ML20245D588
| ML20245D588 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/22/1989 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#389-8831 ASLBP, OL, NUDOCS 8906270163 | |
| Download: ML20245D588 (286) | |
Text
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UNITED STATES f) y NUCLEAR REGULATORY COMMISSION nr:NA-I '
F ,=========================================================
i ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) l
) Docket Nos, )'
PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et.al., ) 50-444-OL
) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING
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Pages: 26854 through 27130 Place: Boston, Massachusetts Date: June 22, 1989
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I HERITAGE REPORTING CORPORATION
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'" 26854 U -UNITED STATES NUCLEAR REGULATORY COMMISSION ,
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ATOMIC-SAFETY AND LICENSING BOARD
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, .; In the Matter of: )
.) Docket Nos.
PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW EAMPSHIRE, et al.,
) 50-444-OL
) OFF-SITE EMERGENCY (SEABROOK-STATION, UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING Thursday, June 22, 1989 Auditorium Thomas P. O'Neill, Jr.
Federal Building 10 Causeway Street Boston, Massachusetts The above-entitled matter'came on for hearing, pursuant to notice, at 9:03 a.m.
BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JUDGE KENNETH A. McCOLLOM, Member Atomic Safety and Licensing Board .
U.S. Nuclear Regulatory Commicsion Washington, D.C. 20555 JUDGE RICHARD F. COLE, MEMBER Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Nashington, D.C. 20555 f
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APPEARANCES:
For the Applicants: O{!*l THOMAS G. DIGNAN, JR., ESQ.
GEORGE H. LEWALD, ESQ.
KATHRYN A. SELLECK, E30 !
JAY BRADFORD SMITH, ESQ.
JEFFREY P. TROUT, ESQ.
GEOFFREY C. COOK, ESQ.
KILLIAM L. PARKER, ESQ.
Ropes & Gray One International Place Boston, Massachusetts 02110-2624 E.or the NRC Staff:
SHERWIN E. TURK, ESQ.
ELAINE I. CHAN, ESQ. ,
EDWIN J. REIS, ESQ. q RICHARD BACHMANN, ESQ. >
Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 E2$ the Federal Emercency Manacement Acency:
H. JOSEPH FLYNN, ESQ.
LINDA HUBER McPHETERS, ESQ.
. Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C. 20472 For the Commonwealth of Massachusetts:
JAMES M. SHANNON, ATTY. GEN. .
JOHN C. TRAFICONTE, ASST. ATTY. GEN.
ALLAN R. FIERCE, ASST. ATTY. GEN.
PAMELA TALBOT, ASST. ATTY. GEN. ,
MATTHEW BROCK, ESQ.
LESLIE B. GREER, ESQ.
Commonwealth of Massachusetts ,
One Ashburton Place, 19th Floor Boston, Massachusetts 02108
(
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M 26856 APPEARANCES: -(Continued)
For the State of New Hampshire:
GEOFFREY M. HUNTINGTON, ASST. ATTY. GEN.
- State of New Hampshire
- 25. Capitol. Street Concord, New Hampshire 03301 For the Seacoast Anti-Pollution Leacue:
l ROBERT A. BACKUS, ESQ. '
Backus, Meyer & Solomon 115 Lowell Street P.O. Box 516.
Mancnester, New Hampshire 03105 JANE D0UGHTY, Director Seacoast Anti-Pollution League 5 Market Street Portsmouth, New Hampshire 03801 For the Towr. of Amesburv:
BARBARA J. SAINT ANDRE, ESQ,
- Kopelman and Paige, P.C.
[ 77 Franklin Streat A Boston, Massachusetts WILLIAM LORD Town Hall ,
Amesbury, Massachusetts 10913 For the City of Haverhill and Town of Merrimac: I ASHOD N. AMIRIAN, ESQ.
P. O. Box 38 Bradford, Massachusetts 01835 For the City of Newburyport:
BARBARA J. SAINT ANDRE, ESQ. !
JANE O'MALLEY, ESQ. !
Kopelman and Paige, P.C.
77 Franklin Street Boston, Massachusetts 02110 ;
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l 26857 APPEARANCES: (Continued)
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for the Town of Newburv:
R. SCOTT HILL-WHILTON, ESQ.
Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street .
Newburyport, Massachusetts 01950 For the Town of Salisbury:
CHARLES P. GRAHAM, ESQ.
Murphy and Graham 33 Low Street Newburyport, Massachusetts 01950 For the Town of West ewburv:
JUDITH H. MIZNER, ESQ.
Second Floor 79 State Street Newburyport, Massachusetts 01950 For the Atomic Safety and Licensine Board:
ROBF.RT R. PIERCE, ESQUIRE Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
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26858 1 E D. E E
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( ,/ WITNESSES: DIRECT CROSS REDIRECT RECROSS EXAM Panel No. 16:
Anthony.M. Callendrello Edward B. Lieberman by Mr. Fierce 26860 by Mr. Turk. 27114 by Mr. Dignan 27126 by Mr. Fierce 27128 -
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EXHIBITH: IDENT. REC. REJ, DESCRIPTION:
(No exhibits.)
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INSERTS: PAGE .
Massachusetts Attorney General's 27130 Cross-Examination Plan for .
Applicants' Rebuttal Testimony No. 16 (Evacuation Time Estimates)
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REBUTTAL PANEL NO. 16 - CROSS 26860 1 F_ B Q Q E E p_ 1 H Q R
,- s i \' Good morning, Mr. Chairman, Members
\ ,,/ 2 MR. FIERCE:
3 of the Board, the Panel.
. 4 Whereupon, 5 ANTHONY M. CALLENDRELLO 6 EDWARD B. LIEBERMAN 1
7 having been previously duly sworn, were recalled as 8' witnesses herein and were examined and testified further as 9 follows:
10 CROSS-EXAMINATION (Continued) i 11 BY MR. FIERCE:
12 Q I wanted to pick up where we had left off in your 13 testimony in discussing some of the major events that occur 14 in the EPZ during a year. One of them is tbn -- there is a 7s t
's- 15 discussion of a concert that occurs during the Newburyport 16 Days.
17 Does the Panel know whether this a daytime or an 18 evening concert?
19 (Witnesses review document. ) .
20 A (Callendrello) I can find it. I've got the 21 newspaper schedule for the events.
22 Q Which year?
23 A (Callendrello) 1988.
24 It was at 8:00 p.m.
25 Q Eight p.m.
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REBUTTAL PANE ~ NO. 16 - CROSS 26861 1 Do you know what the Newburyport ETE is, Mr.
2 Lieberman, for a summer evening at about eightsp.m.?
3 A (Lieberman) No, we didn't run that case.
4 Q You did extract, I see, the Newburyport clear time -
5 of four hours and 25 minutes for the summer weekend with 6 good weather, correct?
7 A (Lieberman) Yes.
8 Q Do you have any idea what the Region 13 ETE is for 9 a summer evening, good weather?
10 A (Lieberman) Well, I would say that it wouldn't 11 vary much from the figure given, because the mobilization 12 time would be on the order of three hours, and the beach 13 traffic, clearly, is much lower.
14 So I would say it would be within an hour of the 15 figure given here.
16 Q Gentlemen, the next section in your testimony is 17 through-vehicles, and I wanted to ask you some questions 18 about that section.
19 At page 26, you mention there were 3000 through-20 vehicles assumed in the New Hampshire ETE study.
21 In that study, Mr. Lieberman, those access control-1 22 points were assumed to be staffed promptly, correct? {
l 23 A (Lieberman) Yes.
24 Q Was it actually from the time that the vehicles 25 began moving off the beach areas?
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REBUTTAL PANEL NO. 16 - CROSS 26862 s 1 A (Lieberman) That's right.
( )
( ,,/ 2 Oh, wait a minute. I'm sorry. I'm sorry.
3 Not the access control posts. I don't believe --
. 4 Well, no. I think you are right. Within the 5 model representation, we did not address the staged arrival 6 of the traffic guides. However, we did represent that the 7 through-vehicles only entered the EPZ at the outset of the.
8 evacuation process.
9 Q That's right.
10 And that these were 3000 through vehicles that 11 would be on the interstates before the access control was 12 implemented?
13 A (Lieberman: That's correct.
f"'s 14 Q And how were those allocated in the model at that
(\- ^) 15 time, 1500 in each direction on --
16 -
A (Lieberman) That's approximately right.
17 I would have to go back to the original listings 18 to give you the definitive answer. But to the best of my 19 recollection, that was about right.
20 Q Now on page 27, at the end of the first paragraph, 21 the top paragraph there, it says, "The value of 3000 22 through-vehicles is appropriate, because many of the
, 23 observed vehicles include local or nonexternal/ external 1
1 24 trips."
25 On summer weekends, aren't most of the vehicles on p
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REBUTTAL PANEL NO. 16 - CROSS 26863 1 Interstate 95 and passing through the EPZ, aren't those l 2 through-vehicles?
3 A (Lieberman) No, I wouldn't say that.
4 Q Heading for Maine or back from Maine to .
6 A (Lieberman) Not in the midday, no.
7 From your films actually, the few exposures which 8 covered I-95 -- you didn't cover the whole thing --
9 indicated to me that was a very sparse deployment of cars on 10 I-95, even less than the range that I indicate here.
11 If you look at the surveys conducted by HMM and if 12 you refer to Table 2-3 on page 2-13, you find that there is 13 a substantial in-flow to the beach areas throughout the 14 afternoon. So there are people who are arriving in the area 15 to go to the beaches throughout the day.
16 So I would say that for the scenarios that we've 17 considered, namely, the summer w;ekend, a goodly portion of 18 those are going to the Paach.
19 Q Well, you don't deny that portions of summer j 20 weekends there is very heavy traffic flow on those
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21 interstates as weekenders are heading back and forth between l l
22 Massachusetts and Maine, correct?
23 A (Lieberman) Yes.
24 You will find Friday evenings and Saturday 25 mornings, you will find a predominantly northbound flow of 1
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REBUTTAL PANEL NO. 16 - CROSS 26864
,s 1 traffic'on the interstates, and that reverses Sunday l 1
\ ,/ 2 evening. s 3 Q Now you've, as I understand it here in this
. 4 sentence, selected the 3000 through-vehicle value based on 5 some discounting of the observed vehicle densities in order 6 to compensate for those who would be local travelers, 7 correct?
8 A (Lieberman) That's correct.
9 Q How did you select that percentage to discount, l 10 and what is it?
11 A (Lieberman) I don't have a fixed number. I'm 12 just saying that, based on observation, many of those 13 vehicles are in fact local or transient, who stop within the g-'s 14 EPZ. So I don't have a fixed percentage.
x- 15 Q Mr. Callendrello, do you have something to add?
16 -
A (Callendrello) No, I don't.
17 I was just looking at Applicants' Direct No. 7 to 18 see if we covered it there. I thought we had and, in fact, 19 I thought we had been cross-examined on it at great length 20 in New Hampshire.
. 21 Q On some weekends isn't it true that the level of 22 traffic is much heavier than Level of Service B and C 23 thrJughout the days, particularly Memorial Day weekend, the 24 4th of July weekend, Labor Day weekend?
25 A (Lieberman) I would say that in early afternoon
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l REBUTTAL PANEL NO. 16 - CROSS 26865 1 my observations confirm what I have seen on the' films. The 2 traffic is light.
3 Q On those weekends?
4 A (Lieberman) I can recall one July 4th weekend .
5 where I did in fact observe traffic in the early afternoon, 6 and the traffic was light, yes.
7 A (Callendrello) Mr. Fierce, that's in our 8 Applicants' Direct No. 7 at page 72, carrying over to page l
9 73.
10 Q Panel, on the next paragraph, I just want to be 11 clear about what is going on here. I want to understand 12 what the traffic is doing in these revised ETEs.
13 You've got 4400 vehicles per hour for over one l
14 hour.
15 First of all, is that 2200 each direction?
16 A (Lieberman) No.
17 That's 4400 each direction. l 18 Q Forty-four hundred each direction.
19 And what does "over one hour" mean? I
- 1 20 How many hours and minutes? )
1 21 A (Lieberman) I would have to check that. I can do 22 that if you would like.
23 Q Could you do that quickly? )
24 A (Lieberman) I'm not sure how quickly I could do 25 it, but I could try.
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- 1. Q Is it going to be less'than a minute? I'll let
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.m, ; 12 you do it. If it's going to be more than that,.maybe we can 3 let-you do'at the break.
. 4' A' (Lieberman) It will'probably be more'than --
5 Q Although I apologize for keep taking your breaks 6 laway from you.
7 A- (Lieberman) That's all right.
8 Q We'll wait for the break then?
9 A -(Lieberman) Fine.
10 Q Do .ou recall that it is something less two hours?
11 A eieberman) Yes.
12- G "he plan is not to implement the access control 13 points, though, for two hours or longer, correct?
14 A (Lieberman) That's correct.
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15' Q Why did you. select a time that was less than two 16 hours then?
17 A .(Lieberman) At the time this was written, my 18 intent was to do it for two hours. And it turns out when I 19 reviewed the input stream, it turned out that it was cut off .
20 earlier.
. 21 So we did, in fact, and I'm not sure we -- oh, 22- yes. You will notice on the middle of page 27 it'says, "The
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23 sensitivity test was conducted which added another hour."
24 So I did, in fact, correct that input error, made 25 another run, and found that it had no impact on ETE.
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REBUTTAL PANEL NO. 16 - CROSS 26867 1 Q That sensitivity run, let me just see if I 2 understand that, you did add another hour, but it was at a 3 rate of-2000 vehicles per hour.
4 Again, each direction? -
5 A (Lieberman) Yes.
6 Q Not the 44007 7 A (Lieberman) For the second hour, yes, that's 8 correct.
9 Q And why is that?
10 A (Lieberman) Well --
11 Q You say for the second hour.
12 You had 4400 then for the first hour and --
13 A (Lieberman) Hour plus.
14 Q Hour plus.
15 A (Lieberman) Right.
1.6 Q And 22 for the second hour?
17 A (Lieberman) Twenty-two hundred for the second 18 hour.
19 Q Yes. .
20 Why did you do that?
21 A (Lieberman) I'm sorry, 2000. -
22 Q Two thousand.
23 A (Lieberman) The reason we did that is, if you 24 refer to the Table 4-2 on page 4-16 of Volume 6, and review 25 the distribution B, which is a time distribution of Heritage Reporting Corporation (202) 628-4888
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l REBUTTAL PANEL NO. 16 - CROSS 26868 I l i . 1- commut'ers. arriving ho'me, you will find that the first hour j
, ) -2 after the OTE captures approximately 85 percent of the 3 returning commuters. 1
.. 4 So the rate of in-flow is not uniformly q 5 distributed over two hours. You have many more returning
'6 commuters over the first' hour than over the second hour. 1 7 Q But these are through-vehicles, not returning ,
8 commuters. Returning commuters are a different category, 9 correct?
10 A (Lieberman) Well, at the time these runs were 11 made, we were not explicitly representing commuting traffic.
12 And in order to represent them at that posture, that is, 13 'without any inbound links other than the expressways f~~ 14 represented in the model, I represented that flow as being i\
% 15 primarily commuter flow, because I reasoned that 16 external / external trips would be discouraged by virtue of 17 the announcements that there is an emergency at Seabrook 18 Station.
19 So I had in mind that these represented commuter 20 flows along the interstates.
. 21 Keep in mind that this testimony predates the 22 explicit treatment of returning commuters.
23 Q But just so we are clear, normally when we talk 24 about through-traffic, we're talking about 25 external / external.
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l REBUTTAL PANEL WO. 16 - CROSS 26869 1 A (Lieberman) That is correct.
2 Q And you somehow modeled these -- I am confused.
3 A (Lieberman) Okay.
4 Q You somehow modeled these to represent returning .
5 commuters, but they passed through the EPZ?
6 A (Lieberman) That's correct.
7 Q What difference did it make to the model, I mean 8 what you are labeling them?
9 They are vehicles in the model that are passing 10 through.
11 A (Lieberman) That's correct.
12 I'm just telling you how I came to the inputs of 13 using a higher volume over the first nour relative to the 14 second hour. And what I based it on was returning commuter 15 distribution.
16 Q Is it anticipated that Maine, the State of Maine 17 is going to be coordinating access control at its end of 18 I-95 in the same fashion that the ORO in the SPMC want to 19 now coordinate the access control at the southern end?
20 In other words, delay it for about two hours?
21 A (Callendrello) That's what I would expect. .
22 I haven't looked at the Maine traffic management 23 manual to see if those instructions have been added. But I <
24 would expect that it would be coordinated with New 25 Hampshire's access control and the ORO's.
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REBUTTAL PANEL NO. 16 - CROSS 26870 fe~g 1 Q Well, that was going to be my next question.
!' ). And the State of New Hampshire, to the extent that s
- s_- 2 3 it has some access' control functions up at the northern end
. 4 of the EPZ where Spaulding Turnpike, et cetera, come into 5 I-95, will they be coordinating access control in that same 6 fashion, would you expect?
7 A (Callendrello) I would expect that they would be f 8 implementing access control in the way that we described, 9 and that is, to implement that about two hours after the 10 order to evacuate.
11 Q I don't think that's currently the plan in New 12 Hampshire, though, is it?
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REBUTTAL PANEL NO, 16 - CROSS 26871 1 THE WITNESS: (Callendrello) There was a June --
2 I believe it was a June or July '88 revision to the New -
3 Hampshire plan and I don't rect.ll whether it included it or 4 not. It may have already been changed. .
5 BY MR. FIERCE:
6 Q But your belief is that if it hasn't been changed 7 it will be changed and there will be a coordination of the 8 access control in this fashion; that is, delaying for about 9 two-hours?
10 A (Callendrello) Yes.
i 11 Q I'm wondering, Mr. Lieberman, if the information 12 you have and the assumption you are making about the drop-
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13 off from the first hour to the second hour of 2400 vehicles i
14 each way has any basis.
I 15 Can you tell me if it does?
16 I heard you say, you would assume that some of the 17 through-traffic would have heard the messages, and it looks 18 to me like you believe -- I haven't done the math, but it's 19 60 percent or so of the expected flow of through-traffic has 20 now dropped off from 4400 to 2000 vehicles.
21 What basis do you have for that? -
22 A (Lieberman) My recollection is that, based on the 23 telephone survey we identified a total inflow of returning 24 commuter trips of about 6000.
25 Q Now you' re going back to commuter trips again and l
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r REBUTTAL PANEL NO. 16 - CROSS 26872 1 I'm still thinking external / external flowing traffic?
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-/ 2 A (Lieberman) Well, let me repeat what I said a few 3 moments ago.
4 At the time this was run, the only representation 5 we had explicitly of commuter traffic was this, what I call 6 the external / external trips generated along the interstates.
7 I did not model the inbound links within the EPZ.
8 My rational was the following: those trips that 9 were motivated to reenter the EPZ or to enter the EPZ during 10 the first two hours of the evacuation, in my. view, are those 11 who had some function to perform within the EPZ.
12 Discretionary t' rips who would nermally trave 3 13 through the EPZ would be discouraged by virtue of the fact
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15 that has been triggered. And even in the absence of traffic 16 guides they would avoid the area.
17 So in my view, tne vast bulk of entering' vehicles 18 would be returning commuters. The only way, at that time, 19 that I could represent these returning commuters is as a ,
20 traffic stream entering the EPZ along the interstates.
21 And the numbers that I assigned to thic incoming 22 volume are those which were relevant to the data I had which I~ indicated estimates of the number of trips that would 23 24 return.
25 Q You're making some assnaptions here, are you not, i
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l REBUTTAL PANEL NO. 16 - CROSS 26873 1 1
1- about the number.of cars that would have the radio on?
2 A (Lieberman) Well, whether it's the radio or 91 '
l 3 whether they originated their trip within this time frame ;
I 4 and became aware of it at that time, yes. I'm asetming that - j l
1 5 over a narrow period of time most drivers would be aware I
6 that there's a problem.
7 Q Lots of peop.le are lietening to their tape decks l 8 as they travel these days; correct?
9 A (Lieberman) I suppose that's true. f i
10 Q Have you seen any data on that?
11 A percentage of cars on an interstate system 12 traveling to a tourist ar,a like the State of Maine that are 13 listening radio stations versus not listening to radio 14 stations?
15 A (Lieberman) I know of no sue:h data.
16 Q Just terminology-wise, is it fair to continue to 17 characterize what we're talking about here rather than after 18 the emergency has begun as through-vehicles, in your view, 19 or are we talking about returning commuters?
20 A (Lieberman) Within the context of the model 21 representation, it's proper to refer to them as through- -
22 vehicles, because that's the way the model treated them for 23 this series of runc. ,
24 Q There would be some people in the second hour who 25 are not returning commuters, who are passing through the EPZ Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26874
.gs. 1 because they were just unaware; correct?
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}s_./ 2 A (Lieberman) I think there could be a small number 3 of those, certainly.
4 Q 7.n that first sensitivity run that you did, that 5 we've just been talking about, where the 2000 vehicles were 6 added for the second hour, what ETE was examined for that 7 sensitivity run? Was it the Region 1, scenario 17 8 You say it has no impact on ETE, but what ETE?
9 A (Lieberman) I would have to check that.
10 0 Could you do that for me as well?
11 A (Lieberman) Well, I would have to call the office 12 to do that, but I will certainly try.
13 Q There is a second sensitivity test which you
(} 14 dee: ribe next, and again, I just want to be clear what the
\'- / 15 totale were each way for the first hour and second hour.
16 This is the same 4400 vehicles for whatever that 17 time is, something over an hour first; correct?
18 A (Lieberman) I'm sorry, where are you referring 19 to, please? .
20 Q You've got a second sensitivity run you are ]
- 21 describing or is it the same one?
l 22 The next paragraph, the very bottom of page 27:
23 " Maintaining the through-trips originating south of the 24 Massachusetts EPZ at 4400 vehicles per hour for over one-l 25 hour2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br />." ,
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- l REBUTTAL PANEL NO. 16 - CROSS 26875 l 1
1 A (Lieberman) It's the same one.
2 Q It's the same one. )
3 Then I see on page 28 you say again: "Through-4 vehicles have little, if any, effect on ETE." .
I 5 I was going to ask you what ETE, but that's the 6 same question; correct?
7 A (Lieberman) Yes it is.
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1 REBUTTAL PANEL NO. 16 - CROSS 26876 rN 1 Q There's a sentence, two sentences at the bottom I I
\s / 2 of that page 28 that I'm not sure I understand: "Further 3 analysis of the exercise TCP/ACP staffing data reveals the
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4 ACPs on the interstates in Massachusetts would be staffed 5 well before two-hours."
6 Is the word "would" misapplied here and instead is
- 7. the. word "could?"
8 This is not changing the intention to staff at no 9 sooner than two-hours and perhaps later if queues are still 10 forming?
11 A (Callendrello) No.
12 The confusion may be, the point is staffed, 13 somebody will arrive there and be available to activate the 14 point. The point would not be activated until two-hours
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15 after the order to evacuate.
16 Q I see.
17 So this is just to point out that you' re assuring 18 -- there's assurance that it can be staffed at two-hours?
19 A (Callendrello) Correct. .
20 0 The question I had about this, Mr. Callendrello, 21 is now that we know that that's the inteation and that's the 22 plan to staff the access control points at the two-hour 23 stage, doesn't that suggest that the priority staffing 24 mequences that are back -- at the back end of Appendix J 25 need to be revised so that the access control point staffing l[ Beritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 26877 1 priorities are not the first ones, and you can then reassign 2 it to a higher priority at some of the internal traffic t
3 control points?
4 Wouldn't that be a good idea? .
5 A (Callendrello) Operating on a straight two-hour 1
6 time frame that would be true.
7 I believe if you look at our testimony, !
8 Applicants' Rebuttal No. 9 I think that the actual language 9 we use is that: "The access control points will be staffed 10 at two-hours or when traffic begins to drop off."
11 Q So it might be before two-hours? j 12 I read it differently. I read uhat as two-hours 13 and perhaps longer if it would still cause lines, but no 14 sooner than two-hours.
15 A (Callendrello) I can't find it in Applicants' 16 Rebuttal No. 9, I know it's in there.
17 I know we did talk about the fact that access 18 controls are to be implemented when traffic flows fall off.
19 Q Are vs not sure what the plan is, Mr.
20 Callendrello?
21 A (Callendrello) No, I'm just looking for the 22 testimony.
23 0 Okay.
24 (Witness reviewing document.)
25 THE WITNESb: (Callendrello) The testimony on Heritag's Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26878
,s- 1 page 33 says: " Traffic guides wil'1 in the future amendment xs 2 'to IP-2.11 be instructed to activate the ACPs approximately 3 two-hours after the OTE providing that inbound traffic
. 4 volume has declined to the extent that the activity of 5 screening motorists.will not result in the formation of long 6 queues of inbound vehicles."
7 So we expect it to be about two-hours.
8 BY MR. FIERCE:
9 Q I understand, you know, an hour 50, two-hours 10, 10 about two-hours, but not sooner than that. And it would be 11 perhaps longer, you say, providing the traffic is at such 12 levels that queues would not form, it could be longer than 13 that?
("'} 14 A (Callendrello) It could be longer than two-hours.
%- 15 0 But the intention is not to staff the accees 16 control points until about -- I shouldn't use the word 17 " staff" -- the intention is not to activate those access 18 control points until about two-hours?
19 A (Callendrello) Right. .
20 It could be shorter than two-hours.
. 21 Q That being the case, and I'm looking at 22 Appendix J, -- take a look at region -- we have ETEs for 23 Region B and Region 13, and if I take a look at the traffic 24 control points staffing priority list for Region 8 and these 25 are for the Massachusetts posts, I see that the first five
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1 posts are access control' posts; correct?
2 A (Callendrello) Correct.
3 Q Now, you are in a situation where you can reassign 4 these priorities in order to more quickly staff your high -
5 priority traffic control points; correct?
6 A (Callendrello) I don't understand the question.
7 Q The first guides that come in the door to the 8 staging area, traffic guides, I understand they' re assigned 9 on a priority basis as they arrive at the staging area; 10 correct?
11 A (Callendrello) Correct.
12 O The first five guides, if it's a Region 8 13 situation, Region 8 is being evacuated, will be sent to 14 access control posts that need not be staffed according to 15 the plan for about two-hours; correct?
16 -
A (Callendrello) That's correct.
17 Q And you're going to stay with that situation?
18 A (Callendrello) Yes.
19 Q Do you understand that you could more quickly 20 staff the priorities listed here as 6, 7, 8, 9, and 10 if 21 you sent the first guides to those traffic control posts -
22 rather than the firat five access control posts; correct?
23 A (Callendrello) We're talking about a fairly 24 narrow range of times for the first 27 points. We're 25 talking about, I think it's an hour and a half to two and Heritage Reporting Corporation (202) 628-4888
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l REBUTTAL PANEL NO. 16 - CROSS 26880 1
l ,g 1 three-quarter hours. This is a set of fairly narrow range l
(
I
(/ ) 2 of times to get individuals out there.
3 We developed this priority staffing sequence with l 4 the access controls being staffed -- access control points j l
5 being staffed first.
6 I don't see what's to be gained by shifting it 7 around internally.
8 Q Those first traffic control points inside the EPZ l 9 are ones which enhance capacity along critical pathways, at l
10 least for Massachusetts vehicles; isn't that true?
- 11. A (Callendrello) That's true.
12 Q And you could 1. tore quickly enhance capacity, and .
13 thereby reduce the ETE somewhat in that process; correct?
i
/ 14 A (Callendrello) Somewhat. l 15 Assuming the mobilization time and staffing times j 16 that we derive from the exercise, there's a five minute !
i 17 difference in ETE. l 18 The other thing is, access control is an important ;
)
19 function that's performed. You're focusing on a scenario ,
20 where in a mid-day, mid-week returning commuter situation, 21 if we're in an off-season evening situation there isn't a j i
22 large commuter flow and it may be appropriate to activate J 23 those access control points at some earlier stage or earlier i
24 time than two-hours. l 25 A (Lieberman) Perhaps I should draw your attention l
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REBUTTA.L PANEL NO. 16 - CROSS 26881 )
i 1 to page 46 of the testimony which is a sensitivity. test ]
1 2 indicating the effects of the late arrival of the traffic 3 guides relative to the ideal condition of traffic guides 4 being there at the outset.
J i
5 As you see from that table there's only a five d
I 6 minute difference in the ETE.
7 Q I'm going to get to that as we progress through 8 the testimony probably latcr this morning.
9 10 11 12 13 14 15 16 17 18 19 ..
20 21 22 .
23 24 25 Heritage Reporting Corporation (202) 628-4883
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REBUTTAL PANEL NO. 16 - CROSS 26882 7 'q 1- Q There's no intention to change the priority
( ).
\_,/ 2 staffing list at the back of Appendix J?
3 MR. TURK: Is that asked and answered?-
^
- 4 MR. FIERCE: I believe it has. I just --
5 THE WITNESS: (Callendrello) I believe that's 6 correct.
7 MR. FIERCE: Okay.
8 BY MR. FIERCE:
9 Q The last sentence on page 28 says, "Thus, 10 representing through-trips in the ETE analysis, as described 11 above, is appropriate and consistent with traffic control 12 operations implemented under the SPMC."
13 As I understand it, the ETE was calculated using fN 14 4400 vehicles each way for something over an hour, correct?
('-
15 MR. TURK: That's asked and answered.
~
16- BY MR. FIERCE:
17 Q And I'm just wondering how representing 4400 trips 18 each way -- well, we don't know what the time is yet; it's 13 something over an hour -- how is that consistent with no .
20 access control staffing for at least two hours?
21 MR. TURK: Your Honor, I think we have been 22 through the line already.
1 23 Mr. Lieberman has explained that he wanted to put 24 the input in as two hours. He discovered an error. He had 25 put it in for something less than two hours. And then he )
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REBUTTAL PANEL NO. 16 - CROSS 26883 1 did this extra sensitivity run and discovered there was no 2 problem, even if he had modeled it for two hours.
3 And here we go, asking the same line of questions 4 again. .
5 Objection.
6 JUDGE SMITH: Do you agree, Mr. Fierce?
7 What's the distinction?
8 MR. FIERCE: Well, I need some further 9 information, I think.
10 Why don't we just come back to this when Mr. I 11 Lieberman tells me the two things I still don't know, which 12 is the time he actually has the 4400 vehicles flowing 13 through, and I also wanted to know what the ETE was.
14 So I think I will withdraw the question for now 15 and come back to it after I get that further information.
16 BY MR. FIERCE:
17 Q On page 29, there is a discussion about vehicles 18 coming from Seabrook Beach into the Salisbury Beach area.
19 And I read here now how there has been an adjustment made to 20 the model to make what the model is doing more consistent 21 with what the instructions were for the traffic guides. .l i
i 22 Is that correct?
-l' 23 (Witnesses review document.)
24 A (Lieberman) I'm having trouble with your phrase 25 " adjustment to the model". I don't see that phrase in our 1
1 l
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L REBUTTAL PANEL NO. 16 - CROSS 26884 0
l f w. l testimony. q
.- 2l -Q In the.New Hampshire proceedings, I think we 3 raised this point.
- .4. Instructions indicated'that when there was )
.5 ~ congestion on-Route 286, the traffic guide was to direct i 6 traffic from Seabrook south into Salisb ?ry Beach.
7 And Dr. Adler indicated that'his examination of i
8 the runs didn't show any traffic ever flowing down into I
9 Salisbury Beach. Yet,.the model showed consistent 10 congestion on Route 286.
11 A. (Lieberman) That's right. l
. 12 O And he pointed'that out as an inconsistency..
