sure whether I'm entitled to ask that or not.
It did come 12 up after my questioning.
13 JUDGE MARGULIES:
You mean, their testimony came 14 up after --
15 MR. CHRISTMAN:
Yes.
Dr. Hartgen I think in 16 response to questions possibly by the Staff, or someone,.
~
17 talked about how the sof tware is limited and that permitted 18 lef t turn, just can't get it.
1 19 JUDGE MARGULIES:
We will permit the question.
20 MR. CHRISTMAN::
Let me hand out a document.
21 It's sufficiently thick that I don't want to -- let me hand 22 out a few copies of this.
l l
23 This is a Chapter 9 from a manual on using that l
24 HCM software but it's only Chapter 9 of that document.
25 (The document is distributed.)
82801717 18935 suewalsh May I ask that it be marked as LILCO Exhibit 39 1
2 for identification?
It's Pages 9-1 through 9-44, and it's 3
labeled " Chapter 9, Signalized Intersections."
And, as you 4
can see from the front page it talks & bout the signalized 5
intersections module of the Highway Capacity software.and 6
gives a number of pictures throughout of what you see on_the 7
screen when you use that software.
8 JUDGE MARGULIES:
It will be so marked.
9 (The document referred to is marked 10 as LILCO Exhibit Number 39 for 11 identification.)
12 BY MR. CHRISTMAN:
(Continuing) 13 Q
And, I will ask that you turn to Page 9-28 and
)
14 look at Figure 9.31.
15 (The witnesses'are complying.)
16 Now, it says up there at the top of the page 17 that if you had specified any protected plus permitted 18 phasings you would get a screen like the one in Figure 19 9.31.
If you look at Figure 9.31, it tells the analyst that 20 you may wish to assign some left turn vehicles from the 21 protected phase to the permitted phase and that you may 22 assign these vehic3es in the following three ways:
Number 23 1,
assign no vehicles to the permitted phase; Number 2, 24 assign the maximum number of vehicles, that is the capacity 25 of the permitted phase Number 3, assign vehic3es to the O
i 1
~
82801717 18936 suewalsh 1
I permitted phase'such that the v/c ratios for the permitted 2
phase and the protected phase are equal.
3 And that suggests to me that there is a way to d
get this software to handle those permitted phases; is that 5
not right?
6 A
As I recall how this works, if you pick option 3 7
the v/c ratios which are balanced are the v/c ratios on the 8
protected portion of the system and not the hidden permitted 9
portion.
10 I stand by my previous description of the 11 methodology.
12 Q
What's your basis for that recollection?
Is it-13 in the Highway Capacity Manual or --
-M)
\\
14 A
I have no specific recollection of the basis 15 other than a general understanding of how the tool works.
16 Q
A general understanding of how the tool works.
17 Have you ever sat down in front of the computer screen and 18 used this software or looked at what comes up on the screen?
19 A
Not this software, no.
I have seen this Manual, 20 but I have not sat at a terminal and run this software.
My 21 staff has.
22 MR. CHRISTMAN:
Judge Margulies, that's all the 23 questions I have.
I would like to move this into evidence 24 as LILCO Exhibit 39, 25 JUDGE MARGULIES:
Any objections?
1 L
3 i
82801717.
18937 1
suewalsh-
)
1 MR. McMURRAY:
I have an obj ection to this whole
('
2 document going in.
It's 44 pages.
They have cross-examined 3
on one page of it..
4 MR. CHRISTMAN:
Well, why don ' t we j us t admit it 5
for the same -- under the same condition that you have 6
occasionally used in the past, which is just for the purpose 7
on which it was cross-examined?
8 MR. McMURRAY:
I have no objection.
9 MR. ZAHNLEUTER:
No obj ection.
10 MR. BACHMANN:
Will I get a copy?
11 MR. CHRISTMAN:
You bet.
12 MR. BACHMANN:
No obj ection.
13 JUDGE MARGULIES:
It will be admitted solely for
()
l 14 the purpose for which it was used for cross-examination.
