ML20237D352
| ML20237D352 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/14/1987 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#188-5286, CON-#188-5315 ASLBP, OL, NUDOCS 8712230213 | |
| Download: ML20237D352 (133) | |
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) SD-444-OL l NEW. HAMPSHIRE. et A 's ) OFF-G11E
) EMkhGENCY (GEABROOK STAT!ON, UNITS 1 AND 2 ) PL Ai4N I NG g
EVIDENTIARY HEARING
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LOCATION: CONCORi). NEW HAMPSHIRE P(CEb: 7 b5t, through 7666 DATE: Dece1ber 34. 1967 s==================================================================================
f / l Heritage Reporting Corporation Q(Acial Reporters 1 20 L Street. N.W.
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7555 1 UNITED STATES NUCLEAR REGULATORY COMMISSION .
2 ATOMIC SAFETY AND LICENSING BOARD Sac 50T&I 3
4 In the Matter oft )
) Docket Nos.
5 PUBLIC SERVICE COMPANY OF ) 50-443-OL
- NEW HAMPSHIRE, et al., ) 50-444-OL 6- ) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING
. 7 8 EVIDENTIARY HEARING 9
Monday 10 Decembcr 14, 1987 11 Hall of Representatives New Hampshire Statehouse 12 Concord, tui
("; 13 .
The above-entitled rnatter came on for hearing, 14 pursuant to notice, at 1:02 p.m. .
15 BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN 16 Atomic Safety and Licensing Board U. S. Nuclear Regulatory Commission 17 Washington, D. C. 20555 18 JUDGE JERRY HARBOUR, MEMBER Atomic Safety and Licensing Board 19 U. S. Nuclear Regulatory Commission Washington, D. C. 205SS 20 JUDGE GUSTAVE A. LINENBERGER, J R. , NLMBER 21 Atomic Safety and Licensing Board U. 5, Nuclear Regulatory Commission 22 Washington, D. C. 20$55 23 -
24 25
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'765th 8
1 APPEARANCES:
2 For the Acolicant 3 THOMAS G. DIGNAN, JR. , ESQ.
KATHRYN A. SELLECK, ESQ.
4 Ropes & Gray 225 Franklin Street 5 Boston, MA 02110 6 For the NRC Staff 7 SHERWIN E. TURK, ESQ. -
Office of General Counsel 8 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 9
For the Federal Emeroency Manaaement Aaenev:
, 10 H. JOSEPH FLYNN, ESQ.
11 Federal Emergency Management Agency 500 C Street, S. W.
12 Washington, D. C. 20472 13 For the State of New Hampshire:
. bm 14 GEORGE DANA BISBEE, ASST. ATTY. GEN.
GEOFFREY M. HUNTINGTON, ESQ.
15 State of New Hampshire 25 Capitol Street 16 Concord, NH 03301 17 For the Commonwealth of Massachusetts:
28 JOHN TRAFICONTE, ASST. ATTY. GEN.
CAROL SNEIDER, ASST. ATTY. GEN.
19 STEPHEN H. OLESKEY, ESQ. .
ALAN FIERCE, ESQ.
20 Commonwealth of Massachusetts One Ashburton Place, 19th Floor 21 Boston, MA 02108 22 For the New Enq1pid Coalition Anainst Nuclear Pollutioni 23 *
(No appearance) 24 25 Heritage Reporting Corporation (202) 628-4888
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('- 7557 1 APPEARANCES: (Continued) 2 For the Seacoast Anti-Pollution Leaaues 3 ROBERT A. BACKUS, ESQ.
Backus, Meyer, & Solomon 4 116 Lowell Street Manchester, NH 03105 5
. JANE DOUGHTY G Director Seacoast Anti-Pollution League
, 7 5 Market Street Portsmouth, NH 03801 8
9 For the Town of Hampton:
10 MATTHEW T. BROCK, ESQ.
Shaines & McEachern 11 25 Maplewood Avenue P. O. Box 360 12 Portsmouth, NH 03801
( 13 For the Towns of Hampton Falls and North Hamoton and South Hamnton:
14 ROBERT A. BACKUS, ESQ.
15 Backus, Meyer & Solomon 116 Lowell Street 16 Manchester, NH 03105 l 17 For the Town of Amesburv:
l 18 (No appearance) 19 For the Town of Kensinoton:
20 SANDRA F. MITCHELL i
21 Civil Defense Director l Kensington, NH 03827 22 23 .
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1 I NDEX
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l 2 WITNESSES DIRECT CROSS REDIRECT RECROSS EXAM 3 THOMAS URBANIK by Mr. Fierce 7560 4
JOAN PILOT (prefiled) 7670 5 by Mr. Backus 7668 by Ms. Selleck 7671 -
6 7 ,
8 9
EXHIBITS: IDEN: RECD: REJD: DESCRIPTION:
10 None 11 12
_ _ _ , INSERTS: PAGEa i- ,
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Mass. A. G. Chalk on Critical 14 Path Est iraates '7596 15 Prefiled Direct Test iraony 16 of Joan Pilot 7670 17 Appl icant s' Cross-E x arn i nat i on Plan of Joan Pilot 7683 18 19 ,
20 l 21 22 23 '
24 25 1
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J t235 i PROCEED I NGS 2 JUDGE SMITH: Good afternoon, l
3 l Is there any preliminary business?
{
l 4 Al right, you may proceed.
5 MR. FIERCE: Thank you, Your Honors.
6 Whereupon, 7 THOMAS URBANIK <
8 having been previously duly sworn, was recalled as a witness 9 herein and was examined and testified further as follows:
10 CROSS-EXAMINATION (Resumed) 11 BY MR. FIERCE:
12 Q Good afternoon, Mr. Urbanik.
13 I just have one additional question that was in the 14 line that'I was proceeding on as we ended last, a week ago 15 Friday, and it's this.
16 Given that you don' t have any particular expertise in 17 working with the handicapped or those who are in' wheelchairs or 18 the frail elderly, you are not offering expert opinion on how 19 fast these individuals can board evacuation buses, are you? ,
20 MR. TURK: Objection. I don' t think that the 21 predicate has been. established yet.
- 22 MR. FIERCE: I' m sorry, I didn' t hear that.
23 JUDGE SMITH: He says there is an objection on the 24 basis that there has been no predicate established for the 25 question. I have to admit, I don' t understand the objection.
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i What predicate might --
2 MR. TURK: Well, the question said, given that you 3 have no expertise in working with the handicapped.
4 . JUDGE SMITH: Oh, I see, right.
5 MR. TURK: That's never been discussed, to my 6 knowledge.
, 7 JUDGE SMITH: Fine. Sustained.
8 BY MR. FIERCE:
9 Q Well, Dr. Urbanik, would you agree that you have no 10 expertise in working with the handicapped?
11 A (Urbanik) No, I wouldn' t.
12 O Do you want to describe that expertise for us, L(
.:- s
' 13 please?
14 A (Urbanik) We have done at Texas A&M under projects 15 that I was the principal investigator, a number of studies of 16 elderly and handicapped transportation, both on a statewide 17 basis in Texas and in a number of cities, Corpus Christi, 18 Texas, and the like.
19 So one of the areas that I do work in is 20 transportation of the elderly and handicapped.
21 Q Well, are you offering expert opinion here on how 22 fast those individuals can board evacuation buses?
23 A (Urbanik) Yes, I am. .
24 Q Dr. Urbanik, I want to review with you the Uncee 25 recommendations that you made in the process of supplementing
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L C URBANIK - CROSS , 7562 1 your profiled written testimony two weeks ago.
2 First, in your supplemental testimony, you were asked 3 this question. "Do you recommend any changes in the KLD ETE 4 study?"
5 Do you recall that question, Dr. Urbanik?
6 A (Urbanik) Yes, I d o.
7 Q And then you proceeded to.make three recommendat' ions, ,
8 but before reviewing these, however, I want to clarify what the 9 question means.
10 The KLD ETE study was completed and published in 11 August of 1986 as Volume 6 of the New Hampshire Radiological 12 Emergency Response Plans, and that study is a fait accompli.
13 Therefore, in recommending changes to the KLD ETE study, are
}~;"
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- 14 you recommending that the ETEs be recalculated with these three 15 changes factored in?
16 A (Urbanik) Yes, I am.
17 Q And are you also recommending that the Volume 6 18 itself be amended to incorporate these changes so that the l
19 plans contain an up-to-date ETE study? ,
]
20 A (Urbanik) Yes, it is my recommendation that the 21 plans be brought consistent with revised estimates, yes.
22 Q Now, two of your recommendations pertain directly to 23 the traffic management plan itself, the recommendation to 24 change the I Route 110 traffic control diagram, and the 25 recommendation to eliminate screening at access control posts.
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1 In addition to amending the ETE study in Volume 6, 2 the Traffic Management Manual and the training modules for 3 traffic management also need to be changed, don' t they?
4 A (Urbanik) I' m not familiar with all those 5 supplementary documents. But everything that's used as part of 6 the evacuation obviously has to be consistent. So if you were
, 7 giving instructions to state troopers on what to do, it has to 8 be obviously consistent with the plan and the way the estimates 9 were done.
10 Q And, in fact, those who have already received 11 training that was based on the old Traffic Management Manual 12 and the old training modules that contain access checking --
< 13 MR. TURK: Jbjection.
14 MR. FIERCE: -- need to be --
15 JUDGE SMITH: Finish.
16 MR. FIERCE: -- need to be given supplemental 17 training, don' t they?
18 MR. TURK: Objection; outside the scope of the 19 testimony.
20 JUDGE SMITH: Well, I think he wants to narrow the 21 question to the question he's examining him on.
22 MR. FIERCE: I' m examining him on the duplications of 23 the three recommendations that he' s mad e.*
24 JUDGE SMITH: Right. Which recommendation?
25 MR. FIERCE: Well, in this case, I said there were Heritage Reporting Corporation (202) 628-4888
- f. g URBANIK - CROSS 7569 1 two recommendations that pertain directly to the traffic 2 roanagement portion of the plan. The recommendation, first, to 3 change the way traffic would be routed through the I Route 4 110 interchange, and the second was the elimination of 5 screening at access control posts. And I' rn exploring the 6 implications of these recommendations.
7 MR. TURK: Your Honor, my objection goes to the scope ,
8 of the direct testimony. This witness is not testifying as to 9 what training has taken place, or what the training modules 10 contain. If Mr. Fierce wants to make that argument and he can 11 show that those documents are inconsistent, then that's 12 something that he can establish without use of this witness;
[
2_m 13 certainly not through the direct test irnony that 's been 14 proffered so far.
15 MR. FIERCE: My quest ion wasn' t that. It was it 1
16 those irnplement i ng the traffic management plan who have l
l 17 received training have already received that training based on 18 a training module and a traf fic managernent module that 19 contained access control checking, and we know it contains the 20 proposed routing through the I Route 110 interchange up 21 over the grassy rnedian, don' t those people require supplemental
- 22 training.
23 JUDGE SMITH: Does your objection stand?
24 MR. TURK: Yes. First, I note the question has now 25 been somewhat rephrased to be a hypothetical, which makes it
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URBANIK - CROSS 756S 1 more acceptable to me. He v.ays if that training has taken 2 place in that manner.
3 I really don' t see, however, that this witness is 4 qualified to state, attempts to state to what extent training 5 programs have to be revised. He has stated that the plan 6 should be consistent with his recommended changes to the ETE.
,, 7 JUDGE SMITH: Nor did he addr'ess training programs in 8 his direct testimony?
9 MR. TURK: Not that I' m aware of; not that I can i
10 recall.
11 JUDGE SMITH: I think that the objection is well-12 , made. I don' t think it's a very important point. It's a point , I
(- 13 as he observed it that you can well argue, and it's not hard to 14 understand. i i
15 MR. FIERCE: I'll move on then.
16 BY MR. FIERCE: ,
17 Q The first recommendation, Dr. Urbanik, was that the 18 traffic control post at Route I-95 and Route 110, "should be 19 revised to eliminate vehicles crossing the grassy median 20 between the ramps."
21 Is that a correct statement, Dr. Urbanik, of your 22 position?
23 A (Urbanik) Yes, I believe so. .
24 Q Now, you' ve used the term " eliminate" here. Does 25 that mean that during an evacuation this particular route over Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7566 l__ -
1 the grassy median should not be utilized?
2' A (Urbanik) Yes, I think that s what I' m stat ing.
3 Q And do you have a recommendation for what ought to be q 1
4 done with the line of traf fic which the plans currently have 5 going over that grassy median?
6 A (Urbanik) Well, I think there are multiple options, 7 and that's why I don' t try to dictate the exact solution that ,
8 might be used in that particular case.
9 One is to reroute the traffic over .o I-495; that's 10 one alternative. The other alternative is to take that-traffic 11 a little further down, U-turn most of that traffic around the 12 end of the median at the next intersection, and then bring them 13 on the on-ramp in the normal pattern.
14 You could Do in there and make some modifications to 15 the median; take the concrete out at the place where it ,
i 16 conflicts with making a change. You could modify the ramp I l
17 geometries. There is a whole host of possibilities to address !
l 18 rny concern. l 19 My concern is that going across a grassy median T ,
20 don' t believe is an all-weather approach for evacuation, and I 21 don' t think we can develop a plan that has possibilities of not '
22 being usable under certain weather conditions.
23 Q Well, with respect t o the recornmendat ion, or the 24 suggestion, excuse me, that the traffic perhaps could be routed 25 further west to the intersection with Route 495, that poses a l
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1 problern, = doesn' t it, Dr. Urbanik, in that the reception center 1
2 for the Salisbury Beach area i s, at least according to the j i
3 utility plan that's. now been filed, in Beverly. And Route 495 q
.i 4 would take evacuees away frorn the Beverly area, wouldn' t it?
5 A (Urbanik) See, that's the exact reason why I' rn not 6 trying to-prescribe an exact solution. Everything has to fit 3 7 together in harrnony here. If sorneone decides to rnodify the 8 reception centers, and go with that approach, I' rn not tv- .g to 9 preclude that. If that's not a feasible approach, then U-10 turning the traffic is another alternative. And ' that's why 11 when I' rn raaking rny recornrnendat ions I' ra t rying to indicate'what 12 it is about the current plan that I find to be less than 13 desirable, but not totally preclude all possibilities that i
14 could be used in a reasonable fashion.
15 So I' rn not prescribing the solution. I did that 6n 16 purpose for ,just the kind of exarnple you are giving, to. raake 17 , sure that I don' t prescribe- sornething that doesn' t rnake sense.
18 Q Now, in taaking changes frorn the way the traffic 19 diagrarn has been laid out in Volurne 6, isn' t conceivable, isn't 20 it, that the ETEs will actually be lengthened as a result?
.21 A (Urbanik) I bclieve, based on sorne addit ional 22- analysis done in the prefiled test irnony of the Applicant, 23 t hey' ve already run those analyses and indicate that it doesn' t 24' cause an increase in evacuat ton t irnes.
25 Q But at least for this part icular traf fic st rearn any Heritage Reporting Corporation (202) 628-4888
1 1
4 URBANIK - CROSG 7568 1 of the suggestions that you have proposed would lengthen the 2 ETE for that traf fic strearn; isn' t that true?
3 A (Urbanik) No, sir.
4 Q Well, let's take the first one, routing the traffic 5 straight through to the west until it reaches the intersection 6 with 495.
7 Isn' t it true that 752 vehicles for origin centroid ,
8 2072 will Join the traffic stearn at node 45; isn't that true?
9 M R. TURK: Your Honor, I want to object to this 10 question, not that I have any problern with Mr. Fierce 11 atternpting to dernonstrate through his own witness sorne proposed 12 solut. ton in the future doesn' t work. This witneus has not 13 indicated that he selected a particular routing in place of 14 what he's deterrnined to be inappropriate.
15 He sirnply said you' ve got a problern here that needs 16 to be fixed. Mr. Fierce is looking for hirn to sornehow step in 17 and do an analysis off the cuff as he sits here in hearing as 18 to a possibility which the witness has not in fact prescribed.
19 He sirnply stated there are rnany dif ferent sol ut ions, and that 20 happens to be one of t h ern.
21 Now whether that's one that works out and is feasible -
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22 is sornething that this witness is not at t ernpt i ng to say.
23 JUDGE SMITH: Mr. Fierce. .
24 MR. FIERCE: I ' rn again exploring the t roplicat ions o f 25 the recornrnendat ion, and one of t n ern, 1 believe, is tnat the
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f- URBANIK - CROSS 7569 1 ETEs, whatever solution is devised, will be lengthened. And it 2 appears that, based on his answer to my previous question, that 3 he's not so sure that's true. And I' m hoping to explore on 4 cross-examination with him why I think that's an incorrect 5 statement.
6 JUDGE SMITH: Yeah, I don' t know if you characterized
. 7 his answer correctly. But, nevertheless, I think it 's an 8 appropriate area for you to explore. Overruled.
9 BY MR. FIERCE:
10 Q Do you have a copy of Volume 5 with you, Dr. Urbanik?
11 A (Urbanik) Yes, I do.
12 Q If you take a look at the traffic control post
( 13 diagr.am numbered B-AM-07, which is on Page I-20, do you have 14 that, Dr. Urbanik?
s 15 A (Urbanik) Yes, I do.
16 Q Do you see at the top of the left-hand side of the 17 page, node 45 is listed there?
18 A (Urbanik) Yes, I see that.
19 Q And do you recognize that to be the intersection 20 which is just immediately directly west of the 495 - 110 21 interchange that we' re talking about ?
22 A (Urbanik) Yes, I do.
23 Q And do you see the arroww which are coming down Elm 24 Street from the north, and are being directed to turn on to 25 Macy Street - Route 110 at that point?
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1 A (Urbanik) Yes, I do.
2 Q Now, if you take a look at the diagram on Figure 1-3, 3 the link node representation, which is on Page 1-13, I believe, 4 do you see a centroid, an origin centroid numbered 2072, which 5 has a dotted line linking it to the link that runs from node 39 6 to node 45?
7 A (Urbanik) My diagram is not clear enough to see ,
8 where that node -- that centroid is connected.
9 Q Does your attorney have a better copy of that?
10 MR. FIERCE: Mr. Turk?
11 MR. TURK: I probably have the same one as the la witness.
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13 MR. FIERCE: Well, I' m going to move down by the
.w 14 witness and show the witness my copy at that point.
15 JUDGE SMITH: He stated that he had worked from a 16 larger copy of the document. Is that available? Does anybody I 17 have that?
18 MR. TURK I see the Applicant is shaking their head 19 no.
20 THE WITNESS: (Urbanik) It's not much better. 01y 21 eyes -- I must be getting old here, but it looks like it's -
22 coming in between 39 and 45. !
23 BY MR. FIERCE: -
24 Q And, in fact, we can check that on Page M-30, the
[ 25 origin destination table, can' t we, Dr. Urbanik?
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1 A (Urbanik) Yes, it does come in between 39 and 45.
2 Q And would you take a look at Page M-1, the traffic 3 demand by centroid?
4 MR. TURK: What page is that again?
5 MR. FIERCE: M-1.
6 BY MR. FIERCE:
7 Q And on that page under Amesbury's centroids take a 8 look at centroid 2072, which is the one we' re talking about.
9 A (Urbanik) Right.
10 Q And do you see there listed 708 permanent resident 11 trips generater! and 44 transient trips generated?
12 A (Urbanik) Yes, I do.
13 Q And so, therefore, there are 752 extra vehicles which
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14 will be added to this traffic stream cominD through the I 15 Route 110 interchange and joining that stream as it is routed 15 west to Route 495; isn' t that correct?
17 A (Urbanik) Well, they' re not extra. They' ve been 18 there all along. They are part of the evacuation --
19 Q I agree. They' ve been there all along, but now if 20 the recommendation is to take the traffic stream that would
- 21 have been routed over the grassy median and routed went to the 22 interchange with 495, it will be joining this stream; isn't 23 that correct? ,
~24 A (Urbanik) Yes, but that's why you run the 1- DYNEV 25 simulation model to get your answer. It puts all tnose cars in Heritage Reporting Corporation (202) 628-4888
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1 and it tells you what the time i s. .