13 And now the model is accurately doing.what the
/'~'
t 14 traffic' guide had been instructed to do. I don't if you
- 15 want,to call it a modification or a change, but the model is 16 now doing it, correct?
17 A (Lieberman) The TRAD model is doing it, that's 18 right.
19 -Q All right. ,
20 When I say the model, I'm now talking about the
+ 21 whole piece of the software.
22 The sensitivity runs --
4 23- A (Lieberman) Just for your guidance, the text on 24 page 30 is a recap of what happened in the New Hampshire 25 hearing. We're simply reviewing what we did there in the Heritage Reporting Corporation (202) 628-4888 4
u _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _
REBUTTAL PANEL NO. 16 - CROSS 26885 1 sensitivity runs that we ran to examine the concerns 2 expressed by the Attorney General.
3 The text on page 31 indicates what we have done in
~
4 connection with the recent set of runs using the TRAD model -
5 which examines the affect of the staged arrival of the 6 traffic guides.
7 Q Now, you describe these two sensitivity runs 8 directing 20 percent of the traffic and then 40 percent of 9 the traffic south onto Salisbury Beach.
10 A (Lieberman) Right. Those ware the runs that were 11 conducted over a year ago.
12 Q Okay, 13 A (Lieberman) In connection with the New Hampshire 14 hearings.
15 Q Can you tell me what the impact of'those two ETE 16 sensitivity runs were for the Salisbury Beach ETE?
17 A (Lieberman) I could try.
18 I can't promise that I could get those results 19 before the end of the day. It would mean calling the -
20 office, digging out those output streams, and then r' inning a )
I l
21 tally which isolates the Salisbury Beach from the rest of -
22 the network to get that data for you.
23 Q Well, let me ask you some more questions to see if I J
l 24 I have to put you to that task. I hope not. j i
25 You indicate there is no overall impact on the i l
9 l Heritage Reporting Corporation (202) 628-4883 1
' i l
V i REBUTTAL PANEL NO. 16 - CROSS 26886 i w 1 ETE, correct?
l \
N- 2 A (Lieberman) Right.
3 Q And that is because the critical path is still to 4 the north, correct?
5 A (Lieberman) That's correct.
6 Q Or is it, perhaps, 286 itself still?
~
'7 A (Lieberman) Might be.
8 Q Might be.
9 It's not in Salisbury Beach?
10 A (Lieberman) That's correct.
11 Q There is no question in your mind, is there, that 12 the evacuation times for Salisbury Beach do go up when you 13 add 20 percent or 40 percent of the vehicles coming out of 14 Seabrook Beach to the load coming off of Salisbury Beach?
[~'N/
\
.15 A (Lieberman) I think that's a reasonable 16 expectation, but one has to review the data to see what it 17 says.
18 Q Now just to be clear, the ETE runs that yo'1've 19 done that give us the times that are in your Appendix D are ,
20 generated with the model that includes the TRAD assignments 21 this way, so that traffic is gettino diverted into 22 Massachusetts, or not?
23 A (Lieberman) I'm not re what you mean by "this 24 way".
25 But the TRAD model is an improvement over the f%)
i, N- '
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REBUTTAL PANEL NO. 16 - CROSS 26887
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1 technology that we had for New Hampshire. And one of the 2 symptoms of that improvement is the fact that TRAD does in 3 fact produce a non-zero movement south from that .
4 intersection of 286 and Route 1A into Salisbury Beach. .'
5 Q Can you just explain for me what a non-zero 6 movement is? !
7 A (Lieberman) It means that the through-movement 8 along the southbound approach to Route 286 along Route 1A is 9 now greater than zero percent. i
\
10 Q Can you tell me what it is? f i
Let me try that at the break also. I 11 A (Lieberman) 12 Q Okay.
13 Or perhaps if not a percentage, maybe there is a 14 number of vehicles that's an easier way to get what I'm 15 looking for.
36 A (Lieberman) That would require a little more 17 work, but I would --
18 Q Well, whichever is easier.
19 A (Lieberman) The percentage is an input to the 20 simulation model.
21 Q Okay. -
22 A (Lieberman) The number of vehicles is an output.
\'
23 That means I have to look at two different places, but I 24 don't mind doing it. !
l 25 Q Either one.
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REBUTTAL PANEL NO. 16 - CROSS 26888
.fs 1 ,I'm interested in knowing for these ETEs we have i
[ I
\s,/ 2 ccming in from Seabrook Beach, either how many vehicles or 3 the percentage of vehicles.
. 4 Just as a driver behavior matter, Mr. Lieberman, 5 won't we still have some drivers who will prefer to move 6 south on Route 1A even if there is, you know, let's say a 7 couple of hundred yards of open road on Route 286 before the
- 8 spill-back ends?
9 A (Lieberman) That's true. We don't model 10 individual drivers.
11 But, again, it --
12 Q But the model doesn't divert any, or have anyone 13 traveling south into Salisbury Beach unless it's full-up.
f'%
t 14 Route 286 is full-up all the way to the intersection, or b 15 what?
16 How does it work?
17 A (Lieberman) Not now.
18 Wibh the TRAD model providing us turn percentages, 19 which allow movement either south or on 286, then there will .
20 be traffic moving south even in the very early stages when
. 21 286 is not congested. You're talking about a rather short 22 time frame.
23 Q Because again we're looking at a system which is 24 optimizing?
25 A (Lieberman) In the sense that it represents
(\m- Heritage Reporting Corporation (202) 628-4888 4
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REBUTTAL PANEL NO. 16 - CROSS 26889 1 drivers' intentions and motivations to leave the area as 2 quickly as possible.
3 Q How do you think the traffic guide will interpret 4 that instruction that he's been given, to divert traffic -
5 southbound when Route 286 becomes congested?
6 Will he believe that means send them onto 286 7 until there is no more space in the queue, or some other 8 interpretation?
9 A (Lieberman) That's the only interpretation that 10 there is room for. That's what the instruction says.
11 Q Okay.
12 Mr. Lieberman, do you have an opinion on if you 13 had allocated, as we were discussing yesterday, 30 percent 14 of the beach vehicles of the 31,000 vehicles to Salisbury 15 Beach and you had looked at the Region 8 and Region 13 ETEs 16 shich we have here for Massachusetts, in doing this 17 sensitivity run, there would have been an impact on those 18 Region 8 and Region 13 ETEs, wouldn't there?
19 A (Lieberman) By doing what?
20 Q If you had allocated, of the 31,000 beach 21 vehicles, 30 percent of them to Salisbury Beach as is -
22 indicated by some of the other data -- that's where they .
23 originate -- and in addition you have the model including 24 TRAD now assigning vehicles down to Salisbury Beach from 25 Seabrook Beach, there would have been an impact on the Heritage Reporting Corporation (202) 628-4888 4
L DI L
26890 REBUTTAL PANEL NO. CROSS l 1
i b- l' Region 8 and Region 13 ETEs.
'\,_/ 2 'Isn't that1 correct?
- 3. A. (Lieberman) But that's what we did.
. 4 We do not allocate,.as Ilsaid yesterday, vehicles 5 to the various beaches by using percentages.
6 Q I understand.
7 A (Lieberman) Right.
8 Q .You'have a percentage which is closer to 20 9 percent for Salisbury Beach, or maybe -- strike that.
-10 It's a lower percentage, I know. Overall, tlus 11 percentage in Massachusetts'you have is 30 percent, not 40 12 as in some of the other data.
13~ In'the Befort data, 30 percent-of the beach area
'~N -
14 vehicles happen:to be in' Salisbury Beach and 10 percent at
-15 Plum Island.
16 -
~Now, as I understand it, you didn't do that in 17 your runs. You don't have 30 percent of the beach vehicles 18 in $alisbury Beach. You have some lesser percentage, 19 correct? ,
20 You got there in a different way. You didn't use
.. 21 percentages.
22 A (Lieberman) That's right.
. 23 Q But looking at it now we now know it's more than 24 20 percent. It's less than 30 percent.
25 A (Lieberman) Right.
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REBUTTAL PANEL NO. 16 - CROSS 26891 1 Q If you had used 30 percent in Salisbury Beach and i
2 had done this exercise for Region 8 and Region 13, the ETEs 3 would have had some impact, correct?
~
4 They would have gone up? -
5 A (Lieberman) You would have to -- I've already 6 done a sensitivity test, as you know, which carried the 7 vehicle population in Salisbury above 7300 vehicles. That 8 amounts to about 24 percent of the total population. That 9 found no change.
10 What you are saying now is suppose instead of 24, 11 we lift it to 30, but did in such a way that the 31,000 12 remains unchanged. That means that you are reducing beach i 13 population elsewhere.
14 Q Yes. ;
15 A (Lieberman) I assume in New Hampshire.
16 Q Yes.
17 A (Lieberman) So there is something of a tradeoff 18 here. If you are reducing the in-flow to Salisbury from the 19 north and you are increasing the number of cars within I
20 Salisbury, the net tradeoff in either direction would be l 21 small. i 22 So I would say that, based on the sensitivity run .
23 that we have run, that it's unlikely that there would be any i
f l
24 material increase in the ETE. !
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o REBUTTAL PANEL'NO'.'16 - CROSS '26892 4
L l
p -< 1 Q_ 'The~ critical path might switch down to Salisbury p (. li 2 Beach; correct? !
3 MR. TURK: Your Honor, we had the whole line 4 yesterday.
-5 MR. FIERCE: This is asking'--
y:.e 6 .!dR. TURK: It's the same question. f
~
7 JUDGE' SMITH: The very question.
~8 What's the difference in this situation?
9 MR. FIERCE: Well, we're. talking specifically l 10 about the addition of the Seabrook Beach vehicles.
11 MR.. TURK: If that's the question I withdraw the 12- objection.
13 THE WITNESS: (Lieberman) It's within the realm
/ 14' of possibility; I think it's unlikely, though.
('--
15 BY NR. , FIERCE:
1 16 Q If we looked at the critical path time for the New i 1
17 Hampshire routes versus the Salisbury Beach route they're 18 not that far apart, are they?
19 A (Lieberman) I would have to check that. .
20 Q But certainly, if we were to take a look and
. 21 extract from the model the ETE for Salisbury there would 22 have been some significant impact; correct?
. 23 A (Lieberman) I don't know if it would be 24 significant because of the tradeoffs that I indicated.
25 Q What are the tradeoffs for Salisbury Beach, if you Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26893 1 were just adding vehicles from Seabrook Beach?
2 I think it was only going to increase their ETEs?
3 MR. TURK: Is the Commonwealth of Massachusetts
~
4 suggesting that we ignore people on New Hampshire beaches? -
5 MR. FIERCE: Of course not. .
6 MR. TURK: And instead give priority to people on 7 Massachusetts beaches because Massachusetts is doing the 8 litigation here today?
9 MR. FIERCE: I object.
10 MR. TURK: Well, that's the thrust.
11 MR. FIERCE: The comment is out of order, Your 12 Honor.
13 MR. TURK: The witness has already testified that 14 there would be a tradeoff. If you increased the numbers in 15 Massachusetts you're decreasing the numbers in New 16 ' Hampshire.
17 JUDGE SMITH: At one time you did make a 18 suggestion that the Governor of Massachusetts might prefer 19 to evacuate his people to the disadvantage of the New .
20 Hampshire people. But I don' t believe you' re doing that 21 today.
22 MR. FIERCE: No, I' m certainly not doing that 23 today, just in terms of looking at what the ETE is for 1
24 Massachusetts, I certainly do believe Massachusetts 25 decision-makers will want to know and will be looking at the Heritage Reporting Corporation (202) 628-4888 l
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c REBUTTAL PANEL NO. 16 - CROSS 26894 q .1 ETEs for their communities.
d }
' 2I If this was a serious problem, Your N ,/ m . MR . TURK:
3 Honor, then I wonder why --
. 4 MR. FIERCE: I object. If we want to argue - -
-5 MR. TURK: If Mr. Fierce would permit me --
6 MR. FIERCE: -- we can do it in proposed findings.
.7 - JUDGE SMITH: Let him make his statement.
8 MR. TURK: If this was a serious issue then why 9 wasn't it litigated in New Hampshire. If Massachusetts
- 10. believes'that, in fact, 40 percent of the beach vehicles are 11 'in Massachusetts and not 30 percent, then.why didn't we do
- 12 that in New Hampshire. We would have lower ETEs for New
'13 Hampshire rather than the ones that Mass AG has managed to 14 jack up there now.
-- 15 MR. FIERCE: I object, Your Honor.
16 He's, again, just going to try to poison the well 17 for the argument that I want to make to you in proposed 18 findings; I would rather argue it there. It's a serious 19 issue. .
20 JUDGE SMITH: Will your position in proposed
. 21 findings this time with respect to ETEs in the Massachusetts 22 communities be consistent with your proposed findings with
. 23 respect to the ETEs in the earlier phase?
24 MR. FIERCE: I'm not arguing --
25 JUDGE SMITH: Well, the more you shift the cars
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REBUTTAL PANEL NO. 16 - CROSS 26895 1 from New Hampshire to --
2 MR. FIERCE: All we argued in New Hampshire, Your 3 Honor, was the overall number of beach vehicles. Nobody got 4 into the discussion -- .
5 JUDGE SMITH: You're sticking with the same number 6 of beach vehicles?
7 MR. FIERCE: I'm absolutely sticking. You've 8 ruled on that. We're now at what I call a second level 9 issue here which is, how does one allocate them? And then 10 in having done the allocation, what are the ETEs that we 11 want to look at for each of our protective action decision-12' makers in New Hampshire and in Massachusetts?
13 Well, just to wrap this --
14 JUDGE SMITH: With the understanding that the 15 Commonwealth of Massachusetts can select almost any ETEs 16 that they want to, those provided by the Applicant, those 17 found by the Board, or those that they deem correct 18 including those that they learn about in this hearing, 19 I think we should give Mr. Fierce considerable -
20 latitude on this issue.
21 MR. FIERCE: I just have basically one final -
22 question here which is the one I had just asked.
l 23 BY MR. FIERCE: -
24 Q As I understand it, for Salisbury Beach it's not a 25 tradeoff situation, we're going to be receiving additional Heritage Reporting Corporation (202) 628-4888 i
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REBUTTAL PANEL NO. 16 - CROSS 26896 1
.)-~< 1- : vehicles.from Seabrook Beach, but there's no countervailing
[ )- j 1
\~ / 2' 'affectoon the ETEs for Salisbury Beach; correct, Mr.
3 Lieberman?
4 A- (Callendrello) I just want to make sure we have q 5 all the assumptions correct.
6 Have we forgotten about the reallocation of the 7 31,000 and we're just addressing the flow from Seabrook to l'
8 Salisbury?
9 Q Yes.
10 A (Lieberman) We've been talking on several planes 11 here and I'm trying to understand the underlying premise of 12 your question so I can answer it.
13 If I can review briefly: first you talked about 14 keeping'the 31,000 fixed and reallocating, as you-put it, L( 7
\
15 percentages.
16 Then as I understood separate from that, you were 17 talking about turning movements affecting the movement of 18 traffic south from Seabrook and from Hampton.
19- And then separately again, you were talking about ,
increasing the number of cars within Salisbury independent 20 21 of the percentage allocation or the changing turn movements 22 at 286.
l . 23 So if you could tie those three things together 24 into a single scenario that would be very helpful to ma in P
25 answering your question.
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REBUTTAL PANEL NO. 16 - CROSS 26897 1 Q Well, I'm not sure we need to go to that level of.
2 difficulty.
3 Let me start with what I think is a simpler 4 question: first, under any set of circumstances that we -
5 start with, if we run the model and send -- any set of .
6 circumstances which does not have Salisbury Beach vehicles 7 enhanced by the arrival of Seabrook Beach vehicles.
8 If Seabrook Beach vehicles are sent down to 9 Massachusetts the Salisbury Beach ETEs will increase; 10 correct?
11 A (Lieberman) There is that potential, yes.
12 Q Is a potential?
13 Why wouldn't they increase?
14 It's a direct relationship, isn't it?
l 15 A (Lieberman) Again, you would have to look at 16 where the bottlenecks are in the system.
17 If Salisbury Square is the controlling bottleneck 18 throughout the extent of the evacuation process, and if 19 saturation prevails throughout the extent of evacuation, 20 then I would say, yes. If there's any increase in demand 21 that's going to take the form of an increased time for 22 evacuating from the area, Salisbury Beach / Beach Road. .
23 If the interchange of Route 110 and I-95 is the 24 controlling area you may have something else. The beach 25 area may empty out perhaps in the same time frame, perhaps a ;
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H j REBUTTAL PANEL NO. 16 - CROSS- 26898
- s. l', little-longer, and the problem would shift into Amesbury.
7 k--.
'2- The only way.to. determine this is to run the model.
'3' So the best answer I can give you is that,.yes, if 4 t'here's a higher demand there's certainly.a potential for 5 increased ETE. I won't' commit myself to-saying that 6 absolutely there will be an increase. There likely will be L7 an increase, but I won't commit myself to it.
8 -Q There's a discussion following that section of 9 evacuee mobilization times, and this is in the context of 10 addressing.some issues that are in contentions about 11' conflicting messages'from different sources that evacuees p 12 might be receiving in a Seabrook emergency.
1.
13 The discussion focuses on, obviously, evacuee 14 mobilization times. I'm wondering if there aren't some 15 additional. impacts on ETEs that could well come from 16 confusing or conflicting messages that would be issued to 17 the public?
18' And for purpose's of this discussion let's assume -
19 we've got some confusing and conflicting' messages. .
20 There.could be some other consequences, couldn't
- i. 21 there,-Panel, such as evacuees taking different routings' 22 than would be otherwise described in preemergency
- 23 information and the authorized EBS message; wouldn't that 24 have a possible impact on ETEs?
.25 MR. TURK: There are two questions there.
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REBUTTAL PANEL NO. 16 - CROSS 26899 P
1 MR. LEWALD: I'm going to object to the 2 generalness of the question. I think there are more than 3 two questions.
4 Mr. Fierce has premises here that I'm not sure are -l 5 clear as to the extent of them. And what the witnesses are .
6 going to respond to, not knowing what the premise of the 1 7 hypothetical are? And I think we're going to have a 8 difficult time in determining really what the value of the 9 testimony is.
10 JUDGE SMITH: Do you agree? !
11 Can you do better?
12 MR. FIERCE: Well, let me see if I can do better. ,
13 I'll be happy to try.
14 BY MR. FIERCE:
15 Q As I understand the testimony it starts with the !
16 discussion of the potential for differing or conflicting (
17 messages and, of course, states that --
18 MR. LEWALD: Could I interrupt and ask you if 19 you're referring to a specific place in the testimony?
20 MR. FIERCE: Yes.
21 Page 31, the discussion under "D: ETEs in
- 22 sensitivity to slower evacuee mobilization." .
23 BY MR. FIERCE:
24 Q The subject matter here is that evacuee 25 mobilization even if -- the assumption is, even if it's Heritage Reporting Corporation (202) 628-4888 O1 i s i
REBUTTAL PANEL NO. 16 - CROSS 26900 1 going to be longer or somewhat slower than has been 2 estimated, presumably as a reeult of conflicting messages 1
3 that that additional extension of the mobilization times f 4 isn't going to have an impact on the ETEs.
5 That's the sum and substance of that section of 4 6 the testimony; correct, Panel?
7 A (Lieberman) Yes.
8 Within the bounds that we explored in the 9 sensitivity test.
10 Q I'm just interested in knowing whetner you might 11 think that rationally there could be some additional 12 potential impacts on the ETE besides and apart from the 13 evacuee mobilization issue?
14 Again, assuming as you've done here that there 15 might be some problems which would have created longer 16 mobilization times, let's assume there are some problems.
17 Wouldn't, perhaps, we also have some difficulties 18 with evacuee routing if they had gotten some confusing and 19 conflicting messages? We might not have the same degree of .
20 orderliness in the evacuation that we had previously 21 assumed; correct?
22 JUDGE SMITH: You're not examining him on that
- 23 aspect of the direct testimony then, are you?
24 MR. FIERCE: Well, they believe that the issue is 25 addressed by the discussion of evacueo mobilization. And 9 Heritage Reporting Corporation (202) 628-4888
1 l
REBUTTAL PANEL NO. 16 - CROSS 26901 1 therefore there's no impact on ETEs from confusing, 2 conflicting messages. .
3 JUDGE SMITH: No, they're saying that slower evacuation mobilization time does not affect the ETEs 4
5 because, assuming that roadways become saturated quickly. .
6 That's the thrust of the testimony. It's a 7 subsidiary part of it about, whether or not conflicting 8 messages are likely te occur. That's not the thrust of I
9 their testimony.
l'0 You want to examine on that sentence?
11 MR. FIERCE: Well, that's how they get there.
12 JUDGE SMITH: But you're not challenging the 13 premise?
14 MR. FIERCE: I'm not challenging the premise.
15 JUDGE SMITH: That if roadways become saturated, 16 quickly delayed and mobilization of evacuees are unlikely to 17 affect the ETEs; that premise you're not challenging now?
18 MR. FIERCE: I'm not addressing it now.
19 JUDGE SMITH: Right.
20 MR. FIERCE: I might challenge it in the abstract, 21 yes.
22 JUDG1; SMITH: You're just challenging that .
23 statement. j 24 MR. FIERCE: I'm taking the thrust of this piece 25 of testimony.
Heritage Reporting Corporation (202) 628-4888 L _ -_
g REBUTTAL PANEL NO. 16 - CROSS 26902 1 JUDGE SMITH: See,'that wasn't the purpose of the 7-~ .
%. - 2 testimony. That was a lawyer's piece put in there, I think.
3 That was not the purpose of the testimony.
4 _MR. FIERCE: Well, there is a contention which is 5 an ETE -- it's a basis of the ETE contention which says:
6 "The ETEs are likely to be longer because we have a 7 potential here for confusing, conflicting messages from a 8 variety of sources."
9 Now I know we have a panel coming in next week on 10 the messages and whether they, in fact, will have that 11 impact.
12 JUDGE SMITH: I guess I shouldn't second guess 13 what they intended. If they're willing to defend that
/~ 14 statement and that was their purpose, fine.
' 15 MR. TURK: May I ask: could you refresh my 16 recollection on that, which contention says that?
17 MR. FIERCE: It's the ETE contention.
18 MR. TURK: Somewhere in 1 to 37 19 MR. FIERCE: Yes. .
20 MR. TURK: All right.
21 Thank you.
22 (Pause to review document. )
. 23 JUDGE SMITH: Just as I sit here I'm surprised 24 that plopped in the middle of this testimony is a defense of 25 the EBS messages. I just didn't expect it.
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REBUTTAL PANEL NO. 16 - CROSS 26903 1 MR. FIERCE: JI-2, Basis C: "The ETEs fail to 2 account for the delays that will result from the confusion 3 among the public caused by hearing different emergency 4 messages from different sources." -
5 How this panel, I believe, is not getting into -- .
6 addressing that issue directly, whether there will be such 7 messages that will cause confusion.
8 JUDGE SMITH: Right.
9 MR. FIERCE: That's beyond their scope.
10 JUDGE SMITH: They could easily have said, even 11 assuming.
12 MR. FIERCE: That's right.
13 JUDGE SMITH: They could have said that, and then 14 their point would have been made.
15 MR. FIERCE: That's where I think we are, even 16 Assuming. We'll let the panels next ueek battle it out over 17 whether that will happen.
18 JUDGE SMITH: Fine.
19 BY MR. FIERCE:
20 Q But even assuming we have some confusing, 21 conflicting messages, for ETE purposes what you've focused
- 22 on is evacuee mobilization only. And I'm wondering whether 23 there may well be other impacts that need to be assessed for -
24 ETE purposes that you haven't focused on here in the 25 testimony?
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REBUTTAL PANEL NO. 16 - CROSS 26904 rs 1 JUDGE SMITH: As the -- oh, excuse me.
/ I O .
2 BY MR. FIERCE:
3 Q For example, if there were an impact -- we have to 4 just assume this -- that created some confusion among the 5 public, might we not have to look at the impact on ETEs of 6 the different routings that the people might be taking at 7 that time? The orderliness of the evacuation, in other 8 words, would not be assumed to be as great as we have where 9 the messages are clear in instructing the public what to do?
10 MR. TURK: Your Honor, I'm going to object without 11 a specification of which messages he's alleging or what 12 kinds of directions people are going to get that he thinks 13 will be confused.
14 Is he saying people are going to be directed along
(
\
15 certain routes in one message, but another message will say, 16 no, do something different? 17 JUDGE SMITH: Even there, I'm even more convinced 18 that that is outside the mafar thrust of the testimony. 19 I could hardly take that position against the . 20 expressed language that they had in the testimony, but 21 there's no such expressed language in their testimony now 22 that you're examining on. That is, driver confusion as to
. 23 roadways, as to evacuation routes caused by EBSs; that's 24 what you' re going to examine him on?
25 MR. FIERCE: I'm not going to go very far with p Heritage Reporting Corporation ( N (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26905 1 this, Your Honor. I just want to explore whether the panel 2 thinks this is the only concern there would be about ETEs 3 from confusing, conflicting EBS messages. 4 Are there other concerns, I' m asking, that we . 5 ought to be looking at. . 6 JUDGE SMITH: Other than mobilization? 7 MR. FIERCE: Yes. 8 BY MR. FIERCE: 9 Q Does the panel have any opinion on that at all? 10 And if you say it's beyond your knowledge, fine, 11 I'll move on. But are there any other potential impacts on 12 ETEs from confusing, conflicting messages that you can 13 perceive? 14 MR. TURK: Your Honor, I can postulate a message 15 which says to people, everyone turn left. Now everyone turn 16 right. Now everyone turn left. 17 I mean, without identifying the messages, how can Sure, you can say if everyone is told at j 18 the panel answer? 19 1 o' clock to head west, and at 1:10 they're told, turnaround 20 and go the other way, and at 1:15 they're told, okay, now go 21 north. Sure, people are going to start getting confused. - 22 Is that the question? l 23 JUDGE SMITH: Well, that doesn't help you. . 24 The answer he's looking for is driver uncertainty 25 and that would affect the ETEs, I assume it could. Heritage Reporting Corporation (202) 628-4888 O1
REBUTTAL PANEL NO. 16 - CROSS 26906
,e^g 1 I think the real issue is: is that within the
% 2 scope of this testimony?
3 4 5 6 7 8 9 10 11 12 13 t ( 14 b- 15 16 17 18 19 - 20 21 22 23 24 25
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1 REBUTTAL PANEL NO. 16 - CROSS 26907 1 MR. FIERCE: Well, the only way to get to that 2 issue is to ask the Panel. . 3 BY MR. FIERCE: 4 Q Do you believe that, by looking only at evacuee 5 mobilization times and finding that there aren't going to be . 6 problems with extensions, you have addressed all of the 7 issues for ZTEs that could stem from confusing EBS messages? 8 MR. LEWALD: Your Honor, I wouldn't object to a 9 yes or no responae to that. But this means we are going to 10 open a whole new ar6a of things way beyond the scope of the 11 testimony. 12 JUDGE SMITH: He says not. 13 MR. LEWALD: Unless the answer is -- 14 JUDGE SMITH: You don't object unless the answer 15 is -- 16 MR. LEWALD: Well, if it can be confined to that 17 one answer and no more, because we' re off to the races if 16 he's allowed to pursue this. 19 JUDGE SMITH: Well, I don't think we are going to , 20 go off. 21 MR. FIERCE: We're not off to the races. I mean 22 the Board knows that I don't have long lines that travel . 23 down various avenues here, and I don't. - 24 JUDGE SMITH: All right. 25 MR. FIERCE: And I promise I won't. Heritage Reporting Corporation (202) 628-4888
' REBUTTAL' PANEL NO. 16 - CROSS- 26908 1 .I' would like to establish this simple point,. that f-2 the Panel has focused on only one issue that's related to
- 3. potential confusing mecsages. And I would like.to know if
- 4 .the Panel thinks that's all there is that'we need to concern 5 ourselves with about ETEs, if there are confusing, 6 conflicting EBS messages.
7 MR. TURK: If that's what he's doing, Your Honor, 8 then isn't it covered by the New Hampshire decision on 9 . aberrant driver behavior?
'10 MR. FIERCE: Which was found not likely.to occur 11- because EBS message: would be out and they would be 12 consistent and clear and people would know what they were 13 doing.
g 14 JUDGE SMITH: Yes. We're not talking about
\ We're talking about ordinary 15 aberrant driver behavior here.
16 driver uncertainty which indeed is assumed in the ETEs. I 17 guess that's what we're talking about. 18 I don't think he can go very far, but let's answer j 19 the question, if you know what the question is. , 20 THE WITNESS: (Callendrello) The way I understand
- 21 the question is, what do we think are the potential outcomes 22 of conflicting or confusing EBS messages.
< 23 And the potential outcome we foresaw and evaluated 24 was a delay in mobili=ation time.
25 I can't accept the other premises that Mr. Fierce Heritage Reporting Corporation (202) 628-4888
i i REBUTTAL PANEL NO. 16 - CROSS 26909 j l 1 has laid out of people taking wrong directions, because of l 1 2 the variety of public information that's out there, the ) 3 calendars and information available for transients. 4 I don't see that being an effect of confusing or - 5 conflicting EBS messages. j l I 6 BY MR. FIERCE: 7 Q Have you examined potential increased shadow 8 evacuation? 9 A (Callendrello) As we testified in New Hampshire, 10 the evacuation time estimates consider at present 50 percent 11 shadow out to the distance of the kayhole ksing evacuated, 12 and then 25 percent 10 miles beyond that. 13 Leyond that consideration of shadow evacuation, 14 no. 15 Q Do you have an opinion, Panel, of whether it might 16 be more likely that the shadow phenomenon would be a larger 17 phenomenon in the event there were confusing and conflicting 18 messages? 19 A (Callendrello) I think Dr. Mileti testified in , 20 New Hampshire that starting with the premise that you've got . 21 bad information for the public, shadow evacuation could be - 22 high, and that's one of the reasons why we have endeavored . 23 to have good, coordinated EBS messages. - 24 Q And with good, coordinated EBS messages, the 25 assumption would be, as we've discussed before, the 25 to 50 j i Heritage Reporting Corporation (202) 628-4888 1 1 I L _ _ __-_ _
L REBUTTAL PANEL NO. 16 - CROSS 26910-l , ,, -~s 1 percent range for shadow evacuation that you are using, l l \ 2 correct? 3 A (Cr.. lendrello) That's what the ETE assumes,
^
4 that's correct. 5 Q The sensitivity runs here for evacuee mobilization 6 times were done for the summer scenarios, not for the off-l 7 season scenarios, correct? 8 A (Lieberman) That's correct. 9 Q ror some of those off-season scenarios for 10 Massachusetts, the ETEs are in the range of four hours, 11 correct? 12 A (Lieberman) For the sparsely populated areas: 13 the West Newbury, Merrimac, even Amesbury, yes.
/ ~' 14 Newburyport and Salisbury are higher.
f
's
'-- 15 0 Well, I'm looking at Region 8 in your table which 16 includes just Amesbury and Salisbury. I see some times in 17 the four-hour range.
18 A (Callendrello) Yes. 19 That's for the midweek -- well, the Scenario 8, . 20 which is less than four-hour, is for off-season midweek
- 21 evening or weekend daytime.
22 Q Yes.
. 23 A (Callendrello) Good weather.