I 15 (The document previously marked as 16 LILCO Exhibit Number 39 for 17 identification is admitted into 18 evidence.)
19 MR. CHRIS7 MAN:
As I say, I have no more 20 questions.
l 21 JUDGE MARGULIES:
Mr. Zahnleuter.
22 REDIRECT EX AMINATION 23 BY MR. ZAHNLEUTER:
r.
24 Q
Mr. Millspaugh, earlier today with respect to a 25 discussion about VR or vehicle recall, you offered a I()
82801717 18938 suewalsh
)
.i 1
1
.ya definition where you said it puts you on the system.
k_)
2 Could you please elaborate on what you meant, j
3 and do so by explaining what you meant by the word "you" and d
what you meant by the word " system?"
5 A
(Witness Millspaugh)
If you recall, looking at 6
the one page that gave me a timing for that signal, that's 7
where you will notice that vehicle recall, at the bottom 8
there.
What that does is -- let's see, we were talking 9
about Sunrise Highway and Newbridge, as I recall.
10 That happens to be one signal in a signal system 11 along Sunrise Highway.
And, by throwing that switch to 12 vehicle recall puts this particular signal in that system.
13 And, therefore, the signal system has 120 second cycle 14 length.
And, that's regularly every 120 seconds that it i
15 changes.
16 The phases for the side road -- and included in 17 that ' side road are the left turn lanes.
In this case, they 18 are treated like a side road phase.
Those phases are held i
19 to the maximum amount of time and any excess time goes to 20 the system along the artery.
Those were Phases A.1 and A.2, 21 as I recall.
22 Q
What is the effect of having that particular 23 signal in the signal system?
24 A
I'm not sure --
25 MR. CHRISTMAN:
That's beyond the scope of the h.O s
82801717-
-18939 suewalsh' 1
cross I think.
s 2
MR. ZAHNLEUTER:
This question that I just asked 3
is a follow-up question to the response that Mr. M113spaugh 4
just gave me.
5 MR. CHRISTMAN:
It didn't sound like a follow-up 6
to me.
7 MR. ZAHNLEUTER:
Well, I asked the question 8
because he used those words and I wanted to ask what the 9
effect was.
10 JUDGE MARGULIES:
The Board will permit the 11 question.
It is explaining the system.
12-WITNESS MILLSPAUGH:
Before, I wasn't too clear 13 when I said "put you in the system" meaning the signal
()
14 system, putting this particular signal into the system 15 rather than working as an independent signal, an isolated, 16 working independent of the system.
17 If it was working independent of the system, 18 then you would be -- if the rest of the signal system was in 19 a progression down the street, you would -- chances are you 20 were going to have to stop at this signal regularly rather j
21 than keeping in pace with the signal down the highway.
22 JUDGE SHON:
Mr. Mi13spaugh, could you explain 23 to us how what sounds like signals that are designed to turn 24 according to the behavior of other signals on 'fne system can 25 possibly be squared with signals that lengthen or shorten
.O V
l
82801717 18940 snewalsh 4
cj I
,,4 their own time pericus depending on the traf fic at the U
2 particular point?
3 It's admittedly just a matter of curiosity, but d
it went on the system, it's timed so that you can catch a 5
green at every corner, how in the world can this thing then 6
accommodate more or less traf fic or the presence or absence 7
of traffic making certain turns?
8 WITNESS MILLSPAUGH:
If the signal is working 9
independent of the system, it would be working at the lower 10 cycle length that I demonstrated before and would be 11 independent of the system and it would be -- the people 12 would be approaching the signal and it may or may not get a 13 green light.
It would be totally independent of the signal f
14 q,
system.
15 I'm not sure I'm answering your question.
16 JUDGE SHON:
Maybe I didn' t ask it right.
You 17 seem to have said that this signal generally operates as 18 part of a series of coordinated signals.
And, you have also 19 said previously that the signal operates in part by 20 determining the amount of traffic that is present at the 21 signal.
