ML20236X140
| ML20236X140 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/04/1987 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#487-5087 ASLBP, OL, NUDOCS 8712090002 | |
| Download: ML20236X140 (75) | |
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UNutu STATES NUCLEAR REGULATORY COMMISSION 1
IN THE MATTER OF DOCKET NO: 50-444-OL 50-443-OL PUBLIC SERVICE COMPANY OF OFF-SITE
.i NEW HAMPSHIRE, et al.
EMERGENCY PLANNING (Seabrook Station, Units 1 and 2,)
1-i EVIDENTIARY HEARING 1
'f LOCATION:
WASHINGTON DC PAGES: 7411 - 7554 1
DATE:
DECEMBER 4, 1987 i
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UNITED STATES NUCLEAR REGULATORY COMMISSION 2
ATOMIC SAFETY AND LICENSING BOARD 3
1 1
4 In the Matter of
)
)
Docket Nos.
5 PUBLIC SERVICE COMPANY OF
)
50-443-OL NEW HAMPSHIRE, et al.,
)
50-444-OL l*
6
)
OFF-SITE EMERGENCY 4
l (SEABROOK STATION, UNITS 1 AND 2)
)
PLANNING 7
8 EVIDENTIARY HEARING 9
- Friday, L
10 December 4, 1987 11 Hall of Representatives l
New Hampshire Statehouse 12 Concord, NH 13 The above-entitled matter came on for hearing, pursuant to notice, at 9:02 a.m.
15 BEFORE:
JUDGE IVAN W.
SMITH, CHAIRMAN i
16 Atomic Safety and Licensing Board U. S.
Nuclear Regulatory Commission l
17 Washington, D. C.
20555 18 JUDGE JERRY HARBOUR, MEMBER Atomic Safety and Licensing Board i
19 U. S.
Nuclear Regulatory Commission l
Washington, D. C.
20555 20 JUDGE GUSTAVE A.
LINENBERGER, JR.,
MEMBER 21 Atomic Safety and Licensing Board U. S.
Nuclear Regulatory Commission 22 Washington, D. C.
20555 23 24 25 Heritage Reporting Corporation 9
(202) 628-4888
1 7412 d
,m 1
APPEARANCES:
2 For the Apolicant:
3 THOMAS G.
- DIGNAN, JR.,
ESQ.
GEORGE H.
LEWALD, ESO.
4 KATHRYN A.
SELLECK, ESQ.
Ropes & Gray 5
225 Franklin Street Boston, MA 02110 For the NRC Staff 7
SHERWIN E.
TURK, ESO.
8 Office of General Counsel U. S.
Nuclear Regulatory Commission 9
Washington, D. C.
20555 10 For the Federal Emercenev Manaaement Aaenev 11 GEORGE WATSON, ESQ.
Federal Emergency Management Agency 12 500 C Street, S. W.
Washington, D. C.
20472 13 For the State of New Hamoshire 14
( _
GEORGE DANA BISBEE, ASST. ATTY. GEN.
15 GEOFFREY M.
HUNTINGTON, ESG.
State of,New Hampshire 16 25 Capitol Street Concord, NH 03301 17 For the Commonwealth of Massachusetts:
18 JOHN TRAFICONTE, ASST. ATTY. GEN.
l 19 ALAN FIERCE, ESQ.
I Commonwealth of Massachusetts I
,f 20 One Ashburton place, 19th Floor Boston, MA 02108 1
21 For the New Enoland Coalition Aaainst Nuclear 22 pollution:
l 1
23 (No appearance)
)
24 25 9I l
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APPEARANCES:
(Continued) l,%gs i,d'
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2 For the Seacoast Anti-Pollution Leaaue 3
JANE DOUGHTY Director l
4 Seacoast Anti-Pollution League 5 Market Street 5
Portsmouth, New Hampshire 03801 6
3 7
For the Town of Hamoton:
PAUL McEACHERN, ESO.
8 MATTHEW T.
BROCK, ESQ.
Shaines & McEachern 9
25 Maplewood Avenue P. O.
Box 360 10 Portsmouth, NH 03801 11 For the Towns of Hampton Falls and North Hampton and South Hamoton 12 (No appearance.)
13 For the Town of Amesbury:
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14
.(
(No appearance) 15
]
i 16 For the Town of Mensinaton
]
)
17 SANDRA F.
MITCHELL Civil Defense Director 18 Kensington, NH 03827 19 20 1
21 l
I 22 23 24 25
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7414 1
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1 INDE X s 3..
2 WITNESSES DIRECT CROSS REDIRECT RECROSS EXAM DR. THOMAS URBANIK II 3
by Mr. Fierce 7417 4
5 6
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9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 l
24 25
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EXHIBITS:
IDEN: RECD: REJD:
DESCRIPTION:
l Massachusetts Attorney General 3
No. 10 7438 7481 Letter from Dr.
4 Urbanik to Dave Matthews, 6 May ' 85, 5
2 pps.
6 3
7 pAGE INSERTS:
Massachusetts Attorney General's 8
Exhibit Number 10 7482 9
10 11 12 13 14 f
15 16 17 18 19 20 21 22 23 24 25
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PROCEED I NGS i.s 2
(On at 9:02 a.m.)
3 JUDGE SMITH:
Is there any preliminary business?
4 MR. TURK:
Your Honor, I would have one matter.
5 I reviewed the chart provided to me by the 6
Applicants, yesterday and I have determined that it contains a 7
level of detail far beyond what I think appropriate for me to 8
introduce into the record.
9 So, I will not move the admission of that document.
10 JUDGE SMITH:
Okay.
11 MR. TRAFICONTE:
The only other preliminary business 12 would be to try tv preserve some time, at the end of today, to 13 discuss the witnesses.
14 JUDGE SMITH:
Right, yes.
We had that in mind, and 15 take up Mr. Oleskey's information about possible hearings 16 space.
17 MR. OLESKEY:
Yes, Judge, and I had a -- hopefully if 18 we could do it in brief discussion with the Board and Mr. Turk 19 about the discovery pending between the Staff and the 20 Massachusetts Attorney General?
21 JUDGE SMITH:
Okay.
22 All right, Mr. Fierce?
23 MR. FIERCE:
Thank you, Your Honor.
24 Good morning, Board.
25 Good morning Dr. Urbanik.
(,
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URBANIK - CROSS 7417
,n 1
Whereupon, E
2 THOMAS URBANIK 3
was recalled as a witness, and after having been first duly 4
sworn, was examined and testified as follows:
5 CROSS-EXAMINATION 6
BY MR. FIERCE:
7 Q
Good morning, Dr. Urbanik.
8 A
(Urbanik)
Good morning.
9 Q
Dr. Urbanik, you have a Ph.D.
in civil engineering, 10 isn' t that correct?
11 A
(Urbanik)
Yes, sir.
12 Q
And that is from Texas A & M, is that correct?
13 A
(Urbanik)
Yes, sir.
14 Q
How many years have you been there?
15 A
(Urbanik)
I have been there since January of 1977.
16 Q
And you are not a tenured professor there, are you?
17 A
(Urbanik)
No, I am not.
I 18 Q
You teach undergraduate courses, as I understand, is j
19 that correct?
20 A
(Urbanik)
Among other things.
21 Q
And you are a program manager, or is it "the" proDram 22 manager for the transport operations at the Texas Transport 23 Institute?
24 A
(Urbanik)
I am "the" program manager of the 25 transport operations program which is one of the 20 or so G
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URBANIK - CROSS 7417A f.
1 programs, within the Institute.
2 O
Is it fair to say, Dr. Urbanik, that your field of 3
work at Texas A & M is in applied traffic engineering, and 4
transportation engineering and planning?
l 5
A (Urbanik)
Yes.
l l
6 I would say that it is fair to say that.
7 0
You are not an expert, are you, in the theoretical
~
8 development of computer models for complex systems?
9 A
(Urbanik)
No, I am not.
10 Q
And you are not an expert in the field of computer il science, generally, are you?
12 A
(Urbanik)
I think that is correct.
13 O
And isn' t it also fair to say you are not an expert 14 in the field of statistical analysis?
15 A
(Urbanik)
I think that is reasonable.
16 Q
And you are also not an expert in the field of survey 17 methodology?
18 A
(Urbanik)
I am certainly not an expert in that 19 field, but have quite a bit of research in that area, and my 20 Ph.D. dissertation involved survey research so that I would not 21 consider myself a total novice in survey research.
22 Q
But you don' t hold yourself out to be an expert in 23 that field?
24 MR. TURK:
Your Honor, well, -- nothing.
25 JUDGE SMITH:
You are objecting?
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MR. TURK:
I believe the questions along this line
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may be seeking a legal conclusion but I will address that on 3
redirect.
4 THE WITNESS (Urbanik):
I believe I answered the 5
question, but I did not claim to be an expert, no, I did not.
6 BY MR. FIERCE:
7 Q
And you also don' t claim to be an expert in any 8
particular field of human behavior, do you?
9 A
(Urbanik)
No, I do not.
10 Q
Nor are you an expert in the area of aerial photo 11 interpretation, isn' t that correct?
12 A
(Urbanik)
I think that is fair.
13 Q
Now, doctor, if you are not an expert in the field of
.,-~~
14 theoretical development of computer models for complex systems, 15 then, I take it that you don' t hold yourself out in evaluating 16 current complex, traffic flow models, or computer simulation 17 models or network models, is that correct?
18 A
(Urbanik)
No, that is not correct.
19 0
Your ph.D.
is not in that field, correct?
20 A
(Urbanik)
I believe I said that, yes.
21 Q
And you do not teach graduate courses in the 22 theoretical development of complex computer models, do you?
23 A
(Urbanik)
What I am trying to say is that --
24 Q
I would appreciate it, if you would answer my 25 question, Dr. Urbanik.
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A (Urbanik)
Well, I think I answered the question, s E) c 2
we seem to be having problems by asking me the same questions.
3 So I am trying to help you out by explaining my position, that 4
is all.
5 O
I think you would be helping me out by answering my 6
questions, this morning.
7 JUDGE SMITH:
Well, if he thinks he has already 8
answered it, then there is a problem.
So, there is a problem 9
with understanding the question.
10 If you think he has not answered it, and he thinks he 11 has, then you are not communicating.
You had better -- what is 12 the question?
13 I thought he had answered it.
14 MR. FIERCE:
Let me withdraw the question and try 15 again.
16 JUDGE SMITH:
Teaching as compared to being an expert 17 in the area, is that it?
18 BY MR. FIERCE:
19 O
Do you teach graduate level courses in the area of 20 theoretical development of complex computer models?
21 A
(Urbanik)
No, sir.
22 Q
I understand thet you did some work in the 23 development of the CLEAR model, but I also understand that you 24 did that work with others, isn' t that correct?
25 A
(Urbanik)
That is correct.
9
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Q And i sn' t it true that.Mr. Moeller did the work on
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2 the program W th the source code?
3 A
(Urbanik)
Mr. Moeller did the work with my 4
collaboration.
5 0
You have not published any articles in refereed 6
journals, have you, which have advanced the state of knowledge 7
in traffic flow models, computer simulation models or the like?
8 A
(Urbanik)
Not any theoretical work, no.
