ML20236M244

Transcript of 871106 Evidentiary Hearing in Concord,Nh. Pp 5,439-5,582.Related Info Encl

ML20236M244
Person / Time
Site:	Seabrook
Issue date:	11/06/1987
From:	Atomic Safety and Licensing Board Panel
To:
References
CON-#487-4869 ASLBP, OL, NUDOCS 8711130044
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{{#Wiki_filter:. ~~ O UNtnD STATES XUCLEAR REGULATORY COMMISSION

======================================================================,===n=======- IN THE MATTER OF: DOCKET NO: ) EVIDENTIARY HEARING ) 50-443-OL ) 50-444-OL PUBLIC SERVICE COMPANY OF ) OFFSITE EMERGENCY )' PLANNING NEW HAMPSHIRE, et al. ) ) (SEABROOK STATION, UNITS 1 AND 2 ' ) i O i LOCATION: CONCORD, NEW HAMPSHIRE

PAGES: 5439 through 5582 DATE:

November 6, 1987 \\E========== ==============================mmmmmmm...... ..,=,,=,,,,,,,,,,,,,,,, I \\ .h 'N Heritage Reporting Corporation q 1 Ogicial Reponers 1200 L Street. N.W. Wuhangton. D.C. 2000$ (202) 628.4444 8711130044 871106 PDR ADOCK 05000443 T PDR .{ \\

l 5439 l I UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD PANEL Scc 50T&I In the Matter of: ) ) Docket-Nos. PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et al., ) 50-444-OL. ) (SEABROOK STATION, UNITS 1 AND 2) ) 1

Friday, November 6, 1987 Hall of Representatives New Hampshire Statehouso Concord, NH The above-entitled matter came on for hearing,

( ('; pursuant to notice, at 9:04 a.m. j BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN j Atomic Safety and Licensing Board Panel j U.S. Nuclear Regulatory Commission Washington, D.C. 20555 j JUDGE JERRY HARBOUR, MEMBFR Atomic Safety and Licensing Board Panel l U.S. Nuclear Regulatory Commission j washington, D.C. 20555 l l JUDGE GUSTAVE A. LINENBERGER, JR., MEMBER 1 Atomic Safety and Licnnsing Board Panel U.S. Nuclear Regulatti' Commission Washington, D.C. 2055a i (Continued on next page.) , ~\\ U Heritage Reporting Corporation (202) 628-4888 , _.. _ -. _ - -. - - -. - -. - - - -... _ -. ~ - - -. - -

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o ' ' i i 1 i APPEARANCES: ~ For the Applicant:- ~ THOMASLG. DIGNAN,1JR.,.ESQ. GEORGE.H. LEWALD,':ESQ. KATHRYN~A.-SELLECK, ESQ. Ropes & Gray-l225iFranklin Street'- LBoston, MA-.02110 For the NRC Staff:- SHERWIN E.. TURK, ESQ. Office of General Counsel' .U.S. Nuclear. Regulatory. Commission. s Washington, D.C.- 20555 For the Federal" Emergency Management Agency: H.' JOSEPH:FLYNN, ESQ. GEORGE WATSON,.ESQ. Federal Emergency Management Agency. 500 C Street,:S.W. Washington, D.C. 20472? For the State of New Hampshire: GEORGE DANA BISBEE,. ASST. ATTY. GEN. GEOFFREY M'. HUNTINGTON, ESO.. State of New Hampshire 25 Capitol Street Concord, NH 03301: For the Commonwealth of Massachusetts: STEPHEN Hi OLESKEY, ALAN' FIERCE) ESQ. ' ESQ. - s-JOHN TRAFICONTE, ESQ'., ASST. ATTORNEY GENERAL One Ashburton Place, 19th Floor Boston, MA 02108 ~ gj For the New England-Coalition Agai'nst Nuclear Pollution: (No appearance) O LHeritage Reporting Corporation (202) 628-4888.

g i '.\\ ^' .a /. ,4 i I 5441. D M-i a 'f APPEARANCES: '(Continued) w i For the Seacoast Anti-Pollution Leagues ROBERT A.'BACKUS,.ESQ. j L 'Backus,.,Meyer, &. Solomon'. 116LLowell Street. s )) Manchester,'NH 03105'. t 1 .) JANE-DOUGHTY Director JJ Seacoast Anti-Pollution League l - 5 Market. Street-1 Portsmouth, NH. 03801-k /l 4 For the Town of'Hamptons,- PAUL McEACHERN, ESQ. MATTHEW T. BROCK, ESQ. 'Shaines &LMcEachern-4 25 Maplewood Avenue 4 P.O. Box.360 i Portsmouth,' tui 03801 For the Towns of Hampton Falls and North l (~ } Hampton and South Hamptons-ROBERT A. BACKUS,.ESQ. Backus, Meyer & Solomon 116 Lowell Street Manchester, NH 03105 i For the Town of'Amesbury: WILLIAM S. LORD',- Selectman Town Hall Amesbury, MA 019131 f'i, For the Town of Kensington: SANDRA F. hITCHELL. Civil Defense Director Kensington, NH;<03827 v O Heritage Reporting Corporation (202) 628-4868 .bc i __--__--_---_.--.________-__2a

4 '5442' -1 .3 \\ f^) - (,/ I NDEX l WITNESSES: DIR_QROS REDIR RECR VRDR EXAM AVISHAI CEDER by Mr. Fierce 5443 by Mr. Dignan (resumed) 5447 .q by Mr. Fierce (resumed) 5469 l by Mr. Dignan 5514 i by Judge Linenberger .5529 J I ) l I 1 l .q 1 I i l 1 4 f} O i l l 2 i l l I 1 t0 . %) Heritage Reporting Corporation (202) 628-4888 _ _ _ = _ _

5443 .c i_) INDEX (continued) l s EXHIBITS MARKED RECEIVED DESCRIPTION Applicants': No. 24 5448 5448 Excerpt, 5 pp,. Chapter 33, Salter's book 1 on traffic engineering INSERTS: Description Page 1 Applicants' Exhibit Number 24 5468 f 1 2\\ ,V l \\ 1 1 i l l i I i -l 1 1 \\ l 4 r's. r b \\_/ Heritage Reporting Corporation i l (202) 628-4888 i l I 1

7. c 1 t., '5444. T-MAR 1 PROCEEDI'NGS 2 JUDGE SMITH: Good morning. We are prepared.to 3 proceed. 4 MR.~l FIERCE: Your Honor, I have oneipreliminary 5 matter. i 6' JUDGE SMITH: Mr. Fierce? 7. MR. FIERCE: First,'I want to announce that.Dr. 8-Ceder, over the evening,.cid: locate the source in the Salter' 9 book'which is the reference for the citation in his testimony. 10-The' thing that I want to: note,: at this point in' time, 11 is that having re-examined that.particular set ofipages', which 12 was the set of.pages that Mr. Dignan originally had1 suggested,- 13 Dr. Ceder, at this time, has indicated to me that he would wish O 14 to revise his testimony slightly, by changing'the number:2.63 q 15 to 2.56. q 16 And I would ask Dr. Ceder, if lie wishes his testimony s 17 to be amended in this fashion,non)page'16(,fI:beli ve? Page 19. 18 Whereupon, 19 !AVISHA,I CEDER 5 20 was recalled as a witness and having been previously' duly 21 sworn, was examined and testified 'as follows:: 22 REDIRECT EXAMINATION (Resumed) 23 BY MR. FIERCE: 24 0 Dr. Ceder, is that your wish this morning, that the 25 sentence that reads, "a vehicle was found, on the average, to (vh Heritage Reporting Corporation _(202) 628-4888

CEDER - REDIRECT 5445 ("l N k-1 be 2.63 seconds per vehicle" should be amended to read,."2.56 2 seconds per vehicle"? 3 A (Ceder) Yes. 4 Q And you wish that your testimony that has already 5 been offered into evidence, to be corrected to reflect this 6 change? 7 A (Ceder) Yes. 8 MR. FIERCE: At this time, I would move that that 9 correction be made to Dr. Ceder's testimony. 10 JUDGE SMITH: Well, I think that it has been. l 11 MR. FIERCE: Well, if it has'been, Your Honor,.at 12 this point, I talked to Mr. Dignan, before the proceedings this 13 morning and I gave him an option as to whether he wished tio (~) 14 proceed at this point, in time, with.his cross-examination of 15 Dr. Ceder, with respect to this particular point, and he 1 16 indicated that he would and I have conceded to allow'him to 17 interrupt my redirect to do that cross, and then I will pick up 18 my redirect at the end of his further: questions. I 19 JUDGE SMITH: All right,.that seems very logical, j 20 MR. DIGNAN: Thisr is subject to-your approval, Your 21 Honor. I am indifferent as to how I proceed. 22 JUDGE SMITH: Well, 'I 'think' that it is better to have 23 it contiguous right here, and he has just made the correction l 24 and now you can develop the record. 25 MR. DIGNAN: I want to be sure that I 1 r\\, kJ Heritage Reporting Corporation (202) 628-4888 1

i 1 l ij CEDER - REDIRECT 5446 (^J ) 'L 1 JUDGE SMITH: Mr. Flynn, were.you trying to get'my. 2 attention? i 3 MR. FLYNN: Yes, please. l 4 I have another preliminary matter, if we are done 5 with this. ) 1 6 JUDGE SMITH: All right, j 7 Proceed. l I 8 MR. FLYNN: There is some confusion in the transcript 9 from Wednesday, November 4th, that I would like to clear up. -j l 10 It appears on page 5159, and it has to do with the discussion 11 of Mr. Dignan's motion in limine on FEMA's sheltering l 12 testimony. i 13 And what the transcript says, is that by Judge Smith: (_'\\ 14 "Mr. Brock the only thing that has been decided this morning, 15 it that as a matter of law, this paragraph cannot be received } 16 into evidence." 1 17 I think that was misreported. I believe that what i 18 you said, was can be received into evidence, and:indeed, two 19 pages later, you indicated, and I am quoting from page 5161, 20 "So your motion" -- this was addressed to Mr. Dignan now, l 21 "on the basis of discussion this morning, and the 1 22 understandings is denied with respect to the testimony, with 23 respect to Exhibit Number C, Mr. Flynn's letter of August 7th, 24 1987, is granted." 25 So I just want to confirm what the Board indicated (~\\ G Heritage Reporting Corporation (202) 628-4B88

] ' ( j. <5447 CEDER - CROSS 1 (D .) V T that certain of the testimony.could come in. T 2 JUDGE SMITH: Certainly the entire context of the 3 discussion reflects that, and if I misspoke and said - 'the 4 paragraph, I think was on page.-- global page 60 -- the' ruling 5 was that we are ruling only that as a matter of law, the-6 . paragraph cannot'be excluded.- It is being' admitted. As to the 7 weight'of it, the accuracy or anything else,.that is open for 8 challenge. 9 MR. FLYNN: That-was my understanding as well, but I 10 thought that the' record was unclear. Thank you, Your Honor. 11 JUDGE SMITH: Any other preliminary business? 12 'FURTHER. CROSS-EXAMINATION 13 BY MR. DIGNAN: O 14 Q Dr. Ceder, I want.to be sure tha't I understand-15 something. It is.my understanding that you have reviewedLthe-- 16 Salter book and.that you have found the. source of what was the 17 2.63 number and I understand that it-is now a 2.56 number. 18 And you found it, as'I1 suggested,to you yesterday,'in. 19 Chapter 33 of the Book, is that correct? ) 20 A (Ceder) That is correct ~and thank'you for?giving me 21 the book. 22 23 24 25 b v Heritage Reporting ' Corporation (202) 628-4888

CEDER - CROSS 5448 1 (~ k-1 (The document referred to, i ~ l 2 was marked for 3 identification as 4 Applicants' Exhibit i 5 Number 24.) 6 BY MR. DIGNAN: 7 Q Doctor,-I represent that what I am showi'ng to you is 8 the book you went over last night, and particularly chapter 33 9 thereof, the original of it, and can you confirm that that is i 10 what you have in front of me? 11 A (Ceder) And now, I know this very well, yes, j l 12 0 And now, Dr. Ceder, I am going to place before you a 1 13 document which the Reporter has marked as Applicants' Exhibit I \\' 14 Number 24, for identification and I will ask you if you can 15 confirm that this is a true and correct xerox copy, of Chapter 16 33 of the Salter book? l 17 (Witness is proffered document and examines it.) 18 THE WITNESS (Ceder): Yes, I.do. 19 BY MR. DIGNAN: l 20 Q And Doctor, I guess'what I would'like to have you do, 21 because I thought that I had been able to recreate your 2.63 22 figure, would you tell us precisely how you got this 2.56 23 figure from the information, in what is now, Applicants' 24 Exhibit Number 24? 25 JUDGE SMITH: Would it be easier for you to do it on n( ) Heritage Reporting Corporation (202) 628-4888

, q, m r ,(.,h, I l r I i. 5449 CEDER -( CROSS 1 the board, too, and if it is easier, if i: Q O make 1 2 understanding of it, easier, then we sM N ea; out some way to 3 get that into the record. 4' THE WITNESS (Ceder): At this pol $w., it is just a 5 simple calculet Mn which one cEa look at one,' table in. .So I 6 don't think that the board wi31 help. 7 BY MR. DIGT\\N: l 8 Q What table are we going to work with?- l l j l 9 A (Ceder) The tables.from which I make my calculation, 10 33.2 on page 204. And that is entitled observed discharge of l 11 vehicles across the stop line. I l 12 So I will very briefly explain how did I reach this 13 number. First of all, it is well-known that th'e English people ,c3N 14 knows quite well how to establish a good control at j l 15 intersection. 1 16 They actually were the pioneers.of all of the models I 17 involve intersection control. Here it is just an example, and j 18 I mark it down in my testimony, it is an example of measurement i 19 to calculate the discharge rate'at intersection.- l 20 How many vehicles actually -- oh, how long it takes 21 one vehicle to cross an intersection if we.want to measure it? 22 Now, the calculation was as follow's: .We-look at I 23 table 33.2 and we see four lines. The fourth line it is 24 discharge per tenths of a minute. And actually those numbers 25 starting with l'.88 through 2.47, indicate the number of gG Heritage Reporting Corporation (202) 628-4888

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i .i 13 'Here the. fourth line, what:I. mentioned:befor,eL the 4 4 j, s ,;.,.. ( 14 numberof<vehiclestha[t'cancrosstheintersectioniperStenths N" e s 0 .(N; 15 of a minutie,. is actusbly.the: product 4 of.the sec'ndsline, e[t M o ,, h :p 16 divided by the' third line'. 7(, wf? s y 17 -which' the second line is khe r$mber< of hehI0i$8 ~ ~; 12, < F: i ', r .r crossing stop :line,. and the third TAlnd ils, numberh. ?

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h;i . r. 19-y!, ..;. ;t, qn y j m - a> .3/,g. z.. -/ n,, y t i-q .y r! 20 instance, th'e first column, 60, diti;ded:$,y;.32,s,and ee?co'mirt up '~ H 21 with 1.88. ' 1;, '1 3, I U. :dr #p~ p, t- ~ t. . v. n ~ Thesameapply,tothe'othercolumnsohCthQright. 22 3 ic O 23 Now,ifweobserve. carefully'andweidonfttayejitfor' 'Ap... 24 granted, the - numbers,. the second :calumn h~as a: m. istake.: 25 Seventy.-six divided by.32, it is not"2.48. Sev'enty-six divided:' i6 4 f 'l j Heritage Reporting l Corporation % (202)'628-4888 .i cd yj, f.gp i w-t yF i y Q m;+ y ,p \\ 'I p" g o .~ = 7 y sc,% 33 '{';f i ?]l l: *

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f/Q4 np, W j r) ( P.--- / p .( u '.- l h ' CEDER -1 CROSS! 54511 j by3 bis 2.37. And so this needs to be' corrected,'andl1f'one- '1' 2 wants to use numbers, he has to.look it more carefully.- 3 So I corrected this 2.37'instead'of-2.48.1 x1 f. 4 Now, the table, the firstl paragraph b'elow th'e tables, ] gg P' . j .t. 3 ';7' " 15 after the three,li.nes below the, tables, start-with the word,. 1 ~ ?] 1 6 "during". t >i 1L 7 And I would read 'It. "rurlngthe'firstandlast. 8 saturated interval, there is a-ldha'of capacity because o'f the. 9 effect of vehicle accelerating from the stationary! position, at-7,. 10 the commencement of the green' period, and. accelerating during'. .L f 11 the amber period " 12 Which is common to'do. So what they.are actually 13 doing, they are suggesting to delete'or to ignore the numbers. 14 of vehicles crossing the intersection in:the.first:tenthstofLa 15 minute, and in theJ1ast tenths of a minute.- And'then'to-come 16 up with an average value. ~ 17 Actuelly what they did,;in contrast to..what they 18 suggest, they. delete the first tenths.of a minute,f1.88~,-while' j L A. 0 i*c 19 calculating the saturation flow below,~'but'they left the 2.47,- 1 e 1 y 20 which is the last column, unexpiainedi Again, if one,.a-W a; f

1 21 profession has to look at,that(and take the numbers,1not1for j

4 5-r l; 22 granted, you;h' ave to dof'it cprrectly.' 23 So ihat I did is't'he following? I picked' up' the ~ b 2j37, which isfthe number of' vehicles discharged per1 tenth of a ih second, in the second column; plus 2'.'22,~plus 2.44 while. M ) J ,,4 1 . Heritage Reporting-Corporation i (292)".628-4888 1 f i., l(!L V ") s-., y I .( ( <l

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<j, 3 'Dividedlit 1 "ya y. y, yy L2 by tAh$e,;and then I come up with anjaveragh;/nulber ti tican-b~-Q .(.. _ v f 3 dischargec.in.a tenths of a-minutog p g< .p ~;. 3 a uv - ,, "g c f . This numberkwas calculater/to be f 2. 34 j (2 LJf L 4 ..)' '! _ Q ' ' ' >+, ., + r, 5 ./):Andciflone Monverted tolA,. ' discharge hehftway, d{ot '] c/, (6 . /.g. gi, 37 y .('.' l numberM,11f vehicles,cbdt'to.the. numb 6r of!dp'conds.re'qd red..forl T .0 6

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t 4; , 'y n f e Nach '/ehicle to-cross the intersection',- we simply %'o.Xhle! 'I 7 m h \\, . /,h > M ;.,,. l 8 inverse of.that number, andiconvert fitJto" seconds ?;. Andjhen we 4 m1Ng. up 'vlith b.,5'6sec/ind ' 3 9 qu eil orf the average,y for,'one? e ,td j 7-1 s. - :< y~ ~s ,1 g 3f vehicle to cross the.intergespl6'n;. ..r 'atis turated' level. 10

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11 I repeat, IJtakbhaIxdivided'by2.34,..or-theinverse'- qsy 12 cf /.'he ntahber of vehidl,es. crossing in tenths'of'a minute, and )3 f.J.. l 13' comin4 up with;2.56., cio 4 ,,14 , And'. Doctor, have you' completed'your sta'tement?f { d 2 /;(p; 1 .) t 2 (Ceder) Yes. 15 g a. r .s You usM the word, inverse, idfthat theEsame.,asJ;j p ~. 3 16 Q l \\ ac A m ~ 17 reciprocal? e j-y .n.,. s %, 't 4 :?.. I 'f // (Ceder) Yes, reciprocal. h.}- f(- ^ ,{ 18 s Now,p svyouhavegivenusthesourceofthe .56.and you' j 19 Q s( ,M 20 said thpt was tTe change that you wanted to make kn.your s O f,;( 21 testimony.J t y 'f ' ' ( 22 ) Could I ask e one other questibn about'y:tur. / ,1 n.x 6 testimony as of fered?./a i k j.J

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23 / 9y ,3 't' 3 [t Just before the 2.55, you de' scribe the chart"dr.the 24

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t + s, ) 25 Salter book, as#pne evild find that' thisl headiny for an, e s y He$itag9 dReporting Corporati'n[ 'I l y> n " h (202F.628-48620 f-3 y 3 i. v ~ ,y 4 j K. q 3y s. r-e c L-l -x ! ' 4* 1 .i - t.s 1 s( -y, ,i

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l. ' observed 80 vehicles. .2 'Do.you/wantito make'a changeLin that number, 80, 3 'also, now.that.you have-reviewed:the book?' 4 A. (Ceder)' The 80 number wasfjust a -rough number. But1 5 we see'here, the number of observed vehic'leicrossing, factually.. 6 more'than'80.- 7 Q Well, chow many~vehiclesudid he observe; if it was? noti 1, n

8 80?

1 I 9 .A (Ceder). The number of-observed'that goes into. + 10 calculation, it is 76, plus 71, plus:78, altogether.- 11 Q What'happens.to'60-and 797 12 A. (Ceder) Those number we are. deleting 11t,cbecause,we, L ? 13 want to get better picture of'what we~ call saturated flowL ,y 14 .Q So I understand now, your testimony;isithat it should 15 .have read, one could find that this headway for'anLobserved?-. d ..q l 16 A (Ceder) Then:we simply said,7- - ~ 2 8 + .an 17 Q -- 226 vehicles?- 3l 18 A (Ceder) .That'should read. l 19 Q Is that correct, sir? l d 20 A (Ceder) Yes. 1 ..1 -12 1. Q And what is the phraseldown belowithe' table'.mean,. [ a 22 total number of vehicles, crossing stop line-41, what doeslthat- ~ . 23 mean to you? i; i 13 2 H j 1 y ; w

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(Ceder) Total number of vehicles -- 25 Q -- crossing stop line 41",c do;you see'that,[in the ) Heritage Reporting Corporation (202)'628-4888 } w; } 4 u

} n 1 CEDER - CROSS <5454 1 second line below the table.that you.are referring to? q 2 A' (Ceder) 'Yes,' sir.. This is -- 3 'O What.does that mean to you? 4 A (Ceder) That means an average number. This is not 5 referred to the calculation of the saturated flow. 6 Q Now, doctor, if I heard'you. correctly, if.you made-i 7 your explanation'of your new number, you understood that i 8 Professor Salter discarded the first column, the first-interval'- l 9 and the.last interval of the table, the cne that' starts.at the', i ] 10 top, 0.57 11 A (Ceder) You are referring to the first line'below 12 the table? 13 Q Yes, now, I' thought that-you said for'your purposes 14 of your calculation -- 15 A (Ceder).-- right -- 16 0 -- you only used the middle ~ numbers, the. columns that 17 have in them, 76, 71, and 78, right? 18 A (Ceder) Right. 19 Q And your justification for not usingithe last one,.'isl 1 1 20 that Salter had not explained why he should not. discard that. u 21 one, right? 22 A. (Ceder) That is' correct. 23 Q And well,..cannot'you find the explanation of why he 24 did not discard that one, in-the three lines below thel table?. 25 A (Ceder) This is refer to the-last saturated s 4 Heritage Reporting Corporation-l (202) 628-4888 .q .i L 'k

? y -i CEDER CROSS 5455 A3sj 1 interval. 2 Q AndL-- 3 A (Ceder) -- but it..is unclear because.he, knocked"down' I 1 4 five columns,-starting from zero and going to .5. 5 Q' Doctor, in the third line below thel table, the-6 .following appears: 7 " Discharge per 0.1 minute during last saturated A.. .8 interval equals 41.6.' divided by(142,(equals li74 vehicles'." 9 Do you see that statement? 10 A (Ceder) Yes.- /# 11 Q That was'the last saturated interval, which'-the' l. 12 author of the article < discarded,<was it not? 13 A (Ceder) I agree. That can be the ' interpretation'.' ~ 4 ( 14 Q So, the article properly used, demands the'use of all 15 four of the last of the five columns,' excuse me, it' demands the-l 16 use of the last four of the five. columns in the table, if we 17 are going to parallel the author'sLwork, is that not-true? 1 18 A (Ceder)' That is',.y'es,.I agree-that this is another. i 19 way to consider it. Unless, again, if the last' saturated 20 interval does not appear on table 33.2, which nothing is 21 mentioning here about that, then instead of deleting the last 22 column, we can include it, the 2.47, and repeat the calculation 12 3 by correcting only the first number which is 2.48, 2.37, 24 I agree. So that there are two ways.to look-at it. 25 I looked at it one way because there is no. explanation for-it. C:) Heritage Reporting Corporation (202) 628-4888

' ;l a. o _ 5456-CEDER - CROSS [() Well, of. course, the;way that'you looked atLit,_gave ~ j 1 Q 2 you.a higher number, didn't it?l -) 3 A- '(Ceder). What number.you.can come upiwith:the;same',. 1 y. 4 maybe -- 1 5 Q Doctor, I made it clear to you,:I;am not technical!., z 6 'Why don't you do?the calculation the right'way nowF andisee:how1 y{ g- 'h 7 it comes out? 4.A ,' (i -3 l 1. .1. _f 8 MR.-FIERCE: Objection to'the use of;thecterm,1the r 9 right way. He will do/it(theiway that]Mr[ Digna~n is S q

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~ ~ ~ ^ 10 suggesting. 11 MR. DIGNAN: sI withdrawf the ' word', "right'%. do :it the ? ,C s U l 12 other way, doctor. 13 (Witness makes calculation.)' 14 THE' WITNESS'-(Ceder):. If you willigive me one-^other 15 minute, I will do it. 16 (Pause.) 17 THE WITNESS 1(Ceder): ILcompleted'it. 18 BY MR. DIGNAN: 19 Q What do you get for a number?,' ( 20 A (Ceder) 2.53, instead of 2.56. 21 Q All right, do you wish to change your testimony from ~ 22 2.56 to 2.53, having had your attention called to the other. I 23 material in the article? 24 A. (Ceder) Essentially.the same for the purposeLILput'., l 25 my testimony. Heritage -Reporting Corporation (202) 628-4888 t .___.__mamu._.-___._._i.m_m.m2___-a___ _h-___--u-...____.--a_.___2-a-______--_e_ .-.a.______m*. _ _. m u ._.._..__.m

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Now,.; doctor,<let's(goion=in your testimony.- % l n

s t s ~ L '7 In the. testimony you'say again,7..if~a conservative-a is 9 perspective. is ;to be; achiAved,f thisiheadway)shouldibeilncreased ' j '8 I I v g f c.,: l; L / -9 ' from - 2'. 4, f which is our lnumlSeQ toI2'. 7 '.' ' ' ~ ' N C i 9 And you base that:2.7 on'the fac.t that:previousl.y9you; ,1 10 3 3 ,+ r f ..y .,- v s l'1 had found it'to be[2i63. \\ '4 9 Vi n ' M, j /' s , - Y;'x. j y_{ ~ l(e ' 12 MR.. FIERCE: - Objection,J!that...is :. mischaracterizat' ion;.f '  ! 4 ',' H t y l 13 of his testimony;. H 1 3 -r .w. p v 14 He.gave us:this.one.examp.le. y 'o. -i

}

m. t 15 JUDGE SMITH: Well, let's let Dr. Cederidecide if?lt! 16 is mischaracterized. yh.- i

c,

a o I i l 17 MR. FIERCE: His'testimonyjis written',;for. example,; y ,J 18 that is my point. V,- p, 19 MR. DIGNANs., What, what.are we talking;about?> q' 20 .MR. FIERCE:a'In.this sentence'regarding. Salter iti ,s. 21 says, "In Salter, R.J., Highway Traffic'Analysisiand Desigit,.' 22 Addison Wesley, Publishing Company,. 1974, for example, one can. T] e 1 23 find this headway for an observed vehicles.was'foundcon average. r d 24 to be 2. i b 25 MR. DIGNAN: -- right, and.then it.goes on.having.. q , b 't Heritage Reporting l Corporation. (202)-628-4888~ a s Jf l \\ k ) O

y, m c ~ / CEDER -1 CROSS'- '5458 1. done the~ calculation which he has now' changed, and he-'said'the' 2 following,1"Again, if.a. conservative-perspective lis't'.be: o ~3 achieved, this headway should)beLincreased from 2.4":m'eaning; 4 'ours, "to 2.7."' o \\ 5 MR. FIERCE: My only objection'was'to the' 6 characterization in the question which was that the' conclusion ~ 7 that he reached was based. solely onJthe Salter: calculations,f .g 8.- .which'is simply not true. t.. 2 I 9 JUDGE SMITHb.Let!s;'let'Dr... Coder tell us.. ,;j 10 BY MR.:DIGNAN:' y 3 .e 11 Q Doctor,c"didnttLyou.usel2.7,:because you:had,the 2.63! 12 out of Salter to rely on? 3 13 A (Ceder) ?2.63:and+2.52'or 2.5,'litJmeans toime the D 14 same, why I mention 2.7. If you round the 2.63, then you:get- .j 4 15-2.6,,so I put on purpose the:2.7 to indicate something'else,- 4 i 16 and I,think that.which I even' marked down'it, andElet me-read l n l 17 it from my testimony. d 1 4 l 18 In addition, the.. remark made..'on'pagel3-3,.'in Volume 19 6, and to explain why the saturation discharge' headway.is a.- 1j 20 conservative estimate. 1 21 And what I am trying to say here, is'that it.is-22 indicated very clearly, very strongly, that1 1t is a 23 conservative number. And this islthe reason why.I said,fas a 24 profession, if we do want to use-conservative numbers', andlwe 25 deal with congestion situations,LI would rather use 2.7 even O Heritage Reporting Corporation. (202) 628-4888' 1 1-g,

y> } Q% a .n CEDER -' CROSS. .5459,', -O. ~V-1 .after those corrections,;those: minor corrections, if the t':is 2 our purposes. 3, Q DoctorJ-- '4 ' JUDGE SMITH: -Just a moment. 5 MR. DIGNAN: 'I.am sorry.-

1 6

JUDGE SMITH: Mr. Fierce, was your. objection attended'

)

.7 to? I don't-believe'that it'was. l 8 Was'your objection to;the effect.that the'statementi j I' i l' .9 beginning, again, if a conservative ; perspective als to be 4 j .~ n ' 10 achieved', this headway should be: nereased from"2.4 to.2.7i -j s.( n seconds,'per vehicls,'.was not9 predicated"upon the' earlier H 11 t e i 7 i t sentence, which 'as as'an example.' 12 w -Was that,your, point'f, 13 ? O. 1, n... ' 4 L 14 MR. FIERCE:- That is'right. 15 g The question he asked was, so your. conclusion,from j.- 16 Salter that it was 2.63, I don't thitik:his conclusion; 17 JUDGE SMITH: Well, let's -- 9 18 MR. FIERCE: that it : should bef.2'.7,- wa'si derived' l l l 19~ solely'from the~ Salter article. ] \\ n 'l 20 JUDGE SMITH: Right, and I thinkathat'may.have been-

j J

21 the essence of his answer, but let's put it"to him quite lc 22 specifically, j 23 When you state, in your testimony there,7for example, 1 24 one can find this headway.for an observed 80 vehicles was;found., q 25 on the average to be.2.56, as it reads now,.second per vehicle, 1 'Q 'I r V Heritage; Reporting' Corporation (202)1 62.8-48881 1 4 ci _.__________Mi_.m___._._..__________________m ._m It: ~

y y :ic 1] s + < ,s se 1 s .*n 3 i i..., ( ( ) ~ l ,a LCEDER-' ' CROSS-5460' 1 is that'the predicate for your next sentence? A- / 2-Is.that the basis for your next' sentence?. .i 3 THE WITNESS (Ceder) ) This'is an' example, but it is' 4 the.next statement can. stand by.itself,.without any examples.: Mq l -5 JUDGE SMITH.. So you are not.saying, therefore,Liffa: \\h 6 conservative approach -- T ;; I) 7 ~ THE. WITNESS (Ceder): .Right. 'l c 8' < JUDGE' SMITH: ~You'areysaying,'again,.thatEis;a .. j J 9 . separate thought,;and it'can stand by.'itself, ]l j 1 r L THE WITNESS"(Ceder)::Right,,'because.I.haveiotherl .10 n ,1 ~11-sources, and I mentioned that up there,.'I.' disagree and soedo q i a ......t S + ' "l - 12 others in the professions- ,wr, ~' 13 Saturation this headway is.a concept and so forth. 'I U i O L. j l . 14 am indicating it veryc clearly anil:I have other source., 4ut I s; 15 . did not find proper to'put everything.here.