24 0 3:35 is even mentioned there. 25 A (Callendrello) That's correct. [ j Heritage Reporting Corporation
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I I i REBUTTAL PANEL NO. 16 - CROSS 26911 1 Q Couldn't we have some impact on ETEs for those 2 scenarios which currently have ETEs in the three and a half l 3 to four-hour range, making the assumptions about delayed
-~
4 mobilization that you did in the sensitivity runs you did 1 5 do?
- 6 A (Lieberman) The best way I can answer that is to 7 refer you to page 46 where we did a sensitivity study for 8 Scenario 5, which is off-season for the entire EPZ, Region 9 1.
10 And while it doesn't explicitly address the 11 confused EBS, or confusing EBS messages, since that's not 12 part of this testimony, it does show the sensitivity of the 13 effects of not having traffic guides. 14 Now, the absence of traffic guides means that 15 certain critical locations do not have their capacities 16 dnhanced, and it also means a lesser compliance with the 17 recommended routing. And I think we talk about that on page 18 38, Item 3, in which we describe the need for two 19 applications of the TRAD model in order to represent the , 20 different routings with and without traffic guides. 21 So if you have a confusing message and you have a 22 lesser compliance with respect to the recommended routing, . 23 then I think some insight can be gained from these - 24 sensitivity studies. 25 Q Mr. Lieberman, isn't it true that delayed evacuee Beritage Reporting Corporation (202) 628-4888
L L c REBUTTAL PANEL NO. 16 - CROSS 26912-f H 1- mobilization. times are only going to have impact on ETEs for' f-s (s 2~ those short BTEs.that we have?- ,ss. 3 'A (Lieberman) They have that potential, yes.
^
4 Q; And the sensitivity run you, looked at looked at 5 some long ETEs, correct? 6 'A (Lieberman) That is correct.: And I believe -- 7 Q For some of these short ETEs, like the ones I was. 8 pointing you to, the effects of delayed mobilization, even-
- 9. in the' time ranges'that you were looking at in your 1-0 sensitivity studies, will have an impact on the ETEs, won't 11 they?
12 .A (Lieberman) I don't know. You would actually 13 have to do the analysis.
.j 14 Q When you did your analysis, you knew that the 15 impact would only appear for short ETE regions, correct?
16 And you did it on a long ETE region. 17 A- (Lieberman) Yes. 18 But in my test'imonyl[ brought out the other point 19 as well. I did not walk away from it. , 20 MR. FIERCE: Your Honor, is this a good time for a 21 break? 22 JUDGE SMITH: All right.
. 23 How much time do you think you will need, Mr.
24 Lieberman? 25 You have several calculations to make. Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 26913 1 , THE WITNESS: (Lieberman) Fifteen /20 minutes 2 should suffice. 3 JUDGE SMITH: All right, 20 minutes.
~
4 (Whereupon, a recess was taken.) 5 , 6 7 8 9 10 11 12 13 14 15 16 - 17 18 19 . 20 21 22 23 . 24 25 Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ - _ _ _ _ ._ 1
REBUTTAL PANEL NO. 16 - CROSS 26914 1 . JUDGE SMITH: Mr. Fierce? 7-~s i A -- 2 MR. FIERCE: Thank you, Your Honor. 3 BY MR. FIERCE: 4 Q Mr. Lieberman, have you had an opportunity to find 5 any or all of the numbers that you were looking for earlier? 6 A (Lieberman) I.found some of them. Your request for the ETE associated with extending 7 8 the external / external trips at two hours required a call to 9 the office. Those files which are quite old now were taken 10 off the machine. 'They are on magnetic tape, and you have to 11 find it, put it back on the machine, do all that sort of 12 thing. So I don't have that. 13 I will try to get it by the end of the day.
/~~N 14 Q Okay.
15 A (Lieberman) Checking the external / external trips, 16 the only runs I have with me are those representing 17 commuters, and they are not responsive to the testimony. As 18 I indicated before, those runs were made for the staged 19 guides without consideration for commuters. The run that I , 20 have available considers commuters. So I don't have that 21 data available. 22 Q Is this in response to the question of how long is
- 23 over one hour?
24 A (Lieberman) Right. 25 So this input stream that I have available is t pi Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 26915 1 different in that respect, and, of course, in other respects 2 as well from the one that was used as a basis for the . 3 testimony you made your inquiry for.
~
4 I had better luck with the other two. Again, I - 5 don't believe that the presence of commuters, or the . 6 explicit treatment of commuters is going to influence the 7 numbers I'm about to give you. 8 You asked what are the turn percentages for 9 southbound traffic on Route 1A approaching 286 within 10 Seabrook Beach. 11 Q Yes. 12 A (Lieberman) Again, we have two executions of the 13 TRAD model, one without guides and one with guides as 14 described yesterday. 15 For the case without guides, 43 percent through to 16 Salisbury, into Salisbury; 57 percent right turn along 286. 17 For the case when the guides get there, the TRAD 18 model yields 19 percent through; 81 percent right turns. 19 I was able to get you the total volume of traffic 20 moving into Salisbury from the north along Route 1A. That's i 21 1492 vehicles. ! l 22 Q The 1492 is the total of the entire period of 23 without and with guides? - l 24 A (Lieberman) That is correct. ! l 25 Then you asked me to check the evacuation time for i Heritage Reporting Corporation (202) 628-4888 9 ,
y.. REBUTTAL PANEL'NO. 16 - CROSS -26916 Y
;(
l' Salisbury in'and of itself. A 12; Q Yes.
'3 A .( Lieberman) I looked at two linus. One is the Y-- 4- approach to Salisbury Square along Route 1A.- That's the 5 westbound approach servicing the evacuees from the beach-
'6 r ea. That cleared in approximately five hours'and 40 7 . minutes.
8 I then looked at the western boundary of the Town 9 of Salisbury,~again along Route 110 westbouni. And that 10: cleared five minutes later, which is not surprising. So 11 that's at 5:45. 12 ThatLeompares with the ETE shown in Attachment'D 13 of 7,05. fa - 14' Q The times you'just gave me for Salisbury.are the 15 times for which run? For the regular run? For the 16 '5ensitivity run? 17, A (Lieberman) No, that is for the Region 13'run
- 18. .with commuters.
19 Q Do you'know what.the impact on those times -- I 20 A (Lieberman) I'm going to have to back off. Let 21 me just check this. 22 Let me retract that. i 3 23 Q Okay. 24 A (Lieberman) This is not for Scenario 1, but
~
25 Scenario 3, Region 13. We conducted our commuter runs on L 4 Beritage Reporting Corporation L (202) 628-4888 1 l 1
REBUTTAL PANEL NO. 16 - CROSS 26917 1 Scenario 3, which is the midweek, midday summer scenario. 2 And we did that because that scenario has the highest 3 commuter traffic.
~
4 So that compares with the 6.05 ETE which appears k 5 in Supplementary 16. . 6 Q The reason I got into this is, I was interested in 7 comparing the Salisbury Beach ETEs in these sensitivity runs 8 where you added 20 and then 40 percent additional vehicles 9 heading south into Seabrook. 10 You don't have any idea what the impact for 11 Salisbury was of those, do you? 12 A (Lieberman) No, I didn't look at that. 13 Q The next section of the testimony deals with the 14 planning basis. 15 Mr. Lieberman, this was a planning basis that got 16 established when? With your initial involvement in the ETE 17 process for Seabrook? 18 A (Lieberman) That's correct. 19 Q And that would have been when? About 1985? 20 A (Lieberman) Right. , 21 It was actually an outgrowth of my earlier 22 involvement with Shoreham, based on discussions with the 23 people there. It just carried over to Seabrook. - 24 Q Okay. 25 Mr. Callendrello, can you remind me of what the Heritage Reporting Corporation (202) 628-4888 G, _ _ _ _ _ _ l
REBUTTAL PANEL NO. 16 - CROSS 26918 7;rs. 'l . initiating conditions are for a. beach closure at an alert ,
- t
\, 2- for New Hampshire?
~3- ' A (Callendrello) "At an alert level" s 4 discretionary action on the-part of the decisionmakers in
.5 I the State of New Hampshire, and there are several 6- conditions,fthere is a condition that has to be met, and I 7 believe that condition-is that the plant is.in a degrading 5 condition.
9 -Q And that's it? 10 You don't need specific wind directions? 11 A (Callendrello) That's right. 12~ I can check the procedures. I have them here in 13 the room.
/"' 14 As I recall, we removed the reliance on wind i
\' 15- diregtion back in February 1988.
~
16 Q. I.think that's right. 17 A (Callendrello) I think it's just on plant 18 conditions. 19 Q I think that's right. . 20 The beach closure for Massachusetts at the site
. 21 ' area emergency -- well, let me just clarify for the record.
22 There is not a provision in the SPMC for a beach
..- 23 closure at the alert stage, correct?
24 A (Callendrello) It's not one of the pre planned 25 actions, that's correct. , Heritage Reporting Corporation (202) 629-4888
REBUTTAL PANEL NO. 16 - CROSS 26919 1 Q But it is pre planned, it's mentioned in,the SPMC, 2 at the site area emergency stage, correct? . 3 A (Callendrello) That's correct. 4 Q And are there any initiating conditions other than i 5 that it be a summertime condition and a site area emergency . 6 is reached? 7 MR. TURK: Are you suggesting that it's an 8 automatic decision at the site area emergency? 9 MR. FIERCE: Again, I'm asking do you need to have 10 particular wind or plant conditions. 11 MR. TURK: Your Honor, my only point is that we've 12 hart testimony already that it's discretionary at the site 13 area emergency in Massachusetts; not an automatic action. 14 MR. FIERCE: We don't need to go beyond that. 15 BY MR. FIERCE: 16 Q There are some conditions, you believe, Mr. 17 Callendrello, that would permit early beach closure at the 18 site area emergency in Massachusetts? 19 A (Callendrello) Yes, that's correct. . 20 That per Implementing Procedure 2.5. Again, 21 that's with all of these. This is a recommendation that ORO 22 would make to the Commonwealth of Massachusetts . 23 decisionmakers. - 24 Q Mr. Lieberman, have you ever evaluated the impact 25 on the Massachusetts ETEs if the New Hampshire beaches close Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26920 f' . .
< "s .1 at an alert, and then say an hour or two or three hours
- 2 later the emergency progresses to a site area emergency 3 which is followed by a general emergency within 25 minutes?
4 A (Lieberman) No. 5 Q Have you ever evaluated what impacts that might 6 have on the Massachusetts ETEs? 7 A (Lieberman) No. 8 Q Ever do any sensitivity runs along those lines? 9 A (Lieberman) No. 10 Q Have any opinion whether there might likely be a 11 large shadow evacuation from the beach areas in 12 Massachusetts? 13 (Witnesses confer.) A (Lieberman) Mr. Callendrello informs me that they
/~'} 14
\ 15 would be sounding the sirens in New Hampshire. I imagine 16 they would be heard in certainly Salisbury Beach.
17 I would expect that there would be substantial 18 movement from Salisbury Beach concurrent with the movement 19 from New Hampshire, and that movement only as to be, to the , 20 extent of saturating the roadways, to affect the same 21 scenarios which we have studied. 22 Q Okay, I'm not sure I understand that answer, but
- 23 let me ask it perhaps in a more general way, maybe not.
24 If there is an early beach closure in New 25 Hampshire wnich occurs an hour or two ahead of Massachusetts
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I' REBUTTAL PANEL NO. 16 - CROSS 26921 1 carly beach closure, and then a general alert follows 2 within, as your planning basis now haa, within 25 minutes . 3 after that -- an order to evacuate occurs within 25 minutes 4 after that -- is the ETE for the Massachusetts connunities - 5 likely to be higher or lower than it is under your planning . 6 basis now? 7 A (Lieberman) Oh, substantially lower. 8 Substantially lower. 9 Q And that is because you would anticipate large 10 numbers of people from the Massachusetts beaches also to be 11 leaving because they could hear the sirens? 12 Is that the reason? 13 A (Lieberman) That's not the sole reason. 14 If you've ever walked around the beaches, you find 15 the a many blankets have radios going. And I think the 16 information on the local radio stations, regardless of which 17 station they are listening to, would carry the news that New 18 Hampshire beaches have been closed because of a problem at 19 Seabrook Station.
\
20 I don't think there would be too many souls who 21 would go back to sleep. I think they would get up and - 22 leave. And that would essentially, by default, create the 23 same conditions that we are postulating on our present 24 planning basis to a great extent. 25 C Some of us thought perhaps there may be a volume Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26922 T 7 ^si 1 of vehicles that would travel down from Hampton Beach and
't N- 'f 2 Seabrook Beach to Salisbury Beach in the event of a New 3 Hampshire but not a Massachusetts beach closing.
4 Do you reject that? 5 A (Lieberman) Absolutely. 6 MR. TURK: Someone has said that? 7 MR. FIERCE: At lease it's been -- 8 MR. TURK: I've heard "you" say that. I've heard 9 "yoa" posit the theory that people will leave New Hampshire 10 beaches and relocate out to Massachusetts beaches. 11 MR. FIEROE: And I've heard others say it as well. 12 MR. TURK: I've only heard "you." 13 MR. FIERCE: Or at least query whether that might
.[ \ 14 happen.
15 MR. DIGNAN: They've got an expert who holds that 16 theory. 17 MR. TURK: Oh, I apologize. 18 MR. DIGNAN: You weren't here for that. 19 BY Mn FIERCE: . 20 Q So you believe that the Region 8 and 13 ETEs would 21 drop as well as the overall ETE for Massachusetts. 22 Is that correct? 23 A (Lieberman) Well, since the ETE is measured with 24 respect to the OTE, order to evacuate, since that is delayed 25 relative to the exodus of people from the beach -- and I'm 1(~'s) N/ Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26923 1 sure other shadow evacuation as well -- it follows that the 2 ETE would in fact be reduced. . 3 And as you recall, we did some sensitivity studies 4 documented in volume 6. - 5 (Witnesses review document.) . 6 A (Lieberman) On pages 10-17, 10-18, which show 7 that at slower rates of accident escalation, which you 8 postulated here, the ETEs do in fact decline. 9 Q These sensitivity studies, in looking at slower 10 rates of accident escalation, still look to have 11 Massachusetts and New Hampshire acting in concert with their 12 beach. closures, correct? 13 A (Lieberman) Right, and that would be the de facto 14 condition which I described a few minutes ago. 15 Q Now, in the exercise, New Hampshire closed its 16 beaches first at, I believe it was about 11:00, 11:01 maybe. 17 Is that correct, Mr. Callendrello? 18 A (Callendrello) The exact time is in the FEMA 19 exercise report. 20 Q Yes. 21 A (Callendrello) But as I recall, it was around - 22 11:00; a few minutes after-23 Q I've just checked it and it looks like it was - 24 about 11:00, 11:01. At least that's when the sirens were 25 sounded according to page 76 of the exercise report. Heritage Reporting Corporation (202) 628-4888
' REBUTTAL PANEL NO. 16 - CROSS 26924 1 And therefore, people would turn on their EBS, i
- ( ,
2~ listen to their radios and get that message.
. ..h. . '
3' A' (Callendrello) Well, they wouldn't need to do
'4 that.necessarily, because the sirens would be putting out a.
p -. l - 5 public= address. message as well. 1
'6 Q .Oh, So it's-11:01, beach closing in New Hampshire.
7' l= 8 And in Massachusetts, the sirens were sounded, I 9 believe, at about 12:25. 10 Does that sound about right to you?
,11 (Witnesses review document.)
12 13 14 k 15 16 17 18-19 . 20
- 21 22
. 23-24 25 O) g v
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REBUTTAL PANEL NO. 16 - CROSS 26925 l 1 Q That's when the report tells me the EBS message 2 went out to close the beaches, 12:25? 3 A (Callendrello) Yes. 4 That's consistent with -- k 5 Q So it's about an hour and 25 minutes later, an 6 hour and 24 minutes, something like that; is that correct, 7 the difference in time between the two beach closures? 8 A (Callendrello) Yes. 9 Q Now, thereafter we know from the exercise report 10 and other information that Massachusetts decision-makers 11 made a series of protective action decisions, and as I 12 understand the situation and Applicants' testimony I think 13 indicates this: the first of the decisions made at the 14 general emergency was a predetermined one, when they 15 recommended the closure of the beaches in Amesbury and 16 Salisbury. 17 But that there was a later PRA, later in the 18 afternoon around, I think it was around 3:45, which was not 19 that; it was a considered one of the kind in which ETEs 20 would be useful. 21 Is that your understanding, Mr. Callendrello? - 22 MR. LEWALD: Do you understand the question? 23 THE WITNESS: (Callendrello) No. 24 MR. TURK: Are you making a distinction between 25 when the PRA was issued and when the EBS message -- Heritage Reporting Corporation l (202) 628-4888 l 1 l j
- 1. .
REBUTTAL PANEL NO. 16 - CROSS 26926 y - 1. - MR. FIERCE: No,.no, no, no , no.
'f Ds /'
2- I.want to get to the PRA for which -- in the 3 . exercise'for Massachusetts which had -- was at least based' 4- -on looking at an ETE. 5 JLs I understand the Applicants' testimony, the 6 : initial one, at the general' emergency was a predetermined 7 PRA. 8 MR. TURK: At the general emergency? 9 MR. FI'L ,E: Yes. 10 MR. TURK: You're thinking of-the SAE7 11 MR. FIERCE: No. No. 12- We know they closed the beaches at the site area 13 emergency at about 12:25. Thereafter -- 14 MR. TURK: Well, they made the PRA at 11:52. 15 MR. FIERCE: I think you're confusing things, Mr. 16 Turk. 17 We have an ORO EBS message at about 2:20 in the 18 afternoon to evacuate Amesbury and Salisbury and shelter all 19 -the other areas. . 20 BY MR. FIERCE: 21 O Was that a predetermined PRA based on other than 22 ETE factors, Mr. Callendrello?
. 23 A (Callendrello) Just so it's clear. It was a 24 protective action recommendation made based on plant 25 conditions. So to that extent it was a predetermined PRA.
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REBUTTAL PANEL NO. 16 - CROSS 26927 1 There are other parameters that go into the PRA 2 decision-making, based on plant conditions, namely, which , 3 way is the wind blowing. 4 For that first PRA they did recommend the action - 5 based on plant conditions. I think at that point the wind . 6 was blowing straight out to sea, out to five miles in 7 Amesbury and Salisbury as well. 8 So that was part of the first protective action 9 recommendation that was issued by or at least passed on to 10 the governor by ORO. 11 Q But the second protective action recommendation 12 made by the ORO which I see was an EBS message 1603, in 13 other words, 4:03 in the afternoon, was to further evacuate 14 the area that had been previously shelters, the five to 15 ten-mile communities? ERFA E, in other words? 16 A (Callendrello) That's correct. 17 Q Was that an ETE that's the type that would be made 18 by referencing an ETE? , 19 MR. TURK: Is that an ETE that would be made? -l 20 MR. FIERCE: Was that a PRA that would be made by 21 referencing an ETE. 22 MR. TURK: Was it made with reference to ETEs? _ 23 THE WITNESS: (Callendrello) That PRA was not - 24 made utilizing ETEs. 25 What happened during the exercise was, the rad l l Heritage Reporting Corporation (202) 628-4888 _ - _ _ - . - -- --- _ -- - .u
REBUTTAL PANEL NO. 16 - CROSS 26928 1 health advisor had been monitoring meteorological forecasts 2 and meteorological conditions throughout the simulated 3 emergency. 4 As soon as the wind shift began they revised the 5 protective action recommendation to extend it into ERPA E. 6 At that point the protective action guides were not 7 projected to be exceeded. And as I recall, they were not 8 exceeded through the exercise. 9 It was a protective action recommendation based on 10 the direct observation of that wind shift occurring after l 11 the initial protective action recommendation. 12 BY MR. FIERCE: 13 Q Without reference to an ETE7 14 A (Callendrello) That's correct. 15 Q Why wasn't the dose calculation done as to the 16 SPMC procedures suggest? 17 A (Callendrello) It would have indicated that there 18 was no dose projected to affect ERPA E. At that point the 19 wind was still blowing out to sea. . 20 Q And projected the shift-around; correct? 21 A (Callendrello) And projected the shift-around. 22 Q And you could have perhaps projected arrival times
. 23 of the plumes?
24 A (Callendrello) That's correct. 25 However, at that point they had no indication as Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26929 1 to how fast the wind shift was or even how far the wind j 2 shift would go. 4 t 3 So the trigger point for that PRA was, the wind l ' 4 shift had started, let's extend the protective action - 5 recommendations, we feel it's the prudent thing to do. . 6 Q Gentlemen, after New Hampshire had closed its 7 beaches at approximately 11 o' clock, and then Massachusetts 8 closed its beaches at an hour and 24 minutes later at 12:25! 9 after that point during the exercise the protective action 10 decision-makers were left with a set of ETEs that had no 11 application to that situation; correct? 12 Because the planning basis was substantially 13 different than that? 14 MR. TURK: I'm going to object, Your Honor. I 15 think the question is mixing what was in the planning basis 16 and what has applicability to the actual criberia that went 17 into a particular PRA. 18 He's confusing the principles and what exists in 19 the planning basis to be considered with the actual factors 20 that affected a particular PRA being issued at the time they f i 21 were issued. - 22 MR. FIERCE: There's the poison in the well again. 23 MR. TURK: An ETE would have applicability whether . 24 it was relied upon as a basis for giving the PRAs is 25 different from whether it has any applicability whatsoever. Heritage Reporting Corporation (202) 628-4888
J l
- REBUTTAL PANEL:NO. 16 - CROSS 26930-
. /- ~ ' = 1 JUDGE SMITH: I_. guess I don't understand.
N Well, Mr. Turk is just_trying to' N.J '2 MR. FIERCE: 3 confuse the. situation. 4- MR. TURK: Obviously, Your Honor -- 5- MR .' FIERCE: If the ETEs that they were left 6 '- :with-'-- 7- MR. TURK: -- if I'm confused I think there must 8 be some reason.' 9 I think the question mixes whether or not an ETE 10 has. applicability in principle with the question of whether 11- a particular PRA was made based upon that as a guiding. 12 principle at the particular time the PRA was made.
'13- Let him ask both questions, but let him ask them
~ 14 separately.
\
\ 15 .BY MR. FIERCE:
16 O' The ETEs those decision-makers were left with, 17- after those two beach closings, had no relevance to the 18 situation they were facing; correct?
.19 A (Callendrello) No. .
20 See, where I disagree with that statement is, it
- '21. has some relevance. The sensitivity of the evacuation time 22 estimates, as Mr. Lieberman indicated, is such that they
. 23 would be reduced the longer the time has elapsed between the 24 beach closure and the order to evacuate.
25 Looking at page 10-18 of Volume 6 it's about two-4 i g Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 26931 1 hours if you would extend the time from beach closure to 2 order to evacuate by three-hours; the total evacuation time . 3 would decrease by about two-hours. 4 The ETEs would still be applicable. They may not - 5 be identical to what you would get from the scenario that * \ 6 was the basis for the evacuation time estimates that are 7 included in IP-2.5. I think they would still be applicable. 8 It happened in this scenario, they were not 9 utilized and did not need to be utilized. And they would 10 have overstated the actual evacuation time in the scenario 11 as it unfolded during the exercise. l 12 Q How would -- strike that. 13 Let's assume a protective action decision-maker 14 wanted to take a look at the dose calculation which is, why 15 the SPMC provides evacuation times; correct? 16 A (Callendrello) That's correct. 17 To examine the dose savings of sheltering versus 18 evacuation. 19 Q And that decision-maker wanted to make that . 20 calculation at -- let's pick midday, 2 o' clock on the 21 afternoon of that exercise. What ETE would he use in the - 22 work sheets that are provided in the SPMC at Implementing . 23 Procedure 2.5, Attachment 37 - 24 A (Callendrello) He would use the ETE from 25 Attachment 4 to IP-2.5. And depending on the region of Heritage Reporting Corporation (202) 628-4888
REBI' ITAL' PANEL NO. 16'- CROSS 26932
? )- R ll interest,-whether it was'out to five miles or ten miles,
\y < l1 '2 would'use the appropriate scenario.- If it was summer 3 weekend midday it would be the first set of numbers that are 4 ' listed in that Attachment 4.
=5- -Q. Assuming we're back at the exercise. It's -- I 6- forget what~ June'28th was, a' Tuesday. It's a Tuesday in 7 June in the week before the 4th of July weekend. It's a 8 -weekday, it's midday, it's good weather; would that be the 9 scenario 3 ETE?
10 A' (Callendrello) Yes, that would be the third
-11 scenario listed.
12- Q. .You're telling me that at that point in time, 13 2 o' clock, with the exercise events in~ progress as they were 1<4 the work sheet would contain - .would be filled out such 15 'that on line 8 where it says: " Evacuation time from 16- Attachment 3," the two numbers listed here in your 17 Attachment-D,'the most current ETEs. In other words, for 18' ~ Region 8, five-hours; and Region 13,.six-hours would be 19' written in? .
- 20. A (Callendrello) Yes, that's correct.
21 Q. But those. protective action decision-makers would-22 know that those numbers come from a planning basis which e 23 assumes that New Hampshire would be closing its beaches a i 24 mere 20 -- New Hampshire and Massachusetts would be closing 25 beaches simultaneously, not what had happened here where p Heritage Reporting Corporation g N (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26933 1 hours had passed since New Hampshire had closed its beaches 2 -and more than an hour had passed since Massachusetts had . 3 closed its becahes. 4 And you're telling ma you all know that the ETEs 5 would be substantially shorter? , 6 They would still use these numbers? 7 I don't want to quarrel with you, I just want to B be clear that that's -- l 9 A (callendrello) They would use those numbers. 10 Just to give you an idea -- 11 Q In the work sheet? 12 A (Callendrello) Yes, in the work sheet. 13 Just to give you an idea of the range of times, 14 take a look at probably what is the extreme case of reducing 15 the beach population and that is, scenario 8 which is off-16 season, midweek evening. Essentially just residents. 17 It's an hour and a half, roughly, less than the 18 evacuation times for the summer midweek midday scenario. 19 There's not a tremendous amount of variability in those . 20 times. And certainly, not the kind of variability that 21 would, in my opinion, affect the protective action 22 recommendation for many scenarios. I mean, I could conceive 23 of a scenario, but certainly wouldn't be the rule. 24 Q So you don't think it makes a difference if a2 ETE 25 is an hour and a half or two-hours off for many scenarios? Deritage Reporting Corporation (202) 628-4888
>t REBUTTAL PANEL NO. 16'- CROSS 26934 j,-w 1: 'A (Callendrello) In some scenario it could' affect' IkN I think 2 the' choice of_ protective action recommendations.
.s: ,
3 those are'very few in number. ~ l4 ~I think, for the bulk of accident < sequences, 5 ' protective actions.would have been ordered earlier based on 6 plant. conditions. 7 'Q We're not talking plant conditions; we're only-
-8. talking scenarios where ETEs'would be of assistance.
?9' I understand that.
10 A (Callendrello) Given that I think there are very 11'- few scenarios that that difference in evacuation times would 12' affect'the outcome in the choice of a protective action 13 recommendation.
/~5 -
14 Q Do you have any idea what the actual ETE for ERPA 15 E would have likely been at 2 o' clock in the afternoon on 16' ' day 1 of the exercise? 17 A (Callendrello) I don't understand the question. 18 I don't know what the actual ETE is under any 19 circumstance until somebody actually evacuates and times it. , 20 I can tell you what the model projects as an
~-
21 evacuation time. estimate and what we would use in 22 calculating the dose savings of evacuation versus
.- 23 sheltering.
24 In the case of the scenario we would have used, at 25- least I would have used, five-hours and 15 minutes for a f Heritage Reperting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 26935 1 Region 8 calculation out to five miles. And five-hours and 2 40 minutes for the 10-mile region. Because those were the 3 numbers that were in the procedure at the time of the 4 exercise. - 5 Mr. Lieberman has since calculated those and those . 6 numbers are revised and are contained in Attachment D to our 7 testimony. 8 Q Mr. Callendrello, do you know what numbers the 9 METPAC model would have been using at that point, ETE 10 numbers? 11 As a matter of fact, I know that they had an older 12 set of STEs in them even then the ones that were in the SPMC 13 at the time. 14 But assuming they had the most up-to-date accurate 15 set of ETEs, does the METPAC model do what you did, select 16 the scenario -- look for the scenaric, day, week, and 17 weather, and pick that ETE without discounting it for the 18 fact that the New Hampshire beaches had closed much earlier 19 and the Massachusetts beaches had closed an hour and a half 20 or two earlier? 21 Does it just pick the number that's in the ETE and - 22 plug that into its calculations; do you know? 23 A (callendrello) Well, there's a couple of . , 24 questions built into that. l 25 I'm going to answer the last one and it is: what
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l REBUTTAL PANEL NO. 16 - CROSS 26936 1 does the.METPAC model pick for an ETE? 2 You' re quite correct, it's got at present ETEs 3 that have come from an earlier study, a 1984 study and not the current KLD evacuation time estimates. 4 5 METPAC as it currently uses ETEs selects one based 6 on the scenario, time of season;. day of week; time of day; 7 and weather. And selects an ETE based on those parameters. 8 It does not adjust them for differentials or deviations from 9 those scenarios. 10 11 12 13 fQ 14
;b) 15 16 17 18 19 .
20 21 22
- 23 24 25 )
O Heritage Reporting Corporation l( ') (202) 628-4888 l 1
REBUTTAL PANEL NO. 16 - CROSS 26937 1 Q So during the exercise, the Massachusetts 2 decisionmakers and also the METPAC model would have been . 3 utilizing a set of ETEs that were not designed for the 4 circumstances they were facing that day, correct? - 1 5 A (callendrello) They would be using the ETEs ,j 6 designed for the scenario described in the ETE. ) 7 Q And not for the -- 8 A (Callendrello) I don't think it's possible or 9 practical or prudent to come up with an infinite number of 10 evacuation time estimates for every conceivable 11 circumstance. 12 Q Nor do I. 13 But isn't it practical and prudent and all of 14 those terms to use a planning basis for an ETE study which 15 is more likely to have some relevance to the situation 16 facing the decision-makers than less relevance? 17 A (Callendrello) No, I don't think so. 18 What you've postulated is we should have had an 19 ETE for the scenario that occurred during the exercise. 20 I can come up with -- 21 Q No, I'm not postulating that at all. 22 I'm saying more relevance than less relevance. . 23 Shouldn't tuo planning casia he one that at least - 24 is likely to have some rolevance to the situation facing 25 deci.sionmakers? Heritage Reporting Corporation (202) 628-4888
1, REBUTTAL PANEL NO. 16 - CROSS 26938 ) fy--A 1 We know we are not' going to have a situation where
-4 3 2 beach closing occurs simultaneously at an alert.
3 We are very likely going to be facing situations
*- 4. where we'have got a situation where New Hampshire closes its L
5 beaches first, and then Massachusetts-closes its beaches 6 some time later, and that factor is not reflected in the set 7 of'ETEs that.we have with that planning basis, correct? 8 MR. LEMALD: Could we have what factor isn't -- 9 you've got about a dozen factors, and then your question 10 ends up with what factor? 11 I object to the form of the quest.lon. I think 12; it's confusing and misleading. 13 JUDGE SMITH: Well, state what factor.
,/~'\ 14 MR. FIERCE: I am going to have to repeat the 'v 15 question and it may not come out the same way.