9 Q
And.are you engaged in any current research which l
10 involves a detailed analysis and review of source codes, for il complex, network models?
l 12 A
(Urbanik)
No, sir, j
.i 13 Q
Dr. Urbanik, with respect to your work at Texas A & M
,[
h 14 since you have been.there, how would you describe Just what is
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15 your particular area of expertise there?
16 A
(Urbanik)
Well, I have several areas of expertise, 1
17 but probably the one that I can most credibly demonstrate as 18 being probably the most renowned expert in, would be in the 19 area of evacuation time estimates for nuclear power plants, in 20 the United States.
21 Q
That 1 what you believe to be your particular area 22 of expertise in your work, at Texas A & M, since you have been 23 working there?
24 A
(Urbanik)
Could you repeat the question again, I did 25 not quite catch it all.
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URBANIK - CROSS 7421 1
Q With respect to your work, at Texas A & M, since yot 7
2 arrived there, if I asked you just what is your particular ar 3
of expertise, or how you would describe it, --
4 MR. TURK:
Perhaps a clarification is in order.
5 The question asks for his work at Texas A & M, okay.
6 Dr. Urbanik's physical location is at Texas A & M, is that the 7
question?
The work that he does while he is at that location?
8 MR. FIERCE:
With respect to his capacity at Texas A 9
& M, correct.
10 THE WITNESS (Urbanik):
The most significant work 11 that I have done as being an expert, would be in the area of 12 evacuation time estimates, yes.
13 BY MR. FIERCE:
14 Q
Isn' t it true, Doctor, that.your work at Texas A &
15 as you have Just described it to me, is primarily in the area 16 of applied traffic engineering and transportation engineering?
17 A
(Urbanik)
Yes, I would say that is consistent with 18 what I have said.
19 Q
Isn' t it true that in the past 10 years, you have had 20 a total of five publications in the field of traffic 21 engineering?
22 A
(Urbanik)
I would have to get my resume out, if we 23 are going to play games with numbers.
24 Q
Well, would you disagree with that number, 25 substantially?
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1 A
(Urbanik)
I would have to have my resume out, and
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2 your question over again, in order to be able to home in on 3
which articles you are trying to describe as being pertinent to 4
the area that you are asking.
5 Q
Does your copy of the testimony have your resume 6
attached at the rear, as mine does?
7 A
(Urbanik)
Yes, it does.
)
~
8 (Pause.)
9 BY MR. FIERCE:
10 Q
Now, as I understand your resume and as I look at the 11 publications and papers under traffic engineering, which occur 12 on about page 3, or 4 of your resume, oh, page 4, I see that 13 there are, since 1977, one, two, three, four, five papers.
14 Is that correct?
15' MR. TURK:
What, where are we looking?
16 MR. FIERCE:
I thought that I just described it on 17 Page 4 of his resume and the category under Publications and 18 Papers for Traffic Engineering.
19 MR. TURK:
And may I have the question, again?
20 BY MR. FIERCE:
21 Q
Isn' t it true, that since 1977, there are.five papers 22 listed here?
23 A
(Urbanik)
In the area of traffic engineering, yes.
24 Q
And three of them are dealing with freeway shoulders, 25 isn' t that correct ?
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1 A
(Urbanik)
Freeway shoulders and related operational
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issues, yes.
3 Q
Do you consider yourself to be an expert in the topic 4
of freeway shoulders?
5 A
(Urbanik)
As they relate to the safety and 6
operations of freeways, yes.
7 Q
Doctor, concerning -- strike that.
8 Are concerns about freeway shoulders involved in this 9
licensing proceeding?
10 A
(Urbanik)
Yes, they are.
11 Q
And can you point to the contention that includes 12 anything that has to do with freeway shoulders?
13 MR. TURK:
I am going to object, Your Honor.
j 14 I think what we are looking for is an interpretation 15 of contentions and I think that is something the lawyers can do 16 best.
17 MR. FIERCE:
Well, he Just told me he believes this 18 is somehow involved in the case.
19 JUDGE SMITH:
Well, are shoulders involved, were 20 shoulders involved in your testimony, in the preparation of 21 your testimony, or your evaluation of the KLD study?
22 THE WITNESS (Urbanik):
The issue of shoulders, yes, 23 is an issue that has come up in the evaluation of the study.
24 It has been posed more in the realm of -- in many of 25 the instances, it relates to two-lane roads, but other places, Heritage Reporting Corporation
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they talk about choke points and things of that nature.
2 So, those choke points could be just as well on 3
freeways as they could on two-lane roads.
So, it has certainly 4
been raised.
5 BY MR. FIERCE:
6 Q
Dr. Urbanik, I want to explore exactly what you did 7
to examine the ETE study, for Volume 6, contained in Volume 6.
~
8 Did you read all of Volume 67 9
A (Urbanik)
Yes, I did.
10 Q
Did you read anything else?
11 A
(Urbanik)
Well, I have read documents going back 12 since 1981.
I have been involved in the Seabrook case, off and 13 on for seven years.
14 Q
Well, I know you have been around, doctor, but I am 15 asking you with respect to your evaluation of the ETE study 16 that we are litigating here, that is contained in Volume 6.
17 Q
What else did you read in connection with your 18 evaluation of that document?
19 A
(Urbanik)
Subsequent, or prior to reading it?
20 Q
Well, presumably your evaluation of Volume 6, 21 occurred after its publication, isn' t that a truism?
22 A
(Urbanik)
I am asking prior to or after I read the 23 study?
24 Are you excluding anything that I read ;)rior to 25 reading Volume 6?
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O Well, let me phrase it this way for you, Doctor,
-3 2
Volume 6 was published, I believe, in August of 1986.
3 Since its publication, I want to know what you have 4
done to evaluate Volume 6.
And I understand that you have read 5
it, and I want to know what else you read in connection with 6
your evaluation?
7 JUDGE SMITH:
After -- that is his point, after --
l 8
MR. FIERCE:
After --
9 JUDGE SMITH:
-- if you are excluding from his 10 answer, information and what he read before, he read Volume 6.
11 MR. FIERCE:
I sure don' t want him to list 12 everything that he has ever read that might have some bearing 13 that could have occurred prior to August of 1986.
14 But I want to know what he read, in connection with 15 his evaluation and that presumably could only have begun after 16 Volume 6 was published so that 17 JUDGE SMITH:
-- well, that is where he disagrees 18 with you and see, that is why he asked you the question 19 implicitly.
20 THE WITNESS (Urbanik):
Everything that I read in 21 advance, is part of my knowledge, and forms the basis of my 22 understanding -- my previous site visits, everything that I 23 have done, at the site, is all part of information that I have 24 available to me.
25 And that is quite extensive.
So, if you want that, Heritage Reporting Corporation (202) 628-4888 s
I URBANIK - CROSS 7426.
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we could be here a long time.
Now,' if you just want what I q.
g, 2
have done in refreshing my memory on things, since I read the 3
report, we could probably hone it down to a smaller number.
4 MR. FIERCE:
Okay.
5 JUDGE SMITH:
What you want, I think, is what he has 6
done expressly, or particularly for evaluation --
7 MR. FIERCE:
Yes, exactly, Your Honor.
8 And presumably that would only be since August of l
9 1986, when it was published and that is what I would like to 10 know.
Presumably also every expert comes in here, and relies 11 on all of their knowledge gained over the years.
12 BY MR. FIERCE:
13 Q
I am talking about what you have done, Doctor, since 14 August of 1986, expressly to review Volume 6, of the New 3
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15 Hampshire Radiological Emergency Response Plan.
16 And we are talking about other things that you l
17 might have read, expressly.
18 MR. TURK:
-- since publication of the ETE.
l 19 THE WITNESS (Urbanik):
There have been a whole l
20 series of things, ongoing, since -- went back and went back 4
21 through our previous study that is in NUREG-CR-2903, to do some 22 comparisons -- for example, on the population estimates that 23 were done to look at the ETE's that we had previously 24 developed.
25 And generally refreshed my memory on some of the
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specifics of the site.
<s
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2 Now, the question is limited to things that I read, 1
3 is that correct?
4 MR. FIERCE:
Yes, that is the category, now.
I 5
THE WITNESS (Urbanik):
I have read the deposition 6
that was taken of Dr. Lieberman.
I have, of course, read all 7
of the pertinent test 4 mony, relative to contentions.
I have 8
read the contentions.
let me interrupt you there, 9
MR. FIERCE:
Don' t 10 Doctor, because --
11 MR. TURK:
Can we have a complete answer?
12 Mr. Fierce spent a good 10 minutes or so, trying to 13 get the answer.
Let's have it.
14 MR. FIERCE:
Well, I believe that last item was 15 outside the category I asked for, that is why.
16 BY MR. FIERCE:
17 Q
Because in terms of conducting your evaluation and 18 then writing your report, and your testimony here, it would not 19 have been possible for you, would it, Doctor, to have also 20 included in that review, the testimony that was filed by the 21 other parties, because it all got filed simultaneously.
22 Isn' t that true?
23 MR. TURK:
Your Honor, I have an objection to the 24 interruption of the Witness.
I don' t think that can be 25 overridden by simply insisting on a new question.
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URBANIK - CROSS 7428 w
1 JUDGE SMITH:
By simply insisting on what?
l,
(,/
2 MR. TURK:
On asking a new question.
3 JUDGE SMITH:
Yes, well, he can withdraw his earlier i
l 4
question, if he wants to. Implicitly that is what he does if he I
l I
5 cuts off the answer.
6 I don' t think we need all this.
He is entitled to 7
the information that he is seeking, but I think you are holding 8
the witness to too tight a standard on his answer.
9 MR. FIERCE:
Well, let me Just clarify and then I 10 will let him continue.
11 When I say, what did you do for your evaluation, I 12 think I need to put an end date on that.
13 BY MR. FIERCE:
O (N 14 Q
And the end date would be, when you filed your 15 testimony in this case, Doctor Urbanik.
)
16 I understand we all now have been reading testimony 17 and listening to testimony, but the evaluation I am talking 18 about, is that which is contained in your testimony, primarily.
l 19 A
(Urbanik)
Well, my testimony was filed yesterday so 20 that everything that I have listed is within that realm.
21 JUDGE SMITH:
Well, we received your testimony in 22 September.
23 Did you go back to, for example, did you go back to 24 the Highway Capacity Manual and check back there for any --
25 THE WITNESS (Urbanik):
Oh, absolutely.
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1 JUDGE SMITH:
Any other resource materials that you i
2 used to evaluate the study?
3 Reference materials, I meant.
4 (pause.)
5 JUDGE SMITH:
Well, I hate to take this over, but I 6
know from your testimony that you went not only back to the 7
Highway Capacity Manual, but some of the underlying reports.
8 THE WITNESS (Urbanik):
Right.
9 A lot of the studies on weather, for instance, that 10 have been brought out, that is why I am Just trying to recall 11 all of them and not leave anything out, because there is a 12 substantial amount of homework that you have to do to get 13 through the process.
14 But yes, the various adverse weather reports that I 15 rely on, for capacity, during fog and rain, and snow and things 16 like that, that are in various documents.
17 My article on forced flow, which has some data that I 18 used in illustrating that concept.
By my recollection, those 19 are the principal documents.
20 BY MR. FIERCE:
21 Q
Other than reading this material that you have just 22 described, is there anything else that you did, in conducting I
23 this review?
24 A
(Urbanik)
Yes.