2 Q Right.
3 A (Urbanik) They' re not extra. They' ve been there and i
4 they' ll be there. And when you do your simulation, it will '
I 5 tell you what the answer is.
6' Q Right. And I agree with what you are saying.
7 And isn' t it also true that once you add 752 extra ,
8 vehicles to that particular traffic stream, which is'one that 9 defines the ETE for that beach area, the Salisbury Beach' area, 10 you will end up with a longer ETE for that particular braffic 11 stream?
12 A (Urbanik) That doesn' t follow at all. You' ve moved
- (', 13 the traffic to a different place, a different roadway, and 14 you' re trying to tell me that because what happened on -- if 15 what you' re saying is fundamentally true, what you' re telling 16 me is we don' t need to do any of these computer simulations; 17 that the answer is prescribed.
18 The reason we do the traffic simulation is there's 19 tremendous interaction between these vehicles both in time and .
20 in space. .And to ask me to sit here and tell you what the new 21 number is just based on the fact that you' ve got an old number -
22 and you' ve got a centroid of traffic is not -- it's not the way 23 to try to come up with an answer. .
24 And I believe i t ' s -- it 's my understands ng t hat the E235 25 simulation has already been done with that traffic.
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7573 T2'36rnb 1 Q Doctor Urbanik, isn' t it true that the way the 2 traffic was rnodeled in the ETE runs done by I-DYNEV for the 3 Vol urne 6, that is behind the Judges, the original Volume 6, ETE 4 study, was to have the traffic split, goinD one half of it, up 5 the up-ramp, on to Route 95; and the other half across this '
6 grassy. median, on to 95, heading southbound?
, 7 A (Urbanik) Your terminology is a little sloppy in --
8 Q -- please --
9 A (Urbanik) -- that I don' t know what an up up-rarnp 10 is, but I will agree that the traffic is roughly split in half, 11 each half using each of two different ramps and getting on to 12 I-95 southbound
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13 The essence of the traffic control plan is to use two
. c__1 14 separate ramps to get twice as many cars on to I-95.
15 Q Isn' t that rarnp the constraining factor for that 16 stream of traffic coming out of the Salisbury beach area?
17 A (Urbanik) That is a critical point in the 18 evacuation, yes.
19 Q And once you know what the rnodel is doing with 20 respect to the number of vehicles per hour that it allows 21 through a rarnp on to an interstate, and you know how many cars 22 are coming through that r arn p, it is a sirnple rnathemat ical 23 computat ion to deterrnine how rnany hours that stream of traf fic 24 will take going through that ramp, isn' t it?
25 A (Urbanik) Yes, it i s.
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t i But that has no relationship to the capacity of 110, 2 which is not a ramp.
3 Q But isn' t the constraining f actor as you rnove the 4 traffic further west on llo, down to 495, the capacity of that 5 rarnp at 495?
6 A (Urbanik) Well, then you are rnoving it into another 7 location, yes. .
8 Q And as you have that strearn of traf fic Do through 9 that rarn p, you now will have rnore cars, going up that rarn p, 752 10 rnore cars, than you did going up the rarnp that had crossed the 11 grassy rnedian, isn' t that correct?
12 A (Urbanik) You are rnakinD a whole bunch of
( 13 assurnptions and you are assurning that I have even said that 14 this is going to be the final approach taken.
15 To answer your question of whether or nob the time 16 goes up, if you take ray other alternat ive, by inspection we can 17 say that the t irne doesn' t go up, okay?
18 So, we don' t have to look at this alternative. There 19 is an alternative that I belinve has no irupact on the 20 evacuation t i rne. It is .just to take thern down to this 21 intersection, you .just pointed out, and U-t urn thern. -
22 Q Are you agreeing with rn e , then, Dr. Urbanik, that if 23 you did route thern through to 110, through 110 down t o 4':sd, it 24 will have sorne irnpact on the ETE for that t raf fic st rearn?
25 A (Urbanik) No, I won' t agree to that. I was .just
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1 trying to get you out of this pocket you seem to be in.
2 Q I am going to have to bring you back because I don' t 3 think that I have made a single assumption here. All the 4 information I provided to you came out of Volume 6, isn't that 5 correct? ;
6 MR. TURK: Your Honor, I think that we are getting a ,
a 7 little argumentative here. If Mr. Fierce wants to ask the 8 question, I have no objection, but I don' t think we need the 9 argumentation.
10 JUDGE SMITH: I think that Dr. Urbanik could do 11 somewhat of a better job of giving him an answer to this 12 particular question he has been struggling to get answered for 13 some time now.
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14 And why don' t you put it to him once more and see if 15 you can answer it, rather then backing out of that alternative.
16 I mean as I understand your testimony is that the 17 I-DYNEV run did not show any increase, however, now he is 18 trying to have you explain why you would necessarily not have 19 one, given the premises of his questions.
20 And I don' t think that you have challenged any of the
- 21 premises.
22 THE WITNESS (Urbanik): Well, one of the premises is 23 that the exact number of -- that the, in.the final analysis 24 that we are going to have exactly the same volume of traffic at 25 Heritage Reporting Corporation (202) 628-4888
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1 any given -- that we are going to move exactly that volurde over 2 on to another ramp. I 3 Through the simulation process, and through revisinD 4 it, we may have some traffic that is given other changes. Or 5 if that, in the simulation of the model, in the simulation, tne
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6 model will, if that traffic from that ramp backs up, then at 7 some of'these other places, some of that traffic may opt to ,
8 turn left and go down from Salisbury center, down Route I.
9 So, it is a very complex process.
10 JUDGE SMITH: So, you don' t accept the premise that 11 all of that traffic will end up trying to Det on to that ramp 12 at 4957 l
13 THE WITNESS (Urbanik): Not necessarily, no.
14 BY MR. FIERCE:
I 15 Q I might agree with that, but if the assumption is 16 that the traffic management plan will be changed to route this 17 traffic there, and the assumption also i s, as it is throughout 18 Volume 6, that all the vehicles will follow the traffic 19 management plan, then won' t the impact be that once those 20 vehicles get to the ramp, the on-ramp at 495, that same number 21 of vehicles that would have been going over the grassy median, .
22 because it is joined now with 752 additional vehicles that are 23 evacuating out of Amesbury, that traffic, stream will now take 24 longer by about, in fact, three quarters of an hour, to get al1 25 the way throuDh that intersection?
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1 In other words, for that traffic to be routed all the 2 way on to Route 95 through that on-ramp?
3 A process, a process which used to occur 4 simultaneously with the traffic that was going over the grassy 5 median simultaneously to the time the 752 vehicles were going f 6 up the on-ramp, at Route 495, will now have to occur in series, 7 isn' t that correct?
8 A (Urbanik) I don' t understand what you mean by, "in 9 series".
10 Q I mean they will all join the same line of traffic 11 and have to go up that on-ramp at 495, one at a time?
12 A (Urbanik) The whole traffig management scheme
~ ~ "
13 doesn' t mean that there is going to be exactly X number of cars C_a 14 doing X movement in reality, in the final assessment.
15 The simulation model allows some diversion of 16 traffic. So given what you are saying, with 750 cars,: and we 17 are talking about 750 cars over what -- seven hours --
so we 18 are talking about 100 cars an hour.
19 First of all, we are not talking about a real large )
20 number of cars. But if that -- and I have not looked at the l - 21 simulation runs for that particular alternative -- so I cannot 22 give you definitive answers as to what this simulation shows, 23 when I have not looked at it. -
24 But just in a conceptual way that the model works, if 25 that becomes over loaded, then the simulation model wi11 show Heritage Reporting Corporation (202) 628-4888
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1 you some diversion of t raf fic, at perhaps some other points, 2 like the one I indicated.
3 You are then goinD to have to fine tune your traffic 4 management scheme, perhaps at another location. This process 5 isn' t just so simple as necessarily fixing one point.
6 So, yes, there may be a problem at another ramp and 7 it may mean a couple of other changes in the traffic management .
8 to make it all work out. But that is what the simulation model 9 then gives you as an out put. And you look at what the model 10 has done with that traffic and then you decide if you have to 11 make any other fine t uning in your traffic management.
12 Q Excuse me, Dr. Urbanik, if no additional changes were
'~~~
13 made and the traffic is routed on to 495, in the fashion on
- a 14 which it is shown on Page I-21, won' t that increase the ETE for 15 that stream of traffic comitig out of Salisbury beach?
16 MR. TURK: I am sorry, what is the assumption on the 17 question?
18 M R. FIERCE: The traffic, if there are no additional 19 changes, and traffic is routed on to 495, off of Route 110, in .
20 the fashion which is depicted on the traffic control post 21 diagram on page I-21, -- -
22 MR. TURK: So that you only have one ramp beinD used.
23 MR. FIERCE: There is only one. ramp shown on this 24 diagram.
25 MR. TURK: Fine. I just want it clear.
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1 1 THE WITNESS (Urbanik): You ment ioned I-21, aren' t we 2 really referring -- I am a little lost here, because I thought 3 the point that we were starting out from was the one on I-19, 4 and that is the on's that I recommended a change, and it is 5 possible to make a change in the diagram on I-19, a change, 6 that has no impact anywhere else in the system and that'is to
, 7 cut a nice hole in the median there,'and turn those people on 8 to the on-ramp that is intended in the other direction.
9 So, there is, there are alternatives that don' t 10 require changes beyond the scope of this intersection, to'make 11 it work. You could pave the median and it is no longer grassy.
12 There is just lots of little things that you could do with this
}'"
- L-a 13 one little diagram to make the ETE unaffected. j 1
14 JUDGE SMITH: Doctor Urbanik, the Board understands t
i 15 your point quite well. You made it before and this time you 1
16 have made it quite clearly. Nevertheless, Mr. Fierce is 17 untitled, if he Di ves the statement in correct form and there 18 is no objection, he is entitled to have you accept his premises 19 and give an answer. And his question was goinD back to Macy 20 Street, and the on-ramp to 495, that if all of the traffic, I 21 believe that has been not permitted to cross the grassy strip, 22 is.sent down to that access ramp, to 495, on Macy Street, wnat 23 would happen then? What was the question -- would it not 24 necessarily do something to it?
25 MR. FIERCE: Won' t that increase the ele --
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URBANIK - CROSS 7580 1 JUDGE SMITH: -- necessary --
2 MR. FIERCE: --
for that traffic stream?
3 JUDGE SMITH: Now, he already answerea not 4 necessarily because.there is only 750 cars, in so many hours, t
5 but now you have asked the question, and that he is not allowed 6 to hypothesize that sorne of that traffic is going elsewhere.
7 He has to accept that all of that traffic goes to .
8 that point. And he can go back to his previous answer if that 9 is still his answer, but he should answer it.
10 MR. DIGNAN: Your Honor, do I understand the question 11 before the Witness now, as phrased by, Your Honor?
12 Because if so, I would respectfully suggest that 13 there should be another pararneter in the question.
14 JUDGE SMITH: What?
15 MR. DIGNAN: I would respectfully suggest that there 16 should be another pararnet er in the question, which at least, 1 17 think is what is giving this Witness a lot of problern in 18 handling it.
19 At no time har ray brother, representing the .
20 Cornmonwea l t h , put in a parameter for the degree of saturation 21 that is involved.
- 22 And I think that is what is causing us the pro b l ern 23 here. .
24 JUDGE SMITH: Well, he had -- well, you mean at the 25 on-rarnp ?
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1 MR. DIGNAN: Or at anywhere in the system.
2 In other words, what I understood the Witness to 3 testify to, earlier under cross, is he said, quite clearly, you 4 cannot just add those 750 cars and say something is going to 5 happen.
6 And at least 2 took that to be an indication that it
, 7 would depend upon how saturated is the system?
8 JUDGE SMITH: Right.
9 MR. DIGNAN: Because i f you ' h ave got plentyLof room j 10 ts throw those 750 in-between cars, you have got no problem.
11 And.my brother has not, at,least I have not heard, l 12 and if I did, I apologize to everybody, I have not heard an
[~"
Da 13 assumption that he is to make, as to the degree.of saturation 14 which might move this inquiry along.
15 JUDGE SMITH:
Well, I think that would ' bre. a good 16 idea, but nevertheless, he is free to answer pretty much the-17 same way that he' answered before.
18 -I am allowing the same quest ion to bre asked again, 19 but this time, we are going to make sure.that;the ylitness- /tl 20 understands that all of that traffic is beinD put on to that 1
21 on-camp.
22 And it is up to the witness to raise questions of 23 saturation if he needs to for his answer.'
24 BY MR. FIERCE:
25 Q Is the witness able to answer the question?
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UR9ANIK - CROSS 758E 1 JUDGE SMITH: Don' t be confused if you think you ,
2 have answered this question before. Just put that aside, and 3 answer it in any event, the best way you can.
4 THE WITNESS (Urbanik): I guess my confusion right 5 now, is that I am not sure I know what the question i s.
6 BY MR. FIERCE:
7 Q Do you want me to repeat the question, Dr. Urbanik? ,
8 A (Urbanik) I think tha would help, if you would not 9 mind.
10 Q If Eo other changes are made in the traffic 11 management plan, other than the one that you have suggested for 12 the t raf f'ic control post diaDram on Page I-19 at 495, and Route 13 110, and all of the traffic which otherwise would be routed 14 over the grassy median, at that intersection, were routed 15 straight through, westbound on Route 110, until it reached the 41 16 intersection with 495, and that traffic contro) diagram at 17 495, which is on Page I-21, were not changed in any way, isn' t 18 it true that the ETE for that traffic stream would be 19 lengthened?
I 20 A (Urbanik) Not necessarily.
21 How well that ramp flows also relates to how much -
22 traffic is on I-495. The ramp at I-95 is that this is 23 replacing, is downstream from another ramp and also tne traffic 24 on I-95. In that case, though, I still don' t think on J -- W 25 there is enough traffic that is creating any particular
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7~,. . URBANIK - CROSS 7383-1 problem. The capacities would not suggest that.
2 Certainly if I-495 has a significant volume of 3 traffic on it, and I don' t have that information, then getting 4 on conceivably could be a problem. To a large extent this ramp j 5 would operate a lot better than the~ maneuver that was 6 previously postulated at the other ramp. It is essentially
, 7 Just a right turn loop ramp on.
8 But in the context of the simulation, if we assume S that the capacity of this ramp is exactly the same as tne 10 capacity of the other ramp, and I would have to take a look at 11 whether that is the case, then it is possible that there mi Dt h 12 be some-slight increase in the ETE, if you didn' t ' allow l
~~~ i 13 traffic, some traffic to divert to alternate routes.
O_J 14 But I don' t believe that that means, por so, that the 15 ETE goes up.
16 Q I am not going to belabor this any longer, Dr.
17 Urbanik, but I gather then that your ultimate position is that 18 you really do need to run this through the I-DYNEV model to see l
19 where it comes out, is that correct?
20 A (Urbanik) Yes. .
. i 21 I believe that the I-DYNEV model should be exercised a 22 with the final form of traffic control that in in place. The 23 traffic control and the model should be i.n agreement.
- 24. JUDGE SMITH: I thought that you bestified that tne 25 1-DYNEV model was run with the grassy strip closed and the F1 .
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f URBANIK - CROSS 7580 1 traffic routed down 1107 2 THE WITNESS (Urbanik): No, I think I testified that 3 the model has also been run that way, is that what you are 4 asking me?
5 JUDGE SMITH: Yes.
6 THE WITNESS (Urbanik): Yes.
7 That is my understanding that we have run it that .
8 way. That we, the Applicant, has run it with the traffic all 9 with -- sent to I-495, and that as a result of that, the ETE is 10 no higher.
11 So, I cannot say it is no higher just because that is 12 the only change in the total flow of traf fic through the 13 system.
14 BY MR. FIERCE:
15 Q Isn' t it true that that Applicant testimony that you 16 arw referring to now, states, simply that the overall ETE is no 17 hi Dher, and doesn' t make reference specifically to this 18 particular traffic stream and its own ETE?
19 A (Urbanik) That is, I believe, correct, but I thouDht .
20 that we started out with the presumption that this was the 21 controlling link? If it is the controlling link, then, in " '
22 fact, the longest ETE and this ETE are the same.
23 I t' we are only saying that it as the controlling link l
24 fron Seabrook, then yes, in fact, it could increase sligntly, 25 could increase the ETE on this particular part of the networa Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7585 1 without increasin; the overall ETE.
2 And there has been, I cannot remember which part of 3 the network, under which scenario, i s, in fact, controlling.
4 At times, different parts of the network under different 5 scenarios does ec<ntrol. It does not necessarily mean that the 6 critical point in any given ETE is always the same. It may
, 7 vary due to changes in the spatial distribution of the traffic.
8 Q Actually I want to Det into that more a little bit 9 later, but bringing you back to this particu?ar first 10 recommendation of yours to avoid using the grassy median, one 11 other concern with respect to routing traffic on 495, excuse 12 me, on 110, further west to Route 495, is that as it passes the
~~~
13 interchange with Route I-95, there could conceivably be a c_
14 sizeable amount of t urbulence couldn' t there, Dr. Urbanik, as 15 the traffic which is in the left lane, the lane that would have 16 otherwise been routed over the grassy median, sees traffic in 17 the right lane going up the on-ramp to Route 95, and as many of 18 the drivers want to access 95, shift lanes over to that right 19 hand lane?
i 20 Do you understand the question, Doctor?
21 A (Urbanik) I understand the question. A D ain, our 22 basis for coing ETE' s is that people, do, in fact, follow the 23 traffic control, so in terms of saying that people will l 24 disregard the traffic control that is in place, that is not our l 25 position.
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1 So there is that turbulence, it would not be a 2 question of turbulence, if that traffic, in fact, does try to 3 get on, there is only a finite amount of capacity on the ramps.
4 So there is no, it is not a question of turbulence.
U It is a question of too many cars, and too few caps. city, too E little capacity, if people from both lanes tried to get on the 7 ramp. .
8 Q And if people from both lanes do try to Det on the 9 ramp, that is another factor, is it not, Dr. Urbanik, which 10 could result in lengthier ETE's for this particular traffic 11 stream?
12 A (Urbanik) Yes, it is true that if people do things
- 13 different than we have assumed, in the simulation, the results 14 would be different. And, in this case, the results of more
- 15 traffic going on a particular ramp than we assigned to it, 16 being a critical camp, would increase the ETE's.
17 But that is not what we believe to be the case.
18 MR. FIERCE: I am going to move back up to my normal 19 space, excuse me.
20 (Counsel
- moves.)
21 (Continued on the next page.)
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24 25 Heritae@ Reporting Corporation (202) 628-4888
l URBANIK - CROSS 7587 lT37 1 BY MR. FIERCE:
2 O Now, Dr. Urbanik, the second recommendation you made 3 was that, "The beach area vehicle capacity should be revised to 4 include approximately 29,000 parked vehicles and approximately 5 1500 vehicles moving in traffic."
6 Is that a correct statement of your testimony as
, 7 revised, Doctor?
8 A (Urbanik) Yes, it is.
9 Q Now I want to put aside for a minute our dispute 10 regarding whether there should be some additional vehicles 11 added to this count for vehicles which are hidden from view in 12 garages and carports, et cetera, and I also want to put aside 13 our disagreement whether your number, your total number of I 14 30,500 can be called capacity in the sense that it was used in 15 Scenario 1 in the ETE calculations in Volume 6, which sought a 16 reasonable upper bound in the number of vehicles at the beach 17 during peak conditions. And I want to focus en what the actual 18 implications are of this particular recommendation.
19 First, depending on how these 30,500 vehicles are 20 distributed amonL the key beaches of Hamptor, Beach, Seabrook 21 Beach and Salisbury Beach, isn' t it tvue that the traffic 22 management plan might have to be ad.j ust ed in order to minimize 23 the ETE along the critical path? .
24 A (Urbanik) Yes, I believe that's correct.
25 Q And I believe a few minutes ago you were suqqesting Heritage Reporting Corporation -
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1 yourself that the ETE -- the critical path which determines the 2 ETE may in fact vary from time to time throughout an 3 evacuation; is that correct?
4 A (Urbanik) Not --
well, yes, even during an 5 evacuation. During a particular scenario, different links 6 could be critical at different times, yes.
