ML20245D467

Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Re Contention JI-56, Reception Ctr Parking.* Estimates of Parking Capacity at Ctr Found Unreasonable.W/Certificate of Svc.Related Correspondence

ML20245D467
Person / Time
Site:	Seabrook
Issue date:	06/19/1989
From:	Adler T MASSACHUSETTS, COMMONWEALTH OF, RESOURCE SYSTEMS GROUP
To:
References
CON-#289-8802 OL, NUDOCS 8906270122
Download: ML20245D467 (8)

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tELATED g{a!IEffy20T:L4.9E owc  !

i l UNITED STATES OF AMERICA  !

) NUCLEAR REGULATORY COMMISSION .s .JJu 21 P5 37 l

ATOMICSAFETY ANDLICENSINGBOARD br% -

Doc E! w . - 'm Before the Administrative Judges: *!? ,

IvanDr.W. Smith, Richard F. ChiJr$ersn Co 1 Kenneth A.McCollom l

In the Matterof PUBLIC SERVICE COMPANY OFNEW Docket Nos.  !

HAMPSHIRE, ET AL 50 443 444-OL- -)

(Seabrook Station, Units 1 and 2) (Off-site EP)  !

1 June 19,1989 a

i TESTIMONY OF DR. 'IHOMAS J. ADLER ON BEHALF OF JAMES M. SHANNON, ATIORNEY GENERAL FOR THE  ;

COMMONWEALTH OFMASSACHUSETTS,  !

CONCERNING CONTENTION JI-56, RECEPTION CENTER PARKINO

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De C(+partment of the Anomey Oeneral '!

-+_ wealth of Massachusetts l One Ashburton Place l Boston, Massachusetts 02108-1698 (617) 727 2200 1 i

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8906270122 PDR 890619 [  ;

T ADOCK 05000443 i - '

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k Ic IDENTIFICATION OF WITNESS Q. What is your name and current occupation? -

A. My name is Thomas J. Adler and I am President of Resource Systems Group of Norwich, Vermont.

Q. Are your professional qualifications as set forth in the testimony and attachments filed for this case on September 14,1987 and summarized in testimony submitted on February 21, j 19897  !

A. Yes, they are.

Q. Referring specifically to the subject of this tesdmony, do you have any particular l

qualifications or experience? . I i

A. Yes. As a professor at Dartmouth College, I taught a graduate-level course in traffic engineering which covered in detail the subject of auto parking lot layout. I have personally I

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supervised and/or reviewed the layout of several dosen large surface parking lots, and so am very  !

familiar both with general design principles and with practical operational issues.  !

1 IL TESTIMONY i

Q. Have you reviewed the Supplement to Applicants' Rebuttal Tesdmony No.17, j i

prepared by Joseph Bisson and Anthony Calendrello and dated June 1,19897 i A. Yes, I have.

Q. Does that tesdmony contain esdmates of parking capacity at the ORO Reception'- *'

Centers, as m=e- i by the Atomic Safety and Licensing Board?

t A. Yes,it does. '

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Q. Do you believe that those estimates are reasonable?  !!

A. No, I do not.

Q. Would you explain the basis of your opinion?

• A. The Beverly Reception Center clean car parking areas contain a total of 44,934 square feet and the North Andover Reception Center contains 45,595 square feet for clean car 1

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e Adler Recepdon Center Parking Testimony 2 parking. The Applicants' calculations indicate parking capacity for the Beverly lots of 180 cars and 182 cars for North Andover. These calculations assume that each parked vehicle occupies only 250 square feet. in practice, even the most efficiently configured parking lots require approximately 300 square feet per space and factors such as the shape of the lot and the amount of tumover in the lot can easily increase the requirement to over 400 square feet per space. The Institute of Transportation Engineers' Transportation and Trq11e Engineering Handbook (1982) shows a range of 276 to 340 square feet per parking space for efficiently configured parking lots, notincluding end aisle areas.

To more accurately determine how many car parking spaces would fit in the areas designated for parking at the two designated Massachusetts reception centers, I developed conceptual layout plans for those areas, based on the reception center sketches attached to the Supplement to Applicants' Rebuttal Testimony No.17 and using what appeared to be the optimal [

layout. For the Beverly Reception Center, I was able to fit 132 perpendicular parking stalls, each 9' by 18' and allowing 26' wide two-way access aisles wii end access where necessary. At the North Andover Reception Center,137 parking stalls of similardimensions could be provided. The Applicants' assumed parking capacities are more than 35% higher than these estimates.