9 16 MR. DIGNAN - All.right, you have answered..my,,

17 . question. 18 BY MR. DIGNAN: 19 0 But you have elected on your own, not?to cite any . 20 other source, except-Salter,.is that right? 21 A (Ceder) If I elected him -- u 22 -Q No, try a direct answer to that question.' 23 A (Ceder) Could I have.it repeated?l L 24 JUDGE SMITH: .My. sense is..that he: genuinely is; 25 confused. s ll.Q_ HeritageL Reporting Corporation -(202) 628-4888 ^ 1 'f ~ .e 1

~; .; n-7' c g ' ', - 4; E 4 -b .-( t i' ' 4 r. s-s 4 r N j .k / 6 4 4 '5461 1-CEDER - CROSSL q m U k.[ 1 >BY MR. DIGNAN:- 1 7 y Q But you ele'cted on your own, when you prepared this; -l '2 - L ,L q 3 testimony.to. cite, no other example',--except Saltcr, isothat: y j 4' correct? l l 5 . A'- (Ceder)_ I electe'd?' Yes. i '6 _ Q 'Okay. l 7 Now', let's talk a'little' bit more about.the' Salter-8 - study. q 9 Where was the.S' alter study-done.? M 10-A (Cedcr) Engicind., m. l' 11. Q In Bradford, Er5 gland? y S i 12 A (Ceder)- That is correct.; g.? s,- s .o 'l 13 Q Now, in that article,'he~also'bheaksidown the" O l 14 vehicles that heJobservedia:did he.not?; l 15 In the bottom'of'the page?- 16 A .(Ceder) All'right. 17 Q And he found that.14% were heavy vehicles? 18 A (Ceder) Correct. 1 x 1 i 19 Q And that,=you know,-to mean~ trucks,. dont.you?-- i 1 20 A (Ceder) Most of them, yes. 1 - s 21 ' Q And he found_S% buses? ) Jj 22 A (Ceder) Right. l 23-Q Six percent = motorcycles? 24 A (Ceder) Right. 25 Q And 70% cars,.75% cars? LO Heritage Reporting Corporation N (202) 628.4888 / h y m.__.__m___.__1._m___m-m_ __m.m_.____

y9 .x 3, m

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e n )., 3 i i m-s j .i. 3 - o ,p 1 <w m ,l' i d' q .f, t I g ,;.,n'.,r t ~ r - ( CEDER -. CROSS 5462: .t '1 ' ~ A (Ceder) .Yes.'_ ,2 a o Li a st i c .2 Q-Now, are you'famill'ar!with the observations.<which KLD d9 3 'made.:and used, that appeariinathe.ETE. study at page 3-8?) 4

4 A

(Ceder) - I can lookfat it. j '1 5 (Witnes s examines.. document.') - "L y,: j 6 THE WITNESS (Ceder):. ThreeLdasheight?' 4 7 MR..DIGNAN: Yes. m, ( 8 THE WITNESS (Ceder): Yes. 1 - 3 1 1: fi 9 BY MR. DIGNAN. ] 1 10 Q. ' Now, Doctor, 'iMthe observations which LKLD[use'd 'whicli-j r 's /' t 5.. ? g

1 4

11 were.tsken in this area,.they,had a' breakdown..of l%_' trucks;.1%-.., ,1 12 buses; 4% recreational: vehicles,;and the balancebeing 4 t, n, y. j 13 ~ passenger cars. i 1 i 14 Isn't that correct?? e8 : '. .y l 15 A (Ceder) That!what31's3indicatedhyes.

{

L j 16 Q And it was -- and youLdidEunderstand,.did you;not,- d 17 that the KLD figure, of-2.4) is basediupon what areyknown'as' 7j 18 passenger car equivalents? j -) l 19 Isn't that what they did?_- ~ )i 20 A (Ceder) Can you show nie where it is indicatedf-21-passenger cars equivalent in their-study? 22 (Pause.) ( H 23 BY MR.. DIGNAN: I 1 24 Q Do.you see at the bottom paragraph:- the problem;1s. ~ I 25 that I did not bring my marked-up copy and I apologize, doctor h' ~ Heritage Reporting-Corporation 4 (202) 628-4888 l 1 1 __.m_-_____ __m_.m___.___-_m__ .______________..___L______m._. _. _ _ _ _. _ m m

y_ i3 y s 9; L{ '3 ) s jj t1 t;4 CEDER-X CROSS .:5463.

• j

.,. M).' -- thecbottom paragraph, the'vehiEle mixed factor is! based both. 1 ~ 4 2 on the percentages.ef heavy vehicles,_ and on the passenger- ~ L 3 cars,; equivalent-value ofTeach vehicle type, do you.see that at .a 4 the bottom?.' ? 5 . A (Ceder),;Which page? y 6 'Q At'the bottom;of page'3-8, the paragraph that? appears o- "7 ~at'the cottom? 8 .A (Ceder') Yes. o m E +i1 1 9

Q,

Do you agree with mel, then,.that their 2.4 figure lis il i i l-10 based on passenger car equivalents? ~ 11-A (Ceder). Here Lti is.not -- there 1sf nothing y i ~12 -mentioning about discharge" rate'.- Her% It is mentioning about: - j A 13 determination.ofithe levelfofDservice;E,jso thatithis is'about: (, L

)

s 14-factors, and I don't.'see'howLdu y,ou correlate. 9 a L 15 This.is= correlated >to 3.7,athe. equation';there, j v 34 i 16' 'two-lane roads. LHow c'ome' yo6 correlate to an intersection?- 1 17 =Q Well, doctor, do you ' recall ( that' in'. your testimony, 18 you criticized the 2.4. figure.. J. 19 A-(Ceder) That is. correct.' 20 Q And my question to'you,is:very' simple, do you.- 21 understand that the 2.4. figure'to-be.a. figure involving l L 27 passenger car equivalents, or something else?' 23 A (Ceder) It is-not passenger, not indicated passenger 24 car equivalent, but it is indicating simply the' discharge' rate. 25 per vehic1'e. Heritage ' Reporting' Corporation? (202)'628-4888~ I ' I [' ___z____ _____._______._a__.._____________ _A

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. 5464' .o CBDER - CROSS 1 Q And what vehicles' were inciuded, :anythingiother: than: passenger cars? 2 A. (Cedi9rr All vehicle _ crossing the intersection;.

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.Q And'in the-KLD ob'servation', what.did.those: vehicles l 5-turn ou't to be? ~ r 6 ' Virtually all' passenger. cars?,- - t-7 ' A- .(Ceder)i All passenger.land other cars, all_ cars, 8 crossing an intersection.- R 4 9 Q Now, you recall in.' the : Salter study, as.: much asI25% L 3 10 of the vehicles.used,'were other thanfears, right? 11 A '(Ceder)'.Right. y. + 12 Q. Now, if you go,overi;to..page,285', Professor Salter. Li ~ 13 First o'f 'all, let me ask you this,1the calculation-O ' that you did --; ,s. ,3 ,4 q 14' [' g . 15 A (Ceder) _Yes. for us, ~ t' 79et 2 [56',. was _' not[ sin anythingKlike f. 16 Q o 17 passenger, car equivalents, or; passenger ; car Junits,f was-it' it a 18 was just observed _ vehicles? 19 A (Ceder).That is-correct. ,a 20 Q Now, you come on over-to the-next page, can1you;tell "] 21 from there, what Professor Salter found_his figure-to be, using. 22 passenger car equivalents?' I -t 23 A (Ceder) He applied the passenger car unit l 24 equivalent, and converted his numbers. 1 25 Q He did did he not/ ]l O 1 Heritage Reporting. Corporation ~ (202)'.628-4888 1

p

___..-_____._.__.m_.~_..m __.m_._

o CEDER'- CROSS' 15465 7-I 1 A- . (Ceder). Yes. 2 Q And the number he would reach', on thatepage, would be-I 3 to take, since he got'1,670 passenger car units,.per hour? ,1 4 A' (Ceder)' Correct.- 5 0 -And.he would' derive, you would divide that into'the' 6 number of seconds!in an' hour, which is 3,600?' o 7 A' (Ceder) Yes.- g. 8 Q And the answer is 2.15568867 9 A. -(Ceder) Car equivalent units, yes. S 10 Q And so in passenger car equivalents,.he.got a headway 1 11 of 2.16 seconds per vehicle, did he not?- 12 =A (Ceder). Itis [aconverted, number,yes. . <. ~ E ti ~ 13 Q And so -if it 'be' that our headway of 2.4:'isL based on-passenger car observations,- only,Uor passenger -' car ' equivalents,f j 14 v-~ yo l-15 we are extremely. conservative'accodding to'Pr'ofessor~ Salter',' ~ 16 are we not? y1 n g. 17 A' (Ceder) ' Extremely conservative, I don't:think so. 18 Q According to Professor Salter who got 2.16? (- 19 A (Ceder).Within the context of what we:are dealingf j i 20 with, namely evacuation scenarios, we are not,.I. don't think.it. j l 21 is conservative. l .) 22 If we compare it to Professor. Salter, it is a 'I 23 conservative number. 24 Q And we have already established that Professor Salter. 1 25 is the only source you decided'to cite, in the testimonyLthat j 'I L() Heritage' Reporting. Corporation (202) 628-4888 11 i L i

CEDER - CROSS 5466 N_/ 1 you brought here? 2 A (Ceder) I decided, but I have other sources, from 3 the United States that can show that when you are in a 4 congested situation,'the saturated rate may go up and 5 therefore, I am saying it is not conservative number. 6 MR. DIGNAN: I believe that is all that I'have, Your 7 Honor, on this matter. 8 Now, the only thing I have left is I had some recross 9 coming out of the redirect that went on so far, but I assume 10 that I should hold that until counsel completes his redirect? 11 JUDGE SMITH: Yes, this was just an interruption to 12 go back to your original cross. 13 MR. DIGNAN: Thank you, Your' Honor. 14 JUDGE SMITH: Mr. Fierce?

• S MR. DIGNANt-Oh, Your*Monor, may I. offer Applicants' 16 Exhibit Number 24, for identification, into evidence, for 1

17 impeachment purposes only. 18 JUDGE SMITH: Do you. object, Mr. Pierce? 19 MR. FIERCE: I believe that it has been explained so 20 thoroughly here, as to what has gone on that we should offer 21 this into evidence. 22 JUDGE SMITH: As your own Exhibic? 23 MR. FIERCE: Pardon? 24 JUDGE SMITH: As your own Exhibit? l 25 You said that it should not be offered into evidence? (O, Heritage Reporting Corporation (202) 628-4888

l t 4 CEDER -: CROSS 5467-1" . b). 1 MR. FIERCE: No, I think that'it should be offered 2 into. evidence, at this' point. y 3 JUDGE SMITH: Oh, all right, without. restriction.- 4 MR. FIERCC' Without restriction. 5 MR. DIGNAN: 'I, offer it, thefApplicantsiofferLit;for 6 impeachment purposes,'only. -7 ' JUDGE SMITH: I'think that we.w111' accept that andL .your ot er opt on is to offer it on your.own, and-then youLwill-8 h i 9 have to justify it. 10 MR. FIERCE: Should I proceed? 11 JUDGE SMITH: As I say,:all right, then the 12 Applicants' offer to admit Applicants' Exhibit' Number 24 for 13 impeachment purposes is~ granted,;and the Exhibit is received. 'fl N/ 14 And I assume that you want it bound? 15 MR. DIGNANr 'Yes,j our Honorf we.will" supply Y 16 sufficient copies so"tinat"1A'w111'be'bobnd'l to'theLtranscript 17 of the proceeding. 18 JUDGE SMITH: Mr. Fierce, I wonder if~you understand 19 what my ruling was? 20 MR. FitRCE: 'I think that I do. 21 JUDGE SMITH: Okay. 22 MR. FIERCE: And we will try to come back to it in 23 the redirect. 24' JUDGE' SMITH: 'All right. 25 ) (~'$ Heritage Reporting. Corporation (202) 628-4888: mO___N---_-__..--------_-_ -_A--.

5-) a, ~ f[i 4 7 4. ,m l [4(OV l. 33 T1e effect of roacway anc environment. factors on tle I capacity of a traffic-signa approac.1 The capasits t a uani; ynal controlled interseenon is linuted bs the capacities of the mdisidual approaches to the intersection. There are two ty pes of factor which alTect the capacity of an approach: roadway >{ and environmental factors, discussed in this chapter, and traffic and control factors discussed m chapter 34 The roadwav and environmental factors that control the capacity of an approach are the physteallasout of the approach,in particular its width, the radii alone which left, or right. turning vehicles han to travel, and the gradient of the approach and its exit from the intersection. The capacity on an approach is measured independently of traffle and control factors and is expressed as the saturation flow, i. Saturauon llow is defined as the maximum flow, expressed as equivalent passenger 1 cars, that can cross the stop line of the approach when there is a continuous green signal indication and a continuous queue of vehicles on the approach. 1 Observations of traffic flow made by the Road Research I.aboratory at intersections in the London area and also in some of the larger cities, supplemented by controlled experiments at tne I.aboratory test track. have shown that the saturation flowts) expressed in passenser ear units per hour with no parked vehicles is gnen by l t s = 550w p.e.u./h . lp* where w is the width of the appiaaeh in metres. 1E This formuia is appheable to approach widths greater than 5 5 m; at widths less than 5 5 m the relationship is not 1;near and saturation flows may be estimated from table 33.1.

( '

282 i.' ((Ch E.

~s } L i 283 TRAITIC SIGNAL APPROACH: CONTROLLING FACTORS .h TAllLE 33.1 f) 300 346 3 t>5 4 00 4 50 5 20 3 i t w un, si

u. hi 18so 1875 19nn 195n 2250 2700 f

-[ These saturanon llows ha.c to be amended for the ef fect of gradient. This moditica. 1 tion ha, been reported as a decrease or iitereuse of 3 per cent in the saturation flow for [ escr> 1 per cent of uphill or downhill gradient ut the approxh. t he gradient of the i approxh was defined as the aserage slope hetween the stop kne and a point on the I i approuh on m before it. At the sites where these observauuns were made. the slope f conunued throuah the intersecoun. Where vehicle's crossing the stop line have then to travel unmediately around a curve ( the rare of discharge across the stop line will be reduced 1his occurs frequently when rigin turnmg vehicles are able to discharge during a nght.turnmg phase. Test track j expernnents have shown that the saturation flow for right turning streams may be g i obtamed from i i l ( 1800 p.e.u./h. for single. tile streams l s= l t 15 2ir i or i600 p.c.u.!h 3000 p.e.u.!h for double file streams s = I + l 52lr or 2700 p.e.u./h where r = turning radius in metres. The ensironmem also has an effect on.the saturation tiow of an approach and while it l _e O is difheuh to deline this effect precisely generalized modification factors are often applied. j I 1 Where a site is designed with a good environment, th:n. is dual carriageway approaches, l no nottecable pedestrian interference, no parked vehicles. no mterferences to traffic flow trorn right turning vehicles, good visibility and adequate turning radil then the } e t saturanon slow is taken as 120 per cent of the standard value. f If however a site is designed with poor environment. that is low average speeds, j i interference from standing vehicles and right. turning vehicles, poor visibility and poor alignment. then the saturation 110w is taken as 85 per cent of the standard value. I Determinatiott of the saturatiort flow of a traffic. signal approach To detennine the saturation llow of an approach select one in which there is a con-I tmuous queue even at the end of the greet; period. Avoid situations in which right- ) turning sehicles have an erratic effect on the traffic flow. For ease of observation it is prelerable to select an approach that is restricted to straight ahead and left turning j 3 vehides. ll sing a stopwatch note the number, type and turning movement of each vehicle crossing the stop Une during each successive 01 minute interval of the green and amber d i period. At the end of the amtvr period there will normally be an interval ofless than f 0 I minute. Note the length of thisinterval and also the number and type of vehicles 1 ( s ~f 4 s 1 i il I

^ ^ z ( d I [i.; 1y 284 TRAFFIC SIGNAL CONTROL l crossing the stop line in the mierval. These intervals are subsequently referred to as last j saturated intervals. p l If at any time the flow on the approach is not satu'.ated, then observations should i I be discontinued until the flow reaches saturation level again, b ifit is not found possible to hbserve vehicle type theti only the number and turning b I ^ ' movement of schicles should he' need At the completion of observations a separate b d ' :.! :. count is then necessary to desenmne the 00mposition of the tra! Tie slow, !c 1: I The observations p'ven in table 33.2 we'r4lobt.urd at a traffic-signdi controlled 1f.W i;

intersection in the City of liradfiird. In th)s.ihstdnee observations were made.iif mixed ! 4 ' f" vehkles travelling straight alicad.

TAIJLE 33.2 Observed discharge of schieles across the stop line Tirne #rninute) 0 0- t 02 03 n4 05 j' M No. of vehicles crosung stopline 60 76 71 78 79 t, No. of saturated intervals obsened '32 32 32 32 32 f j t Discharpe pes o-i min 1 88 248 2 22 2 44 2.17 j Total duration of the last saturated intervals = 142 seconds i Total number of vehicles crossing stop line = 41. Discharge per 01 tmnute during last saturated interval = (4i 6)/142 = l 74 schielesls i Dunng the lirst and last saturated intervals there is a loss of capacity because of the effect of velncles acceleratmg Itom the stationary position at the cornment.ement of the green period and decelerating during the amber period. The flow during the remainder of the observed periods represents the maximum ' discharge possible and their mean value gives the saturation flow for the approach i 2 48 + 2 22 + 2 44 + 2 47 saturatmn flow = l 0 L 4 u 4-2 40 vehicles per 0-I minute = 1440 vehicles /h lhis value must now be co:nerted to traffic. signal passenger car units and a subsidiary traffic count is required to deternune the composition of the traffic. Observe the composnion and turmng movements of the trallie flow for a period of 30 minutes and at similar tune to when the original observations were made. The following composition of trallie was noted on the approach where the flow ligures given in table 33.2 were observed (esmg the equivalent effects of various vehicle types i given in chapter 34) l 1 heavy schieles 14 per cent j buses 5 per cent i motor cycles 6 per cent l pnvate cars 75 per cent i all velucles proceed straight ahead l t l ^ l j ~. F l L i i !w..

TRAFFIC SIGNAL APPROACll: CONTROLLING FACTORS 285 The passenger sur equivalent of the tiow is then -l l + 14 x l 75 + 0 05 x 2 25 + 0 06 x 0 33 + 0 75 x ! = l 16 i i t .. I Saturation ihm - 1440 x l I6 .j = 1670 p.c.u lh. ,I i The design tigine gnen in Raid Research TechmcalPaper 5n is l')00 p.e.u./h for a - 1 3 h5 m lane width. I Problenn Four differine n.ufic smaal approaches are described below. Place them in the order of 'l 1 their trallie capasa:. (at An approah with good emironmental conditions where all sehicles discharge straight acros.s the miersection and where the approach width is 7 30 m. e I (b; An approach with poor enviromnental conditions with a continuous uphill gradient )

l of 3 per cent. u ncre all schieles diwharge straight across the intenesnon and where the

{ approach width n 10 50 m. i. 6 (c) An approxb with noimal emirontnental conditions from winsh all vehicles turn f' right m a douh'e li!e -ticarn on a path with a radius of 30 m. s i i (d) An appioun unh eood ermronmental conditions and downinii padient ut 4 per. i,! cent. where aii s.tincies discharge straight across the intersection and where the approach li 1 l width is 5-20 m. i 9 'r u E Solutions The traffic capnines of the approaches are: l 3 (a) saturation tiow = 550 x 7 30 = 4015 p.e.u./h j plus environmental tactor of 207 j = 4015 x l 2 { = 48 iS p.e.u./h ~ (b) saturanon tiow = 550 x 10 50 = $775 p.e.u./h l minus environmental taetor of 15',7 [ i l. = 5775 x 0 85 = 4909 p.e.u.!h i

)

minus gradient effect of 3 x M = 4909 x 0 91 = 4407 p.c.u./h i 5 c-i j ' I, \\ l 1 .l 1

l s 2S6 TRAFFIC SIGNAL CONTROL i' 3000 tu saturation Cow = p.e.u./h j i t 152/r l4 3000 a .4 'I a !.i I + l 52/30 )?E i t ' ; t 'I

i,

= '857 p.c.u./h + 4 II'[' . Idi saturation flow = 2700 p.c. : /h (table 33.11 , [ fl[ 2 I q

.l pan environmental factor of 20%

ir- >d'

'} P,

= 2700 x l 2 e = 3240 p.e.u.lh plus padient elTe:t of 4 x 3% = 3240 x 1 12 ( = 3629 p.e.u./h the order of capacity of the approaches is (a).(hh (d),(c). t i. i ! T P P i t t + o: s i o tl i ij k al it! 7 1 l di } !. l 4 n .. ]. ; ; l 25", i n - p - l ji d l k G c: r ut e 44l . i . h4 1 cs '.,d I:i h- ,e ). i 1 6 I i 1

1 s s .;q c 1 7 i j 4 1 i CEDER CROSS-5468. i1 'l .(The;documentcpreviouslyl.' 1,.. 4 2 referred masked:for. g - identification ! as'- 7' 3 '4 -Applicants'HExhibit 7 5. .NumberJ24,-was received.L q 6 into evidence.)

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.(The Applicants ' Exhibiti. w ~ ' > t .I i ,_( 8 . Number 24'was' bound"into, J.' l. i ( - the~. transcript'.)- ]. 9 .10 i i i l- ~11 r i 12 i, 4. m. l 13 'L ct 'e A y-O D 14 / v. . p', <-, w I-9 .15- ., =- , j, ', 1 L 16-f - ^,, f 1 ~ " "' ~ S 1~, " N y. ly %.J ' 4 ji j 1 e H 17 .T.T, 1, l i I J i.

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5469' 1

. REDIRECT EXAMINATION (Resumed)- i.- 2 BY MR. FIERCE: .3 Q I think that I: amGgoing to rtake.:up: this;. top,1c, right: 4 'now, with you, Dr. Ceder. 5' First of all,iregarding thb Salter article,jwas.the' 6. Salter study of vehicles at-Bradford, England,itaken under, 7 done under saturated congested' flow conditions? 1 U

! L.

i8 ~A (Ceder) No. 'It.was done.under' normal? conditions,'.- 9 not saturated conditions. -10 Q And, in-your. professional' opinion,Eisisaturation. 11 discharge headway under congested'flowjconditions (level of-12 service F conditions, likely to.be, higher than it would;be,,- o 13 under levels of service conditions that age'less severe?than-14 that? + t 15 A (Ceder) For the1 professional' iti 'is; straightforwa'rd, ~ ., o ~ 16 should be higher, arid 'if you. allowed me,=Irindicated references d a lookddyesterdayfand*--+ I 17 which I just 18 0 I will.get to.,that in;assecond,ibbt with respect'lto. ~ x' O ' l

• q 19 Salter then, the passengerccar. equivalent calculation;that Mr.'

20 Dignan pointed you to, in the Salter. article, is a1 passenger -i ) 21 car equivalent calculation for.seturated discharge-hea'dway,: 3. 22. under less than congested flop. o'JLtions, is that correct? 23 A (Ceder) That is. cot; c. 24 Q And when you compare that with a situation which is 25-likely to be experienced in an evacuation from Seabrook'lcwith 3 g Heritage, Repo_rting Corporation _(202) 628-4888 ~,1 mE___._..._._____._i._._ ._1___

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['E 5'470 .om )I 1 very congested conditions ci crri g, 1sithat one of the factors-c 1 '2 that you take into.accounc when you say that that. figure is not d YO' il 3 conservative? 'l .i' i '4 The use of that datu :for Seabscok purposes is ' noti, h i; 5 conservative? j 1 That is correct. J i 6 A (Ceder) 7 Q And now, you'have mentioned that you have a. number of 8 other sources that you-could refer u's to.with respect.toEyour 9 st'atement, in your testimony, that headwayfshould be increased ~ 10 in the model from 2.4~to 2';7 seconds per vehicle. 11 Do you have any of those other sources with you 4 12 today? l l~ 13-A (Ceder) Yes. ^ 4 A 14 Q And what is that? s

l I

i 15 MR. DIGNAN: IObjection,Jand I would l'ike.to;be; heard. l Youcanb{' heard. 16 JUDGE SMITH ' 17 MR. DI'GNAN:.kYour[Honbr,fthislisindtd.whatil, 18 understand to be proper redirect'.. ' Redirect is-co' fine'd toithe n s n + Trie witness 4 came in' h'ere, and gave us Lone.

l 19 scope of the cross.

E .20 article, and I have crossed that article. I deliberately did 21 not let him,.indeed, get into any other articles. I did not' 22 purport to ask him about'any.other articles, i 23 He kept trying to shout them in, but I did not ask l 24 him a question about them. This.is.not redirect. This is 1 25 initial direct. 4 ( Heritage t'eporting Corporation (202) 628-4888 w__x----

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Now,.here is al witness'that'has-been' presented,:. when 2 .he was presented,.we;were told that'weihad.to. cross him~by,the( m9 3 .end of,the day, today..And he relied'on'one article when?he:

j 4

came.in here,Jand I think'that for'him to'befallowed..to shovei 5-

a bunch,of-other literature in thatlI.willLhave no. opportunity..

p 'l 4 6 to review! carefully:and,:as Your Honor,uI1 hope, cancargreciate,. H q 7 it took'a lot.of-careful' work-.to do.whati-I.was able'to do,Lif;I. l 8 was able.to do anything, with those.otherearticles.- L l L l' 0 ( 9

And I -just claim surprise, andnI:think;that ittis; 1

10 -unfair. I don't think-that he-ahould be,.'at this juncture,. 4 11 allowed to pump a new bunch,ofL11terature in to back th'is' 12 number up. 13 MR '. FIERCE: .Your: Honor,-may I respond? R g]- - 14 JUDGE SMITH:' 'Yes, you may. l ~. ~ ~ ~ L 15 MR. FIERCE: I.have alreadygread you what1the s e s o 16 sentence says and I will"rbdd it'again.- -l Salter,-Highway Traffic [ Analysis,and, Design,fArticle- - 17 N, c .1 g. y 18 in 1974. ~ "C# j \\ 19 "For example,'one can. find that,jhisJheadwayf rom j f v. 20 observed vehicles, was found, on the average to'be 2.56 seconds. 1'i l 21 per vehicle " N ~I 22 Yes, he elected-to cite no other articles thanithis 23 one but he specifically used the term, "for examp1'e" and I~ q 24 submit that the thrust of this entire calculation wasiintended 25 to show.or leave the' impression.that this was.the articlecuponc . A. - \\_/ Heritage-Reporting R,rporation I (202) 628-4860 i s 4 a 1 __. _. _ _ _ m

i> .547? l' which Dr. Ceder based this conclusion;that the; discharge 2 headway for Seabrook's calculations in-I DYNEV'shouldibei L ncreased:from 2.'4 to~2.7'. 3.- i + 4 'He.has Indicated,Lrepeatedly throughout1his cross - S' ~ examination.with Mr.JDignan,.that he had'other cites,Tand hes 6 has been begging-the opportunity to explain what theselother 7 cites.are.- '8 And I think,'in all fairness, he deserves..an. 9 opportunity to explain to the Board,L what 'some of these1.othere > 10 cites were. l 11 Now, let me also suggest thatLMr. Dignan will haveLari 12 opportunity to submit rebuttal testimony, if he wishes..He 13. submitted to us, absoletely no discovery;whatiso ever, with': Ad 14 respect' to our expert witnesses,'. on -tihe ETE 's. ~" l 15 If he had, he:could have learnedLabout.Dr. Ceder [ and' 1 16 perhaps ask some questions about? his '. work ~. - J

He wa's inLtown'.

g l. 17 And he could.have,been< deposed at that point. Mr. Dignan did1 18-not do it. 4

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+ s 4 19 And now he is trying to limit.this7 testimony,?I 20 think, severely here. I..think tNat)itfis,just'a fair.. comment, L 21 based on the cross-examination that has occurred, that:Dr. 22 Ceder be allowed to at least mention the ' title of one of these ~ 23 other articles. d l 24 I don't intend to go into it in any great riepth.. 25 JUDGE SMITH: The Board'will have to consult'.'This.is-O l -Heritage Reporting Corporation .(202):628-4888' .,1 .l e e 1

f b hg + ws : g., y r ' 4 c,. s it. , e( ; c - v n m' yW ,}..lgo:.fl5f73 a k 1 a matter of -- we perceive.to'be of.graatLimportanc to ou \\ ,1 - W: '.l ' 's J y,'. ef j ; n", .2 testimony.

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At:the very'least,1 -whatLyNu hre going'to.be allowed N ((:'

z 3y m '4~ Eto doLis'to proffer. If;we?uphoN?Mr. Dignan 's/ object' ion,; you.: h! .J ' 7 ;j .will be able-to list the sources'?. V 3. he would haves. cited,.had.we-5 m V 6 permitted him.. C/2 G . (}0, - j _t:t1 i, f .j b, i 't y, 7 But we will'have'to6 ake 1s'to account,, ithe '. entire - /4 s lt t o m 4-

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"'3 8' scene as it unfolds hero, that-well, L it - 1s a little: bit : 9 early for the break. 10 'Would-you like to go ah'ead with your redirect,~and on 11 the break we will. return.to it? j

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12 MR.-FIERCE: Sure,.sure. 1 s - 1; 13 JUDGE SMITH: You are stating that all'you want to do, a ' (% p' _{ \\ 14 is to get him, you don't-want to embellish'or elaboYate','/you b,. /. s s.e want him to list the names.of the other sources t$$.1t hbfN.ould M 'u 15 3 f. r 3...