22 I don't see how it can simultaneously both 23 coordinate with other signals and act according to the 24 amount of traffic presented to it.
25 WITNESS MILLSPAUGH:
I see what you are after I rpa
.g
82801717 18941 suewalsh r
Thisiparticular signal we are discussing has certain I
think.
2 maximum green times on it, and as I demonstrated earlier ll
- 3 those have maximum greens and the signal holds to those 4
greens on that one sheet of paper.
5 And, if it was operating independently of the 6
signal system, it would have a cycle lane something like 75 7
something, whatever that came out.
Now, when we put it into 8
the system it's going to operate -- and the signal system is 9
a 120 second cycle length regularly, and it will be -- the 10 signal will yield at a certain point which was on that sheet 11 of paper that gave the yield points, that it would yield at
.12 a certain point in this 120 second -- or in the signal 13 program so that the traffic could progress doyn the highway.
I) 14 And, the timing for the side roads or the side 15 approaches and the left turn lanes, which are treated like a-16 side road in this case, would revert -- would yield to this 17 system so that it could -- the signal system could progress 18 the vehicles at a constant or a regular speed.
19 JUDGE SHON:
And, is that why you got 75 and a 20 half seconds and the note on the sheet said 120?
21 WITNESS MILLSPAUGH:
Yes, because that one sheet 22 showed the cycle length for when it's operating isolated.
23 It's not in the system.
i.
24 JUDGE SHON:
And, do we know which condition 25 pertained for the analysis?
O
W 82801717 18942 suewalsh I
j 1
WITNESS MILLSPAUGH:
I believe the signal
.O' 2
system.
Generally, I would hope it would be in the signal 3
system.
4 And, that information at the bottom of the sheet 5
showed the yield points for three different programs in the 6
signal system.
7 JUDGE SHON:
I see.
Well, thank you.
8 BY MR. ZAHNLEUTER:
(Continuing) 9 Q
Gentlemen, do you attach any significance to the 10 fact that you were unable to make or perform calculations 11 for the maximum -- excuse me, for the minimum phasing times 12 for the left turn, north / south and east / west movements at 13 the Newbridge Road and Route 27 intersection?
r,
(
14 A
(Witness Millspaugh)
I still maintain we didn't 15 have enough information on the location of the detectors to 16 determine those minimum greens.
17 (Witness Hartgen)
But that information isn't 18 necessary since we are trying to overload these turns with 19 maximum traffic.
So, it's the maximum time that's of 20 interest to us and I think to the Board.
We are looking for 21 the maximum amount of green time that's available.
The 22 minimum amount of green time is only of marginal interest to 23 us.
24 Q
Now, Dr. Hartgen, I wou3d like to ask you two 25 questions about the NRC Staff Exhibit 1..
Do you see on Page i-
- \\
82801717 18943 suewalsh 1
13 of that document, Item 2:
Manual counts are likely to 2
contain considerable errors, particularly if conducted by.
3 inexperienced or unsupervised personnel?
4 A
Yes.
5 0
Does this statement have any applicability to 6
the analyses performed by KLD regarding the evacuation "I
7 routes to reception centers?
1 8
A WeII,-of course, I have no knowledge of their 9
experience or the supervision that was applied at the time 10 they were there.
I can recount what happened in this l'
11 experience.
12 Experienced individuals were sent out to a site 13 and requested to count traffic manually at the same time l ()"
14 that electronic counters were counting that same traffic.
15 Stop watches were applied so there could be no error in the L
16 clocks, and the electronic system was functional.
,t 17 The results were that the manual counts varied 18 from each other by as much as five or six percent, as I 19 recaII, and varied substantially from the counts obtained by 20 the electronic equipment.
We were surprised to discover the 21 amount of error that could be introduced by what one might 22 think would be the perfect accuracy of human beings simply l
23 recording vehicles as they passed by them visually.