Q. After you completed that analysis were you provided copies of aerial photographs of the reception center sites, as submitted by the Applicants?

A. Yes, I was.

Q. Would you describe what effects, if any, the details shown in these photographs have on your esdmates?

A. De North Andover parking area is striped in a partem similar :9 thelayout that I had assumed in performing calculations for this lot. There are cars shown in the lot, making a determination of parking capacity relatively straightforward. Dere is a substantial amount of equipment stored along the long side of the parking lot shown in the foreground of the photograph, It appears that this storage area was excluded from the lot width of 170' given in the sketch, because there are five rows of parking (at 18' per row) plus three aisles (at 26' per aisle) apparent

0 Adler Reception Center Parking Testimony 3 in the photograph,whose combined width should be 168'. The section of the lot shown to have a capacity of 70 can in the Applicants' sketch is occupied in the photograph by a large pile of what  !

appear to be utility /selephone poles. Here does not appear to be any striping of parking spaces in f this area. If this pile of poles were removed,I estimate, from the photographs, a clean car parking lot capacity of 19 cars. This compares to the 137 can that I estimated based only on the reception center sketch. If the poles were not removed, the capacity would be only 115 spaces. The aerial photograph indicates that the controlled vehicle parking area is entirely filled with equipment.

He Beverly lot, as shown in the Applicants' other aerial photograph, appears to be completely unstriped. Here is equipment stored along the acetherly edge of the area selected for clean car parking; again, it appears that storage area was propedy not included in the 175' lot width shown on the reception center sketch. He pattern of parting established by the parted vehicles shown in the photograph is somewhat inefreient and would result in a lower capachy than I estimated based only on the rh center sketch. He vehicle monitoring and controlled vehicle parking areas are occupied, in the photo, by substantial quantities of equipment.

Q. Is it appropriate to assume that the lots will be used to their full capacities by visitors to the centers? ,

A. No. As stated by Dr. Urbanik, one of the NRCs witnesses in the hearings on the New Hampshire Plan, it is more v- - -vdy the case that lots are not used to full capacity because [

of parking tumover and other facton. De Applicants have asserted in their Supplement to Applicants' Rebuttal Testimony No.17 that the average residence time in the clean car parking ' I' spaces will be less than 15 minutes. At the espacitien assumed by the Applicants, one space in each lot would change occupants on avensge once every 5 seconds (180 spaces times 4 tumovers per hour = 720 turnovers per hour = 12 per minute = 1 per 5 seconds). This extremely rapid  !

tumover rate will result in significant reductions in usable capuity. It wM result in congested conditions within the parking lots and delays for vehicles seeking oper parking spaces.

In addidon, the Beverly parking lot is not striped at all and the N. Andover lot is only partially striped to indicate the optimal layout as assumed in my estimates. If the appropriate layout -

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Adler Reception Center Parking Testimony 4 of rows is not somehow designated, the effective capacity would be significantly reduced. 34 i- ;

Similarly, ifindividual parking stalls are not rnarked, the capacity will be reduced by inefficient I vehicle spacing.. Odd-sized gaps will be formed between parked vehicles, aisles will become i irregular, and, given the high demands for parking, vehicles may become blocked by other parked 1

vehicles.

Q. Could you estimate the usable capacity provided by the ORO reception center lots, l

accoundng forthese factors?  !!

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A. If the lots were completely striped to designate optimal row and stall placenents and ,j if 3 to 5 attendants were provided at each lot to expedite movement into available spaces, up to l 90% of the physical capacity may be achicved (appmximately 119 cars in the Beverly and 123 in the North Andover clean car lots). Absent these measures, I do not believe that more than 100 cars could be accommodated, on average, at the Beverly lot. Because the N. Andover lot is partially  ;

striped and has a simpler configuration, the utilization rate would be slightly higher than at the Beverly lot, accommodating up to 110 cars.

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Q. Does that conclude yourtestimony?