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,c gn 4A /.' ^ 7F-16 have relied upon? + k,. I L:' ; y l '!3 + 1 17 MR. FIERCE: That is right. Y d / T ,. ; T-.. All right,#w(ell, W wf,11 tellSyou what' 18 JUDGE SMITH: 3,.; 'F 19 we can do. .( ]!l

• You can do it,: as right.now,uas ;a prof fer, an'dfif,we y

20 , a 21 decide that it should be entered'in as a part;of his te'stimony, a 22 over Mr. Dignan's objections,.we will accept it as such. ^};:- ) 23 But just for continuity, get it in as a proffer. ' I. q 24 MR. FIERCE: Fine. sll ' v{ ' 25 MR. DIGNAN: So, I can understand' that rulir}g, Your ' 'i.y \\d -y, O ,q' I,,, a J ? t s' /af; .5 i ~ Heritage Reporting Corporati6n T (202) 620g4988 ,(. I . g~ + m, A'

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i. Mf21 nothing(idoreihanl.fisttitles,atthis'.. point?!

l 3 JUDGE. SMITH: ,Thatils whatLhedrepresented' wg f y, I' f BY MR'.. FIERCE: 4 ,e .a C7 - u ^ L 5 .Q. Dr. Ceder,,I[have,askedyouifyou?havebroughtiany?' ] a 6' of those-other documents along=with'you.today,.have}you?- t .l l 7 7 A-

(Ceder)Yes.

D m l' .8 M .Q: 'And'what is-the title of the documentn'that you.lhave 9 today?.-_

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) ,1 + ,i + i 10.. s A Y(Ceder) The title appears on:page.13, of my. l ,yv a ^ testimony, so that it.would)be easier to 16oli at Eit.:. ' On.page-11-y y 1 l' t 12 .13, there are two articles cited.there,fand one'_of themtic'the. 4 .t 13 one that I have hem, so. I f'N V 14 Q So you are saying<that'youN;ould.have1 cited _.thisj; d articleonpage13,isthat3y ~ f '\\ 15 g I 16 J A (Ceder).On page,13, s'omewhereffn theLmiddle underi .O, 17 number two, starting withetheiword",iPignataro., . ( ', This is.;the article that< L have:-here, fromL1978, r, w" ', L 18 1 f l NCHRP reports. ,j q,a .:p ,p s 19 q 20 0 So you would have cited this artiidle, ' that you have p o s 21 alreadypreviouslyciteiEfofanother' purpose-laterinyour-l 1 i 22 testimony, on page 197 g L l 23 A (Ceder) -That is correct. j 1 f <24 ~ So this -- and you have this article with you'1today?- ] Q j 25 -A (Ceder) Yes. 0 ' Heritage Reporting Corporation' W (202)-628-4888- .q g o 1. s., T.. c +,# ( a ] f(, W -i f 7' { f. 7 _hs , J L O L-u----L-----

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'py gru y u- ,j y'- . y }. '7 J r - ,3.. 3 J c ,/ g ^] ,z. q g; s R h y t k 'jy;. y wQ}f' Q 3 ,A'l ,Q _ 3 t ,a_ n ' ' " ~ 5475.- "i 4 _h_.e 1. Q 'And'are<there any other articles that'you hpve with I .t l 2 you,'today,1 that would support your'ci[ clusion that!'the: t g L discharge headway in 1I DU4EV shp! (d be : increased' from 2.4.to. 3 ,a , ;. 3 4 2.7?; f .p L' '(Ced r) There hre other articles, yes, Iido'have-- 5 .A 1 6 other articles.. 4, ; 0' + ~ j 7: Q Do you know the titles off.the, top.of!yourLhead,:as 8 to what-these' articles.are?. .j q 9 A ,(Ceder) LThe segond article.is the.same, number:one .j 10 here,.has less.information~.than number two, but it.'is also.an' 'i 11 article that can support what I said, and-on,page --- 12 0 Which article are you referring.to now? 13 A (Ceder) -- number 13,.you see, number one?' 14 This is another article. Everything-is dealing with _l 15 saturated conditions. .j 16 Q Is that article entitled, Traffic.Contro1 Din. 17 Saturated Conditions, Road Research Organization for Economic ~ 18 CooperationandDevelopment?/ 19 A (Ceder) Thab'is-correct.; y a s 4 ,j d 20 Q-January 1981?- 21 A (Ceder) Yes. i. 22

1. DGE SMITH:

Is that l'n his tiesti aony?- 23 .here :s that? 24 MR. ?TERCet These_are on page 13, articles that are 25 being cited. LO Heritage Reporting Corporation (202).628-4888 R l l i. 1 Z hmi____ m_.._._._.________i___.__i_._._____.._ i

.,g,. 5 v r 5476 .h 1 ! JUDGE SMITH: 'I'saw the.first'one, but I don't --'- 2 okay, right above it. 3, MR. FIERCE: 'But you.wciuld have primarl'ly referred to '4 the Pignataro,one?' 5 THE WITNESS-(Ceder): (Witness nods head-6 affirmatively.); 7. BYLMR. FIERCE: L 8-Q Dr.' Ceder, in your. professional opinion,'designingia' i 9 'model.toydo what-I-DYNEV.is'doing-here,-at Seabrook,'. estimating'- L 10 evacuation times, is it realistic,.not conservativecnow, but is-11-it realistic to-be using-a. number:for' saturated ~ discharge 12 headway of'2.47 '13 JUDGE SMITH: This is not.a'part.of:the proffer.. 0. si 14 MR. DIGNAN ' I take it that this:is straight-15 redirect. 16 MR. FIERCE:- No,'we are, going into the. redirect.- ~ 17 JUDGE SMITH: fall right. 18 Your answer previous td this,Jwas the~end:of the 19 prof fer, and now.fwe > are back on;yotir' redirect? 20 MR. FIERCE: (Thatfis right. ~ r- '21 THE WITNESS (Ceder): Let me answer.it carefully.fAs. l-22 a profession I would say" go'anhi check'it.in-the Seabrook are'a. 23 Go and check the. discharge rate, during highly 1 congested 24 situation, which may be seen during rush hours,.and see whatais l 25 the discharge rate, applied to that area, to those' cars,'to-O Heritage Reporting-Corporation! (202):628-4888 1 l

l 5477 rx !/ 1 those vehicles, in the surrounding. s 2 My understanding is that nothing, almost nothing has 3 been done with respect to satueated conditions in all of the 4 cited numbers, including the one which is-used in Volume 6, 5 refers to normal operation. j 6 Under normal operation, like'the one that we.may 1 7 expect in Seabrook area, I think that the number 2.4 isLtoo j .) 8 low and higher number like 2.7 need to be used because of the 9 congestion. 10 That is my opinion. 11 BY MR. FIERCE: 12 Q Would it also be appropriate to conduct such. field 13 measurements on congested roads-leading out of the beach areas,. Ix-14 in the summer time? 15 A (Ceder) That is a possibility, yes. 16 Q Isn't that even'more similar to what we might be 17 experiencing during an evacuation, than normal rush hour 18 traffic? 19 A (Ceder) I would think'so. If you can go there 20 during the dispersion of vehicles, with respect to the beach 21 population, it may be more similar to the' evabuation scenario ~ 22 than even rush hour, I agree. 23 Q And doctor, in your view, at this point in time, 24 having not done those field measurements, is 2.7, in your 25 opinion, a more realistic time to use for saturated discharge /% (_) Heritage Reporting Corporation (202) 628-4888 E _---

.o ~n; 5478 'i () I headway, than 2.47 2 A (Ceder) 'I think so. 3 Q Now, Dr. Ceder, I want to take youIback toJwhere'I 4 left off yesterday, when I was doing some' questioning ~and so as 5 not to confuse anyone, my approach was to take you basically _ 1 6 through your testimony, that was my order of attack. 7 -And I was asking you:some questions about someJof the 8 behavioral ~ assumptions that you discussed during;your cross- ^lj 9 examination that-you thought-might be questionable,cand-10 implicit in the-traffic control and management 1 tactics applied; 11 at Seabrook. 12 And I wanted to ask you some. questions now, about-13 another behavioral issue you raised in your testimony, which-is 14 the intersection at route 110, with I-95, and that is a1 traffic 15 control post that you have at. Attachment 3, of your testimony. 16 Would you turn to that' attachment now? l l 17 (Witness examines document.-) 18 THE WITNESS (Ceder): Okay, I have it',' Attachment 37 19 BY MR. FIERCE:, 4 20 Q Yes, Attachment 3. This15afigurei~ labeled, figure 1,:and.itisat ~ ~ 21 22 traffic control post that is labeled, post number B-AM-06, is 23 that correct? 24 A (Ceder) Yes. 25 Q Now, in questioning yesterday,.you were asked whether O Heritage Reporting Corporation (202) 628-4888 i --~w~. ..-_.u

..>,r. 1 i ^ l .547'9 A Q 1 your concerns about the abili.ty of. traffic"in the-.left l'ane, 2 .the left evacuating-lane, to m'ake the maneuvers suggestedlhere, 3 a sharp left turn and~then traversing of the curved median,. ) 4 would be alleviated if the traffic were to be routed: straight 5 through that-intersection, west, and.poss'ibly diverted.onito fJ ] 6 route 495,.a few miles down the road. 4; 7' Do you remember that?.

1 8-A (Ceder)

Yes. I 9 Q And'I'believe that yod said, in response to that i10 question, that your concerns were possiblyl alleviated, is that' 11 right? 12 A (Ceder) That is right.: 13 Q Now, I want to' clarify that,_if I might, at"this-7 14 point. 15 What did you mean exactly by possibly alleviated?L 16 Were you saying,that you only meant.that_if the ~ 17 traffic did not make this left-hand turnion-toithis off-ramp): 18 and over that curbed median, of. course, your-conc. erns about 19 whether traffic could traverse'it,jwere alleviated,_is that 20 what you are_saying? 3 1 -1 y 21 A (Ceder) Let me first :of all- --/the way that'it'is- ..~ 22 constructed'in Volume 6, and I understood through-the cross-1 23 examination yesterday, that:it was'ac'cepted, that.this.wayj 24 cannot be' handled during emergency situations. 1 25 It is unlikely that the vehicle.would'be ableito turn' 0: J , Heritage Reporting Corporation (202) 628-4888' 1 j

it. o ).., 4, W L5480 u b-].- r ' l ~1. 'lef t, and to have.a:'significant" amount of vehicles. going. 2 through that. turn. 3,, 3 The possibility to divert themand.to change:the 4 plan, to' divert them to.I-495, it< is a possibility.snd E : would w J I 5 . reach it at the first' place,,asva-pro ess on, Jbut~that's',;what ~ f i 6 I say, is a possibility and this may create.some.otheriproblems'- 7 which we. have to' investigate and-fin'd, out. in': terms j of capacity. ~ 8 Because'this-l's a: bottleneck. ? + \\ ~ 9. I can'just commentJon the fact that1those people 10 .comingfromSalisb6ry,.fromroute110$>towardLthis 11-intersection, will..see a big' sign, saying-to; Boston,fthroughsI-: 12 95. (, 13 So it-will'be, what we call in the profession,- 1 14 weaving situation,- weaving means that those lonithe: right--hand ' 15 side -- they have; two lanes -- those' on the - right-hand side,: .E 16 =which would like to continue to 495, will-have'probab'ly'to-17 force themselves to go to the left' lane. 18 -And those on the l' eft-hand side,which would~like to -i 19 cut and go directly to Boston,.would have to cut to the right, J. r 20 from the left. 21 Weca1{itweaving. ..This' weaving s'ituation1 reduces, .g 22 it is widely known,, or' reduces' tihe capacity,' reduces; the -amount 3 ~ >" y. w:> 23 of vehicles that this intersection can accommodate'per; unit of: 24 time, and at the same.ti'me, "obviously; increases the problem' or-25 the. rick of being involved in an accident. l Heritage Reporting. Corporation (202)1628-4888' l s \\b d2- _2__ _a_

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.) '5481 .O 1 Thet, 1s, ingenre1, se wey thet 1 cen co-eet. 1 2 .Q So'is it your. opinion, that if the left lane'of ~3 traffic were allowed to go straight-through toward 495, a? 4 weaving' situation would'be created?: 5 A (Ceder) That is very likely. 6 Q And, that therefore, additional investigation-is'

j 7

needed to determine what capacity would then - - 8 A (Ceder) That is correct.

q 9

Q. And now, as the plans exist'in Volume ~6, thisLis.:thet h 10. traffic control arrangement ~in the plans, is that not correct?-: ,.m 11. A (Ceder) In Volume 6,7yes. 3 12 Q And the ETE's tha't were calculatied for Volume l6, were. 13 based upon use of this particular. traffic control arrangement. 14 here, is that correct? 15 A (Ceder) That.is right. 16 Q And what assumption was made in the-ETE study, in' ] 17 volume 6, about the: speed or.the rates of' flow, ofJeach lane'of 18 traffic on to 495, here? 9-1 19 A (Ceder) The -- 20 MR. DIGNAN: Objection'as to form. ~ 21 My brother inad0ertently sai'd, 4'95, and said?here,; ~ q 22 and I claim that.he means.95.in figure one. [ ^ i 23 Am I correct, Mr. Fierce?' 24 MR. FIERCE: It:is not,95s;in.51, cit is 110. +.. 25 . MR. DIGNAN: I said 95'in Figure 1-is what you'are, O Heritage' Reporting: Corporation

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4, ,. c s ,j.-.> c 3,5.,4l62 j -l-. pointing at',.is that rig't?n N) h s >+ 1 - . [ l' 2 MRi. FIERCE: Exactly,' exac.tly... o 3 'it 3-c i.- 4, -MR. DIGNAN:- Thank you.: 3 7 4 s 4j .d 4 'BY ' MR. - FIERCE :, ?' e t ,i o a 5 'O-What assumptionsiwere'made'abouth 9 low; rates [for i ' ]( L t 1. 1 i 6 each ofEthese.twoLlanesi:in the ETE study?! p., ',] ~7' A (Ceder)-,In the ETE study lwe mentioned thisi ' l.1 .n swi '8- . intersection because'it is a'buttleneck; ; Bottleneck isJthe, '9 + .a. v.. 9 place, in which weLhave'tol consider what.willEbefthe: amount'.of1 j 1 ^ m, 10 vehicle that can golthrough and thisDactually;has,a diiect;' V H ~ 9 , g.y 11 effect on'the'ETE. j I 12 The assumptions here made that'.the traffic will. h 'equallybe'divertedtothe'leftandto.therigNt,'toreachth'e: 13 14 I-95. As explained in my testimony,.it is..impossibleEto divideo o 15 it, equally because-the.left turn can-hardly be:made. -1 16 Therefore,.we anticipate that this bottleneck would: 17 be more' severe and'less car.will.be able to;go.--- 18' MR. DIGNAN; .I'am. going.to object. C 19 That answer is totally unresponsive. 'The witness was I 20 asked a question did he know what I-DYNEV' assumed:the flow was, xe 21 and I'am hearing a speech laboutsbottl'enecks,;and howsit is 22 going to be trafficJjammed-. J C

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-23 The questiontwas,jdirectly,idoes he,know what'I-DYNEV 24 assumed, and we are not getting that answer. l ,m 3 25 MR. FIERCE: I am' prepared.to-lead him through it,- 1 i] t Heritage Reporting Corporation j .(202)-628-4888 j o j 1 1 ___.2.._._--_-_-_._____-.____---__-------_------------------.-u------------------------

5483 ((_/ 'l step-by-step, if you would like? 2 JUDGE SMITH: All right. 3 Excuse me, I guess you really did not want to use 4 that exact verb. 5 MR. FLYNN: Your Honor, in fact, on that point, I i 6 would like to raise an' objection,.myself. We are getting into 7 the efficacy-of the I-DYNEV model and'I am interested in this l l 8 and if Mr. Fierce intends to' lead the witness, I will certainly I i 9 object. He..is not under oath. It is the. witness that we 1 i 10 should be hearing from. 1 11 JUDGE SMITH: There is no question that the witness 12 han the capability to present the testimony sought >by Mr. l 13 Fierce, and a certain amount of leading is desirable?for ") kl 14 efficiency. 15 But having been objected to, I think that you had 16 better be sensitive to the objection of leading. 17 MR. FIERCE: My question here was, did he know what. I 18 I-DYNEV did, with the rates of flow forzeach of these two lines 19 of traffic? i 20 I did not think that was a leading question. l l l l 21 JUDGE SMITH: No,.that is not leading, no, not at I 22 all, but the objection right now, is that he did not' respond to. l 23 your question. 24 He went into a disedurse of some substance. And I i l 25 think that is well taken, so,that let's start again with your (3 l \\_/ Heritage Reporting Corporation i (202) 628-4888 i l i

= .3 3 U 1 3 5484 1 yl,e -1 question? I s 1 2 BY MR. FIERCE. <l 3 Q Do you want me to repeatLthe' question? 41 A (Ceder) No, that is.okay. i 5 BY MR. FIERCE: i l 6 Q I am asking,about the rates of flow.for each: lane?. 7 A (Ceder).The assumption'that-they can be divided 8 equally;to two, i i 9 0 When you say,' divided equally, are you saying that, .10 what are you saying, divided equally by time,--or just; divided, j

j 4

11 equally by numbers of vehicles? 1 J 12 A (Ceder) By numbers of. vehicles, that can cross this l 13 intersection.and move on to I-95. 14 Q And what about the~ rate of flow,-for each of those ] ~ 15 two lanes, what does I-DYNEV do with them?. I I l 16 A (Ceder) Assume as we -- I-DYNEV assume'certain i 5 l 17-capacity rate, I remember around'1170, less 15%,.which'is l l 18 around'994 vehicles per hour,'through each of their own' route,. i l 19 indicated in this figure. 20 Q The same rate for each ramp? 21 A (Ceder) Yes. 22 Q And in your opinion,;Dr. Ceder,;given this traffic 23 control configuration,vis that possible?l 24 A (Ceder) Absolutely not'. a a 25 Q Why not? O Heritage Reporting Corporation (202) 628-4888 1 = _ _z_

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+ 3, p .J t 1 '5405 1 A' '(Ceder) It is indicated cle'arly iri[the :tesbimony 2-that this capacity rate, cannot 'be obtained: while making; the 3 left turn. I don't'know exactly'what will be the capacity,'but. 4 much, much lower, ifLatiall.. d 5 Again, you' mentioned.~1t yesterday,-the capacityfmay: 6 drop either to almost zero?if there would be snow, for;that: j 1 7 lane. Therefore, we-left,-instead'.of 990 Lor-say'1,000) times-8 two, we left with'about half'.ini.the. case'of. snow. 9 Otherwise-, it may be higher,'but not uplto.2 000,L n d i .q 10' which, that I understandjI-DYNEV consider. ] '1 11 Q And so'.if.the.left lane does notlhave:.the samel 1j ? 12 capacity to. flow at the' speed that the right lane;does,:what; 13 impact will that have on the~ETE's? 14 A (Ceder).Less vehicles'will be'able'to:goLthrough in-i 15 a unit of time, therefore, the~1ast vehicle'.toL. leave this area,. j 16 would'be higher, he will go up.the same' proportion..4 17 Q Okay, now turninguto.the next'section ofLyour-c

• 1, 18 testimony, which is the technical' traffic _ engineering concerns,-

q 19 it begins on page 16. 7 20 A (Ceder) Okay. 21 Q Item number two, at the bottom, deals with. thel; ) 22 service volume, under congested, conditions; and in fact,cIfjust a, s i; e 1 23 see something right noy.. 24 I wantfto ask?you_aboutLthe. third 11'inef from the' ~ _ g y 25 bottom of the -page, ' Dh. Ceder; the 'li'ne. that b$ gins with the O l_ Heritage, Reporting ' Corporation ~ (202) 628-4888 s. = _ _ = -

s F 5486 A. (_) l1 . number two in parentheses.- 2 A -(Ceder). Yes? 3 Q In. Volume 6, page 3, is thatla correct'page. cite? (Ceder)' No, the correct _page should be'3-4,7not only; 4 A 5 3, it is a typo. ) 6 0 .Three dash four? ' l 7 A (Ceder): Right. 8 Q' The. sentence reads,'in. Volume'6,fpage 3-4, it is 9 indicated that the' service volume VF,-under congested ,10 conditions is determined by the formula, capacity timesEO.85'.: 11 And now, does Volume 6, Dr. Ceder, on page'3.-'4, or: 12 any where.else, explain how the' authors derived thatJreduction-13 factor, 0.85 used in-Volume 6? O sl 14 MR. DIGNAN:.May'I have'that question read back, Your 15 Honor? 16 JUDGE SMITH: .Please? 17. (Reporter readstback question.)' 18 MR. DIGNAN: So I understand that the question is,. 19 whether that explanation is anywhere.in the Volume?- 20 That is the question put to the witness?- 21 MR. FIERCE: Yes. 22 MR..DIGNAN: Thank you. 23 THE WITNESS ' (Ceder):[ diay7 answer? I, 14 MR. FIERCE: "Yes. 25 THE WITNESS;(Cederi: As I re$d 3-4,lth,ic.value, ) e Heritage.. Reporting Corporation. (202) 628-4888 6 1

1 5487 ) ' ^s i (,j-1 based on empirical data collected on the freeway. Nothing more 2 than that. That is what is mentioned in how they derived the q i 3 0.85. i 1 4 BY MR. FIERCE: 5 0 And Dr. Ceder, what about the additional sentences in 1 6 that paragraph, Doctor Ceder? j l 7 Does that of fer ar.y further explanation?- 4 8 A (Ceder) This is something which I disagree. It l 9 said, if I will read it, it is important to mention that some i l 10 investigators on analyzing data collected on freeways, conclu'e d 11 that little or no reduction in capacity, occurs even at level l 12 of service F. i l I completely disagree with that. 13 i Nl 14 Q What is the prevailing view, in the profession, of i 15 transportation science, regarding this point? 16 A (Ceder) Yesterday and today, I mean it is hard to 17 explain something technical. I thoughc to do it yesterday, but 18 if the Court will allow me to explain it on the blackboard, all f l 19 of the issues of congestion and this 85% what is all about, I l 20 think it will be more clearer, is that is all right? 21 Q. Well, before I ask you to do that, Dr. Ceder, my 22 question was, with respect to that sentence that you just read 23 us, which you said that you disagreed with, my question is, 24 what is the position, prevailing position, if you know, in the 25 field of transportation science today, regarding where the (.Q/ Heritage Reporting. Corporation (202) 628-4888

\\ .f -I. 5488 ) 1 reduction in capacity occurs, on freeways, at level of service 2 F? 3 MR. DIGNAN: ' Objection, as to form, and I.ask'to,be 4-heard? l 5 JUDGE SMITH: Proceed. 6 MR. DIGNAN: Prevailing position is the question. 7 -And it is bothering:me, Your, Honor. Unless it.is o;l J y 8:. established that the' witness.has, indeed,igone about and 'i 9 canvassed.every. expert in.the, field, he is not competent to 10 give a prevailing position. l 11 I have no objection to his opinion or his citation. ~ [ l l 12 As he said, he.has got other people who: agree with him, but 13 prevailing position, until you lay that. foundation',.that-you ~ i A 14 have essentially canvassed-the field, yourself, I don't!think ) 15 that the witness is competent. \\ 16 JUDGE SMITH: Well, let's let the expertLtell us"on l 17 how the prevailing position might be identified in-his 18 profession. 19 He may not agree with you that a ourvey is necessary.. ~ 20 MR. DIGNAN: Then I understand that before he gives 21 any opinion, that that preliminary question has to be put to-22 find out what he means by prevailing position? 23 JUDGE SMITH: -Yes. 24 I think that'it is only: fair that he<just does not c 25 give a summary answer without explaining how ho -- just m 1 Heritage Reporting Corporation -(202) 628-4888. 1

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15489 ,j d genercily how'he would"know.-what a-prevail'ing douition is. t .1 R 2 But that is not to'say that by.asking that, that we' 3 ' agree with 'Mr. Dignen that he ~h'as to cSitact and' poli every.1 i ~ 4 expert:in.the-. field. n, 5 Are you with me?. 6 MR.'FIERCEi [I=am'.not'sure. 7 ' JUDGE SMITHS Well, Mr.'Dignan, said, unless:hefcan.' ~ 8 establish that he'has been in contact and has. assessed.the? ,e -9 opinion:of'every. expert inLthe field;of. transportation', studies,' 4 =,! .7.. ~10: that he:is not~ qualified to answer your question.- .'g -a i 11' I-disagree. You.-don'.t haveito\\ respond.there,lbutiI-r! t 12 do agree that<someifoundation should bellaidSfor'him to give] Q 13 the answer.- r 14 That'is, is..ho, capable,of - rdoes he know and Iiow 15 does he:know.what.the; prevailing position is? 116 Is.it a.part of'his; expertise to be current on:the-17 prevailing position, for. example? 18 I' don't'know howfto do lt. ~ .] 1 19 'BY!MR.' FIERCE: 5 n 1 20 .O Well, let's start with the'. question ~.; h 1 .21 Do you know whether there is'aLprevailing view,Lin ,j 22 your opinion, in'the profession? l s . 1 23 MR.' PIERCE:,And then ILwill,.if1he says,.no,; then-I c1 + 24 won't go any-further. ( i. l7, c q,ry'tainly'cann'ot quarrel with that,. ') } i 25 JUDGE SMITH:- I-cer -. j ,'t' gE e. 'b 4 t Heritage iReporting'; Corporation' (202)'628-4888- \\..' / ~ d s P.- t

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f l 5490 1 )' 1 !Mr. Dignan. j 2 MR. DIGNAN: Well, can I-try? 3 JUDGE SM1TH: I don't want to say'that you wantcto' 4 quarrel with that or anything. JE am sure that you -- 5 MR. DIGNAN: Well, no, Your' Honor, myfpoint is this. '6 My'nangup and why I made it a form'instead,of a~ ' i 7 ' foundation objection, is this' word,. prevailing. LI' don't-I 8 know -- prevailing can mean a lot of things. -9 It can mean'a majority vote. It can mean the i 10. strength of one person convincing'10. -It'is a plastic word, or-1 J 11 a -- 1 12 JUDGE SMITH: I.am sure that it-is, but-it is'laLvery1 1a 13 traditional and common word, too. 'I hear it'in medical H 0-i 14 testimony, you know, without the precision that'you-would-1 15 require. .a ?.6 Your relief may be that'if you'are not' satisfied at 5 17 how he arrives at it, is for recross on it. : But?I don't1think-18 that you are going to be injured yet. j 19 Let's wait and see until you are reallyLatung,.and. 20 then see what happens. .1 .{ 21-THE WITNESS (Ceder): Well, I at least can say that'I' q 22 am happy to be on.the side'of fact, rather than'-.I-rely my 23 answer on data, on studies, and my opinion I think that many-24 people would share my op nion, about what:1 said-before. 25 BY MR. FIERCE: O Heritage Reporting Corporation ( 2 0 2 )---~6 2 8 -4 8 8 8 ' h,) A = _ -. - _.. -

i b 5491 /~'s N.,/ i Q Dr. Ceder, are you familiar with studies analyzing 2 data collected on freeways that conclude that little or no l 3 reduction of capacity occurs,.even at levels of service F? i 4 A (Ceder) It is a way of interpretation, because we 5 said before, level of service F, it is undefined accurately. 6 And as I said before, the best thing is to show on the 7 blackboard, what is all about. 8 Q In your view, your view Dr. Ceder, however, you l e f 9 disagree with the conclusion of those investigators?- 10 MR. FLYNN: Objection, leading. J l 11 JUDGE SMITH: Who objected? f 12 Mr. Flynn, what is the basis of your objection? i l 13 MR. FLYNN: That the question was leading. 14 JUDGE SMITH: Oh, no, it was not. No, that is u I 15 overruled. J 16 THE WITNESS'(Ceder): I disagree. 1 1 17 JUDGE HARBOUR: I am sorry. 1 18 I did not understand who it is that he is disagreeing l 19 with. 20 MR. FIERCE: Those investigators who analyze data 21 collected on freeways, who have concluded that little or no 22 reduction capacity occurs, even at levels of service F. I 23 JUDGE HARBOUR: Thank you. 24 BY MR. FIERCER. 25 Q Now, Dr. Ceder, how would.you characterize this, the i [~) x' l Heritage. Reporting-Corporation (202) 628-4888 l

m 1 5492 1 importance of'.this reduction factor-in terms-of its:effect on l ~ i 2 ETE calculations by I-DYNEV? 3 A (Ceder) .It is almost a direct.me'asure to offect-the' ~ 4 ETE, because once we go.into congested mode, the rate in which 5 we discharge vehicles la going down. And.less vehicle-can leave. i 6 the area.In a unit of time. 7 Therefore-the ETE going to increase, if.less 8 vehicles are going to be able to escape the area. ,) 9 Q Now, is this the topic, a' minute ago, that you'were 1 10 interested in explaining on the blackboard? 11 A (Ceder) If possible, I think that it would clear l 12 some of the --- 13 Q You believe that it could' clear some-of the 14 confusion, is that what you are saying?- 15 A (Ceder) I think so, yes. 16 'O Why don't you give it'an attempt ar-the. blackboard.to. ) ~ l 17 explain this reduction factor, and its.'importance on ETE a 18 calculations, if you can? ? -{ 19 A (Ceder) Well, okay. l 20 MR. DIGNAN: Your Honor, I suggest,--again, this is b 21 new direct. It is not redirect. I have-a very clear. memory of 1 22 what I examined thic witness on and what I did not,.it was all ] 23 in.a book. 24 And if you recall, he said he wanted _to use-75,.and. d 25 your guy used 85, I disagree,<and I chased him a little bit'on. Ileritage Roporting' Corporation-(202) 628-4888' I .y ..6-. ,i-. .\\' 1

p., u -- - +sa. 'l q 15493 j 1() I his 75. .j a 2 I never got into a general) discussion withihim'on. 4 3 what reduction factors do to ETE's or.anything else..This is 4 new direct examination, I. submit, and'it is not redirect. 1 5 JUDGE SMITH: The Board' agrees that'is on-the order i l 6 of new direct examination. t L 7 .That does not, in all. instances, categorically! ,.] 8 exclude it, however, but on thatythis objection isisustained. l ) 1 9 If there were.some reasonitoLreopen the direct and-we-y 10 we sid:never exclude that possibility,,1frit wereEreallyi j q 11 . essential'to a decision, but-herek I' don't.believe that it:is. 12 And so, the objection:is sustained. 13 MR. FIERCE: I am not going'to object to that, Your 0 ] 14-Honor. -15 As I understand that if there is no confusion, then-16 the Board won't ask him to explain it.further, either, and if 0 17 there is, of course, he will. 3 'l 18 JUDGE SMITH: I wouldn't.say that all[of'his 1 19 testimony is free of fear of: confusion. -It may take a lot of q l 20 analysis, but it is -- really what you are asking, is that the ] >l 21 direct be reopened, on an important point,.and we.cannot sit c .] 22 here, and say, at any time, well, you havefm'adeEyour~pointLor. ? d 23 you have not made your point. j 24 Frankly, we may not know until we start reading. 25 through the transcript, and then we may not know'then. .g (S-) 1 Heritage ' Reporting ~ Corpo' ration (202) 628-4888 ] ~ l i w