1 25 I made another field trip to the EPZ, to once again,
~
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bring my knowledge of the EpZ up to a more current date and te c77-(_,,)
' il 2
review the traffic control measures that were being recommended 3
in the study.
4 Q
Did you go to each of the intersections that have 5
designated traffic control points?
6 A
(Urbanik)
Absolutely not.
7 Q
Which ones did you go to then?
8 A
(Urbanik)
The ones from looking at the study, that j
l 9
were most important, from assuring the amount of capacity that i
1 10 was being used in the study, could, in fact, be achieved. Some 11 of the key ones are I-95, at Route 51.
That fit in that 12 category.
13 I am not saying that those are the only ones that I
[
'N 14 looked at, but the ones that I had the greatest concern about, s:J 15 were I-95, and 51, and I-95, at Route 110.
16 I think the area called Salisbury center, and then 1
17 all of the -- look at many of the principal routes. But the 18 traffic control ir, many of them isn' t critical to the ETE's.
19 And I also looked at some of the beach traffic 20 control, closer into the beach.
21 Q
When did you conduct this field trip?
22 A
(Urbanik)
I believe it was in August, but I don' t 23 know if I can be -- find that from my records, here or not.
24 I am not sure.
25 Q
Well, was it a field trip that occurred on a single rh d'-}
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day, this past summer?
~
2 A
(Urbanik)
It was a weekend trip, so I am trying to 3
recall.
I left Friday and stayed over the weekend.
I believe 4
that I came back Monday.
5 It was a couple of days in the field.
6 Q
Did you stay up there in the EpZ?
7 A
(Urbanik)
Yes, I did.
8 We stayed at the Hampton Falls Motel.
I believe that 9
is roughly the name of it.
It is on Route 1.
10 Q
Did you conduct any measurements or data collection 11 activities, while you were there?
12 A
(Urbanik)
No, sir.
13 0
Now, Doctor, did you obtain a copy of I-DYNEV7 14 A
(Urbanik)
I already had access to I-DYNEV.
15 Q
Where do you have access to I-DYNEV?
16 A
(Urbanik)
Through the Federal Emergency Management 17 Agency.
18 Q
They have a copy of I-DYNEV in Washington, is that 19 correct?
20 A
(Urbanik)
Yes.
21 Q
And do you have facilities that allow you to work at 22 Texas A & M using the FEMA I-DYNEV model?
23 A
(Urbanik)
Yes, I do.
24 But I also have from
-- FEMA also sent me a copy of 25 the I-DYNEV model.
~,
Heritage Reporting Corporation (202) 628-4888
l URBANIK - CROSS 7432 l
1 Q
So, you have received it from FEMA?
['];.,
(,
2 A
(Urbanik)
I believe so, yes.
l 3
Q When did you receive it from FEMA?
l 1
)
4 A
(Urbanik)
Oh, many, many months ago.
i 5
Q And can you tell me what year'it was?
6 A
(Urbanik)
I would guess it was about a year ago.
7 But I -- somewhere in the process of doing this we
]
J 8
got -- we had been using the system online, and then
)
9 subsequently we got a taped copy of it.
10 Q
Doctor, are you aware that the version of I-DYNEV l
11 that FEMA has, is not identical to the version that KLD I
12 utilized to conduct the ETE study here?
13 A
(Urbanik)
I understand that the version that FEMA is
.,7'n\\
14 using now, is, in fact, different, but the version of I-DYNEV
-Q) 15 that I have, I believe is the same model that KLD has.
16 FEMA has decided to try to broaden their use of I-l 17 DYNEV and expanded it into what they call, I guess, a regional 1
18 model that they are trying to develop for hurricane evacuation 19 and larger arenas.
20 And that is not the version of I-DYNEV that I have 21 been using.
22 Q
Now, did you also obtain copies, as Dr. Adler did, of 23 the inputs for the Volume 6 runs, and the outputs?
24 A
(Urbanik)
No, I did not.
25 (pause.)
T's
(
)
Heritage Reporting Corporation (202) 628-4888 4
l
{
l
URBANIK - CROSS 7433 rs 1
(. )
2 BY MR. FIERCE:
3 Q
Do you also have a copy for the source code for 4
I-DYNEV7
]
5 MR. TURK:
I am sorry, I did not hear the question.
6 BY MR. FIERCE:
l 7
O Do you also have a copy of the source code for I-8 DYNEV?
9 A
(Urbanik)
I believe one of the versions of the tape 10 that we got was a source code version of the model.
But I --
11 Q
I gather from your answer, that you haven' t really 12 exemined that carefully to be sure.
13 A
(Urbanik)
Well, the reason that I am aware of it is 14 because we had to compile it and get it up and operating on o 15 computer.
16 Our interest in the matter, we have never gone in and 17 done anything to I-DYNEV in terms of trying to make it 18 different, better or review the source code.
19 Q
So you have not conducted a review of the source 20 code?
21 A
(Urbanik)
Absolutely not.
22 O
And are you aware of whether anyone has conducted an 23 independent audit or review of the source code?
24 A
(Urbanik)
I couldn' t answer that unequivocally.
I 25 could not answer that without qualification.
Heritage Reporting Corporation u
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The manner in which FEMA became aware of and finally II 2
adopted I-DYNEV~ involved some of my involvement. FEMA 3
contracted with Battelle Memorial Institute to help them 4
develop a computer system and in the_ course of that, !
5 recommended that they consider the TRAFLO family of computer 6
models, of which I-DYNEV came about.
7 And they did-some evaluation in helping FEMA 8
construct a system.
So, in terms of reviewing the source code, 9
I can only speculate what Battelle may or may not have done, 10 but they are those kinds of people that you claim that I am 11 not, and they are the ones that did all the things to bring I-12 DYNEV into the world, for FEMA.
13 So, I would guess that a lot of the kinds of things 14 that you are alluding to, were, perhaps done.
But that is Just 15 my speculation.
16 MR. FIERCE:
I am going to ask that the speculation 17 be stricken from the record.
18 JUDGE SMITH:
No.
19 That was the type of question you asked, and when you 20 ask that question, in the first instance, does he know if 21 anyone else has evaluated it, you invited a speculative 22 response.
23 And it will remain.
24 BY MR. FIERCE:
25 Q
Doctor, did you use I-DYNEV in your evaluation of the Heritage Reporting Corporation (202) 628-4888
__-._____________________u
URBANIK - CROSS 7435 f.s i
KLD ETE study?
' L..
o JUDGE SMITH:
Of the what ?
3 Oh, KLD.
4 THE WITNESS (Urbanik):
No, I did not.
5 BY MR. FIERCE:
6 Q
Pnd did you anything else to conduct your review and 7
evaluation of this KLD ETE study?
4
(
8 A
(Urbanik)
Did I do anything, is that what you are i
9 asking me?
10 Q
Anything else?
11 MR. TURK:
At any time, or are we still in August of 12 1986, to September 1987?
13 MR. FIERCE:
That is correct.
14 MR. TURK:
What?
15 MR. FIERCE:
That we are --
16 BY MR. FIERCE:
17 Q
I am talking about his evaluation of the KLD ETE 18 study that was published in August of 1986.
19 So, from that date, specifically to evaluate this 20 model, in order to prepare your testimony in this case?
21 A
(Urbani k's You have asked me two different questions.
22 You have asked me, did I evaluate the model and did I 23 evaluate the study?
24 And those are two different questions.
Are you l
25 asking me both of those questions?
Heritage Reporting Corporation
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1 Q
I am asking you now, if you did anything else in that (j
)
\\,,/
2 period of time, as you conducted your review and analysis of 3
the ETE study?
l l
4 MR. TURK:
And we are looking beyond review of l
5 documents.
)
{
6 THE WITNESS (Urbanik):
The -- as a result of the 4
I 7
review, and my field trip, I made a call to Mr. Lieberman, to
~
8 ask him to explain the diagram at the I-95-Route 110 1
9 interchange, because I ws.s totally confused as to how that 10 could possibly work.
11 BY MR. FIERCE:
12 O
Were you satisfied with the explanation that he gave 13 you at that point?
,[
}
14 A
(Urbanik)
Yes, I was.
L/
15 0
You understand that it utilized the grassy median 16 strip with granite curbings, at that time?
17 A
(Urbanik)
That's part of it.
The other part has to 18 do with the, how you get around the concrete divider on Route 19 110.
20 Q
And what was Mr. Lieberman's explanation, at that 21 time?
22 A
(Urbanik)
I believe his explanation, at that time, j
23 was that the diagram was wrong.
l 24 That there was, you know, information missing, from 25 the diagram and that it was not correctly drawn, which was, in i
["'A j
'g
)
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l I
i URBANIK - CROSS 7437 i
fact, the case.
g 2
But that there would be some modification made to 3
that particular diagram.
4 O
So, he indicated that he would modify the diagram but 5
not modify the traffic flow, up and over that off-ramp, is that 6
correct?
7 A
(Urbanik)
He made no reference to changing any 8
capacities, that is right.
9 Q
And Dr. Urbanik, you would agree, would you not, that 10 without having a copy of I-DYNEV, excuse me, without using 11 I-DYNEV, in evaluat ing the ETE's generated here, by KLD, and 12 described in the ETE study, your evaluation Just is not very 13 effective, is it?
14 A
(Urbanik)
I would not agree with that, at all.
15 MR. FIERCE:
Your Honor, I would like to have this 16 document marked as the next Attorney General's Exhibit, and 17 because of the way we do this tag team operation here, I am not 18 sure what the number i s, and it may be number 10.
19 It is number 10?
20 The Court Reporter says that it is number 10.
21 JUDGE SMITH:
Yes.
1 22 MR. FIERCE:
Mark it as number 10 for identification.
23 JUDGE SMITH:
I am a little bit concerned cbout the 24 quality of it.
The one I have is perfectly readable but it 25 probably would not withstand much more replication.
Heritage Reporting Corporation
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But in any. event, for now, it is.
$(O%.. {'
N, 2
MR. FIERCE:
I apologize.
It was the best copy I was 3
able to come up with at the time, Your Honor.
4 (The document previously 5
referred to, was marked 6
for identification as 7
Massachusetts Attorney 8
General Exhibit Number 10.)
9 BY MR. FIERCE:
10 Q
Doctor, before I go into this document with you, I 11 Just want to backtrack one or two questions.
l 12 With respect to what you did, after you had that l
13 conversation with Mr. Lieberman, on the telephone isn' t it true l
-[
14 that then you wrote in your testimony, that was prefiled in 3
15 this case, a series of comments regarding the KLD study?
16 And this was not one of them -- a concern about the 17 intersection at I-95, and 110, isn' t that true?
18 A
(Urbanik)
Yes, that is correct.
19 MR. TURK:
If the next step is to move to this 20 document, I would like a few minutes to read it.
21 MR. FIERCE:
Pardon?
22 MR. TURK:
If the next line of questioning will 23 address this document, I would like a few minutes to read it 24 before we begin.
25 MR. FIERCE:
I am willing to give you as long as you Heritage Reporting Corporation
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URBANIK - CROSS 7439 l
1 like, Mr. Turk.
2 (pause while counsel examines document.)
3 MR. FIERCE:
Mr. Turk, are you ready to proceed?
4 MR. TURK:
Yes, I have been ready.