16- BY MR. FIERCE: 17 Q You've got a situation where Massachusetts is not 18 going to be closing its beaches at an alert. And we've got 19 a common situation. It was faced in the exercise where New . 20 Hampshire closed its beaches almost an hour and a half anead 21 of Massachusetts closing its beaches. .
}
22 In those circumstances, that planning basis that i
- 23 -is used for these ETEs, which assumes a simultaneous beach I
24 closing, has produced a set of ETEs which are not as 25 relevant to the decisicnmaker's task as a set of ETEs that g Heritage Reporting Corporation X (202) 628-4888
l 1 REBUTTAL PANEL NO. 16 - CROSS 26939 1 assumed a staged beach closing. 2 A (Callendrello) No , I don't agree with that. 3 Implicit in your question is that every accident 4 will be an escalating emergency. I can't accept that. - 5 I think that Mr. Lieberman has chosen a scenario , f 6 that is probably a faster one that we would normally face, 7 but one which, I think, places a -- or is a good indicator 8 of the kind of stress you would put on the evacuation 9 network and provides a reasonable estimate of the times that 10 we should use to make a protective action recommendation 11 when we are comparing those dose savings. 12 To say that every accident scenario would start 13 out in an unusual event and go to an alert and New Hampshire 14 would close their beaches and then escalate to a site area 15 emergency, I can't accept that as being the only type of 16 scenario we should plan for. 17 Q Would you accept that there at least ought to be a 18 set ^f sensitivity runs showing the impact on Massachusetts 19 ETEs of different times for the New Hampshire beach closure 20 relative to the Mass beach closure, so decisionmakers would I
- 1 21 have semo basis fore assessing where they actually are?
22 A (Callendrello) In my looking at the data and as 23 one. of the people who has to use this in the ORO -( f 24 organization, I wouldn't find that heloful, i 25 The range of times, as I indicated for the Heritage Reporting Corporation (202) 628-4888 O, 1 _ _ - - - )
REBUTTAL' PANEL NO. 16 - CROSS 26940
;1 scenario we,were talking about, if you-look at what are
/-~{
'/ _ 2' left, .the residual pecple,'the residents, it's three and a 3' half,' roughly. When you add in the summer transients, it's 4 five hours and 15 minutes.
5- That's not a very large range, and I just can't 6 conceive of that:affecting -- I shouldn't-say.that. 7 I can conceive of a PAR that could be affected, 8 but it would be one of a very small number. 9 : Q. The sirens in Massachusetts are sent from their 10 staging areas to their acoustic locations at the alert 11 stage, correct, Mr. Callendrello? 12 Not your field? 13 A_ (Ca11endre11o) It is my field.
/}. :14 And I know they are sent at.the alert, and I'm 15 trying to recall whether they are sent'at the unusual event
'16 6r not.
17 I don't know how long we're going to. I don't 18 recall whether they are sent at the unusual event. I can 19 check that. I know they are sent at the alert. I 20 Q Well, you can check this and let me know after j
' ;21 lunch if you disagreu.
22 But let's assume that they are sent no socnar than
. 23 the alert, but they are sent at the alert.
24 A (Callendrello) Okay. 25' Q Juul we know you are attempting to meet the 15-Heritage Reporting Corporation
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i REBUTTAL PANEL NO. 16 - CROSS 26941 L 1 minute standard. 2 ' But to get to the Massachusetts beaches and sound Ojl I 3 the sirens to announce a beach closure, it's the Applicants' 4 position that can be done in 15 minutes from the alert? -
)
l 5 A (Callendrello) We do not order or recommend to . l 6 the governor that he order beach closure at the alert level. 7 It's not until the site area emergency level. 'l 8 Q Excuse me. The site area, right. J 9 If we have the planning basis accident that is 10 used for the ETE study, which has a simultaneous 3 1ert and j i 11 site area emergency, you would be able to meet -- within 15 ) 12 minutes get out to the Massachusetts beaches with the 13 sirens, sound the sirens to announce, a beach closure? 14 A (Callendrello) Yes, that's the design basis of 15 the VANS system, the mobile alert and notification system. 16 I shouldn't say mobile. 17 The VANS system which is the system of fixed f 18 sirens mounted on trucks. l 19 Q I know this is a small point, Mr. Lieberman.
- i l
20 The planning basis assumed that people on the i i 1 21 Massachusetts beaches would actually begin to move cut of i 22 the beach areas within about five minutes of the site crea
)
23 emergency, corr e':t ? I 24 A (Lieberman) Other than those already in their
- i 25 cars. j Heritage Reporting Corporation (202) 628-4888
J i REBUTTAL PANEL NO. 16 - CROSS 26942 ] r~~Ni 1 Q Yes.
\ )
'/
2 A (Lieberman) That's correct. 3 Q So there is a 10-minute difference here, correct, 4 between the assumption in the planning basis and in fact the ! 5 capability of the ORO organization in the planning basis 6 accident?
~
7 It's not a lot of time, I know. It's 10 minutes. 8 A (Lieberman) I don't follow that. 9 Q If the site area emergency is coinciding with an 10 alert, which is what your planning basis is for your ETEs, 11 it will take your sirens, you believe you can get them out 12 there in 15 minutes, sennd the sirens to notify the 13 population of the beach closing. . [}
\ /
14 Itr . Lieberman's ETEs are based on a planning basis 15 which assumes that within five minutes after that site area 16 ' emergency people are in their cars and moving. 17 If I'm wrong, please help me. 18 MR. TURK: What's the question? 19 MR. FIERCE: Isn't thore a -- . 20 MR. 'IURK : 1 mee.n every question is a paragraph, 21 BY MR. FIERCE: 32 O Doesn't that result in a 10-minute differential 23 Setween the ETE times as calculated and the ETE times as can 24 be achieved? 25 It's a small time, I agree. im Heritage Reporting Corporation (N - (202) G28-4888 L_______
REBUTTAL PANEL NO. 16
- CROSS 26943 1 A (Callendrello) I don't know if that follows. Mr.
2 Lieberman is certainly the expert on the ETEs. 3 But with your scenario, we' re talking only about 4 the Massachusetts portion. There are sirena, there are .- 5 fixed sirens in place in the New Hampshire portion. And as 6 I recall from testimony back in New Hampshire, those beaches 7 . load up the networks early on. And in fact, as we've 8 testified here, those are the crlhical paths in the summer 9 evacuation scenario. 10 So I don't know whether that would affect overall 11 ETEs or not. But I'll defer to Mr. Lieberman on that. 12 Q Well, I'm also only focusing now on the 13 Massachusetts ETEs. 14 Massachusetts ETEs are going to be off by 10 15 minutes. 16 - MR. TURK: Why? 17 You are saying there is no prior alert, that the 18 alert and the SAE are simultaneous. In effect, you never 19 had an alert. You are going to SAZ immediately. So both 2D New Hampshire and Massachusetts beaches are being closed at 21 the same time, or are being recommended to be closed at the . 22 same time. 23 BY MR. FIERCE: 24 Q Except that the Massachusetts beacher have nobile 25 sirens that have to run out to them to notify them. That i Heritage Reporting Corporation , (202) 628-4888 I i i
REBUTTAL PANEL NO. 16 - CROSS 26944 1 takes approximately 15 minutes as opposed to the fixed 9' . 2 sirens in New Hampshire which, in fact, do the PA mode, 3 instantly telling people that there is a beach closure.
. 4 When the sirens sound in Massachusetts, the people 5 still have to turn on their EBS messages and hear a message.
6 So, in effect, it may be longer than a 10-minute 7 differential. It may be a 12 or 13-minute differential. l 8 But there is that differential, is there not? j 9 That's my question. 10 (Witnesses confer. ) 11 A (Lieberman) It just shifts the origin of the 12 evacuating movements 10 minutes relative to.the site area 13 emergency. 14 Q I'm not sure what that means. 9 15 It shifts the -- what did you say again? 16 - A (Lieberman) What we say is that the beach area 17 folk start their evacuation 25 minutes before the OTE. The 18 other details aren't important from my perspective. There 19 is a 25-minute -- 20 Q They are notified 25 minutes.
- 21 A (Lieberman) They are notified.
7.2 Q And they actually start to move out within about
. 23 20 minutes of the o'.2, correct ?
24 A (Lieberman) Those who are on the beach. 25 Q Yes. 9 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26945 1 A (Lieberman) The people who are behind the wheels 2 of-the moving cars, these 1400. 3 0 Continue to move. 4 A (Lieberman) They take off immediately. . 5 Q That's what is modeled. 6 A (Lieberman) Right. That's correct. 7 Q And in fact in Massachusetts, the beach vehicles, 8 other than the ones that are in motion, probably won't be 9 moving until, well, the notification occurs, which is going 10 to be again, I think, probably 12 or 13 minutes after the 11 site area emergency. And then you have a period of perhaps 12 five minutes before any significant number of them get into 13 their cars and are moving on the roads, correct? 14 A (Lieberman) That's right. 15 Now you realize that you are narrowing the time 16 between the start of the beach are evacuation and the time 17 the general population evacuates. 18 Q That's right. 19 A (Lieberman) Okay. 20 Q That's right. 21 A (Lieberman) So I'm not sure what the net effect . 22 is. 23 Q You haven't modeled that? . 24 A (Lioberman) No. ! 25 I guess there is one more thing I should point Heritage Reporting Corporation (202) 628-4888
l REBUTTAL PANEL NO. 16 - CROSS 26946 js 1 out. j i )
\m/ J No, I, guess not.
3 0 I was going to move on to the next section in the
- 4 testimony. It's on traffic control on page 35.
5 JUDGE SMITH: Mr. Fierce, may I interrupt here for 6 a' moment? I 7 MR. FIERCE: Sure. -l 8 JUDGE SMITH: You worked out your own limitation 9 to the cross-examination -- l 10 MR. FIERCE: Yes. I' 11 JUDGE SMITH: -- with the parties and with the 12 approval of the Board. And as I look at your cross-13 examination plan, I want to point out to you we're going to i f r~'s 1 14 hold you to it. But I just can't see how you are going to i Y/ 15 make it. I 16 MR. FIERCE: I'm going to try to move faster. i 17 That's how I'm going to do it, Your Honor. 18 JUDGE SMITH: Well, you are moving faster and we 19 noticed yesterday, and noticed with apprcval But I'm still 20 concerned that you've got a lot of work to do.
. 21 MR. FIERCE: I know. I find myself biting my 22 tongue wanting to ask another question on a particular item,
. 23 because I know I want to move on.
24 BY MR. FIERCE:
~
25 Q The traffic guides, gentlemen, are assumed to I O ,[ Heritage Reporting Corporation ! \_ (202) 628-4888
26947 REBUTTAL PANEL NO. 16 - CROSS f it sr.ys here, as 1 implement the traffic control strategies, 2 specified in the SPMC. , 3 As I read that statement, gentlemen, implicit in 4 it, and I'm asking if this is true, is the assumption that 5 these ORO traffic guides can facilitate movements just as . 6 efficiently as police officers. 7 Is that your position? 8 A (Callendrello) The question is, implicit in the 9 traffic control point diagrams? 10 Q For ETE purposes, is the assumption here that the 11 ORO traffic guides are moving the traffic just as 12 efficiently as police would? 13 A (Lieberman) I think I've said this before. 14 We don't take any credit in terms of reducing I hope you 15 capacity because there are guides there. 16 understand that. 17 Traffic performs at the same discharge rates 10 without guides as they would with guides at most locations. 19 At some locations, we have penalized the evacuation And whea the guides 20 movements when there are guides absent. 21 arriva, than we remove those penalties. 22 And when I say " penalties", I mean blockage . 23 factors which reduce the rate of flow of evacuees at these 24 locations. 25 Q Is that something different than what happens when Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL'NO. 16 -' CROSS 26946 ) i.
;. p ! 1' out. ' '/!
El_ 2' No , I, guess not.
'3 Q I was.. going to move-on to the next section in the )i
. 4: testimony. It's on traffic control on page 35.
5 JUDGE SMITH: Mr. Fierce, may I interrupt here for 6 a' moment? 7 MR. FIERCE: Sure. 8 JUDGE SMITH: You worked out your own limitation 9 to the cross-examination -- 10 MR. FIERCE: Yes. , j 11 JUDGE SMITH: -- with the parties and with the 12 approval.of the Board. And as I look at your cross-13 examination plan, I want to point out to you we're going to f 14 hold you to it. But I just can't see how you are going.to i' 15- make it. ; 16 MR. FIERCE: I'm going to try to move faster. 17 That's how I'm going to do it, Your Honor. 18 JUDGE SMITH: Well, you are moving faster and we 19 noticed yesterday, and noticed with approval. But I'm still 20 concerned that you've got a lot of work to do. e 21 MR. FIERCE: I know. I find myself biting my i ~ 22 tongue wanting to ask another question on a particular item,
. 23 because I know I want to move on. 3 1
24 BY MR. FIERCE: 25 Q The traffic guides, gentlemen, are assumed to j i O Heritage Reporting (202) 628-4888 Corporation j l i l 4 m_-______.m ______,_____m._.__._m . _ _ _ _ _ _ , . _ . _ . _ _ , , _ . , _ _ _ _ _ _ _ _ , _ . , _ _ _ _ _ _ _ _ , . _ _ _ _ _ _ _ _ _ _ _ _ _ ,_ _ _ _ _ _ _ _ __ __ _ }
REBUTTAL PANEL NO. 16 - CROSS 26947 1 implement the traffic control strategies, it says here, as 2 specified in the SPMC. 4 3 As I read that statement, gentlemen, implicit in 4 it, and I'm asking if this is true, is the assumption that . 5 these ORO traffic guides can facilitate movements just as 6 efficiently as police officers. 7 Is that your position? 8 A (Callendrello) The question is, implicit in the 9 traffic control point diagrams? 10 Q For ETE purposes, is the assumption here that the 11 ORO traffic guides are moving the traffic just as 12 efficiently as police would? 13 A (Lieberman) I think I've said this before. 14 We don't take any credit in terms of reducing 15 capacity because there are guides there. I hope you 16 understand that. 17 Traffic performs at the same discharge rates 18 without guides as they would with guides at most locations, 19 At some, locations, we have penalized the evacuation 20 movements v. hen there are guides abrent. And when the guidec 21 arrive, then we remove those penalties. 22 And when I say "ponalties", I mean b.icekage 23 facters which reduce the rate of ficw of ovacuees at thene 24 locations. I 25 Q Is that something different than what happens when 1 Heritage Reporting Corporation (202) 628-4888 l 1 i _ _ _ _ . . _ _ _ _ _ _ _ l
x REBUTTAL PANEL NO. 16 - CROSS 26948-
./ g . l'- you enhance capacity at a given intersection?
( V. 2 .A- (Lieberman) Yes. 1 3 It's a form of enhancement, but at a much lower 4 level. 5 Q And the basis for that is what, that the traffic p-6 guide'a presence will enhance more efficient flow?
-7 A' (Lieberman) That's right, a more orderly response 8 to traffic conditions.
9 10 11 12
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( 15 16 - 17 18 -. 19 -
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REBUTTAL PANEL NO. 16 - CROSS 26949 1 A (Lieberman) As I said, with regards to absence 2 we already impose some penalties at key intersections. 3 I think I may have offered an example of that in 4 here. . 5 (Witnesses confer.) . 6 THE WITNESS: (Lieberman) Going to your question 7 as to whether there's a distinction between the modeling to 8 represent that there are ORO guides out there rather than 9 policemen, no, we haven't done that because we don't see a 10 need to do it. 11 And also, because we rather expect at some point 12 ,the local police will, in fact, be there. So I just did not 13 do that. ,, 14 BY MR. FIERCE: 15 Q So when you remove this blockage factor that you 16 mentioned it would be removed entirely for the ORO traffic 17 guides as well as state police? 18 A (Lieberman) ' Assuming that the state police don't J 19 show up, which I don't think follows. )
.)
20 Q It sounds to me like you are essentially giving 21 them equal ability to faci.litate that efficient traffic flow . l
- 22. at that intersection? j 23 A (Lieberr.an) A more efficient traffic flow than if . j 24 there were nc guides there.
25 Q You don't have any basis, in fact, for making that l l l Heritage Reporting Corporation ! (202) 628-4888 l l l l
REBUTTAL PANEL NO. 16 - CROSS 26950 1 assumption, do you? 2 A (Lieberman) I have no basis for not making it. 3 Q If, in fact, the ORO traffic guides at those
. 4 intersections where that blockage factor were applied were, 5 say, 10 percent less efficient than state police; then along 6 those roads anyway it would have a 10 percent impact and if 7 that turned out to be a critical link it could be a 10 -
8 percent impact on the ETE; correct? 9 A (Lieberman) No, that's totally incorrect. 10 Q Can you explain: traffic is flowing at 90 percent 11 of the efficiency with which it was flowing in your model, 12 why that wouldn't have a 10 percent impact on ETEs on a 13 critical path? 14 JUDGE COLE: Do you maintain your objection, Mr. 9 15 Lewald? 16 - MR. LEWALD: I maintain the objection of the 17 hypothetical asking the witnesses. That particular question 18 as to whether or not -- I gather, whether the linear 19 relationship between the efficiency or a nonefficiency of an 20 ORO guide as compared with a uniformr.d officer or state
. 21 police officer.
22 MR. FIERCE: I think that's exactly a relevant 23 question. 24 MR. LENALD: I think we've already covered that 25 ground. This is, in essence, what I celieve he's asking. O Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26951 ] 1 JUDGE SMITH: You mean this is repetition or an i 2 excluded subject matter? 3 MR. LEWALD: I think it was excluded, this whole i i 4 line as to the difference in the efficiency or the .] 5 capabilities or whatever of the uniform officer as against J 6 an ORO traffic guide. ) 7 And what this question asks is a question as to 8 whether or not the -- assuming there is a difference -- 9 whether it's linear into the conclusions that he's trying to 10 get from the witnesses. 11 MR. FIERCE: Well, it's certainly a relevant 12 issue. In fact, we've got a whole issue regarding the ORO 13 training for traffic guides to discuss this very point. 14 JUDGE SMITH: Yes. 15 I want to distinguish between the excluded subject 16 matter which is the public's reaction to uniformed sworn 17 police officers compared to civilian OROs, that subject 18 matter is excluded. 19 But the efficacy of their actual performance of 20 their duties has not been excluded, to my memory. 21 MR. LEWALD: I thought that was the other side of - 22 the coin, Your Honor? 23 JUDGE SMITH: No , I don't believe so. . 24 You have to be more specific in reminding me. 25 MR. FIERCE: I think Your Honor is exactly Heritage Reporting Corporation (202) 628-4888 9; 1
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REBUTTAL' PANEL NO. 16'- CROSS 26952: 1 correct. il h 2 JUDGE SMITH: The exclusion that I recall was E MEEF ,. 4 3 simply the fact of the uniform and the fact that the traffic guide wasn't a sworn police officer apparent to th.e public;
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l . -4 5 'not the relative. competence. 6 MR. LEWALD: I didn't appreciate the difference, 7 Your Honor. 8 JUDGE COLE: I don't understand the question, Mr. I 9 Fierce. 10 You said if an nonuniformed traffic guide is 10 f 11 percent less efficient'than a policeman or a professional i 12 routing the traffic,.would that manifest itself in a 10 13: percent reduction in the traffic passing by? jrN g 14 I just don't understand that?
\'- '
1-15 MR. FIERCE: That's what I'm -- the way I want to 1 '
. 16 pose it. !
i 17 JUDGE COLE: If you're posing a hypothetical, I
.)
18' don't know what the question is. You say, it depends on how 1 19 you measure his efficiency. If you're going to measure it 4 20 in terms of letting cars by --
. 21 MR. FIERCE: That's exactly what I'm talking 22 about. l 2
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.- 23 JUDGE COLE: Then he's going to assume that that's j 24 the case; then what's the question?
4 25 MR. FIERCE: Doesn't that have a direct Heritage Reporting Corporation
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i l REBUTTAL PRNEL NO. 16 - CROSS 26953 l 1 relationship on the ETE. 2 JUDGE EMITH: If he assumes that -- 1 3 JUDGE COLE: If he assumes that -- { 4 MR. FIERCE: Yes. . 5 JUDGE COLE: -- he's only going to let 90 percent 6 of the cars go by that a professional policeman would? 7 MR. FIERCE: It's not "let by." 8 But the skills he has in terms of enhancing the t 9 flow, enhancing and facilitating the flow, he's not able to 10 do it as well -- let me go back a couple of steps and ask 11 Mr. Lieberman a couple of other questione. 12 13 14 15 16 17 18 19 20 21 - 22 23 - 24 25 Heritage Reporting Corporation .. . (202) 628-4888 . J I l - - - _ . __ 1
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" ,' REBUTTAL PANEL NO. 16 . CROSS 26954-BY MR. FIERCE:
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Os- :2 'Q'- The blockage factor.that we have, what is the size 3 of it relative to the volume of traffic-flow? 4 A (Lieberman) The blockage factor is expressed in
.5 terms of.a capacity reduction at certain locations.
15 Q And is it five percent or 10 percent? It's about -- it depends. 7 A (Lieberman)
- 8. At most locations it's about 10 percent. At 9 ' Salisbury Square it's greater. The absence of a traffic 10 guide has a greater effect on traffic movements through 11 Salisbury Square from the beach areas.
12 -Q You said, the absence of guides or the presence? 13- A (Lieberman) Right.
.p . 14 Q Absence?
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15 A (Lieberman) Absence of traffic guides has a 4 16 greater effect on the through-put of the evacuating traffic . 17 from the beach of 10 percent. 18 0 10 percent which way, up or down? 19 A (Lieberman) The blockage factor is higher than 10 } 20 percent which means that there's a greater reduction in 21 capacity due to the absence of a traffic guide at that 22 particular intersection.
. 23 C Do you know what the percentage is?
24 (Witness reviewing document.) 25 f Heritage Reporting (202) 628-4888 Corporation
REBUTTAL PANEL NO. 16 - CROSS 26955 1 BY MR. FIERCE: . 2 Q Perhaps all I need is a range. 3 Is it somewhere between 10 and 15, 15 and 20?
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4 A (Lieberman) It's 35 percent. 5 0 It's 35 percent? . 6 A (Lieberman) Yes. 7 That goes to the fact if you want an explanation 8 of that, it's a more complex square. 9 Q And what the model does when the guide shows up is 10 remove that blockage factor and the traffic then flows at 11 100 percent rather than 65 percent? 12 A (Lieberman) That's correct. 13 Q Okay. 14 A (Lieberman) 100 percent of the specified 15 capacity. 16 Q All right. 17 Now, let's assume an ORO guide shows up at that 18 location and is able to facilitate the traffic somewhat by 19 what he does or she, but doesn't get it up to 100 percent, 20 only gets it up to 90 percent. q 1 21 MP. . TURK: It might be useful to recall at this 22 point from the traffic management testimony thac Salisbury . 23 Square is a complicated set of intersections at which they - 1 24 are not simply using existing capacity but they are adding l 25 lanes of capacity, if I'm not mistaken. Heritage Reporting Corporation f I (202) 628-4888 1
REBUTTAL PANEL NO. 16 - CROSS 26956
, ~q 1 So when we're talking about 100 percent it's not i \
k -) m 2 100 percent of existing normal roadway capacity, as I 3 understand it, but it's 100 percent of this increased 4 capacity which is present through the use of the traffic 5 management devices. 6 MR. FIERCE: I don't disagree with that. 7 When we're talking these percentages we're talking 8 about ultimately what it gets up to in the model when we're 9 running these ETEs after the guides are present. That's J 10 what I mean by 100 percent. 11 MR. TURK: Just to be sure I'm not confusing the 12 record I would ask if the witnesses agree that that's the 13 case? That the 100 percent refers to this increased (~'i/ 14 capacity above normal. roadway capacity? N' 15 THE WITNESS: (Lieberman) Yes. 16 It's the capacity associated with the presence of 17 the traffic control policy there. 18 BY MR. FIERCE: - 19 Q But as I understand you earlier, this issue here 20 that we're discussing, this bicekage factor, is not a 21 capacity issue; it's a traffic efficiency / facilitate traffic 22 movement type issue; correct?
. 23 A (Lieberman) No, it is a capacity issue.
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I 24 Q Oh , so we are talking capacity here, on this one? i
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25 A (Lieberman) Blockage factors are applied to I i fO)
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i REBUTTAL PANEL NO. 16 - CROSS 26957 I 1 capacity, yes. 2 Q They're applied to capacity? ij 3 A (Lieberman) Yes, that's right. 4 As you know the traffic control policy there is to . j 5 set up cones in such a way as to facilitate the movement of . . 6 two-lanes of traffic plus traffic guides, of course. J 7 In the absence of this traffic management policy 8 the cars do, in fact, form two-lanes under heavy flow 9 conditions, but they don't do it nearly as efficiently as 10 they would if there are cones in place there with traffic 11 guides encouraging them and facilitating their movement in 12 an orderly fashion through that intersection. 13 So the 35 percent reflects the absence of this 14 capacity enhancing capability. 15 Q All right. 16 - I'm sorry that we got into Salisbury Square 17 because I really wanted to have you focus on one of those 18 intersections where the blockage factor was purely for 19 reasons of enhanced efficiency of the traffic flowing just 20 by the presence of the guide and not by his impler.entation 21 of a capacity enhancing strategy. 22 A (Lieberman) That's about 10 percent. 23 Q About 10 percent. . 24 A (Lieberman) And that's just a judgment call on my 25 part. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26958 s L ., '1 -Q All right. L l- x 2 Well,:let me'take one.that's about 10 percent. 3 JUDGE SMITH: Mr. Fierce, the Board proposes, we
. 4. want to give you as'much time as we can squeeze out of the 5 day.for. cross-examination. We propose that we take a
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p 6 somewhat' earlier lunch break, a shorter one, and beat the 7 crowd. 8 MR. FIERCE: Good idea. 9 JUDGE SMITH: Would this be a good time to give 10 you a break? 11 MR. FIERCE: Yes. 12 JUDGE SMITH: We'll take 45. minutes, return at 13 12:45. j's L 14 .(Whereupon, at 12:00 p.m. the hearing was recessed
\- / 15 to reconvene at 12:45 p.m., this same day Thursday, 16 June 22, 1989.) .
17 18 19 .. 20
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REBUTTAL PANEL NO. 16 - CROSS 26959 f 1 A E I E E,H Q Q H SEEEIQH l I 2 (12:47 p.m.) 3 JUDGE SMITH: Anytime you're ready, Mr. Fierce.
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4 MR. FIERCE: Thank you. 5 Whereupon,
- 6 ANTHONY M. CALLENDRELLO 7 EDWARD B. LIEBERMAN 8 having been previously duly sworn, resumed the witness stand 9 herein, and were examined and further testified as follows:
10 CROSS-EXAMINATION (Continued) 11 BY MR. FIERCE: 12 Q Good afternoon, Panel. 13 Perhaps I should ask if Mr. Lieberman has any 14 further information on those questions that hadn't been i 15 answered yet from this morning? 16 A (Lieberman) Yes, I do. 17 I just called in to the office, and this addresses 18 the question of -- I guess it addresses the first two 19 questions. On the sensitivity test you alluded to in the 20 testimony which said that when we added 2000 vehicles per 21 hour of external / externa.1 trips there was no change in the 22 ETE, I can give you the specifics on that. l 23 What we did was to input 6000 vehicles per hour . 24 for the first five minutes for the purposes of establishing ) 25 the initialization in each direction. 1 Heritage Reporting Corporation (202) 628-4888 i _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ - . _ _ _ _ d
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- ;a REBUTTAL FANEL..NO'. 16 - CROSS 26960 .
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);~i 11 Q 6000 in eachLdirection? l "/ \
kj -2 ;A (Lieberman)' That's right. f
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4 3- Then following --
*C i4 JUDGE SMITH: Wait a minute.
5-Did you say 6000 in each direction? 6 THE WITNESS: (Lieberman) Yes,' sir. L Now, the first five minutes - I have to explain ! 7
'8- 'this -- the-first five minutes is a dummy five minutes.
l ' 9 It's,what we use to initialize the network. We talked about
'10- .that in the past. .Put vehicles on the network before we 11 start-simulating.
I 12 So we used 6000 vehicles an hour to hasten the 13 whole process. That was.followed by 4400 vehicles per hour [.[~N 14 in each direction for one-hour and 25 minutes.
-15 BY MR. FIERCE:
16 - Q One-hour and 25 minutes? 17 A (Lieberman) Yes.
.18- Q Just to clarify, the initialization adding the 19 6000, they' re not dispersed over the entire network? .
20 A (Lieberman) No. 21 They' re on t.hs interutares. 22: Q They're on the interstates?
.. 23 A (Lieberman) Right.
24 0 So 4400 for one-hour and 25 minutes? 25 A (Lieberman) That's correct. j Heritage Reporting Corporation k
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REBUTTAL PANEL NO. 16 - CROSS 26961 1 And the ETE for Region 13, scenario 3 at that time 2 was 6, 10 for the region. 3 Q Okay. 4 A (Lieberman) Then we took that run and added 2000 - 5 vehicles per hour in each direction for a period of one- . 6 hour, which yielded the same ETE of 6, 10. 7 Q Which ETE is that? 8 A (Lieberman) That is Region 13, scenario 3 at that 9 time. 10 Q Thank you. 11 Just picking up briefly where we left off right 12 before lunch. 13 We are at one of these intersections where you do 14 have a blockage factor in place that imposes a 10 percent 15 blockage factor before the guide arrives. And the guide who 16 then arrives is an ORO guide who is not as efficient as a 17 police officer. 18 And, in fact, rather than getting the flow from 19 what, in effect, would be 90 percent up to 100 percent of 20 what the model would have it at the full staffing, he is
'1 21 able to get it up to 95 percent. -
22 And that then were to be a link on a c::itical 23 pathway, would that have a five percent affect on the ETE? . j 24 A (Lieberman) It could have. 25 Again, I can't give you - you state a hypothesis Heritage Reporting Corporation (202) 628-4888 _ _ - - - _ - - _ - - - _ .--- 1
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l l REBUTTAL! PANEL NO. 16 - CROSS .26962
- 1 with.which I; don't agree. .And you're also asserting that the~ difference.in efficiencies translates into having,
' V? - J2 3 essentially, this ORO guide has half the utility of a state
- 4' - police;fthat's what your. postulate implies.
5- Now, given that we walk along that path, it 16 - depends on whether the saturation flows extend over the 7- entire time and co forth, as.I described earlier. p 8 I:should also point to the fact that the 15 9: percent reduction factor also takes into account driver
' 10: uncertainty. .
i ll So what you're doing is superposing a purported-12 loss of efficiency or lesser efficiency on the part of the. 13 traffic' guides as being separate and distinct from the
- 14 accounting for driver uncertainty, which we do throughout
. 15- the process.
16 . Q Well, I am doing that.
- 17 A (Lieberman) I know you are; I just want to bring 18 that out.
19 Q Are you saying that the reduction factor would , l' 20 account for that as well, if that were to occur as a p
.. 21' separate factor?~ ;
22 A (Lieberman) I can't slice things to thut degree e
. 23 of refinement, and I don't think anyone can.