7 Q Let's make a definitional agreement here, because I .
8 think that's actually confusing to say that the critical path 9 shifts during the course of an evacuation. I use the term to 10 mean "the path" which is the last to clear whatever the zone is 11 that we' re talking about, the two, or the five, or the 10-mile, 12 or the EPZ boundary.
T 13 Can we agree to use that, as I proceed with this L
14 cross-examination, to use that definition, that the critical 15 path is the last path to clear?
16 Or if you have some other term that you want to give 17 for that concept, then maybe we could use that term.
18 A (Urbanik) The last path to clear is fine. The only 19 problem I' m having is at certain points it may oe -- there may 20 be more like a tree than like a line. So, a path gives me a 21 little -- we could get into trouble by talking about a path, -
22 but that terminology has been used, so I don' t have any problem 23 with using it. .
24 Q Okay. Isn' t it fair to say that the overall ETE to 25 clear the entire EPZ is likely to be o:e of the three critical I
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4 URBANIK --CROSS 7589 1' roads that evacuate the beach area, either 1-A, on the' southern 2 end coming out of Salisbury Route 1-A as it then turns into 3 Route 110 is one path. And then.in the middle we have Route 4 286 evacuating the Seabrook area. And then to the north the-5 Hampton Beach area has Route 51 as the main evacuation pathway.
6 Those are the three critical evacuation pathways; iun' t that 7 true, Dr. Urbanik?
8 A (Urbanik) By and large, but toward the north we do, 9 do tend to use some other routes to supplement that. So it's 10 51.in concert with 1-A, 101-C and the line. So it's a little.
11 more -- it's not quite that simplistic on the nort', but-those 12 are --
~~" 13 Q Okay, now I --
LaJ 14 A (Urbanik) -- the significant routes.
15 Q Now~,I understand what you mean by tree then. As the 1G trunck line from the beach area in Hampton, Route 51, gota to 17 the I-95 interchange, there is a tree effect that some of the 18 traffic is routed on and other traffic branches off, I believe 19 on Route, what is it, 1017 20 A (Urbanik) Righb.
. 21 Q But in terms of the main trunk lines, those are the 22 three; isn' t that true?
23 A (Urbanik) Well, we've left out 1-A to the north, so 24 I would kind of consider that as a secondary, but still 25 nevertheless a'significant route, I would think.
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759'I) l l' O. Are you now aware, Doctor, that the distribution of 1
2 cars counted by Avis for the Applicants.and those counted by 3 Dr. Befort for our office, the Attorney General's of fice, 4 result in a different distribution that in fact results in 5 different critical pathway? Are you aware of that?
6 A (Urbanik) I haven' t actually played with the l
7 numbers, no.
- 8 Q Well, this --
9 A (Urbanik) I don't find that surprising.
10 Q It's apparent in the Applicants' testimony on Page --
11 if you take a look at Page 44 of the Applicants' ETE 12 testimony, do you have that with you, Doctor? Do you have that I~'
L_a 13 testimony?
14 A (Urbanik) Is that No. 77 4
15 0 Yes.
16 A (Urbanik) Yes, I do. ,
17 Q On the top of Page 44,.do you see'the first couple of 18 sentences which read, "As noted on Page 10-20 in Figure 10-29 19 of Volume 6 of the NHRERP, the population of Seabrook Beach was ,
20 the last to clear from the EPZ. On the basis of updated 21 astimates obtained from the July 1987 photographs, the *
- 22. population of Hampton Beach will clear at a later time."?
23 A (Urbanik) I see that. .
24 Q And if you have read the testimony of Dr. Thomas 25 Adler reporting on the ETE runs which he did based on the beach I
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1 counts done by Dr. Befort and Dr. High, you see that they have 2 concluded -- he has concluded that the Salisbury Beach area is 3 the last to clear; isn' t that true:
4 MR. TURK: Could we have a page reference, please?
5 MR. FIERCE: We31, there's -- for example, there's a 6 diagram on Page 11-A, and there are various other examples
, 7 where Dr. Adler has reported that it is the Salisbury 8 evacuation routes which are the longest to clear.
9 I' m not sure I had a question outstanding. Let me 10 proceed with my question, Doctor.
11 (Pause.)
1 12 MR. FIERCE: I' m going to wait until I see you stop 13 reading. Are you ready to proceed?
14 THE WITNESS: (Urbanik) I' m with you.
15 MR. FIERCE: Okay.
16 THE WITNESS: (Urbanik) And I don' t perceive that 17 you' ve asked me a question yet.
18 MR. FIERCE: Al right.
19 BY MR. FIERCE:
20 Q But we are in agreement that we have a potential 21 three different critical paths for determining the overall ETE 22 here; i sn' t that true?
23 MR. TURK: Your Honor, let me object. The question I 24 think asks if the're is a potential. If Mr. Fierce is asking 25 isn' t it possible, then I don' t object, because the answer will Heritage Reporting Corporation (202) 628-4888
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1 reflect the question. But if he's asking i sn' t it true that 2 Dr. Adler has, based on a vehicle count has come up with a 3 definition of Salisbury as the critical path, I think we have 4 to look to see what goes into Dr. Adler's test imony.
5 As I recall, it was a lot more than simply the number 6 of vehicles on the beach. He put some other assumptions in 7 there, too. .
8 JUDGE SMITH: Well, aren' t you premature though? We 9 haven' t come to that point yet, have we?
10 MR. TURK: I may be premature. I' m just getting 11 ready to be mature.
12 (Laughter.)
I~" 13 MR. TURK: I thought t he t ime --
2: a 14 MR. DIGNAN: We' l l give you a free correction of the 15 transcript on that one.
- 16 MR. TURK: If the time is not ripe, then I' l l. Wait ,
17 but 1 thought the time was ripe.
18 MR. FIERCE: If Mr. Turk wants me to ask the question 19 using the word "possible" rather than the word " potential",
20 I' ll be happy to do that. That's not a critical part of my 21 question. . l 22 JUDGE SMITH: Ask the question in tnp way you want 23 it. .
24 BY MR. FIERCE:
25 O Isn't it true, Dr. Urbanik, that we have three j r-,
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i possible critical evacuation paths here depending on the 2 distribution of the cars on the beach?
3 A (Urbanik) Depending on the distribution of the cars 4 on the beach, and also depending on how we are going to route 5 those traffic. All the traffic management plans have built in 6 at places where traf fic may back up from one route the sat ion
, 7 t'o go another route. So these numbers that Dr. Adler have may 8 or may not take the dynamics of the traffic management into 9 account. I don' t know.
10 Q In fact, the traffic management plan ought to take 11 into account factors like that, isn' t it true, Dr. Urbanik?
12 A (Urbanik) I believe the traffic management plan does 13 have to be flexible enough to handle the contingencies of an 14 evacuation if it were ordered. There is no -- I don' t believe i
15 that any evacuation is going to look like any scenario that 16 we' ve postulated if it does occur. ,
17 Q If you take a look at Page 45 of the Applicants' 18 Testimony No 7, which is describing a series of sensitivity 19 runs regarding manning of control posts, you' l l see that on --
20 they are on Page 45 with respect to their sensitivity run No.
21 1. They note, "During the first two hours, evacuees from I
22 Hampton Beach will not be discouraged from traveling south over 23 the Hampton Harbor bridge into Seabrook.. Subsequently, all l
'.4 Hampton Beach evacuees will travel north and west only."
25 And then if you look two pages further on page 47, at
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i URBANIK - CROSS 7599 1 the top of the first full paragraph there is a sentence which 2 reads, "Since Hampton Beach traffic now (using the Avis data) 3 constitutes the critical path under the planning basis, any 4 movement south over the bridge could expedite evacuation."
5 It's apparent, isn' t it, that the Applicants realize 6 that depending on where that critical path is, out of Hampton, 7 out of Seabrook or out of Salisbury, changes can be made? .
j 8 For examp.e, a change in the traffic management plan 9 which either routes or does not route traffic over the Hampton 10 Harbor bridge can be accomplished; isn' t that so?
11 A (Urbanik) I don' t really understand your question.
12 You read some text out of a couple of different things and then 7~. 13 says, is that not so.
14 I think what you quoted is in fact true, and in fact 15 that, depending on how the traffic is routed, affects the 16 evacuation time, i f that's the quest ion you' re asking me.
17 Q If the critical path is out of the Hampton area, as 18 the Applicants have assumed in this testimony, then it makes 19 some sense, doesn' t it, to route some traffic to the south over 20 the Hampton Harbor bridge so that not all of the traffic from 21 Hampton is using one of those two critical path trunks that you '
22 have described, Route 51 or Route 1-A to the north?
23 A (Urbanik) If the question you. asked me does it make 24 sense to use, most effectively utilize the available capacity, 25 I think I agree with that. I think that's the wnole reason for I
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i URBANIK - CROSS 7595 1 this exercise is to understand how traffic and the roadway 2 system interact so that we can most effectively use it. Th a t ' s 3 really what we' re trying to do.
4 Q But, likewise, if the critical path is that-which l
5 comes out of either Salisbury Beach or Seabrook Beach, then it 6 doesn' t make any sense to route traffic from Hampton across the
,; . "7 Hampton Harbor bridge down into that area,.does it?
8 A (Urbanik) It doesn' t make sense to route traffic in 9 a direction that will -- that you know will increase the ETE, 10 that's correct, and if there is some part of the network that's 11 overloaded and you have another alternative that's not 12 overloaded, yes, you should direct the traffic in the direction i
13 that's not overloaded. That's essentially what all the traffic 14 management is trying to do.
15 Q Now I want*to direct your attention to the blackboard 16 upon which I have in chalk, I believe appropriately placed the j 17 chalk, which has on the left three columns, or three of the 18 beach areas, excuse me, Salisbury on the top, Seabrook in the 19 middle and Hampton I put north and south, and a N and 5 meaning 20 north and south on the bottom. And in the rows across the top, 21 or maybe I' ve got my rows and columns reversed, but they are in 22 the numbers 1, 2, 3, and, No. 1, I will tell you, stands for 23 the count of cars done by Bill Befort between 3:30 in the 24 afternoon and 4:45 on July 5th, and comes from Table 1 on page 1
25 17 of the Befort testimony. And No. 2 represents the count by !
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URBANIK - CROSS 7596 1 Avis of cars on the photos taken between 12:00 and 1:00 p.m. on 2 July 18, 1987, and comes from page 38 of the Applicants' 2 Testimony No. 7. The third column I have labeled No. 3 is in 4 fact not cars. That is the capacity numbers that were utilized 5 in Volume 6, and come from Appendix M of Volume 6 as reported 6 by Dr. Befort; again as a note on Table 1 on Page 17 of his 7 testimony. .
8 And, again, keeping in mind that the critical path, 9 according to the Applicants' in Volume 6, was that for Seabrook 10 Beach, Route 286, and according to the Applicants in their 11 tas*tmony No. 7, the critical path has now shifted to Hampton f
12 because of the count based on the Avis photos.
}~~ 13 And in the Adler testimony, Dr. Adler testifies that, 14 based on his work, and the counts from Des. Befort and High, 15 the Salisbury Beach area is the critical path. ,
16 Isn' t it apparent, Dr. Urbanik, that shifts from one 17 beach to the other of a few thounand vehicles causes the 18 critical path to shift from that used by the Hampton traffic to 19 that used by the Salisbury traffic to that used by the Seabrook ,
20 traffic? j 21 (A copy of what appeared
- 22 on the blackboard follows:)
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,, URBANIK - CROSS 7597 l 1 MR. TURK: Your Honor, for purposes of the question 2 I' ll simply accept it as a hypothetical. That 's represented to l 3 us that these are the numbers and I have not checked to see 4 these are in fact correct, but we will assume that if it is l
5 correct, I' ll let the witness answer on that basis.
6 MR. FIERCE: Subject to check.
7 MR. TURK: Subject to proof. .
f 8 THE WITNESS: (Urbanik) Looking at those numbers 9 don' t quickly lead me to the conclusion that you -- that you 10 would indicate. For instance, if I' m correct here, No. 1, 11 Salisbury controls, yet Salisbury has a smaller number than No.
12 3 where you say 286 controls, and that has a smaller number I-~
13 than 2, I think it's a little more complicated than just 14 drawing the numbers that you would suggest out of it.
15 BY MR. FIERCE:
16 Q Oh, I' m not saying it's not this simple, Doctor, 17 because obviously each of these critical --
each of these l 18 paths, these important trunk lines out of the beach area are 19 paths which are used by residents of the towns. There are ,
20 other roads that join them somewhat downstream f rom the beach 21 areas, but I' m just looking at the beach area vehicles, and
- 22 asking you, based on the testimony that we have, whether it 23 appears that shifts of a few thousand vehicles from -- in the 24 distribution of a few thousand vehicles from one beach area to 25 the other, assuming the testimony is correct about which area
=-,
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1 has becorne the crit ical path, it raakes a di f fererice in what 2 that critical path is; isn' t that true?
E237 3 (Continued on next page.')
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7S99 T2'38mb i A (Urbanik) To a large extent, that follows almost by 1
2 definition of what we are trying to do. We are trying to make !
3 the most effective use of all of the roadways out of the areas, 1 1
4 so desirably we would like them all to be pretty close in terms
)
5 of utilization. j
)
6 If we had a road that cleared in four hours, and a l 7 different part of our network was clearing in eight hours, we .
4 8 would probably want to do some traffic management to get some 9 of that other traffic on to the road thab was being under-10 utilized.
11 So, that is what -- traffic management is about 12 equalizing the volume of traffic on the various roadways.
[^ 13 Therefore, it follows if you change the demand in different
-a 14 areas, and didn' t change the traffic management, then, to some 15 extent, the -- a different part of the network might become 16 critical because they are all running at about the same ratio, 17 more or less.
18 We are not trying -- keeping in mind, we are not 19 trying to fine-tune the process so closely that we have got ,
20 exactly equal demand on all parts of the network.
21 Q So your recommendation, Dr. Urbanik, to use 30,500 22 cars, in the ETE runs for Scenario 1, in the beach area, does 23 not address this issue, does it, of how these vehicles are to 24 be distributed among these three beaches?
25 A (Urbanik) I did not make any specific recommendation L._, -
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URBANIK - CROSS 7600 1 on the distribution of vehicles, no, I didn' t.
)
2 Q And without knowing this distribution, you don' t know f 3 whether it is a good idea or a bad one, as a matter of traffic 4 management, to move the Hampton Beach traffic south, over the 5 Hampton Harbor bridge, do you?
6 (Pause.)
. 7 THE WITNESS (Urbanik): Well, in a real evacuation --
8 well, I guess to answer your question, the way to determine in 9 a real evacuation, which way to send them in the final 10 analysis, is going to be once a particular path becomes under-11 utilized, then we will send them the other way.
12 Q That makes some sense to me. But when you are 13 sitting here, in advance, designing a traffic management plan 14 and you know that you have got a problem because you cannot 15 implement all of your traffic control posts immediately and you 16 have to rely on a staffing sequence of state troopers that 17 perhaps only gets you seven troopers in the first hour, and you 18 have to make some decisions about where those troopers will go, 19 you need to know in advance, which traffic control posts are 20 important ones to implement and which are not, don' t you?
21 A (Urbanik) Yes, we do and I think we also know where 22 they are. They are -- going back to our analogy of the tree --
23 the traffic control is less important in the beach area, than 24 it is out on those places like 110 and I-95, where all the traffic is concentrated, l 25 Heritage Reporting Corporation -
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1 The traffic control at other areas is only necessary 2 to the extent to make sure that we are keeping the critical 3 points well supplied with traffic. What-I think you may be 4 getting mixed up with from time to time is we really aren' t 5 worried about who is the last person out. What we are worried i 6 about is are we utili. zing the capacity at the critical points 7 in the network to its utmost? .
8 So, later on, in the evacuation we can shift some of 9 that stored beach traffic either north or-south, depending on 10 which way is actually flowing better. So through radio 11 communications, aerial observation, whatever, you would balance 12 out the, you would balance out the traffic.
"~
13 Q As a general proposition that might make some sense,
- J. a 14 Doctor Urbanik, but where we are talking about this particular 15 traffic control post, over the Hampton Harbor bridge, if you 16 have a situation where that traffic control post isn' t 17 implemented, and a thousand vehicles, coming out of the 18 Hampton Beach State Park decide, because of the traffic 19 congestion they see to the north in Hampt on, to go south over ,
1 20 the Hamoton Harbor bridge, ending up in the traf fic st ream down 21 in Salisbury, and that turns out to have been a mistake,
- 22 because the critical path is either out Route 286, or out )
23 Rout e 1-A and Route 110, you can' t t urn t> hat traffic around, I a 24 can you, and send it back north, back up through"Hampton, 25 because to do so, is to send it direct ly back closer to the i--
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URBANIK - CROSS 760a 1 nuclear plant, isn' t that true?
2 A (Urbanik) No, it is not.
3 And you have missed an important point. You are 4 assuming that these cars, at Hampton Beach State Park, for 5 instance, can just summarily, all of a sudden, transpose their 6 position down past into the Salisbury traffic.
7 Now, we have been going through how slow .his traffic 8 is moving, how dense it i s, and all those people in front of 9 them are there, occupying the space.
10 So, within a short period of time, after the beach 11 closing or the order to evacuate, or whatever is appropriate, 12 the roads become saturated, those people, which you have argued 13 with me, very extensively, are not moving very fast, have, in 14 fact, not even left the Park.
15 So they don' t have to turn around; they are still 16 waiting to Det out.
17 Q Well, you have changed my hypothetical on me.
18 I have given you a hypothetical, which is that the 19 traffic coming out of the Hampton Beach Park finds no traffic 20 control post, which, if it were implemented, would discourage
- 21 them from turning south over the Hampton Harbor bridge.
22 And decides to go that route. It is at the very end 23 of the traf fic stream, for either pathway: that coming out of 24 Hampton or that which would have been coming out of Seabrook 25 Beach.
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URBANIK - CROSS 7603 i i But you can' t turn that traffic around, can you, !
2 Doctor Urbanik, once that traffic has made that decision and is 3 rnovi ng in that direction?
4 A (Urbanik) I could turn them around if I wanted t o.
5 But I am trying to tell you there is no reason to turn them 6 around.
7 JUDGE SMITH: Does this exarninat ion st ill trace .
8 itself back to the -- their recornmendation that the -- is it 9 still gerrnane to that?
10 MR. FIERCE: Yes.
11 This has to do with the recommendation about 12 30,000 --
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1 13 JUDGE SMITH: -- 500 --
.-a 14 MR. FIERCE: -- 500 vehicles.
I 15 BY MR. FIERCE:
16 Q And Dr. Urbanik, --
17 MR. FIERCE: Excuse me, Judge, did.you have sornet h i nD 18 further?
19 JUDGE SMITH: Well, are you on Part 8 of your cross- ,
20 examination plan?
21 MR. FIERCE: Your Honor, my cross-exarni nat ion plan 22 was prepared before the testimony was supplemented. My 23 intention is to ask a great deal rnore questions about this 24 supplementary stuff, and I am going to be striking substantial l 25 portions of what is on that outline.
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1 JUDGE SMITH: I am just trying to follow the logic of i 2 it.
3 MR. FIERCE: Okay.
4 BY MR. FIERCE:
5 Q Dr. Urbanik -- 1 0
6 JUDGE SMITH: Could you give us an estimate of how
, 7 much longer you do have?
-8 MR. FIERCE: Oh, I may have an hour.
9 JUDGE SMITH: Okay.
10 BY MR. FIERCE:
11 Q Dr. Urbanik, isn' t it entirely possible, and perhaps 12 even likely, that the beach area vehicle distribution, varies
, 13 from one good beach day to another?
(.
14 A (Urbanik) Yes, I agree with that.
15 And in fact, that was the reason that I made the 16 point that wear marks are not a good indicator of how many you 17 can get on the beach, because at particular times, these cars 18 are going to be in different places.
19 So, yes, the distribution on the beach will vary.
20 Q And it is because we have got some different features 21 up and down this beach. We have a casino area up in the 22 Hampton Beach strip. We have an amusement park with rides down 23 in the Salisbury Beach strip which are special situations that 24 tend to draw populations at different times of the day, isn' t 25 that true?
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1 MR. TURK: Is the question, that that is the reason i
2 for the distribution changes?