5 I have been waiting for you to proceed.
6 MR. FIERCE:'
I was waiting for some signal from you.
7 I am sorry.
8 BY MR. FIERCE:
9 Q
Dr. Urbanik, do you recognize this document, which 10 purports to be a letter, dated May 6, 1985, to a Dave Matthews 11 at the Nucinar Regulatory Commission that purports to be from 12 you?
13 A
(Urbanik)
Yes, I do.
14 Q
Did you write this letter?
l 15 A
(Urbanik)
Yes, I did.
16 Q
Did you mail this letter?
17 A
(Urbanik)
Yes, I did.
18 G
At that time, in May of 1985, is it fair to say that 19 you wanted to obtain a copy of the I-DYNEV model?
20 A
(Urbanik)
I guess that is probably a reasonable 21 assumption.
22 Q
And you wanted to be able to utilize the I-DYNEV 23 model for your work for the NRC in evaluating evacuation time 24 estimate studies, i sn' t that correct?
I think what you are saying is 25 A
(Urbanik)
I am not Heritage Reporting Corporation (202) 628-4888 l
(
URBANIK - CROSS 7440 i (S 1
probably not totally correct, in the sense of using it to y~
[
2 evaluate, but that I-DYNEV was likely to become the model that 3
was going to be used.
And if I were going to be testifying for 1
4 the NRC, I had to know whether I-DYNEV was any good, because l
5 FEMA would probably be endorsing this particular model.
l 6
So, I was not interested in I-DYNEV so that I could 1
7 go out and do comparison studies at all the sites in the United 8
States.
I saw I-DYNEV, as it says here, " clearly represents 9
state-of-the-art technology."
10 And we needed to make sure that because it did 1
11 represent that, that it was likely to see more and more use and 12 we had to be sure that that model was a good model, not that 13 that model needed to be --
14 Q
Dr. Urbanik, isn' t it true, at that time, you had
,s 15 already made up your mind, clearly, that that was a good model?
16 MR. TURK:
Your Honor --
17 JUDGE SMITH:
You did interrupt this time.
18 So, strike the question and let him finish and then 19 you can ask the question, but this time you interrupted, I 20 think.
21 THE WITNESS (Urbanik):
I lost my --
22 MR. TURK:
Your Honor, I would appreciate it, if 23 instead of interrupting in the future, if Mr. Fierce could 1
24 wait, and let the Witness finish.
He will get the answers he 25 is looking for, if he is patient.
/'"
Heritage Reporting Corporation
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URBANIK - CROSS 7441
(
(',
1 JUDGE SMITH:
He is not intentionally interrupting.
I 2
This is a problem that every examiner has and we Just have to 3
deal with it, as it comes up.
4 MR. TURK:
I understand it is a frequent problem for 5
questioners, but I would ask Mr. Fierce to please wait and 6
listen to the answer to the best possible extent that he can.
I 7
JUDGE SMITH:
All right, Mr. Fierce, go ahead witn 8
your question.
9 BY MR. FIERCE:
10 C
Dr. Urbanik, at the time you wrote this letter, you 11 had already made up your mind, hadn' t you, that this is a good 12 model?
13 A
(Urbanik)
Well it had the best foundation of any 14 model that had been used in evacuation time estimates, to tha 15 point.
16 I did see it as being state-of-the-art, but at the 17 same time, being concerned, expressing in this letter, sincere 18 concern that we couldn' t just, that I could not just come up 19 here, based on, knowing that it was state-of-the-art, and 20 testify that the model was any good.
21 So, yes, it was the best, at that time, but I was 22 concerned.
I had deep concern that I could not just come here, 23 based on the fact that it was state-of-the-i.et, and say it was 24 good model.
25 We could probably save a lot of time -- I could tell
~
Heritage Reporting Corporation (202) 628-4888
{
l
._ ______ a
t
)
URBANIK - CROSS 7442 l
l 1
you, they funded this study and we did the work and we are
. g y-s f
)
1
(,,/
2 ready to publish the report.
j 3
Q And Dr. Urbanik, isn' t the focus of this letter, your 4
ability to continue to be effective as a Witness for the NRC 5
Staff, in hearings, licensing proceedings, which involve
)
6 disputes with Interveners or perhaps with FEMA, as well, over l
7 evacuation t ime studies?
)
1 8
A (Urbanik)
Yes, and if NRC had not funded this study, l
9 I would not be here today and that is what this letter says.
I 10 So, I am no hack.
]
11 0
Dr. Urbanik, you have written and said before, in 12 evaluating evacuation time estimate studies, the model, itself, 13 is not as critical as the assumptions that go into it, haven' t
[
14 you?
15 A
(Urbanik)
Absolutely.
l l
16 O
And isn' t the thrust of this letter, the notion that l
17 in the future, with I-DYNEV, the fights are going to be over l
18 the. assumptions that go into the model, isn' t that correct?
19 A
(Urbanik)
Yes, I believe that is correct.
20 Q
And in order to be able to participate effectively in l
21 that debate, you are going to need to have I-DYNEV in order to 1
22 be able to test those assumptions, as other parties would 23 likely be doing, so that you could compete in that debate, at a 24 level of sophistication, those other parties were at, isn' t 25 that true?
Heritage Reporting Corporation s
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A (Urbanik)
Certainly you had to know the answers to.
2 those kinds of questions to be a credible Witness, yes.
3 You had to do the research.
What we proposed was a 4
research study, answer the questions.
5 Q
What was the study that the NRC funded you to do?
6 A
(Urbanik)
Well, it has two aspects.
One aspect of 7
the study was a small validation of the model against real 8
traffic data, where what we were wanting to confirm or deny was 9
whether or not the model could replicate real life traffic 10 under heavily congested conditions.
11 The other part of the study was a sensitivity study 12 to look at how transportation networks, at generic nuclear how ETE's at these generic nuclear 13 power plants affects 14 power plants are affected by different assumptions so that yo 15 could have an idea of how the model -- you get two things out 16 of it -- how the model works and also how sensitive the 17 estimates are to the various assumptions, because clearly, it 18 has been unfortunate in this process, that we spent a lot of 19 time arguing over the model when the model really shouldn' t be 20 the issue.
21 The issue really should be the numbers going into the 22 model.
23 Q
This study was completed when, Dr. Urbanik?
24 A
(Urbanik)
Well, it is not complete.
We Just ran out 25 of money.
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Q You mentioned a report.
\\
2 A
(Urbanik)
Well, we are in the process of drafting 3
the report.
The report-is not yet in draft. form.
My 4
colleague, Matt Moeller at Battelle, and I, have both been 5
extremely busy with other matters in recent months and have not 6
been able to get the final draft of the report complete.
- 7 MR. FIERCE:
Can I request, Mr. Turk, that we be 8
provided with a copy of this report, as soon as it is even in 9
draft form?
10 MR. TURK:
Yes, as I had previously committed to the 11 Massachusetts AG, as soon as that draft is in final. publishable 12 form, it will be distributed to all parties in the proceeding..
13 MR. FIERCE:
I am asking for a copy of the first 14 draft, Mr. Turk?
15 MR. TURK:
No, I cannot and will not send out 16 incomplete drafts which have not yet reached approval stage.
17 BY MR. FIERCE:
18 Q
So, Dr. Urbanik, you have not evaluated specifically, i 'd this site-specific input assumptions that were made in the KLD 20 ETE study for Seabrook, have you?
21 A
(Urbanik)
Yes, I ha.ve.
22 Q
But you haven' t evaluated the sensitivity of those 23 input assumptions in I-DYNEV, for Seabrook, have you?
24 A
(Urbanik)
I think that the Applicant has done the 25 more than adequate Job of doing sensitivity studies.
( ~
Heritage Reporting Corporation (202) 628-4888
)
I URBANIK - CROSS 7445 1
Q I am asking what you have done, Doctor?
-)
a?
2 A
(Urbanik)
No, I have not.
3 In the second -- I need to qualify.
No, I have not 4
done sensitivity studies.
I have certainly looked at, in great 5
detail, the input assumptions that go into an ETE at Seabrook.
6 Q
You have looked at some of the generic input 7
assumptions, i sn' t that correct?
8 A
(Urbanik)
No, not at all.
Some of the specific 9
inputs, like population, roadway capacity, things of that 10 nature.
11 Q
Did you evaluate the input assumptions about the 12 capacities at the I-95-Route-110 interchange?
13 A
(Urbanik)
Yes, I evaluated their reasonableness.
14 I did not do a site-specific study.
That is not wh 15 the guidance is intended to have you do.
16 Q
And isn' t it true that I-DYNEV routes the traffic in 17 the Volume 6 runs that are for the ETE's contained in Volume 6, 18 through that interchange by having approximately equal 19 percentages of the traffic taking the right-hand turn on the 20 up-ramp, and the left-hand turn around the median and over the 21 grassy median on to Route 95?
22 A
(Urbanik)
I don' t have the out puts, so I cannot 23 comment on the numbers.
The routings, I believe, as indicated 24 in Volume 6, is that the split prior to actually simulating it, 25 is to direct the traffic on 110, I believe it is straight Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7446 f^7 ~s 1
through and that it is only when the straight-through traffic q
\\
2 is congested.that we then get traffic turning left over the 3
median.
4 But I am doing that from recollection.
It is true 1
1 5
that vehicles are going to cross that grassy median and I would 6
add, as simulated.
7 0
Isn' t it true, Doctor, that 100 percent of the
)
8 vehicles are routed, are split, as you call it, either right or 9
left on to one of the two rampways on to I-95, and that is, in 1
10 fact,. demonstrated by the Table in Volume 6, in Appendix N?
11 A
Well, why don' t 12 MR. TURK:
May the witness open the volume and --
13 THE WITNESS (Urbanik):
Yes, why don' t we go to that?
14 JUDGE SMITH:
Would you give me a citation?
15 MR. FIERCE:
Well, it is in Appendix N, as the turn 16 percentages.
And I am asking the Doctor, if he can show me 17 where he sees in there, any traffic going straight through?
i 18 THE WITNESS (Urbanik):
- Well, let's first establish 19 the link.
Is it link 93-457 20 (Pause.)
21 THE WITNESS (Urbanik):
It is pretty hard to work off 1
22 of thisi it is a small link node diagram, without actually 23 drawing it on.
24 If we have the right link, with 93-45, which is 1
25 listed as Route 110 west, says, 51 percent through, 49 i
l
~k,)
Heritage Reporting Corporation l
(202) 628-4888 o
URBANIK - CROSS 7447
,r s, 1
diagonal.
2 That may not --
3 BY MR. FIERCE:
4 Q
Are you through with your answer, Doctor?
5 A
(Urbanik)
I am having, I guess I am getting old 6
here.
I am having a lot of trouble with my eyes here.
Do we 7
have a bigger link node diagram that we can --
8 M R.
TURK:
If I may ask, can Mr. Fierce point the 9
Witness to whichever link node he wishes him to examine?
10 MR. FIERCE:
I am asking the Witness to see if he can 11 show me, where, in this turn, in the turn percents here, where 12 he can find me the link that shows what he believes to be the 13 case?
14 The traffic is going through that intersection --
15 THE WITNESS (Urbanik):
Well, I would need the bigger 16
-- there is a bigger version of this link node diagram that I,
17 you know, work from.
So I am having troubles seeing the coding 18 of an interchange.
