ML20237E829

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Affidavit of Eb Lieberman in Support of Lilco Motion for Summary Disposition of Contentions 1,2 & 9 -immateriality.*
ML20237E829
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 12/14/1987
From: Lieberman E
KLD ASSOCIATES, INC., LONG ISLAND LIGHTING CO.
To:
Shared Package
ML20237E542 List:
References
OL-3, NUDOCS 8712290210
Download: ML20237E829 (5)
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LILCO, Dec mber 14,1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensinst Board In the Matter of )

)

LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station, )

Unit 1) )

AFFIDAVIT OF EDWARD B. LIEBERMAN IN SUPPORT OF LILCO'S MOTION FOR

SUMMARY

DISPOSITION OF CONTENTIONS 1. 2 AND 9 -IMMATERIALITY Edward B. Lieberman, being duly sworn, deposes and says as follows:

1. I am President of KLD Associates, Incorporated which was retained by LILCO to develop a traffic plan and evacuation time estimates for the Shoreham EPZ.

My professional qualifications are bound into'the record in this proceeding at Tr.17,421 as part of LILCO Exhibit 1, Attachment C. I have personal knowledge of the f acts re-cited below because of my extensive involvement in the calculation of evacuation time estimates for t.5e Shoreham EPZ.

2. The Shoreham Emergency Plan contains a variety of evacuation time esti-mates depending on the assumptions one makes about an evacuation of the Shoreham EPZ. These times estimates appear in OPIP 3.6.1, Attachments 2 and 7 and in Appendix A to the Plan.

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3. One set of evacuation time estimates that appear in the Plan are premised on a " controlled" evacuation, that is, one in which Traffic Guides are in place at the time they are able to affect evacuation times. Another set of evacuation time esti-mates assumes an " uncontrolled" evacuation, that is, one of which all of the traffic control points remain unmanned throughout the evacuation. For both of sets of evacu-ation time estimates, it is normally assumed that all evacuees will comply with the routes they have been assigned in the Plan. However, sensitivity runs have been con-ducted for both the controlled and uncontrolled cases to determine the effect on evacu-ation times of 25% and 50% of the evacuees not following their assigned paths. The re-suits of these runs are presented in OPIP 3.6.1, Att. 7.
4. During the emergency planning litigation, which centered on Revision 3 to the Shoreham Emergency Plan, I testified to the following evacuation time estimates (ETE) for an evacuation of the entire Shoreham EPZ under normal summer weather conditions:

Evacuation Controlled / Time Estimate Uncontrolled  % Non-Compliance (hours-minutes)

Controlled 0% 4-55 Uncontrolled 0% 6-30 Controlled 25 % 4-55 Controlled 50% 5-30 Uncontrolled 25 % 6-30 Uncontrolled 50% 6-30 From these estimates, one can see that the timely presence of Traffic Guides had the effect of reducing evacuation times by approximately 95 minutes. Only in the case of

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1 50% non-compliance during a controlled evacuation did evacuees not following their as-signed routes have any effect on evacuation times.

5. Subsequent to the close of the record in the emergency planning litigation, .

KLD was requested in November 1984 to help with the Revision 5 update of the LILCO f Transition Plan. KLD was asked to calculate evacuation time estimates for a series of 90 keyholes (Revision 3 of the LILCO Plan contained evacuation time estimates for 67i" keyholes) and to develop traffic routing to the Nassau Coliseum (which at that time was the designated reception center). As a part of that update, the decision was made to model more explicitly those evacuees living in Zone Q. Prior to the Revision 5 cvacuation time estimates, 690 cars had been modeled as evacuating Zone Q on the evacuation network; the remaining Zone Q evacuating vehicles were not explicitly modeled but were assumed to evacuate the EPZ on local roadways. For the Revision 5 time estimates, additional roads in Zone Q were represented as links in the evacuation network and adcitional origin centroids were defined to represent evacuating vehicles accessing those new links. As a result, approximately 2000 vehicles were explicitly modeled as evacuating from Zone Q on the evacuation network; about 300 cars from Zone Q were still assumed to evacuate by local roadways not represented as links in the evacuation network.

6. As in the case of the prior evacuation time estimates, the traffic assign-ment model of the DYNEV system was run to assign traffic to those paths of travel on the evacuation network which would minimize the travel time from each origin centroid to each associated destination node. The traffic simulation model of the DYNEV system was then used to calculate the evacuation time estimates.

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7. The Revision 5 evacuation time estimates (which presently appear in the Plan) for the same six cases presented in Paragraph 4 above are as follows:

Evacuation Controlled / Time Estimate Uncontrolled  % Non-Compliance (hours-minutes)

Controlled 0% 5-05 Uncontrolled 0% 5-40 Controlled 25 % 5-25 Controlled 50 % 5-25 Uncontrolled 25 % 6-00 Uncontrolled 50% 6-25 As can be seen from these results, the difference in evacuation time estimates from the timely presence of Traffic Guides and special traffic control treatments, such as one-way flow and lane blockages, is now 35 minutes instead of the prior 95 minutes. This difference is largely the result of different traffic assignments in two subzones in Zone F. Specifically, the addition of approximately 1300 vehicles to the evacuation network in Zone Q, described above, had the effect of diverting traffic demand from the section of roadway converted to one-way flow under the LILCO Plan to Route 25A and other roads to the south. One effect of this new assignment of traffic and the more explicit treatment of traffic in Zone Q is the lessening of the difference in ETEs between the controlled and uncontrolled cases.

8. Noncompliance with assigned routes affects the Revision 5 evacuation times for both controlled and uncontrolled cases.

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The foregoing facts are known by me to be true, of my own knowledge; Iam q 1

1 competent to testify to such facts, and would so testify if I appeared as a witness in a -

public hearing on this matter.

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P w Subscribed and sworn to before me on !ht2nhr 15 ,19 d.

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