3 MR. FIERCE: It is one of the reasons, isn' t that --
4 THE WITNESS (Urbanik): Well, you added in terms of 5 different characteristics of these different beach areas, I 6 think that has some implication on the distribution.
7 But so does the availability of the sheer physical -
8 size of the facilities. How many, how many, how many usable 9
l' parking areas you have based on what you can get i n, and in 10 fact, use that.
11 But then you brought in time of day and I don' t la understand the implication of time of day in your question.
~~~
13 BY MR. FIERCE:
14 Q Well, let me take you back.
15 You have agreed with me that distribution of vehicles 16 perhaps varies among these three beaches, from one good beach 17 day to the next, is that correct?
18 A (Urbanik) Yes, I believu the distribution would vary 19 somewhat.
20 Q And isn' t it also likely that distribution of 2i vehicles on the beach might vary from one good beach day to a
- 22 mediocre beach day? l 23 JUDGE SMITH: This is proportionate distribution?
24 MR. FIERCE: Yes. Between Seabrook, Salisbury anc i
25 Hampton Beaches.
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1 THE WITNESS (Urbanik): I think that there might be 2 some differences during different weather conditions, 3 certainly.
4 Q And isn't it also possible, and perhaps even likely 5 that the distribution among these three beaches of vehicles in 6 the area, varies by time of day?
, 7 A (Urbanik) Yes, I think the distribution could vary 8 by time of day.
9 Q Now, in the ideal world, Dr. Urbanik, wouldn' t the 10 prudent planner like to have information, not only on how large 11 the total size of the beach vehicle population was at a given i 12 moment, but how it was distributed as well?
13 A (Urbanik) Well, there is no way the prudent planner ,
l 14 can know on any given day, time, -- j i
15 Q That is not my question, Doctor.
16 My question is, wouldn' t a prudent planner like to 17 know that in an ideal world?
18 JUDGE SMITH: You are right, he can answer it that 19 way, if he wishes.
20 MR. TURK: I object to the interruption. I think 21 that the Witness was giving a fair answer and he should be 22 permitted to complete it.
23 JUDGE SMITHS Yes, I agree. .
24 THE WITNESS (Urbanik): I lost my train of thought 25 here. The prudent planner has to deal with the reality that Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 760'r 1 the distribution does vary as you say, from beach to beach and 2 day to day and week to week and season to season.
3 And the way we deal with that is coming up with a 4- representative estimate of the population, developing a plan to 5 address that population and build in enough flexibility to be 6 able to adapt to changes.
7 What seems to be lost,- is that somehow we are going -
l 8 to construct a big set of estimates that are going to cover 9 every contingency. I 10 And there are.just too many combinations to do that.
l l 11 BY MR. FIERCE:
I.
12 Q Pretty easy to do an I-DYNEV run for a half a dozen
'7~ 13 or another dozen situations, isn' t it, Doctor?
L )
14 A (Urbanik) Once your model is up and running, 15 additional runs are relatively easy to come by, but at a 16 certain= point, you have too much data and not enouDh 17 information. You cannot seu the forest.for the trees. I think J
10 we are already approaching lthat point with 500 separate ;
19 estimates of evacuation time. .
20 Are we going to have 5,000 estimates and then which 21 one does the decision-maker pick?' I think we have got to keep '
- 22. the number of estimates down to a reasonable number, and then 23 the decision-maker, assuming he has some. good estimates and 24 knows what those estimates are based on, can then make the 25 adjustments he needs.to handle any of the dynamics in a real Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 7608 1 situation, if it were to occur.
2 Q Your estimate of a reasonable number, of ETE's for a 3 summer weekend, is one, is that correct?
4 MR. TURK: Can I hear the question again?
5 JUDGE SMITH: Your estimate -- well, --
6 BY MR. FIERCE:
. 7 Q Your estimate of a reasonable number of ETE's for a 8 sunsmer weekend is one, is that correct, Dr. Urbanik?
9 A (Urbanik) No.
10 Q Well, how about a half a dozen?
11 A (Urbanik) There is no magic number. We have 12 probably done at least a dozen or more already. It is probably 13 a lot more than that.
14 We have a number, and then we have a series of 15 sensitivity runs that indicates, what is affecting that number.
16 So we have a good number as a starting place,- and 17 then we have a series of sensitivity runs that tells us what 18 that number is sensitive t o.
19 So, we have got quite a few estimates already.
20 JUDGE SMITH: Pick a place, will you, for the 21 afternoon break?
22 MR. FIERCE: Let me just try one more question and 23 then we can take a break. .
24 BY MR. FIERCE:
25 Q If I read Applicant s' Testimony Number 7 correct 1y, Heritage Reporting Corporation (202) 628-4888 I
.g. URBANIK - CROSS 7609 L_ .
1 they did a series of sensitivity runs,- perhaps like you are 2 suggesting and one of the things that they were doing, is 3 allowing vehicles to travel south over the Hampton Harbor 4 bridge, and they believe that was a smart thing to do, because 5 in fact, the critical path has now shifted from the southern j i.
6 portions from Seabrook Beach in Volume 6, up to Hampton.
7 And that that, therefore, relieves traffic congestion -
8 in the Hampton area.
1 i
9 But you don' t know, do you, on a given day, whether 10 that is a smart move to make unless you know something about 11 the distribution on that day of the beach area vehicles in the 12 Hampton, Seabrook and Salisbury Beaches?
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13 MR. DIGNAN: I object.
_. a 14 That question is flat dead wrong in its premises of l
15 the Applicants' thought that was a better thing to do. Just 16 flat dead wrong.
17 Page 47 on direct makes it clear what we did and we 18 never recommended that.
19 MR. TURK: Your Honor, let me note that I had an .
20 objection also in terms of the complexity of the question, and l 21 whether the predicate had been established. '
22 JUDGE SMITH: Do you believe.that it has been 23 established? -
24 MR. TURK: Well, the questioner nald that --
25 JUDGE SMITH: No, I was asking Mr. Fierce.
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URBANIK - CROSS 7610 1 MR. FIERCE: Well, I will rephrase the question in 2 line with the testimony, Applicants' Testimony Number 7, which I 3 says, that since Hampton Beach traffic constitutes the critical 4 path, under the planning basis, any movement south over the l 5 bridge could expedite evacuation.
6 BY MR. FIERCE:
. 7 Q And my question is, you don' t know, do you, Doctor, 8 whether allowing movement south over that bridge, on any given 9 day, could expedite evacuation or lengthen evacuation, unless 10 you know something about the distribution of those vehicles in 11 the Hampton, Seabrook and Salisbury Beach areas?
12 A (Urbanik) The distribution of traffic could affect 13 which links are critical but I don' t agree with what you are 14 saying in terms of the notion that sending them south is an l 15 idea that is attempting to optimize the flow.
l 16 I think what the Applicants' testimony is saying is l
17 that for a variety of reasons we sent the traffic north, but if 18 we don' t have any traffic control the traffic will go south.
19 And that is consistent with my understanding and my 1
20 experience with Seabrook. One of the early concerns, one of l
21 the early concerns we had was the question of the drawbridge 22 over Hampton Harbor.
23 And we were concerned that what if we had an 24 evacuation and all of these people want to go south, want to go 25 over the drawbrid De and the drawbridge is up, letting all of Heritage Reporting Corporation (202) 628-4888
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1 the boats come in?
2 So the natural perception for a number of people to 3 evacuate is to evacuate south. So that is the way they-are 4 going to go.
5 In terms of it being critical, it turns out -- well, 6 in terms of trying to get the most use of the existing 7 roadways, you do, in fact, want to send people to the north. -
i 8 You cannot take as many south as would like to go, so the 9 traffic control sends them to the north.
10 The idea that these people are going to be able to 90 1 l
11 south, i s, in the early hours of an evacuation, is contrary to '
12 the idea that those roads are saturated with traffic from all
\w
}"" 13 the other beaches.
l 14 So the people from Seabrook Beach will be utilizing 1
l 15 all the capacity of Route 28G to go out of there, and few, if 1
l 16 any people can get out of the area.
17 So, I don' t believe that the distribution of-traffic 18 along the beaches, is a monumental impact on the evacuation, 19 evacuation times, given that we are going to be trying to ,
20 manage the flow in the best possible way.
21 MR. FIERCE: Take a break.
- l 22 JUDGE SMITH: All right. ,
l 23 We will take a 15 minute recess.
24 (A brief recess was taken.)
25 1-L_ .s -
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T239 1 JUDGE SMITH: Mr. Fierce.
2 BY NR. FIERCE:
3 Q Dr. Urbanik, if you could have half a dozen indicator 4 points from Salisbury north to North Hampton which indicate the 5 approximate size of the population at each point, and this 6 could then give you a quick read on the distribution of 7 vehicles, wouldn' t you agree that that would be a relevant data 8 base to have?
9 A (Urbanik) A relevant data base for what?
10 Q Well, if you had some read on what the distribution 11 of vehicles was, you' d have a better sense of what the' critical l 12 path was, wouldn' t you?
I~~ 13 A (Urbanik) I guess you would know what the critical I J_J 14 path at that particular point was.
15 Q At that particular point in time on that day.
16 A (Urbanik) Right.
17 JUDGE SMITH: Well, what is the hypothesis now?
18 You' re going to have half a dozen?
19 MR. FIERCE: If you had half a dozen indicators.
20 JUDGE SMITH: Indicators.
l
. 21 MR. FIERCE: Indicators.
22 JUDGE SMITH: Wh at ' s an indicator, a population 23 figure? .
24 MR. FIERCE: It could be a variety of things. It )
i 25 could be the percentage at which a particular beach lot was !
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2 JUDGE SMITH: Okay, but it's an indicator of the 3 population at that --
4 MR. FIERCE: Yes.
5 JUDGE SMITH: -- hour.
l 6 MR. FIERCE: Yes. Could be a traffic recorder.
7 BY MR. FIERCE: .
8 Q And wouldn' t it also be relevant because thm; once 9 you knew what the relative distribution of vehicles was on the 10 beach, you might be able in advance to make some adjustments to 11 your traffic management plan, and know where to assign your 12 traffic control personnel first; isn' t that true, Dr. Urbanik?
- 13 A (Urbanik) I' m not sure that that would be the case.
i l 14 We have to develop the plan, and print it, and publish it, and l
l 15 distribute it to all the policemen. So I woula think a better 16 approach would be a traffic management plan that could respond i l 17 to differences in distribution of traffic rather than trying to 18 predict every conceivable different distribution.
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19 l l
Q I guess I just don' t understand how that can be done ,
i 1
20 unless you' ve got some read on a given day of what the j 21 distribution of vehicles is and the number of vehicles. Can '
1 i
22 you explain to me how you develop in advance that kind of ;
23 flexibility? . ,j l
24 JUDCE SMITH: I' m missing the ' point of difference
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25 between you and the witness. It escaped me.
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i URBANIK - CROSS 7619 1 I would like to hear his answer read back.
2 (Accordingly, the record was read back by the E239 3 court reporter.)
T240 4 JUDGE SMITH: Yes, go ahead. I don' t see what your 5 dispute is right now.
6 MR. FIERCE: Well, maybe thare isn' t one, and maybe
. 7 that's what we need to clarify, because I think I could agree 8 that there ought to be a plan which responds flexibly to the 9 situation as it is presented at the moment, but my question is 10 how does one does that without having information about the 11 size and the distribution of the population on the beaches.
12 JUDGE SMITH: Did I infer correctly from your answer 13 that information concerning population distribution at any 14 particular time would be useful? You' re not denying that it 15 would be useful, are you?
16 THE WITNESS: (Urbanik) No, I' m not denying that, 17 no.
18 JUDGE SMITH: Your point is that it should not be 19 used in a fixed, preset plan, but it should be used in a 20 flexible plan if you had the information.
21 THE WITNESS: (Urbanik) What I' m saying is that 22 there -- knowing all that information would be helpful in 23 looking at what might transpire in the network under different j 24 circumstances. But to actually develop plans for all those 25 different kinds of distributions just isn' t practical.
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i URBANIK - CROSS 7615 1 It's int eresting information, but I guess what I' m l 2 saying is I don' t think it's going to be practical in 3 developing a traffic management plan.
4 BY MR. FIERCE:
5 Q Isn' t it practical in a situation like we have here, i 6 Dr. Urbanik, where you know what you have limited resources to 7 call on immediately to staff your traffic control points, you . j 8 have flexibility therefore in deciding where those initial 9 arrivees, the state troopers and others, will go with respect 10 to which traffic control posts to implement and which ones not 11 to? Isn' t that the flexibility that this plan offers at this 12 time for which knowledge of the distribution of the vehicles on 13 the beaches would be extremely helpful?
14 A (Urbanik) I don' t think it would be extremely 15 helpful in developing the -- the actual, actual plan. I guess 16 I have to -- the problem I' m having is to exclude information.
17 Obviously, the better understanding you have of any phenomenon, 18 you know, the better you could plan for it.
19 But when it gets right down to the usefulness of that 4 s 20 information in the plan, at a certain point the plan becomes 21 too complicated, too many alternatives to be effective. So tne -
22 plan has to have flexibility and be more responsive to what'u 23 going on. And I think we know where the. critical poi nt s in the 24 network are relative to early staffing. And I think the i 25 decisions that are made in the beach area are not going to be l
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1 overly critical in the early hours. i 2 What will be critical is in the later hours that we j i
3 get enough traffic in the various parts of the system.
4 Q The later hours. You are assuming then that there is '
5 some flexibility in this traffic management plan? 1 6 A (Urbanik) Yes. I think a good example, if you would
. 7 turn to Volume 6, Page I-13. The traffic management scheme at 8 this location says, " Facilitate movement from southbound Route 9 1-A on the westbound 286. If westbound 286 becomes congested, 10 then send traffic southbound on 1-A."
11 So you can balance traffic on alternate routes when 12 one becomes -- if your principal route is overly congested and 13 the other major route of the area, in this case is 1-A to 110 14 is able to flow, then you send traffic down that alternate 15 route until it also becomes full with t ra f f).c. So you' re 16 essentially at this point loading two alternative paths.
17 Keep in mind that within a 10-mile EPZ of largely 18 two-lene roads flowing at capacity, at most we can get perhaps 19 200 cars per mile. So it's not --
it's not like if the route 20 is congested we can send huge volumes of traffic down there.
. 21 The system, once it becomes full, is a pretty good indicator of 22 whether or not that capacity is being utilized.
23 And if Route 286 is congested and stays congested, 24 and 1-A doesn' t , you can continue to send traffic down 1-A 25 until it becomes congested.
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i s URBANIK - CROSS 7617 1- So the trcffic management can be very responsive to 2 the distribution of traffic that exists in the area. If it 3 turns out --
for example, it it turns out that this day that 4 Salisbury Beach is very crowded, you' re not going to be able to 5 send much traffic south on 1-A, and that option just won' t 6 materialize in real time. And so what you' ll do is ycu' ll 7 continue to send it your primary route, which'is 286. .
8 Q Dr. Urbanik, on Page 1-1, the traffic control post at 9 the Hampton Beach St ate Park, you don' t see any such 10 flexibility do you?
11 A (Urbanik) No. The situation here is to seno the 12 traff,ic north. However, the sensitivity runs actually indicate l
13 that this traffic -- this traffic plan does not, does not
.\
14 optimize the total system capacity. Their additional runs said '
l 15 that in fact if you did send some south, you actually can have 16 a reduction in the evacuation time.
i 17 Q And those sensitivity runs are based on a series of i I
18 assignments of the beach area vehicles according to a i 1
l' 19 distribution that came from the Avis counts; isn' t that ,
20 correct?
21 A (Urbanik) Yes. -
22 O And i f the distribution had instead come from the 23 Befort counts, that's sensitivity study might have shown 24 something completely different;' isn' t that true?
25 A (Urbanik) Might have, might not have.
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1 MR. DIGNAN: Wait a minute. Excuse me.
2 Was that'from the Befort counts?
3 MR. FIERCE: That's right.
4- BY MR. FIERCE:
5 Q But there's no flexibility built into this traffic 6 control post, is there? Yes'or no, Dr. Urbanik?
. 7 A (Urbanik) Well, in an absolute sense, all the 8 traffic-control points have flexibility. If his bona gets on-9 the radio and tells him to disregard the_ plan,-then he goes' 10 into an alternate mode.
11 Q Know of anything in the plans that says'that that 12 traffic control guide as he stands there in_ front of those
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13 barricades has a radio.with him?
14 A (Urbanik) I don' t know what'this.particular. officer 15 does or doesn' t have, no.
16 Q If the distribution were different than in the Avis 17 counts, and in fact were more heavi'ly distributed to the-south, 18 then if traffic were allowed to travel over the-Hampton Harbor 19 bridge, the fact that there is flexibility;down at the_ Route 20 286 intersection doesn't remove this initial problem of 21 directing traffic into an area where it may take them longer to 22 get out, does it? <
23 A (Urbanik) I don' t ' understand your question, because 24 the. analysis says if they go south it takes.less timeL to 25 evacuate.
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i URBANIK - CROSS 7619 1 Q If you have a different distribution of vehicles such i
2 that it would not take a shorter time if they'went south but !
3 would take longer, then this would be a mistake to allow these 4 vehicles to head to the south, wouldn' t it?
5 A (Urbanik) You' re givinD me a hypothetical that in 6 fact the situation exists that you want to send no traffic 7 south; is that correct? .
8 Q That's right, that's right.
f l
9 If the distribution of the traffic.in the beach area i
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10 is such that the critical path is either Route 286 or out of i J
11 Salisbury on 1-A to Route 110, then you would not want to add 12 vehicles to that stream of traffic from the Hampton Beach area; 13 isn' . t hat correct, Dr. Urbanik?
14 A (Urbanik) That is correct, and that, (a) doesn' t 15 happen with the traffic control plan, but,- (b) if the traffic
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16 control plan is not there, all that will happen if that traffic 17 control isn' t there during the early time in an evacutation, for 18 instance, the only thing that will happen is a few people will 19 get out of the beach, will get over the road, over the bridge 20 and then they' ll wait.
21 So you' re asking me, I think, whether or not the few
- 22 cars that could initially get out of there under the condition 23 that there is no capacity are going to affect the ETEs, and 24 you' re -- I can' t accept your hypothetical as being at all 25 reasonable.
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URBANIK - CROSS 7620 1 If there is too much traffic to the south of the 2 bridge such that the traffic to the south of the bridge 3 controls ETEs, very, very little traffic will be able to get 4 out of Hampton Beach Park and go south. They will, of their 5 own observation, decide to go north, if they can get out at all 6 in the early hours.
- 7 Q Dr. Urbanik, are'you aware that the traffic control 8 posts for the Seabrook traffic management plan cannot all be 9 staffed immediately upon the declaration of an order to 10 evacuate?
11 A (Urbanik) Right, I understand that immediate 12 staffing is not possible for all traffic control points, yes.
13 Q And are you also aware that suggestions have been 14 made with regard to which of the traffic control posts ought to 4
15 be staffed first, and that the traffic control posts have been 16 given an order of priority?
17 A (Urbanik) Yes, that's my understanding, and t hat ' s, 18 I think, consistent with what my testimony says ought to be 19 done.
20 Q And, therefore, that when a state trooper is 21 responding to the EPZ, he will be notified based on his rank in 22 the arrival order, i f he's first, second, third or fourth. He 23 will then be informed as to which of the. traffic control posts 24 to report to?
25 A (Urbanik) That's my understanding, yes.
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1 Q So that, therefore, there is flexibility.with 2 respect to which of the traffic control postu are staffed 3 first; isn' t that true?
4 A (Urbanik) There is always flexibility to change your 5 mind at the last minute. But as I would understand the 6 process, there would be a predetermined sequencing that would 7 be used. -
8 Q And that's based on an assumption of a particular.
9 distribution of vehicles in the beach areas, isn' t that so?.
1 10 A (Urbanik) Not necessarily, no. It's based on where 11 are the critical points that need capacity enhancement. And 12 capacity enhancement is only modestly related to the 13 distribution of the traffic, and it's certainly not related to 14 the distribution of the traffic early in an evacuation, because 15 we' re going to have plenty of traffic at all places.
16 What we' re trying to avoid is having any of them 1 17 starve for traffic, but that's not going to be a problem early 18 on.