19 BY MR. FIERCE:
20 Q
Okay, so your answer is that you cannot really see j
21 it, you are having trouble using this smaller l
22 A
(Urbanik)
Right.
23 0
-- diagram.
24 A
(Urbanik)
The traffic control diagram clearly says 25 that it is routed, that traffic at that location is routed Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7448
(<Jys 1
left.
)
\\s /
2 Q
I am sorry, I did not hear that answer.
3 A
(Urbanik)
The diagram for traffic control, which is 4
5 Q
It is on Page I-19, isn' t it?
6 A
(Urbanik)
Yes.
7 Q
And it shows all traffic either being routed to the 8
right or the left, doesn' t it?
9 A
(Urbanik)
That is correct, yes.
10 Q
And when you called Mr. Lieberman and discussed this 11 intersection, that was your assumption, wasn' t it?
12 A
(Urbanik)
Yes, it was.
13 Q
And you did not bother to check the I-DYNEV code, did O
14 you, to see, whether in fact, that was what was happening at 15 the model in that intersection?
16 A
(Urbanik)
Well, no, I did not.
17 O
And Dr. Urbanik, are there other specific input 18 assumptions of that sort that you checked on, when you did your 19 review of I-DYNEV in Volume 6, for purposes of preparing your 20 testimony here?
l 21 A
(Urbanik)
I don' t understand the question.
22 Could you either repeat it or rephrase it?
23 Q
Well, this is a very site-specific input assumption, i
24 wouldn' t you agree?
25 A
(Urbanik)
Yes, sir.
I O\\
f('~'/
Heritage Reporting Corporation (202) 628-4888 i
l l
l
l I
I URBANIK - CROSS 7449 1
Q And I am asking you if ycu did any other site-g ~s
'i. '
2 specific checks, of input assumptions like this, in conductin 3
your review of the Volume 6, ETE study?
4 A
(Urbanik)
Well, in the broad sense, yes.
In terms 5
of population, I went back to NUREG-2903 to see what our 6
previous estimates for the site were.
7 Certainly reviewed the traffic control, which I have 8
stated, that is all site-specific.
9 Q
And Dr. Urbanik, you are not an expert in demography, 10 are you?
11 A
(Urbanik)
No, sir.
12 Q
Do you know when that other population study was 13 done?
14 A
(Urbanik)
Approximately in 1981.
15 Q
So you are not offering expert testimony on whether
~
J 16 that population study has any relevance to the ETE study 17 conducted here, are you?
18 A
(Urbanik)
Well, it certainly has relevance.
19 Q
But Dr. Urbanik, how does the review of the 1981 20 population study help you assess the adequacy of a population 21 input, to an I-DYNEV run, made in 19867 22 A
(Urbanik)
Because we' re reviewing, we are not doing 23 the study, so that we are not developing our own estimate.
24 Although we did that particular time, develop an estimate.
25 Populat ions don' t just change dramatically without some other Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7450 1
indicators indicating what is going on.
l r v ~h IV!ss/
2 So, it is a definition of what the population in the 3
EPZ, and NRC's estimation was, at that point in time, and we 4
look at traffic counts, changes in the permanent population and 5
look at the other indicators to see if there is a reason to 6
believe that there is significant growth taking on in the area.
7 So, based on all available information, you make an 8
informed Judgment as to the reasonableness of the input 9
assumptio" l
10 Q
Ts it your position that there was or there was not i
11 significant growth that occurred in the area, since 19817 12 A
(Urbanik)
There has been growth in the area.
There 13 has not, based on what I have seen, been significant amounts of fh 4
)
14 growth in the beach area.
l T.%d l
15 Q
But you are not an expert demographer in population l
16 in southeastern New Hampshire, are you?
17 A
(Urbanik)
I think that you asked me that question 18 and I will try to answer it the same way.
No, I am not.
19 Q
So, when you say, use the term, reasonable, you are 20 offering a lay opinion, aren' t you?
I
- 21 MR. TURK:
Your Honor, I think that is asking for a 22 legal conclusion.
2,3 JUDGE SMITH:
No, it is not.
It is asking for a 24 conclusion within his ability to answer it.
25 THE WITNESS (Urbanik):
No, I don' t consider myself a Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7451 g:3 1
layman in this area, of evacuation time estimate studies.
,1 i
2 BY MR. FIERCE:
3 0
Well, I am a layman and I would assume, perhaps, 4
there is some growth going on in the area.
t I
5 I would look at the population study from 1981 and I 6
would look at some population figures that might be used, in d
I 7
1985, and 1986, and if they were a little bit higher than I saw 8
in 1981, and I think that is reasonable.
9 Now, what did you do that was more than that to 10 conclude that its use of the number for population in the study 11 in 1985, or 1986 was reasonable?
12 A
(Urbanik)
I reviewed all of the information in the I
13 licensee's study that indicated the methodology and the data 14 bases that he used to derive his estimate.
15 Q
But you have no independent source where the source 1
16 of information, whether the data that was included was 17 accurate, is that correct?
18 A
(Urbanik)
I have no independent study of the 19 population in the EpZ, that is right.
20 Q
And with respect to the beach population, the 21 methodology that you saw there, in the ETE study that you found 22 to be appropriate and reasonable, was the methodology for 23 counting cars, and spaces, isn't that correct?
24 A
(Urbanik)
Cars and spaces that there was an l
25 expectation that could be filled, yes.
l Heritage Reporting Corporation
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Q Now, Dr. Urbanik, with respect to this letter, in the
{'
2 first sentence it reads, "I believe that we need to move ahead 3
in the area of evacuation time estimate studies as they relate 4
to current technology in general, and I-DYNEV, in particular."
5
" Based on my experience in licensing hearings and 6
other events like Maine Yankee, it is time to move ahead in i
7 order to avoid potential future problems for NRC.
I do not l
I 8
believe that I can continue to be effective for NRC Staff if we 9
do not address some fundamental issues, underlying how 10 evacuation time estimate studies are done, and how FEMA will 11 affect present and future evacuation time estimate studies."
12 Doctor, what were the potential future problems for 13 the NRC that you were referring to there?
14 A
(Urbanik)
Well, in the Maine Yankee case, FEMA took 15 the I-DYNEV model and input somebody's number that they said 16 was the number with no basis, and they came up with a huge 17 evacuation time estimate for the Maine Yankee plant.
18 Q
What is a huge number, in your opinion, Doctor?
19 A
(Urbanik)
I am guessing in the 29-hour range, but I 20 don' t remember what the number was.
A 21 Q
So did you say that someone had obtained I-DYNEV and 22 put a --
23 A
(Urbanik)
No, no, FEMA had.
FEMA made a run by just 24 plugging numbers into the model, without regard to how to do 25 it.
Heritage Reporting Corporation (202) 628-4888
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)
URBANIK - CROSS 7453 l
l 1
You know, sort of a garbage-in-garbage-out approach f7x 2
Q And what was the problem for the NRC7 3
A (Urbanik)
Well, we had to spend a lot of time going 4
back and getting everything -- the whole process had to be 5
repeated all over again, and a new study done, and --
6 Q
The problem was that the NRC was not able effectively 7
to present an opposition to that position in that proceeding, l
8 isn' t that correct?
9 A
(Urbanik)
The number was not reasonable.
It was not 10 a question of opposition.
It was a question of getting the 11 process to work correctly.
12 There is no number that we are searching for, believe 13 me.
14 Q
And Doctor, that last statement is not exactly what 15 you meant, isn' t it?
You are searching for the accurate 16 number.
There is a number that you are searching for?
17 A
(Urbanik)
Yes, I am sorry, I appreciate that 18 correction.
19 Yes, we are searching for the correct number, without 20 any preconceived notion on what it should be.
21 Q
How would you describe generically what that correct 22 number is?
23 Is it, for example, the most accurate number that can 24 be obtained using all reasonable sources of information that 25 prudent planners would use?
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A (Urbanik)
The best number that we can come up with 2
using all reasonable sources of data, realizing that a number 3
of things that go into the estimate are not known with absolute I
4 certainty.
5 Q
But if there are things that are reasonably easy to 6
know, and prudent planners would want to know them, shouldn' t 7
they be included in an ETE study?
8 A
(Urbanik)
If there are numbers, or situations that 9
are reasonably obtained, and we can know with reasonable 10 certainty that they are accurate, yes.
i l
11 There is nothing that would summarily be dismissed, I I
12 don' t believe.
l 13 Q
Well, it's more than that, isn' t it?
14 I am suggesting that if there is an uncertainty, with 15 respect to a factor that is used as an input in ETE study, and 16 it is reasonably able to resolve that uncertainty -- not l
l 17 without, you know, using methods that are not extraordinarily 18 costly or time consuming -- but if it is a piece of information i
19 that can be obtained reasonably, so that that uncertainty can i
20 be resolved, that should be done in an evacuation time study, 21 shouldn' t it, in order to produce those reliable and accurate 22 numbers that we are talking about?
23 A
(Urbanik)
I don' t have any problem with your 24 characterization.
I think that you may get to a specific 25 example, we may disagree.
Heritage Reporting Corporation (202) 628-4888
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Q Let me go on in the letter.
,73 KJ' 2
The next paragraph, it says, " Historically, 3
evacuation time estimates were defended against criticism that 4
they were too low.
We have apparently driven that point home 5
and the current contentions often deal with the relevance of 6
assumptions."
7 "As you might easily conclude, it is more difficult 8
to defend the absolute magnitude of assumptions. than it is to 9
defend their reasonableness.
That is to say, it is easier to 10 convince someone that an estimate is not low, than it is to 11 convince someone that an estimate is accurate."
12 Do you still believe that today, Doctor?
13 A
(Urbanik)
I guess I would.
14 Q
And isn' t that the case with -- are you finished?
15 A
(Urbanik)
Yes, I am.
16 Q
And isn' t that the case with this proceeding here, 17 Doctor, that many of the contentions regarding the ETE study 18 have to do with the accuracy of the assumptions and inputs 19 rather than their reasonableness?
20 A
(Urbanik)
I would not totally agree with that.
No,
\\
21 I would not.
22 Q
But many of the contentions here, are challenging the 23 accuracy of certain input assumptions, isn' t that true?
24 A
(Urbanik)
Why don' t you give me a list and we can 25 take them one at a time?
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1 Q
Doctor --
_/
2 A
(Urbanik)
I am trying to say that there are some 3
that I would agree are issues of accuracy.
I don' t think that 4
the ones that are issues of accuracy are by and large, the 5
great majority of them.
6 I think most of them are a question of reasonable.
7 Q
Doctor, I may be assuming something here, so I am 8
going to ask the question straight out.
9 I did not hear you mention, when you listed the 10 things that you looked at, in conducting the ETE study, that 11 you had looked at the contentions.
12 I guess that I assumed that you did that.
13 A
(Urbanik)
Oh, I did.
(
14 Q
And you are aware, for example, that certain
\\
15 contentions challenge the assumptions made about the reduction 16 factor for snow and rain.
17 A
(Urbanik)
Right.
18 Q
Now, those contentions may or may not,, I, don' t have 19 them in front of me, say that the factors that were used are 20 not reasonable, but the assumption implicit in that is that 21 they are not accurate and ought to be higher than that, isn' t 22 that correct?
23 A
(Urbanik)
I don' t believe so.