A. Yes, it does.  !

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UNITED. STATES OF AMERICA NUCLEAR RECULATORY COMMISSION '89 JJN 21 P5 37 ATOMIC SAFETY AND LICENSING BOARD oF :u i Before the Administrative' Judges: 'E N ',. :', y ,

Ivan W. Smith, Chairman Gustave A. Linenberger, Jr.

Dr. Jerry Harbour l

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In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL PUBLIC SERVICE COMPANY -) (Off-Site EP)'

OF NEW HAMPSHIRE, EI AL. )

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(Seabrook Station, Units 1 knd 2) ) June 19, 19891

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CERTIFICATE OF SERVTCE I, Allan Fierce, hereby certify that on June 19, 1989, I made service of the MASSACHUSETTS ATTORNEY GENERAL'S OBJECTION IN THE j NATURE OF A MOTION 1H LIMINE TO PORTIONS OF THE PREFICED TESTIMONY OF THOMAS URBANIK II ON JOINT IN7EAVENOR CONTEDTICNS 4 AND 7A, TESTIMONY OF DR. THOMAS J. ADLER ON BEHALF OF oanES M. SHANNON, I a

l ATTORNEY GENERAL OF THE COMMONWEALTH OF MASSACHUSETTS, CONCERNING' j

CONTENTION JI-56, RECEPTION CENTER PARKING, and MASSACHUSETTS ATTORNEY GENERAL'S OBJECTION IN THE NATURE OF A MOTTON lN ETMTNE TO THE SUPPLEMENT TO APPLICANTS' REBUTTAF S'ESTIMONY NO. 16 via Federal  ;

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k Express Mail as indicated by [*], hand delivered as indicated by

[**] and by First Class Mail on June 19, 1989 to:

• Ivan W. Smith, Chairman *Kenneth A. McCollom Atomic Safety & Licensing Board 1107 N. Knapp St.

U.S. Nuclear kegulatory Stillwater, OK 74075 Commission East West Towers Building

• Docketing and Service 4350 East West Highway U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, DC 20555

• Dr. Richard F. Cole Atomic Safety & Licensing Board U.S. Nuclear Regulatory Commission East West Towers Building 4350 East West Highway Bethesda, MD 20814

• Robert R. Pierce, Esq. ** Thomas G. Dignan, Jr., Esq.

Atomic Safety & Licensing Board Katherine Selleck, Esq.

U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place 4350 East West Highway Boston, MA 02110 Bethesda, MD 20814

• • H. Joseph Flynn, Esq. **Sherwin E. Turk, Esq.

Assiscant General Counsel U.S. Nuclear Regulatory Office of General Counsel Commission Federal Emergency Management Office of the General Counsel Agency 15th Floor i 500 C Street, S.W. 11555 Rockville Pike

! Washington, DC 20472 Rockville, MD 20852 Atomic Safety & Licensing Robert A. Backus, Esq.

Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Board Jane Doughty U.S. Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 l

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Charles P. Graham, Esq. Barbara St. Andre, Esq.

Murphy & Graham Kopelman & Paige, P.C.

33 Low Street 77 Franklin Street Newburyport, MA 01950 Boston, MA 02110 Judith H. Mizner, Esq. R. Scott Hill-Whilton, Esq.

79 State Street Lagoulis, Hill-Whilton 2nd Floor & Rotondi Newburyport, MA 01950 79 State Street Newburyport, MA 01950 Dianne Curren, Esq. Ashod N. Amirian, Esq.

Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W. Bradford, MA 01835 Washington, DC 20008 Senator Gordon J. Humphrey Senator Gordon J. Huraphrey U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack) (Actn: Herb Boynton)

John P. Arnold, Attorney General Phillip Ahrens, Esq.

Office of the Attorney General Assistant Attorney General 25 Capitol Street Department of the Attorney Concord, NH 03301 General Augusta, ME 04333 William S. Lord Board of Selectmen Richard Donovan Town Hall - Friend Street FEMA Region 10 Amesbury, MA 01913 130 228th Street, S.W.

Federal Regional Center Bothell, WA 98021-9796 COMMONWEALTH OF MASSACHUSETTS JAMES M. SHANNON ATTORNEY GENERAL

{k Cc-Allan R. Fierce /AO AssistantAttorneyGenera)l Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 l (617) 727-2200 '

DATED: June /(, 1989