19 Q Now with respect to the size, just the size of the ,
20 beach population, don't you think that would be a useful piece 21 of information for protective action decisionmakers to have at
- 22 hand before they make a determination regarding what protective 23 action to take, and in fact before they can even make the 24 reasoned calculation on what the evacuation time is likely to 25 be for that given day and weather conditions?
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1 MR. TURK: I' m sorry. I lost the' question due to its '
2 length.
3 JUDGE SMITH: Would you read it back, please?
4 (Accordingly, the pending question was read back l
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5 by the court reporter.) ,l E240 6 (Continued on next page.)
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, ., URBANIK - CROSS 762.s T241MB 1 BY MR. FIERCE:
2 Q Can you answer the question, Dr. Urbanik?
3 A (Urbanik) Well, if I understand the question, that 4 is what we are doing in the ETE, is giving the decision-maker a 5 useful ETE, based on what we expect the beach population to be.
6 O But on a given day, since we have discussed thiu 7 problem before, the population may not be at 30,500 vehiclest ,
8 it may be at 20,000 vehicles, 25,000 vehicles.
9 Woul dn' t it be a useful piece of information to know 10 on a given day, what the size of the vehicle population was in 11 the beach area?
12 A (Urbanik) It would be helpful in picking numbers to 13 have an indicator of the population, yes.
14 I think to a large extent, we have some general 15 indicators -- weather, month of the year.
16 Q Dr. Urbanik, were you here when Dr. Adler testified 17 about the kind of indicators that would be useful in affording I 18 protective action decision-makers with information regarding 19 the size and distribution of the beach vehiclo population on a 20 given day?
1 21 A (Urbanik) Yes, I was. . i 22 O And Dr. Urbanik, let's assume that this coming 23 summer, 1988, Seabrook is yet unlicensed.to operate. And that 24 for a total of $20,000, a data base of this. kind could be put 25 together upon which further ETE work could be conducted. l l
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77 URBANIK - CROSS 7626 1 Given that hundreds of thousands of dollars have 2 already been spent by the Applicants to give us, and the State 3 of New Hampshire, to give us the ETE's . in Volume 6, that no one 4 here thinks are accurate, not even the Applicant, wouldn' t it 5 be reasonable to ask the Applicants and the State of New 6 Hampshire to gather this data, in order on a day-by-day, hour-
- 7 by-hour basis to know what t raf fic cont rol -- strike that'-- to 8 know what the size of the vehicle population was in the beach j 9 areas?
10 And, also perhaps to have some distribution about 11 those vehicles?
12 MR. DIGNAN: Objection to the form of the question.
, 13 I don' t recall any Applicant Witness saying that I
14 those ETE's in Volume 6 weren' t accurate.
15 M'R . FIERCE: I believe there were Witnesses who said 16 that they may have been accurate at the time that they were 17 made, but they would not rely on them for the summer of 1988.
i 18 MR. DIGNAN: That is a much different proposition, I 19 Mr. Fierce.
20 JUDGE SMITH: Well, given that.
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21 MR. FIERCE: Given that --
22 JUDGE SMITH: Well, as I understand it, he is 23 supposed to say wouldn' t ' it be reasonable or to state it 24 another way, would he recommend that if valid indicators of 25 day-to-day population could be developed for $20,000, would he Heritage Reporting Corporation (202) 628-4888 l
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s URBANIK - CROSS 762'y 1 recommend that that be done?
2 MR. FIERCE: Exactly.
3 JUDGE SMITH: Would you?
4 This is not your money either. This is --
5 THE WITNESS (Urbanik): It makes it so much easier to 6 spend when it is not your own. Sorting out, sorting out t he --
7 the question was extremely long and had a lot of extra things -
8 in it, but if we focus on the, if we could, for S20,000, come 9 up with a little black box to project population at any hour of 10 any day, on any summer, would that be a wise expenditure of 11 funds?
12 I think that reasonably would be. That if we could 13 easily come up with a number like that. I don' t believe that 2_a 14 to be the case, at all, given the amount of time, effort and 15 study that has gone into trying to quantify the beach 1
16 population.
17 You would need to use Doctor Adler's little equation l
4 18 with four or five different parametern. You would need a huge j 19 data base that would include all of those things in it, and ,
20 being able to go out there and with aerial photographs at 21 different hours of different days under different_ conditions,
- 22 so that you could know the population when it is cold and web; l 23 the population at 2:00 o' clock; the population at S:00 o' clock. )
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24 And be able then, to have all of those data points to ;
1 25 correlate in a regression analysis or some equation, would I.- - -
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i require more than a few aerial sorties just to begin gathering l
2 that data.
3 So, just based on the aerial photography costs, I 4 don' t think you could do that.
5 BY MR. FIERCE:
6 Q One of the easy things to do is to make it sound so
- 7 expensive, that it is unreasonable. But if you are asking a i 8 protective action decision-maker, whether it would be useful 9 information, not to have perfect information that every hour of 10 the day, in every kind of weather conditions, but asking them 11 whether it would be useful to have a data base of information 12 that would provide a series of points, of information at a 13 variety of different times of day, not all times of day.
14 And on a variety of different kinds of weather 15 conditions, what the size, and the distribution of the 16 population of the beach vehicles was at those points in time, 17 wouldn' t that protective action decision-maker say, yec, that 18 is a piece of useful information I would like to have?
19 MR. TURK: Objection.
20 Objection for several reasons: one, the complexity 21 of the question; two, the statement at the beginning where he 22 said, it is possible to make the costs seem so high as to make 23 it unreasonable. .
24 And finally, the asking the Witness to put himself in 25 the shoes of a decision-maker and trying to' answer what a Heritage Reporting Corporation (202) 628-4888
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1 decision-maker might say. t 2 JUDGE SMITH: Well, as to the first, I did not regard 3 that as a part of the question. That was an argumentative 4 statement that you, perhaps, you could have objected to and we 5 will just ignore that.
6 As to the rest of your objection, no, I think that to 7 the extent that he is asked to be put in to the place of a .
l 8 decision-maker in the area of his expertise, it is appropriate. 4 9 Objection overruled.
10 THE WITNESS (Urbanik): Obviously, if I am making a 11 decision, I am always going to want as much information as I 12 possibly can to make a decision. However, I have been involved 13 in enough decision-making processes to realize that most 14 decisions have to be made on a less than perfect data base, and 1
15 that you have to mentally fill in some of the gaps that come in 16 with the decision.
17 BY MR. FIERCE:
18 Q Dr. Urbanik, I want to move on to the third 19 recommendation that you made, which has to do with what is ,
20 described in your supplemental testimony as screening at4 access 21 control points.
- 22 And I believe your testimony was that the plan snould 23 be revised to eliminate screening at accass control points of 24 vehicles returning to the EPZ during the'early portion of i 25 evacuation.
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T URBANIK - CROSS 7628 1 Is that correct?
2 A (Urbanik) Yes.
3 Q I think I understand what you mean by screening at l 4 access control points, but perhaps it would be helpful to 5 describe exactly what you meant?
6 A (Urbanik) What I am talking about by screening is 7 that there would be a traffic control person at the perimeter 8 of the EPZ askinD occupants of the automobiles for 9 identification indicating that they, in fact, had a legitimate 10 reason to be within the EPZ.
11 O What is wrong with doing that kind of checking, 12 Doctor?
13 A (Urbanik) Well, it is going to impede those persons 14 from returning into the EPZ and I don' t b.elieve going to 3
15 particularly provide any benefit.
16 Q I am not going to disagree with you on that. In 17 fact, I think that this may be one of the areas wnere you, Dr.
18 Adler, and Mr. Lieberman are all in agreement.
, 19 But I want to ask you some questions about the 20 implications for that recommendation.
21 And if you would turn to the traffic control point, 22 or, excuse me the access control point on Page L-30, it would 23 be helpful to me. .
24 (Witness examines document.)
25 THE WITNESS (Urbanik): I have it.
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URBANIK - CROSS 7629 ]
I 1 BY MR. FIERCE:
2 Q Now, is in making the recommendation that you have, 3 are you also recommending that this particular access control 4 diagram be changed, in any way, or would you recommend that 5 this particular access control diagram be changed?
l 6 MR. TURK: And this is at early parts.of the 7 evacuation? -
)
l 8 MR. FIERCE: That is right. !
9 (Pause.)
10 THE WITNESS (Urbanik): I am not sure where this 11 point exactly is.
I 12 MR. FIERCE: Oh, well, I can -- if I can approach the 13 map, I believe that I can show you where this is, Dr. Urbanik.
14 THE WITNESS (Urbanik): Thank you; I would 15 appreciate that.
16 (Counsel approaches the map.)
17 THE WITNESS (Urbanik): Yes, that was rny perception 18 of the general area. I was not -- for the record, he is l 19 pointing to Route 1, is that the number? ,
20 It is just west of I-95, on the Spaulding Turnpike.
21 Route 4. '
22 MR. FIERCE: I might also add that this particular 23 access control point is one which will be high on the priority 24 list of the recommendations that the Applicant has made for i 25 staffing of access control points.
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URBANIK - CROSS 7630 1 BY MR. FIERCE:
2 Q And my question i s, would you recommend that the 3 traffic control diagram, the accesr.. control diagram be changed 4 in any way in order to achieve the purpose for which you are 5 making this recommendation about checking, that it not occur?
6 A (Urbanik) I am not aware of-anything that would make 7 my recommendation at this location be different than, different 8 than elsewhere.
9 I presume that the reason for returning these traffic 10 is to keep them from accessing I-95, and heading southbound.
11 Q Well, presumably the way the traffic is being routed 12 here, on this diagram, suggests that unless -- under the plans I l
13 as they existed, unless ore were able to show an identification 14 or a sufficient purpose for entering the EPZ, the traffic j
15 control staff person there, would direct the remainder of the !
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16 traffic to turn about, and head back the other direction on 17 Route 4, toward Dover.
1 18 And I am just -- what will happen now, under the 19 early stages of the evacuation, without access checking? What 20 will happen to this returning traffic? 1
. I 2: A (Urbanik) Well, without access checking, the 22 returning traffic is free to Do through, at their will.
23 Q So the barricaden would utill be there, but traffic
.i 24 would be free to go through at its will?
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i said nothing was in place, and now you have --
2 Q Oh , no.
I 3 I am asking you if you would change anything, for 4 example, the placement of the barricades. Would the 5 barricades still ne there, if you did not use the access 6 checking technique, the ID checking?
7 A (Urbanik) I Duess my presumption would be that for .
8 the early portion of evacuation, it is unlikely that the 3 9 barricades are Doing to be there anyway. But I would see no-10 reason to necessarily prohibit the returninD evacuees from
- l 11 using that particular route.
12 But there, you know, there may be a particular, you !
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}~' 13 know, local circumstance that, as a result of meeting, you l 14 know, when the Applicant does all this, they have to meet with 15 all the local folks and know all the local circumstances.
i 16 And I cannot sit up here, and purport to know that 1 17 there is some unique reason why there should or should not be 18 a different strategy here.
19 But I would assume that you would perhaps let t hsem go .
20 through during the early times, without barricades.
21 Or perhaps put up your barricades such as to
- 22 discourage the movement and let people that really want to get 23 through, Do through. That would.probably.be the - you know, ;
-l 24 you put up a -- you know, you could put up a sign, local 25 traffic only. I 1-1 4 .
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URBANIK - CROSS 7632 1 Q Well, that is the kind of question I was asking' about 2 before, because it seems to me that maybe something like that 3 makes sense. That maybe the vehicles who are travelling on 4 Spaulding Turnpike who don' t really have any important reason 5 to be entering the EPZ, ought to be turned around, so that they 6 could avoid any exposure to any possible radiation as they
. 7 drive down Route 95, and come within, you know, a mile or a 8 mile and a half of the nuclear plant.
9 Is it your recommendation that you would leave this 10 up to some local decision making after further analysis?
11 JUDGE SMITH: My problem with this line of 12 questioning is that I don' t know if you have established the 13 logical relationship between access checking and discouraging 14 or encouraging traffic through the access point.
15 I don' t know if the question has been put in that way 16 or answered in that way.
17 MR. FIERCE: I think that this is somewhat confusing '
18 and maybe we can explore it.
19 JUDGE SMITH: I really don' t know what has been Doing 20 on. I don' t know what has been established.
21 MR. FIERCE: Well, let's back up. l 22 BY MR. FIERCE:
23 O Isn' t this really kind of a Hobson's choice 24 situation, Dr. Urbanik, where neither alternative is a 25 particularly Dood one, but you have to make a choice, and if l
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2 URBANIK - CROSS 763h 1 you do implement access checking, you are therefore going to be 2 prohibiting or discouraging substantial number of vehicles that l
l 3 have no important reason for travelling throuDh the EPZ on l l
4 Route 95, going very close to the nuclear plant, frorn doing so. I l
5 But i f you don' t have access checkinD, and don' t have l l
6 barricades, you will be perhaps, avoiding the probleni of having '
7 these queues created as access checking forces cars to back up. .
8 But you will be allowing a certain nurnber of people i
9 to expose themselves potentially to radaation who would not i
10 have to be exposed, isn' t that true?
I 11 A (Urbanik) I am not sure I believe that that is true.
12 I think there is too many complexities in your question that
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13 have not been or presumptions that there i s, in fact, radiation '
.. a 14 in which to run into.
15 JUDGE SMITH: Well, in your recommendation that 16 access checking not be done, does it also follow, in your 17 recommendation that there be no discouragement of access into I 18 the EPZ?
19 THE WITNESS (Urbanik): No, that does not necessarily ,
20 follow. j i'
21 BY MR. FIERCE:
- 1 22 O And how would that discouragement occur, Doctor? l 23 This is what I was originally asking you for, whether 24 you would change any of the instructions or put up signs, or 25 add additional traffic personnel or do anything differently i
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1 than is reflected on this-diagram?
l 2 A (Urbanik) Well, hopefully that there is a lotLof 1
l 3 other things going on also that i f, in fact,. the situation was 4 that, you know, there was radiation to run into, you mi Dht even 5 change your plan, and not let people into the area, and there 6
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is going to be news media and other information.
. 7 On a main route, such as-this, it might be~a.
8 reasonable approach'to do a little bit'more in the way of 9 signing, in terms of encouraging people through the traffic 10 control, to actually'U-turn.
11 Q But the barricades would remain, is that-true?.
12 A (Urbanik) Well, you could move the barricades in a
,' . 13 way that would force them into the left turn lane, but not 14 preclude them from then deciding that they don' t really want to 15' go in that particular direction, such that there is['that you 16 are accomplishing both objectives at the'same t'ime.
17 So, I guess, just thinking:out here, out loud, what I 18 would do is move these barricades back a little bit, force 19 everybody in to the left turn: lane early on, butl1 eave afgap at 20 the end of the left turn, so that'those, who'had a reason to. 3 21 continue on, would do so.
22 O Isn' t that likely to produce a situation where 23 motorists who see a traffic guide,. and: barricades that dre.
24 encouraD ing them to' turn'left, will slow down, stop perhaps, 25 roll down their window and' shout to the traffic guides'what.is Heritage Reporting Corporation ,
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, . URBANIK - CROSS 763S 1 going on? Can I go through?
2 A (Urbanik) My recommendation was relative not to 3 shouting, providing information or otherwise, it was to the 4 physical act of having to go into your wallet, get out your 5 driver's license, show the officer a license that had an 6 address that looked like it belonged in.the EPZ.
7 And the efficer figuring that out and saying, you can .
8 go by. We are saying -- so it is a change, it is a. change in 9 the amount of interchange and the time to do it, that goes on, 10 to keep it moving more expeditiously.
11 JUDGE SMITH: I think that --
12 THE WITNESS (Urbanik): That the person stops, rolls
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13 down his window and asks the question, I presume that tha
__m 14 officer weuld be courteous enough to give the person an 15 appropriate response.
16 JUDGE SMITH: I think that you are taking his 17 recommendation too far. I did not hear it to have such far 18 reaching implications.
19 I heard only that the judgment as to who has access 20 is shifted to the motorist and away from the traffic quides, 21 simply that and nothing more. -
22 MR. FIERCE: You may be right, I am just exploring 23 this, because I did not know what the implication was.
24 JUDGE SMITH: But your various hypotheses all seem to 25 depend upon some other type of scenario, which I could not see l
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1 in his recommendation.
2 MR. FIERCE: Well, let me, if I may ask this 3 question.
4 BY MR. FIERCE:
5 Q Isn' t it true that what we are trying to do here by 6 eliminating the access checking is to avoid the problem of
. 7 having long queues develop and thereby delaying the time that 8 it will take for people who truly need to get into the EPZ to 9 gather their belongings, their family members, or what have 10 you, and get out?
11 Isn' t that true?
12 1
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t242 1 A (Urbanik) Partly that, and partly just not screwing 2 up traffic in general any more than you need to. That then has 3 implications on everybody behind, around and in other areas.
4 It's keeping in mind the long evacuation times involved.
5 Getting back in a timely manner is not as -- is not going to be 6 a necessarily controlling factor.
7 JUDGE SMITH: I guess I' ve been in traffic situations ,
i 8 enough times, I don't know how my colleagues feel, and it's a l
9 familiar situation. You know, the traffic guy is there. ' He's 10 directing the mainstream of traffic say, for example, to the 11 left. You come along and put your right turn signal on, and he 12 signals you to the right. I' ve been in that situation.
13 countless times.
14 And here we' ve examined on it a half-hour just at 1
l l 15 simple one little recommendation that he doesn' t demand 16 identification from motorists as going into such a complicated l
l 17 situation. I don' t see how productive it is.
18 M R. FIERCE: I have my reasons, Your Honor.
19 JUDGE SMITH: All right.
1
- 20 MR. FIERCE: I' d rat her -- I' ll approach the bench if 21 you would like me to explain to you. -
22 JUDGE SMITH: No, if you represent -- if you 23 represent that you have a reason for this, that's fine. It's 24 just that as I sit here I just can' t imagine the problem that 25 you' re trying to establish.
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s v IlRBANIK - CROSS' 7636 1 BY MR. FIERCE:
2 Q Is that, Dr. Urbanik, in fact the way you assumed it 3 would occur, in the fashion the judge just described?
4 M R. TURK: When did he make this assumption, Mr.
5 Fierce?
6 MR. FIERCE:. I' m sorry, I didn' t hear that, Mr. Turk.
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7 MR. TURK: You' re asking him is the way Judge Smith 8 described the situation the way Dr. Urbanik assumed it would 9 occur. Are you asking about in his testimony? ~
10 MR. FIERCE: No, now. I' m asking him how he assumes 11 his recommendation will play out at a particular' access control-12 post, and here we have one where.the traffic would --
13 JUDGE SMITH: Does he have any assumption? Did his 4
14 recommendation even require an assumption? The recommendation 15 in sum is wnatever the restriction is caused by pulling out the 16 wallet and looking at an identification, that is released. 'The 17 quantity of release, he had made no recommendation on, and how 18 it would work he made no recommendation.
. 19 But if you want to ask him, fine. I just don' t -- I 20 think that your question assumes that he had an asshcation.
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21 But go ahead. You cross-examine your way. I' m - sori y, I 22 shouldn' t interrupt if you have a~ purpose.
23 MR. FIERCE: Let me make it as simple as I!can.
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m URBANIK - CROSS 7639 1 points without using access checking be able to proceed without 2 slowing down at that-point, or will there be some slowdown 3 effect occurring here?
4 A (Urbanik) There will certainly be some slowdown of 5 the traffic as a result of the traffic control funne11ing it 6 down into a_ single lane and forcing a maneuver that may be 7 unanticipated by the motorists. -
8 Q Some traffic which would have been stopped and turned 9 around under the other system of access checking will not 10 proceed into the EPZ; isn' t that correct, using this other 11 method?
12 A (Urbanik) It's -- everyone that has that desire, it 13 would be my presumption, would be allowed to do that, yes, 14 Q And there will be those, especially those who aren' t j 15 listening to the radio, who as they travel down the Spaulding 16 Turnpike will be seeking to access Route 96 no that they can be 17 on their way to points to the south of the LPZ1 isn't that 18 correct?