Let me take that 24 example and try to put it in the context that you are leading 25 me to believe that you want me to accept.
A Heritage Reporting Corporation g
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In the case of a capacity reduction for rain, the 2
numbers that we have are certainly reasonable based on the 3
available data.
The research that would be required to develop 4
a more accurate snodel of rain-reduced capacity, would be 5
phenomenal.
6 So, getting that one more accurate than it is is 7
going to take a tremendous effort that would not meet your 8
other test of reasonableness.
9 Q
You could get better information than we have now, by 10 using some measurements conducted, site-specifically, in a few 11 rainstorms in the EpZ, couldn' t you?
12 A
(Urbanik)
Not as easily as you would think.
First 13 of all, you need to have a lot of traffic because we are 14 measuring capacity and the only way that we can measure 15 capacity, is to measure capacity when there is lots of traffic.
16 So, the first prerequisite of your study, is that I 17 have to have a lot of traffic.
Then the next prerequisite i s, 18 that I have to know when it is going to rain, and in order to 19 do that, then I either have to have people Just paid every time i
20 we anticipate it is going to rain, have them standing out on 21 the corner, waiting and hoping it is going to rain, on that day 22 that we also hope that it is going to be busy.
23 Then we are going to have to replicate this study 24 several times.
So collecting that data is difficult.
That is 25 why there aren' t -- if it were a simple thing, the literature Heritage Reporting Corporation
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1 would have picked it up a long time ago.
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2 Q
But you don' t disagree with my premise that you could 3
gather helpful information by looking at the data collected on 4
a couple of busy days in the rain, isn' t that correct?
5 A
(Urbanik)
No, I don' t totally agree with that.
6 You are trying to change the expectation of the 7
accuracy of the ETE by collecting what you say is a little 8
data. What does a little data do to help improve the accuracy 9
of a number that is based on a lot of inputs, unless that 10 number that you are going to give me can be set with great 11 precision is better than the one I am using.
12 Q
Let me talk about snow for a minute, Doctor.
13 JUDGE SMITH:
Well, let's take up snow, after the 14 morning break.
15 Ten minutes, please.
16 (A brief recess was taken.)
17 JUDGE SMITH:
Back on the record.
18 Mr. Fierce?
19 MR. FIERCE:
Thank you, Your Honor.
20 Give me a break and I think of another question, so I 4
21 am going to go back to rain before I get to snow.
22 BY MR. FIERCE:
23 Q
With respect to rain, Doctor, in August of 1983, you 24 testified in proceedings related to Seabrook, that you had 25 reviewed what was then the Applicants' EPZ submittals in 1980 Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7459 (5
1 and 1981 and found a deficiency in them, in that they did not 2
include a summer adverse weather scenario, do you recall that 3
A (Urbanik)
Yes, I do.
1 4
Q And do you recall in your testimony, that you 5
recommended that the deficiency be resolved by doing an 6
additional computer run, using a reduced road network capacity 7
of 20-to-30 percent to account for a rain-induced capacity 8
reduction?
9 A
(Urbanik)
It sounds like I probably said that, yes.
10 Q
Would you like to see a copy of your testimony to 11 refresh your recollection?
12 A
(Urbanik)
I think that I have one.
13 MR. TURK:
Can we ask for a page reference, please?
14 MR. FIERCE:
Yes, it is the transcript from Thursda m.
15 August 18th, 1983, and it is on page 3, the top line of Dr.
16 Urbanik's testimony which is bound into the transcript after 17 page 1304.
18 THE WITNESS (Urbanik):
Yes.
19 I see that reference and I agree that that is what I 20 said.
4 21 BY MR. FIERCE:
22 O
Now, with respect to ETE's, Dr. Urbanik, what do you 23 consider to be an appropriate degree of accuracy?
24 Do you understand my question?
25 A
(Urbanik)
Yes, I do.
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I think what we strive for is something in the t
2 neighborhood of 10 percent.
Whether or not we achieve that, I 3
don' t think we know with any certainty.
4 Q
Did you also agree with me that -- a minute ago --
5 the ultimate goal is to obtain, isn' t it, the most accurate, 6
reliable ETE that you can, using, by examining all of the 7
information that one can reasonably obtain, regarding the
=
8 uncertainties, in order to give us that number?
9 (Pause.)
10 A
(Urbanik) I am trying to perceive if that is any 11 different than the question that has,been asked before.
12 JUDGE SMITH:
That was our impression too, Mr.
13 Fierce, that --
14 MR. FIERCE:
There was no intent to make that a 15 different question, here, Your Honor.
16 JUDGE SMITH:
Oh, okay.
17 MR. FIERCE:
It was intended to be the same point, I 18 think I tried to elicit earlier.
19 THE WITNESS- (Urbanik) :
We' re trying to make the most 20 reasonable estimate we can, using those data sources that we 21 can either have or find and apply to the particular case, 22 realizing that there is uncertainty and realizing that 23 estimates are being used, in a context that is going to require 24 final interpretation in their application.
25 So, it is not a number that someone is going to go to N$1 Heritage Reporting Corporation
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l URBANIK - CROSS 7461 (S
1 the chart and say, the answer is here, use it.
l 2
BY MR. FIERCE:
3 Q
But you believe that there is a range of uncertainty 4
here.
You expressed it in your testimony in 1983, a 10 percent 5
variation between 20 and 30 percent, isn' t that true?
6 MR. TURK:
Twenty to 30 percent of what?
7 MR. FIERCE:
This is a capacity reduction factor, 8
that Dr. Urbanik recommended be applied in an additional 9
computer run, to determine the adverse weather ETE's.
10 BY MR. FIERCE:
11 Q
And before I put another question to you, to clarify 12 the record, isn' t it true, Doctor, that reduction factor, when 13 it is applied will have a direct linear relationship on the 14 ETE's?
15 A
(Urbanik)
It doesn' t necessarily have a direct 16 linear relationship, it may.
17 Q
Well, if you have the crucial link in the entire 18 network, the one that empties last, and you apply a reduction 19 factor, in that range, say, 25 percent, doesn' t that mean that 20 the computer will generate a number of hours, for that ETE, 21 which is either 25 percent longer exactly, or very darn close 22 to that?
23 A
(Urbanik)
Right.
24 Assuming that that link is, in fact, satursted for 25 the entire period of the simulation, which is not necessarily l
Heritage Reporting Corporation (202) 628-4888 3
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the case. So that is why I qualified the answer.
1
((
l 2
O For Seabrook, we know that the critical paths, and we 3
know have a couple of them, depending on which beach population 4
average you would take a look at, either the Route 51 path, or 5
the Route 110 path, are going to be saturated throughout the 6
entire length of the evacuation, and therefore, for our 7.
purposes of discussion, the application of a 25 percent 8
reduction factor, would directly affect the length of the ETE's 9
by increasing them 25 percent, isn' t that true?
10 A
(Urbanik) Not in an absolute one-to-one relationship.
11 Q
Well, I said, or pretty darn close.
12 A
(Urbanik)
For Seabrook, given the congested nature 13 and if we are talking about the estimate that comes out of the
/
14 simulation model, yes, the numbers -- there is going to be a 15 pretty close relationship between the capacity reduction and 16 the time estimate.
17 Q
And so my point was, with respect to the variation, a 18 20-to-30 percent, that is a 10 percent variation potentially in 19 the length of the ETE's, i sn' t that correct?
20 A
(Urbanik)
That is correct.
21 Q
That is an uncertainty here, isn' t it, Doctor, what, 22 in fact, will happen under an adverse weather.ETE scenario?
23 A
(Urbanik)
There is a huge amount of uncertainty.
24 The estimate is prepared on the basis, for example, of 25 assuming, in the analysis to generate a number for the Heritage Reporting Corporation (202) 628-4888 s
URBANIK - CROSS 7463 1
decision-maker, that it is raining for the entire period of t 2
evacuation.
3 You may, as a decision-maker, have that estimate and 4
the other estimate and pick a number in between and reflect the 5
fact, that, hey, a storm is moving i n, this storm this morning l
6 was predicted and so you may pick another number as the number 7
you are utilizing.
8 So, yes, you have to realize that the estimates are 9
based on a number of assumptions, and use that in the decision-10 making process.
11 Q
But whatever the assumption is that you decide to 12 utilize, and here, the assumption is, rain throughout the 13 period of the evacuation.
Your suggestion in 1983 was to run 14 it with a reduction factor of 20-to-30 percent.
15 And I am again asking you i sn' t it possible to reduce 16 that range of uncertainty by doing some reasonably costly, 17 site-specific studies that would give you a more accurate 18 handle on what that exact number is?
19 A
(Urbanik)
You could come up with another number that 20 was site-specific doing a very costly study, and probably 21 reduce the uncertainty.
22 Q
I sn' t it true that what happened here, is that given
~
23 your recommendation that a rain-reduction factor be applied in 24 the carge of 20-to-30 percent, that the Applicants here -- or 25 excuse me -- the State of New Hampshire here, in adopting the Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS.
7464 1
KLD ETE. study has adopted the low end of that range, the very
\\
2 low end of that range, 20 percent?
3 A
(Urbanik)
That.is the Judgment that they made, yes.
4 Q
And generically when you have a situation like this, 5
Dr..Urbanik, and you have a situation where there is a range of 6
uncertainty, and you have a 10 percent range, wouldn' t a 7
prudent planner, pick a number to use, that is somewhere.in the 8
middle of that range, if he could not resolve that uncertainty 9
in any way?
10 A
(Urbanik)
I would have to go back and look at the j
11 data to determine if today, in 1987, I would agree that the 12 20-to-30 percent was, in fact, the appropriate range.
13 If the data showed that range to, in fact, be the 14 case, I might pick 25, yes.
15 Q
Dr. Urbanik, with respect to onow, the KLD study 16 here, utilizes a 25 percent reduction for snow, does it not?
17 A
(Urbanik)
I would have to look.
It sounds like --
18 do you want me to confirm that?
19 Q
Well, before you confirm that, Doctor, do you think 20 that is a reasonable number, off the top of your head, based on 21 your knowledge and experience?
22 A
(Urbanik)
Yes, that is in the -- off the top of my l
23 head -- in the range, yes.
l 24 Q
What do you believe the appropriate range to be?
25 What is the range of uncertainty here?
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1 A
(Urbanik)
Well, the range of uncertainty here, in 2
the -- what is the context?
3 Q
Well, we want to run an adverse weather, adverse
)
4 winter weather run on I-DYNEV, and we want to assume an 5
appropriate reduction factor for snow conditions that would 6
occur throughout that evacuation.
7 And let's talk about snow conditions that are more 8
typical to New England, than what we saw this morning, which 9
most of us disregarded entirely, it was so light.
10 A
(Urbanik)
You may disregard it, but it does have an 11 effect on capacity.
12 Q
Well, I imagine that it would have some effect, but 13 when I am talking about a snowfall in New England in the real 14 winter, which we are not in yet, and a snowfall that occurs 15 over the course of half a day I understand that there may 16 be a snowfall today that may hit portions south of us, and dump 17 in the eight-to-10-inch range.
18 And that is a typical New England winter nor' easter.
19 Let's make it a real snowstorm. What is an 20 appropriate reduction factc.r to apply for that adverse weather 21 scenario?