L 24 Q The reduction factor covers the whole eflect, the 25 ret effect? D' Heritage Reporting Corporation (202) 628-4888 l d' _____._._m.______-____________.___._________________________.____.~.._m-_ _ . _ . _ _ _ . ______.._____.__________________._____________.______.______.__._._.______m._..__.____.____m
d REBUTTAL PANEL NO. 16 - CROSS 26963 1 A (Lieberman) I don't compartmentalize 2 contributions to the effects that cause driver uncertainty. 3 Driver uncertainty is largely internal. It has to do with 4 the personality of the driver and his driving skills and so - 5 forth. . 6 I can't tell you to what extent a lesser 7 efficiency on the part of a traffic guide is going to 8 6nhance that driver uncertainty or not. 9 That's a postulate that you have made that I don't l 10 find persuasive. 11 Q I'm trying to determine whether your view is that 12 the inefficiency of a guide would translate only to a driver 13 uncertainty factor or whether there's a separate factor 14 there? 15 A (Lieberman) There's no -- 16 Q A driver could be certain of what he's doing, but 17 the guide is just not doing it very well to facilitate the 18 'tra f fic , couldn't that happen? 19 A (Lieberman) I don't think so. 20 Q I wanted to look at the rolling terrain issue you 21 have raised on page 36. 22 A (Callendrello) Mr. Fierce, just before you move 23 out. . 24 One thing I had committed to get you was an answer 25 on when VANS are deployed. And I've checked the procedures Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO. 16 - CROSS 26964 js 1J and they are deployed at the alert. They are notified at EI lD 2; .the; unusual event, but they are deployed'at the alert. D .. 3- Q' Thank you.
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4- On'this rolling terrain issue that's mentioned on 5 'page 36. As I understand it this was imposed -- this is a 6 capacity issue, certain type of roads that exist in'the EPZ 7' were given. capacities for rolling terrain and, in fact, they 8 probably can be characterized as not rolling terrain but 9 whatever you call them, flat roads? 10 A (Lieberman) Level terrain. 11 Q Level terrain. 12 I'm just wondering why that was done? 13 If we recognize that the roads are level, why was 14 the rolling terrain capacity applied in the first place? (r's
\ 15 A (Lieberman) The predominate number of roads in 16 the area satisfy the rolling terrain descriptor. There are 17 some in the coastal area which are flat; and I've indicated 18 that in the testimony. -
19 In considering the capacity estimates I felt that . 20 given the importance of these roads, I thought it would be 21 the prudent thing to do to assign the rolling terrain 22 capacity -- the capacities associated with rolling terrain
.. 23 throughout the EPZ, without trying to make a roadway-by-24 roadway distinction. Realizing that, if anything, it would 25 tend to raise the ETE slightly.
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- 11 'Q -- .Well, is'it-'an unneeded conservatism then-in the 34
,) 2 model?
N 3: A. (Lieberman)- .It'may be.
~~.- .4 JUDGE SMITH: It's unneeded for ETEs, but needed
- 5. 'in litigation.
n. 6 (Laughter) 7 MR. FIERCE: The rolling terrain litigation - 8 factor.
- 9. .BY.MR.. FIERCE:
- 10. O Let me ask you about TRAD.
11 The.next subject we come to here is traffic guide 12 mobilization on page 36 and it introduces the TRAD model to 13 us. The times that were used for traffic guide g 14
\ 15 staffing are the-times from the exercise, I believe you've 16 indicated previously; correct?
17 A (Lieberman) Yes. l
.18 Q Now, you've got a'no-staffing situation now in the -
l 19 model and a staffing situation as well. TRAD has allowed 20 that two-step calculation to be conducted.
. 21 I'm sorry, you're perhaps wanting to correct me.
22 A (Lieberman) Yes. L . 23 You use the term "model" in the singular. 24 Q As I explained before, I see the TRAD and the 25 I-DYNEV model working together to form a unit that, in my Heritage Reporting Corporation [ (202) 628-4888 (, l l L____-_-______-_____-_--_
[ REBUTTAL PANEL NO. 16 - CROSS 26966 l 1 1 mind, I'm briefing calling "the model." 2 A (Lieberman) Then it's necessary for me to correct 3 you on that. 4 Q Okay. 5 A (Lieberman) There are two separate and distinct 6 applications of the TRAD model, which are quasi study 7 models, as I've described previously. 8 The simulation model, however, represents the 9 passage of time explicitly. And for the simulation model j 10 then the staged arrival of the traffic guides are specified 11 explicitly input stream. 12 So you don't have, quote, "a two phase," end 13 quote, representation of the traffic environment. You have 14 a " multi-phase" representation of the environment which 15 reflects the arrival of some guides at a given point in time 16 at some locations, and at a later time some guides at other 17 locations and so forth. i 18 Q There are a couple of intersections I'm concerned 19 about, and I apologize. This is a question that was on the 20 next page and I wish I had asked you this before lunch 21 because you could have looked these up. - 22 But we've already discussed the turn percentages 23 at I-95 and Route 110, so I won't go back to that. . 24 But at Salisbury Square the turn percentages 25 before the guides arrive and then after all of them arrive, Heritage Reporting Corporation (202) 628-4888
i 1 REDUTTAL PANEL NO. 16 - CROSS 26967 I o 1 is that handy? f-( 2
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REBUTTAL PANEL NO. 16 - CROSS 26968 1 A (Lieberman) (Conti.aued) You'll have to give me 2 a few minutes to dig it out, but it'a in there. 3 You want it before the guides and after the 4 guides? .- 5 Q And let me just give you the other one I'm 6 interested in, which is Route 286. It crosses Route 1. 7 A (Lieberman) Which route is that? 8 Q Route 286, before the guides and after the guides. 9 I'm interested in how the model now deals with those two 10 situations. 11 Do you think it's just going to take a minute? 12 A (Lieberman) Well, not for both of them. 13 Q Why don't we see, if we're going to have a break, 14 if I'm going to go through the break with the Panel. If l 15 not, maybe we can take this up at the very end, okay? 16 A (Lieberman) Fine. 17 Q Now, you outline the steps here on the next few 18 page. And in Steps 1 a'nd 2, I'm interested in knowing l l 19 whether the selection of the candidate destination nodes . 20 again was always consistent with the reception center 21 destinations for the town of origin or not. . l 22 And I think that's what you are going to tell me, 23 but let me verify that. . 24 A (Lieberman) Well, they are not designed to be 25 inconsistent, certainly. Heritage Reporting Corporation (202) 628-4888 l s J
REBUTTAL PANEL NO. 16 - CROSS 26969 1 But going back to the statements I made yesterday, ji'
! 2 the primary motivation of evacuees is to leave the area.
l 1 l 3 And what I do is for each origin node, given the absence of l l *
. 4 guides, I identify the most attractive destination nodes 5 which are defined by the intersections of outbound paths 6 with the EPZ boundary.
7 For that origin, in other words, I trace visually . 8 the various paths which are available to the evacuees from 9 each origin point, identify the associated destination 10 points and specify those for the TRAD model. 11 Keep in mind that we do not specify how many from 12 that origin node goes to each member of this set of 13 destination notes. That's something that's done by the 14 model, by merely defined destination nodes. 15 For example, people who leave from Salisbury Beach 16 are not assigned as a candidate node the bridge crossing 17 into Maine, because clearly that's a path that would not be 18 appealing to people who want to move away from the Seabrook 19 Station. 20 That set of destination nodes for a given origin
. 21 is generally, but not always, larger in number. That is, 22 there are more choices available to them in the absence of 23 guides because, to a degree, the guides restrict somewhat or 24 discourage, I should say, some paths which are physically 25 available. And this is done for each node in the system.
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1 1 I REBUTTAL PANEL NO. 16 - CROSS 26970 1 By "each node', I mean each origin node. 2 Q And as we've discussed before, TRAD then, using 3 these equilibrium principles, will attempt to optimize the 4 routing selected to those candidate destination nodes? .- 5 A (Lieberman) Right. It tries to represent the 6 behavioral processes of the evacuees consistent with the
- 7. motivation we've discussed earlier.
8 JUDGE McCOLLOM: Isn't it true that " optimize" is 9 not a very good word to say what that does? 10 THE WITNESS: (Lieberman) In a sense. I won't 11 dispute it. 12 There is, within the equilibrium principle 13 implementation, an optimization procedure. 14 BY MR. FIERCE: 15 O Mr. Lieberman, isn't it true that equilibrium 16 principles applied to traffic applications work best for 17 normal commuter flows and less well for single-time flows 18 lj.ke an evacuation? 19 A (Lieberman) I think what's implied there is that 20 under normal flows the travelers have a good knowledge of 21 the roadway system and the paths available to them. That's 22 what underlies that hypothesis. 23 Q And have an opportunity over time to explore the . 24 different routings and decide which works best for them?
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25 A (Lieberman) It follows from their knowledge of Heritage Reporting Corporation (202) 628-4888 1 f -___ - 1
b ] r . REBUTTAL' PANEL'NO.'16 CROSS 26971 Ii[ ' I 'l tae roadway system.- kp[O 2 .W hat we're saying here.is'that..there'is a 3- ' comparable' knowledge;of the-roadway systems which take 'l*.4 4 peopleEfrom the. beach. areas to outside the'EPZ~given that -- 5 .and.id you look at.the roadway" system, there isn't all that H '6' .much choice, quite frankly. 7 < When I did the "no. guides" TRAD run, I found.that,
- 8 while the set of candidate nodes,' destination nodcs:was 9 .often larger, that is, had additional nodes than the set of 10' candidates nodes when. guides were in place, there wasn't a
. night' and day dif'ference.
11 ' , 12 Q- .It wasn't night and day, but was there some 13- ' difference? 14 A (Lieberman) .There was some difference --
.I' A small difference?
15 Q 16
- A .(Lieberman) -- for-some' origins, right.
17 Q But you don't disagree'that the principles apply. 18 most readily to commuter traffic flows? - 19- A (Lieberman) Under normal conditions,1 that's true,
.20 yes.
- 21 Q In the event that there may be some variance 22 between how an optimized system might flow out of the 1 4
.. 23 Seabrook Beach area if one were to do it repeatedly with a 24 group of computers, and on the other hand, what happens with 25 =one-time flow of evacuees, if there were some difference in Heritage Reporting Corporation
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i REBUTTAL PANEL NO. 16 - CROSS 26972 J 1 terms of the performance and the route selected, does your 2 reduction factor cover that? 3 Is it sufficiently large to cover that 4 distinction? .- I ' 5 A (Lieberman) Well, I think you are creating a
= i 6 distinction which is largely illusory. )
l 7 You have to keep in mind that the TRAD model sets 8 up the initial turn movements on all links. That is input i 9 into the simulation model, which has what we call a queue 10 adjustment feature, which overrides these percentages j 11 generated by either the TRAD model or the assignment model 12 if the dynamics of the traffic environment are such that it 13 would cause evacuees to stall or be delayed unnecessarily in 14 one direction when there is available another pathway. 15 So what happens is that the simulation model takes 16 over and it represents a decision-making process of the 17 evacuees as they evacuate if, in fact, the original 18 assignment produces a kind of imbalance in congestion at 19 each decision point. 20 So that's why I say that this distinction which 21 you've noted is largely illusory because of this feature in . j 22 the simulation model. 23 Q I'm not saying, you know, it's a 25 percent . 24 difference. But it could be a 5 or 10 percent difference, 25 couldn't it between the actual performance of the commuters l Heritage Reporting Corporation , (202) 628-4888 l L 1 I
1 j I REBUTTAL PANEL NO. 16 - CROSS 26973 l i 7s 1 'in a no gaide situation and where they go, given the ! [ 1 i-(_,/ - 2 congestion they face in various directions and what the j
- J model has them doing using equilibrium optimizing I
3
. 4 principles? j l
5 A (Lieberman) Okay, again you used the model in the
)
6 singular. And what I'm saying is that there are two ; 7 processes, two modeling efforts involved. . 8 And while there may be some less efficiency 9 purported because there are some evacuees who have a lesser 10 knowledge of.the availability of alternate paths than in the 11 case of a commuter system, that is largely overcome by this
-12 ongoing dynamic decision process in the simulation.
13 Q I'm just trying to find out if you believe there y-^x 14 would be 100 percent coincidence or it might be only about a ( ,I
's-' 15 95 percent, or whatever.
16 A (Lieberman) Oh, I can tell you that even in the 17 commuter situation you're not going to get 100 percent, by 18 any means. 19 And what happens in the real world is that 20 commuters do in fact adjust their paths in accord with
. 21 traffic conditions as they experience it. That's why we put 22 this feature into the simulation model.
23 I think you are attacting too heavy a weight to 24 that difference between the real world and the ideal
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25 condition as defined by equilibrium. TN i Heritage Reporting Corporation y
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REBUTTAL PANEL NO. 16 - CROSS 26974 1 Q I want to jump ahead, I think, to page 43 where 2 you begin to discuss the updated ETEs, and I see the 3 discussion you are presented there. 4 These updated ETEs again are for Regions 8 and 13 .- 5 which have critical paths in New Hafnpshire, correct? 6 A (Lieberman) I think I added 286 to that list. 7 Q Okay. 8 There is a reference to the -- there is a sentence 9 which discusses "recent freeway operations data". Suggests 10 that once Level of Service F conditions take hold, the 11 capacity reduction remains in effect. And, thus, you say, 12 the 15 percent reduction is maintained in the updated model 13 for the most part for as long as congestion prevails. 14 Can you explain to me how the reduction factor 15 worked previously to this change in the latest version? 16 A (Lieberman) Essentially what it did is to refresh 17 the situation. The. simulation operates by computing 18 conditions through a sequence of time intervals. That is, 19 we discretize time into time intervals of about five minutes 20 and calculate the movement of traffic on each over the 21 network in each five-minute period. . , 22 And in the old model, if we had a density which 23 was say in Level of Service E in one five-minute period, , 24 whereas before it was the Level of Service F, then we 25 dropped back, that is, we would eliminate the 15 percent Heritage Reporting Corporation (202) 628-4888 _ _ _ _ _ _ _ _ - l
REBUTTAL PANEL-NO. 16 - CROSS 26975 1 ' capacity reduct' ion factor'for that' period. And this can g--(1 - t v \-.
/I 2 happen when you-have fluctuations in the numerical L3' computations. ~'
4 Physically, when you drop into Level of-Service F, 5 you stayLthere until the incoming demand drops well below 6 the reduced capacity level for a length of time adequate to 7- clear the queues which have accumulated during the congested
- 8. condition.
9 We didn't represent that consistent Level of
- 10. Service E situation earlier, in the earlier version.
11- Q What'does the phrase "up to 15 percent" mean? 12 A (Lieberman) What I've just described. 13 Q It sounded to me like it was fluctuating between
- r
/N 14 15 percent and zero.
15 A (Lieberman) Well, it could be -- what we have 16 built ir._o the model for each link is a relationship between 1"i speed and density and service rate and density. 18 And essentially what you do is the model looks at - 19 number of vehicles on the link at a given point in time, . 20 calculates the' density, goes into these curves and comes up 21 with a value of service rate. 22 If the density exceed a certain value, I believe
, 23 it's 120 vehicles per lane per mile, then it uses this 15 24 percent capacity reduction factor consistently; whether it's 25 120 or 130 or whatever.
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REBUTTAL PANEL NO. 16 - CROS3 26976 1 If it's between say 80 and 120, it will go into 2 the curve and use that figure. 3 Now what we'do is we say whenever the density 4 exceeds 80 -- I 5 Q Eighty percent of? , 6 A (Lieberman) No , 80 vehicles per mile per lane. 7 Q Eighty vehicles. 8 A (Lieberman) And I'm not sure 80 is the correct 9 figure. It might be 67. I'll have to look it up. 10 But whenever that's exceeded, we now go 11 immediately to the 15 percent reduction factor. We don't go 12 into the curve which would give us somewhere between zero 13 and 15 percent. 14 In comparing results with the new model against 15 those with the old model, it doesn't seem to have very much 16 sffect. 17 Q On ETEs? 18 A (Lieberman) On ETEs. 19 But it does, I believe, lower -- I'm sorry -- , 20 raise the ETE possibly by 10 or 15 minutes in and of itself.
^
21 Q Now you can have a road at capacity at Level of 22 Service, what, C? ,
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23 A (Lieberman) No. That's not -- no. 24 According to the HCM, capacity is defined as Level 25 of Service E conditions. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26977 1 Q E. 2 A (Lieberman) And to be more precise, every level 3 of service corresponds to a range of volume.
- 4 So if you look into the HCM very carefully, you 5 find they are really talking about the upper bound of the 6 Level of Service E range. Often that distinction is not made in the tables contained within the HCM.
7 8 So if you ask a lot of engineers, they won' t make 9 that distinction. 10 11 12 13 14 15 16 17 18 19 . 20
- 21 22 e . 23 24 25 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26978 1 Q Level of Service D, what does that tell us about 2 the volume of the traffic, service volumes? 3 A (Lieberman) What it says is that demand is 4 somewhat below capacity. .- 5 And you understund that Level of Service is an 6 index descriptor of the quality of traffic operations. And 7 it corresponds to a ranges of what are called " measures of I 8 effectiveness". 9 So when you say that a highway section is 10 operating at Level of Service D, depending upon the kind of 11 facility it is, you can go into the Highway Capacity Manual 12 and recognize that, from the tables provided, you are either 13 in a certain density range where density is the measure of 14 effectiveness or in a certain speed range where speed is the 15 measure of effectiveness, and so forth.
.16 Q Wi>ch those earlier runs, the 15 percent reduction 17 factor wasn't there at Level of Service E. It fluctuated 18 off or was on the curve, correct?
19 I thought that's what you just told us. 20 A (Lieberman) It isn't there now. 21 Q And it's not there now. . 1 22 A (Lieberman) No, it's not there now. 23 Q It's at Level of Service E. , 24 A (Lieberman) You have to understand that Level of < 25 Service F covers a broad range of conditions, particularly l i l l Heritage Reporting Corporation , (202) 628-4888 j 1 l l 1
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Fnn i I tE REBUTTAL PANEL NO. 16 - CROSS 26979 i. f dk,( 'l- in density.
;I I (,) ~ 2 Q Which.is beyond capacity?
l' 3 A '(Lieberman)- Which'is a density which is' higher
. 4- than that at capacity..
5 Q Density is higher than that. 6 ~A (Liebe rman)' That's. correct. 7' Q Correct.- 8 A (Lieberman) Now, what we did,previously, as I 9 explain, is we have an upper bound to density cutoff, 120 10 vehicles per hour -- sorry -- 120 vehicles per lane per 11 mile. 12 Densities beyond that, we apply the 15 reduction i 13 factor. Densities between what's called optimal density, fs . 14 that is, the one at Level of Service E, and this figure.of
- 15 120, we used to go into the curve to calculate. service 16 volume.
17 By going into the curve, the capacity reduction 18 factor was in the range of zero to 15 percent. - 19 Now we go immediately to 15 percent. And the
- 20. reason we do that is because data which is derived from
'.. 21 surveillance systems indicate that there is a very rapid 22 drop from Level of Service E into F.
. :23 If you read the Highway Capacity Manual, you will 24 find at Level of Service E flow conditions are described as 25 very unstable, wherein any perturbation in the flow process
't .
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REBUTTAL PANEL NO. 16 - CROSS 26980 1 will drop it into Level of Service F. That's the nature of 2 the traffic flow process. 3 If you look at the I-DYNEV output, you will find 4 that the output reflects this. You will not find many, if - 5 any, links which supports Level of Service E traffic . 6 conditions over a long span of time because of its 7 instability. 8 And that is why the difference between what we did 9 before and what we do now is pretty benign. No major 10 difference. It's just I feel more comfortable with the way 11 the model is now. 12 Q Is a density range from 80 to 120 what you would 13 call Level of Service E7 14 A (Lieberman) No , that would be F. 15 Q That would be F7 16 A (Lieberman) Yes. 17 Q What's the range for E? l 18 A (Lieberman) I don't have the HCM with me, but 19 it's a lower level. 20 Q It's a lover leve:1, obviously. 21 And in the model right now we have roads, some - 22 roads at some times that are flowing at densities that aro l 23 in that Level of Service E range, don't we? 24 A (Lieberman) For short periods of time and few in 25 number, yes. - I l O! Heritage Reporting Corporation ! (202) 628-4888 i
REBUTTAL PANEL-NO. 16 - CROSS 26981 When you say "few in number", was that because
-1 .O
%_, 21 they'are all. flowing at Level.of Service F, or flowing at 3 Levels of Service below-E -- A, B or C7
. 4' 'A (Lieberman) Right.
5 .Both actually. The' congested roads are at Level. 6' of Service F, by definition. The undersaturated roads'are 7 at Levels'of Service A through D. 8 Level cf Service E, .f i you look at'the table, it 9 is a very narrow domain'of conditions. And because.the flow 10 is unstable, those conditions are not retained well over 11 time, and that's why you won't find it very frequently. 12- Q. Up in the New Hampshire proceedings, Mr. 13 Lieberman, you argued, did you not, that the 15 percent 14 reduction factor was there as a backstop to cover any
't
'N- 15 concerns about uncertain driver behavior and minor 16 disturbances?
17 We talked a little bit about that yesterday. 18 Breakdowns, vehicle breakdown on the one hand, driver - 19 uncertainty on the other. . 20_ A (Lieberman) I think I used the term " disruptions"
- 21 there.
22 Q Minor disruptions.
. 23 A (Lieberman) Well, I don't think I used the term 24 " minor".
25 Q Temporary disruptions, perhaps. Heritage Reporting Corporation (s (202) 628-4888
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REBUTTAL PANEL NO. 16 - CROSS 26982 ] 1 A (Lieberman) Whatever. ; i 2 O I think that may have been the term. , l 3 A (Lieberman) I did take a look on Monday morning 4 at that testimony, and there's a fairly extensive 5 description there, and I'm happy to say it's consistent with , 6 what I've said here. 7 Q But the capacity reduction factor of 15 percent 8 was not in place in the 80 to 120 density Level of Service F 9 range in those runs that were the subject of the New 10 Hampshire litigation, correct? 11 A (Lieberman) For those few situations, there was a 12 lesser capacity reduction factor under the old model. 13 Q Will roads that are flowing at near capacity, but 14 below, which experience cars that run out of gas or break 15 down, need to be adjusted in any way with a capacity 16 reduction factor to account for the affects on those roads? 17 MR. TURK: Are you still talking about LOS F7 18 THE WITNESS: (Lieberman) I think what you are 19 saying is that a free-flowing road may be shoved into Level l 20 of Service F if there is a major disruption. 21 BY MR. FIERCE: 22 Q Well, if a car breaks down, as you indicated , 23 before and it takes a few minutes to push it to the side of - 24 the road, there is a temporary disruption at that point 25 which impacts the traffic, or cars running out of gas. Heritage Reporting (202) 628-4888 Corporation O'i l 1 I
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~I REBUTTAL PANEL NO. 16 - CROSS 26983 l
p_q l' Automobile accidents can still occur on roads which are near L , 2 . capacity '. 3 All those things can happen, correct?
.. 4 A (Lieberman) Those things can happen.
'5 Q- Why shouldn't we be applying the reduction factor
' I 6 in those situations as well?- ] i 7 A (Lieberman) Well, first, what I'm saying is that .]
8 when you. talk "near capacity", you are describing an
.9 unstable flow condition, as I've discussed, which will drop 10 into Level of Service F of its own accord.
11 Q I don't understand that. 12 The model doesn't read an automobile accident . 13 occurring or a car running out of gas, does it? 14 It will see a road at something less than -- t f 5 15 A (Lieberman) Might be Level of Service C or D. 16 0 It's at a density that doesn't in the model cause 17 the 15 percent reduction factor to kick in.
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18 A (Lieberman) Right. ,1 19 Q In the real world, there are cars running out of 20 gas, there are cars having accidents, temporary disruptions
. 21 that are not reflected along those roads that are at or 22 below or near capacity.
23 A (Lieberman) Well, they are not near. That's what 24 I'm trying to tell you. 25 Near capacity is not a sustainable. You are
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REBUTTAL PANEL NO. 16 - CROSS 26984 I 1 postulating a condition that doesn't exist in the.real world 2 and it doesn't exist in the model either. 9: 3 Level of Service D even in the HCM is described as
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4 potentially unstable flow. That's just the nature of the 5 animal. ,i 6 So over the long term you will find in the ) i 7 I-DYNEV links which are operating at A and B; to a lesser 8 extent, C; more rare, D; and very, very infrequently, E. i 9 You can see that for yourself if you go through the listing. 10 Q Nevertheless, why shouldn't we have some sort of a 11 capacity reduction factor built in for those D and E 12 situations when they occur? 13 MR. DIGNAN: All right, at this point I'm going to 14 object. And the reason I'm going to object is we are on 15 I-DYNEV. We're on a characteristic that has not changed and ' 16 that they are complaining of. And I direct the Board's 17 attention to the PID which the Board found flat out, "We 18 conclude that I-DYNEV is appropriate for use in determining 19 ETEs of the n'uclear power plants." 20 I don't think I-DYNEV, other than the TRAD model, 21 which clearly was new, or exploration of how the change was 22 made is open for litigation in this proceeding. j 23 MR. FIERCE: Well, I am litigating the change. . j 24 MR. DIGNAN: No, you are not. l l 25 He's asking why didn't they throw in a factor for I Heritage Reporting Corporation (202) 628-4888 4
f REBUTTAL PANEL NO. 16 - CROSS 26985 1 accidents,fand they hadn't. thrown in a factor for accidents 7_s '[.(_f; 2 up in New Hampshire either, Your Honor. [.. 3 MR. FIERCE: He's now dropped down. . 4 The capacity reduction factor applies at a density. 5 now down -- a fixed 15 percent down to 80, and I'm exploring 6 why he's picked 80, e.nd why it shouldn't perhaps.be some 7 lower density than that given that we know that there are 8; . going to be accidents, know there are going to be 9 breakdowns,l cars running out of gas. Temporary disruptions 10 occur on those roads as well. That's what I'm doing, 11 exploring the subject of this testimony. 12 MR.' TURK: I may -- 13 -MR. DIGNAN: I'm going to withdraw the objection
, s 14 because it's going to take longer to resolve it than 7 I withdraw the objection.
\_/ 15 to withdraw it.
16- . (The Board confers.) 17 MR. TURK: Your Honor, I would like to make an 18 observation if I can. . 19 Mr. Fierce's last argument, I heard him say 20 essentially that the 15 percent capacity reduction factor
.-. 21 has now changed to essentially a 20 percent capacity 22 reduction factor.
23 MR. FIERCE: No, no, no. 24 MR. TURK: He's using the number 80 of density as 25 if it was a 20 percent capacity reduction. And I think l [ Heritage Reporting Corporation !
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REBUTTAL PANEL NO. 16 - CROSS 26986 1 that's fouling up the record. 2 '*ERCE: I certainly did not do that, Your 3 Honor. 4 JUDGE SMITH: All right. . 5 I think it would be helpful if you could give to 6 the Board an overview of this recent discussion. Just 7 summarize the relationship of the capacity reduction factor 8 to the various Level of Services as you use it now and as 9 you used it before. 10 And particularly where there is some confusion is 11 where you have the lower and marginal -- I mean, Level of t 12 Service C and D as compared to E and F. 13 What is the rationale, if any, for having a 34 capacity reduction factor when the roadway isn't being used l 15 at capacity, if that's the case? 16 Just generally, we're confused. 17 THE WITNESS: (Lieberman) Okay. 18 Traffic operates under one of two conditions, 19 brcadly-based conditions. It's either undersaturated or 20 it's oversaturated. 21 I use the term "oversaturatec" synonymous with the . 22 term " congested" and synonyaous with the Level of Service F 23 designation. . 24 The term " undersaturated" implies that the traffic 25 demand at a point or along a uniform section of highway is Heritage Reparting Corporation (202) 628-4888
! j Y k REBUTTAL PANEL NO. 16 - CROSS 26987
,csq, 1- 'less than the capacity of that section of highway.
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'2- -In the Highway Capacity Manual, the range of 13 . undersaturated flow is subdivided into five Levels cf 1 '4 Service,Lwhere each Level of Service represents a different 1 5 description of the quality of traffic operations.
[ 6- ' Level of Service A, which is the lowest range of 7- traffic demand, is called the unimpeded range. It's.where . 8 the interactions between vehicles are very, very weak, 9 almost to the point of being nonexistent. 10 Again, I don't have the Highway Capacity Manual 11 here, but roughly speaking, for highways the range of volume 12 for Level of Service A spans all the way from zero to a 13 thousand vehicles per hour per lane. A very broad range of 14 conditions are characterized by that description: very 7-N- 15 little' interaction of vehicles. 16 - As we go up to the next volume level, or demand 17 level, Level of Service B, that's described as a condition
'18 where there are some interactions between vehicles but that 19 they do not cause any lasting delay. That may range from 20 say a thousand vehicles per hour per lane to perhaps 1500.
. 21 You will notice that the range is less for Level of Service 22 B than for Level of Service A.
23 As we go up to C, D and E, we find that the range 24 for each Level of Service declines in its breadth. And 25 Level of Service E might be 100 or 150 vehicles per hour per Heritage Reporting Corporation i (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26988 1 lane wide, where the upper bound for highways is 2,000 2 vehicles per hour per lane. 3 That's the way it appears in the Highway Capacity 4 Manual. . 5 In the model, we represent Level of Service as an 6 output. It does not play a role in the internal 7 calculations because, again, it is a descriptor and not an 8 essential representation of traffic operations. 9 What is important to the model are the 10 relationships between demand, capacity, density and speed. 11 The three dominant and related macro-variables that traffic 12 engineers worry about are density, which is vehicles per 13 mile; speed, miles per hour; volume, vehicles per hour. And 14 there is an equation called the Equation of State which 15 relates to these three. 16 In the model the dividing line between the point 17 where capacity occurs, at Level of Service E, and everything 18 beyond that into the oversaturated regime is roughly, and I 19 think now it's around 67, that number comes to mind, 67 20 vehicles per mile per lane. 21 Everything to the left of that, less than that, - 22 covers the entire spectrum of Levels of Service A through E. j 23 Everything to the right of that, which theoretically can go . 24 up to 200 vehicles per miles per lane but rarely does, is 25 called Level of Service F. i 1 Heritage Reporting Corporation ! (202) 628-4888 l
m 1 REBUTTAL PANEL NO. 16 - CROSS 26989 ; l' . Now,.in.the' course of calculations.one of the j,.c 3 2 outcomes of the calculation is the number of cars on each 3 . link,-and that's computed every five minutes or so to use a 4 4 specified variable. But every five minutes or so the 5 simulation model computes that. 6 We then, for-the next five minutes, look at that 7 number, calculate the density and go into a curve which - 8 relates speed as a function of density, and come up with a 9 value of speed. 10 It turns out that volume is the product of speed 11 and density. So we take the product of speed and density 12 and that gives us service rate. We use this information to 13 move traffic. 14 a 15 16 17 18 - 19 , 20
. 21 22 23 l
24 25 Heritage Reporting Corporation (202) 628-4888 i
! REBUTTAL PANEL NO. 16 - CROSS 26990 1 THE WITNESS: (Lieberman) Whenever the density 2 exceeds 67 percent -- I'm sorry, 67 vehicles per mile -- 3 the monitor says, oho, I am now in Level Service F, I'm 4 going to take the capacity of this link and reduce it by 15 .- 5 percent. And that in turn dictates the service rate, the 6 rate at which I will permit traffic to leave this link, 7 subject to the condition that there be no congestion 8 downstream which precludes traffic from leaving this link. 9 But absent the so-called spill-back condition I will allow 10 "raffic to 1 cave the link at this rate. 11 And than going into more detail, at the end of the 12 time interval we now take a look at density, because we arc 13 discretizing time and we say, are we still in Level Service 14 F? Generally we are. , 15 And if so, we iterate over space. We make three 16 sweeps through the network, for reasons which I won't go 17 into unless you're interested, in order to have a 18 synchronous syste.u. 19 At the end of that third sweep we then are able to 20 determine what the density and throughput is on each sweep. i I 21 The reason we don't apply the capacity reduction . j 22 factor for undersaturated flow is because: one, it's moot, ! 23 the demand is less than capacity. So even if I were to . 24 apply the capacity reduction it would have no effect. 25 And the other reason is that the capacity l Heritage Reporting Corporation (202) 628-4888 l l
REBUTTAL PANEL NO. 16 - CROSS 26991 (~~y 1 reduction factor for highways represents a turbulent ( ) ss/ 2 condition which only occurs under congestion. 3 So those two factors are the basis for my not
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4 applying it for undersaturated conditions; there's no point 5 .to it. 6 The Level of' Service E condition is a transient I 7 one. For example, I just pulled out a page in the middle of 8 simulation and I took the time, this is at three-hours and i 9 30 minutes when the network is very congested. Out of 120 i 10 linke there are four here that are on Level of Service E at i 11 this point in time. 12 The vast majority of the links on this page and on 13 other pages are either Level of Service A, they're 14 uncontested or Level of Service F, they're congested. There t
) /N 15 are a few Bs, Cs -- there's no C here, there's a B and a few 16 Ds. But that's the nature of traffic flow in an evacuation 17 condition.