19 A (Urbanik) That's possible. , 1 20 Q And those people will not be turned back under the 21 system you' re recommending; isn' t that true? ;
22 A (Urbanik) I believe that's correct, yes.
I 23 Q These people will be driving - how close do you I 24 estimate Route 95 is at its closest point to Seabrook Station?
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25 A (Urbanik) You' ll probably do that as well as I -
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URBANIK - CROSS 7640 1 could. What are the radiuses on there? Two miles? A mile?
2 Q Well, the first circle on the map before us is the 3 two-mile ring.
4 A (Urbanik) So something less than two miles.
5 0 And in addition, won' t we, now conducting the I-DYNEV 6 runs really for all of the scenarios, have to make an
. 7 assumption that greater than 3,000 through vehicles will be 8 traveling through the EPZ7 1 9 A (Urbanik) I don' t believe so. I mean, you' re saying 10 that we' re discouraging people. Some of them won' t be 11 discouraged, yet there will be more there than there would be 12 there normally. That doesn' t logically follow in my mind.
13 0 Well, let me explore it with you this way.
14 The way the plan now treats the through vehicles is 15 to assume that perimeter control, or access control would be 16 established at the moment the order to evacuate is issued, and 17 that, therefore, the number of through vehicles that need to be 18 dealt with in the modeling of the traffic inside the EPZ during
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19 the evacuation is to look at only those traffic, those cars )
l 20 that were inside the EPZ at that moment that the perimeter of {
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21 cont rol was established, and various estimates have been 22 examined and the number that has been utilized in the ETE study 23 is 3,000 through vehicles; isn' t that conrect, Dr. Urbanik?-
24 A (Urbanik) Yes, I believe 3,000 is the number that's 25 been used for the through traffic.
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URBANIK - CROSS 764; 1 Q Now if access control is not implemented to 2 discourage any further through traffic from coming i n, 3 additional vehicles flow into our model that needed to be 4 treated over and above 3,000; isn' t that true, Dr. Urbanik?
5 A (Urbanik) There could be some additional vehicles 6 that one might want to simulate, but as it turns out in this 7 particular situation the capacity of I-95 is not such to be -
8 concerned even if that flow rate continued.
9 Now that 3,000 i sn' t a flow rate. Even with normal j 10 midday flow rates on I-95 has got plenty of excess capacity to 11 handle both additional'through traffic and evacuating traffic.
12 O Well, that may be, but isn' t that a question to put 13 to the I-DYNEV model using some greater amount of through 14 traffic than 3,000 vehicles?
15 A (Urbanik) I guess based on what I would expect to be 16 the number of additional cars, which would be few, and the-17 surplus capacity on I-95, I don' t -- I don' t see where that 18 would have to be done.
19 Q I' m sorry, I didn' t hear'the last part of that. ,
20 A (Urbanik) I don' t see where that would have to be 21 done. We' re dealing with relatively small numbers and
- 22 relatively large capacity.
23 Q You would agree though that the~ number of through 24 vehicles traveling through the EPZ during the period of time 1
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1 evacuating vehicle clears the EPZ will be greater than 3,000 2 through vehicles, correct?
3 M R. TURK: Objection.
4 JUDGE SMITH: What's your basis?
5 M R. TURK: Two grounds. One, the testimony that the E witness put in says durinD the early hours of evacuation they 7 would not have the access control point screening in place. He 8 didn' t say throughout the evacuation, 9 And, second, to the extent that doesn' t cover it, I 10 think it's asked and answered; that he has already stated that 11 there would be some additional cars, but he doesn' t think there 12 will be that many.
~~
13 JUDGE SMITH: Well, that's my memory, but is your 14 question somewhat different?
15 MR. FIERCE: If the question --
16 JUDGE SMITH: Are you just summing up?
17 MR. FIERCE: I think I was.
18 JUDGE SMITH: Yeah, okay.
19 MR. FIERCE: And if Mr. Turk will stipulate that the 20 question has been asked and answered and the answer is yes, 21 it's greater than 3,000 vehicles, I won' t press it.
22 JUDGE SMITH: I think that's my memory, that it's a 23 somewhat small amount he said. .
24 BY MR. FIERCE:
25 Q Dr. Urbanik, would you agree that implicit in the i
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1 guidance contained in NUREG-0554, Appendix 4, is the'need to 2 consider all relevant factors on a site-specific basis in order 3 to derive reliable time estimates?
4 A .Urbanik)
( The guidance is intended t'o give an 5 indication of how to do an ETE without overly restricting any 6 site-specific. things that need to be considered.; That doesn' t 7 mean -- that' isn' t . intended. to mean that one has to go well -
8 beyond the bounds- of what's considered current practice.
9 MR. FIERCE: I' d ask' that that answer be stricken as 10 nonresponsive to my question.
11 JUDGE SMITH: . Let's pby attention to his -- close 12 attention to his question. It's - NUREG-0654 would _ require that 13 all relevant factors --
k.
14 MR. FIERCE: Irnpl i c i t , is it implicit.
15 JUDGE SMITH: Al1~ relevant factors be taken --
16 MR. FIERCE: Need to consider all relevant factors on 17 a site-specific basis in order to arrive at rel'iable' time 18 estimates.
19 JUDGE SMITH: All relevant factors. No other ,
20 modification of the factors, .just relevant.-
21 MR. FIERCE: That's right.
- 22 THE WITNESS: (Urbanik) No, it's not implicit in-23 there. .
24 BY MR. FIERCE:
25 O Are you sure?
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URBANIK - CROSS 7649 1 MR. TURK: I' d like to object, Your Honor. I don' t 2 want to prolong this. I' ll let the question stand.
3 (Pause.)
4 MR. TURK: Why don' t I object.
5 JUDGE SMITH: Well, I think that you had the answer 6 to the question, and he's under oath. The question was put 7 back to him, paraphrased by me, put back to you. He had ample 8 opportunity to consider it. The question does have quite a few 9 problems with it, and I think once you got the no answer, I 10 don' t think it's appropriate for you to ask the additional 11 answer. Certainty is -- I think if you want to approach it, 12 you' d better let him define what he understood your question to I~~ 13 be, what you meant by all relevant factors that would be taken d_m 14 into account, site-specific factors that would be taken into i
15 account. I mean, all of them, you know, just all relevant 16 factors.
17 MR. FIERCE: Can I put it to him this way, Your 18 Honor? Can I ask the question whether he has ever made the
. 19 statement that implicit in the guidance is the need to consider i
20 all relevant factors on a site-specific basis in order to l
21 derive reliable time estimates? !
22 JUDGE SMITH: Okay.
23 BY MR. FIERCE: -
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'l 24 Q Have you, Dr. Urbanik? )
25 A (Urbanik) I may have said that, and that's why
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URBANIK - CROSS 764fi 1 I ' m -- I' m struggling with the question as to where -- what 2 relevant factors, and I tried to give a broader answer and you 3 called me noncesponsive, and then when you force me into a yes 4 or no answer, you didn' t like that either.
5 Implicit in the guidance is considering all factors 6 that reasonably impact evacuation time. 0654 does not preclude 7 you from doing anything that would be appropriate to do a good
- 8 Job.
9 JUDGE SMITH: But does it require -- does it not 10 require you to do it?
11 THE WITNESS: (Urbanik) Well, 0654 i s, as I 12 understand it, guidance. So it isn't in any sense a ,
13 requirement. It is -- J J
14 JUDGE SMITH: Does it guide you to do it?
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15 THE WITNESS: (Urbanik) It's intended to have you do i
l 16 the best possible job, so you should consider all things that j i
17 make it reasonably -- have a reasonable expectation of 18 affecting the evacuation time.
19 BY MR. FIERCE: ,
20 Q That begins to sound a great deal like the statement l 21 that I asked you earlier and whether you agreec with it.
1 22 Are you saying anything different now? Can I ask ycu l
23 the question again then?
- 24 MR. TURK: Your Honor, asked and answered --
25 JUDGE SMITH: Well --
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1 MR. TURK: -- 10 times.
2 JUDGE SMITH: -- he's' laying -- he's t rying to ' lay a 3 predicate.for, you know, a foundation for asking him now some .
4 specifics. Now he' s --
5 MR. TURK: He's also asking him -- I' m sorry.
6 JUDGE SMITH: 'I wish he' d get . to the specifics, 7 because the 'foundat ion -- you' re not going.to pull'up.the I
8 previous statement that he said all relevant factors must'be 9 considered, site-specific relevant factors must be considered, 10 and then require 'him.to concede, therefore, that a list'of 11 f actors that you' re going to list - to him must, therefore,' be 12 considered. I mean, it's just-not going to work that.way. But 13 you can try it, but I ' think you' ve beaten 'the foundation to 14 death now.
15 M R. FIERCE: I thought he maybe had been chanding'his 16 mind, Your Honor, when he first said he didn' t think so, but 17 now says that maybe he said that.
18 JUDGE SMITH: Well, the problem with the question and
. 19 answer and exchange is what he means by all relevant ~ f act ors,'
l 20 and what you mean, and what I think either of you mean, .or what
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21 all think, it's very subject ive, because hardly any of us 22 literally take the word "all relevant factors", hardly any of 23 us take that literally. We take.it cost-effective, reasonable,'
24 appropriate, or whatever. But you' re asking him an - absolute; 25 question, and proceed with it. But'the f undament al -- t he !
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URBANIK - CROSS 7647 1 question is fundarnentally flawed for the purpose that I-think 2 that you' re going to try to use it for.
3 MR. BACKUS: Judge Smith.
4 JUDGE. SMITH: And I' m not looking at.your. cross-5 examination plan.
6 M R. BACKUS: ' Judge' Smith, I have a witness'wh'o.is 7 here for the. fif th tirne, - and I' rn now doubt ful that we' re going *-
8 to reach her this afternoon.
9 I wondered i f any ~ of t'.e parties would.haveuan 10 objection. I don' t know whether. Staff is planning on having 11 Dr. Urbanik here tomorrow morning to finish this' examination or 12 not. If so, I wondered if.anybody would mindLif we suspended 13 with him, and let Mrs. Pilot go forward. I'really. feel' bad 14 that she's had to rnake five trips up here. It's. nobody's 15 fault. People est imate t irnes in good faith. .But I just wonder 16 if anybody would seriously object if:as the last i t ern o f .
1 j 17 business today we had Mrs. Pilot sworn in.
l l 18 JUDGE SMITH: How close are you'to cornpleting your 19 cross-examination of Dr. Urbanik? The pace-and the ,
20 productivity of the exarninat ion this af ternoon, . I' m not
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21 comtnent ing on earlier, but.later this afternoon has-'been very_
22 unsatisfying.
23 MR. FIERCE: I have'about 20 ' rnore minut es, Your 24 Honor 4 25 MR. TURK: Your Honor, I do object.
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1 JUDGE SMITH: I am concerned about Ms. Pilot coming 2 over here time and time again, and five times you say. That 3 seems as if should be sufficient. l I
4 MR. TURK: Your Honor, Dr. Urbanik started Thursday j 5 of the last session. We had him Friday morning on the last 6 session. We have him today. At the end of Friday's session, 7 Mr. Fierce stated he had only a little more to do. I made it 8 clear that Dr. Urbanik is teaching a course on Wednesday and he 9 has to leave no later than around noontime tomorrow. And we 10 haven' t finished -- it's already 4 :00. There's been three 11 hours, including the break time, of examination by Mr. Fierce.
12 He still thinks he has 20 minutes. I ,would like him to finish.
7"~ 13 I have redirect I want to do, and I don' t want to be precluded 14 from that tomorrow because of any bumping of the witness.
15 JUDGE SMITH: I understand that, but we have not yet 16 required any person to foreshorten cross-examination that 17 they' ve represented is essential, and we' re prepared to do that 18 if need be. It's not a means that we throw out. But Dr.
19 Urbanik is an important witness --
20 MR. TURK: I understand.
4
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21 JUDGE SMITH: -- on an important subject matter, and 22 we want to have maximum latitude.
23 But, Mr. Fierce, certainly, you know, you must have a 24 feeling of frustration here too. Maybe you' re j ust not going 25 to achieve what you hoped to achieve.
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1 MR. TURK: Judge Smith, my comment goes to Mr. I 2 Backus' request that we excuse the witness fer the day.
3 JUDGE SMITH: I know.
4 MR. TURK: I' d like him to stay and complete.
5 JUDGE SMITH: I beg your pardon?
6 MR. TURK: I' d like the witness to stay on the stand 7 and have his cross-examination completed. -
8 JUDGE SMITH: Yeah, well, do you think we can finish I 9 Dr. Urbanik this evening?
10 MR. BACKUS: I have some examination for Dr. Urbanik 11 as well.
E242 12 (Continued on next page.)
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24 25 Heritage Reporting Corporation '
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URBANIK - CROSS 7650 T243MB 1 MR. TURK: I don' t know what we are Doing to find 2 tomorrow. Mr. Fierce may find that his 20 minutes, au happens 3 to me often, actually takes more than 20 minutes.
4 JUDGE SMITH: You have redirect and I don' t know if 5 others have --
6 MR. BROCK: I have 15 or 20 minutes, Your Honor.
7 JUDGE SMITH: Well, we are not likely to complete him 8 this evening.
9 MR. TURK: I would like to make the best progress we 10 can so that we are sure to finish him tomorrow by the time that 11 he has to leave.
12 JUDGE SMITH: All right, well, that is fine, Mr.
l l 13 Turk. We understand your reasons, but you addressed not at l
14 all, the problem that Ms. Pilot has faced in coming over here 15 repeatedly only to be frustrated.
16 You know, you are ignoring that aspect of it.
17 MR. TURK: Well, on a number of occasions, --
18 JUDGE SMITH: How lonD would Ms. Pilot's test imony
. 19 take?
20 MR. BACKUS: Well, I presume that the principal 21 examiners are probably either the Staff or the Applicant, so 22 maybe they can say.
23 JUDGE SMITH: What is her testimony about again, it 24 is the --'I hava not looked at -- I --
25 MS. SELLECK: I don' t anticipate more than about a Heritage Reporting Corporation (202) 628-4888 s
. - URBANIK - CROSS 765'.
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1 half an hour.
2 JUDGE SMITH: This is the ambulance.
3 MR. TURK: Your Honor, on a number of occasions the 4 Interveners have moved the Witness off the schedule, because 5 they had other things they wanted to have come up first.
6 It was not at my request, I don't believe, it was --
7 JUDGE SMITH: I am reminded now, Ms. Pilot's
- 8 testimony is a very short piece. I think that we can require 9 that the parties take up Ms. Pilot, complete her, in short 10 crder.
11 Do you have cross-examination of Ms. Pilot?
12 MR. TURK: I will pass it.
~~~
13 JUDGE SMITH: I beg your pardon?
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14 MR. TURK: I will pass it, in order to save time.
15 But can we at least have the Massachusetts Attorney 16 General complete his cross-examination?
17 JUDGE SMITH: Yes.
18 This is my proposal.that you be required to conclude 19 your cross-examination, on Mr. Urbanik, this evening, before ,
20 four-thirty, and that gives you five n1 ore minuten than you '
21 estimated.
22 That will be the first time, I think, that is 23 reasonable. And then we will make an ob.fective to finish Ms.
l 24 Pilot within the remaining time. ]
i 25 So you can begin sharpening up your cross )
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URBANIK - CROSS 7652:
.I 1 examination.
2 BY MR. FIERCE:
3 Q Dr. Urbanik, do you recall filing testimony before an 4 Atomic Safety and Licensing Board in the Long Island Lighting 5 Company proceedings, over Shoreham?
6 JUDGE SMITH: Yes, certainly you do.
7 THE WITNESS (Urbanik): Ch1 more than one occasion.
8 JUDGE SMITH: If we could pick up.the pace a little 9 bit, without damage' to the content.
10 BY MR. FIERCE:
11 Q And.I will'be happy to come down and show.you.this, 12 but do you recall at that time being asked this question and.
13 giving this answer?
(
14 Question: Is there any specific guidance in NUREG-15 0654, Appendix 4, Revision I, concerning evacuation shadow 16 phenomenon? i 17 Answer No. Specific guidance on evacuation shadow 18 is not included in NUREG-0654, Appendix 4, ' Revision I.
, 19 Implicit in the guidance, however, is the need to consider all 20 relevant factors on a site-specific basis, in order.to' derive 21 reliable time estimates. Consideration of evacuation. shadow at 22 most sites would indicate that it is not a problem.
23 Would your counsel like me to'show you~this?L 24 A (Urbanik) No.
25 I don' t have 'any problem with that..
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'i.s 1 O You recall being asked that question and giving that 2 answer?
3 A (Urbanik) I don' t specifically recall it, but I 4 don' t dispute it. I think that I probably said it.
5 Q Now, Doctor, are you familiar with the Seabrook 6 Station evacuation analysis prepared for FEMA, in July of.1980 7 by Alan M. Voorhees, and Associates? .
8 A (Urbanik) Yes, I have reviewed that. I don't have 9 all of the specifics in my head.
10 0 Well, do you recollect that a key unresolved issue in {
l I 11 est imat ing ETE's discussed in that Voorhees analysis is the l j
la issue of the impact of traffic congestion on driver behavior? 1 I"~ 13 A (Urbanik) I don' t recall that in particular, no.
3a 14 I don' t dispute that it may say that.
15 MR. FIERCE: May I move down by the Witness, again, i
16 Your Honor? ]
)
17 JUDGE SMITH: All right.
18 (Counsel moves to Witness.)
\
l l 19 BY MR. FIERCE:
2 j
20 Q Dr. Urbanik, I want to show you a document which is 21 labeled Seabrook Station Evacuation Analysis, Final Report, -
l 22 Estimate of Evacuation Times Prepared'for Federal 1
23 Emergency Management Agency by Alan M. Voorhees and Associates, 24 and ask you if you recognize that document?
25 A (Urbanik) That looks like the study, yes.
\\
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URBANIK - CROSS 765L 1 Q And now, would you turn to Page 59 of that document?
2 (Witness examines document.)
3 BY MR. FIERCE:
4 Q And read us the last paragraph on Page 59, which I 4
5 believe I have indicated.
6 A (Urbanik) "The level of conDestion, the length of
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7 the time spent in traffic back-ups, and the length of these 8 back-ups are unlike anything that the population of the 9 Seabrook EPZ has encountered previously, and is important that i
10 the dimensions of this congestion be understood:"
11 Q Now, if I heard you correctly, you said, as you read 12 that report, I think that you used the term, "unlike any 13 condition", is that correct, that the evacueen have seen
(
14 before?
15 A (Urbanik) Had seen before in Seabrook, yes.
16 Q Do you agree with that statement, that the conditions 17 during an evacuation from Seabrook Beach, in the summertime, on 18 a weekend, from the Seabrook Beach area, will involve levels of
. 19 traffic congestion unlike anything that the drivers will have 20 ever seen before?
21 A (Urbanik) Not totally. It will be longer than they 1 22 have seen before, but it will certainly be very similar to some j I
23 of the stopping of traffic that is seen during certain peak !
1 24 summer days.
25 Q Okay, it will be longer, than they have seen before, j Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS , 7655 1 How much longer?
2 A (Urbanik) Oh, probably on the order of twice to 3 three times as long.
4 Q And in fact, if you are in the end of a traffic 5 stream, along a critical path, or the critical path from the 6 EPZ, you could be in these conditions for seven hours and 7 longer, isn' t that true, Dr. Urbanik? -
8 A (Urbanik) I think that is well established.
9 Q Depending on whose ETE's you are considering, isn' t 10 that true?
11 A (Urbanik) Yes.
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l 12 Q Now, on Page 62 of the Voorhees Report, there is a l
'~~"
13 description about the length of traffic backup and I would ask ccJ ,
14 you to read : Sat paragraph, if you would?
15 A (Urbanik) "In several locations, the amount of 16 traffic that is attempting to enter the street system exceeds 17 the space available on the entire road system. In other words, 18 there is not enough space on the streets to store'the vehicles 19 attempting to get on the street. Consequently many vehicles ,
20 will not be able to leave their parking space, driveways, 21 etc." '
22 Q Do you agree with that statement?
23 A (Urbanik) I think that I haveaused that point to 24 amplify many of mine.
25 Q And with respect to a traffic congestion and driver l a
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1 behavior, on Page 63 of the Voorhees Report, would you read 2 this first paragraph, under that heading?