22 MR. TURK:
Can I just get a clarification?
l l
23 What is the scenario that we are contemplating?
24 JUDGE SMITH:
Yes.
25 I don' t think that is clear.
What is --
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1 MR. FIERCE:
Adverse winter weather -- it could be -
.g{
they have various weekend, weekday, but the reduction factor 2
3 that would be applied would be the same, whether it is weekend, 4
weekday, if we have the adverse winter storm conditions, 5
existing throughout the length of the evacuation.
6 MR. TURK:
And my only question is, I am not sure if l
7 we have established what this adverse weather condition is.
1 l
8 Is it that which was modeled in the KLD study or is i
9 it an eight-to-10-inch snowfall?
10 MR. FIERCE:
No, I was asking a hypothetical.
11 MR. TURK:
Yes.
12 I just want to understand wnat-the assumption is.
13 JUDGE SMITH:
That is not clear to me.
14 MR.. FIERCE:
Do you want me to explain it again?
15 It is an evacuation of the entire EpZ --
16 JUDGE SMITH:
If it is the hypothetical, what is not 17 clear is the type of snowstorm.
1 L
18 MR. FIERCE:
I call it a real New England snowstorm.
19 JUDGE SMITH:
I heard what you said.
l 20 MR. FIERCE:
A nor' easter, and it is going to last 21 throughout the length of the evacuation.
It will leave an 22 accumulation, when it is through, of in the range of eight to 23 10 inches.
24 THE WITNESS (Urbanik):
This 10 inches of snow is --
25 I am trying to make sure that we absolutely agree on what the l
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1 conditions are, so that we can -- this eight to 10 inches of 2
snow is going to just begin at the time that the evacuation 3
begins, or has it been underway for some period of time?
4 In other words, I have to know something about what 5
the road is like -
you know, tell me more i n t erms o f --
6 BY MR. FIERCE:
7 Q
Okay, let's assume that it has begun, we are not 8
going to make it that coincidental that it would begin the 9
moment the sirens sound.
10 But let's assume that it has begun snowing in the 11 afternoon, the plows are out, the roads are clear.
It has not 12 been snowing that long and then an accident occurs.
It 13 continues snowing, it continues snowing through the evening as 14 the evacuation ensues, and continues snowing through the peri 15 when the evacuation would end.
16 A
(Urbanik)
As long as the conditions were such that 17 the roads remained clear, to the extent that they are passable, 18 not that there is not snow on the pavement and not that it is 19 not wet, then the appropriate reduction is probably in the 20 neighborhood of about 30 percent, j
21 Q
And if you made another assumption, which is that 22 there were no plows out, during the evacuation, what would your 23 assumption be?
24 A
(Urbanik)
Well, as a decision-maker, I am going to 25 have to -- this is why you get back to the decision-making part O1 Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7468 r
1 of the process -- you decide whether or not the condition can d
2 be achieved.
3 If the snowplows therefore, are not going to be 4
there, and you cannot maintain the capacity of the roadway, 5
then the ability to estimate the time is modified by your need 6
to do something to make the roads passable,
=
7 Q
I agree with that, but I am talking about, at this 8
point, we are doing the ETE study and I am doing a run.
9 Whether it is the run for the time or a sensitivity run, and I-10 want to do a run like I have just. -- with conditions like I 11 have Just described -- where the snowplows are not out during 12 the evacuation.
13 Do you have any data, sources that you know of that 14 provide us information with what an appropriate capacity
(
15 reduction factor would be under those circumstances?
16 A
(Urbanik)
No, I don' t and that is not the premise on 17 which the ETE is done.
18 Q
Is it the premise on which the ETE is calculated in 19 this ETE study?
20 A
(Urbanik)
The premise that is used in all ETE 21 studies, is to reduce the capacity, to represent a condition 22 where roadway capacity has been reduced due to the adverse 23 weather, but the road is still, nevertheless passable, usable.
24 If that is not the case, then you are going to have 25 to factor in, to your estimate, at the time.
We cannot
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URBANIK - CROSS 7469 i
(7 1
possibly construct thousands upon thousands of ETE's to 2
represent every conceivable scenario.
You have already got 5 I
3 separate estimates, of ETE.
You get to the point where you are 1
4 overburdening the decision-maker with too much data and not 5
enough information.
6 And the ETE's frame some data points, and then a l
7 decision-maker looks at those data points, and makes his 8
decision.
9 Q
This is supposed to be an adverse weather scenario, 10 isn' t it?
11 A
(Urbanik)
Right.
12 Q
Are you aware that in New England, many of us would 13 not consider the conditions that you just described as adverse 14 at all?
15 A
(Urbanik)
I understand that.
But I don' t understand 16 what the point is.
17 Q
Well, isn' t the point in doing an ETE study for 18 adverse winter conditions to model those conditions which are 19 likely to exist during adverse weather, not something which is 20 reasonably mild in scope and duration?
21 JUDGE SMITH:
Is your question now following up your 22 series of questions?
23 It seems to me that your successive questions ignore 24 his answers.
25 Are you going to deal with his statement, his Heritage Reporting Corporation (202) 628-4888
URBANIK.- CROSS 7470
'(gCf s-1 testimony, that you begin with passable roads,.or are you going 2
to put that back to him or-whatever?
4 3
You should clarify.
4 BY MR. FIERCE:
5 G
You are familiar with NUREG-0654, Appendix 4, aren' t
=
6 you, Doctor?
7 A
(Urbanik)
Yes, I am.
8
-O Do you have a copy before you?
9 A
(Urbanik)
No, I don' t.
10 0
Well, let me, so as not to cause substantial 11 disruption, read you the sentence and see if you can recollect 12 that it is part of NUREG-0654, with respect to the analysis of 13 evacuation times, Part 4, under -- well it is on Page 4-6, is j
14 where I am reading.
15 Under Subparagraph A, reporting format, down about 16 four. sentences, there is a sentence which reads: "The adverse 17 weather frequency used in this analysis, shall be identified 18 and shall be severe enough, to define the sensitivity of the l
19 analysis to the selected events."
20 A
(Urbanik)
I see that and essentially a road that has 21 snow on it, but is still usable, is the one that reaches that 22 critical case.
Once you get past the point of being passable, 23 the ETE goes up by another factor which is the amount of time 24 to return the road to the state that is passable.
25 So, we are defining, in our analysis, using this 30 Heritage Reporting Corporation s
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URBANIK - CROSS 7471 1
percent number, the upper range of a capacity reduction that 2
exists, when the roads are snow-covered but still can be used.
3 The next condition which moves into a new arena, is 4
hey, the roads are no longer passable.
Now, you are in a new 5
ballgame and the capacity number is not relevant.
6 Q
Well, this may be a problem of a Texan coming to New 7
England.
In New England -- we have said this before at the 8
hearings -- we believe that there is a substantially wide range 9
of conditions between roads which are regularly plowed, and 10 roads which become impassable.
11 Are you aware of that, Dr. Urbanik?
12 MR. TURK:
Mr. Fierce says, "we".
13 I don' t know if we have established who this generic j
14 "we" is?
15 M R.
FIERCE:
Well, let me withdraw the question and 16 put it to him this way.
17 BY MR. FIERCE:
18 Q
Are you aware, Dr. Urbanik, that in New England 19 people generally drive on roads, which are not regularly plowed 20 in winter during snowstorms for hours before roads would 21 actually become impassable?
22 A
(Urbanik)
I see nothing wrong with that statement.
23 Q
Now, i sn' t it true that the data that you are aware 24 of, with respect to the appropriate reduction capacity for 25 snowfall, excuse me, all comes from studies of roads which are Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7472 62-1 undergoing regular plowing?
t
\\_-
2 A
(Urbanik)
I don' t think it is necessarily correct 3
that they are all undergoing plowing, but they certainly cannot 4
have deep drifts or be otherwise impassable.
5 So, whether they are passable due to the fact that 6
the snowfall is light, people don' t necessarily plc.: at low 7
snowfall.
8 Q
Are you aware of any specific studies, and if you 9
are, I would like you to name them for me, which indicate what 10 the reduction capacity for snowfall on roadways would be, under 11 conditions which are short of impassable, but where plowing is 12 not present?
13 A
(Urbanik)
I don' t know of any such data.
)
14 Q
And in the absence of such data, wouldn' t it be 15 reasonably helpful and do-able, and practically do-able, for 16 some site-specific data to be collected in the Seabrook area, 17 during a snowstorm?
18 A
(Urbanik)
Not very practical at all, no.
l 19 JUDGE SMITH:
Is it your testimony that for snowy 20 conditions or adverse weather conditions, that you had either 21 as much as 70 percent capacity, or there abouts, or the road is 22 impassable?
23 Is that -- I mean is there an area, sir, like 30 24 percent capacity, 40 percent capacity, is there a continuum 25 between reduced capacity and impassable conditions?
j i
Hwritage Reporting Corporation (202) 628-4888 i
URBANIK - CROSS 7473 r7g i
That is about four questions there.
pick any one
\\ :j 2
that makes sense to you.
3 THE WITNESS (Urbanik):
I understand the line you are 4
pursuing.
5 It is not going to be a neat change from one 6
condition to the other.
But if the roads are in some state 7
that is worse than passable, the presumption, I guess, is that 8
one is not going to make an evacuation recommendation with the 9
uncertainty of not knowing how badly the roads are, you know, 10 covered with snow.
11 JUDGE SMITH:
But you leave that up to the decision-12 maker?
13 THE WITNESS (Urbanik):
Yes, sir.
14 JUDGE SMITH:
You give him a baseline of what you 15 believe adverse conditions are, and then the decision-maker can 16 decide whether to order an evacuations to assume even a smaller 17 capacity factor, or impassability?
18 THE WITNESS (Urbanik):
Abso l ut e l y.
19 BY MR. FIERCE:
20 Q
How does the KLD adverse weather scenario for winter, 21 define the sensitivity of this factor for us, in a way that can 22 be at all helpful to these protective action decision-makers?
23 A
(Urbanik)
I am going to turn what you just gave me, 24 back upon you, okay?
i 25 You told me that there is a linear relationship Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7474
(,{}P 1.
between capacity and evacuation time.
So, if this linear
- t
\\s 2'
relationship that we both kind of agreed was in the ballpark, 3
well, if you believe the number is 50 or 60 percent, you can 4
take those two nu.mbers and do your linear relationship and come 5
up with another number.
6 Q
Well, my problem is that I don' t know what the 7
reduction factor is.
8 If I am the protective action decision-maker, and in 9
this hypothetical we have now, we have a situation developing 10 at Seabrook and I am evaluating whether to evacuate the 11 population.
12 And I look and I see the weather forecast and it is 13 for a northeaster, and it is going to be snowing for the next 14 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, and it is going to be snowing relatively heavily.
15 You are saying that I want to evaluate that 16 situation, isn' t that correct?
17 A
(Urbanik)
Yes, sir.
18 G
Now, do you know what the plans call for?
19 Do they call for plows to be there, during that 20 period of time during evacuation or not?
21 A
(Urbanik)
It does not matter what the plan calls for 22 to make the decision.
23 Q
Well, I am asking you, do you know what these plans
]
i 24 call for?
l b
25 A
(Urbanik)
No, I am not sure, j
c k
Heritage Reporting Corporation (202) 628-4888 l
l l
URBANIK - CROSS 7475 e~s 1
Q Let's assume the plows will not be present. And let IEJ 2
assume that our protective action decision-maker knows that t 3
adverse weather scenario for winter used the capacity reduction 4
factor of 25 percent.