18 You're either congested or your uncontested and 19 there is very little in between. , 20 JUDGE McCOLLOM: What you've described right now, 21 is that the way the model is working currently or is that 22 the way it was working back in the Naw Hampshire model?
. 23 That was one of the questions that we were concerned about.
24 THE WITNESS: (Lieberman) It's working uhe same 25 way except for the treatment of the reduction factor, p { Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 26992 1 In the old model between this boundary between 2 undersaturated and saturated which I now think is 67 ' ( 3 vehicles per mile per lane, and a cutoff of 120 vehicles per 4 mile per lane. . 5 In the old model I would go into the curve to 6 calculate the service rate. And that service rate would be ' 7 somewhat higher than 85 percent of capacity. It would be 8 below capacity but somewhat higher than 85 percent of 9 capacity. In the range of 85 to 100 percent. 10 Now, whenever we're past this 67 vehicles per mile 11 per lane, we go immediately to the 15 percent reduction. 12 JUDGE McCOLLOM: And is that what causes slightly 13 longer ETEs? 14 THE WITNESS: (Lieberman) Yes, that's one of the 15 contributing factors. 16 (The Board confers. ) 17 JUDGE SMITH: Thank you.
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18 Mr. Fierce? 19 MR. FIERCE: I just want to clarify a couple of 20 things. 21 BY MR. FIERCE: - 22 Q When you used the word " congestion" as you did in 23 volume 6 on the diagrams that are in chapter 10, diagrams . 24 that begin on page 1021, what did you mean by " congestion" 25 there? Heritage Reporting Corporation (202) 628-4888 4
REBUTTAL PANEL NO. 16 - CROSS 26993 s 1 Is that Level of Service F or E and F? i l \
\ ,) 2 A (Lieberman) In the displays given the shaded 1'
3 links indicate E and F. 4 Q 3 and F. 5 A (Lieberman) But they're virtually all "F." 6 Q In that section you refer us to some definitions 7 of the Level of Service definitions. Back in Appendix E of 8 Volume 6 on page E-2 I see some definitions given there of 9 Levels of Service A, B, C and over on page E-3, D, E, and F. 10 And it tells then thht these are adapted from the 11 1985 Highway Capacity Manual. 12 Do you see that, Mr. Lieberman? 13 A (Lieberman) Yes. rN 14 Q I see that for Level of Service C, which is s t
\'/ ) described here as " stable flo. that users," and I gather 15 16 that means drivers, "are significantly affected by 17 interaculons with others in the traffic stream."
18 Is that correct? - 19 A (Lieberman) Right. 20 Q Now, if we've got a Level of Service C roadway
- 21 link in the evacuation that is experiencing occasional 22 breakdown, a car running out of gas, you have no capacity
. 23 reduction factor applied to account for any delays that 24 might result; correct?
25 A (Lieberman) That is correct. [ \ Heritage Reporting Corporation
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1 REBUTTAL PANEL NO. 16 - CROSS 26994 1 Q And you believe no delays will occur? j 2 A (Lieberman) No , I don't say that. 3 Delays will occur, but it will not affect the ETE. 4 Q Just because they' re not on critical paths? . 5 A (Lieberman) No , because at Level of Service C the 6 demand is sufficiently below capacity that any localized 7 disruption will, in fact, cause some affect, but because the 8 demcnd is below the capacity any queuing that takes place 9 will dissipate fairly rapidly and you will return to the 10 stable flow condition. 11 Remember what I said before about how Level of 12 Service F eventually gets back into undersaturated flow 13 conditions. The demand has to drop below capacity. 14 Q So it's only if the last car out is delayed, is 15 what you're saying, on a Level of Service C road would there 16 be an affect on the ETE7 17 MR. TURK: What is an ETE if it's not the time it 18 takes to get the last vehicle out? 19 MR. FIERCE: I understand. 20 I think he's going to say, yes. 21 MR. TURK: It's a syllogism. - 22 THE WITNESS: (Lieberman) I suppose so, if the 23 timing of the disruption is at the very end. . 24 JUDGE SMITH: All right. 25 That's a demonstration, I think. Let's say it is Heritage Reporting Corporation (202) 628-4888 _ j
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REBUTTAL PANEL'NO. 16 . CROSS 26995' m,_q. 1 not at the. very end, ' let's . say it's in the middle? 2- THE WITNESS: (Lieberman) ~I'm sorry. 3 JUDGE SMITH: Say it is,in the-middle, it will not
. 4 affect it? It will not affect the time that the last car 5 gets out?
6 THE WITNESS: (Lieberman) Yes. 7.- JUDGE' SMITH: In simple terms.is it because they 8~ catch up the time lost? 9 THE WITNESS: (Lieberman) Exactly.
'10 BY MR. FIERCE:
11 Q Well, I would put it that the last car out has no 12 . time lost by the time he passes perhaps through the location 13 where there may.have been an earlier breakdown, if there is 14 one, it's not there then? CI/s 15 A (Lieberman) That's correct. 16 Q It may be that the cars that broke down or the 17 . ones that queued behind him never actually caught up to the 18 point they would have been without the breakdown. But the - 19 last car.out merely just doesn't experience any delay. 20 I think that's probably the way to put it.
. 21 JUDGE McCOLLOM: Unless the last car breaks down.
22 (Laughter) 23 MR. DIGNAN: There you got it, Allan. If the last 24 guy cracks up you' re going to extend that ETE.
~
25 MR. FIERCE: There we go. [' - Heritage Reporting (202) 628-4888 Corporation
REBUTTAL PANEL NO. 16 - CROSS 26996 1 MR. DIGNAN: I'll stipulate it. 2 MR. FIERCE: Or it could be, you know, 100 cars 3 ahead of the last car out there's a breakdown and he's 4 caught in a 100-car queue. - 5 BY MR. FIERCE: . 6 Q Just to bring it back to the 67 -- I'm looking at 7 a density of 67 or higher, is that what you call Level of 8 Service F7 9 A (Lieberman) It's the crossover point. 10 Q Between E and F7 11 A (Lieberman) Right. 12 Q 677 13 A (Lieberman) Don't hold me to the number, please, 14 it's in that neighborhood. 1S Q Well, I'm just trying to be clear, Mr. Lieberman, 16 that in the New Hampshire proceedings with the ETEs you were 17 presenting there Level of Service F conditions did not 18 always have a 15 percent reduction factor applied to them; 19 correct? 20 A (Lieberman) Yes, that was testified at that time. 21 Q Isn't it the case, Mr. Lieberman, that the reason - 22 you're making this change now is to make the ETE runs . 23 consistent with the Board's PID? . 24 A (Lieberman) That change was made before the 25 Board's PID. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 26997 1 Q When was this change made? 7_ \ ( ,) . 2 A (Lieberman) It was made, as I recall, roughly the 3 same time frame or perhaps even before the hearings. It was
. 4 a model update under contract of FEMA which included that 5 change.
6 Changes made subsequent to the time that we 7 performed the study for MCDA, and I can't tell you whether - 8 it was before the hearing or after the hearing, I didn't pay 9 too much attention. But that change was in there well 10 before the Massachusetts hearing was a gleam in anyone's 11 eye. 12 MR. TURK: MCDA is Massachusetts Civil Defense 13 Agency?
,g 14 THE WITNESS: (Lieberman) That's correct.
I i
's. / 15 JUDGE SMITH: Well, the Board's decision on the 16 ETEs -- the only thing that we did that would be relating to 17 what you said is that we changed the demand. Nothing else, 18 just the demand. Just the number of people to be evacuated. .
19 Number of cars to leave, that's all we did. Just the demand 20 and nothing else.
. 21 MR. FIERCE: But the Board was assuming in the PID 22 I think pretty clearly that there's a 15 percent reduction 23 factor that was applied for all Level of Service F 24 conditions and that's just not the case.
~
25 JUDGE SMITH: But we did not -- i
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l 1 1 REBUTTAL PANEL NO. 16 - CROSS 26998 1 MR. FIERCE: That's all I'm saying. 2 I agree with the demand issue, yes. 3 JUDGE SMITH: That's all we did. 4 And we didn't quarrel with any other aspect of it. - 5 MR. TURK: Nor did Mass AG. . 6 JUDGE SMITH: Exactly. 7 MR. FIERCE: Had we known. I mean, this -- 8 MR. DIGNAN: Had you known what? 9 MR. FIERCE: Well actually, I think we did quarrel 10 with it, Your Honor. I do recall discussions about -- 11 MR. DIGNAN: Had you known what? 12 That in the old model it went on a curve? 13 Because, Mr. Fierce, that was testified to absolutely 14 clearly in New Hampshire. 15 MR. FIERCE: I'm correcting myself, Your Honor, I 16 believe we did litigate the fluctuation -- 17 MR. DIGNAN: And you offered no proposed findings. 18 You walked away from Ceder. 19 THE WITNESS: (Lieberman) As a matter of fact, 20 Dr. Ceder agreed with that aspect of treatment of Level of 21 Service F. 22 MR. FIERCE: And my only point is, I think the 23 Board did not understand that discussion and in the PID . 24 seems to indicate that the 15 percent was applied across-25 the-board for all Level of Service F conditions. t Heritage Reporting Corporation (202) 628-4888
REBUTTAL' PANEL NO. CROSS 26999 decision. 3 MR. FIERCE: Well -- 4 MR. TURK: No denial. 5 BY MR. FIERCE: l 6 Q On page 45 of the testimony, Panel, on item No. 2 7 it says:- "The latest version of the I-DYNEV simulation - 8 model asserts a more conservative application." 9 What is the previous version of the I-DYNEV model 10' Ithat we're referring to.here, if this is the latest? 11 A (Lieberman) Previous version -- when I talk about
- 12. "previously," I mean, the model that was.used in generating 13 the ETE for.the Commonwealth.
D .14 Q And the ETEs in the NHRERP7 i,x-- 15 A (Lieberman) Which is the same document, 16 essentially. 17 .Q Volume 67 .
~
18 A (Lieberman) Right. - 19 Q What is the phrase now in here, near the end of 20 paragraph 2 where it says: "For the most part 15 percent
. 21 reduction is maintained in the updated model for the most 22 part for as long as congestion prevails?"
. 23 A (Lieberman) When -- well, as I said before, in 24 the simulation model we have a dynamic representation of the 25 traffic flow. It is possible for a link which is under t
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REBUTTAL PANEL NO. 16 - CROSS 27000 1 Level of Service F conditions to drop below Level of Service 2 E or D for a short period of time, and then return to Level 3 of Service F. 4 When it does drop below Level of Service F 5 conditions, then the 15 percent reduction factor disappears. 6 JUDGE McCOLLOM: Just making sure I understand 7 that. 8 Even if you had done it, then it would have had no 9 effect because you aren't using the capacity of the line? 10 I think I haven't gotten it, is the reason I'm l 11 saying that. Because earlier you said, we don't use the 12 capacity reduction factor because it wouldn't make any 13 difference anyway. We're not using the capacity of the 14 street. 15 THE WITNESS: (Lieberman) When you're : 16 undersaturated. 17 JUDGE McCOLLOM: Right. 18 THE WITNESS: (Lieberman) No, the statement I 1 19 just made is that over time a link which is congested can 20 for a variety of reasons become uncontested, undersaturated. 21 JUDGE McCOLLOM: For a short period? - 22 THE WITNESS: (Lieberman) Well, short or long 23 depending upon circumstances. . 1 24 JUDGE McCOLLOM: Okay. 25 THE WITNESS: (Lieberman) As long as it's Heritage Reporting Corporation (202) 628-4888 l s
g,, , ~- ' as O' g , REBUTTAL PANEL NO. 16.- CROSS 27001 fja-sg , 1 undersaturated then the capacity' reduction factor is not
.. : \
,/i J2 applied.
3 JUDGE COLE: When,you're using saturated at 67
'N' 4' . cars per mile? ;
5 THE WITNESS: (Lieberman) Tes.
.. j 6' ' JUDGE COLE: Per lane?
7 THE WITNESS: -(Lieberman) Yes. --j
- 8. BY MR. FIERCE:
~I 9 -Q And1also, in:this sentence you're using the word ]
I
' 10 L '" congestion"'when'you say: "For as long as congestion- !
'11 prevails," in a different sense than you did in the diagrams
'12- in volumef6 where you told me congested conditions was E.and i 13 F. Here,you mean congestion to refer to F?
- j. ~' 14' (Witness referring document.)
's :15 THE WITNESS: (Lieberman) I don't think that says 16 that.
17 Let me just quote the sentence: "All highway j 18 links'which experience either Level of Service E or F are -
'19 delineated in the figures by a thick dark line."
20 I'm not using the term " congestion" specifically
..- 21 to apply to Level of Service E in that statement. The 22 titles to the figures say, " traffic congestion patterns."
23 BY MR. FIERCE:
- 24 - Q That's the only reason I sought the clarification.
25 A (Lieberman) Oh, all right. p Reporting Corporation 1 Heritage
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REBUTTAL PANEL NO. 16 - CROSS 27002 1 (Witnesses confer. ) 2 A (Lieberman) Yes. 3 M. r Callendrello just pointed out that a more 4 detailed description of Levels of Service E and F appear on .- 5 page 10-19 of Volume 6. And these are taken verbatim from 6 the HCM. 7 Q I think I just have one final question, Mr. 8 Lieberman. 9 MR. FIERCE: Do you want me to pause? 10 JUDGE COLE: Final question, did you say? 11 MR. FIERCE: On this line. 12 JUDGE COLE: Oh. , i 13 MR. FIERCE: We should be so lucky. 14 BY MR. FIERCE: 15 Q Nevertheless, that it does occur over perhaps a 16 .brief period of time, would it still -- all of the 17 principles that you have announced seem to indicate that the 18 reduction factor ought to be applied to Level of Service E 19 conditions, don't they? 20 A (Lieberman) No , I don't see that. 21 Q When a road is at capacity or very near capacity, . 22 if we have the kinds of disruptions we've been discussing, 23 temporary -- , 24 A (Lieberman) Then it drops into Level of Service 25 F. Heritage Reporting Corporation (202) 628-4888
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-REBUTTAL PANEL NO.116 - CROSS 27003 i: .
W /% , IL Q When the model is reading a segment, it's 2 fluctuating but it's. reading it now let's say at' Level of 3 Service E, the capacity reduction factor is not applied in 4 .the model, correct?- 51 A (Lieberman) That.is correct. 6 0 Why shouldn't it be? 7 A (Lieberman) Why should it be? 8 Q Because.--
-9' A. (Lieberman) You have --
10 Q -- all'of the principles that we have just 11 discussed'about disruptions occurring when roads are at 12 ' capacity means we are. going to havo less flow through that 13 link 1than capacity would give us. yN 14,. A (Lieberman) You've just defined Level of Service t 15 F, I think. 16'
~
If I may quote from the definition of Level of 17 Service E, " Operations at this level'are usually unstable, 18 because small increases in flow-or minor perturbations i 19 within the-traffic stream will cause breakdowns." . 20 What happens with a breakdown? 21 " Level of Service F is used to define forced or 22 breakdown flow."
. 23 Q I understand all that.
24 The model is fluctuating.between Level of Service
.25 E and F. And when it --
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I REBUTTAL PANEL NO. 16 - CROSS 27004 1 A (Lieberman) No, it doesn't. That's the point I'm ) 2 making. It's not the way traffic operates. . 3 Once it slops over into Level of Service F, it ) l 4 generally stays there. i 5 Q It stays there.
- l i
6 But at some points links are seen in the model's 1 7 eye as traffic perhaps diminishes or maybe on some roads it 8 just gets up to E and never quite gets to F, but at those 9 five-minute segments when the model is reading a roadway of I 10 Level of Service E, it's at capacity. 11 A (Lieberman) For a short period of time generally. < 12 Q It's at a particular number of vehicles per lane l 13 per mile. J l 14 A (Lieberman) Right. 15 Q And no reduction is applied in this evacuation 16 situation for those kinds of temporary reductions that could
occur from all of these things we have been talking about:
18 cars running out of gas, 19 JUDGE SMITH: You mean anticipatory capacity . 20 reduction? 21 MR. FIERCE: Well, I think that's we are doing at 22 Level of Service F, too. It's anticipatory with respect to . 23 these temporary disruptions that we don't know where they - 24 are going to be. We are not sure of the number, but it's, 25 it's wise, prudent to apply the capacity reduction factor in Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27005 y s, -1. anticipation of those events occurring.
~2 MR. TURK: Well, you are already at.LOS F, in that 3 case. You already have the disruptions. That's when he
- 4 . applies the capacity reduction factor.
i .- 5 My problem is, Your Honor, what he's asking 6 ' essentially is why isn't it proper to use the capacity 7 reduction factor five minutes ahead of the actual decrease. 8 . JUDGE SMITH: Well, that's right. 9' MR. TURK: Because every five minutes you are
'10 going to get the next reading.
And whether it's F or E will 11 be shown in the model, and therefore -- you know, all he's 12 arguing about is'maybe you should get into-the LOS F 15. 13 percent reduction five minutes earlier. And that's a very-14 useful line of questioning today. 15 JUDGE SMITH: Well, we just. don't understand the 16 logic.of why, if the assumption is it is at capacity, that 17 you would change the assumption. 18 I mean, if it is saturated, using the full - 19 capacity of the road for the fleeting moment that it does, .
'20- why would you change that assumption?
21 MR. FIERCE: Remember, what the.model is reading 22 is a certain number of vehicles per lane per hour.
. 23 MR. TURK: Every five minutes.
24 MR. FIERCE: Every five minutes. 25 And Mr. Lieberman picks a cutoff point below which Heritage Reporting Corporation (\ (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27006 j l 1 he doesn't apply the 15 percent reduction and above which he 2 does. I understand that. l l 3 I'm asking why the number is there, the cutoff j 4 point is there, when capacity is still a range of numbers - ' l 5 below that. In other words, the vehicles per :snes per hour - i" 6 could be something lower than that number. 7 JUDGE COLE: Could I ask a couple of questions? -l 8 MR. FIERCE: Sure. 9 JUDGE COLE: Mr. Lieberman, the car density for 10 Level of Service F is in the range of 80 to 120 cars per 11 mile per lane. 12 Is that so? Do you recall that? 13 THE WITNESS: (Lieberman) No, the range can be 14 larger than that. I have now substituted 67 for 80. But 15 it's anything in excess of 67. It could go all the way up 16 theoretically to about 200 or 220, theoretically, i 17 JUDGE COLE: So then the cars are bumper to bumper 18 at that stage. 19 THE WITNESS: (Lieberman) Right. That's correct. 20 JUDGE COLE: So there is no car density per se > 21 associated with the Level of Service F or E? 22 Sixty-seven, you know by experience, could be F, 23 could be E; is that right? 24 THE WITNESS: (Lieberman) What I did is I took it 25 right out of the Highway Capacity Manual. Sixty-seven is , i Heritage Reporting Corporati.on (202) 628-4888 j
, , . _ - - = _ _ _ _
i
. REBUTTAL PANEL NO. 16 - CROSS 27007
,_q - 1 their dividing line between the upperbound of E and Level of
\-
(
; (_,/ 2 Service F. So it wasn't judgment.
I-used the standards in 3 'the HCM. 4 JUDGE COLE: All right, sir. 5 BY'MR. FIERCE: 6 Q What's the lower boundary of E in the Highway 7 Capacity' Manual?
.8 JUDGE COLE: Mr. Fierce,.I think you were mixing 9 up the. capacity-in. vehicles per hour with the density in 10 vehicles per mile.. And that's where some of the confusion 11 might have been.
12- MR. FIERCE: Well, perhaps. 13 THE WITNESS: (Lieberman) I just queried Dr. es . 14 ~ Urbanik to see if he brought the HCM along with'him, and'he h 15 did not. 16 - BY MR. FIERCE: 17 Q So you are not sure what the lower boundary of E 18 is? .. 19 DR. URBANIK: Sixty-seven. 20 MR. FIERCE: It is 677
. 21 It's the lower boundary on E7 22 DR. URBANIK: No.
23 MR. TURK: Let me indicate in the microphone. 24 Dr. Urbanik has indicated from the back of the 25 room that 67 is the upper bound for the LOS E range in the [\ ( ) Heritage Reporting Corporation (202) 628-4888 b m______iu____.___=_._.__._._
REBUTTAL PANEL NO. 16 - CROSS 27008 1 HCM. 2 BY MR. FIERCE: 3 Q And we're just not sure, none of the parties seem 4 to be sure what the lower bound on E is. . 5 Do you have a reasonable guess, Mr. Lieberman? . 6 A (Lieberman) Yes. 7 I would say it's probably 58 or 60, somewhere in 8 there. 9 Q The cars are -- 10 A (Lieberman) Vehic1cs per mile per lane. 11 Q And I'm wondering when the model reads that, why 12 we shouldn't apply a reduction factor there, too, because 13 cars are at capacity and temporary disruptions will delay 14 the last car out, won't they? 15 A (Lieberman) Well, you have to have a cutoff point 16 somewhere. 17 Q And why shouldn't it ba 587 18 MR. DIGNAN: Your Honor," could I remind the Goard 19 that the Board took evidence in New Hampshire. I guess 20 because the Attorney General didn't contest it, no findings 21 were included on it. We made proposed findings on it. - 22
- You will recall that in the New Hampshire phase 23 there was a bunch of litigation over what would an accident 24 do. And Mr. Lieberman testified to the fact that he had 25 done sensitivity runs in which he had simulated 10 accidents Heritage Reporting Corporation (202) 628-4888 4
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l 1 REBUTTAL PANEL NO. 16 - CROSS 27009 i
- 3 l' in.the system, and the-range in which the ETE increased with l
(,,'\: '
$y_,/ 2 . respect to that did it.
~ i 3- < So this business of trying to throw disruptions in' ]
. 4 .is just getting us nowhere. The record is clear that if you j
5 put 10 random accidents in there, the increases -- I'm 6 looking at my proposed findings. It was in Applicants' .] 7 Direct ho. 7 after transcript 5622, at 62 and 63 of the New - 8 Hampshire hearings. i l 9 This is the same thing. And we did the 10 ' sensitivity. runs and put them in evidence. The increases, f-
- 11. you know,. there was zero to 10 minutes, depending upon the 12- duration of the impedance. One to two hours was zero to 10 13 minutes. Up to two to three hours being 15 to 40 minutes in
~ 14 certain things.
sd 15 And I just don't see where we're going with this e 36 thing. That's the same thing as dealing with this: what 17 happens to the model if you start assuming you are going to 18 have some disruptions. We've done that. We did that in New ,
.19 Hampshire at length.
20 It seems to me it's the same thing. I mean he's
. 21 calling it a breakdown rather than an accident, but it's the 22 same idea, and we dealt with that up in New Hampshire.
23 Now, I agree that I can't find a finding on this 24 by the Board, although I know we put in proposed findings. 25 And I rather suspect the reason is because the Attorney Heritage Reporting Corporation [ (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27010 1 General backed this one off and you didn't have to decide 2 it. 3 JUDGE SMITH: That's <;xactly right. We didn't 4 decide anything we didn't have to decide. 5 MR. DIGNAN: Yes, right. [ 6 JUDGE COLE: Isn't that similar situation covered i 7 on page 50 of the testimony? 8 THE WITNESS: (Callendrello) Yes, Your Honor. 9 JUDGE COLE: With the 10 accidents? l 10 ,THE WITNESS: (Callendrello) Yes. 11 MR. FIERCE: Well, I said what I said before, I'm 12 here -- 13 JUDGE SMITH: Well, I think right now -- 14 MR. FIERCE: -- litigating a change that's been 15 made since the numbers in Volume 6 were litigated. 16 JUDGE SMITH: But you've asked now, I think, on 17 several occasions, at least two, why he didn't apply it at 18 Level of Service E the capacity factor, reduction factor. 19 MR. FIERCE: That's right. And I' m not sure I' ve - 20 gotten -- 21 JUDGE SMITH: And it's not going to be productive. - 22 JUDGE COLE: He's explained why he set it where he 23 set it. . 24 JUDGE SMITH: Yes, I don't think you are going to 25 get a better explanation. i I I Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL'NO. 16 - CROSS. 27011 [ -
..- 11: MR..DIGNAN:- It'is the-Attorney-' General's
..t t .; "hs_,/. 2 contention that we shouldn't have made the change and the { ) - 3- ETEs should remain shorter? 1
'* - . 4 I thought their theme was'the ETEs always should
'5 be'made' longer.
1.j 7; - 6 MR. FIERCE: The theme is that they are 1 k 7 inaccurate. -
'8 MR. DIGNAN: This is what it does, is make them 9 . longer.
10- MR. FIERCE: The theme is that they are
-11 inaccurate.
12 MR. DIGNAN: Okay.
'13 BY MR. : FIERCE.;
1 c
./
e-'y 14 Q There's a paragraph at the top of page 46, that's
.A )
\/ 15 No. 4, thatosays, "The ability of evacuees in Hampton Beach 16 to travel south'into Seabrook and Salisbury Beaches.in the-17 absence of traffic guides acts to shift vehicles from the l
.18 critical paths in New Hampshire, other paths.which exhibit 19' lower ETE, and this acts to lower overall ETE."
' 20: Why is'the Panel' assuming that the Seabrook police
- 21 Lare going to late-staff its post along Salisbury Beach?
22 A (Lieberman) The statement here addresses trave? 23 from Hampton Beach into Seabrook, and then potentially into 24 Salisbury. , i 25 This was discussed also in the New Hampshire ] I l Heritage Reporting Corporati'en (, (202) 628-4888 i 1 -m__________________._________ _ . _ _ _ _ . -- 1
REBUTTAL PANEL NO. 16 - CROSS 27012 1 hearings. 2 Q Right, and not resolved, as ! recall. 3 Left to New Hampshire to decide what they wanted 4 to do about the Hampton Harbor Bridge. .- 5 A (Lieberman) No, that was not the issue. 6 The issue that was raised is what happens if the 7 guides arrive late. And we did a sensitivity study there - 8 which demonstrated that if they arrive late and traffic 9 which would otherwise be guided to the north, would have the 10 access to the bridge and would move south. 11 Q And we disputed that the guides to the south would 12 be late-staffing because they are from the Town of Seabrook, 13 not from state police coming from acress the State of New 14 Hampshire. And the issue of whether the Hampton Harbor , 15 Bridge came out of this, whether the bridge was going to be 16 up or down. And whether the State of New Hampshire wanted 17 to encourage flow from Hampton into Seabrook was left 18 unresolved and basically up to the State of New Hampshire. 19 And I'm just wondering why you are assuming here 20 that that decision has been made. 21 A (Lieberman) There is no decision made here. - 22 We're talking about the factors which enter into these 23 revised ETEs relative to those which were performed earlier. . 24 And one of the factors is Item 3, the staged ;
\
25 staffing of traffic guides. And one of the consequences or j l Heritage Reporting Corporation (202) 628-4888 9! l
REBUTTAL PANEL NO. 16 - CROSS 27013 i i the outcomes of the staged staffing of traffic guides and, 2 in the event of a rapidly escalating accident, their late 3 arrival on the scene, would be that evacuees in Hampton
- 4 Beach would have the ability to travel south.
5 Q It's assuming that the Seabrook traffic guides get 6 there late. 7 A (Lieberman) The Seabrook traffic guides have - 8 nothing to do with it. They are on the other end of the 9 bridge. 10 Q That's right. 11 And if they close the bridge at their end, which 12 their instructions are, isn't that correct, Mr. Lieberman? 13 A (Lieberman) No. 14 Q Do you want to take a look at the Volume 6 diagram O- 15 for the Seabrook TCP? 16 (Witnesses review document. ) 17 18 . 19 20
. 21 22 23 24 25 O Heritage Reporting corp 9 ration (202) 628-4888
i REBUTTAL PANEL NO. 16 - CROSS 27014 1 Q My recollection is, and maybe I'm wrong, that the.y 2 turn cars around that are heading north?
\
3 A (Lieberman) If they're heading north, yes. l 4 Q And you're saying they will allow cars over the .- 5 bridge. 6 I'm looking on page I-12 and my diagram shows cars 7 being turned around either way with barricades across the 8 road. 9 (Witness reviewing document.) 10 THE WITNESS: (Lieberman) Yes, that is indeed 11 what it shows. 12 But it still doesn't preclude the statement that I 13 made, namely, that before the guides get there this flow 14 would continue. 15 BY MR. FIERCE: 16 Q How long have you modeled these guides getting 17 there now? 18 A (Lieberman) How long? 19 Q How long is the no-staffing condition for this 20 position in Seabrook? 21 A (Lieberman) I'll have to do that in the break, - i 22 also. l 1 23 Q Okay. . l 24 I'll move on then. 25 In the -- does the panel want a minute? Heritage Reporting Corporation l (202) 628-4888 , 4
REBUTTAL PANEL NO. 16 - CROSS 27015 fy 1 (Witnesses confer.) i 2
'sy / 2 THE WITNESS: (Callendrello) No, I was just 3 reviewing with Mr. Lieberman the testimony -- Applicants' 4 Direct No. 7 which was filed in the New Hampshire portion of 5 this proceeding and there's about a five or six page section 6 that describes the sensitivity runs for the manning of 7 traffic control points, based on the staffing sequence that 8 the New Hampshire State Police have indicated they would 9 staff the points at.
10 BY MR. FIERCE: 11 Q And they are not staffing points in Seabrook; 12 correct? Seabrook police are doing that? 13 A (Callendrello) That is what it appears. 34 I'm looking at the New Hampshire State Police
\f)N
15 manning sequence and I don't see that traffic control post.
16 A Seabrook is, in fact, a cooperating community and 17 has always been counted on. 18 MR. DIGNAN: One of those bad guys $ ' 19 MR. FIERCE: That's right. , 20 It happens to be the one cooperating community 21 within five-miles of Seabrook. 22 BY MR. FIERCE:
. 23 Q So you're using their traffic guides -- their 24 police?