3 A (Urbanik) "There is considerable uncertainty as to 4 what might happen to driver behavior in 30-to-90-minute traffic 5 backups, under circumstances such as an evacuation. The 6 existing evidence for this type.of occurrence in sketchy and 7 uneven. In some more or less documented incidences, such as i
8 evacuation after chemical spills, or evacuations related to l l
9 natural disasters, generally orderly flow has been reported."
10 "On the other hand, the experiences such as major 11 snowfalls, even in regions accustomed to such type of weather, ;
1 12 suggest that driver behavior deteriorates quite regularly under l l
13 circumstances of 30-to-90-minute delays." !
l 14 JUDGE SMITH: Was that too fast, Mr. Reporter?
15 THE REPORTER: I think not.
16 JUDGE SMITH: I appreciate you picking up the pace, l
17 but I think that you are pushing our reporting technology to l l
18 the limit here. However, he got it, that is all right.
. 19 THE WITNESS (Urbanik): I will try to keep that in 20 mind.
21 BY MR. FIERCE:
22 Q Dr. Urbanik, do you agree with that statement?
23 A (Urbanik) Parts of it. -
24 Q Would you tell us which parts you disagree with?
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1 driver behavior deteriorates quite regularly under 30-to 2 minute snow delays.
3 Q The reference there is to people abandoning their 4 cars, when they are stuck in snow for those periods of time, 5 isn' t it?
6 A (Urbanik) Well, if your car is stuck, abandoning it 7 is not necessarily an unreasonable alternative. It seems .
8 pretty reasonable, assuming that there is some place for you to 9 go.
10 Q But you don' t disagree that in the Voorhees Report, 11 the authors were concerned about the impact.on driver behavior 12 if they were stuck in traffic for periods as short as 30-to ~~"
13 minutes, isn' t that correct?
14 A (Urbanik) That is what they say. I don' t agree with i
15 it.
16 They have since gone out of business.
. 17 Q Now, immediately after that paragraph that you just 18 read in the Voorhees Report, are listed some of the specific l
19 motorist behavior problems that they believe could be caused by ,
20 these delays of the length expected at Seabrook, and I wonder f 21 if you would take a look at the very first potential problem
- l 22 they have listed on Page 64? )
23 And read these'two paragraphs bhat go with this first l
24 point?
25 A (Urbanik) " Creation of more lanes in the outbound lh .
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1 direction; in effect-the one-way system out of the area, as 2 motorists impatient with the length of queue simply begin using 'l 3 the left hand that is inbound lanes for travel out of.the area.
4 This is not necessarily a poor strategy of. plan, but could be 5 chaotic if it occurs spontaneously."
6 Second paragraph, "Furthermore,,if a two-lane' flow 1 ~
7 must be returned to a single lane at some downstream point, 8 then there is no advantage to the two-lane flow. To the 9 contrary, the merging activity as two. lanes are combined into i l 10 one will cause a loss in capacity relative to.a singleLsmoot'h. 1
\
11 flowing lane."
12 Q Now, Dr. Urbanik,' would you agree that;if:two-lane 0 13 flow occurs, on roads which the Traffic Management Plan has-14 designed for single-lane flow, that that would be a chaotic t
15 condition?
.]
16 (Pause.) '
17 THE WITNECS (Urbanik): I don' t know that I would -
18 choose the word, " chaotic". Certainly undesirable. Annuming
. 19 you had some desire to maintain two-way flow.
20 But I don' t agree with the assumption because if you 21 have two-way flow, people are not going.to pull out in-front-of 22 on-coming cars, to establish one-way flow.
23 So I don' t see.how what they are saying.can happen.
24 Q They are saying, this:in aLpotential problem that 25 needs to be considered, isn' t that true?- .i l '
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1 A (Urbani k.) That is their-opinion.
2 (Continued on the next page.)
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, URBANIK - CROSS 7660 lT244 1 Q And among the other problems that could be generated l
2 by traffic behavior under these congested conditions is the l 3 point which is on the next page, Page 65. I wonder if you coul'd 4 read the paragraph under that point.
5 MR. TURK: Objection to the form of the question; to 6 the extent that the questioner is asking the witness to 7 establish a fact. I have no problem with him reading the text, 8 but I don' t want that read to mean concurrence necessarily with 9 a written statement in the text.
10 JUDGE SMITH: We understand the answer -- we agree 11 with your objection, and we understand the answer in that 12 context.
I'~~ 13 THE WITNESS: (Urbanik. " Abandoning vehicles is L
14 frequently seen in situations, no worse than routine large 15 snowfalls. If vehicles are abandoned along the roadways or in 16 the traffic lanes, they will seriously diminish the capacity of 17 the roadway and cause bottleneck situations."
18 BY MR. FIERCE:
i , 19 Q Now, the Voorhees report makes that utstement in l
20 conjunction with a list of potential problems that could be 21 caused by driver behavior under these congested traffic 22 conditions; isn' t- that true? This is under that same heading 1
23 that you -- -
24 A (Urbanik) Right --
25 0 -- read earlier. I l-a ~
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l URBANIK - CROSS- 766; 1 A (Urbanik) -- iti s. referring to situations where the 2 road is impassable which is not the situation we' re talking 3 about in our ETEs.-
4 Q It's referring to situations where the roads are 5 extremely contested for lengthy periods of time; isn' t that 6 true?
7 A (Urbanik) No, it doesn' t say-that. -
1 l
l 8 Q Two pages earlier the text of the Voorheen report l
9 reads as follows, does it not, Dr. Urbanik? "Some specific 10 motorist behavior problems that could be caused by delays of 11 the length expected in the Seabrook EPZ evacuation include:"
12 And then there are a series of points which are listed, and l
13 among them is this point about abandoning vehicles; isn' t that 14 true, Dr. Urbanik?
15 MR. TURK: I sn' t it true that the statement appears 16 in the text?
17 MR. FIERCE: That's correct. Under that --
18 THE WITNESS: Oh, I --
l 19 MR. FIERCE: -- response to that colon? .
20 THE WITNESS: I agree those statements exist in the l 21 text, yes.
- 22 BY MR. FIERCE:
23 Q Now, isn' t it also true, Dr. Urbanik, that the 24 Voorhees report authors were so concerned.about having a l 25 breakdown in orderly traffic flow'at Seabrook during an Heritage Reporting Corporation (202) 628-4888
URBANIK - CROSS 766a 1, . .
1 evacuation that in their analysis two possible actions were 2 sugDested to reduce the. chances of a chaotic breakdown in 3 traffic control? One, being a sequential evacuation of the 4 beach area and the second being a sheltering action of the 5 beach.
4 6 -And in order to answer that question, I would refer 7 you to Page 74 of the Voorhees report.
8 MR. TURK: Objection to 'the form of' the quest ion. '
9 The question is asking whether the authors had --'were so 10 concerned, in the questioner's terms. Un..ess that's ; going to 11 be establ.ished by the text, .I don' t think the witness can state 12 what the concerns of the authors were. ,
g 13 JUDGE SMITH: Well, you know, now-that.you have wa 14 raised it, this has been going on for so' long ~I' m almost 15
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reluctant to raise it, but what's going to happen to this 16- report? I mean, it's not in evidence, and what'are you' going 17 to do with it? Where are we going with it?' j 18 MR. FIERCE: Where are we, going with it?
. 19 JUDGE SMITH: Yeah.
20 MR. FIERCE: I was asking the witness whether he --
21 JUDGE SMITH: Agrees or disagrees.
22 MR.. FIERCE: -- knew of this report.
23 JUDGE SMITH: Yeah.
- j 24 MR.' FIERCE: He said he did. He is aware of certain 25 statements in,the report. Other statements he's reading and )
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- g. URBANIK .CROSG 766' 1 giving us his views on, and now I' ve asked him the question 2 whether.that report also didn' t make certain recommendat ions.
3 JUDGE SMITH: Right.
4 MR. FIERCE: Now I can withdraw that part of the 5 question that said they were so concerned about it, but' didn' t 6 the Voorhees report make certain recommendations in order to 7 specifically reduce the chances of a chaotic breakdown in -
8 traffic control.
9 MR. TURK: Your Honor, the point is well made. This 10 witness cannot testify for that report.
11 JUDGE SMITH: Well, that's'why I was confused here.
12 I would have expected a flurry of objections by now were not 13 for some expectation that somehow you' re going to ' take this 14 report and put it to some use other than asking.him to read it.
15 Now I understand if you1ask him.does.he agree with 16 the statement or not, then you are elicitinD his testimony..
17 But when he doesn' t agree, what are you going to do.
18 MR. TURK: Or,1f in. fact the question is'not' asked'as 19 has happened on one or two occasions. The statementeis: read ,
20 into the record and Mr. . Fierce may have omitted, as I recall, omitted on one or two occasion.the follow-up question offdo you 21 22 agree or not agree.
23 MR. FIERCE: Depending on how he answered t t)c*
24 quest ions -- I' 111 bo honest. Depending on how~he answered ~the 25 questions, I was either going to move thelreport.into.evioence-Heritage Reporting . Corporation (202) 628-4888
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URBANIK - CROSS 7669 1 or not move it into evidence.
2 JUDGE SMITH: I see.
3 MR. FIERCE: And if this is an anticipatory 4 objection, we perhaps can discuss it now. I 5 MR. TURK: Well, certainly if the report is attempted l
6 to be moved into evidence, I would object to it as not having a 7 proper sponsor witness.
8 MR. DIGNAN: Well, I don' t know whether I' ll object 9 to it or not, but could I be advised, or maybe Mr. Fierce 10 wishes to do it later, is the purpose of the offer. If the 11 purpose of the offer is some limited purpose, maybe I won' t 12 have an objection. But if the purpose is to offer that report
[~ 13 for the truth of the matters contained, I object until the w
14 authors are put on the stand so I can cross-examine him.
15 JUDGE SMITH: Well, we' re --
16 MR. FIERCE: It's not being offered f or the proof --
17 truth of the matters that it contains. It's being offered for 18 the simple proposition, if I decide I.want to offer it,'that
. 19 another analysis has been performed of a Seabrook area l
1 20 evacuation which thought it to be a relevant factor and an i 21 important factor to take into consideration driver behavior {
i 22 uncertainty. 1 1
23 JUDGE SMITH: That's what I thought, and it's 24 different.
25 MR. DIGNAN: And then that's an of fer for the truth 1.C' 1
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,.~.s URBANIK - CROSS 7665 1 of the inatters contained in part to raise -- to ask for a 2 finding frorn ti.e Board that there was a serious matter to be 3 considered. And unless I ' rn going to be given the author who 4 made the statement that -- unless you get this witness to agree 5 with everything --
6 JUDGE SMITH: Yeah, ri Dht.
7 MR. DIGNAN: -- it seerns to rne I' m being denied .
8 cross-examination.
9 JUDGE SMITH: Well, this is such a f undarnental 10 evidentiary consideration I thought I' d rnissed the point, but I 11 haven' t. I rne an, it's very f und arnent a l . Unless you get hirn t o 12 agree with the statements there, your cross-examination has 13 been to no avail. -
14 I mean, you' re not going to get the staternent s in 15 that report adrnitted for the truth of thern without sorne other 16 dernonstration of reliability, trustworthiness and always the 17 opportunity to confront the i nfortnat i on.
18 MR. FIERCE: I rnay be rnissing somethinD here, Your 19 Honor, because these statements are not fact statements. These .
20 statements are not statements like the size of the beach 21 population is X. These are staternents regarding an iraport ant - 1 1
22 uncertainty that even the Voorhees people did not know how to ]
23 address -- -
^
1 24 JUDGE SMITH: And an irnpor --
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25 MR. FIERCE: -- and they are only pointing these '
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1 uncertainties out. And the question is whether Voorhees -- did 2 they at least consider that there were uncertainties.
3 JUDGE. SMITH: An important uncertainty in: itself a I
4 fact that has to be subject to confrontation and' cross--
5- examination.
6 MR. TURK: This witness may not agree that ' it's 7 important or there's an uncertainty, or that' it's rulevant.
8 MR. FIERCE: I'm only asking him whether another 9 evacuation time analysis considered that factor, and I believe 10 his answer was, yes, that other -- those other factors are in 11 the record and they were considered in the Voorhees' analysis.
12 BY MR. FIERCE:
' 7"~ ' 13 Q Do you disagree.with that, Dr. Urbanik?
16 JUDGE SMITH : Well, you' re asking him to agree 17 whether something was in the report, and we can look at the 18 report ourselves'and see that.
.. 19 Going back, I was exactly right, my first. impression.
20 You' re .trying to get that report in for the truth of the
-21 statements made in it, and for no other reason. You' re not 22 using it elicit -- well, you are.trying-to elicit-testimony 23 from Dr. Urbanik, and to that extent, we'*11 :let' you do it But 7
24 you' re not Doing to get it in unless you pul1~some magic out of 25 your sleeve here, and you' re running .out of time.-
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URBANIK - CROSS 7667 4
1 MR. FIERCE: I' m ready to f'nish it if I could be 2 given the opportunity. Thank you.
3 BY MR. FIERCE:
l 4 Q Dr. Urbanik, you' ve read Dr. Adler's test imony, have 5 you not?
6 A (Urbanik) Yes.
l 1
7 O He is concerned, is he not, about what he describes ,
8 as a major uncertainty with respect to driver behavior, whuther 9 the traffic control measures that are in place will be 10 sufficient to prevent widespread abandoning of vehicles; isn' t 11 that true?
12 MR. TURK: Object ion to the quest ion's form in terms 13 of what his concern is. If he strikes those words and just 14 say, does the testimony address the point, I don' t have a 15 problem.
16 BY MR. FIERCE:
17 Q Does the testimony address those issues, Doctor?
18 A (Urbanik) Yes, the testimony addresses those issues.
19 Q And does the Voorhees report also address those 20 issues?
21 A (Urbanik) Yes, the Voorhees also adaressies those . l 22 issues.
23 Q Dut you have no concerns in this area; in that 24 correct?
25 A (Urbanik) That is correct. I do not believe those Heritage Reporting Corporation (202) 628-4888
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PILOT - DIRECT 766d C_ . -
1 individuals have adequately studied the situation. Lay people.
2 who just hypothesize about what might happen, and even 3 experienced traffic folks have often thought the words, and 4 then when reality takes place, that people don' t behave like we 5 think they' re going to based on fear.
6 O You believe that people in Hampton Beach State Park 7 will stay with their automobiles for seven houru and longer j 8 within site of the nuclear plant during a radiological 9 emergency when the beach population is being evacuated?
10 A (Urbanik) Yes.
11 MR. FIERCE: I have no further questions.
12 JUDGE SMITH: All right. Ms. Pilot, let's proceed
~~
13 promptly. ,
__J 14 You may step down and return tomorrow.
15 THE WITNESS: (Urbanik) Thank you.
16 (Whereupon, the witness was excused, to return 17 tomorrow.)
18 Whereupon,
. 19 JOAN PILDT 20 having been first duly sworn, was recalled as a witness herei'n, 21 and was examined and testified as follows:
22 DIRECT EXAMINATION 23 BY MR. BACKUS:
- 24 0 Would you state your name and address for the rectord, 25 please? 1
'i L. -
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l PILOT - DIRECT 7G69 q 1 The little button on the top, you have to push it 2 towards you. There you go. Now you' re on. -
3 A (Pilot) I' m sorry, sir. Would you repeat it please?
4 May name and address?
5 Q Yes, your name and address for the record, please.
6 A (Pilot) My name is Joan Pilot. I live at 623 Mast 7 Road, in Goffstown, New Hampshire.
- 8 G And am I correct that you at the present time are in 9 the ambulance business?
10 A (Pilot) That's right.
11 Q Ms. Pilot, are you the author of.this-three-page 12 document entitled Rebuttal Testimony of Joan Pilot on Seacoast 13 Anti-Pollution League Contentions No. 25, and Nos. 8 and.8A,-
14 and SAPL Redrafted Contention 157 15 A (Pilot) Yes, sir.
16 O Are.there any corrections or additions that need to 17 be.made to that testimony as we' ve filed it with the=Doard and-18 the parties?
19 A (Pilot) No. .
20 Q Is that testimony true and correct to the best of
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21 your knowledge and belief?
22 A (Pilot) Yes, it i s.
23 O And do you desire-to have it entered into the record 24 of this proce'edinD7
.25 A (Pilot) Yes.
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PILOT - DIRECT 7670 l,
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MR. BACKUS: All right. With that, Mr. Chairman, the 2 witness is available for examination. I believe all the 3 parties have been furnished with this testimony, and I shall 4 furnish a copy for the reporter.
5 JUDGE E,MITH: Do you have extra copies? Otherwise, 6 we' ll take just a moment.
7 MR. BACKUS: I have some extra copies. Do you need 8 some for the Board?
9 JUDGE SMITH: We have two.
10 MR. BACKUS: Okay.
11 JUDGE SMITH: Are there objections?
12 The testimony is received.
13 (The Rebuttal Testimony of Joan 14 Pilot on Seacoast Anti-Pollution 15 LeaDue Contentions No. 25, and 16 Nos. 8 and 8A, and SAPL Redrafted 17 Contention 15 follows:)
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24 25 a -
Heritage Reporting Corporation (202) 628-4888
UNITED STATES OF AMERICA
( ~[ NUCLEAR REGULATORY COMMISSION ,
before the ATOMIC SAFETY AND LICENSING BOARD In the Matter of ) Docket No. 50-443-OL
)
PUBLIC SERVICE COMPANY ) (Offsite Emergency Planning OF NEW HAMPSHIRE, et al ) Issues)
)
(Seabrook Station, Unit 1) )
REBUTTAL TESTIMONY OF JOAN PILOT ON SEACOAST ANTI-POLLUTION LEAGUE CONTENTIONS NO. 25 AND NOS. 8 AND 8A AND SAPL REDRAFTED CONTENTION 15
- 1) Please state your n,ame, address and employment.-
My name is Joan Pilot. I reside at 623 Mast Road, Goffs-town, New Hampshire. I am the President of Amoskeag Ambulance Service at 621 Mast Road, Goffstown, New Hampshire.
- 2) How long have you been in the ambulance' business?
I have had my own ambulance business since 1981.
- 3) What are your qualifications? 1 When I started the business and up until December 1986 I was a Nationally Registered Ecergency Medical Technician-Ambulance (NREMTA) . I no longer am because I have. physical-limitations that make it impossible for me to take the practical partHof the exam, which involves among other things-lifting patients.
- 4) What is the purpose of your testimony?
. My testimony is to address issues related to ambulance transport including numbers of people per ambulance, the need for ambulances for nursing home patients, and the availability of
. drivers.
. 1
- 5) In your experience, how many Advanced Life Support (ALS) f patients can be transported per ambulance?
1 In my opinion, only one ALS patient can be transported per ambulance because of the complex nature of the care that has to' be
- provided. I need to have a nurse accompanying the. patient ,
because during the trip only a nurse can administer medications .
d under a written physician's order. ALS patients often have _
numerous intravenous lines (the range is from 1-11) and a nurse is i required to monitor those. As a practical matter, it can take from 28 minutes to an hour to move the patient from the hospital 4
I
p bed to the ambulance stretcher. Additionally, copies of the patient's medical records can take time to gather together, but they absolutely have to go with the patient so that the receiving hospital will know what kind of care is required.
- 6) Would you transport more than one ALS patient / ambulance?
We did it once, but I'd never do it again. It is neither practical nor sensible because one patient going into a crisis can adversely affect the other. .
- 7) Are ambulances only required for Medical Level of Care Class III (ALS) patients?
No. Class II patients include post-surgical care and have intravenous lines that could not be handled with a bus conversion type mode of transport. Further, oxygen can be necessary and an EMT is required to administer it.
- 8) In your opinion, are certain nursing home patients in need of ambulance transport?
Yes. For example, some of these patients have severe osteoporosis and need to be handled with great care. If they are handled wrongly bones.could inadvertently be broken. Moving and transporting these people takes a good deal of time and care.
Other examples are Alzheimer's patients, diabetics who require administration of insulin and patients with chronic obstructive pulmonary disease. '
- 9) Do you believe that sufficient personnel will be available to drive ambulances into the Seabrook Station EPZ?