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c + t, 4 '.i 't.- k ,),. 54947 m J ut we'-- .1 B -j .2 LMR. FIERCE: I am' not. objecting' Lto your ~ ruling,: ~ - 3. 'because'I still'believe that if the Board.wants Doctor Ceder to-9 4 explainlit at the.. blackboard,_you have that opportunity _tof.ask' 5 that_ question,:yourself. 1 6 JUDGE SMITH: .Right. -{ 7 MR. FIERCE 2,I did-inot make thuitechnica1l response I~ i i l r s.... 8' would hav'e madeLto'the objection,;which is,-that I believe'the R -9 implication;of._the. cross. examination was'to diminish.the 10- .importance of-this difference between the,0,85, and.0.75, whichE 1j .11-we believe is more important. 12 Eut'I;am not going 1to pursuefit. If\\the. Board.'wants 1 13 to bring it_.up on itsiown,.it may'do that. GN 14 JUDGE' SMITH:. All right,.and we understand. ~l l 15 Thank you.- 16 MR.' FIERCE: Fine. 17. BY MR. FIERCE: 1 '\\ 18 0 lThe next' topic, in your testimony, under.the_ b 19 technical f actors-section,: is the discussion of the manner:in= l l 20 which I-DYNEV handles -tiraf fic flow through congested' L q 21 intersections and that begins on page 19. 22 This is where the discussion of'theEsaturated 23 discharge. headway occ.urs,.and I don't wantL.to go_through it in 24 great detail again,_because we have been through that now, this, . 25 morning, with the. Salter discussion. O I Heritage,tReporting" Corporation. (202) 628-4888 d i 7 6 5 ., _i j.y d .__a_--

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'?. j w s y y + .x t f5495L$ 4 'll But'I'do want;to'ask one' question just'to;clarifyjlt,- 2 can'you, in simple. terms,; Dr. Ceder, explain ths concepti 'of - 3 saturation'dischargeLheadway?1 3 '( .[ 4 .A (Ceder) Sure.; 'S LIn simple terms,'it means.the' number of vehicles at 6 saturated, rate, -- the numberiof vehicles'that,we. Lean push' J L ,7 through:the intersectionlas.much"as_possible.- 8 How many vehicles we can push throughEan l1ritersectioni h ~ '9 in a unit of time. .10 The higher we can,.the higher;is theis'aturate'dLrate, 11' - this.actually what it.means.. 12' Q And for any.given number'of. saturation discharge' 13 ' headway, 2.4, 2.7,;.can you' explain'to me, the' relationship.

j f

~ i 14 between that' number, and ETE's?- 15 A (Ceder) We..have tofbear'in mind,'first of;.all, thatL 16 an intersection is a bottleneck. -If itiis notLa. bottleneck, 17 and elsewhere, in the network, there-is.a bottleneck,fthenfth'e' l 18 effect on the ETE got to be veryzsmall. 19 However,.we know that most of the' bottlenecks are-.at' 20 the. intersections and if one/ intersection is a bottlenecks 21 'again, the: number of vehicles that it can push through',Jit is.a t ' 22 very important number.in a-unit of time. i 23 If you can' push through1more in a unitLof time,:.then: 24 the ETE is. going to be.'less, otherwise, the'ETEl going to~bei 25 higher. l 't ' Heritage Reporting,. Corporation R ..(202)s 628-48887 1 ~

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q; l" . i.. 5496 g/ (, 1 Q And let me.ask the question again,~ in a different 2 way, because I did not get the answer-that IEwanted. l 3 The question was, the relationship between' discharge l 1 L 4 headway numbers, and ETE's, let me put it to'you this way,.ift j 1 5 the discharge. headway'is'hi'gher in reality than I-DYNEVLused,- i 6 will the ETE's be longer or shorter? I 7 A' (Ceder). The:ETE will bellonger,-s, straightforward. j 1:1 ~8 JUDGE SMITH: Mr.. Fierce, althoughLit:may seem-as of' 9 this hour, we have a generous amount of time, if we-really. 10 think about what is ahead of us this morning, I sense that,you. j i 11 have the Assistant Attorney General 1to argue that present,.that. 12 Sholley motion present? 13 MR. FIERCE:.Right. 14 JUDGE SMITH: Even as matters st'and;right'now,'withf 15 no further argument, the Board is. going.to need 10 or;15 16 minutes to rule on it, and perhaps more, so that we are running 17 a little bit short of time, 1 18 MR.. FIERCE: I will try.to do what I'can,1Your Honor, d ~ 19 .but I have a few more questions. 20 J10DGE SMITH: i Certainly, certainly, I am not asking 21 you to shorten it, but I am just really.looking'for I 22 information. ' 23 You do have a few more?- 24 MR. FIERCE: I do. i 25 MR.' BACKUS: Judge Smith,'I would just'like to advise Heritage Reporting Corporation; (202) 628-4888 J ^ ___m __m_._.___________. _u__ m__ _u. ._______...u. 2

7 p* gg, ~ wy 7 p, a 7 gv 7;. 4 .,o v.j t r ,, N ..i n, g ', t-s . C 5497 ] Q l~ the Board that our rebuttal' witness is here,'too,?and we would-2 hope.that she could be heard before you suspend for.the day. 31 JUDGE SMITH: I don't--know,'.I; don't.see howLwe are 4 going to. 5 It is just a matter of. adding up minutes,.unless-'we 6 make a' priority of.your witness over the, Massachusetts Attorney [ 7. ' General.. 1 1 8 'I guess we can - ;I really don't know how: much time t j -) 9 the witness:is going to.take. .J 10 .MR. OLESKEY: Judge,Lwhy dont:you~let-Mr. Backus and~ t 11 I.. discuss;the timing of thefrespective witnesses'andLarguments, 12 at the break and we will see how-the flow ~of the morning, goes.: h J 3 13-JUDGE SMITH: Okay, well if:you.can4 accommodate'both,. 14 we'really want to. 15 MR. OLESKEY: Surely,'thanks. 16 BY MR. FIERCE: 17 0 I am skipping ahead now,-to.thejthird' substantive-18 section of your testimony,'which.is the likelihood of 19 ' disorderly accidents. 20 .And, yesterday, you were'a'ked a' series of questions s 21 about Attachment 8 of your testimony. 22 Excuseme, I believe that it was' attachment-9. 'I j a 23 stand corrected, it is attachment 9, which' is'a figure from an' j 24 article you wrote in 1982, entitled, Relationships Between.' Road' 1 25 Accidents and Hourly Traffic Flow:..II, Probabilistic Approach l O Heritage Reporting Corporation (202)_628-4888 4 t ;.'._ Qj as 4 s: %

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raa- .,1 .. ~ v si ' s n. ,. 3 }; ,3 <![g e ' * \\ dE ' ' 'u M ,g y. ~ y -5498-2 d,.f L l' in;the Accident'. Analysis and' Prevention Journal.; } O a 2 And I believe.that;was Applicants' E.xhibit Number 23 .j 3 for impeachment if I;am correct. 4. ,And yesterday, you were asked a series of questionsL 0 5 regarding a; discrepancy;between.the_figurefin the) attachment,; q q' 6-and the figure'in the: article from which it,came.- ,a y 77 And there was 'a..dif ference pointed outE,inithe articlef 9 ~ .1 .8 'and I-dont~know-wh'ich'isithe ordinateIandiwhichlisithesabscil I h( 9-but'it is the bottom'lineJon the' chart'which'1'sflabele'd Y (ten' q 10 to~the third hours) in'th'e article-and'169 he chart is labeledi t 11_ ~H to the 10 to the thirdivehicle hours.

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12- 'I just"want'tonknew if you-h' avena s'imple explanation,; O ~ 13 that you could.give-in laymen's. terms,Jas.to;why.this 14' ' discrepancy has occurred? ..A 15 A (Ceder) Yes. 16 I indicated, yesterday,_.why'looking at the-article,.I.. 17-agree that there.is misleading sentences or that'one can-18 misinterpreted the :value'. I will, in: simple? term,7as you_ asked 19 try to explain it, because.it 1s.involv'ed'probabilistic i 20 aspects. 21 The way it said.here,.and why I decided to change.it: 22 from hours, to vehicle-hours,.is quite: simple and.it is:more. ] 23 explainable _in-the article, by vehicle kilometers,;as-opposed-24 to-total kilometers. 25 What is said under whatLI wrote'in Attachment-9_-M, it j

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1' s' imply-the amount of hours 1requibedifor.ohsLvehicle,..one.~singleL 2

vehicle to travel at certain level'of. flow, before he entering. 3-an accident. 4 The probability-that one single; vehicle will_Ltravel, q 5 'let's say,10,000 hours.before.he: is entering an. accident. TheJ i 6' same apply to: kilometers. How many kilometers let's.say,'one D 7 .million kilometers required.ifor one: single vehicle to; travel' t . orLthe probability-for.that. 8 before he is' entering an accident, -9 'It is completely -- that whatTILtried.to:say. 10-yesterday --.and that isLnot specifically explicitly indicated; ) 1 11 .in the. paper.-- it is' completely'. equivalent.to the numberJof-b 12 hours required to several vehicles,-'before entering an q 13. accident'. 14 So, if we'think in terms of'one: vehicle.for thousand 15 hours, to entering an accident,'it,is'same as:saying thousand;' 16 vehicles in one hour will enter an accident. The sames 17 probability. 1 18 So, I change it.to rehicle_ hours, to amplifyLthat we? 19 can associate it with more than one vehicle,-'as opposedito.whati 20 is indicated-in the article-in. probability manner,.for'one _ i 21 single vehicle. 22 So, it is simply a clearer.. L 23 Q In your view,.Dr. Ceder,-is;the labelling that'you 24 have given us on attachment 9, the more appropriate labelling,. 25 in your view? LO 1 Heritage -Reporting. Corporation. (202) 628-4888~ l ~ ,h J-; $ 3 1 __1______._______ ..u.____u m

.a g e 5 t t 4 q -s 1 4 5500: '1 'A (Ceder) 'Yes. ~ ^ '2 .Q-And now,'these are highly complex statistical .3 calculations that you have'made, in this article,'areDthey.not? 4 .A ' (Ceder) Depend'from what, perspective. 5 Q Okay. 6 From my perspective they! ar'e'. l 7 Your article,. Appellants'.22. for. impeachment K--. 8 - MR. DIGNAN: Number 23. Ia m l o 6 k i n g,a t l 2 3,.- ' I L 9 ' MR. FIERCE: You.are right, 23o 1 'l 10 right here. 11 BY MR. FIERCE: M 12 Q Does it explain in. greater.' detail how these - 13 calculations in appendix 9, attachment.9 are< derived?l 14 A (Ceder) Why we can read'.it' thoroughly.and understand" l 15 it, I think interpreted correctly, but I dojagree that seveial-16 sentences need to-be rewritten in order'.to. fully understand it, .. ca m 17 so that I am' sympathize-with the one.. wh'o; read: the sentence; ~ 18 yesterday and=did not understand.what its mean. ~ T 19 Q But it'.idoes,.to:some,, extent,rexplai'n where these' t 20 calculations come from? 21 A '(Ceder) Sure*. 22 MR. FIERCE: At this time, I would offer Appellants' 23 Exhibit Number 22 for impeachment into.evidenceJas an. Exhibit. 24 in the-proceedings. 25 - MR. DIGNAN: First of all, it is Applicants'-; Exhibit 10 Heritage Reporting Corporation y' L _(202) 628-4888 l __mm _m. m_$ ,__.m__m ._.m_....

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.4 ep 4 p. -~ .x Q q Ql, p i ; p, D [Q.f ; j ! e , j-u m 5501 J 10' 1 Nember 23. ~ d t f 2 MR. FIERCE: ' Applicants'.' ,(- ',.f .'W Wg i U[! 3-MR. DICNAN:- Applicants' 23 10ht? Andyouwant~to-offer'itsfor-thetrdthof.the'mathersl 4 5 contained?z-M.. 6 LMR. FIERCE: I want to offer it':into! evidence as';an [ 1($., +' m f 7 exhibit -- M 76 7 '8 MR. DIGNAN:' -- for all purposes.-.., .['lf :59[ 1 1 7i . $h,1 h 9 ~MR. FIERCE: -- for_allLpurposes'.- l. My.h'th] 6 10 JUDGE SMITH ~.And all'of-it?. V 11 MR. DIGNAN: 'And all. of 'it. - M\\l. 12 MR. FIERCE: And all of it, n1 L 13 MR.~DIGNANt No objection._ n l. 14 JUDGE SMITH:. All right,-then that isLthe basis. fore 15 the acceptance and thefprevious.? limitation is removed.. 16 BY MR. FIERCE: 17 Q Now, your calculations,withfrespect to the.likelih'oodJ r i 18 of disorderly - - )- .* s ~ 19 MR. TURK:. Excuserme, onetsecond.- nFor- .V t 20 clarification, are we' designating this?'- 21 JUDGE SMITH: L, It still-will remain Applicants' .- a 22 Exhibit. 7 I c l 23-MR. TURK: _It is-simply admitted for1all purposes-f 1 . 24 now. 25 JUDGE SMITH: I think that it is time for the mid l Heritage ~ Reporting Corporation (202) 628-4888 Y m__________

-( 74(j,. W, 3{,.,T){ - %s Ii j ,1-4, ~ n , Y, e l ' f' Ax' / J )n;p!~. y.,f.* 1 l I. l b~, ;- s ,e a ,Qps and telY y6u about :them' only 'in the proposed. findings,fI1 p.i .be;-picked:up. c .q 21 What did you work"out.? -i q 22 MR. TRAFICONTE: We are prepared.to argue. j 23' JUDGE SMITH: ' All right, and'.then:I think that-is. l: 1 I'

24-pretty clear that -- where is Mr..Backus?-

l-25 MR. TRAFICONTE:.-He!is coming, but-he indicat'es(that" a d Heritage Reporting : Corporation -(202)'628-4888-eq s c-T E______zE1_____i_--___._--_i_. _i : --- E-_ - - i _ - - - - i -- - J--- -b b-

IV 'O L ' Ql. 1. 5504: ' 9( f.- ~ 1 his witness wi11 be available:next-hearing week. 2 JUDGE SMITH:' Okay. 3 All right, even the'way that it.is going,.we.will'- - 4 the pace'is. going'to have to be p'icked up. 5 LHow much timeLdo-you have left,.do you think? 6 MR.-FIERCE: I'have about 15 minutes, Your Honor. ~ 7 JUDGE; SMITH. Okay,.it is going to be' tight, but how-8- about recross, Mr. Dignan, what do you'think?; 9-MR. DIGNAN: 'I would think' extremely short, Yot' c - 10 Honor. 11 JUDGE SMITH: ' Okay. 12 MR. DIGNAN:.I.would say.that1Illimit[it right'now,n1 13 will limit it to five minutes. O. 14 JUDGE = SMITH: Perhaps.not the content,1but theLpace, 15 can be accelerated a little bit without damageLto1the1 content.. q 16 MR. FIERCE: May I proceed? 17 JUDGE SMITH: -Yes, please. 18 IMi MR'. FIERCE: - l 19 Q. Dr. Ceder, in thelEbird'part ofiyour testimony?about-20 the likelihood of, traffic disorders, and accidents,'underi l cr r+, 21 congested conditio'ns, you.'did a calculation, ba' sed. on.a2. 65-o 22 mile stretch of road along route 110', heading out toward'this i ~ 23 intersection at route 9.5.- y -j ~ 24 And are there some factors in your -- are there any-q a 25 factors in your view, which were not considered-in your l 3 ll l< Heritage ! Reporting Corporation' b (202) 628-4888i H (b IN, 4 r j I l a e , ]

=, a; 3 s, s i r ' 5505 ); 1 calculation'that migur. serve.to: increase the. actual likelihoods 2 of traffic disorders --

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.3 MR. DIGNAN:l Objection'. 4 Okay,~here we go again. We had'a calculationLand?It 5 crossed it and now we are going to see if we~can add something; 6 else.as'a basis', beyond the. calculation actually.done. 7 It is the same technique;;itala new direct.; A-. 8 MR.' FIERCE: I.will' withdraw:the'questioncand 9 rephrase the question. 10 BY MR. FIERCE: 11 Q You testified yesterday, Dr. Ceder, regarding'the'se 12 calculations that it applied only to accidents-where there were-13 injuries or fatalities,_did'you not?- 14 Now, in your view,.under these conditions, would a. 15 computer modeler, who was designing a model tordo whatothis' ~! 16 does, include an' accident rate factorLinto-the model? l I L 17 MR. DIGNAN: Objection as to form until':ILknow;what,. 18 "this" means. 9 l 19 Is this his calculation or I-DYNEV, or what? (% f f I 20 BY MR. FIERCE: 1 21 Q Would, Dr. Ceder,,..usinggyour calculations'as=a, basis, 22 vill there likely be an'effect1on ETE's'if"this probability ~of 23 accidents is not considered in the model? 24 A (Ceder) I prefer if.it'would be a yes or no answer, 25 I think that it should be=or must'be included in'the model.

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4 1 5506 H (() l' .This is not the only model' existing in thesworld.!(Other model,; ' which_ IL mentione'd yesterday, -include accident " rate., f andjifc.in} ~ 2 3 the simulation model, Lit is.very easy to run;to generate 4 accidents.in.the road, much work, including bottlenecks. 5 And to consider them within:the norma 1' behavior of 6 tr'affic.-'Unfortunately_that what'we.are in.. We facing-7 accident on a' daily basis and we.must-consider it, as a normal? 8 realistic way to. simulate 1 traffic. 9-1er opinion, with' regard to the testimony, can!$e-i 10 supported farther by what'I saidiin the testimonycthat all thet o 11 ' evidences in the example.I. mentioned,'is'fataliand' injury,only.. 12 And we can be blocke'd by an accident which is/ damage' '13 only,'which means that the. number ofl accidents I mentioned may. 14 be even' higher, not mentioning thessituation'that'the data I- -15 used was taken in good weather. We mayfface accident-inchad 16 weather and the likelihood of accidentfinLbad weather is'three: l ~ 17 times as much as the accident in goodiweather. ~ 10 Not mentioning the' fact that1during thelevacuation 19 the arrangement at certain points are similar to construction, 20. zones, in which we f ace higher accident l rat!'es than ' normal a. ,v.n 2' traffic. Notmentioning-thatin'normbl, construction' zones, 22 saa 23 had signs and marking,"for to give'informationifor the' motorist 24 before he is approaching the zon"e,,=sotthaE3he can:be1 aware of 25 it. j\\ ' x). :- oaporting / Corporation f ! Heritage, (202)L628-4888~ q .-l-' u m JI.. _._i..___,,______ 1 m. __.___._m_.____.___m_1mm___...i_____._._______.m _._L.__._____ __.2__J.._

1 5507-(o ,j 1 I don't think that one can do it during an evacuation-2 scenario, because of its time consuming. So all those factor 3 increases the number of, increases the probability of accidents 4 in an evacuation scenario. 5 Therefore, I would say that prudent and knowledgeable 6 planner would randomly include accidents in a simulation model. 7 to simulate the. traffic evacuated from the area. 8 Q When you say, randomly simulate accidents, where 9 would these accidents be simulated? 10 A (Ceder) Accident can occur everywhere and what'I~am 11 saying, based on the information similar to what I show in the i 12 paper, with the probability of accident depending on the 1 13 traffic travelling, we can from time-to-time, simulate accident j ('T I \\_) 14 at certain points. { 15 Those points, which refer to bottleneck, are the most 16 crucial points. And those going to affect directly the ETE. 17 Q Are there computer models, that you are aware of, 18 that can randomly generate accidents in treffic models as you j i 19 have described? 20 A (Ceder) Sure, it is very -- it is common to'use 21 random generated events in simulation model and I am aware of 22 two models: the evacuation model that I mentioned yesterday, i 23 that are considering accidents within the road network. 24 Q Are these accidents generated at random locations? 25 A (Ceder) They are generated in random locations ,m () Heritage Reporting Corporation (202) 628-4888 l '\\

( 6 J .4 x, a t. 'l s + \\ 4 l 15508: m 3 ~> 1 . n) - l' throughout the network, and they'are;not'onlygthe' accident" v..( E 2 themselves', but the clearance l time',;the-time.requiredito clear; s L 1 it, depends.on the' congestion factor,tand the possibilityfof j 4 ' tow trucks to come.to.the area,.all of those! factors can be' b' i l r l 5-included in the simulation model'. 6 That'is~why'the simulation.modeliis so convenientEto j s J l 7 use. And:I think that it should be included here, asfwell. H 8; Q .Okay. l '9-And Doctor Ceder, yesterday,.in.Tresponse to'a-

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question-or two, I~believe,7from Judge Harbour, you were6 asked; j a 11 some questions about the gap l. phenomenon.. 12 Which is that:if:a blockage occurs, because:of'an. I 13 accident, orwhatev'er,and.ag' apis. created.when.thel.downstbeam AV 14 traffic moves ahead, leaving the' upstream traffic l blocked < 15 behind the blockage, whether when that blockage;isL. removed,, 16 let's assume, after say, 10 minutes' the. traffic b'ehind'it, 17 . won'tspeed-upanddriveupveryrapidly. closing lthegap,-[and:: 18 thereby, eliminate any' extension'of the evacuationitime.- 19 Do you believe that that gap' phenomenon ~wo'ks.in that r . y .g 20 ' fashion to prevent any extension of'the evacuation. times? 1 L 21 A (Ceder) I said,ituyesterday-to.the Judge, that as' .. ) l 22 long as we are dealing with one; route, which has no;other 23 feeding route on; the *hikle,[th'is [is "the phen 6 men' }, Ilf. theJ a 24 accident occur for.a'certain amount.of minute, those, amount of l ^ 1 25 minutes going to be addedlto3the evacuation ~.-time.. If we-care < l j H O. Heritage Reporting Corporation 1 ( 202 )~ ' 628-4 888: l i p' l, 8, e e m

,y ? t a y 5509 ~ 1 talking about discharging:at capacity-rate. 2 However,Lif there-are ultimate routes that will allow 3 the' traffic standing in the_ queue, to cha'nge th'eir route.and to -i 4: come.dif ferently to overpass. the. accident, :that.is a ;dif ferent 5 story. 6 ,But.as long as.we,.'are talking;aboutl single and1one 7 . route, or one roadway, this is going to be the.effect. No 8 matter where the accident located on that: route, it is: going'to ~ 9 create a bottleneck and the amount of delay to'the traffic, to- ] 10 the ETE is directly proportioned.to the' amount,.the time'the 11. accident is there'. 12 Q Dr. Ceder, areLthere.-feeder routes'as you describe 13 them along that 2.65-mile stretch of road that you calculated 14 your probability on? ~15 A (Ceder) Not that I know of. 16 Q Would you take a look'at figure 1-3, in-volume.6, and a 17 tell me if you recognize this? 18 A (Ceder) Yes. 19 Q And what is figure 1-3? 20 A (Ceder) Is actually the road-map of the 10-mile. '21 zone, the EPZ. 22 Q And what does that road-map =show you on it? 23 A (Ceder); The roads. 24 Q And what else,' the, doryou see the po'ints? l 25 A (Ceder) There is an internal node, origins, central- ,i 'sv' Heritage ' Reporting Corporation (202) 628-4880 L ~ ~.

l-1 1 4 5510 i s 1 - (,) 1 and destination nodes. j t' 2 Q And let me ask you if the link that you studied for-3 your calculation, is the link that runs from the blue dot, 4 internal node, which is labeled 93, to the group of three blue. 1 5 dots, to the west, the top point of which is number 255, is 6 that the link that you did your calculation on?- j 7 A (Ceder) Yes. 3 Q And along that stretch, do su see any other origin 1 9 centroids? 10 A (Ceder) No. This is a straight route, without any 11 feeder routes coming into it or leaving it. 12 Q Is it possible that the red dot, labeled 2098, is an { 1 13 origin centroid that feeds on to that link? l f~% (,) 14 A (Ceder) It is a minor one but I don't see any route. 15 0 When you say that it is a minor one, do you have, do 16 you know how many vehicles might be coming out of that area, 17 loading on to route 110, at that point? 18 A (Ceder) No, I don't have the data, I don't know. 19 Q But if that was only a small amobnt of traffic, and a 20 blockage were to occur along that stretch, so that only a small 21 number of cars could fill in the gap -- 22 A (Ceder) If the gap is along it, if the accident is 23 in front, thats, they are simply adding to the queue, to the 24 line of people. 25 otherwise, they will be able to enter. (~N i %,) ^ Heritage Reporting Corporation (202) 628-4888 i i b

A '5511 [ )' 1 Q But a small number-of cars loading'on,_might'not 2L have any great impact?- L, 3 A (Ceder) Again, when we.say "small"'we have-to> deal. l 4 with' numbers, but at it looks here,. the' route that you 5 mantioned to me, it is'a straight line wherever the accident l-6 would occur on that, it will create a problem, it will stop_the; l l 1 7 whole vehicle. 8 Q Okay. Now, Dr. Ceder, you'were asked about other l n 9 models yesterday,.and we've mentioned a little' bit moreLabouti .I i 10 other-models today, but is.it-your recommendation that what j 11' needs to be done here io the actual construction of another 12 model? Is that your testimony? 13 A-No. You mean other constructions of other models' O) ( 14 than I-DYNEV? 15 Q That what should beldone with respect to thu ETEs forl 16 Seabrook is that we need'to have another model?L 17 A 1 said it very clearly in the: testimony.- .In. order to 18 answer such a question, youLreally-need to-havefmore 19 information. There is two' possibilities,-or three. 20 While, obviously people like myself, profession,,need 21 to see, to observe the source code inforder to' evaluate fully '22 full-scale evaluation of the I-DYNEV, we still miss many 23 points, many unclear'pvints'as"Iitried toiindicate'it in the 24 testimony. 25 After doingtso, th'enlone~cantcome into,the conclusion-(O ~ 1 Heritage Reporting.l Corporation.

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+ Q L '5512' () -1 whether a'new model need to be developed, or:which I think it's. 2 more111kely the I-DYNEV can be' moved to the level in which'it 3 can serve.its purposes. That's -- '4 Q So your recommendation specifically is th'at.this-5 additional study.needs to be done; is that correct? 1 6 A 'Sure. I mean, if there is a lack'of/information and. 7 one had been' asked to evaluate something and;he-doesn't-haven y l 8 the whole information,lthe? result of'that'it's what one can ~ t i i a 9 . read in my testimony. And.that's a question -- that's a .i 10 function of point, and there.is'some revision that-..need~to;be 11 made like the accident part and other parts. I j 12 Q How long would itstake, in your opinion,;to'do this 13 kind of review you were talking about?' R 14 MR. TURK: Objection,'at least.cs to'. form.; 'As 'I - ~ 15 understand the witness, he is stating whac additional' study he 16 would have to do. I believe the question now is.more' general i 17 as to what other persons might have'to do. Mn I. wrong? 18 JUDGE SMITH - What a'competentTother' person would-19 .have.to do. i 20 }Hl. FIERCE: Right.- 'I mean, -- let me ask a .] 21 preliminary question. I 22 BY MR. FIERCE: 1 >I l 23 O Should this review be d6ne.by an{ independent ~ person 24 or peer review group, in your view? 25 A I would think so,,.yes. ~ s() Heritage Reporting -Corpo' ration E

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a3 l l 1 -5513 ] m J () 1 Q And assuming they were working at a reasonable pace, 2 I'm asking you if you if you kno% how long it would take to do 3 such a review of-the source' code and the other steps..that you. 'I 4 have recommended? 5. A It woulo te.ke few months to review the source code,. [ 6 providing all the rest of the review'if everything.would be q ~ 7. available. A few months would do it, I guess. 8 Q Do you~have any estimate on what;this might. cost? 9 Ball park figures? 10 A I havo no' idea. If everything -- 11 MR. DIGNAN - Your Honor, aren't we well into brand ~ l 12 new direct? I mean, I don't know whether we're putting a -l 13 contract out for bidJor what, but there was nothing-in the. 14 direct that I saw,-and certainly nothing in my-crossfthut 15 brought this up. 16 JUDGE SMITH: It does seem to be.augmentat' ion o'f the 17 theme that was in his direct testimony, Mr., Fierce. 18 MR. FIERCE: I'll withdraw it. 19 BY MR.' FIERCE: 20 Q Dr. Ceder, do you have an opinion regarding whether 21 the ETEs produced by I-DYNEV for evacuation from Seabrook 22 Station are likely to be realistic?' .s 23 A I said in my' testimony I don't think'they are - 24 likely -- again, based 1on the information~I have, and it's only i 25 partial information, based,on,that, I don',t,think that' they are -O ~ L Heritage.. Reporting Corporation (202)^628-4888 ) u_____________m_ . _ _ _ _. _._____i__ _i_________._.____

n L 5514 y'h 1-realistic'and they tend'to err on the lower' side which mean I- '2 <think they are estimating.the ETE too low. AndLI would - but' 3-that's based on the information-1 have.- 4 MR. FIERCE : Thank you. 'I.have no further questions. 5 JUDGE SMITH: Mr. Dignan. 1 6 7 l'l 8-RECROSS-EXAMINATION 9 BY MR. DIGNAN: l 10 Q~ Doctor, would you get in' front of you'.your Attachment' 11 8 to your testimony, please, if you would be'so. kind? That l's 12 the curve -- the two curves, the right-hand'one of which you. 13 and. Judge.Linenberger discussed yecterday. ,V 14 A Yes. l 'I 15 Q Now,. Doctor, as I understood your discussion with His. i 16 Honor yesterday,.and your discussion'before that with_'me, the l 17 solid line represents the nard. data; is-that right? 18 A Correct.- 19 Q And the dotted line is interpolations. 20 As I read the thing, and you put whatever number you i 1 21 want on it, your last hard data point is at a vehicle.per hour { 22 flow of around 1800; is that correct? j 23 A Correct. l 24 Q Okay. And if I read.,the, chart correctly again,-and I. 25 understand I'm approximating, your ' hard' datia then shows that ' at P x) , 2 Heritage ReporEing.Corporat' ion. (202) 628-4888 t 'y s a ____.__._____m___ . _ _ _ _ _ _ _ _ _. ~

. cn. 3 y . l 1, - 'r j + i 5515 / CEDER.- RECROSS' 1 a vehicle flow-of 1800 hours,'there11s' about'-- there is;;goingj 2-to be~1.25 or'so accidentsiper millionLvehicle kilometers;.L-is, ] 3 that correct? i 4 A -Right. j 1 1 5 QL 'Now if-you can. recall our exerciseLyesterday, wei,* a 6 talked about' converting your 2.65 miles:into, kilometers,'and we- ] 7 agreed.that'it.was';4.24. And:we.multipliedL4^.24. times 111,4001 8 and we.got'48,336 vehicle kilometers involved in.your example,: 9 correct? o 10' A Yes. 11 Q Now, am I correct that_the way I couldifind outithe. ] 3 s 12 probability from your chart.using.that date_ point 1we'just.- 1 13 talked about is I would take 1.25, multiply;that by.48,336,-and 14 divide it by a million~,: and that would give -me the. equivalents ' q 15 probability of an accident at the flow of01800' vehicles;per; l 16 hour according to your chart; sis'that.right? j t O 17 A Similar,-that;will -- ,] 18 Q Yeah. And IJdid the math,-and will-you accept my y --19 math subject to check, that the resulting answer:was :.060427.-- 20 A I have to check the, number, but -- 21 Q Will you accept that subject to check? 22 A I think it's more than.0.1, but -- 23 Q I said.06042, 24 Well,'want to do it on the blackboard? I'll go up to 25 the-blackboard. LO- ~ ^ Heritage Re' porting,' Corporation <? (202) 628-4888 .y y.: 4 i, 'i s a "q s --?_.'.~.-- Y.' _A

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..- c CEDER - RECROSS' 5516. h 1~ I knew one o'f.us.would wind up here before we..were w s 2 through. T 3 The calculation I have done,-sir ~, 1.25. 4 A Wh'ere it comes from? a 5 Q. The.1.25? Didn't we agree that 1.25'-- 6 A But it's' associated with what flow?~ j 7 Q 1800. 'I'm assuming 1800. 8 A 1800. You are assuming 18007 H 9 Q-That's your last hard data point is.1800. 10 A No. The last, it's more than'1800. It's11850 or --- 11 Q Okay, 1850 is fine. I'll take 1850. t l' 12 1.257 .1 13 A It's more than that. It's 1.35. 14 0 Okay. 1 15 A Okay? 16 0 1.35. And.then'a calculatio'n we would1do~1s to I -1 17 multiply that by 48,336 vehicle kilometers, right, and.' divide ] q 18 it by a million, correct, to be the probability?~ ) 19 A The only thing you have'to beariin mind.'t.that.the 20' 48,000, you are assuming this capacity, the one'I' mentioned.it' 21 through the -- 22 Q No, no, Doctor. The 40,336 cae from theJ fact that' 23 we took your 2.65 miles. We converted it to kilometers and 1 24 multiplied it by the.11,400 cars which you assumed.were going l 25 to go it. That's how I"got'48,;336 vehicle kilometers. O a Heritage Reporting ' Corporation, 1(-202)(628-4888L ./ l'. NL, f4 2, ? a ),m ) 1 e ^ _.x 5 y .)