5 And let's assume that our protective action decision-6 maker also knows that that capacity reduction factor is based 7
on studies that were primarily based on situations where roads 8
were undergoing intermittent plowing and let's also assume that 9
based on the weather forecast, the protective action 10 decision-maker knows that throughout the next six or seven 11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />, the area is likely to receive six inches of snowfall.
12 What would that protective action decision-maker 13 conclude would be the ETE for evacuating the entire EpZ, if the 14 one that he can reference in the manual is in the range of --
15 let's just assume
-- five hours?
16 A
(Urbanik)
Well, if I am the -- you made me the 17 decisic:-maker, you have told me that by your hypothetical, 18 that i have exhausted any possibility of finding the resources 19 to keep the roads open, I guess that I would expect that I had 20 no reasonable assurance of being able to get these people out 21 and I would probably would suggest that you consider 22 sheltering.
23 Q
So, I have given you a hypothetical where you believe 24 the roads become impassable.
25 I was hoping to give you one where it would be Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7476 pm i
slightly less than that.
N
)
(,/
2 JUDGE SMITH:
Well, I think what you better give him 3
-- well, I don' t know, you give him whatever you want to.
4 MR. FIERCE:
I would like to give him that 5
hypothetical.
6 JUDGE SMITH:
But you are making him not only be a, 7
you know, an ETE expert, but a road expert and other things 8
which he does not claim expertise on.
9 You have not given him temperature.
Even if you did, 10 I don' t know what it would -- you are making him assume thinDs 11 that he does not claim expertise i n.
12 How good the forecast is?
There is a mix there, and 13 there is so many variables that you are asking him to account j' \\
14 for, that I don' t think that you are fairly expecting him to be
'(
15 able to answer.
16 I think -- why don' t you give him -- I don' t know 17 what to tell you to give him.
I am not trying to ask it.
18 Give him a reduction factor.
19 MR. FIERCE:
That is what I am trying to derive.
I 20 don' t think that there is any way for the protective action 21 decision-makers to have any confidence that the ETE's that are 22 provided here, with respect to adverse weather, provide any 23 sensitivity, give that protective action decision-maker any 24 sense of sensitivity to snowfall which exceeds --
25 JUDGE SMITH:
-- well, isn' t it true that in an O
(
Heritage Reporting Corporation (202) 628-4888 l
URBANIK - CROSS 7477
('s 1
actual -- well, here is my trouble with it.
You are giving h 2
a hypothesis and you select certain variables that might be i 3
a hypothesis, but a decision-maker, at the time, will have 4
every variable, everything, but perhaps will not have complete 5
confidence in the weather predictions, but will know about 6
snowfalls, and know temperature and will know what has actually 7
fallen and will know all of these things.
8 MR. FIERCE:
I am not asking --
9 JUDGE SMITH:
-- not only that, but will have an 10 empirical view of what the roadway conditions actually are.
11 That is why I cannot understand what you expect from 12 him.
13 MR. FIERCE:
I am not asking him to make a protective 14 action decision, Your Honor.
15 Let me drop back.
16 One of the factors that I think he needs to know and 17 1 think is suggested here, in NUREG-0654, is that he be 18 provided with some information regarding the sensitivity of his 19 ETE numbers to snow.
The sensitivity is a measure, of whether 20 snowfall in particular amounts, of what effect that will have 21 on the ETE's.
22 Now, this is a piece of information that will go i nt o 23 this complex mix that you hava just described.
I am only 24 focusing on this one factor.
25 Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7478 1
BY MR. FIERCE:
{;r-
\\.s!
2 Q
And I am just asking, Dr. Urbanik, how that 3
protective action decision-maker knows what that particular 4
sensitivity is, if you have got snowfall that allows the roads 5
to remain passable, but is beyond that point, where it 'is the 6
kinds of roadways that were studied in the studies, that tell 7
you the capacity for 25 or 30 percent.
8 A
(Urbanik)
And I am telling you that the decision-9 maker is going to have to make the passable /no passable 10 decision.
11 And then anything on the other side of that, can be 12 interpolated from the two estimates -- the normal weather and 13 the adverse weather.
b So, for example, say that you expect that it is going 14 15 to start snowing two hours into your evacuation. So now, you 16 can interpolate between the good weather estimate and the bad 17 weather estimate and say, well, it is not going to be 30 18 percent, because it is not snowing during the entire 19 evacuation.
20 I have got two hours that is going to be under the 21 normal weather condition, I will pick a number if we got a -- I 22 hope that I got this right -- if we have got a six-hour and an 23 eight-hour estimate, then I am going to pick one that is -- the 24 math is escaping me, at the moment -- we are going to pick one 25 that is obviously not all the way down to the 30 percent.
i r
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i-(
Heritage Reporting Corporation (202) 628-4888 4
URBANIK - CROSS 7479
/S 1
We are going to take credit for the two hours that
(
2 are at a good, at a higher capacity.
So that is what it is 3
intended to do.
It gives you a way to play with the times in 4
your decision.
5 Q
Isn' t it really a little bit more complex than that?
6 You are assuming that the snowfall is roughly the 7
equivalent snowfall that is contained or assumed in the run for 8
the adverse weather scenario that is contained in the ETE's.
9 I am proposing a situation where the snowfall is 10 worse than that but not posing a problem that will cause the 11 roads to become impassable.
l 12 How do you factor that in?
You have got -- using the 13 hypothetical you just gave me here, it says, since the snowfall 14' does not start for two hours after the evacuation is to begin 15 And as I look in Table 10-8, at Scenario 10, which is 16 for the adverse winter conditione, I see that to evacuate the 17 entire EPZ under those conditions is six hours, and 30 minutes.
18 I know two things now.
I know A, the evacuation will 19 begin two hours before the snowfall.
And I also know B, that 20 this is a considerably heavier snowfall than was assumed in 21 that run.
22 What do I do now?
23 JUDGE SMITH:
But still passable.
24 MR. FIERCE:
But still passable.
25 1
1 Heritage Reporting Corporation (202) 628-4888 i
URBANIK - CROSS 7480 f'
1 BY MR. FIERCE:
2 O
What do I do now?
3 A
(Urbanik)
Your premise is wrong.
You are saying 4
that there is a -- that this estimate of capacity is a number 5
that we related to some particular storm, and the data is Just 6
not that robust. I mean we cannot segregate out degrees of 7
snowfall out of that data.
8 Q
I agree, it is just not that robust.
9 And that is why it is important, isn' t it, Doctor, 10 Urbanik, to try to go out and gather some data?
11 A
(Urbanik)
It would certainly be nice, being a 12 researcher, to do more research into that particular topic.
13 You are taking it one step further into the ability to do a 14 site-specific study of snow conditions that replicate t
15 evacuations.
16 How am I going to get people to evacuate under 17 different snowstorms, to pose the kinds of conditions that you 18 want me to give you this real precise number on?
19 I cannot be -- I mean if I am going to give you a 20 number that you are really going to want to live with, I am 4
21 going to have to ask everybody to evacuate, so that I simulate 22 a realistic condition.
23 Q
It is possible to do sampling techniques, isn' t it?
24 A
(Urbanik)
Well, statistical sampling?
25 Sure.
Heritage Reporting Corporation (202) 628-4888
l l
\\
URBANIK - CROSS 7481 1
MR. FIERCE:
Your Honor, at this time, I would like 2
to offer the letter dated May 6, 1985, from Dr. Urbanik to Dav 3
Matthews, into evidence.
4 JUDGE SMITH:
Are there objections?
5 (No response.)
6 JUDGE SMITH:
The letter is received, as 7
Massachusetts Attorney General's Exhibit Number 10 is received.
8 (The document previously marked 9
as Massachusetts Attorney 10 General's Exhibit 10 11 was received in evidence.)
12 BY MR. FIERCE:
13 Q
Dr. Urbanik --
14 JUDGE SMITH:
And we will bind it into the.
f 15 transcript, too.
16 MR. FIERCE:
Thank you, Your Honor.
17 JUDGE SMITH:
Do you have a copy for the Reporter?
18 MR. FIERCE:
I believe he has been only given one 19 copy but we are going to get him a couple of more.
20 JUDGE SMITH:
Well, look at them and pick out as 21 clear a copy as you can.
22 MR. FIERCE:
Yes.
23 Unfortunately we got this from the NRC, in 24 substantially the same condition that we see it here.
25 JUDGE SMITH:
It is legible.
Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7482
(^s 1
(The letter from Dr. Urbanik to 7
2 Dave Matthews follows:)
3 4
5 6
7 8
9 10 11 12 13 14 15 16 17 18 19 20 4
21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
(3 T il E T E X A S A 6: N1 L' N I V E ll S I T Y S Y S T E NI TEXAS TRANSPORTATION INSTITUTE m.
s...
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L..
-- ~
"r u,.is.s in.. vu now cui cum May 6, 1985 Dave Matthews U.S. Nuclear Regulatory Connission Division of Emergency Preparedness Washington, DC 70555
Dear Dave:
I believe that we need to move ahead in an area of evacuation t ime est imate studies as they relate to current technology in general and LDYNfV in part icul ar.
Based on my experience in licensing hearings and other events likt' MJine Yankee, it is time to move ahead in order to avoid potent ial future problems for NRf.
I do not believe thrt I can continue t-) be effectivesfor NHC staff if we do not address some f ui Jament a'i issues underlying how evacuation time estimate studies are done and how FEMA will affv-t present and f ut ure evacuat ion t ime estimate studies.
Historically, evacualion t ime est io.;
were def ended agains t erit it ism that they were too low. W9 have 3pparent, g driven that poiit home and current content ions of ten deal with the relevancy t.T assumptions.
As you might e.is il y
( nncl ude, i t is more dif f icul t to dcfend the absolute magnit ude of auumpt ions.
than it is to defend their reasonableness.
That is to say, it is easier to convince someone that an estimate i s n,o t, l ow t h a n i t is to convince someone that the estimate is accurate.
More recently. FEMA has begun to get invol vert in evacuat ion t ime est im.it es per se.
This involvement further exasperates the i sue of assumptions.
This involvement of FEMA is likel y to increase as it is clearl y within their lomain.
In order for NRC to be in a strong posture relative t o evar o.it inn t om es t una tes. ! must bo able to move f orward cuocerniaq tne st at e.ot -t he-ar t
! it i vi i
'o evacuat ion t irne est imate studies. Otherwise. I am riot qu iriq t he ibl e to t ont t ion et f or t ivel y on behil f of NRC.
!DYNLV r !"arl y represent s s t ate.of.the. art f t.t hnol ogy in ev.it ua t ion 1ime estimates.
The !OYNfV model dons not represen. f f MA t er muil uqy. hot on $ y f! MA phiaginq nt U. S. Dr. par (men t of Transportation models
! suggesI we ( ni 1 abor it c
,. i t h f f MA ind lDYNE V whil
- ma int a in ing a s t rotu; NRf (.Ipab il i t y.
Thit wiil ivoid iost of develnpinq i simil ar c 1000 i l i t y.ind t he i no v i t.ibl o h.it t i es ovor < ompu t er
,g g mortel s,
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