No. First of dll, ambulance drivers have to be specifically trained to operate an ambulance. My general manager has stated the opinion that he would be headed in the opposite direction if there were a radiological emergency at Seabrook Station. I have heard other comments from employees that their first priority is .
their family and that they would be "long gone."
- 10) Have you reviewed the letters of agreement with
- ambulance companies in Volume 5 of the NHRERP?
I Yes, I have.
- 11) What is your opinion of these agreements?
What struck me in reviewing these agreement 2 was that not one i of the ambulance agreements included had comn.unications frequencies listed. Communications capability is vital. Even if
- you have such capability you can't always get through. For ;
example, if I was transporting a patient from Exeter Hospital to '
Catholic Medical Center, about halfway along I could talk neither to Exeter Hospital or CMC. If my patient went critical, I would want instructions from the receiving hospital. Furthermore,
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Is ambulances get hard use and there are sometimes breakdowns. There must be a means of getting assistance very quickly.
- 12) Do you have any other concerns about the role of ambulance companies under the plans?
Yes, I do. I am concerned about coverage of the communities normally served by the companies that would be responding to an
. event at Seabrook. Those communities will have no way of l -obtaining ambulance services for the unrelated emergencies that could occur.
- 13) Do you think 36 ambulances would be enough to service the EPZ communities during a Seabrook emergency?
I think 36 ambulances would be gro.ssly inadequate to the task. I have cead Applicants' testimony on Special Needs/Trans-portation and I understand there are tso hospitals and ten nursing homes in the EPZ. I would expect that 20% of nursing home residents would need to be transported by ambulance at a minimum.
All hospital patients in intensive care would need ambulance transport as well as many others. Women in active labor who are crowning can't be transported at all and post-delivery mothers
( with their infants would definitely need ambulance transport.
- 14) Does that conclude your testimony?
Yes, it does.
9 0
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PILOT - CROSS 767]
1 MR. BACKUS: Okay, I move the admission of the 2 testimony into the record of the proceeding.
3 JUDGE SMITH: I' ve just done that.
4 Is Ms. Pilot available for cross-examination now?
5 MR. BACKUS: Yes, she i s, Your Honor.
6 JUDGE SMITH: Ms. Selleck.
l l . 7 CROSS-EXAMINATION 8 BY MS. SELLECK:
9 Q Is it Mrs. Pilot?
10 A (Pilot) Yes.
11 Q Mrs. Pilot, you' re from Gof fstown, New Hampshi.re; is 12 that right?
l(' 13 A (Pilot) Yes.
14 Q And your company is Amoskeag Ambulance Company, is 15 that how you pronounce it?
- 16 A (Pilot) Amoskeag, yes.
17 Q Amoskeag is also in Goffstown, New Hampshire?
18 A (Pilot) Yes.
19 Q And you are the president of the Amoskeag Ambulance 20 Company; is that right?
21 A (Pilot) Yes, I am.
22 Q Who is the owner of the company?
23 A (Pilot) I am. .
24 Q Is it incorporated?
25 A (Pilot) Yes, it is.
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1 Q And how many'employnes do you have?
2 A (Pilot! Between 12 and 20. We have full-time people 3 and part-time pe< 2+..
4 Q And how many of your employees are drivers?
5 A (Pilot) Drivers in what sense?
6 Q Ambulance drivers.
7 A (Pilot) They all drive at one-time or another. if .
8 they are EMTs.
9 Q I' m sorry, you said if they are EMTs?
10 A (Pilot) If they are EMTu, they do all drive at one 11 time or another.
12 O Are they all EMTs?
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13 A (Pilot) Yes, at least.
l[Ju 14 Q How many ambulances do you have, does your company.
15 have?
16 A (Pilot) I have two on the road at the present time.
I i 17 Q Are you familiar with the term EPZ, emergency l 18 planning zone?
)
I 19 A (Pilot) No, you have your shorthand; I have mine.
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20 Okay, emergency what?
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21 Q Planning zone? -
l 22 A (Pilot) Fine, emergency planning zone, yes. {
23 O Are you familiar with that term?
24 A (Pilot) It doesn' t come up in my every day 25 conversation, but I know wnat you.mean.
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PILOT - CROSS 7673
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1 JUDGE SMITH: I think that if you wish, you can 2 establish by official notice. whatever way you want, where the 3 business is located. You don' t have to Det her to understand 4 the EPZ.
5 MS. SELLECK: Okay.
6 BY MS. SELLECK:
, 7 Q Do you know how many rniles Goffstown is from 8 Seabrook?
9 A (Pilot) Seabrook Station? Seabrook town? Harnpt on?
10 What?
11 O Seabrook Station.
12 A (Pilot) No, I don' t . It's not within the 10-mile,
"( " 13 certainly.
C-~
14 Q Now you were until recently a nationally registered
- l 15 ernergency medical technican arnbulance; is that right? '
16 A (Pilot) That's correct. s 17 Q What are the different Deades of EMT?
IS A (Pilot) It could be a registered EMT state only.
19 You can be a nationally registered EMT. You can be a 20 nationally registered EMT-I. You can be a nationally 21 registered EMT-P, which is pararnedic.
22 Q And I stands for int errnedi at e ?
23 A (Pilot) I nt errned i at e, yes. .
24 Q Do you acid any rnedical or nursing degrees or 25 certificates?
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p PILOT - CROSS 7679 b.. 1 A (Pilot) No, I do not.
2 Q In your test irnony you used the terrn " advanced life 3 support".
4 Does advanced life support refer to rneasures over and 5 above basic life support?
l 6 A (Pilot) Yes, they do.
7 O On Pages 1 to 2 of your test irnony, ' the carryover
- 8 sentence, you state, "As a practical rnat t er, it can takte frorn 9 28 rninutes to an hour to rnovo the patient frorn the hospital bed 10 to the arnbulance stretcher. "
11 Is that correct; did I read that correctly?
12 A (Pilot) That's absolutely correct. )
13 Q In that sentence were you referrinD to a patient who
.L 14 needs advanced life support?
15 A (Pilot) .Yes.
16 Q And when you say frorn the hospital bed to the 17 stretcher, do you rnean froro the bed to .the stretcher next to 18 the bed, or froro the bed to the stretcher inside the arnbulance?
19 A (Pilot) It's a literal st at ernent ; frorn the bed to ,,
20 the stretcher inside that roorn.
21 Q If a patient is prepared for transport before the
- 22 arnbulance arrives, it takes considerably less 'than 28 rainutes 23 to rnove that patient; is that right? -
24 A (Pilot) I ' rn sorry, would you say that again?
25 Q If the patlent is prepared for transport before the r-,
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1 PILOT - CROSS 7675 1 ambulance gets there, it takes considerably less than 28 2 minutes to move that patient.
3 A (Pilot) Prepared for transport is a contraction in 4 terms. They are never prepared for transport so that you can 5 just pick them up and put them on your stretcher. It doesn' t
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E344 7 (Continued on next page.)
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T245MB 1 Q Is there no preparation that can be done before the 2 ambulance gets there?
3 A (Pilot) It would be nice if they had the paperwork 4 ready.
5 Q I am sorry?
6 A (Pilot) It would be nice if they had the paperwork 7 ready. We are going to have to move lines. We are going to .
B have to move oxygen connections. If it is a balloon run, we 9 are going to have to move innumerable tubes from body openings 10 everywhere.
11 It is a very, very complicated process and it is very 12 time consuming and you cannot take less time than it takes.
13 Q Aside from paperwork, is there anything else that can
(
14 be accomplished before the ambulance gets there?
15 A (Pilot) No.
16 You still have to do all of those things.
17 Q Have you read the'New Hampshire Radiological 18 Emergency Response Plan Revision 2, or any part of it?
19 A (Pilot) Since I don' t know the reference, may I ask, ,
20 Bob, if that is part of what I read? -
21 Q Well, let me put it this way, what have you read? '
22 A (Pilot) I am sorry?
23 Q What have you read on the New Hampshire f< radiological j i
24 Emergency Response? I 25 A (Pilot) I have read several documents in Mr. Backus' i
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1 PILOT - CROSS 7677 l~; -
1 office, and of course, what has been printed in newspapers, 2 etc.
3 0 You mentioned, I think, in your testimony that'you 4 read the Applicants' testimony on special needs transportation, 5 is that right?
6 A (Pilot) Yes, I did.
. 7 Q What other documents did you read, do you recall?
8 A (Pilot) I read all of the letters that were 9 contained in that. I read classifications etc., in that i 10 section.
11 That was what, of course, concerned me the rnost.
12 O Do you recall reading any other documents outside the 13 Applicants' t est irnony?
14 A (Pilot) Official d.Juments, or just printed 15 material?
16 Q Either.
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17 A (Pilot) I am sorry, what?
18 Q I am sorry, either one.
19 A (Pilot) I read a great deal. I read a great deal 1
20 about evacuation plans, Seabrook, some of it, official I would l 21 imagine, and some of it just public information.
22 O But you don' t remember specifically the name of any 23 of the documents, or where they carne from?
24 A (Pilot) No. Is there something I am supposed to 25 remernber here?
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PILOT - CROSS 7676 I am just trying'to1 establish what-you read and 1 Q -
2 whether you read'the New Hampshire Radiological Emergency 3 Response Plan?
4 A (Pilot) I read the portion that I have in my 5 briefcase, which'is what I addressed myself t'o, in this 6 testimony.
7 Q Are you familiar'with the term,1 default values?. .
8 A (Pilot) I am.sorry.
9 Q Are you familiar with the term, default values?:
10 A (Pilot) Put it in context, please.
11 -Q Are you familiar with the process.of. identifying in 12 advance, in advance of an emergency, how many vehicles the-13 hospitals and nursing homes in the EPZ would need?-
14 A (Pilot) No, I dor.' t know' how they did L this one.
15 Q Do you'know that, well,. do you know that-the 16 emergency planners for'Seabrook worked withthe hospitals and 17 the nursinD homes to make.those determinations?
l 18 A (Pilot) No. I did not.
! '1 19 Q Are you aware that the hospitals in the EPZ have-20 agreed with the numbers of ambulances that were allocated: for 21 their facilities?
- 22 A (Pilot) No, I did not know that. j t
23 D And would you aDree that the-best:way to determineLin 24 advance, how many vehicles the nursing homes:ar:d hospibils j
25 would be likely to need, would be to ask the nuruing; homes and !
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1 hospitals?
2 A (Pilot) Considering the fact that nobody in a-3 hospital or a nursing home ever gets into an arnbulance, I would 4 disagree.
5 0 Are ever, excuse rne, I did not hear you.
6 A (Pilot) Considering the fact that no one from a
, 7 hospital or a nursing home ever gets into an arabulance, except l 8 in an advance life support situation, I would disagree. They 9 don' t know what the arnount of t irne is that it takes to just t
10 plain load a patient, from start to finish. They don' t know 11 what Does on in the arnbulance. ;
12 O Okay.
13 Aside from the question of time, puttinD that aside, 14 --
15 A (Pilot) Which I -- j i
! 16 Q -- do you think that --
l 17 A (Pilot) -- sorry? j 1B Q Do you think that hospitals and nursing hornes are W
19 qualified to decide what sort of transport their patients 20 require? -
21 A (Pilot) According to state law, I would suppose that i 22 I would have to say, yes.
23 Q Are you familiar with the plans for determining the 24 precise number of vehicles that would be required by hospitals 25 and nursing homes in the event of an actual ernerDency?
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-s PILOT - CROSS. 7680 1
1 A (Pilot) No.
2 O I take it, then, that you.are not aware thatuat the 3 alert stage, the nursing hornes and hospitals are to report 4 their. patient census and transportation cateDorien for'their 5 patinnts?
6 A (Pilot) .See, I disagree with that anyway.. I 7 disagree with their categories. If you 'are talking about the -
8 3G arabulances, I do know about that. I disagree'withlthat,.
9 t oc;. '
10 0 Okay, in the t irne of an act ual ernergency, do you know 11 that the plans call for the nurses and doctors to deterrnine 12 what type of transport each patient needs?'
{ 13 A (Pilot) I thought that was deterrnined by that reporb 14 that-I read, where they fall into one, two and'three i
15 categories. The nursing horne pationts autornatically were not 16 going to be transported by arabulance, that ' is what it ' s,ays. -
17 O So you are not aware.that, at the time of .an' actual ~
18 erner gency, it is a nurse or a doctor who deterrnines the proper 19 category for each patient individually? ,
20 A (Pilot) No. I arn not' aware of that.
21 O Would you agree that nursou and doctors are qualified
- 22 to raake that decision?
23 A (Pilot) Yes. .
24 Q Have you'ever seen'the conversion kit buses that'the 25 State of New Harnpshire plans to use in the ovent of an Heritage' Reporting ' Corporation.
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1 emergency?
2 A (Pilot) No.
3 I have heard about them.
4 Q Excuse me?
l 5 A (Pilot) I have heard about them. I have never seen G one, unless they are the kind that they une at a mock civil
. 7 defense drill.
l 8 If that is what they are, then I have seen those.
9 Q Okay.
10 Are you aware that these conversion kit buses are 11 equipped with magnetic hooks for IV solutions?
12 A (Pilot) No.
13 I did not -- magnetic hooks for IV solutions?
14 Q Yes.
15 A (Pilot) No, I was not aware of that. It is a 16 plastic bag, where are they going to put a magnet?
17 Q Pardon me?
18 A (Pilot) IV solutions are plastic bags.
19 Q You were not aware of the existence Of maDnetic 20 hooks, is that right?
21 A (Pilot) No, I was not.
22 Q Okay.
23 On the bottom of Page 2, of your testimony, you 24 state, "What struck me in reviewing these agreements" and 25 there, we are talking about letters of agreement -- "wan that
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g PILOT - CROSG. 7682 1 not one of,the ambulance agreements included, had 2 communications frequencies listed."
3 Did I read that correctly?
4 A (Pilot) -That is right.
5 Q And did you make any inquiry into the-possibility 6 that frequencies are kept confidential'and deletedLfrom public 7 copies of.the letters of' agreement?
- 8 A (Pilot) No,,I did not know that. You can.go out-and 9 buy a book and find out anybody's frequency.
10 Q Okay.
11 Are you familiar with State-Regulat' ions-aboutLwhat.an 12 ambulance has to carry, to be an ambulance?
- 13 A (Pilot) Yes.
14 Q Do you know that among the minimum equipment 15 required, is a two-way radio which'shall have.the capability to 16 communicate directly with primary receiving hospitals?a 17 A (Pilot) That is one channel, one frequency.
18 Q Yes, with primary recolhing hospitals?'
19 A (Pilot) Yes. ..
20 Q You don' t think that thel ambulance companies that 21 signed the letters of agreement are in violdtion.of.that 22 regulation, do you? .
23 A (Pilot) 1 don' t think that-they are-'in.viointion of; t
24 that minimal equipment, but how-is anybody going to,talx to 25 anybody else?
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1 I would hate to be out there in the middle of nowhere 2 and not have anyone to be able to talk to if I broke down with 3 a critical patient?
4 Q I am sorry?
5 A (Pilot) . I said I would hate to be in the middle of 6 nowhere, not able to get back to the facility I came out of,
. 7 nor-to be able to talk to my' base, because the only frequency 8 being used was the primary medical frequency and it is so 9 Jammed, that I cannot get on'to it.
10 And there is no other provision for any other 11 frequency there, that I could see.
12 MS. SELLECK: Your Honor, I have no further 13 questions.
14 ( Appli cant s' Cross-i 15 Examination Plan of Joan 16 Pilot follows:) ,
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25 l Heritage Reporting Corporation (202) 628-4888
6 Dated: N 987-c1 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
~ )
In the Matter of )
) ..
, PUBLIC SERVICE COMPANY- -) Docket Nos. 50-443-OL OF NEW HAMPSHIRE, ET AL. ) 50-444-OL
)
(Seabrook Station, Units 1- ) (Offsite-Emergency-and 2)' ) Planning Issues).
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OUTLINE OF APPLICANTS' CROSS-EXAMINATION OF REBUTTAL TESTIMONY OF JOAN PIIDT.
(
- 1. Establish that Amoskeag Ambulanca Service.in'Goffatown is not within the EPZ.
- 2. Inquire into witness's medical qualif'ications.-
- 3. Inquire about the time it' takes.to: move an' advanced: life support patient if patient is prepared.for' transport before ambulance arrives.
< 4. Inquire if witness has read NHRERP and knows the process-- .
of allocating numbers of vehicles for evacuating hospitals and
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, i nursing homes in advance of an emergency.
- 5. Inquire if witness knows plans for determining precise -
number of vehicles needed in the event of an actual emergency.
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- 6. Inquire whether witness has se'en a conversion bed bus.
and in particular whether witness knows of magnetic hook for IV solutions.
- 7. Establish that letters of agreement need'not specify communications capabilities.
By their attorneys Thbmis G. Tiicjfian, Jr.
George H. Lewald Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 .
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PILOT - CROSS. 7669 1 JUDGE SMITH: Is there any further cross-examination?
I 2 MR. HUNTINGTON: The State has none.
l 3 JUDGE SMITH: None?
4 MR. HUNTINGTON: None.
5 JUDGE SMITH: Does any other Intervenor have 1 -
6 questions?
- 7 (No response.)
8 JUDGE SMITH: Redirect?
9 MR. BACKUS: No redirect.
l 10 JUDGE SMITH: Well, we do have a question.
11 JUDGE HARBOUR: I have a comrnunicat ion problern here, l
12 rny microphone cord won' t corne out of the hole.
13 Can you hear me all right?
14 THE WITNESS (Pilot): I can hear you.
15 JUDGE HARBOUR Good.
16 Do you have radio communications equipment in your 17 ambulances?
18 THE WITNESS (Pilot): Yes, sir, I do.
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19 JUDGE HARBOUR How rnany frequencies do you have in 20 each ambulance?
21 THE WITNESS (Pilot): A miniinum of eiDht.
22 JUDGE HARBOUR: Thank you.
23 That is all. .
24 JUDGE SMITH: Anytning further of Ms. Pilot?
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25 (No response.)
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, PILOT - CROSS 768U 1 THE WITNESS (Pilot): Thank you, Judge.
2 JUDGE SMITH: Thank you.
3 You are excused and we regret your false trips over 4 here, 5 (The witness was thereupon excused.)
U G MR. TURK: Your Honor, I note that the hour is about l 7 12 minutes to 5:00 o' clock.
1 8 I took the liberty of discharging Dr. Urbanik, since 9 it had been indicated that there would be about a half an hour 10 for this witness.
11 So he is not available to resume the stand, at this 12 time, t 13 JUDGE SMITH: All right.
14 MR. TURK: I would ask that we could talk about the 15 schedule for tomorrow and Wednesday, so that we can prepare.
16 JUDGE SMITH: That is a good idea, yes.
17 All right, go ahead, talk.
18 MR. TURK: Okay. I assume that the --
a 1
, 19 JUDGE SMITH: Well, now, is there any reason why this ~
20 has to be on the record? ,
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21 Can we excuse the Reporter?
22 MR. TURK: As far as I am concerned, yes.
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1 23 JUDGE SMITH: All right.
- j 24 Is there anything further on the record, before we .
25 adjourn?
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1 (No response.)
2 JUDGE SMITH: All right.
3 We are off the record.
4 (Whereupon, at 4:49 p.m., the hearing was adjourned, 5 until 9:00 a.m., the following day.)
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1 CERTIFICATE 3 This is to certify that the attached proceedings before.the 4 United States Nuclear Regulatory Cornrnission in the rnatter of:
5 Names PUBLIC SERVICE COMPANY OF 6 NEW HAMPSHIRE, et al.
7 Docket Nurnber: 5-443-OL, 5-444-OL 8 Place: CONCORD, NEW HAMPSHIRE 9 Date: Decernber 14, 1987 10 were held as herein appears, and that.this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Corntnission taken electronically by rne and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court report ing cornpany, and that the recording'is a
[ .
15 true and accurate recore of tte fo goi'iu proceedings.
16 /S/ - -
17 (Signature typed): KENT ANDREWS 18 Official Reporter 19 Heritage Reporting Corporation f
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