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. ; r. w, -- n q 3{, 2) ^ .A 's ^ s -j ~5517-CEDER - RECROSS: 4 4 1 A Yeah. 3 !. ~. 2. Q And'I'm'saying that!ifJI.taka.1.35, multiply'it byf 3 that number;and' divide'by(a millionb:Il'm going;toLget'a j .O 4 probability of an< accident, or the nunber'.of accidents %-:take?. s .a 5 that back -- the number of s ' accidents por '100 : -. for : that from t 6 your chart,.the number of accidents that can'be' expect'dato-e 1 L 7 occur at a flow ~of'i1850,71s thatiright? 1 1~ 8 'A Let's see..now,:youj-expect 9 -Q-Let's'do the math, 10-A We can agree around,.1.. 11 _Q Mr. Lieberman did'the' mat $ for me-and he gets ~ 12 .0652536. Do you want.to--- 13 A I agree. I mean, if~that's the math of it..' f A 14 Q And I'll round that:to.0L for purposes:of ~ o 1 ] 15 discussion. i 16 So what' that tells -us ' la' that -- your. chart is. t) L 17 telling us that at a flow of 1850,7.one would expect. 07,_ sevani l 18 one-hundredths of a multi-vehicle: accident every. million i 'l 19 vehicle kilometer miles; isn't that right?. 1 l 20 A Yes. 1 21 0 And now you are trying'tio tell us,.;as,I un'derstand 22 it, that if I move the flow from 1850 to-2000, the probability l 23 rises to 100 percent that that wi.11 occur. 24 A I didn' t say 100 perce nt. I said high. 25 Q High. How high? i i Oi L Heritage: Report ing Corporation' E /~ L, '( 2 0 2 )1 ( 2 8-4 8 0.81, ; ', ' 1 0' x. s, y ~ '.T*,, 4 y (-i 4 _..g-uf J f ) (' t ~$ -t 4_. 't.'?' _? ~.j -'{ r a 4, ~ )4 - g 1 4 1 o

a' y ,s. g. 7 6 4 s . CEDER' RECROSS' 55'18 o(s) 1 A How high?' W 2 .It may rangeLaround., because I don't have the exact 3 J l \\ 3- -figure, but I said around 90 percent according to the figure of -l i-4 probability, not the number of accident. You mix;two things. ,1 5 That's why you are coming out with a different number.. i 6-I converted the figures here into probabilities. 7 While.doing so, you have -- 8 Q Convert that number into a probability for.me, that l 9 .07. Would you do that? l 1 10 A What I'm trying to say it's went through.a.model. .i 11 It's not went directly from the number. I I 12 Now onco you do the probability, you are changing .y 13 some, and you are using some assumption. The figure I use'in I () 14 based on probability, not onLnumbers. L 15 Now by doing the extrapolation we mentioned =before j l 16 for the 2000, we really come up with higher, number than.07. 17 But the point I tried to make it's simply that we.aroidealing. ') 18 here with only fatal and injury accidents,fand therefore, we l 19 may expect more than that. AndLI mention it in the test'imony. ~ 20 several times. 21 Q So as I understand, you want to leave your number,. 22 that.07, it's not a probability,'and if I had 150 cars'to'the' 23 flow, that number would go way up. You don't know quite how. 4 24 high; is that right? 25 A That's right.

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f 5{ o.. , CEDER - RECROSS-5519-j - -5 Q 1 0 And the reason 3t would go way.up,~if-I understood 1 2 your colloquy with-the judge, is something -- because this:is-3- something called an asymptotic curve,..is that.the -- l-7 4 A Exponential curve. q 5' Q Exponential' curve. 1] q l 6 A Yeah. j 7 Q And it is also, didn't I hear the term." asymptotic"?. 8 A' Also'what? 9 JUDGE HARBOUR Asymptotic. h 1 10 THE WITNESS: Asymptotic. 11 BY MR. DIGNAN: ,g 12 Q It is also an asymptotic. curve. 'l 13 A It's not asymptotic,'it's exponential, yeah. j 14 Q Yeah. And what asymptotic'means-is it approaches ^ 1 j 15 something but never-gets there,'right?- j 16 A Yes, but thiE 17 Q Okay. Now, and the reason you get that big number is -i 18 because that curve mathematically takes off like a rocket and 19 never does get to 2000, does it? q 20 A It does for 2000, and it'does'for 3000~and for 4000.. 21 However, we are limit by the amount of vehicle during 22 congestion situation. Therefore, there,is"a limit to what we 23 can think of. The 2000 is actually the limit. So we-.can.still j-24 plug in 2000. We cannot plug in 3000, be~causeino way.you can 25 move 3000 vehicles into two lanes. .i Heritage -Reporting,, Corporation-1 (202) 628-4888 3 I ) 4' 4 4 0

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s 1 i i CEDER - RECROSS 5520 ) 1 Now I am trying to think what you are leading to, and 2 I don't understand. 3 Q Just stay with my questions. I sometimes don't know 4 where I am going, but let's try it. 5 What I am getting at, Doctor, is very simply'I've got 6 seven one-hundredths-accidents and you are going to move it way 7 up. You said 20 or 30, and you're going to do it with another 8 150 in flow. That's the bottom line; is that right? 9 A It is very critical in high flow, because of rear-end 10 and chain collision, and it's highly risky in such situation in 11 which you arrive -- ] 1 12 Q Doctor. 13 A That's the factor. That's the -- r-(-)x 14 Q I apologize, but I don't think.you are. responding to l 15 my question. 16 You want to leave it before this Board that'when you l 17 put another 150 vehicles in that flow, you move,that accident j l 18 number from.07 up to 20 or 30 as you said by the simple 19 addition of 150 vehicles to the flow. 20 MR. FIERCE: Objection to the' premise of the 21 question. All that is happening'is 150 more cars are going 22 into a flow of traffic. 23 MR. DIGNAN: That's what I thought I said. 24 MR. FIERCE: Well, the flow' rate increases to one-25 which is 150 higher. M (Q Heritage-Reporting Corporation (202) 628-4688' l =__

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?.. CEDER. LRECROSS 5521 1 B MR. DIGNAN: 2 Q You will increase the flow. rate'.by 150 vehicles. /And

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from that, you are. going 4to move lit from.that'.07.numberiup to 4 d 4 20 or 30 as 1 hear your testimony.- 5 A That's the' data-telling us.. 8 6 Q-Pardon? 7 A That's what.-- that's what the model is telling'us, 8 the data, the separation of the -- 9 Q I understand that's what'the model is. telling us. :Do W 10 you recall believe that kind of a model'in the real world?L ~ 11 A In the real wor' J taking into' account the 'datalis a 12 . based only on fatal and injury and good weather..:I repeat," 1 'I 13 fatal, injury and good-weather. If.'you include:other 14 accidents, damage-only accidents, bad weather,--during. 15 construction zone, no sign, no marking, I think it's going to 16 move up.to the figure more'or less I mentioned.' That's my 17 belief based on my experience. 18 Q Doctor,.your model is based on fatals and Injury-- 19 producings, and that 20 or 30 number you'are. going to get out~ '\\ 20 of your model is fatal and injury-producing..Never mind what' 21 the weather is or anything else. All by itself,.because'of its 22 nature, your model cranks it from.07 up.to'20 or 30, as:you 23 said it, because you add 150 cars to the flow, or. flow-rate of 24

150, 25 Now, and that's-the bottom line as I understand [it;--

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s CEDER'.RECROSSJ. 5522 s .A. ' (s_). 1-is that' correct? .2 A Flow rate. 3 Q That's right. a 4 A 150 per hour,.okay? d 5 Q Right,:and that's the bottom line. And you.think; -6 that represents the real world. j I 7 A That represent the data I'm using, and I think;that' I 8 that's the real world. I 9 Q And the whole thing happens because the, curve is I 10 asymptotic, isn't that right? 11 A The whole thing happened because the data telling us 1 12 that this is the way the traffic is behave-during congested l l 13 flow. I repeat, congestedfflow. 14 Q One minor matter, Doctor. Yesterday, you;and I U 15 discussed a model called NETVAC.- Do you remember that? 16 And I noticed it.got' rendered at leastJtwol days ago: 17 in the transcript as NECVAC. Can we agree the. proper name is l 18 NETVAC, N-E-T, as in " Thomas ", 'J-A-C?. 19 A V-A-C, right. 20 Q Thank you. 21 Now, under redirect examination of my' friend, Mr. 22 Fierce, you indicated a number of' time that assuming the I l 23 110 interchange had the problems you have elucidated on:-- 24 which we agree with' -- the ETE would go' up. Do'yousremember 25 saying that? Heritage Reporting. Corporation (202) 628-4888 D L' ~' ~ - ~ _z __ ___

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F ~], a ~ J; y, 1 L gCEDER.- RECROSS- .5523 l' 'A ' Tha't 's correct.' 'A's' opposed --~I compare it to-what s 2 I-DYNEV is doing now. .] 3 0 Okay. Is thatinecessarily so, sir,.or ishit-true' j .i 4 that the ETE will go up, the whole ETE will go up'ifE in. fact 5 .that is the traffic that is.the last traffic to leave the 6 evacuation zone? 7 A If this is'the-last traffic to evacuate, if this is a i; 8 bottleneck? i 9 Q I am saying you have indicated that.if you have i 10 bottlenecks, ETEs.go up. 11 A That's correct. I 12 Q 'Now'as you know, an ETE, and evacuation time 13 estimate, as at least'I-use the t<erm and if I'm using it. wrong, e-(~g / 14 is the time to clear the zone you want to evacuate. 15 A Completely. 3 16 Q Right. And my point is if.a given bottleneck' occurs 3 I 17 like this one you described, the.only.way it will lengthen.the-18 ETE is if in fact,it was, to=use.atlayman's term or an 19 engineering term I hear sometimes, the. critical path.- That~is l J 20 to say, that was the last traffic that had to clear the zone. 1 21 Isn't that right? 22 A That's correct. 23 Q So that if -- and do you-know-whether the traffic-24 coming west on 110 is expected to;be the last traffic to clear 25 out of the EPZ in a Seabrook evacuation? O: Heritage Reporting Corporation l l (202).628-4888 a 1 ? ^ .j __Zm__.._.__._.-_.____.__ .__.__? -~

j 4

r i. T c ,I <s u n CEDER - ECROSS 5524 , ~. 1(,) 1 MR. FIERCE: Objection. 'Last: traffic to clear the 2-EPZ or t'o clear the zone?' I 3 MR. DIGNAN: Well, describe the difference between 4 the zone and the EPZ to'me. 5 MR. FIERCE: Well,.you_just.went'through a long l ) 6 explanation which I agreed with, that the ETEs are the' times to 7-clear particular zones. And I don't think we have'any' quarrel ) 8 with that. But the ETE is a_ term that I do' quarrel with. I 9 There is no such thing as the ETE. There.are ETEs.to clear 1 10-various zones. So I object to the form of the. question. 11 MR. DIGNAN: Press it. I pressed the question. 'I 12 think it's a fair question. I-think the witness knows what he 1 1 f 13 is talking about, and I think I do, too. 14 JUDGE. SMITH: So long.as the witness understand:the: 1 15 sense in which the question is being put,1and he.seemedLto, no 16 harm is done. But I agree'with you, Mr. Fierce,1-that'there j l 17 should be a clarification of what is,being referred to. 18 MR. DIGNAN:. All right, let'me go slowly. 19 BY MR. DIGNAN: l 20 Q Dr. Ceder, you have said.that the'bottleneckLthere 21 and other bottlenecks could increase the ETE, right? Let's l 22 assume the evacuation ordered is the whole EPZ. Okay, the 1 23 whole, right. 24 In that situation, any particular bottleneck that' 25 occurred would lengthen the ETE only.if the traffic-passing I ^) Heritage Reporting Corporation (202) 628-4888 g l~ .n ^ - - - _ = - _ - _ - -.. - - -... - _ .6-

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y 3 E-4 ,1 ' 1 ,e i. j ' s a CEDER - RECROSS 5525 q ,kh 1 through that bottleneck w . going-to be the last traffic to-2- exit the'EPZ, isn't that right?, ) 3 A' That's correct, according to.,the definition ofJETE.' 4 Q And my question to you,. sir, is, are'you aware 5 whether or not the traffic that-is expected to go down Route 6 110 to the west is the traffic that is assumed to'be that which 7 will be.the last to leave assuming an evacuation of the entire-8 EPZ? I 9 A To my best knowledge, the answer is yes, based on the 10 computer run made by Tom Adler in Vermont. When he used the-11 I-DYNEV, he found out while using the Seabrook. data that the k 12 major -- I think two bottleneck. One of them is the one you -J 13 just mentioned. 14 Q That's Dr. Adler's run, correct? ) 15 A That's correct. 1 16 Q Do you know if it's assumed to be the traffic to last a i 17 leave in the runs that the Applicants'.. experts'have made?: l i 18 A I am not aware of that. I.am-aware only of Tom Adlerc j 19 runs when he used the Seabrook data give to him by Volume 6. -) i EndT68 20 Q Fair enough. T69 21 And the last point is would you be kind enough to get 1 3 22 in front of you, sir, Applicants' Exhibit 23 which is your-1 23 article, Relationships Between Road Accidents and Hourly 24 Traffic Flow II,.which you discussed with Mr. Fierce-this 25 morning? J 0; Heritage LReporting 'Corporati'n o (202) 628-4888 - a . J_. .__.m _d

t -J Jr ;< f ta - t q y ,I, 5 1 5526 " CEDER - RECROSS .h ^ l' A Yes. -C 2 -Q 'And you once again}said that in1 utilizing the curves: 7 1 3 on Page-41 where the abscissa is la'eled M in hours, it was. b l' 4 ~ perfectly appropriate:for you'to relabel-that.to~be vehicle 5-hours in your' Attachment 9. 6 Do you recall that? 7 A 'I recall,-yes. l 8 Q .And you said.that perhaps your article hadn't been 9 clear, but that.that was the intention.- 1 10 Now,.could you come to'Page'37, sir,'of your article? 11 JUDGE HARBOUR -Mr. Dignan, you'just. referred.to-the 12 figure on Page 41. Did you mean'Page 41, or anotherEpage? 13 MR. DIGNAN: I apologize, Your-Honor. I meant to k 14 refer to Page 42. j 15 JUDGE HARBOUR: Figure 5 in the article. 16 MR. DIGNAN: Yes.' I apologize. 17 BY MR. DIGNAN: 18 Q Let's make that clear. We're talking about Figure 5 19 on Page 42 of the article, which is the'one'that 1sl reproduced ~ 20 as Attachment'9 to the your-testimony.withLthe abscissa-labeled' l i 21 vehicle hours, correct? 22 A Okay. 23 Q And you made the point.that the article wasn't: clear 24 perhaps, but they were equivalent. I was intrigued'by l 25 something. On Page 37 in the paragraph.that appears'below the . Heritage: Reporting.. Corporation 1 (202) 628-4888' a ,j

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CED'ER - RECROSS 1 5527 first equation on that page', you make a reference-in the second

() 1-l p 2 'line to VEH-KM. That's vehicle kilometers, right? ~ 3 A Can you tell me.which'-- 4. Q Page 37. 5 A .Yes. 6 0 There is an equation that says ADWQ equals -- 7 A What number of equation? ] l 8 Q The what? ) 9 JUDGE HARBOUR: Number of equation? 10 THE WITNESS: No number is the first equation? s 11 MR. DIGNAN: It's got no number on it. 12 THE WITNESS: So it's the first equation on the-top, f 13 MR. DIGNAN: Yes, the first equation.- I> 14 THE WITNESS: Okay. l 15 BY MR. DIGNAN: 16 Q Two lines below that you make a reference to VEH-KM, u 17 right? 18 A Right. 19 Q And that's vehicle kilometers. j i 20 A That's correct. It's one measure. ) 21 Q And down below equation five again, I see a reference 22 to VEH-KM, correct? 23 A Yes. 24 Q Now coming out of Page 41 -- 25 A Yes. O Heritage Reporting Corporation (202) 628-4888

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CEDER - RECROSS 5528

,};. [n]- 1 'O' --- below the equhtion Lthat's about:f two-thirds of the-2_ way down.the;page,-the first line, there is a reference to 3-kilometers.. Do.you see that? ' 4 A Vehicle kilometer? 5 Q No, a' reference to-just plain, old kilometers. Do 6'

you see that?

The line begins, "And N kilometers". 1 7 A Number'of kilometer. 1 l 8 Q Now vehicle-kilometers and kilometers are two J 9 different things, correct? I 10 A -Not'in the context I'm putting.. One' vehicle-i 11 traveling many kilometers'are equivalent to many vehicles > j 12 traveling one kilometer. 13 Q Yeah. But a kilometer.is a kilometer,.and a vehicle fm - d 14 kilometer is a product of kilometers and' cars, right? 15 A Right. 16 Q And hours are hours,-and. vehicle hours are-products 17 of hours in cars; isn't that right? 18 A That's right. 19 Q Now in this document in which you carefully q { 20 distinguish between using kilometers and vehicle kilometers,-I J -l 21 see nothing but references to hours, and I cannot find a j 1 l 22 reference to vehicle hours anywhere in that document. Am I l l 23 correct? 24 A As I mentioned before -- l 25 Q No. My question is, sir, am I correct that I cannot j Heritage Reporting Corporation n (202) 628-4888 ~l

i CEDER - RECROSS '5529 /~T i find-the term " vehicle hours" -- g 2 A You cannot -- 3 0 -- in this article?-- 4 A You can find the term " vehicle". -You cannot find the 5 term " vehicle hours". 6 MR. DIGNAN: Thank you. That's'all I have. 7 JUDGE SMITH: Is there any additional examination of 8 Dr. Ceder. 1 9 JUDGE SMITH: Dr. Ceder, you are excused, and thank i 10 you very much for coming, sir. 11 THE WITNESS: Thank you. j j 12 JUDGE SMITH: Doctor, Judge Linenberger has a j

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13 question for you, i ['T l N/ 14 JUDGE LINENBERGER: Sorry to take up the additional j .j 15 time here, but I need just a little bit of help. j 1 16 Dr. Ceder, if I were to ask two recognized j 17 cosmologists about the age of the world, one might say 5 18 million years. Another might say six million years. And I-19 really would consider them to be pretty much the same number,- 20 because of a variety of kinds of thing that I suspect you are-21 familiar with. l 22 Several times in recent hours, I have heard numbers f 23 such as 2.4 and'2.7 discussed. The lower one being less 24 desirable than the upper one. I can only say that if I look at 25 .the five million years and the six million years, I'm not in a j I /~ i l-)S j Heritage Reporting Corporation I (202) 628-4888 s _I

f ? .i \\ 1 i 3 o.- em u ^ e 5530: () 1 position to talk about 'which one is more ' desirable.. m w 7 2 When yo"u talklabout 2'.45and'227,^why;is.it_you are in- . w. 3 a position to. find one more desirable than the other?- ] .,J. t .c -? 4 THE WITNESS: _,(Ceder)AAndlyoulask why I amcin"the 5 position? 6 JUDGE LINENBERGER: Why is the stateLof:your" H 7 knowledge, the state of the discipline in?aEposition.to,make"a: j 8 distinctionbetweenthiose'twonumbers? 9 THE WITNESS ' (Ceder) Based onLthe situation which1I j 1 10 assume:to happen during evacuation scenario,,I have the full-i 11 confidence that the numbers taken from normal operation, normal' .l 12 activity are inadequate. New number must be entersin order to -1 13 account for spacial ~ operation, spacial behavior...This is.the j 1 k_ 14 reason why I'm suggesting or recommending to use.different d 15 numbers, and questioning theLother numbers. l l 16 JUDGE LINENBERGER:'.Well, I guess I'm.still a littles 17 bit concerned here, because I can-understand ~why some'aspectiof-18 the result would be more appealing if.you used say a higher 19 number than a lower number,~but I really am trying to get a 20 feeling for in the real world is the state'of' refinement of 21 your, and when I say you, I mean people'such as you' 22 collectively, is the state of refinement of your observations 23 and analysis such that changing 2.4 to.2.7 is.really 24 meaningful. 25 THE WITNESS: (Ceder) It may.not. Itimay be. I O Heritage Reporting Corporation (202) 628-4888 .i _= = -

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6 s j 5531 h 1 -would say that with.the information;I(have,UILtried to shed-w- ~ _ 2- . some ' light ' on the problems 'I. see it Lright now with the hope to j 3 come to more realistic number. When'I-started to;do~myl work,.I 4 didn't know'if I'm going to'come up with -- if the'ETE are.too 5 high to my opinion, too low, or they are'to my opinion, 6 realistic. I 7 I came up with'the conclusion that they are.too; low 8 based on the information I have. ] t 9 JUDGE LINENBERGER: Thank you,' sir. j ~ l '10 JUDGE SMITH: Okay. Now you are excused, sir. 11 THE WITNESS: (Ceder) Thank you. 12 (The. witness was thereupon excused.) .13 JUDGE SMITH: Now, we'll take up:now the, Applicants's 14 motion, or Applicants' objection to the testimony of the Panel 15 of Sholly, Beyea, Dr. Thompson and Dr. Leaning. 16 We have -- already we.have'the Applicants' motion, ) H 17 the Massachusetts Attorney General's response to,the motion,t i 18 and Ms. Curran's response. NRC Staff has indicated that it 19 wishes to be heard orally on it, and just for planning 20 purposes, who else -- does anybody.else wish to be heard on it 21 orally except, of course, I understand that Massachusetts AG 22 does. Does anybody else wish to be heard orally on it? l 23 MR. BACKUS: I expect all we'll do, Judge Smith, is 24 just note for the record our concurrence on the position argued 25 by the Massachusetts Attorney General. l-A( / Heritage Reporting Corporation (202) 628-4888 i -i fj s

] ( a. 5532: i 1 (])' -1 MR.' BROCK: I'd' agree.with thgt,.Your Honor. 2 Hampton. ..l 3. MR. DIGNAN: Your-Honor, I don't want~to be. heard as' 'l 4 such. I would like an opportunity,Lif I. feel it.necessary, to' 5 .replyfto the oral argument which we' hear t'oday from the-6 Attorney General. 7 JUDGE SMITH: All right, i 8 Okay, Mr. Turk, please. -l 9 MR. TURK: Thank'you, Your Honor.. i 10 JUDGE SMITH: Oh, let me just. point'out a minute. 11 I'm sorry, -- yes. 12 MR. TRAFICONTE: My name is~ John Traficonte, Your 13 Honor. O 14 JUDGE SMITH: Oh,'yes, I'm familiar with your notice l i q 15 of appearance. 16 MR. TRAFICONTE: Yes. 17 JUDGE SMITH: About how long ch) you'think that your 18 remarks will take, if you can give us an. estimate. 19 -MR. TRAFICONTE: Well, I will try to be as concise I 20 can be, but 10 - 15 minutes. 21 JUDGE SMITH: Oh, that's fine. We have et least that 22 time. 23 The. Board realizes that this is.a very important 24 issue, a watershed issue here, and we want to hear absolutely 25 fully everything that has to be said even if we have to provide Ov Heritage Reporting Corporation (202) 628-4888

'w"' .q, .p ( ;r i"-5* u 3, s -5533 ( f' 1 additional time. 2-All right, Mr.: Turk.' 3 MR._ TURK: Thank you, Your Honor. LI'll'.try to be. 4 very brief as well. 5 The' Board'may recall that sometime-ago I indicatedLin 6 ouritelephone~ conference call,.I believe back in September,_ 7 that the Staff was considering a motion to strike the. 8 Sholly - Beyea testimony. The Applicant'has done'it'already. 9 I have reviewed the Applicants'. paper, and I concur 10 in it fully. So my comments today will betrather brief.. 11 I do want to lay in a bit of history, and I would 12 like to take an opportunity to respond bElefly to some things I-13 saw in the Massachusetts Attorney General's opposition txt the j 14 Applicants' motion. ~ 15 First, back in early 1986, the Massachusetts. Attorney. 16 General proffered a contention,.the only' contention that they 17 have proffered in'the off-site emergency planning phase-of._this 1' l 18 proceeding.- That contention essentially asserted that.the 19 provisions in the-New Hampshire plan with respect:to beach 20 populations were inadequate, and the premise underlying'this' 1 21 was that there could be significant doses incurred by the beach h 22 populations in the event of an emergency. 23 The Massachusetts Attorney General indicated that .) I 24 they were in the process of developing a study to support the-25 contention. And the study which they -- excuse me. The q l O Heritage Reporting Corporation (202) 628-4888 ) l _.___.__.___A____

i l l 5534 l () 1 persons involvedIin1that study were stated'in the contention to 2 be inclusive of Mr. Beyea. Trying to find the exact page-3 reference. I don't have it'in front of'me, and I won't belabor 4 the point. 5 It's our perception that what has been proffered as 6 evidence to be admitted in this proceeding now is really what 7. the Massachusetts Attorney General had in mind.711 along back 8 when the proffered their original contention which has already 9 been rejected by the Board. 10 Our position, in response to that initial contention i 11 proffered by the Mass. AG, was that consideration of dose ] I 12 consequences is inappropriate in an emergency planning 13 proceeding. That's not the purpose of the Commission's rules 14 and that's not something that we should be'getting into in this 15 proceeding. 16 Now, we did state in our response to that contention, 17 however, that to the extent the contention sought to assert 3 18 that there were inadequate provisions for sheltering contained 19 in the New Hampshire plan, that was something that we felt was 20 fair for litigation within the context of this proceeding. 21 Now the Massachusetts Attorney General rejected that 22 suggestion and said, no, it's all or nothing. This is our 23 contention. This is what we stand on, and the contention was 24 rejected. 25 Now the reasons why it's inappropriate to consider b' v Heritage Reporting Corporation (202) 628-4888

5535 () 1 dose levels in emergency planning proceedings ~~are pretty much' 2 well laid out within the Applicants' motion. And if I can 3 simply summarize very briefly,.perhaps in one sentence, and 4 this will probably be an overstatement, it's the function of 5 the emergency planning regulations to assure that there are 6 plans in place to help deal with the consequences of an. 1 7 accident should one cccur. 8 We don't get into probabilities at'this phase. We 9 simply make the assumption that an accident can happen,.and if I 10 an accident happens, we need to have plans in place within the 1 11 areas outside of the plant to help the evacuation or other 12 protective actions which may be recommended for the population. 13 And that's what we have been doing through these many weeks of 1 Gk/ 14 hearings until now, and that's what we wi11' continue to do. 15 until this phase of the hearing is completed. 16 There is no minimum acceptable dose for emergency ~! 17 planning purposes. To the extent that the Massachusetts I 18 Attorney General's testimony here seeks to assert that some 1 i 1 l 19 level of dose reduction has been provided, or is not being I 20 provided, that's simply irrelevant for purposes of emergency ] l 21 planning. I 22 In their response to the Applicants' motion, the l 23 Massachusetts Attorney General's office says that, in fact, ) 24 dose consequences have been considered in certain NRC 25 proceedings, and he cites two. One is the Jamesport proceeding j i ('i 1 s/ i Heritage Reporting Corporation I (202) 628-4888 t l

a t 5536 i (f 1 in which a decision was rendered in 1978. The other'is the 2 Clinch Breeder Reactor proceeding in which I note Judge i 3 Linenberger was involved, because I also was a part of_the j 4 proceeding. Those two cases are simply inapposite. l l 5 The Jamesport decision came out prior to the adoption 6 of these emergency planning rules at a time when the emergency-7 planning occupied a totally different-place within the 8 Commission's regulations. At that time, as'the Jamesport 9 decision itself discusses, the consideration was whether design 1 10 basis accidents would have certain consequences which had to be 11 ameliorated. It's in that context that the doses at Jamesport ) 12 were considered in that decision. 13 The Clinch River case, similarly, is not applicable. () 14 The Clinch River was a -- was not a light water reactor but 15 rather, was a breeder reactor cooled by liquid sodium. 16 NUREG-0654, and indeed the regulations for emergency planning i 17 make it clear that these relate to light water reactors. I 18 Clinch River presented something entirely new for the 19 Commission to consider. It presented a reactor concept which i 20 had not been considered in the course of adopting the 21 Commission's regulations. 22 For that reason, various new considerations were I 23 given to that reactor which are not given in normal light water l 24 reactor proceedings. For instance, in that proceeding we had 25 extensive testimony on the consequences of core disruptive 1 C) Heritage Reporting Corporation (202) 628-4888 l