25 A (Callendrello) Their police. p. f Heritage Reporting Corporation k (202) 628-4888 i s m
REBUTTAL PANEL NO. 16 - CROSS 27016 1 As I said, I look at the New Hampshire State 2 Police manning sequence and I do not see that point . 3 A-SE-05 on the New Hampshire State Police manning sequence. 4 So it appears to be one that is staffed by local police. 5 In fact, I've got the manning sequence for local , 6 police and they do man A-SE-05. It would be the second 7 point that they would man. 8 Q The first down at Route 286 and Route 1-A? 9 A (Callendrello) Correct, that's A-SE-06. 10 Q Well, let's come back to that after the break. 11 On the bottom of page 46 I see 7 table here, 12 Penel, and I see Region 1, scenario 1; Region 1, scenario 5. 13 These times again are going to be showing us New Hampshire 14 critical path times; correct? 15 A (Lieberman) That's true for Region 1, scenario 1. 16 I would have to check the listing for scenario 5. 17 Q Can the panel explain to me -- I see that when I i 18 move from A to C in Region 1, scenario 5 the time increases j 19 from all traffic guides at start to no traffic control at
*l 20 any point. And I would have expected that when traffic 21 guides arrive over a period of time that the time would be 22 somewhere in the middle, but it's not, B is less than A for .
23 scenario 5. . 24 Is that an anomalous glitch or is there some 25 reason for that? Heritage Reporting Corporation (202) 628-4888 s
.* .1 4
-i o REBUTTAL; PANEL.NO. 16 - CROSS 27017 L . gr 1 A :(Lieberman) I don't place any' significance to the j
=2- five minutes. We are representing different travel patterns 3 before and'after.
4 You have, in the following discussion on page 47, 5 . we talk about the various tradeoffs.that are in play here. 6 ' And these are the results of the model, we put-it down as it
'7 comes out. -
8 It's not. terribly surprising that_there is little 9 difference between A and B, the fact that one'is five
~10- minutes more and the other is five minutes less, I deem of 11- no consequence.
12 Q' I;just want to jump back, I'm sorry, Panel, in 13 speakingfof the tradeoffs. I'm thinking of the Hampton y /- ' 14 Beach travel'into Seabrook, you indicate that that would ,i 15' ' have an impact on ETEs by. lowering the.overall ETE.
'16 - It.would also have the opposite effect if that 17 TCP,'in. fact, were' staffed promptly. It wouldn't have an 18 affect on increasing it, but it surely would stop the .
19 decrease from occurring; correct, for that factor? 20 A (Lieberman) That's correct, for that factor.
- 21 Q .The tradeoffs discussed on page 47, Panel, in 22 looking at the "no guides" condition the -- strike that.
23 (Pause) 24 BY MR. FIERCE:
- 25. Q The TRAD model's impact on ETEs is a concern I
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y _ __ _ REBUTTAL PANEL NO. 16 - CROSS 27018 1 have because TRAD redoes the assignment of people to 2 destinations and results in different routings for these -- 3 well both for the no guide and for the guide situations now; 4 correct? .- 5 A (Lieberman) Did you say, "more for one?" 6 Q No. I said, you havs TRAD doing the assignments 7 for both situations, no guide and with guide situations. 8 And we understand in the "with guide" situation TRAD now 9 assists in modeling the traffic coming out of Seabrook 10 Beach, now some of it will be routed into Massachusetts on 11 Route 1-A; correct? 12 A (Lieberman) For the "with-guides" case there will 13 be no traffic coming south from Hampton. 14 Q I'm not' talking about Hampton, 15 Seabrook into Salisbury at Route 286, you're using 16 TRAD now and it does in a "with guide" situation assign -- 17 as you've indicated and given me the turn percentages I 18 believe -- some residents south onto Route 1-A? 19 A (Lieberman) Into Salisbury? 20 Q Into Salisbury. 21 And at other intersections, now is TRAD doing a - 22 similar kind of thing where a pathway has become congested, 23 will TRAD make a shift in the eisignment of some vehicles to . 24 another pathway? If it's aAw..g those -- at least pathways l 25 leading to potential destination nodes? Heritage Reporting Corporation (202) 628-4888 Am.- _ - _ . - _ _ . _ . . .
l b REBUTTAL PANEL NO. 16 - CROSS 27019 L 1- A. (Lieberman) Within the construct of the quasi-
. .I 2 ~s tudy state analysis,tyes.
is 3L Q My concern, gentlemen, is that I understand at
.: 4 Route 286 and Route 1-A at the state line the traffic guides !
.i 5 have an instruction that makes that variation possible. But
^
6 that at other' intersections throughout the EPZ I'm not aware 7 of that kind of instruction being provided to the traffic f 8 guides. 9 In other-words, the guides have fixed 10 instructions, yet, TRAD is doing a variable assignment at 11 particular intersections; isn't that true?
.12 Except at~this one intersection at Route 286 and 13 1-A7 14 'A (Lieberman) See, I:have problems with your.
s 15 characterization that'that intersection is different. R16
- Q Only in terms of the instructions to the guides?
17 A (Lieberman) Oh, all right. 18 But I would maintain that what the guides are - t' 19 doing is entirely consistent with the motivat17n of people 20 to leave' the scene. If'one direction is blocked they'll
- 21 take the other direction. That's what ths guides are told 22 to do.
, ,,E 23 Q The guides are told to facilitate traffic along 24~ certain directions and to discourage traffic along other
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25 directions? Heritage Reporting Corporation
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1 REBUTTAL PANEL NO. 16 - CROSS 27020 1 A (Lieberman) That's correct. 2 Q TRAD doesn't do that; correct? 3 A (Lieberman) TRAD represents uhe actions of 4 guides. - 5 I give the example. . 6 (Witness reviewing document.) 7 THE WITNESS: (Lieberman) Somewhere in here I 8 give the example that before the guides arrive traffic on 9 the westbound approach to Salisbury Square has the 10 opportunity to either go through or make a left turn onto 11 Route 1. 12 And then after the guides appear that opportunity 13 to make a left turn is removed from, quote, "TRAD"s 14 consciousness" and it's assumed that the traffic will follow 15 the guide's instruction. 16 At this intersection for both with guides and 17 without-guides TRAD is offered the opportunity to send 18 traffzc in either direction. 19 BY MR. FIERCE: 20 Q Which is not what the traffic guides are 21 instrteted to do? 22 A (Lieberman) It is consistent with what they're 23 instructed to do. Because the rate at which TRAD assigns . l 24 traffic in either direction also reflects the volume 25 capacity relationship throughout the network. l Heritage Reporting Corporation (202) 628-4888 l l t
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REBUTTAL PANEL NO. 16 - CROSS 27021 s. [ 1 Perhaps what you're-referring.to is the. override () j_,j 2 capabilities of the simulation model. I 3- Q Well, maybe that's what I'm referring to.
=+.. 4~ You've now got situations where despite traffic 5 guide ir.structions on their traffic control posts diagrams t .. ;- 6 to facilitate cer'cain movements and discourage others,'the 7 model -- maybe it's I-DYNEV and maybe it's TRAD, I'm not +
8 sure which -- is giving those drivers' options to take other 9 routings-in order to apply these equilibrium principles; I 10- correct? 11- A .(Lieberman) Well,-speaking of the traffic control 12 posts -- S-EO-6 which is the 286/ Route'l-A -- the 13 instructions indicate that guides can permit or will
-14 facilitate -- I'm using the wrong words here -- movements in
\ 15 .either direction. The preferred movement is 286, if that 16 gets jammed keep them moving down to Salisbury..
17 The simulation model does exactly that. 18 Q~ That's the one'I think is consistent. -- 19 What .I'm saying is that in'other intersections 20 throughout the EPZ, traffic guides are not given those kinds
. 21' of instructions, but have a fixed set of instructions and 22 the model is now playing with that.
23 Giving additional leeway to the traffic flow that 24 the traffic guides haven't been instructed to offer; 25 correct? '! i Heritage Reporting Corporation (202) 628-4888 l l I
REBUTTAL PANEL NO. 16 - CROSS 27022 1 A (Lieberman) No, that's not true. l 2 Q Can you show me an intersection -- 3 JUDGE McCOLLOM: Let me ask a question first, , i 4 please. .- 5 MR. FIERCE: Sure. 6 JUDGE McCOLLOM: Did I understand that you take 7 the instructions of the traffic guides at every intersection - 8 and impose them on top of TRAD in making its decision at 9 that intersection? 10 Is that too simple? l l 11 THE WITNESS: (Lieberman) It's not an imposition. 12 If there are discouraged movements which are 13 implemented by the guides, then those discouraged movements 14 are eliminated from the opportunities available to evacuees. 15 So if the left turn is now discouraged at the 16 entrance to Salisbury Square, then TRAD does not send people 17 to make this left turn. 18- JUDGE McCOLLOM: Yes, that's what I thought. 19 BY MR. FIERCE: 20 Q So you believe TRAD is now 100 percent consistent 21 with the traffic guide instructions on discourage and - 22 facilitate? 1 23 A (Lieberman) Yes. , 24 Q Is the I-DYNEV model, the simulation model, 100
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25 percent consistent with those instructions? Heritage Reporting Corporation (202) 628-4888
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' REBUTTAL PANEL NO. 16 - CROSS 27023
- g. 1. . -A ~ (Lieberman) _Yes.
L i -/ ( ,,) -2' JUDGE COLE: Did you answer, sir? 3 THE WITNESS: (Lieberman) I said, yes. L
.. 4 JUDGE' COLE: I didn'tl hear you, I'm sorry.
5 BY MR. FIERCE: 6 0 'There's a section that follows this~about 7 -protective action recommendations. We've' talked'some about~ . 8 this and so I don't want to go,through it again. 9 But I did want to just clarify that Mr. 10 Callendrello. You say that you would do it in terms of 11 picking the' number off the chart that seems to be closest to 12- the scenario you have and would be the number you then would 13 use in the PRA work sheet? f-~s 14 If I'm stating this wrong, please correct. 15 But that.your system is, in fact, what the-ORO ( -
- 16 people are being instructed to do in their protective action' 17 decision-making training, and it's consistent with their 18 drills and exercises on protective action' decision-making?_' .
19 MR. TURK: You mean.TRAD and I-DYNEV are 20 consistent with the traffic guide training; is that the
. 21 question?
22 MR. FIERCE: No. 23 The way Mr. Callendrello said he would select an 24 ETE for the protective action work sheet Faking one of the 25 numbers from the table, not interpolating it, transposing [ Heritage Reporting Corporation t (202) 628-4888 l l l- . _ _ _ _ _ _ _ _ _
i I 1 1 REBUTTAL PANEL NO. 16 - CROSS 27024 i l 1 it, or whatever. 2 But taking one of those numbers and putting it O\ 3 into the work sheet is, in fact, what the ORO protective I 4 action decision-makers who will out that work sheet are - 5 being trained to do and, in fact, are doing in their . 6 exercises and drills. 7 THE WITNESS: (Callendrello) Just one 8 clarification. I would provide that evacuation time 9 estimate to the radiological health advisor who in turn 10 would complete the work sheet. I don't fill out the work 11 sheet. 12 BY MR. FIERCE: 13 Q Who are you when you say "I?" 14 You're one of the players in the ORO command i 15 structure? 16 A (Lieberman) Assistant Offsite Response Director 17 for Response Implementation. 18 Q But you're the -- 19 A (Lieberman) The position that's responsible for 20 selecting the evacuation time. 21 Q And you would give that time to the rad health - 22 advisor and then he would use it in the work sheet? 23 A (Callendrello) Correct. . 24 That's also consistent with Mr. Roberts' 25 understanding who is also the -- he is the red team person l Heritage Reporting Corporation (202) 628-4888 1 l
REBUTTAL PANEL NO. 16 - CROSS 27025 I who fills that same position I do. 7 2 3 t- .
, 4 5
6 7 8 9 10 11 l I l 12 13 14 15 i 16 . i 17 18 - 19 20 21 i 22 23 24 25 [ Heritage Reporting Corporation k (202) 628-4888
1 REBUTTAL PANEL NO. 16 - CROSS 27026 1 Q So even though you were to perhaps run a summer 2 weekend in the late evening, you would use what, the summer , , 3 weekend good weather ETE? 4 A (Callendrello) Yes, that's correct. 5 Q And what would you use for a May, mid-May -- what , 6 would be the number you would apply for mid-May, weekday, 1 7 8:00 in the morning, good weather? , I B MR. TURK: Mid-May meaning before May 15th or 9 after May 15th, or do I have it wrong? 10 MR. FIERCE: I just said mid-May. 11 Is there some distinction regarding May 15th? 12 MR. TURK: That may be my misunderstanding. 13 THE WITNESS: (Callendrello) I missed the 14 parameters. 15 MR. FIERCE: Well, I'm responding to Mr. Turk. 16 BY MR. FIERCE: , 17 Q I just said mid-May. 18 What time would you reference if it were mid-May, 19 weekday, 8:00 in the morning, good weather? 20 A (Callendrello) I would use the off-season,
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21 midweek, midday, good weather scenario. 22 Q If it were -- Mr. Turk said something about May - l r 23 15th. - 24 Is there a cutoff between off-season and summer-25 season? Heritage Reporting Corpor tion (202) 628-4888 j
\ H REBUTTAL FANEL NO. 16 - CROSS 27027
;f, 1 A (Callendrello) There is in terms of making
/ .2 . protective actions recommendations for the beaches, the 3 precautionary actions.
-'. 4 We've extended a window to include.what we call 5 . beach season, from mid-May until mid-September, although
~6 mid-May is not the best time to go down to the.New Hampshire 7 beaches.
8 But for the purpose of taking precautionary 9 actions, we have extended our window to those-two ranges, 10 May 1th to September 15th. 11 ~ Q By the way, Panel, this is an aside, but while we
~12 are looking at this chart, which is your Attachment A, I've 13 had this question for the longest time and I just wanted'to p 114 ask it at some point.
4 15 In the description for Scenario 1, it says, " Beach 16 area population at capacity. Employees are at percent of 17 midweek in towns."
,18 There is a percentage figure that's been left out 19 in that printed copy that -- ;
20- MR. TURK: Volume 6 has the number.
- 21 THE WITNESS: (Callendrello) Yes.
- 22. It was left out. It's 70 percent. It's on page 23 10-2 of volume 6. I penciled it in on my version of the 24 procedures. q 25 l
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REBUTTAL PANEL NO. 16 - CROSS 27028 1 BY MR. FIERCE: 2 Q Let me juc go back to the questions I was asking. . 3 Where do you draw the line in selecting between i l 4 summer and off-season, Mr. Callendrello? - ' l 5 , A (Callendrello) I would draw the same line as we " 6 do for the precautionary actions; that is, the May 15th to 7 September 15th time frame. , I 8 JUDGE SMITH: Mr. Callendrello, would you see to 9 it that the three copies of the exhibit offered into 10 evidence are configured to that, that the 70 percent is put 11 in?
.12 MR. TURK: This may be the bound-in testimony, if 13 I'm not mistaken.
14 THE WITNESS: (Callendrello) I would be glad to, 1$ Your Honor. 16 JUDGE SMITH: Oh, it was the bound-in testimony? 17 THE WITNESS: (Callendrello) It is the bound 18 testimony. It was copied from the procedure that I -- 19 JUDGE SMITH: Yes, I just slipped over that this 20 was an exhibit and not -- okay, we're fine. 21 BY MR. FIERCE: 22 Q The bound testimony itself has this printing error , 23 in it, too? - 24 A (Callendrello) Yes. 25 JUDGE SMITH: But he corrected it. Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO. 16 - CROSS 27029 i
,j~s 1 -THE-WITNESS: ' (Callendrello)' No, I did not. It. 1 Aq ,/. 2 was copied from the procedure this way. .The procedures are 13 "in error. They are missing that percentage.
. ll JUDGE SMITH: My point is,'is the one that's bound a 5 into the transcript, you had already corrected it?
6 THE WITNESS: (Callendrello) No , I have not. !
- 7. JUDGE SMITH: No , you haven't. -
8 BY MR.-FIERCE: 9 Q And just let me do one more. j 10 You've got, let's say, a November weekend, it's 11; 3:00 in the morning, with rain. 12- A -(Callendrello) I would use Scenario 9, which is 13 off-season, weekend, all day rain scenario. 14 That scenario is also applicable to midweek
/-~k l
,'V 15 evening. 16 - Q Okay. 17 Now this is a question that might be beyond the 18 scope of your knowledge, Mr. Callendrello, and tell me if it ; 19 is because it's really a question about the liaisons, and I 20 perhaps I was neglectful in not putting it to Mr. Robinson 21 when he was here. 22 But when an ORO liaison is asked up at 23 Massachusetts Department of Public Health or wherever he is, 24 civil defense headquarters, about this chart that we're ,
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25 looking at and is asked, what's the ETE for Amesbury and
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- - - - _ - _ _ _ _ _ _ _ _ - _ _ - - _ - i
1 l REBUTTAL PANEL NO. 16 - CROSS 27030 1 t 1 Salisbury for Scenario 1, is the ORO liaison going to say, 2 well, for five miles it's 6.20, and 10 miles it's 6.40? . 3 or is the liaison going to say, well, these are 1 4 the ETEs for the regions that contain Amesbury and 5 Salisbury, and the ETEs for these regions are shown here, ,, 6 but I can't tell you what they ETE is for just Amesbury and 7 Salisbury for Scenario 1? 8 Do you know which of those two kinds of responses, 9 or any other response the ORO liaisons are going to offer? 10 MR. TURK: Are you asking whether they are trained 11 to be specific and to identify -- 12 MR. FIERCE: Yes. 13 MR. TURK: -- what the ETE is for a region rather 14 than for those two particular towns? 15 THE WITNESS: (Callendrello) I don't know 16 specifically what they would give. I would expect them to 17 give your latter explanation and that is, the evacuation 18 time estimates we have are for the regions that include 19 Seabrook, Hampton Falls, Hampton Beach, as well as Amesbury . 20 and Salisbury.
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21 BY MR. FIERCE: 22 O Why do you say that? , j 1 23 Does the liaison training include this point? 24 A (Callendrello) I believe the liaison gets 25 protective action recommendation training, although I would I I i Heritage Reporting Corporation (202) 628-4888 OJ 1 1 I __---_ _ _ _ _ _ _ _ _ i
i REBUTTAL PANEL NO. 16 - CROSS 27031 j rx 1 have to check the training matrix to see if they get that ( l N7s')- 2 training. i 3 JUDGE McCOLLOM: And if they do get that training, ,
^
4 would they have had that instruction then? S THE WITNESS: (Callendrello) Yes. They get 6 trained on what the evacuation time estimates are. 7 BY MR. FIERCE: 8 Q If the Massachusetts officials are informed that 9 this is not the ETE for Amesbury and Salisbury for Scenario 10 1, but for those critical paths for New Hampshire and 11 perhaps 286 for Region 13 and Region 8, and the 12 Massachusetts official says, well, can you tell me what the l 13 ETE is for Amesbury and Salisbury, do you know what the (N 14 liaison will say?
', ) 15 A (Callendrello) Probably would say, I don't know 16 what it is for those communities. I'll check with the EOC, 17 with the folks at the EOC. l 18 Q Okay.
19 You are back at the EOC and you get that call. , 20 What do you do? 21 A (Callendrello) I would say, we don't have that 22 information.
. 23 Q I want to move on and discuss the sensitivity runs 24 described on page 50 for a few minutes. This is again where 25 we're describing the 10 anticipated accidents from defined (3 Heritage Reporting Corporation 4 )
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REBUTTAL PANEL NO. 16 - CROSS 27032 1 statistics based on the vehicle miles of travel expended 2 during the evacuation. 3 Can I ask the Panel what defined statistics you 4 are referring to? 5 A (Callendrello) This section is a compilation of 6 the testimony that was provided in Applicants' Direct No. 7 7 at the pages we cited, 62-63. 8 Mr. Lieberman can verify this, but I don't believe 9 we ac'ded any new information to this. 10 Q Okay. 11 A (Callendrello) It was, again, a repetition of 12 what was contained there. 13 Q Well, as I recall it, and Mr. Lieberman can 14 correct me if I'm wrong, it comes from statistics that have 15 been gathered from various evacuations which have been 16 observed over a period of years. 17 Is that correct? 18 A (Lieberman) No. 19 These are based on nationwide accident statistics 20 where you can derive the number of vehicle miles, the 21 average number of vehicle miles associated with an accident - 22 from nationwide statistics. 23 And since we know the total vehicle miles within . 24 the evacuation, then we simply use that figure and came out 25 with 10. It's roughly one accident every 100,000 miles, i l Heritage Reporting Corporation i (202) 628-4888 1 m______-- _ _ _ _ J
REBUTTAL PANEL NO. 16 - CROSS- 27033 r4 i 1 vehicle miles. {
's / 2 Q Nationwide, on average.
3 A (Lieberman) Right. 4 Q Do you have any statistics about the accident 5 rates which occur during Level of Service F conditions? 6 A (Lieberman) There have been studies conducted to 7 determine how volumes, traffic volumes influence accident 8 rates, and it's a source of considerable controversy among 9 safety specialists. 10 Everyone agrees that the number of accidents i 11 increases. There is disagreement as to whether the accident 12 rates increase. There is evidence to suggest that they do. 13 There is other evidence to suggest that they don't, depending, I suppose, upon how you collect and analyze the (~'}/ t
.14
' ' ' 15 data and the locations where the data are collected, i 16 Q You are aware of the studies Dr. Ceder has done 17 and were placed in evidence in New Hampshire proceedings, 18 correct?
19 MR. TURK: Your Honor -- . 20 MR. DIGNAN: Your Honor, I'm going to object. If 21 there is anything that's res judicata, it's that one. l l 22 You remember Ceder went down and he had an 1
. 23 absolute probability of one that there was going to be an 1
24 accident. And we cross-examined him. And the Board's 25 finding on Ceder in this whole respect was, "He was easily { Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 27034 ;
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1 fended off", citing our proposed findings which were not ! 2 kind to Dr. Ceder, OI . ! l 3 This is a repeat, Your Honor, of exactly -- I' m j 1 4 looking at my proposed findings. The Board did not - '! 5 reproduce these in the decision. He was asked as we brought 6 up the fact that accident facts had this 100,000, although 7 in New Hampshire, Mr. Lieberman expressed it as 10.9 out of , 8 a million. 9 This is a repeat of what we went through in New 10 Hamp3 hire, and if it was anything that was, I think, flatly 11 decided by the Board out of the New Hampshire hearings, it 12 was that Dr. Ceder's accident analysis didn't get it done. 13 MR. FIERCE: Well, I'm just laying some 14 groundwork, Your Honor, for questions that I have here about 15 statements in this testimony that this study -- 16 JUDGE SMITH: Are you going to cross-examine them 17 on Dr. Ceder? 18 MR. FIERCE: No. 19 JUDGE SMITH: You are going to use Dr. Ceder's -- 20 what are you going to do? 21 MR. FIERCE: Well, that was just a further 22 commentary on the point that Mr. Lieberman had made that 23 this is an area of perhaps some controversy, he says. . 24 MR. TURK: Your Honor, the testimony that's being 25 cross-examined is simply a recitation of the testimony that Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27035
, _x 1 was presented before you in New Hampshire. On page 50, all / i \ ,) 2 you have are references back to Applicants' No. 7.
3 MR. FIERCE: I'm curious about the concern here.
. 4 Does this mean I'm barred from cross-examir,1g 5 testimony that has been presented now?
6 JUDGE SMITH: Well, that's the problem. He's not. 7 So it makes it a complicated -- 8 MR. DIGNAN: My problem was not cross-examining 9 the testimony presented. It's trying to revive Dr. Ceder. 10 MR. FIERCE: Well, who brought the issue in? 11 MR. DIGNAN: To quote myself in the appellate 12 brief, I thought we had left him "in the forest." No pun 13 intended. x 14 (Laughter) I l \ s- / 15 MR. FIERCE: You state here on page 50 that, "The 16 study adopted the overly-conservative assumption that all 17 accidents result in roadway impediments." 18 BY MR. FIERCE: - 19 Q Can you tell me what you mean here by 20 " impediments"? 21 MR. TURK: Your Honor, I want to renew my 22 objection. 23 JUDGE SMITH: What's your objection? 24 I thought we avoided making a ruling there. 25 MR. TURK: Maybe I misunderstand the justice or [' 1 Heritage Reporting Corporation ( ,) (202) 628-4888
l REBUTTAL PANEL NO. 16 - CROSS 27036 1 the merits of my cause. 2 But it's my understanding that the testimony was , 3 presented before. Mass AG had a full opportunity to l 4 confront it back then. Whatever they were able to do at l 5 that time, they did, and that's it. , l 6 The mere fact that this Panel is now referring 7 back to other evidence that was put before you and was ! l 8 subjected to cross-examination in New Hampshire doesn't mean l 9 it gets a whole new round of cross-examination. 10 JUDGE SMITH: What. 's the question? 11 MR. FIERCE: There is a sentence on page 50 that 12 says, "The study adopt the overly-conservative assumption 13 that all accidents result in roadway impediments." 14 And I would like him to describe for me what he 15 means by " impediments". Is that a complete blockage? 16 MR. TURK: My problem, Your Honor, is that -- 17 JUDGE SMITH: I thought -- 18 MR. TURK: I'm sorry. 19 JUDGE SMITH: Go ahead. 20 MR. TURK: My problem is this is a recitation back
~
21 to evidence that was before you already. 22 Now, if they were putting forward new evidence , 23 along the same line, maybe he would have an argument to say, - 24 well, I never had an opportunity to confront this before. 25 But he doesn't say that. Heritage Reporting Corporation (202) 628-4888
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- k. REBUTTAL PANEL NO. 16 - CROSS- 27037'
-1. He's just saying, well, it's here. Therefore, I
.7, %s . ,
e x_ / 2 have a second chance. I 3' ' JUDGE SMITH: It is there. 4 MR. TURK: Yes. 5- JUDGE SMITH: But he does'not have a second chance 6' to litigate it, but he-can ask what they mean by it, which 7 is'what he purports to be=doing. 8 MR. TURK: I don't see any reason for that unless 9 he intends-toisubmit a proposed finding.about this matter. 10, JUDGE SMITH: Well, you are not cross-examining. 11 I'have to admit I don't know where you are-going j 12 cn1 your cross-examination. But.just looking at the question i 13 in a very narrow sense, I don't see why you can't ask it.
. / 14 But for what purpose?
-f 15 It'may be for a purpose that indeed would be 16' ' covered by Mr. Turk's objection.
-17 LMR. FIERCE: Well, I can show you where I'm going, 18 Your. Honor.- Again, I've got a page of questions here. And *
-19 I'll'tell you this much. }
20 It's focusing on the Massachusetts aspects of this 21 issue. 22 MR. TURK: On the theory that Massachusetts is
, 23 going to have accidents unlike accidents in New' Hampshire?
24 MR. FIERCE: Come on, Sherwin. 25 MR. TURK: No, that's the point. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27038 1 MR. FIERCE: Get serious. 2 MR. TURK: Unless you are going to show that there 3 is some new issue that hasn't been considered. 4 MR. FIERCE: Well, I'm going to get there. It .- 5 will take me about 20 seconds and I'm going to ask some 6 questions about Massachusetts. I just want to know what 7 we're talking about when we're talking about road 8 impediments in the model. 9 MR. TURK: It's hard to say no to just one kiss. 10 (Laughter) 11 MR. FIERCE: I'm not saying that we have no 12 knowledge of this. It seems to ng my recollection was that 13 it wasn't a complete road blockage. It was only a partial, 14 and my memory is fuzzy as to how long or the extent of 15 capacity reduction. I'm just trying to clarify that, 16 because then I'm going to ask him where in Massachusetts he 17 placed these 10 accidents. 18 19 20 21 - 22 I 1 23 J 24 25 j l l Heritage Reporting Corporation (202) 628-4888 l l l j
I REBUTTAL PANEL'NO. 16 CROSS 27039- j 1- JUDGE SMITH:- All right. I g_,) [2 THE WITNESS: (Lieberman). I guess there are two 3- questions.
. .4= BY MR. FIERCE:
5 Q Well, I just wanted to ask you one, , p . <: 6 First' you've got these roadway impediments; can 7- .you tell me what.they.are and how they impacted the model? 8 A (Lieberman) Again, my recollection is fuzzy, 9- -also.- But as I recall, on a multi-lane highway an accident 10 reduced the number of lanes by one with a consequent
- 11. reduction in' capacity.
12 13n a one-lano roadway it halved the capacity of 13 that' load rate. jf s 14 I'm doing this by recollection and I hate to do it
-l ~
. 15 that.way. But subject to check it's the best I can give you 16 in short term. And maybe I shouldn't have relied upon my 17 memory.
18 Q All right. - 19 Do you recall the time durations for the existence . 20 of these impediments? 30 to 60 minutes?
- 21 A (Lieberman) Well, they're given on page 63 of the 22 Direct Testimony No. 7 23 Because it's a kind of Monte Carlo experiment my 24 recollection is that we did four runs in each set. And we 25 had for two series of runs -- the first two series of rurs:
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REBUTTAL PANEL NO. 16 - CROSS 27040 1 one for scenario 1; one for scenario 5. The impedance is 2 varied between one and two-hours. 3 For the second series of runs the impedance has 4 lasted between two and three-hours. 5 Q Okay. , 6 MR. DIGNAN: Before we pursue this too much I 7 think it is important to -- I guess I'll make an objection 8 and then I have the right to the floor. 9 To put this in perspective: leading into this 10 discussion of the accidents is page 49 of the testimony. 11 Just so Your Honors understand what it says. 12 And if you look at the next to the last paragraph 13 of that this is the conclusion at which the witnesses are 14 expressing that the following parameters vary with scenario. 15 And then they go on in that last paragraph to say: 16 "The SPMC ETEs provide all the necessary information and 17 parameters." 18 And then again anticipating a de'fense: "It is not 19 possible nor prudent to attempt to analyze in advance every 20 situation that could occur." 21 And then what is used is an illustration out of - l 22 what has already been litigated. You know, we ran the 10 1 23 and it showed that it really didn't make much difference. I _ l l 24 don't think it was necessary nor is the testimony intended 25 to put in litigation whether those runs were any good. It Heritage Reporting Corporation ' (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27041 1 was rather to reference the fact that the runs had been 2 made. 3 Now, as I said to Your Honor earlier, you made no l
. 4 specific findings on these matters. However, you did, in ]
5 dealing with Dr. Ceder, you stated: "I-DYNEV is an 6 analytical tool developed -- this is 9.21 by KLD. "It 7 contains an equilibrium," I'm sorry, I'm missing it. 8 Then the next one, 9.22: "Although the j 9 Massachusetts Attorney General through his expert witness 10 Dr. Avishai Ceder criticized the I-DYNEV model on many 11 grounds and criticisms. The Applicants and Staff handily ; 12 fended off his criticisms." And at that point you cite and 13 I would say adopt, because you're citing it for the 14 statement made in the decision: " Applicant and Staff 9 15 proposed findings 6.1.15-6.1-53." 16 JUDGE SMITH: That'e right. 17 MR. DIGNAN: Now, Applicants 6.1.42 says: "A 18 series of sensitivity tests were undertaken to quantify.the 19 affect on ETE of highway impediments." Four runs and so 20 forth and so on, and we give the conclusions.
. 21 And then at 6.1.43 begins: "10 accidents were 22 simulated in each run from this number and represents 23 anticipated number of accidents from defined statistics."