1 24 And, we also observed that as time went on that 25 performance deteriorated substantially and became worse over
'O
)
82801717 18944 suewalsh i
time.
That's what led us to the conclusion that electronic f_ab 2
counts, the longer the better, would be preferable to manual 3
counts.
d Q
Concerning Item 4 below, counts should be taken 5
for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to minimize overall clock error.
6 Does that statement'have any applicability to 7
the analyses performed by KLD?
8 A
Yes, it does.
The ' manual counts takeri by KLD f
were for.very short periods o.f time, some less than an hour o
p.
,o I believ'e.
Most of them between an hour and an hour and 15 11 minutes.
12 In our view, counts that short are too short 13 from which to derive percentages of traffic in turns.
(h-)l 14 15 s
16 17 18 19 20 21 22 23 24 4
25 b
v
'82801818 18945
_Joewalsh i
1 MR. ZAHNLEUTER:
I have no further questions.
7U 2
MR. CHRISTMAN:
No, sir.
3 JUDGE MARGULIES:
Mr. Bachmann?
I 4
MR. BACHMANN:
No questions.
5 JUDGE MARGULIES:
The panel is excused.
Thank i
I 6
you.
7 (WITNESS PANEL STANDS ASIDE.)
8 JUDGE MARGULIES:
That completes the witnesses 9
for this week.
We would like to speak to you Mbout 10 scheduling.
Have the parties come up with scheduling for 11-next week?
12 MR. CHRISTMAN:
No, sir.
Not yet.
And I need 13 to,raJse that point, I guess.
It has been suggested we (q
_/
14 might need to go over into the next week for Mr. Lieberman, 15 because he can't be here on Friday next, although he can be 16 here every other day next week.
17 Mr. Lieberman is available Monday through l
18 Thursday, any time on those days.
19 Doctor Lindell can come in on Tuesday or 20 Wednesday, although he has to leave Wednesday afternoon to 21 get back to Seattle, and I think he can be here Monday as 22 well.
23 If, because Mr. Lieberman cannot be here on 24 Friday and we have to go into the next week, we need to l
25 know, I guess, if that is categorically unacceptable to the O
a
q l
I 82801818 18946 joewalsh
~
l e'l 6
I Board, or somebody on the Board has a conflict, that would 2
constrict our scheduling discussions.
3 JUDGE MARGULIES:
Well, I do have a conflict the d
following week.
What is the matter with the 28th, in that 5
this panel was scheduled to testify on the 28th, Tuesday?
6 MR. CHRISTMAN:
That is okay with us.
7 MR. McMURRAY:
I think that the parties can 8
probably work this out.
Th.is information is new to me, and 9
we can probably get back to the Board tomorrow morning with 10 a letter, and attempt to work this out this afternoon and 11 get back to the Board.
12 I think that would be the best approach.
13 JUDGE MARGULIES:
We should be able to wind up U
14 this proceeding next week, and there seems to be adequate 15 time, and that is the feeling of the Board, so we will await 16 to hear from you tomorrow.
17 From a time standpoint, it would be best that 18 you contact us after 2:00 tomorrow.
19 MR. McMURRAY:
Fine.
20 JUDGE MARGULIES:
We will stand in recess.
21 (Whereupon, the hearing ad3ourned at 5:23 p.m.,
22 this same day, to reconvene at the call of the Chairman.)
23 24 25
!Q
CERTIFICATE OF OFFICIAL REPORTER-O This is to certify that the attached proceedings before the UNITED STATES-NUCLEAR REGULATORY COMMISSION in the matter of:
NAME OF PROCEEDING:-
LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit'1)
DOCKET NO.:
50-322-OL-3-(Emergency Planning)
- PLACE:
HAUPPAUGE, NEW YORK DATE:
THURSDAY, JULY 23, 1987 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.
j (sigt)
/vA AWg (TYPED)
MARY C.
SIMONS Official Reporter ACE-FEDERAL REPORTERS, INC.
Re
's Affiliation
/caes#
du
//
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