.a 5537 () 1 accidents. Those are accidents which are beyond the design 21 basis and, in essence, I guess.to over simplify again,Lthose-3 are core melt-type situations; j 4 Similarly in that proceeding, the Board had a concern 5 as to whether the protectivo action guidelines of the EPA which 6 apply to light water reactors similarly should be applied.to a 7 breeder reactor, which is not a light water. reactor. And'it's L 8 in that context that we got,into somewhat of a limited, but 9 still a discussion-of what the dose consequences would be and j 10 what emergency planning would require for the bre'eder reactor. 11 Those cases are not applicable. Thecmain body of law j s; 4 12 of the Commission, as cited in the Applicants'. motion'with 13 respect to the San Onofre decision, as' cited in -- and as 14 reiterated most.recently when the Commission adopted its final 15 rule last week with respect togjurisdictions where governments 16 do not participate in emergency planning, that law states that ] 17 it is inappropriate for the dose reductions to be taken into l i 18 account in considering emergency planning of any particular 19 governmental regime. 20 And on that basis, the staff supports the Applicants' l 21 motion to strike the testimony. 22 JUDGE SMITH: Mr. Traficonte. 23 MR. TRAFICONTE: Thank you, Your Honor. 24 Initially the Commonwealth wants to-express its 25 appreciation for the opportunity to have oral argument on the O Heritage Reporting Corporation (202) 628-4888 i

y 'f 5538 O 1 Applicants' moti n to strike the Beyea - Sholly testimony. 'We 2 appreciate the additional time and we understand, obviously, 1 3 that it does burden'the' proceeding, but.we agree with the-Panel 4 that that this is an extremely important issue,..and one' worth 5 hearing. 6 I personally feel in a rather awkward position. 'I've 7 never argued i.. o situation before where'I have been so l 8 convinced that I was.right with a certain' degree of certainty,. l 9 having the same degree of. certainty.that the Panel believes y +- 10 quite the contrary. And I wouldlike to as.briefly andtas J 4 l 11 concisely as I can lay out what I believe the Interveners" l l 12 collectively see as the immediate' clear and direct relevance of 1 13 the testimony that's been proffered. And then to proceed to'a 14 discussion of the precedent, as Mr. Turk has mentioned,fto 15 distinguish that precedent and to show why'in the circumstances 16 of this particular case the kind of evidence that's'ateissue 17 here should not be stricken. 18 In fact, it would be.-- we believe it would be error 19 not to take this evidence into consideration in judging the ! EndT69 20 adequacy of the New Hampshire plan. l l T70 21 To begin on relevance, we like to characterize this 22 evidence essentially as an effort to display or illustrate the 23 actual level of protection afforded the summer beach population 24 by the plan. This illustration takes the form of radiological 25 dose consequence information, in part. -Obviously, it.also O Heritage Reporting Corporation (202) 628-4888

o 5539 ( l contains health consequence. discussion. 2 But, in essence, Ewe'believe it is illustrative of the-3 actual level of protection afforded the: summer beach population 4 in the event of a range of accidents afforded that. population ~ P 5 by the plan. Expressed that way, I believe the Interveners 6 collectively.have a hard time seeing how that cannot be 7 relevant..To a layman, it's,quite clear if a layman were 8 reading a newspaper or in a discussion about.what's.at' issue 9 here, he would no doubt come away from that discussion 10 understanding that this Panel is burdened with'the task,of 11 judging the adequacy of this' plan. Does it provide' reasonable 1 ~ 12 assurance that there will be adequate protective measures 13 afforded the population at risk. j O 1 14 If that lay person then found out that Eur empirical i 15 piece of evidence that was. illustrative of the actual level of 16 protection afforded was not going to be considered,Jwas not 17 going to be admitted because it was determined that that kind I 18 of evidence, the actual level of protection afforded'the 19 relevant population was not relevant to the determination by l l 20 this Panel as to whether that level of protection was adequate 21 or not, I think that person would be puzzled as'I am. 22 As I said at the outset, I am fairly certain that on 23 the issue of relevance alone, which if the Panel would review. 24 the Applicants' motion, it's certainly on the basis of 25 relevance that the objection has been stated; that on the basis j Heritage Reporting Corporation (202) 628-4888

l ] 5540 ( 'l of relevance alone if the issue is what is'the level -- is l 1 2 there -- strike that -- is there an adequate level.of l 3 protection. 4 .On that issue evidence of the actual level'of 5 protection afforded is directly, clearly, immediately relevant. f 6 I go as far as to say that something must be blocking, either 7 something in the way of an exclusionary rule, which I would 8 like to come back to in e: few minutes, or something else is .g 9 blocking it, thac obvious perceptions that this is.-relevant 10 testimony. I think it would be' considered relevant by most i 11 people. ] t 12 That in the general way should be more narrowly put, 13 I believe, in the circumstances'of the'Seabrook case, because l 14 whatever the rule is or is not generally at the operating 15 license stage adequacy of emergency planning is tested. In 16 this particular circumstance where the plan has no planned i 17 sheltering provision, that essentially the applicant is i 18 prepared to run on the basis of -- to go forward and run on the i 19 basis of evacuation alone, I think that clearly sets your task, 20 the judgment of the adequacy apart from the normal, if there is 21 such a thing, the normal test of adequacy of some other plan. 22 You are to judge the adequacy of the plan essentially 23 with no planned sheltering in it. On that basis, setting aside 24 25 JUDGE SMITH: Would you repeat that? O Heritage Reporting Corporation (202) 628-4888

1 .l J 5541: .t 'l MR. TRAFICONTE: Cert'ainly. 2 ' JUDGE SMITH: .I.just-wandered there'for a. minute, and-I 3 I thought I was following you, and-it didn't come.out that way. ] 4 MR. TRAFICONTE:-,Certainly. .I am distinguishing.the; 5 Seabrook plan,.and the task in front'of you from the-general 6 context of judging the adequacy of emergency planning,..and the 7 key distinction is that in this case you are to judge the 8 adequacy of the plan in the absence of a planned shelter.ing 9 component in the plan. 10 I think that distinguishes what the task is.. The 11 issue of adequacy is not as simple'as it otherwise would be. j 12 In part, because the regulations clearly anticipate that a plan 13 will have a range.of protective measures,'and that;the Panel, 14 the public, the NRC.can take some confidence that there is -- i l l-15 take confidence in the fact that there.is this range. ) 1 l 16 Here there is no planned range of protective-17 measures. There is simply one -- evacuation. In those 18 circumstances, our evidence -- and again, our effort to display 19 or illustrate the actual level of protection afforded should be 20 admitted. You should consider what the result is in terms of 21 radiological dose consequences. You should consider what the j n 22 result is on the affected population at. risk of the absence of 23 one of the major set of protective measures, which is' exactly 24 what we have in this case. Sheltering has become quite clear, 25 at least as of now, it's not a planned protective measure. O Heritage Reporting Corporation (202) 628-4888 i 1 l ,1:)

1 ,5542 ..h ' fl. on that. point, and I'll.be..very brief, I think.on. 2 that. point at'least this. evidence is~ completely in harmony _with ~ c, 3' Hampton Contention 8. 'Hampton Contention 8 being the; 4-contentien, in fact,.that in.the absence of;a.' sheltering l 5 measure there can be no finding of adequate protection.= And so l 6 our testimony would -- our test'imony would support lthat 7 proposition that in the abaence of a sheltering measure,, 8 planned sheltering, the actua2 radiological dose. consequences-l 9 are severe enough that the Board is~ going'to be unable to~ find r 10 adequacy. ii 4 11 Along the same line, I.would-say that our testimony is relevant here because TEMA in it's prebiledfte's' tim _o.ny' $ s 12 13 made exactly the same point. It essentially.has distinguished O .? 14 this case from other' cases. Finding that:in the absence of a-15 sheltering or-a realistic sheltering alternative, there is not 16-adequate protection. 17 We, obviously are in -- we are. attempting to supply,. 18 if you will, the technical basis for.that judgment that'in'the U 19 absence of sheltering there is no adequacy. o 20 Now let me proceed. I think I have said certainly 21 enough on relevance as an essential matter, as a preliminary 22 matter. We obviously think the testimony is relevant. I 23 However, it is also clear,'it's clear'both from case 24 precedent cited by the Applicant in its motion. It's clear 25 from a careful reading of the Commission's.rulemaking issue O Heritage Reporting Corporation (202) 628-4888

5543 () 1 this week. It's also clear that you are not obligated to make 2 specific dose saving findings. That it is not necessary.for 3 the purpose of your task to make findings in the record that 4 this is going to be the number of people. injured in the event' 5 of Accident X, or.this is going to be the amount of dose l 6 savings achieved in the event of Accident Y. 7 It's very clear that that is not your task, nor does-l 8 the Massachusetts Attorney General believe it is your task. l 9 JUDGE SMITH: Well, did you before? 10 MR. TRAFICONTE: I don't believe that anytime we have 11 taken the position in the pleadings that I have reviewed, or 12 otherwise, that we felt it was a part of the' job,'a'part'of 13 your task to take specific findings of the level of dose kT r ) 14 savings. Never felt that way, and.I don't'think the testimony 15 is structured is on that basis. 16 There is a far -- there is large difference, and it 17 is a far cry from the need, or the absence of the need to make 18 specific findings of dose consequence to.the position that 19 evidence of the actual level of protection expressed in doss' 20 consequence terms in not relevant. That, quite frankly, is 21 apples and oranges. 22 JUDGE SMITH: Okay, this -- 23 MR. TRAFICONTE: That's the heart of the matter. 24 JUDGE SMITH: Right there you are. 25 MR. TRAFICONTE: I believe it is. And I think if I Heritage Reporting Corporation j (202) 628-4888

q i i l 5544 i -~ $( ) 1 can analogize it to a court sitting in judgment on the 2 competency of an individual, for example, comes up every_ day -- 3 probate courts and other kinds of cases. If a panel or a court f I 4 is required to find competence as a general legal matter, it { 1 5 may well hear evidence of the objective results of testing, for l 6 example, presented by a psychologist. It may hear evidence of ) l 7 a similar kind that is quantitative, objective. l l 8 That evidence which would be admissible is admissible 1 9 because it's relevant to the ultimate fact -- is the person l 1 l 10 competent. It is not necessary for the court in those ( 11 circumstances to find, yes, the person scored a certain 12 numerical amount in the Minnesota test' That wouldn't be a 13 necessary finding. It wouldn't be your burden to do that. But 14 the evidence of what the person scored on that test would 15 certainly be relevant as part of the picture as to whether or l 16 not the person was competent. 17 I think we are in absolutely analogous, if anything 18 is absolutely analogous, I think we are in an analogous 19 situation. I think the task before you is the determination 20 that the plan is adequate. And we all know, and we don't need 21 to clutter the record with a dispute as to what is adequate. 22 It's clearly something that's site-specific. It's not defined i 23 for a good reason. The Commission has not indicated what that 24 is in numbers. 25 You cannot conclude from that that to hear about Heritage Reporting Corporation (202) 628-4888

5545 im ( ) 1 numbers or to take evidence expressed in numbers of the actual v 2 level of protection afforded by a plan, that somehow that 3 exercise is illegitimate, or that that evidence is 4 inadmissible, because it'is the position of the Applicant that 5 that kind of evidence cannot be admitted, and that's different 6 from a determination that this Panel must find that the level 7 of protection expressed in an objective mathematical way l 8 reaches a certain level. l l 9 JUDGE SMITH: Do you want me to ask you questions as 10 you proceed or -- 1 l 11 MR. TRAFICONTE: Certainly, certainly. 12 JUDGE SMITH: -- wait until you get done? 13 Well, all right, take that point, take your point, ("% (m/ 14 and then carry it through to the next step. Let's assume that 15 we -- under your argument we accepted testimony as at least I 16 relevant for the reasons you said. Now comes that we have ( 17 received it, it's cross-examined and it survives pretty much. 1 18 What are you going to do with your proposed findings? 19 Where do we go with it? How do we plug it in to the rest of 20 the evidence and to our conclusions of law and proposed 21 findings. Where does it take us? 22 MR. TRAFICONTE: Not to precommit ourselves to how we 23 would actually reference it in a finding of fact -- l l 24 JUDGE SMITH: Well, but that's a test you are going 25 to have to meet. I~T Rol Heritage Reporting Corporation (202) 628-4888 l

5546 ry (j 1 MR. TRAFICONTE: Certainly. 2 JUDGE SMITH: That's really what the test is. 3 MR. TRAFICONTE: Sure, let me be directly responsive 4 to that. 5' I believe that the testimony other than this 6 radiological dose consequence testimony the Interveners have 7 put forward is designed, and this is no secret, to illustrate 8 and to prove that the plan is not adequate. And again it's no 9 secret that if we believe it's inadequate, we believe it is ( 10 inadequate because too many people are put at too great a level l 11 of risk. That's the point. That's why there is opposition to 12 the plant. It's also a major reason why we are here. We 13 believe that too many people are put too great a level of risk. 14 If you press us as to what constitutes too many 15 people, and what constitutes too.much risk,.we're going to, ( 16 unfortunately, kick it right back'at you. We view that as your 17 obligation to determine what is too many people and what is too 1 18 great a risk. But we believe that if reasonable assurance of l 1 19 adequate protection means anything, if it means anything, if l 20 there is a standard there at all, obviously there is because we l 21 are all here testing it, there has to be a line that could be 22 drawn. Too many people -- 23 JUDGE SMITH: A quantitative line, a quantitative 24 level of adequacy. 25 MR. TRAFICONTE: Judge Smith, whether we express it O Heritage Reporting Corporation (202) 628-4888 l l

5547 () 1 as a quantitative line or a qualitative line, as FEMA obviously 2 has done, chosen to express it as a qualitative line, whether ) I 3 it's quantitative or qualitative, it's a line. It's a point, l l 4 and here obviously we take great exception with the thrust of 5 Mr. Dignan's motion which essentially, in my view, reduces to 6 the point that there really is no line. That once the plant is 7 sited here, it's passed the siting requirements, we will put a l 8 plan in effect, but the level of pro,tection is not any longer 9 going to hold up the licensing, or the actual level afforded [ 10 the population will not hold up the licensing. 11 We obviously disagree with that. We think that-the l 12 Commission has set a standard of adequate protection. It's a 1 l 13 finding that comes before a' license, can't get one without it. 14 And we think, again going back to the quantitative / qualitative l 15 distinction, we think any kind of evidence is relevant. 16 Qualitative evidence, the traffic management plan is not 17 adequate, I-DYNEV is not the best that it could be, the ETEs l 18 are artificially low, and quantitative evidence. In the 19 absence of sheltering, and again I want to reinforce that 20 point, in the absence of sheltering, this is going to be the 21 consequence of an entire range of accidents -- serious 22 radiological injury to a significant number of people. I 23 Of course, we believe those are too many people at 24 risk, and we believe that level of risk is too high.

But, 25 again, not to be particularly vicious about that, but that's

(_s) Heritage Reporting Corporation (202) 628-4888 1

i 5548 () 1 your problem, to determine whether it is too many people,'and 1 2 it is too great a risk. But we believe that'the evidence of H I 3 that risk is clearly admissible to your task of trying to j l 4 establish that line. I 5 I don't want to take up too much time. Obviously, I-6 have gone over the 15 minutes. 7 JUDGE SMITH: Take your time. I l l 8 MR. TRAFICONTE: Let me make some final points in the l 9 way of just clearing the ground, although from the Panel's 10 comments, I understand perhaps you have a very clear view of 11 what the issue is. 12 We are not presenting this -- 13 JUDGE SMITH: I want you'to take all'the time that A k.-) 14 you feel is necessary. We will~ provide for it. This is an j 15 issue where the Board wants as'much help as we can~possible I l 16 get. I mean, it's awfully important as you recognize. i t j 17 MR. TRAFICONTE: All right, thank you, Your Honor. j 18 Just son.e quick ground-clearing points. As I just ) i 19 indicated, I believe the Panel has the question quite clearly 1 20 in view, but I just want to eliminate these issues, because i 21 they are not serious issues although they do appear in the l J 22 Applicants' motion. 23 Our evidence is not evidence that would lead us to 24 litigate a worst-care scenario. It is not evidence that is 25 structured or based on a single accident. It's quite clear O Heritage Reporting Corporation (202) 628-4888 i

I i -l <I 5548 ,~(,) 1 your problem, to determine whether it is too many people, and 2 it is too great a risk. But we believe that the evidence of 3 that risk is clearly admissible to your task of trying to 4 establish that line. I 5 I don't want to-take up too much time. Obviously, I 6 have gone over the 15 minutes. 7 JUDGE SMITH: Take your time. 8 MR. TRAFICONTE: Let me make some final points in the 9 way of just clearing the ground, although from the Panel's 10 comments, I understand perhaps you have a very clear view of l 11 what the issue is. I 12 We are not presenting this -- Iwanyyoutotakeallthetimethat f 13 JUDGE SMITH: ( 's_/ 14 you feel is necessary. We will provide for it. This,is an i 15 issue where the Board wanta as much help as ina can 'possible 16 get. I mean, it's awfully important as you recognize. 17 MR. TRAFICONTE: All right, thank you, Your Honor. I 18 Just some quick ground-clearing points. As I just i 19 indicated, I believe the Panel has the question quite clearly ~ 20 in view, but I just want to eliminate these issues, because j 6 21 they are not serious issues although they do appear in the f I 22 Applicants' motion. 23 Our evidence is not evidence that would lead us to i 24 litigate a worst-care scenario. It is not evidence that is 25 structured or based on a single accident. It's quite clear ("% i \\_) l Heritage Reporting Corporation (202) 628-4888

I 1 5549 () 1-from the Sholiy portion of the' testimony.that we have attempted ~ -i 2 to model the radiological' effects of a whole range of accidents J 1 3 within the planning basis.- And our papers on this point I 4 think speak to it. 5 JUDGE SMITH: You mean the Beyea portion?. j 6 MR. TRAFICONTE: The Beyea portion. 7 JUDGE SMITH: Yeah. i 8 MR. TRAFICONTE: Sorry. 9 Furthermore, along the same line, my comments should 10 be clear if our papers are not that it is not our position that i 11 the issue here is zero risk. That has never been our position. 12 And after rereading the pleadings that predate my work on the 13 case, I have to insist on the record that'that'is Mr. Dignan's 14 red herring. I don't believe<the Massachusetts AG's office has 1 15 ever represented that zero risk'is the name of the game.. Quite 16 frankly, it doesn't make any sense. 17 The third point, and this is.in the way of clarifying 1 18 my earlier points, we are not offering this testimony in i 19 support of the proposition that any particular level of 20 protection that we can identify in the record, and give it a 21 numerical expression, we're not offering our testimony for the 4 22 proposition that any particular level of protection is 23 necessary. 24 Instead, we are offering our testimony as' evidence 25 that this plan doesn't provide adequate protection. And it l Heritage Reporting Corporation (202) 628-4888

5550 ( 1 doesn't provide that level of adequate -- it doesn't reach the 2 level of adequacy because of the number of people at risk and 3 the severity of that risk. It's not -- this is really aLgloss 4 on the point that we don't represent zero risk. Not only do we 5 not represent zero risk as the standard, we are not. identifying 6 in our testimony what level of risk is acceptable. Again, we 7 don't see that as our task, thankfully. We see that again as 8 the Panel's task. We are only representing that the level of 9 risk that this plan imposes on the population is.too high, and l 10 therefore doesn't reach the level, the statutory and regulatory 11 level of adequate protection. l l 12 Final point, and I'm prepared to go into some detail 13 on this one. I think it's an important point. I apologize to T i ,k/ 14 the Panel for not having cited further case which I am prepared 15 to cite and will cite in the, record this morning.,Further 16 cases indicating that the NRC and the' licensing boards at'the 17 operating license stage have taken dose consequence' evidence 18 into consideration in a very analogous circumstance. I 19 So, in part, I want to respond to Mr. Turk's point i 20 that our two cases that we have cited, the Clinch River case j 21 and the Jamesport case are distinguishable. 22 I would like as an initial matter just to read into l 1 23 the record these cites. The first is at 5 NRC 1197. It's the j 1 1 24 Tyrone Energy Park construction permit case of 1977. The 1 l 25 relevant -- in fact, Judge Smith, you were chairman of that l O l Heritage Reporting Corporation (202) 628-4888 i l l

5551 m (_) I board as well. The relevant portion of the opinion concerning. 2 dose consequence evidence is set forth on Pages 1223 and 1224. 3 JUDGE SMITH: Mr. Traficonte,-would you concede at 4 that time, however, that the board was' addressing the siting 5 standards? 6 MR. TRAFICONTE: Yes. If you would allow me to 4 7 simply -- there are only two other cases. j l 8 JUDGE SMITH: I'm sorry. I 1 9 MR. TRAFICONTE: And, obviously, I'm going to make an j 10 effort to show how they are analogous. l 11 JUDGE SMITH: All right, l l 12 MR. TRAFICONTE: We don't contend they are ) 13 controlling, but I want to present to theLPanel.the argument O) k-14 that they are, in fact, very. analogous although obviously 15 involved at a different stage in the proceeding. 16 The second case I would'like to cite this morning is 17 at 8 NRC 9, and it is an Appeal Board discussion, and the 18 discussion of dose consequence evidence is set forth on Pages l 19 15 and 16, and that is a Three Mile Island, Unit 2 operating 20 license proceeding. 21 And the final case is the Wolf Creek case at 22 5 NRC 301, and the discussion of radiological dose consequence 23 evidence is set forth at Pages 369 and 370. That is a 24 licensing board decision, and again involving construction 25 permit. (G Heritage Reporting Corporation (202) 628-4888 l

' m; .o 7 15552 h 'l .And, please, let's'be. clear with one another. -We'

• 2 don't-believe these are directly. analogous.. Strike that..We 3

don't believe these are~directly-controlling cases.-. We believe j r 4 -- they are analogous. 5 These cases involved the siting requirement'which'is-6 still good law, still a. regulatory requirement. In the event-7. that someone had it into his mind to attempt to. license a 8 nuclear reactor today, they.would have to meet this standar'. d ( 9 I want to be brief on this point, butLI want the: Board toL 10 understand why we think these cases are analogous. 11 Under the siting requirements, there are.. clear, l l 12 objective dose requirements for the determination of.~theJLPZ 13 boundary, the distance away_from the plant of that, boundary, O 14 and the relationship between that' LPZ' bouridary and 'the il 15 exclusion area as well as the. relationship between the LPZ i l 16 boundary and the nearest' population-center. 17 These regulations'a -- they are not the easiest- 'i 18 thing to read, but they are set l,forth.in:Part'100 of the l 4 19 regulations. q 20 However, not only must an applicant both at,the-21 construction -- and I'm now talking before, obviously, the 22 emergency planning regulations were adopted. During the 1970s, 23 not only was an applicant required to meet those expressed 24 objective dose calculations for purposes of drawing the-25 boundary of the LPZ, but licensing boards had another issue O i Heritage Reporting Corporation (202) 628-4888

1 ] 5553

V~

f 1 that it had to determine. It had to determine both at the 2 construction permit stage, as well as the operating ~ license 3 stage, that there were adequate emergency plans in existence. ) ) 4 At the construction stage they had to be -- they didn't have to 5 be overly detailed. They had to be presented in some detail, 6 but at the operating license stage there had to be'a 7 determination as there in the Tyrone Energy Park case. There 8 had to be a determination by the licensing board that the' area I 1 9 within the LPZ could be adequately -- strike that. That the 10 evacuation plan for the area inside the LPZ provided a level of ] 11 adequate protection. l 12 JUDGE SMITH: Well, wasn't that indeed the case right 13 here in this proceeding, too? I mean, 14 MR. TRAFICONTE: It seems that the standard -- we 15 believe that the standard is in fact the~same. 16 JUDGE SMITH: No, I mean wasn't that an issue and -- l 17 MR. TRAFICONTE: Yes, the same issue had tx) be 18 crossed. That's correct, Your Honor. 19 JUDGE SMITH: Here, at Seabrook. ~ i 20 MR. TRAFICONTE: No question, no question. 1 21 And, again, because this is an important point, nor 22 are we now attempting to litigate with our evidence the siting 23 decision. We are not trying to argue that the siting decision 24 that was made in this case -- I might want to retract that 25 slightly. We might believe that that siting decision was wrong O \\_) Heritage Reporting Corporation (202) 628-4888 I

5554 () 1 in a more global sense. We're not here arguing that the siting 2 decision that was made under the then prevailing regulations 3 was wrong. That's not our point. 4 It is legally analogous, because in every case boards face the problem of what is the adequacy of the evacuation 5 1 6 plans proffered by the applicant for the area.inside.the LPZ. 7 Some cases that involved thousands of people. One of the cases 8 I cited involves 15 to 18 thousand people. 9 Boards had to determine, is the level of protection 10 afforded by the plan adequate. Same issue in an analogous 11 stage of licensing. 12 What did those boards do? They took evidence of the 13 radiological dose consequences that was often proffered by the ( 14 board -- strike that -- by the staff, and offered proffered by 15 the applicant, and sometimes proffered by the applicant ut the 16 insistence of the staff. 17 JUDGE SMITH: But aren't the radiological dose 18 consequences an essential part of the Part 100 regulation? And 19 they are required -- 20 MR. TRAFICONTE: They are not. And here is the crux 21 of tho matter, and I think perhaps the reason why our argument 22 that there is analogous case law out there has not resonated in 23 a way that I think it should. 24 There is a difference between the objective dose 25 requirement that's set forth in those regulations for the O Heritage Reporting Corporation (202) 628-4888

5555 /'" (_)% 1 boundary of the LPZ, and I can pick up the regulation if I need 2 there. There is clearly objective standards set forth. l 3 If the Panel would review these cases that I have 1 4 mentioned, it is equally clear that that standard, that dose 5 standard which set the boundary of the LPZ was not going to be 6 the standard applied to the determination of the adequacy of l 7 the protection afforded the population within the LPZ. There 8 is two completely different issues. 1 1 9 JUDGE SMITH: All right. J 10 MR. TRAFICONTE: On the issue of what standard to 11 apply to the people within the'LPZ, the cases I have cited are 12 quite clear that it's not -- it's simply, to be blunt, that the 13 standard for which you draw the boundary is way too high. That r~T (_) 14 can't function as the test for adequacy of the plan for the 15 people within the LPZ. They didn't express it in an objective, 16 there was no objective standard. The cases are clear on that 1 17 point, too. Panels struggled with that question -- what was an 18 adequate evacuation plan. 19 Sut our point is this. In struggling with the 20 question as to what was an adequate level of protection for the 21 population within the LPZ, and again that standard was 22 expressed in the same language that we are now litigating, 23 those licensing boards took radiological dose consequence 24 evidence offered often by the staff of the NRC, and offered by 25 the applicant at the behest of the staff on one occasion, and (~) v Heritage Reporting Corporation (202) 628-4888

5556 m() 1 spontaneously in another. 2 Now it's quite clear to me why the app 1'icant in those 3 cases was offering that evidence. Because the plan, the dose 4 consequence study revealed that evacuation of the relevant ) 1 5 population was adequate. The people would get out in time. J 1 6 The consequences would not be great. l 7 The Applicant in our case today here in'Seabrook is 1 8 not about to offer that evidence. And again, that's not 9 surprising. But to go to.the point of arguing that that kind 10 of evidence is not admissible is simply to ignore the record of 11 licensing proceedings at the siting stage, and we think by 1 12 analogy, to the operating license stage after the adoption of i 13 the emergency _ planning regulation. /~'s 4 i/ 14 In conclusion, I just want to say this. I believe i 15 the Board should be very circumspect on this point as its 16 willingness to hear extended argument for which I apologize. 17 It's quite clear it's willing to be circumspect and careful. 18 One of the concerns we have goes back to my initial 19 point about the appearance here of the proceeding, and what the 20 issue that this Board has to address involves. We believe that j i l 21 this Board should not allow itself to be put into the situation i 22 of having found or not found that the plan at issue provides an 23 adequate level of protection, but at the same having stricken i 24 from the record and refused to admit evidence of what the 1 25 actual level of protection is. We think that's an untenable (3 %) Heritage Reporting Corporation (202) 628-4888 1 I l

1 j 5557 () 1 situation. We don't think it's necessary. We don't think 2 it's -- we believe no case controls that determination. We 3 don't believe that you have to find that. 4 But more importantly, we believe that to find that ) 5 would be a serious error both of law, in light of the existing l l 6 precedent and you task, as well as a serious error in terms of 7 the acceptance by the public of the determination that you are l 8 attempting to make. 9 Thank you very.much for the time. I appreciate that. 10 If the panel would like I could present the three l k 11 cases. I don't know if you have access to them. 12 JUDGE SMITH: No, no, that's fine. We won't take 13 time now for that, because we are generally familiar with them. l'_) s/ 14 We will go -- we will read them. 15 I will listen to you further if you wish to comment 16 specifically -- 17 MR. TRAFICONTE: If the Panel would like to address l l 18 specific questions, that would be fine. I have nothing further. 19 except to respond to questions. l l 20 JUDGE SMITH: Of course, you recognize the Panel will 21 be guided by -- a very large extent by what we think that the 22 Commission had to say on this issue in the Shoreham decision l 23 which they reiterated in the new emergency planning rule, and-24 also the -- well, to a lesser extent in San Onofre when they 25 were talking about contaminated injured persons and, treatment (q) Heritage Reporting Corporation (202)'628-4888

I 5558 "t 'l for them. 2 And if you'-- we are going to read those. Those are-3 important. If you'want to' talk"about~them,' well, I know you 4 must know that we know that;they are important cases. 1 5 MR. TRAFICONTEs. Of course ~,~I'dd. 6 JUDGE SMITH: Yeah. 7 MR. TRAFICONTEs~ If the_ panel would indulge me, let 8 me comment on those cases, as well.as comment again on the ~ 9 proposed -- not the proposed -- the new rule as, adopted this 10 week, and the language used.in that discussion. ? 11 I believe'there is a difference between requiring an 12 applicant to produce the kind of evidence, or the kind of. 13 testimony that we have proffered for purposes of passing a 14 Commission-enunciated standard, or test of adequacy.~ l 15 It is quite clear that is not where we stand as a 16 matter of regulatory law. The applicant ~need.not do what the 1 17 Mass. AG's office has done. .It need not go out and hire 18 somebody to do what we have done. ] 19 It is equally clear the Commission hasn't announced, 20 and here is the standard against which that' objective evidence 21 is to be measured. You must have no fewer than these people at i 22 no greater than this risk. That's also equally clear that's 23 not been required. ( 24 And I think the San ~0nofre case as well as the 25 discussion by the Commission this week makes it quite clear Heritage Reporting Corporation (202) 628-4888 q l i .) - -I

5559 () 1 that that's not been a requirement of an applicant. But what 2 has been the requirement -- so we think that those cases are, 3 as far as they go, obviously quite.-- we don't disagree with 4 them as far as they go, but how far will they go? 5 It seems to me the Applicant wants to take them to 6 the point that this Board will rule irrelevant the proffer of j 7 evidence, or the evidence proffered by an Intervenor as to the 1 8 actual level of protection afforded by a plan. That, to me, is i 9 apples and oranges not to -- sir, i i 10 JUDGE SMITH: No, I wasn't -- I thought you had ] l 11 concluded. I was sort of agreeing with you there that you have j l 12 identified the issue and I -- go ahead, I'm sorry. 13 MR. TRAFICONTE: Well, it's a question of 14 perspective. I don't disagree the Applicant is not under the 15 burden of doing this. He's not. 16 JUDGE SMITH: Yes, but you're talking about -- 17 MR. TRAFICONTE: That's a different issue. 18 JUDGE SMITH: -- ordinary relevancy. i 19 MR. TRAFICONTE: Ordinary relevance, absolutely. 1 20 JUDGE SMITH: And if I were to summarize your point, 21 would this be fair, in that you can't really give a good look 22 at what is a reasonable effort toward dose savings unless you 23 know in advance what those dose consequences are expected to l 24 be. 25 MR. TRAFICONTE: I don't believe that you can give a O V Heritage Reporting Corporation (202) 628-4888

x -. 5560 1 reasonable look. 2 Furthermore, Idon'tknowofanhexclusionaryrule. 3 JUDGE SMITH: Well,'right'. 4 MR. TRAFICONTE: In fact, that's-what we are dealing 5 with. 6 JUDGE SMITH - There isna point'of evidence, we could 7 go down that direction, but again, we always have to come back. 8 and to what are we going to do'with the evidence in which --'in 9 the event it's received. And.in your. view, the relevance is 10 that we cannot make -- and.this isn't your only point, and I-11 don't exactly -- you can disagree with me..You don't even have 12 to agree with me, but this is the way I come away from your 13 argument. ( 14 That we cannot make an informed judgment as to the 15 effectiveness, or the reasonableness of the New Hampshire I l 16 radiological plan with respect to reasonable dose savings, dose l 17 avoidance, unless we have a better idea of what-the dose 18 consequences are expected to be. 19 MR. TRAFICONTE: I would agree, and state.it, if I 20 may, another way, which is I don't believe that it woulo make 21 sense, regulatory sense and legal sense for you to make a 22 finding, affirmatively make a finding that the plan is 23 adequate, it adequately protects.the population at. risk, after 24 you have stricken evidence of what the actual level of 25 protection is. That's another way~of putting it. O Heritage Reporting-Corporation .(202) 628-4888 ____m._..__.___.m___._._m.- m

5561 i ([) 1 JUDGE SMITH: All right, that's exactly it. That 2 is -- you have identified the very issue that is going to be 3 driving this case. l 4 MR. TRAFICONTEs. We don't believe the Commission has ] 5 ruled -- we don't believe you are bound by any precedent, let 6 me put it that way. 7 JUDGE SMITH: Okay. All right, we will find that 8 out, and right now is when you can just exactly talk to what 9 the Commission has said on it, and we point you in particular l I 10 to what they said in Shoreham, not only the points cited by Mr. 11 Dignan in his brief, but to back up. This member of the Board 12 wasn't involved in emergency planning for quite a few years. 13 And when I come back to it in this case, I had a very, very. ( 14 difficult time trying to understand just what is the 15 philosophy, and what is expected, and where are we going. 16 And I heard all the arguments about, well, you don't l 17 have to have any particular dose savings achieved by evacuation 18 plans, or in sheltering, nor in any of the other protective 1 19 actions which might be taken. Nevertheless, we are required to i I 20 find whether a plan is adequate. l 1 21 So is that a third standard, you know? And 22 apparently the Commission has spoken to that in Shoreham. 23 MR. TRAFICONTE: Well, to the extent that Shoreham 24 deals with a situation in which the state is not a participant. 25 JUDGE SMITH: Okay, right. O Heritage Reporting Corporation (202) 628-4888

5562 [~D 1 MR. TRAFICONTE: I think that would be grounds to %) 2 distinguish the treatment of that kind of evidence in Shoreham, 3 although, Your Honor, -- j 4 JUDGE SMITH: I want to -- 5 MR. TRAFICONTE: -- I don't think there is a holding 6 in Shoreham, and correct me if I'm wrong, but I know of no i 7 holding by a board or a higher authority that the kind of 8 evidence proffered here is not admissible evidence. 9 JUDGE SMITH: Right, but I just want to point you 10 right -- I understand that. j 11 MR. TRAFICONTE: Yeah. 12 JUDGE SMITH: But I want to point to you'the language 13 that the Board will be focusing on. I mean, and so that you (3 s_/ 14 know, you know, just what we think is important in Shoreham. 15 And it begins on the -- the citation as given throughout this 16 hearing, and it is very well known to everybody, it's I l 17 24 NRC 22 is the case, and the discussion begins on page 29. 18 And the Commission says at the bottom of that page, "The root 19 question becomes whether the Long Island LILCO plan can provide 20 for ' adequate protective measures' in the event of-a 21 radiological emergency." 22 Then it goes on to say, "This root question," on Page 23 30. "This root question cannot be answered without some 24 discussion of what is meant by ' adequate protective measures.'" 25 And the rest of it, it was cited in Mr. Dignan's brief and is Ab Heritage Reporting Corporation (202) 628-4888

5563 [] 1 well known. But there, it seems to me, the Commission has 2 taken that very phrase.and provided what they regard a meaning. i 3 I just want you to know that that is.the Supreme Court of the 4 NRC speaking here as far as law is concerned. That is very, 5 very important law to us, and we are focusing.on that. ( 6 MR. TRAFICONTE: To belabor this, because I think at 7 this point it would be belaboring it, but I think given your 8 indication of the significance of this language, let me respond 9 to the portion of it. I don't have the entire opinion in front 10 o f me, but I have Mr. Dignan's brief, and I think it picks up 11 from quoting that same opinion right after the point that you l 12 stopped reading. 13 JUDGE SMITH: Right after that. 14 MR. TRAFICONTE: Yes. 24 NRC 22 at 30. The portion 15 in the motion of the Applicant reads, "Our emergency planning 16 requirements do not require that an adequate plan achieve a 17 preset minimum radiation dose saving." 18 No dispute. We don't have a dispute with that. We l 19 believe it does not preset a minimum dose saving. We believe 20 the standard, however, does require a finding of adequate 1 21 protection. And another way that's been often expressed is 22 that there be reasonable dose saving. There is an affirmative 23 requirement here. 24 This is a negative way of stating something. There 25 is also an affirmative way of stating the same point. There is f% V Heritage Reporting Corporation (202) 628-4888

.. t l; ; 5564 () 1 no preset objective standard. That's not the same as saying 2 chat evidence of what the. level of protection is simply not 3 relevant. That's the baby'with,the bathwater. 4 JUDGE SMITH: Right. 5 MR. TRAFICONTE: Thank you. 6 JUDGE SMITH: Mr.'Dignan. 7 MR. DIGNAN: -Yes,- Your. Honor., I will be brief. I 8 wish to address only what I consider to beLnew points'that were 9 brought out in this oral argument. 10 Perhaps the difference between our reading of the 11 regulations and the Commonwealth's was best illustrated with 12 the learned counsel's opening remarks. He talked about 13 adequate level of protection. 'And the regulation doesn't say ( 14 that. The regulation phrase is " adequate protective measures". 15 Ar.d when you go into the Commission authorities that we have 16 cited, I think the Commission has made patently clear what the 17 standard is. 18 And I think Mr. Flynn articulated it well when he 19 indicated to you the full thrust of the FEMA position. And 20 that is that what the Board is to judge-is have all the 21 efforts, and I'm going to go a little -- just let me use the 22 superlatives. Has every effort been made by the Applicant 1to 23 minimize the dose savings that -- excuse me -- to maximize the 24 dose savings in any given event. It may well be that the j 25 event, as the Commission as indicated, could be totally O Heritage Reporting Corporation (202) 628-4888

l 5565 i \\ (,-) 1 catastrophic and you still have a great deal of potential 2 injury. But has the Applicant put a plan together that l 3 whatever the event may be, this will do the best job that'the I 4 human beings can do, even'though it may mean that all they can 1 j 5 do is save a certain number of people, or save a certain amount 6 of dose rather than all of it. I 1 7 And there is the difference. The Commonwealth -- l 8 every time I have heard them argue this position in any forum 9 keep reading that regulation as saying " adequate level of 10 protection", and it doesn't say it. 11 The only other point I wish to make is this business 12 of arguing that dose savings -- excuse me -- evidence of doses 13 came in before. Conceded. It comes in in every single 14 construction permit case. And if a plant came for one, it wauld 15 come in again. It comes in because of the siting regulations 16 which still require that design basis accidents be analyzed to I J l 17 set the low population zone, the population center distance and- ].i 18 the exclusion area. l k i i 19 The manual, I believe, I reach back, TID-1484 is 20 still the bible on that. Every application has had it. 21 Whether it gets discussed in the hearing or not is whether or i 1 22 not somebody has made a contention as to whether one of the 23 zones or the population distance, center distance has been 24 properly set. 25 The only reason that that ever got mixed up at all l l O v l Heritage Reporting Corporation (202) 628-4888 l

y ~5566-I with emergency planning was this,..and I'ask the Board to think, 2 Lback a little history.- At the time Seabrook was in'the 1 3- -construction permit stage two cases came out of the New England l 4 area to the Appeal Board.~1OnejwasntheiSeabrook caseion~appealt j -5 from the initial decision grantilig the construction permit. i 6 Another one that? camel outi ~was[the New; Englandf Power reactors j 7 'that were then slated to go'into Charleston,'Rhode. Island. 8 In that case, a contention'had been let'in that-would have 9 allowed evidence of this: nature.. In the Seabrook case, the 10 licensing board had ruled as a matter of law that emergency i 11 planning, if you will, stop at the low. population. zone boundary-12 insofar as what-they call dynamic'-- what we call dynamic l 13 protection is concerned. That is to say, evacuation or-14 shelter. 15 The issue came up.to a Joint Appeal Board. It was 16 argued before five Appeal Board members, and they ruled.in that 17 case, that joint case, that there was an, unbroken line of 18 authority going back to the beginning -- to the AEC times that 19 the siting criteria insofar as-they mentioned in 100.3 that.the q 20 low population zone had to be an area'were effective measures 21 could be taken. 22 It had made it clear that dynamic protection, such as 23 evacuation or sheltering, and demonstration of its stop at the 1 24 low population zone boundary, and that was the old rule. And 25 -it became -- the only reason that dose evidence.ever got talked .O Heritage Reporting Corporation (202) 628-4888 1

1 l 5567 1 -about in that context was it came up.through those cases in 2 which that ruling was made. 3 And-in those days, one of the -- and still you can 4 under the siting. criteria, you can pull the LPZ in, or the 1 5 restricted area.in, or the population center distance in by the 6 use of engineering. safeguards. And that was historically the q l 7 way it was done. And, indeed, one,could make.an argument that 8 it was an extremely rational regulation from the point'of view j 9 of public protection, because if.one believes, and some do, and-10 this is a philosophical argument which is relevant'here, butiif' 11 one' believes that the better way to protect is with. hardware 12 than the vicissitudes of evacuation, the utility was encouraged i 13 to put more engineered safeguards in the plants, and thus f 14 shrink the zone in which it had to demonstrate an ability to: 1 15 evacuate or shelter. j 16 And, indeed, Seabrook in particular, I remind the~ 17 Board, was designed as a so-called double cont'ainment reactor 1 18 for precisely that purpose. That second containment had'the i 19 effect of pulling the LPZ in very tight. The final setting of l 20 it was I think at -- I may be wrong, but I think it'was at 1.25 21 or 1.15, I don't remember, 22 So that's just -- 23 JUDGE SMITH: You take no credit for that fact, 24 however, in the emergency planning regulations. 25 MR. DIGNAN: We cannot -- we cannot under the-new Heritage Reporting Corporation (202) 628-4888

8 5568 1 regulation. And that,in--- all.I amigetting at.is'when the' 2-Commission after TMI changed the regulation, the question'of. 3 doses went right out the window, because what they.said is you1 4-had to plan ~for this 10-mile area. But they never'said in. ~ l 5 addition'to that, that you get into doses.y They say,-we're l ~ j r 6 going to assume there is big doses out there in one of.these- ] What you havelgot.to(demonstrat'e[to..us is you h' ave E 7 events. 8 done everything, and everything is,too strong a word maybe,tbut 9 you-have done essentially"everything human-beings can do to 10 minimize what's going toffollow from that; kind of.an event,'and 11 that's why the word " spectrum of-accidents"t is infthe planning: 12 -document. 'And I submit that's what the regulation mean. 13 And the standard that any plan is judged against is 14 just that. And if a given site results in a given, accident 15 producing more injury than'another given site results-in-with' 16 the same accident, that is of no moment, and that has been 17 painted absolutely clear in the recent issuance of the rule 18 where they -- in discussing what. standard.the utility plans 19 would be judged against, the Commission made it clear.we're'not 20 going to judge one plant against another..And again in so 21 stating, they are saying we're not going to. judge one site 22 against another. 23 The siting regulations are a. separate item.now.. They 24 no longer deal with the question of emergency planning. And-25 with that foll.the relevance of any dose evidence of the nature 1 LO Heritage Reporting Corporation (202) 628-4888 w__- _ -

5569 (v~l 1 that the Commonwealth is trying to offer. 2 That completes my argument. l l 3 MR. TRAFICONTE: Could I briefly respond? i 4 JUDGE SMITH: Yes, Just a moment. 5 MR. TRAFICONTE: I'm sorry. 6 JUDGE SMITH - I.want to askfMr. Dignan a question. l 7 This argument about.the relevance seems to have come ) 8 up in the context, and under the' assumption that.there is no l 9 sheltering as a part of the plan. 'And I'm not real familiar 10 with the history of that issue. Although my colleagues have 11 brought me up to date on it, I'm just not' familiar. 1 12 But if it were your: position that sheltering simply I 13 is not needed, would you agree that their testimony was (_/ 14 relevant? 15 MR. DIGNAN: No, I would not. I 16 JUDGE SMITH: It would seem to me that it would be I i 17 relevant. j l 18 MR. DIGNAN: No, I think not, Your Honor. I think, I 19 think if the position was -- if I could trace that out, and 20 call you back to the argument we had concerning the FEMA 21 testimony, and I thought your colloquy with Mr. Flynn was quite 22 revealing. If the -- i 23 JUDGE SMITH: What I'm saying is -- what I'm saying 24 is let's say that -- I'm not suggesting that there is any j l 25 quantitative standard that has to be achieved by sheltering. f')h \\ \\_ Heritage Reporting Corporation (202) 628-4888

~~ .t T 5570. 1 () 1 But if you'were.to takelthe position that:apparently-wasitossed 2 around the RAC or something that, you know,~1n this0 area we 3 just~ don't have to bother with sheltering. ' Evacuation 1 times 4 are fast and low probabilities'and.everythingflik'e that'. ) ,1 5 Would you.then agree'that there?- you_would not-6 even -- r 7 MR. DIGNAN: No,.no,.Your Honor, because the evidence 8 'that would become relevant"atithat' point *is?the~ evidence - : 's a3 y 9 that portion of the Commonweal $h'sl evidence tb_which we have 10 ' raised no' objection, thersheltering --<th'e~so-callsd.shel,tering w 11 evidence, other.than Sholly. 12 What becomes: relevant as Mr.sFlynn indicated at that 13 point is this. If it were:the' Applicants' position'that under. ' l ( 14 no circumstances would sheltering be a chosen.protectivej 15 measure, and the plan'has' stated that it's:a-doubtfu1 Lone onla' 4 l 16 summer day on the beach. But on the.other hand, fin'certain 17 accidents it still could be the choice there. l 18 But if the Applicants' position and.that of the State 19 were that sheltering is never an. alternative at SeabrSok an'd'we-20 are not going to plan for it, the. relevant evidence would'then-i 21 be for somebody to come in and say, now, look, you have got 22 this building, this building,.this building and this building 23 that should be used, and'you people should have afprocedureLto 24 use that, because there may_be an accidentiwhere that would 25 maximize the dose savings. And you'are ignoring that, you-ire O Heritage Reporting Corporation-l (202) 628-4888 i

m-3 5571 (~1 1 ignoring sheltering means that your plan does not contain w). 2 adequate -- 3 JUDGE SMITH:L Yes. 4 MR. DIGNAN: -- protective measures. That is a much 5 different piece of evidence than the Sholly panel'-- 6 JUDGE SMITH: I would agree with that but -- 7 MR. DIGNAN: And that's why I say even if-that were-8 the position of the Applicant. 9 JUDGE SMITH: But my hypothetical was,'and you have j i 10 disabused it, but my hypothetical was, hey, it's true we've got 11 a lot of neat sheltering buildings there, but we are just ) i 12 simply not going to bother because they are not needed. And I 13 then that would be a different, entirely different matter. But j ('^/') ) 14 that's not your position, so that's just a -- 15 MR. DIGNAN: That is not my position, but I could see I 16 the thrust of your -- but I guess even then if the hypothetical j t 17 is would you still object to the evidence, the answer is yes, j ) 18 because I think the evidence that would meet that would be 19 evidence that says, come on, you can do it and it would help. l ? 20 That's the kind of evidence that's relevant under these l l 21 regulations. Not evidence that says on accident one you've got t 22 this kind of death and destruction. l 23 JUDGE SMITH: Sir, that would be your choice of the 24 evidence that would be used to meet it. But, okay, that's 25 fine. /^T i \\-) i Heritage Reporting Corporation (202) 628-4888 f 4

~5572. (]) 1 MR. DIGNAN: Well', I'think that's the only thing that. '2 would be relevant to meet it, Your Honor. I am not'just-3 choosing..My point simply 11s.that as I read the Commission 4 ' decisions and putlthem together.with the.words of thet 5 regulation, the fact of the matter ishit is not relevant 1to get 6 into what is in fact going to or not-going to happen in.certain; 7 accidents.. You can "what if" any nuclear poweriplant.to' death. J: ' 8 JUDGE SMITH: Right. j l 9 MR. DIGNAN: IAn[ had the"C$mmiss'ibn' allowed that,- 10 then this would be rel'evant. -l 11 JUDGE SMITH: I understand.' 12 MR. DIGNAN: But the Commission-does not. 13 JUDGE SMITH: I postulated'a position that.Iiguess. 14 you have not taken. 15 MR. DIGNAN: That's correct. 16 JUDGE SMITH: And so there is no.use pursuing'it, EndT71-17 because it doesn't throw any light. T72 18 Mr. Flynn. 19 MR.-FLYNN: May I be heard for just one moment? 20 As you know, FEMA has not taken a position on:this 3 21 motion, and I certainly don't want to jump into the middle of. 22 this debate. But I am just a bit uncomfortable having Mr. 23 Dignan act as spokesman for FEMA. 24 I just want to point out that the colloquy to-which' 25 he referred appears on Pages 5153 and 5154 of the transcript O Heritage Reporting Corporation (202) 628-4888 ~ __________._____i____._____________.___-_-___._____.____.__-______._________.__. .___m

~p 5573~ 1 from' November ~4i.and we will standIby.what we said, but.we' 2' don't want it enlarged either'. 3' JUDGE SMITH: Now Mr. Traficonte. 4 MR. TRAFICONTE:- 'I'm going to be very;brief. 5 MR. TURK: Could I -- 6 MR. TRAFICONTE: Oh,.I'm sorry. 7 MR. TURK:- -- just'for sake of orderliness. \\ n _,.sr, 8 JUDGE SMITH, 'All right.- l 9 'MR. TURK: .I will want to respond.to Mr. Traficonte's- [ ~ ii. j i 10 oral presentation somewhati > But I.. leav.e.it ato'you.to tell: me ? 11' whether I may at ali, and~whether tl[is is the time'or.-after.'he. 12 speaks. 13 JUDGE SMITH: 'Well, let him complete'his arguments.. .14 Then you can respond all at once. 15 MR. TURK '.Thank you. 16 MR. TRAFICONTE: Thank you,' Your. Honor. 17 Just very quickly on several: points.Mr. DignanLhas 3 18 made. I'll return the compliment, learned counsel for the 19 Applicant. However, learned counsel for the Applicant,'in-20 citing.those siting cases, is simply not correct. And I'll. 21 leave it to the Panel's reading of those ca'ses to determine j j 22 that the radiological dose evidence that I'make ' reference-to,- I L d 23 those' relevant pages in the transcript, are not--evidence for 24 purposes of drawing the LPZ boundary. Far from it.- 25 That was evidence submitted on the sole issue as to- ~ ..\\ O i Heritage' Reporting Corporation (202).628-4888 l 1 9

5574 () 1 whether the evacuation plans for the LPZ were or were not 2 adequate, and that judgment was made by taking evidence of the 3 radiological dose consequences. And if the panel.would -- and j 4 when it reviews those cases that distinction.will become quite. 5 clear, I'm sure. 6 Second point, and again I would' add this in thinking 7 it through, I think this is another ground for distinguishing 8 our case from the Shoreham case. Notionly do we not have an 9 absent state here, at least on the.New Hampshire side of the 1 10 border. But in addition, we have, and I'm really' reinforcing 11 my point, we have~no range of protective measures in the plan. 12 We have a reliance on evacuation essentially alone. So that I 13 think that's a ground for distinguishing the Shoreham 14 discussion on what you must do or what you must not do.from our 15 present case. 16 Finally, I want to be fair, but I think to state this 17 argument is to refute it, Mr. Dignan's crabbed reading of this 18 standard. I don't believe there is much dispute about that. 19 If Your Honors want to make a finding in this case and say, 20 well, we don't have to find adequate protection. We only have 21 to find adequate protective measures. And that's a big 22 difference. 23 If we have to find adequate protection, well, then we 24 would actually have to make sure the public is safe. But if 25 all we have to find adequate protective measures, well, that's (G x_J Heritage Reporting Corporation (202) 628-4888

--,1 l ~ ' ),- 4 ..i.. .5575. 1 a' completely different fish-that.we have torfry. 2 ~I think to say.that really is.to refute-it. I. don't' 3 believe that's a -- that's not;a meaningful-distinction in the 4 regulation. I don't believe the case law supports that 5 proposition. 6 That'.s really all I have. 7 JUDGE SMITH: Mr. Turk. { 8 MR. TURK: Thank you,,Your Honor. I'll try.'notyto ~ 9 bring us too much further;out in time.. I do want...to; respond to 10 a few comments made,by Mr..Traficante. .s s 11 First,1he has aniargument that the1 doses that;could: l 12 result in a severe accident are relevant, and'it's relevant ~for 1 l 13 you to consider them. H a 14 Well, the question of[ relevance always hastto be 15 governed by the question relevant.to what..And under the 16 Federal Rules of Evidence, Rule 401, the definition of relevant-17 evidence reads. " Relevant evidence means evidence having any-18 tendency to make the existence of'any fact that is of. 19 consequence to the determination of the action-more probable _or 20 less probable than it would be without the evidence." 21 The question in this proceeding is has the utility, i 22 through its proffering of the New Hampshire RERP,icomplie'd with 23 NRC regulations. The.only way that the Beyea - Sholly. 24 testimony would be admissible as relevant is if it.tends to 25 make it more probable or less probable that Commission O Heritage Reporting Corporation (202) 628-4888-i o

y

y

., g 4

5576 () 1 regulations are being complied with. 2 Now, then.the question is again,.whatEdo the-l 3 regulations require. And I.think the mostLclear statement in 4 this regard came out just-Llast weekLwhen'the; Commission ~ 5 promulgate'd its final rule dealing with situations where state' j 6 and local governments are'not'participatingLin theLplanning; 7 process. And earlier when I-distributed this rule'on. Monday,t I' 8 indicated I would be. citing Page 27, and I'd like to turn to 9 that. 10 'The Commission in this stEtement'of consideration, 11 reexamined its decision in Shoreham,JCLI'86-13..And in the b 1 12 bottom paragraph'-on;Page'27of the statement 'of" consideration, H 13 in discussing that decision'it -.it discusses the potential-1 c ( 14 reading of its shoreham' decision as. saying1that the: NRC must .i 1 15 estimate radiological-dose reductions which would be achieved l 16 by the utility plan, and then. compare them'to the dose' s 17 reductions which might be achieved under a governmental plan. 18 And then further, that reading would say; that you - 1 19 could only have issuance of an operating license if the dose. 20 reductions are generally comparable. 'Now that's the 21 background, and I would like to-read the following language 22 from the Commission's statement. 23 "Such an interpretation would be contrary to'NRC 24 practice under which emergency plans are evaluated for. adequacy 25 without reference to numerical dose reductions which might be () Heritage Reporting' Corporation (202) 628-4888 1

5577 (')T 1 accomplished, and without comparing 'tluun to other emergency s 2 plans, real or hypothetical. The final rule makes it clear 3 that every," and let me underline that word, "every emergency 4 plan is to be evaluated for adequacy on its own merits without 5 reference to the specific dose reductions which.might be 6 accomplished under the plan or to the capabilities of any other 7 plan." 8 Well, it goes on but for my purposes I don't think 9 the -- well, let me complete the paragraph. "It further makes 10 clear that a finding of adequacy for any plan is to be 11 considered generally comparable to a finding of. adequacy for 12 any other plan." 13 Now the Commission was very clear in this statement ("3 \\ 14 as well as in prior case law. There is simply no standard for 15 this Board to evaluate in terms of the adequacy of dose 16 reductions which would bear upon whether or not the utility is 17 complying with NRC regulations. 18 The emergency planning rules take knowledge of;the 19 fact that a severe accident can happen, and that there can be 20 severe dose consequences. And for that purpose this overlayer. i 21 of protection, this need for planning in the areas outside of 22 the plant was developed. So that if you do have a severe 23 accident with potentially severe consequences, the public can 24 be protected rather than simply letting them stay in place, or 25 letting chaos and confusion reign in the absence of planning. Heritage Reporting Corporation (202) 628-4888

5578 l( ) 1 Now if Massachusetts' testimony should come in as i 2 dose consequences, it's quite likely that the Applicants and 3 the Staff would feel a need to bring in similar testimony, and 4 we may be litigating the consequences of enumerable accidents. 5 Aside from the fact that it's irrelevant and it's not I 6 contemplated -- l 7 JUDGE SMITH: If we were to find that it's. relevant, l l 8 we would do that, provide for that. 9 MR. TURK: I understand that, but my point is not 10 only is it not relevant to the decision you must make, but it's l l 11 going to lead to the introduction of lots more irrelevant 12 testimony, none of which'is going to"get us'anywhere because i 13 it's not what the. emergency planning regulations require. ( 14 Now the Massachusetts-Attorney General's office also 15 made the point that they would have this Board determine what 16 the appropriate standard is as to whether too many people here 17 are being put to too great a risk. And I-submit to you that's 18 not the function of an adjudicatory body. That's the function 19 of rulemaking, and it's within the province of the Commission. 20 If the Commission should decide that they do wish to promulgate j 21 a rule as to how many people may be exposed to how great a 22 risk, that's something they would do through the general 23 provisions of rulemaking, through notice and comment. And that 24 type of a rule would apply to all plants, not just to Seabrook. 25 the Massachusetts Attorney General's suggestion would Heritage Reporting Corporation (202) 628-4888

R u 5579 4, () 1 invite.this Board to make'a rule in this case which is not j applicable to any other plant operating:in.the country.- r 2 3 JUDGE SMITH: Mr. Traficonte, I1senseg that you'would_ .A 4-like to respond. 5 MR. TURK: Well, if I may -- .s. 6 JUDGE SMITH: I'm sorry, I thought.you were --- 7 MR. TURK: -- two very brief points. 8 I have not reviewed the' cases cited today by Mr.' 9 Traficonte, but it's obvious to me that these cases'go;back'in. l 10 time. It's my impression, certainly for Tyrone~and Wolf Creek,. 11 that they precede the emergency planning; rules of 1980.- AndI j 12 would hazard a guess,that the,TMI case he cited similarly 13 predated the. current emergency planning riiles. .They. simply are 7-s .j 14 not applicable. 1 15 Now, finally, I~believe I heard.a statement in his ] i 16 presentation that went to the effect that Shoreham did not 17 involve a situation where dose testimony was being considered I l 18 by the Commission when it issued 86-13. And if I'm wrong,-I~ l 19 stand corrected and leave it at that. l 20 But I would point out if that is what I heard that 21 there was an attempt-in Shoreham to proffer testimony as to 22 doses, and it was testimony not by Beyea and.Sholly, but by 23 Radford and others. 24 JUDGE SMITH: But would-it be sufficient to say that 25 that's not what the Commission was talking about in their Heritage Reporting Corporation _ (202) 628-4888 l l ___m___.___._____________________________.m_______.___________._m_______.___.___.________.____._______._.__m__....______m______ _____.__e.___________.__

6 .5580- '( ) 1 discussion that was being' cited?- 2 .MR. TURK: 'They certainly did not-have this -- that testimony which I have=.just 'eferred to in front of.them.- 3 r

But I was going to make is-that that kind of< testimony.

4 the point c 5 was excluded in Shoreham as well. It's an~ unpublished 6 decision. It may not be proper for you to. rely upon it so 7 I 8 JUDGE SMITH:..You mean by'the Licensing Board there? i 9 MR. TURK: Yes. 10-JUDGE SMITH: Oh, okay.. 11 MR. TURK: That,'for reference,.is a decision dated 12 January 11, 1984 in th( 4oreham emergency planning proceed'ing. 13 OL-3. (<s 14 JUDGE SMITH: January 11, '84. l 15 MR. TURK: 1984'. 16 JUDGE SMITH: It's' unpublished?l. 17 MR. TURK: I believe it's unpublished. 18 JUDGE SMITH: Does it have an LBP. number on the top? 19 MR. TURK: No. 20 JUDGE SMITH: Okay, it's -- we probably -- we 21 wouldn't rely on it. 22 Mr. Traficonte. 23 MR. TRAFICONTE: Yes, just really a one-sentence' 24 response. 25 In a strange way, I don't disagree.with even perhaps O Heritage Reporting Corporation (202) 628-4888 1 l j 1

.i l 5581. .O 1 the er tex < ar r=rx 9 1 t thet we're aere ex1 9 the re#et 2 to make a determination that is applicable to this reactor.and q 3 this reactor alone. That's.not verbatim,.but that's-fairly 4 close. 1 5 That's true. We're asking the panelLto, apply the

)

6 adequate protection. standard to'this one reactor in this-1 l 7 instance by at least accepting evidence of what the actual j 8 level of protection afforded is. l 9 We don't think that's' incorrect.- We think'thattis' ~ 10 what the standard requires that you do.. 11 JUDGE SMITH: Okay. 12 MR. TRAFICONTE: Thank-you. i 13 JUDGE SMITH: Sure. Well, Mr. Traf' conte,.as you, recognized at.the outset i ~ 14 15 that you began with a situation where you were totally 16 convinced that you are right, and you.are facing what you 17 thought was held a contrary view. l 18 We had planned to rule following the. arguments.- We 19 are not going to. We will go back and read the transcript an'd-h 20 listen to the debate again,'and approach the issue _as fresh as i 21 we possibly can, with an open mind as we possibly can. In the 22 meantime, however, regardless of how it comes out I want to 23 commend you in particular for bringing the issue to us'in a q 24 responsible, well-reasoned way. I can't' imagine how it could l 25 have been presented any more effectively or forcefully, and you O. u Heritage Reporting Corporation' (202) 628-4888 =

5582 g-I have done the Board a substantial service in your. argument,,and' 2 we appreciate it. 3 MR. TRAFICONTE: Thank you, Your Honor. 4 JUDGE SMITH: Anything further today? 5 All right, we are adjourned. 6 (whereupon, at 1:00 p.m., the hearing was recessed, to resume at 1:00 p.m., Monday, November.'16, 1987.) EndT-67MB 8 3 ,s q,.,, 1 s 10 .g 11 x 3 e.1 l ,Q y 12 3-O f. ,'q, i t 6 13 . i 14 l, i 4 15 '5,' ) ( t l 1'6 i g a\\ h 1 v 1 \\s 9,'s Qs,, yl-17 4 1 ,S.,t y.,'.' 1Q f s 'i ~,g. s N'- s 19 _\\ s a l' i t 20 pp, y e 21 ,I t t, 3 ), 22 t T r^- 4 / J,s( { i 23 4 l a\\ 1 v.s, s 24 N ;(,,n j 25, s g ) { Heritage _ Reporting Corporation (202) 628-4888 ( i' .g ,h ! + 2) ,c <, , 1 N[ > i, 4 . p 't d,..'

n

).:

1 'l CERTIFICATE 2 . r. 3 This.is to certify that;the attached proceedings'before the '4 United States Nuclear Regul'atory-Commission in the matter of: 1 PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, q' 5 Name:- EVIDENTIARY HEARING- . et al.- (SEABROOK STA' ION, UNITS 1 AND 2) 6 T 7 Docket Number: 50-443-OL; 50-444-OL; OFFSITE EMERGENCY \\ PLANNING 8 Places. Concord,.New' Hampshire 9 Date: November 6, 1987~ l 10 were held as herein appears, and that this'is the original 11 transcript.thereof for.the. file of the United States Nuclear 12 Regulatory Commission taken stenographically by me'~and, 13 thereafter reduced to. typewriting by me or under'the direction. 14 of the. court reporting company,.and that the transc.ript.is a ~O 15 true and accurate.re d.of'th , fore oing p c dings. U 16 /s/ 1 . m 17 (Signature typed): Kent A. Andrews q q 18 OfficialLReporter a 19 Heritage Reporting Corporation-20 21 1 22 23 24 F 25 j A a y Heritage Reporting Corporation (202) 628-4888 i 'l

IF h 33 T1e efTect of roacway anc environment factors on tle 1. capacity of a traffic-signa approac1 The capasit) - a trattic signa! controlled intersection is hmitea hs the capacities of the indisidual upproaches to the intersection. There are two types of factor which :.ffect the capacity of an approach: roadway and environmental tactors, discussed in this chapter, and traffic and control factors i discussed in chapter 34. l The roadwa', and environmental factors that control the capacity of an approach are l the physical layout of the approach,in particular its width, the radii along which left-or nght turmng sehicles have to travel, and the gradient of the approach and its exit from the inter.section. The cansem ot an approach is measured independently of trattle and control factors and is expressed as the saturation flow. , ti-Saturation Ilow is defined as the maximum flow, expressed as equisalent passenger cars, that can eross the stop line of the approach when there is a contmuous green signal indica: ion and a conunuous queue of vehicles on the approach. Observations of trattic tiow made by the Road Research Laboratory at intersections in the 1 ondon area and also in some of the larger cities, supplemented by controlled experiments a: the 1.aboratory test track, have shown that the saturation flowls) expressed in passenger ear units per hour with no parked vehicles is given by s = 550w p.e.u./h . j ;; where w is the width of the approach in metres. ,J; This formula is applicable to approach widths greater than 5 5 m; at widths less than .J 5 5 m the relationship 13 not linear and saturation tiows may be estimated from table 33.1. c ,/bbD0 ~ 2 n@lfs7 UN@L0 l@ behrak

i t h f 283 TRAFFIC SIGNAL APPROACll: CONTROLLING FACTORS f p h d J.l j TAllLE 33.1 s.. w i nn 3 no r4n as 4 no 4 50 5 20 1 [ 't.' i t 27n0 l; j s: g u.In 185n 18 s 19nn 195n 2250 ]~ g f 'Kl b, These saturation 110ws have to be amended for the elTect of gradient. This moditica-g y ,o 1 I i tion ha, heen reported as a decrease or increase ut 3 per cent in the saturation llow for -I 1 per cent of uphdl or downinil gradient ot the approach, l'he gradient of the { es e rs appni.wh was ilelined as the userage slope between the uop hue and a point on the ( 8 appro.sh ol m bef ore it. At the sites wheie these observations were made, the slope [ conunoed throuch the intersecuon. f' W hoe schides crossing the stop kne have then to trasci unmediately around a curve f the rate of discharge across the stop line will be reduced. This occurs frequently when ndit turning vehicles are able to discharge during a nght turmng phase. Test track l expernnents base shtwn that the saturation llow tor right turmng streams may be j g t obtamed from 1800 s= p c.u./h. for sir.gle. file streams 1 r t 52lr { [ or 1600 p.e.u.!h I 3000 5= p.e.u.ih for double. tile streams g I + l-52lr p or 2700 p.e.u.!h l where r = tunnne radius in metres. The enviroom'ent also has an effect on.the saturation tiow of an approach and while it i I is dilueult to detine this effect precisely, generalized modification factors are often applied. l j Where a sue is designed with a cood environment that is dual carriageway approaches, l no nonceable pedestrian interference, no parked vehicles. no interferences to traffic ( A tiow f rom right turning vehicles, good visibility and adequate turning radii then the f saturation ilow is taken as 120 per cent of the standard value. l l 11 however a site is designed with poor environment. that is low average speeds, j i interference from standing vehicles and right turning vehicles, poor visibility arid poor alignment, then the saturation tiow is taken as 85 per cent of the standard value. Determination of the saturation flow of a traffic-signalapproach i I, To deternnne the saturanon llow of an approach select one in which there is a cen-tmuous queue even at the end of the green period. Avoid situations in which right-turmny schieles have an erratic etTect on the traffte flow. For ease of observation it is .j preferable to select an upproach that is restricted to straight ahead and left turning ~ l 4 vehices. l (Xng a stopwatch note the number, type and turning movement of each vehicle N crossmg the stop line dunng each successive 01 minute interval of the green and amber .l l penod. At the end of die amber period there will normally be an interval of less than d I 0-1 minute. Note the length of this interval and also the number and type of vehicles I j l 1 1: E O

I a } *! ('. \\ 284 TRAFFIC SIGNAL CONTROL crossing the stop line in the mierval. These intervals are subsequently referred to as last saturated intervals. If at any time the flow on the approach is not saturated, then observations should l be discontinued until the llow reaches saturation level again. Ifit is not found possible to observe vehicle type then only the number and turning movement of velucles shouhl be noted. At the completion of observations a senarnic. .i i.I, count is then necessary to deieinnne the composition of the traffic flow. 'I / The observations given in taHe 33.2 were obtained at a tra'flicisignal controlled.., j n' interseenon m the City of liradford, in this instance obs'ervations were made of mixed; vehicles travelling straight alicad. - i { l TA11LE 33.2 Ohsened discharge of sehicles across the stop line Tune tminute) 0 01 02 03 n4 05 f. t No. of vehicles crossing stopline 60 76 71 78 79 No. of saturated intervah observed 32 32 - 32 32 32 f Dist.harge per n I min 1 88 2 48 2 22 2 44 247 Total duration of the last saturated intervals = 142 seconds Total number of vehicles crossing stop line = 41. Discharge per 0 l minute during last saturated interval = (416.1/142 = l 74 vehicles;s During the first and last saiurated intervals there is a hns of capacity because of the effect of velucles accelerating trorn the stationary position at the commencement of the green period and decelerating durmg the amber period. j The flow during the rernamder of the observed periods represents the maximum discharge possible and their nan value gives the saturation flow for the approach 2 48 + 2 22 + 2 44 + 2 47 saturation flow = i 4 1 t, = 2-40 vehicles per 01 minute j = 1440 veincies/h 'lhis value must now be converted to tralfic. signal passenger car units and subsidiary I traffic count is required to detennine the compositico of the traffic. Observe the composition and turmng rnovements of the trallie flow for a period of 30 minutes and at similar tune to when the original observations were made. The followmg composition of tranie was noted on the aporoach where the flow figures i given in table 33.2 were obsened tusing the equivalent effects of various vehicle types given in chapter 34) l 1 heavy schicles 14 per cent I buses 5 per cent motor cycles 6 per cent private cars 75 per cent all vehicles proceed straight ahead 3 I i I e

= TRAFFIC SIGNAL APPROACII: CONTROI LlhG FACTORS 285 The passeneer tar equivalent of the flow ;s then I jylt o [.,, jji, - 0 I 4 x l 75 + 0 05 x 2 25 + 0-06 x 0 33 + 0 75 x 1 = l 10 g 3 .. Ib ' yli f-Saturation ihns = 1440 x l 16 < ht ,...] { h i , f' $ h - j !' l.Uls@3 7c. h.l. lJ. b

• 1670 p c.u.ph.

i

. ). w.2 < y p J . j t i; .t a 1 M M,f:,"? dl,I-i J!h I, J The desien li::nie given iri Road Research 7'ec/vncal Asper 50 is l'luo p.e.u./h for a ' ,3. k'y , If (. MA f i ;' 3 65 in lane wi iih. 'F I n obisons 1 Four differine irauis. somal approaches are described below. Place thern m the order of their trallie c.nwi'. (at An appro.n.h w nh yoml enuria.w.u,ta canditions where all s ehicles discharge i straight atross the unenection and where the approach width i3 7 30 m. the An approach with po ir environinental conditions with a condonous uphill gradient ul 3 per cent. uneve all schieles discharge straight across the inter <etrion and u here the approach width r, lh 50 in. (c) An approath wnh normal enuronmental conditions f rom wluth all vehicles turn right in a donh'e n!e sticam on a path with a radius of 30 m. Id) An approAn wnh good erwironmental conditions and downluii yradient of 4 per cent. where ali whiws dacharc' straight across the intersection and w here the ap[. mach l wid th i> 5'20 m. 4 O l .%lution s } l The trallie capatines of the approaches ar>: ) i i l (a) saturation ilow = 550 x 7 30 = 4015 p.e.u./h plus enviromnental factor of 20'J i l l = 4015 x l 2 _j 1 = 4818 p.c.u./h i (b) saturation flow = 550 x 10 50 = 5775 p.e.u./h ) minu> environmental lactor of 159 j f = 5775 x 0 85 - 490') p.e.u.;h l l minus gradient cifect of 3 x 3'i -) = 4909 x 0 91 I ) I = 4467 p.c.u./h { i k i 4 I j 1 4

li

i..

'86 TRAFFIC SIGNAL CONTROL 1, 3000 y [. te) saturation flow = 1.+ l 52/r p.e.u./h i t ,9 cl ' i { g : :", 3000 m 4. ,,dl c, t y : q. v n, [ t f. ;b, ' I - lJ1l )L I '.} $ S I$ bi ', if I + l 52/30 '

t. j [?,

,tif r v. fo .( j':,Q. ;t u!;h;c. i ,, T..,' ei ( ' [a. = 2857 p.e.u./h .. Ij n; p

}

s t- ,.. p })[';,l,[i,' idI sattna' tion Ilow = 2700 pic.u./h (table 33.1l' ),.' I. . d.3- ' Ij Mkj: i i; i pius esivid>ntnental factor of 20$ 1! . i k. i t ; " <, p i, f g,.. = 2700 x i-2 r- = 3240 p.e.u./ h

?

*

1 plus gradient effect of 4 x 3% i = 3240 x l 12 \\ = 3629 p.e.u./h y T he oider of capacity of the approaches is (a). (hl. (d),(c). f1 i, T l .c p P I i j I 'e f i 'i i g,,

)

I 1 1 'hh} f. 9 I l e b1 8. ,;l-(i! Il' .l:. i l n I tl I 0}}2' l ,*i.! P l [ fe d I

• i st s

ii C; l l' l( l , lf(! [%.. q 1 I pp S c. I a

W

in.

- ;. s i i 33 T1e effect of roacway and environment factors on tie capacity of a traffic-signal approac.1 The capacit'. o a tranis aignal controlled intersceuon is limned by the capacities of the mdhidual approaches to the intersection. There are two types of factor which affect the capacity of an approach: roadway and environmental factors. discussed in this chapter, and traffic and control factors discussed in chapter 34. The roadway and environmental factors that control the capacity of an approach are the physical las out of the approach. in particular its width, the radii along which left-or nght turnmg schieles have to travel, and the gradient of the approa:h and its exit ~ from the intersection. The capacin ot an approach is measured independently of tratfic and contul factors and is expressed as the saturation tiow. Saturation ilow is defined as the maximum flow, expressed as equivalent passenger cars, that can cross the stop line of the approach when there is a continuous green signal indication and a continuous queue of vehicles on the approach, Observanons of traffic flow made by the Road Research Laboratory at intersections in the London area and also in some of the larger cities. supplemented by controlled experiments at the l.aboratory test track, have shown that the saturanon flowis) i expressed in passenger ear units per hour with no parked vehicles is given by s = 550w p.e.u./h . } }i

• where w is (i.e width of the approach in metres.

,i ' This formula is appheable to approach widths greater than 5 5 m; at widths less than 5 5 m the relanonship is not linear and saturation tiows niay be estirnated from table 33.1.

s '

~ 282 S

O l<v d 283 y 6 TRAFFIC SIGN AL APPROACll: CONTROLLING FACTORS t 1 O .h j a TAILLE 33.1 a f no Nn H5 ' no 4 50 5 20 h w ino s iq u u.in t350 1875 190n 195n. 2250 2700 e lhese sat'usanon llows have tu be amended for the' ef fect of gradient. This modifica-

).g tion ha> heen reported as a decrease or inercase ut 3 per cent in the saturation llow for j,3

1phill or downhdl gradient of the approach. Ihe gradient of the every 1 per een s.

approxh wa, oelined as the verage slope between the stop hue and a pomt on the 8 I approuh ol m before it. At the sites where these observauon> were made. the slope 'g conunued through the interseenon. ) Wheie vehicles ermsing tt e stop kne have then to travel immed6ately around a curve r the rate of discharge across the stop line will be reduced.1his occurs frequently when f right tuinmg vehicles are able to discharge during a ught turning phase. Test track h i expernnents have shown that the saturation llow lor right turning streams may he d obtamed from 1 y 1800 c p.e.u./h, for sincle file streams { 5= i+l52/r j or 1600 p.e.u.!h [ 3000 e .s = - p.e.u.lh lor double tile streams t I + 1 5 2lr / or 2700 p.e.u.ih t h where r = teming radius in metres, The environment also has an effect on.the saturation tiow of an approach and while it i i. is dillicult to deline this ellect precisely, generalized modification factors are often applbd. [ [ Where a sue is designed with a good environment, that is dual carriageway approaches, [ no nonceable pedestrian interference, no parked vehicles, no mterferences to tratlic [ t j tlow f rom right-turning vehicles, goed visibility and adequate turning radii then the saturanon i ow is taken as 120 per cent of the standard value. l [ T l If however a site is designed wah poor environment. that is low average speeds. l interference from standing vehicles and right-turr;ing vehicles, poor visibility and poor f alignment. then the saturation llow is taken as 85 per cent of the standard value. [ f Determination of the saturation flow of a traffic signalapproach ( r To detennine the saturanon llow of an approach select one in which there is a con-j tmuous queue even at the end of the green period. Avoid situations in which right-turning sehicles have an erratic effect on the traffic flow. For ease of observation it is u ( preterat le to select an upproach that is restricted to straight ahead and lett. turn.ng j "k l vehicles " I l? sing a stopwatch note the number, type and turning movement of each vehicle crossing the stop line dunng each successive 01 minute interval of the green and amber penod. At the end of the amber period there will normally be an interval ofless than 01 minute. Note the length of this interval and also the number and type of vehicles .? l I l 'I a g f a

l tri 1 284 TRAFFIC SIGNAL CONTROL crossing the stop line in the uiterval. These intervals are subsequently referred to us last saturated intervals. If at any time the flow on the approach is not saturated, then observations sliould be discontinued until the !!ow reaches saturation level again. l Ifit is not found possible to observe vehicle type then only the numberand tidninh :l ' i movemeni of schicles should he noted. A!t tlie compic rion of. observations a separate i.; dl' d,.. 1 i count is;then nee ssary to deteinnne the co'mposition of liie traffie llow. The, obseru tions given in table 33.2 Ore 'obtained ill a traffic signdl controlled I i intersection in the City of Ikadford. In this instance observations were mad )- vehicles travelling straight ahead. TAllLE 33.2 Observed discharge of schicles across the stop line Tirne uninute) 0 0l 02 03 0-4 05 No. of vehicles crosung stopline 60 76 71 78 79 I i i No. ut'sa turated intervah observed 32 32 32 32 32 1 Dm.harre per n I nun 1 88 248 2 22 144 247 Total duration of the last saturated intervals = I42 seconds Total number of vehicles crossing stop line = 41. Discharge per 0-1 rmnute during last saturated in:erYal = (4l h)/l42 j = l 74 vehiclesis i Dunng the first and last uturated miervals there i, a loss of capacity because of the effect of vehicles acceleratme horn the stationary position at the conunencement of the l green period and decelerating dunng the aniber period. k The flow during the remainder of the observed periods represents the maximum discharge possible and their mean value gives the saturation flow for 'he approach ( 2 48 + 2 22 + 2 44 + 2 47 ., t.. saturation flow = 4 i = 2 40 vehicles per 01 minute j = 1440 vehicles /h l This value must now he conterted to traffic signal passenger car units and a subsidiary traffic count is required to detenmne the composition of the traffic. Observe the composition and tunnng movements of the trallie flow for a period of J 30 minutes and at similar inne to w hen the original observations were made. The I folhiwing composition of trailic was noted on the approach where the flow figures f given in table 33.2 were obsened (usmg the equivalent effects of vanous vehicle types given in chapter 34) g t I heav> schicles 14 per cent j i' buses 5 per cent r motor cycles 6 per cent private cars 75 per cent i all vehicles proceed straight ahead i e e i

\\. mmmmm -emmmmmmmowmuwree== l V TR.\\FFIC SIGNAL APPROACll: CONTROLLING F.\\CTORS 285 O) The passenter sar equivalent of the tiow is then \\_ ie j U 14 x l 75 + 0 05 x 2-25 + 0 06 x 0 33 + 0 75 x l = l 16 - s. 1440 x l 16 1 i Saturanon ihm e i n70 p.m u.i t. .l l il. k .i i 1 i;{ ' The design hgnie viven in Road RcAcatch 7'cchmcull'uper 5h ;> l' lou p.e.u./h for a t ,}: i 3t5 m 1.me widih. i F hohlems Four dif f erine n.itri., -nenal approaches are described below. I't. ice them in the order of their t rat tic capait'. (ai.\\n approx h w uh p uid emironment.d conditions w here ai! schicles discharge l straight atrow noz intenection and where the approach width h ?O m. (b) An appro ich willi pitor ensironinetital conditions with a toniinuous uphill gradient f of 3 per cent. a h."e ill schicles dhcharge so.nghi aeross the iniersedion imd where the t h apprisach width lif 50 Ifi 4 E (t) An approxh with normai environmental conditions from whish all schicles turn l { right in a douHe a:e sticam on a path with a radius of 30 m. i (d) An appiomu e oh uod environmental conditions and doaci ;, tradient ol 4 per cent. where.ui entoe> dish;nge straight across the intersection and where the approach I width is 5 20 ni b [ v .%/u thms \\ The trallie capa.ities of the approaches are: { i 6 l (a) saturation ilow = 550 x 7 30 = 4015 p.e.u./h [ l plus enstronmental lamtor of 20 ( i ? I i = 4315 x l ' I I l = 4818 p.e.u./h l 1 i j (b) saturation llow = 5 50 x 10 50 = 5775 p.e.u.!h nunus envnonmcai.d t.utor of 15v i i [ = 5775 x 0 85 = 490') p.e.u.;h minus gradient s Mut of 3 x 3'" = 490') x 0 91 l I = 4467 p,C.U./h I i ~h

0 e i: { l 2S6 TRAFFIC SIGNAL CONTROL 3Ih 3000 $li acs saturation flow = I + l 52/r p.e.u./h i-

' t 3000 ll2i

= I + l 52/30 f,'I.l = 2857 p.e.u./h iI I -

;i l (di saturation flow = 2700 p.e.u./h (table 33.1) pius enviro

unental factor of 20%

II = 2700 x l 2 e- = 3240 p.e.u./ h plus pudient effect of 4 x 3% = 3240 x l 12 ( = 3629 p.e.u./h t he order of capacity of the approaches is (a),(bi. Idl,(c). i= s T P P i bl!

i.

og: 'it fi !l }t-fl r tl j 7 al l si! 7 1 -i: I k n tl I Gl?, l i 'E E p { i L< d L !? ( c; l' 0 ;, l i 'ivi i 414 1 d' 4}$ l l'.'ll ) py?' I $I!+ 1 I a ii-

', ' (!

tt-r1 "'tb a + + 7, 33 T1e effect of roadway anc environment factors on t Te capacity of a traffic-signa approac1 The capasit) trattie signal controlled mterscetion is limited by the capacities of the mdisidual approaches to the mtersection. There are two t> pes of factor which affect the capacity of an approach: roadway and environmental factors, discussed in this chapter, and traffic and control factors discussed in chapter 34. The roadw as and environmental factors that control the capacity of an approach are the physicallavout of the approach,in particular its width, the radii along which left-or right-turmng sehicles have to travel, and the gradient of the approach and its exit from the interseenon. The capacity oi an approach is measured independently of tratfic and control factors a. ,1, and is expressed as the saturation flow. 3-Saturation ilow is defined as the maximum flow, expressed as equivalent passenger .t cars, that can cross the stop line of the approach when there is a contmuous green signal indication and a continuous queue of vehicles on the approach. Observations of traftie llow made by the Road Research Laboratory at intersections in the London area and also in some ot' the larger citics, supplemented by controlled experiments.it the I.aboratory test track. hase shown that the saturation flowf s) expressed in passenger car units per hour with no parked vehicles is given by s = 550w p.c.u./h . I 'j; where w is the width of the approach in metres. j], This formula is appheable to approach widths greater than 5 5 m; at widths less than 5 5 m the relationship is not linear and saturation licws may be estimated from table 33.1. 28. i /ppGc?% z )

I. I l 283 TRAITIC SIGN AL APPROACil: CONTROLLING FACTORS 3 .h TAllLE 33,1 f ~ 4 50' 5 20 ' roo No. MS 4 00 y -[o 4 wo- > i m u to 1850 1875 '1900 '195n ' 2250 2700 .h .l d c 1. I m ,1 [ These saluiauan 110ws have to be amended f or the ef fect of gradient. This moditiea-hj { .i [ tion has been reported as a decrease or increase of 3 per cent m the saturation llow lor , j f; 3 l eser> I per cent oi uphill or downhill gradient 01 the appro.ich. l'he gradient of the { appro.ah was ilelined as the aserage slope between the stop kne and a pomt on the 8 appro.wh 01 m betore it. At the mes where these observauons were inade, the slope l continued through the intersecuon. I % heie vehicles crossing the stop line have then to travel unmediately around a curve i the rate ot discharge across the stop line w.ll be reduced. 'lhis occurs trequently when I nght iurnmg velucles are able to discharge during a upht.inrning phase. Test. track l expernuents have shown that the s::turation llow for right.turnmg streams may be obtamed from 1800 p.e.n./h. for single tile streams 5= I + l 52/r or 1000 p.e.u.!h 1000 p.e.u.ih tor double lile streams s=-l + H lr or 2700 p.e.u.ih where r = tunune radius in metres. g The envuonm'ent also has an effect on_the saturation tiow of an approach and while it i is diflicult to deline this effect precisely, generalized modilleation factors are often applied. I Where a site is designed wah a good environment, that is dual carriageway approaches, no nonceable pedestrian interference, no parked vehicles. no mterterences to trattic j llow irom right. turning vehicles, good visibility and adequate turmng radii then the t 1 saturanon ilow is taken as 120 per cent of the standard value. l If however a site is designed wnh poor environment, that is low average speeds. l interference from standing vehicles and right. turning vehicles. poor visibility and poor alignment, then the saturation llow is taken as 85 per cent of the standard value. Deterinination of the saturation flow of a traffic-signalapproach To deternune the saturanon tiuw of an approach select one in which there is a con. tmuous queue even at the end of the green period. Avoid situations in which right. turmng sehicles have an erraue etfeet on the traffic flow. For case of observation it is .l pref erable to select an approach that is restrieted to straight ahead and left. turning 4 vehicles. l! sing a stopwatch note the number, type and turning movement of each vehicle crossing the stop line dunng each successive 01 minute interval of the green and amber penod. At the end of the amber period there will normally be an interval ofless than a 0-1 minute. Note the length of this interval and also the number and type of vehicles T I 7 6 e a

d yn I f tW P 4 284 TRAFFIC SIGNAL CONTROL crossing the stop line in the interval. These mtervals are subsequentiv referred to as last saturated intervals. If at any time the flow on the approach is not saturated, then observations should I be discontinued until the flow reaches saturation level again.. y ifit is not found possible 10 observe vehicle type then only the number and turning,, l

movenient of vehicles should be noted. At the completion of observations a separd.e. J W ' i b

cpunt is then necessary'to deietnnne the conirosition of the traflie flow', /h. d- ' l The observanons given in table 33.2 were 'obtained at a traffic signal controlled D. ! @c t I' Jntersecuon in the City of liradfold. hi tiiis instance observations were made of mlke vehicles travelhng straight ahead, g TA ULE 33.2 Observed discharge of vehicles across the stop line Time iminute) 0 0t 02 03 04 05 i No. of vehicles crosung stepline 60 76 71 78 79 No. vi saturated intervals observed 32 32 32 32 3' 6(

{

Discharge per 0 t mm l'88 2-48 2 22 244 2 47 h t Total duration of the last saturated intervals = 142 seconds i Total number of vehicles crossing stop line _ = 41. Discharge per 01 nunute during last saturated interval = (41 r>>/142 = l 74 schicles/s I t During the first and last saturated intervals there is a loss of capacity because of the l elTect of vehicles acceleratmg IMn the stationary oosition at the conunencement of the [ green period and decelerating dunng the amber period, u The llow during the remainder of the observed periods represents l'ic maximum I discharge possible and their mean value gives the saturation flow for the approach It 2 48 + 2 22 + 2 44 + 2 47 i saturation ilow = 3 4 t = 2 40 vehicles per 01 minute j = 1440 vdueles/h l This value must now he converted to traffic signal passenger car units and a subsidiary traffic count is required to detennine the composition of the traffic. 5 Observe the composition and turmng ruovements of the trallie dow for a penod of 30 minutes and at similar inne to w hen the original observations we e made. The l following composition of trallie was noted on the approach where Ine flow ligures l given in table 33.2 were obsened t using the equwalent cliets of vraious vehicle types given in chapter 34) e i heavy schicles 14 per t. cut i' buses 5 per cent motor cycles 6 per cent private cars 75 per cent all vehicles proceed straight ahead L I 6 i l l I i I %J

= TRAFFIC SIGNAL APPROACil: CONTROLLING FACTORS - 285 The passenter sar eqmvalent of the Gow is then e t U I4 x l 75 + 0 05 x 2 25 + 0 06 x 0 33 + 0 75 x I = l 16 ~i s .l !o;, Saturation ilow = 1440 x ! 16.- .pg 'l - hdo p.c.u.t h. i,. ,, git m i j j. ? + 'Mi, The desien sigure given in Road Rescarch Techmcall'apet 50 ii 1.900 p.c.u.th for a a! MOhpi q r]h) h 3 65 m lane width. l s l'ruhle m> Four dilTerine natiis siunal approaches are described below. Place them m the order of their trattie c.m.is n:. ( s (a) An approah unh p>od emironmental conditions where all selueles discharge l i. straight across the intenection and where the approach width is 7 30 m. j g n (b) An approach woh poor envimmnental conditions with a continuous uphill gradien' [ L of 3 per cent. w here all vehicles discharge straight across the inienestion and where the l approach width i, lii 50 m. l h i E (c) An approath wuh normal environmental condinons f rom wiu,h all vehicles turn l 5 right m a doub'e tile shcam on a path with a radius of 30 m. i ) t (d) An appioAtt woh good environnielital Conditions and downl.,, uf adient of 4 per l cent, where aii whisus discharge straight across the intersection and wheie the approach 'l d width i3 5 20 m. ' ~ i Solutions The traffic capasines of the approaches are: i 4 l (a) saturauon llow = 550 x 7 30 = 4015 p.e:u.lh plus envirotunental factor of 20') { = 4015 x l 2 = 4818 p.c.u./h j (b) saturation ilow = 550 x 10 50 = 5775 p.e.u./h minus enviroinnental lactor of 15') f = 5775 x 0 85 r 4909 p.e.u.lh l minus gradient effect of 3 x 3'" r = 4909 x 0 91 = 4467 p.c.u./h I ? i

i 9 '86 TRAFFIC SIGNAL CONTROL 3 !!. lf-ai saturation flow = p.e.u./h 3000 6 I + l 52/r a I< 4; .e i f: 3000 v. l j{, ' I + 152/30 { 'i l $;;.! '. = 2857 p.e.u./h .i: - *

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nli saturation llow = 2700 p.e.u./h (table 33.11 I- ' ' ^! ', ' piin enviiontaental factor of 20'J = 2700 x 12 e = 3240 p.e.u.!h i ! plus gradient effect of 4 x 3% = 3240 x l 12 ( = 3629 p.c.u./h 4 Ihe order of capacity of the approaches is (a),(b),(dl,(c). [ j! T P P i l 'ni; s 4 g ', stl i I

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