24 This is the same thing we just heard redone over 25 again. 9 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27042 1 I don't know, one of the problems -- not a problem 2 -- one of the things we had in this case is, of course, we . 3 have two members of the Board who did not sit through New 4 Hampshire. All this is an illustration to backup our 5 statement which the substantive statement in the testimony , 6 is: it's not possible or prudent and, indeed, we think 7 unnecessary to go beyond the parameters that we have 8 included. 9 And I don't think a fair reading is to take page 10 50 and 51 and put up for litigation again what has been 11 decided by the Board. It was an illustration of what we 12 have done in the past and that the Board has decided -- as I 13 read the finding -- is a valid point. 14 MR. FIERCE: May I respond, Your Honor? 15 JUDGE SMITH: Yes. 16 'The difficulty is, when you tell me what you' re 17 doing now I think I understand what you said, but I guess I 18 don't really understand what you're doing. 19 MR. FIERCE: Well, I want to explain. ,1 20 I believe this is another one of these second
- 1 21 layer issues, if you will. We had litigation in New 1 22 Hampshire over the accuracy of the ETEs and what we are ~
\
I 23 litigating now is the accuracy of the Massachusetts ETEs. - l 24 Now, there may have been reference to this in New j 25 Hampshire with respect to showing that the overall ETE -- I Heritage Reporting Corporation (202) 628-4888 1
_g-- i i l 1 I REBUTTAL PANEL NO. 16 - CROSS 27043 7- g 1 and perhaps for some regions -- doesn't change.
"_h I
2 But I think it's beyond purview that where these 3 accidents get placed in these simulations is going to make i 4 the difference in how the simulations come out. 5 And I would like to ask some questions about the ! l 6 placement of these accidents with respect to the 7 Massachusetts critical pathways. 8 JUDGE SMITH: See, this is where I say, oh, okay, 9 that's great, that makes sense. 10 MR. FIERCE: To see whether those runs -- 11 JUDGE SMITH: But when you're talking about 12 simulation -- 13 MR. FIERCE: I want to know if those runs -- ('~ 14 JUDGE SMITH: I can't relate what you' re doing to
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\~ 15 the real world of Massachusetts pathways and the testimony 16 from New Hampshire. You cross that bridge and I don't go 17~ across that bridge with you.
18 MR. FIERCE: Let me just pose the situation as a 19 hypothetical. , 20 If I were to ask Mr. Lieberman, were all these 21 runs -- all these accidents that were simulated in those 22 sensitivity studies in New Hampshire, that I believe I could
. 23 validly before you in this proceeding propose a finding that 24 says the sensitivity runs that you were looking at New 25 Hampshire and you cited in the PID have no applicability to ln')
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REBUTTAL PANEL NO. 16 - CROSS 27044 1 the issue of whether a random selection group of accidents 2 in the Massachusetts roadways, and particularly on the 3 critical pathways, might have some impact. 4 Now, I'm not sure. I want to ask some questions - 5 about where these accidents were placed and see if, in fact, . 6 the sensitivity runs that they're referring to here to 7 support their claim that the Massachusetts ETEs are 8 accurate, in fact, follows. ! 9 (The Board confers.) 10 JUDGE SMITH: What do you say about the testimony 11 that these were randomly selected, high-volume EPZ 12 evacuation links? 13 JUDGE COLE: Over varying and substantial periods 14 of time? 15 MR. FIERCE: Well, there's only 10 of them, Your 16 Honor. And it may well have been randomly selected. 17 JUDGE SMITH: You don't think that was 18 statistically sufficient? Then was your chance to challenge 19 that. 20 MR. FIERCE: They are using those runs now to 21 support their claim that for the Massachusetts ETEs these - 22 runs also show significance. 23 MR. DIGNAN: No. No. . 24 That's my point. What we're using it for in here 25 is to come over, back to page 49, we state what parameters Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27045
,s - 1 vary with scenario in the region to be evacuated. And we're
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x _,j 2 going on simply to make the point, it's not possible or 3 prudent to attempt to analyze in advance every situation
. 4- which could occur. And then give as an illustration the 5 fact that we run sensitivity runs on the accident problem 6 and it wasn't a problem.
7 And plus the fact, I would remind the Board -- - 8 MR. FIERCE: It's not going to be -- 9 MR. DIGNAN: -- they included in the findings that 10 you cited, in addition to these ones on the model, you 11 adopted findings to the effect that: "The authoritative 12 publication accident facts published by the National Safety 13 Council shows statistics derived from the total national f-~3a 14 experience including travel at high speeds which give rise
\- / 15 to a calculation of 10.9 accidents of all kinds per million 16 vehicle miles will occur."
17 And then a finding was adopted: "An. evacuation of 10 the Seabrook EPZ would involve approximately 1 million . 19 vehicle miles of travel in the EPZ during evacuation time." 20 This is another key finding you adopted: "In
- 21 actual fact there have been no reported fatal accidents in 22 over 100 million personal miles, about 40 million vehicles 23 miles of experience in the United States with actual 24 evacuations."
25 If it's one issue that I think got put to bed up
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I REBUTTAL PANEL NO. 16 - CROSS 27046 f 1 in New Ha'.npshire by your adoption of those findings was this I 2 whole question of accidents and its effect on evacuation 3 times. I l 4 I don't know, maybe the easiest thing is to point .- 5 that back out to you in another set of findings and let this j 6 roll on. But, boy, that one got beat to death up there. 7 (The Board confers.) - 8 JUDGE SMITH: We believe that you had the 9 opportunity to challenge the random selection, the 10 statistical approach for testing the accident frequency used 11 in New Hampshire. It doesn't have a particular relationship 12 to New Hampshire nor a particular relationship to 13 Massachusetts. 14 MR. TURK: May I also point out, Your Honor, that 15 the testimony indicates the random sampling was done for 16 Region 1, which lncludes Massachusetts portions of the EPZ. 17 Now where the random -- where the actual location 18 of the similar accidents was in that entire EPZ, I don't 19 know. But if it was randomly selected for the entire EPZ, 20 then that includes Massachusetts as well. 21 JUDGE SMITH: Which is the way accidents happens. 22 MR. FIERCE: May I respond, Your Honor? . 23 JUDGE SMITH: Sustained. . 24 MR. FIERCE: Well, then, Your Honor, at this point 25 I move to strike from the testimony the relevant paragraphs Heritage Reporting Corporation (202) 628-4888 i
7 l REBUTTAL PANEL NO. 16 - CROSS 27047 7~~ 1 on pages 50 until the end of that section in discussion of s
) 2 those sensitivity runs.
3 JUDGE SMITH: The objection was sustained because
. 4 you were cross-examining with the wrong premise of those 5 sensitivity runs. Not that these sensitivity runs were 6 irrelevant to the issue before us.
7 I don't understand what you're doing. - 8 MR. FIERCE: Well, maybe I just don't understand 9 what the Board is doing, I'm sorry. 10 What was sustained? 11 JUDGE SMITH: In our earlier mutual understanding 12 you lose and you got to win -- 13 MR. FIERCE: .Can you tell me what has been g~ ' 14 sustained? Further cross-examination on any portion of N.- 15 these sensitivity runs because the issue is res judicata? 16 JUDGE SMITH: The question. What was the 17 question? It was about Massachusetts accidents. Accidents 18 in Massachusetts, which we said was not related to this - 19 concept of randomly selecting accidents. } 20 MR. FIERCE: I just wanted the Board to know, I'm 21 not challenging the random selection issue. 22 Let me ask this question and if the Board wants to 23 sustain it, it will be clear for the record. 24 25 [~h Heritage Reporting Corporation u.] i (202) 628-4888 l I 1 s I 1 _________A
REBUTTAL PANEL NO. 16 - CROSS 27048 1 BY MR. FIERCE: 2 Q Are any of the 10 accidents that were selected on 3 critical paths for Massachusetts ETEs? 4 JUDGE SMITH: I just don't understand. 5 MR. FIERCE: Okay. , 6 MR. DIGHAN: Can you answer that? 7 MR. TURK: Your Honor, no objection has been made 8 on that question. l 9 MR. DIGNAN: No objection has been made yet. 10 I think we will shorten it up. He either knows or 11 he doesn't know. We will get an answer and go from there. 12 JUDGE SMITH: All right. 13 No objection. 14 THE WITNESS: (Lieberman) I cannot say with 15 absolute assuredness that there were accidents on the 16 critical paths. I could only do that by looking at the 17 listings. 18 I can, however, describe how we did it and assure 19 you that, yes, there were accidents in Massachusetts. Yes, 20 they were only heavily-loaded links. 21 BY MR. FIERCE: 22 Q But you're not sure they were on the critical , 23 paths for Massachusetts ETEs? . 24 A (Lieberman) Well, I'm not sure what you mean by 25 Massachusetts ETEs. Heritage Reporting Corporation (202) 628-4888 s
REBUTTAL PANEL NO. 16 - CROSS 27049 7-~ 1 Q The ETEs that it would take to evacuate -- let's As) . 2 take the ERPAs, ERPA B or ERFA-3. 3 A (Lieberman) There were accidents on the heavily- l
}
4 loaded roadways within Massachusetts. I would have to go j 5 back to the listings to tell you where they were. 6 Q The ETEs that are referenced here in the testimony 7 are for Region 1, Scenario 1 only, correct, in terms of the 8 conclusion from the sensitivity runs? 9 A (Lieberman) Region 1 and Scenario 1. 10 Q And Region 1, Scenario 1 ETEs have critical paths 11 in New Hampshire, correct? 12 A (Callendrello) Mr. Fierce, just for 13 clarification. f'~'N 14 We have referenced the Region 1, Scenario 1, N\ h 15 Applicant's Direct No. 7, and also included Scenario No. 5 16 as well. 17 MR. DIGNAN: And the testimony the Applicants gave 18 with respect to five was laid out in a Proposed Finding 19 6.1.42 which is one of the ones adopted in the initial } 20 decision.
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21 JUDGE SMITH: It's time for a break. 22 Ten minutes.
. 23 (Whereupon, a recess was taken.)
24 BY MR. FIERCE: 25 Q It's my understanding that Mr. Lieberman has come i I l l f'~\ Heritage Reporting Corporation !
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REBUTTAL PANEL NO. 16 - CROSS 27050 1 up once again with some information for us over the break. 2 A (Lieberman) Yes, I have. 3 You asked for the turn percentages at Salisbury 4 Square with and without guides. 5 Q Yes. . 6 A (Lieberman) Without guides, the turn percentage 7 is 20 percent left, 80 percent through. And with guides, 8 it's 100 percent through. 9 You asked for the same information at Route 286 10 and Route 1. 11 Q Yes. 12 A (Lieberman) For, I suppose, the westbound 13 evacuees. 14 Q Right. 15 A (Lieberman) Without guides, it's 25 percent left, 16 75 percent through. With guides, it's 14 percent left, 86 17 percent through. 18 And in checking the TCP diagram, I noticed I left , 19 out the left-turn arrow. So that has to be corrected. That 20 is, left turn from the westbound approach on 286, onto the 21 southbound Route 1. Just left out the arrow. 22 You also asked when do New Hampshire guides arrive . 23 at Seabrook, and that I haven't had the opportunity to get . 24 for you. 25 0 Okay. 1 Heritage Reporting Corporation ' (202) 628-4888 _ _ _ _ _ _ _ _ _ - - - - - - - - - - - - - 1
REBUTTAL PANEL NO. 16 - CROSS 27051 i; 1: 'You're still making-the assumption, I see,!Mr. , I,k l Lieberman, that vehicles.in a "without guides" situation are. 2 (f.
- 3. ~ going to be traveling, voluntarily turning north on' Route 1 f
'4 either.at Salisbury Square or at Route 286, correct?
5 A- '(Lieberman) Not north. Not' north. i l They make a left turn from the westbound R 6 South. 7 approach. 'They are traveling south. 8 Q -That's right. You have none of the vehicles 9' turning right -- 10 A: (Lieberman) That is correct. 11 -Q -- on Route 1 either at Route 286 or at Salisbury 12 Square? 13 ~A - (Lieberman) That.is correct. That would be j- 14' toward the' plant. i]\_ 15 Q And you are still making that assumption. 16 - And somehow the TRAD model has taken that i7to. 17 consideration, or did you find that that just was a 18 fortuitous result of the way you had directed the potential - 19 routings, the destination nodes for those vehicles? 20- A (Lieberman) Well, I'll have to chech that.
. 21 (Witnesses review document.)
22 A- (Lieberman) No, it's not fortuitous. 23 The way we modeled it is that right turns were not 24 compatible with evacuation routing. That is, movement north 25- toward the plant were not consistent with evacuation Heritage Repotuing Corporation lq (202) 628-4888
REBUTT.AL PANEL NO. 16 - CROSS 27052 ) 1 movement. 2 O On page 51, actually it begins on page 50, carries 3 over to 51, there is a discussion of another sensitivity run 4 here regarding the beach population, and reducing the beach 5 population by, as you have here, up to 60 percent. 6 I just want to clar'ify that these are runs that 7 were done, first of all, on the Avis data and the Avis 8 numbers, not the 21,000 vehicles, correct? 9 I see the citation again from your Direct 10 Testimony No. 7 in New Hampshire. So I'm assuming that 11 that's using Avis data, not the recommended number the Board 12 came up with subsequently in the P7D. 13 JUDGE McCOLLOM: It says it right there, "as 14 . determined from the data provided by Avis. " , 15 BY MR. FIERCE: 16 Q And can I also assume that you are using the beach 17 ratios that we discussed earlier? 18 A (Lieberman) It's an across-the-board -- 19 Q Application of Avis? - 20 A (Lieberman) That's correct. l 21 Q Okay. - { i 22 Again, it's looking at the overall ETE, correct? i l 23 A (Lieberman) May I interrupt? .
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24 Q Yes. 25 A (Lieberman) It is true we' re using the Avis data, j l Heritage Reporting Corporation (202) 628-4888 !
REBUTTAL PANEL ~NO. 16 - CROSS 27053 I
- . g; . l' -but we'have the'1440'in'there. I.can tell that from the f
\ f. 2' ' ' fact that the peak ETE is 7.40, and that derives from the --
3' if you go back to page 44 where we discussed the various 4 -4 factors'that have been introduced, and.then provide the 7.40 5' figure at the bottom of page 46. 6 So that does include 1440 cars added to the Avis 7 data. - 8- -Q Those ETE numbers again, those'are Region 1, 9 . Scenario.1 numbers, correct?. 10 A (Lieberman)- That is correct. Ell - Q Do you know what the Salisbury Beach, or Salisbury 12 ETE reduces to when you reduce the Salisbury Beach 13 ' population'by 60 percent? 14 A (Lieberman) Again, I would have to go into the f _ t 3 15 listings.. I don't know it offhand. 16' Q It could be more than a third reduction, correct? 17 A (Lieberman) I don't see why. 18 I would be speculating if I said yes or no. - 19 Q Well, let me just query this briefly.
'20 The Salisbury ETE is really determined by the
. 21 beach population. The last vehicles to clear out of 22 Salisbury are going to be coming off of Salisbury Beach.
23 Isn't that true? 24 A (Lieberman) That's true, but you have to keep in 25 mind that there is a merging of traffic from elsewhere in f Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 27054 l I 1 Salisbury onto the Route 110 west. They come down Route 1 2 and they merge. And they, of course, are not affected by -- 3 that is, their volumes are not affected by the beach
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4 volumes. 5 So while it's true that folks from the beach are . 6 the last to get out, you can't ignore the role played by the 7 in-town evacuees. 8 Q Right. 9 But that's a much lower number of evacuees 10 overall, isn't it, than the beach numbers? 11 A (Lieberman) It is lower, but it remains 12 unchanged, you see. i 13 Q Right. 14 I mean, we can look probably at Appendix M even , 15 now and see what those numbers are, correct? 16 A (Lieberman) Right. 17 Q The beach population reduced by 60 percent, don't 18 you believe would have probably at least a 50 percent ! i 19 reduction in the ETE for Salisbury Beach? . 20 A (Lieberman) For the beach? 21 Q For Salisbury. 22 MR. TURK: What is the ETE for Salisbury? . 23 MR. FIERCE: ETE for Salisbury, the time to clear . 24 Salisbury. 25 MR. DIGNAN: What contention is that coming out Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27055 1 of?
,6 .
2 MR. FIERCE: I'm litigating the ETEs for 3 Massachusetts. Always have been.
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4 MR. DIGNAN: Yes, but aren't I right -- 5 JUDGE SMITH: And always will. 6 (Laughter) 7 MR. DIGNAN: Aren't I right -- 8 MR. FIERCE: No. 9 MR. DIGNAN: Aren't I right that the contention 10 was that the ETEs we had were inaccurate rather than we 11 should have had some different ones? 12 MR. FIERCE: Well, inaccurate for Massachusetts. 13 Also, we've got a contention that says you have no 14 ETE study for Massachusetts. 15 MR, DIGNAN: No , wait a minute. 16 JUDGE SMITH: I'm surprised to hear you point out 17 that there's no contention that covers this. 18 MR. DIGNAN: Well, that's because my very bright 19 young people just advised me of it. , 20 If you think I retain all of this, maybe I should 21 leave the illusion that I' m that smart, but I'm not. 22 THE WITNESS: (Lieberman) No.
. 23 I wouldn't subscribe to that. Just looking at the 24 numbers --
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REBUTTAL PANEL NO. 16 - CROSS 27056 l 1 BY MR. FIERCE: 2 Q You're in Appendix M? , 3 A (Lieberman) I'm in Appendix M. 4 Q What page? 5 A (Lieberman) M-2 and M-1. , 6 Q Now these numbers are not the Avis numbers, 7 correct? 8 A (Lieberman) I understand that. 9 Q These go back to your Volume 6 totals. 10 A (Lieberman) Right. 11 That works against you, as a matter of fact. 12 Q Because you had more Salisbury Beach vehicles in 13 Volume 6 than you do in the Avis data. 14 Is that what you are saying? 15 That is in fact the case, correct? 16 A (Lieberman) Well, there are more -- that's right. 17 Well, there are 11,400 trips, and there are about 18 7300 people from the beach areas. 19 So if you reduce the beach areas by 60 percent, , 20 you're cutting about say 4300 from the 7300. So you've lost
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21 3000 out of the 11,000, which is 26 - 27 percent. 22 Now you can't rush and say, well, that translates , 23 into an ETE that's lower by 27 percent, because you've got 24 guys coming down from the north and that sort of thing. But 25 it does argue against a linear relationship, or a Heritage Reporting Corporation (202) 628-4838 4
27057' REBUTTAL PANEL NO. 16.- CROSS 1 near-linear relationship that you are suggesting. That a 60
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i - ;2> percent reduction in the beach area should produce a 50 13 . percent reduction in the ETE. I don't think that will
*T-4 happen, r
'S 'Q. These runs also reflected.in the testimony do not l ,
15 contain.- 'I'm groping for the word:- do not utilize the.
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7: new revision to I-DYNEV, and as a result'of.TRAD which - (
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8 causes some beach vehicles from Seabrook to be assigned down 9 into Massachusetts, correct? 10 'A (Lieberman) Well, the old runs did not send 11' people into' Salisbury from Seabrook, if that's --~that's 12- what.you just said.. 13 I'm sorry. Say it again. t f-~s -14 'O Well, these runs which show the Scenario l's, N - 15; moving away-from the concern about Salisbury for a moment. 16 - The overall ETEs lieted here,-if those runs had 17 been done with the model as it now is, assigning some beach 18 vehicles down into Salisbury, wouldn't the ETEs overall have - 19 been reduced further? 20 A. (Lieberman) But it does do that. 21 What I said when I interrupted you is that these
. 22 runs represent the late guides, the latest series'of runs to 23 this point, during which time the "before guide's case" you 24 had left turns at Salisbury Center and so forth.
- 25 Q Do you have any empirical information.regarding i
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I REBUTTAL PANEL NO. 16 - CROSS 27058 j i l-i 1 what percentage of the Salisbury Beach population drops off 2 from a peak summer weekend midday to a Sunday late evening? - j { 3 MR. TURK: " Empirical" meaning actual observed l l 4 drop offs in traffic? 5 MR. FIERCE: Any empirical data. It may not be , 6 observed. It may be -- ] 1 7 MR. TURK: Well, " empirical" means something l 8 that's been observed. 9 MR. FIERCE: It may be there are projections based 10 from something observed, or counts that have been done on 11 other days that could be projected to the weekends. I don't 12 know. 13 THE WITNESS: (Lieberman) Yes. 14 There's a wealth of empiric 11 data, as you know, 15- from the HMM data collection summues, 1982-1983, which would 16 provide that. 17 BY MR. FIERCE: 18 Q It doesn't isolate Salisbury Beach, though, for 19 us, does it? . 20 A (Lieberman) Yes. ; 21 You have detectors placed on Beach Road and there 22 is another one at Route 1A near 286. So you can -- I think . 23 you can isolate Salisbury from that. . , 1 24 25 l Heritage Reporting Corporation (202) 628-4888 l 1 l 1 i l ____ _ _ _ _ _ i
i REBUTTAL PANEL NO. 16 - CROSS 27059 ) I
, - ~ 1 Q The beach population on Salisbury Beach could drop ]
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x_,/ 2 off by 75 percent from a summer peak, reasonably peak l 3 expectable weekend to a late Sunday night when the weekend
- 4 motel stayers have left as well, couldn't it?
5 A (Lieberman) I just don't know. 6 Q Fewer hotels and motels per beachgoer in Salisbury 7- Beach than in Hampton Beach? 8- A (Lieberman) Yes, that's correct. 9 Q A greater percentage of the beachgoers in 10 Salisbury are day-tripers? 11 A (Lieberman) I'm not sure that's true.
'12 I think there are more homes. The predominate 13 number of people are in Salisbury, because they have summer 7-~g 14 homes there and families share apartments and so forth, t
i
\s- 15 As you said yesterday, the big lot in all the 16 films that I've looked at has never been more than half 17 full.
18- So I would just have to look at the data before I - 19 could quantify this. , 20 Q In the -- 21 MR. DIGNAN: Your Honor, may I make a motion here. 22 Do I understand this line is one more attack that 23 there should be more and different ETEs than we've done? 24 MR. FIERCE: This is -- an attack, I don't know.
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25 It's curtainly a challenge to the sensitivity runs --
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I l l REBUTTAL PANEL NO. 16 - CROSS 27060 ; i 1 MR. DIGNAN: Exactly. J 2 MR. FIERCE: -- that are done here on the grounds , 3 that we may have unknown -- it provides little or no
. I 4 information about Shiisbury Beach. {
5 MR. DIGNAN: And we should have done runs or ETEs , 6 just for Salisbury Beach? 7 JUDGE SMITH: Well, that was the theme of his 8 . cross-examination this morning. And I think he has hit that 9 several points along there. 10 MR. FIERCE: You've done it; it's there. 11 MR. DIGNAN: But my point is, the Commonwealth 12 obviously feels from the cross-examination I've heard -- and 13 I know I did miss this morning but my partner briefed me on 14 it -- that we should have one for Amesbury, we should have 15 one for Salisbury, maybe for the beach. We should have done 16 sensitivity runs using different areas. And I understand 17 that's their position. 18 The witnesses have told the Board -- and I hope 19 the direct testimony told the Board -- what we did. There's , 20 no question we didn't do these. And aren't we down to 21 argument now? 22 Now it's up to them to argue to you that these , 23 should have been done. We admit, we didn't do them. No - 24 question about that. 25 And the question is: do the regulations and rules Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27061 ' s 1 require that we should have done them? And that's a matter 2 of argument to the Board. 3 Again, unless we really expect Mr. Callendrello to 4 step up to that mike and say, Mr. Fierce, you're right we 5 did it all wrong and by gosh, we buy it. We should go out 6 there and do 15 more ETEs. And I think the chances of Mr. 7 Callendrello doing that are quite slim. 8 But unless that's the thrust of the cross, we 9 spelled out what we did and they're free to argue we should 10 have done more. And I don't know what more cross-11 examination can do with it, Your Honor. 12 I guess there's an absolute promise and ruling 13 that he's going to finish these witnesses and Urbanik by the
,e~x 14 end of the day today and I should just sit back, relax and
( ) 's / 15 let it happen. But I just don't know where we can go. 16 MR. TURK: Can I note also, Your Honor, I just 17' looked through the contentions again and there's nothing in 18 there that says that the Applicants should have done a . 19 sep& rate ETE for Massachusetts regions apart from any New 20 Hampshire traffic. There's nothing in the contentions. 21 MR. FIERCE: We've gct a contention that is 22 straight out that says, there's no ETE study for 23 Massachusetts. 24 MR. TURK: Which one? 25 MR. FIERCE: You say one? [m't Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 27062 1 JUDGE SMITH: It seems to me, Mr. Turk, that there 2 must have been, o*harvise we wouldn't have been having any l 3 ETE teati-iony here sc all. 4 MR. TURK: No , my point, Your Honor, is: sure, .- 5 there is an ETE that's been done that includes Massachusetts 1 . 6 and as this panel has testified it also includes parts of l 7 New Hampshire in those same two regions, Regions 8 and 13. - 8 There is nothing in the contentions that says they 9 should have done a Massachusetts separate ETE with no 10 inclusion of New Hampshire traffic. It's not there. 11 In fact, one of their contentions says that there 12 was one ETE done for Massachusetts for Region 1 and there I 13 should have been more. Let me get the words on that. 14 MR. DIGNAN: My motion was simpler than that. I 15 mean, I really don't want to fight what's in or out of the 16 contention, that can be done in proposed findings. 17 But as I say, I hope we spelled.out what we did 18 do. And whether that was enough is a matter of argument 19 from there on out. 20 I haven't heard any of these witnesses vary from 21 what we said we did. - 22 MR. FIERCE: The objection here is not pertinent 23 to this particular cross on this sensitivity study, because , 24 I am, in fact, attacking the sensitivity study -- to use 25 your word -- as it stands, for the overall ETE as well. Heritage Reporting Corporation (202) 628-4888
l REBUTTAL PANEL NO. 16 - CROSS 27063 l l s 1 MR. DIGNAN: Then I withdraw the motion, Mr. l
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2 Fierce. i i 3 MR. FIERCE: I'm pursuing a two prong attack here 4 and I think -- 5 MR. DIGNAN: Okay. 6 MR. FIERCE: -- at least that prong of it covers
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7 it. 8 MR. DIGNAN: Okay. 9- The classic pincer maneuver. 10 MR. FIERCE: I'm moving on to the next item. 11 BY MR. FIERCE: l 12 Q' At the bottom of page 51, Panel, you note that the 13 Accident Assessment Coordinator and the Assistant Offsite fN 14 Response Director for Response Implementation briefed the (~l' 15- rad health advisor on any constraints to evacuation in 16 considerations or scenarios which may enhance the estimated 17 evacuation time. 18 My first question is: do they brief about matters
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19 which may reduce the estimated evacuation time? , 20 And if not, why not? 21 A (Callendrello) If you look at the procedure 22 IP-2.5 on page 11 there are several steps listed for the
. 23 Assistant Offsite Response Director, Response 24 Implementation. Let me focus on that position, because the 25 Accident Assessment Coordinator is focusing primarily on If\sx)/ Heritage Reporting Corporation (202) 628-4888 L
REBUTTAL PANEL NO. 16 - CROSS 27064 1 meteorological data. 2 But looking at the assistant director. What the 3 assistant director is doing at that point is, doing an 4 analysis of what protective action should be taken and then . 5 can be taken. We've labeled that as constraints to 6 evacuation. But it really is a two-stage analysis: what 7 should you take because of nonradiological risk; and what - 8 can you take because of the practical needs for implementing 9 such a protective action. 10 And that is really essentially what is done. 11 There's no assessment as to a quantification as to how it 12 affects evacuation time. It is simply -- in some cases 13 there's some judgment. It's a judgment and an assessment of 14 the protective actions on what actions.you can take t6 -- I 15 won't say enhance -- but to make those actions possible and 16 most efficient. 17 Q Well, as I understood the procedures, I thought 18 that there was to be this little discussion in which the rad 19 health advisor was to be advised on, not only constraints to 20 an evacuation but considerations which might lengthen 21 evacuation times so that an appropriate ETE could be - 22 selected, perhaps one from the tables and then interpolated. 23 And that the rad health advisor would then plug in . 24 that revised number in the protective action work sheet. 25 But I gather from what you told me earlier that's Heritage Reporting Corporation (202) 628-4888 ; s
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REBUTTAL PANEL NO. 16 - CROSS 27065 1 l' not the way'it works; correct? g_,) 2' A (Callendrello) That's correct. 3- Q Why have this discussion at all then with the rad:
- 4 ' health advisor?
5 Jr (Callendrello) Well, as I said -- and if you look 6 at the reference -- let's start with the reference for those 7 constraints which is Attachment 7. The constraints are 8 listed'as Attachment 7 and Attachment 8 to IP-2.5. 9- They come from a document entitled, " Planning 10 Concepts and-Decision Criteria for Sheltering and Evacuation 11 in a Nuclear Power Plant Emergency." And in that document 12 in the chapter entitled, " Decision Criteria for Selecting 13 ' Appropriate Protective Actions." There's a section on page
;14- 2-11 and 2-12 that discusses the evaluation process.
l-
\
N .
-15 .And it says: "First, however, analyst must 16 determine whether concurrent hazards would elevate the risks 17 of either protective action," meaning sheltering or "18 ' evacuation, "and'whether there are measures that might be -
19 taken to mitigato these hazards." That's the "should a 20 protective action be taken." 21 The second type of constraint that's evaluated is: 22 " Specific items," and here's the text from this document,
, 23 " Specific items that address the question of whether 24 protective actions recommended on the basis of radiological 25 considerations can be implemented are then considered."
4
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REBUTTAL PANEL NO. 16 - CROSS 27066 1 So the individual who is evaluating these 1 2 constraints looks at them and says: first of all, should , l I 3 this protection action be recommended because there may be j 4 some nonradiological risk associated with it. For example, J 1 5 the -- let's pick one -- the roadways are covered with glare , 6 ice and therefore the risk due to a traffic accident may be 7 higher than a radiological risk. 8 And second of all, can it be implemented. And 9 that is, if you want to make that protective action or 10 implement that protective action what should you do so it 11 can be implemented. 12 And so those constraints are evaluated. And 13 there's an interactive process between the assistant 14 director, the director, the radiological health advisor who 15 is looking at the radiological considerations; and together 16 you come up with a protective action that considers all of 17 these effects as well as the dose savings. 18 Q Why does the rad health advisor need to be told of 19 considerations or scenarios which may enhance the estimated , 20 evacuation time when what he needs to know to complete the
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21 work sheet is the evacuation time, unenhanced, straight from 22 the chart as you've described? 23 A (Callendrello) Let's say we're in a winter - 24 scenario and there's a projection for a heavy snowfall 25 within eight-hours. It would be my recommendation that we, Heritage Reporting Corporation (202) 628-4888 L _ --- --
l l REBUTTAL PANEL NO. 16 - CROSS 27067 1 if the radiological considerations warrant it, that we 2 implement an evacuation earlier rather than later hecause if 3 we try to evacuate through heavy snow the evacuation times
. 4 will be longer.
5 Therefore, for that scenario my recommendation 6 would be, if we're going to move and it looks like we're 7 going to have to mo"e, let's move earlier. - 8 Q Gentlemen, on page 52 you summarize the ETEs. 9 Number 2 says: "The ETEs provided to the PRA 10 decision-makers are for an adequate number of scenarios 11 which account for the most predominate conditions and 12 variables normally experienced." 13 What I don't see here is a reference to the 14 regions. And we noted earlier that the SPMC ETEs contain 9 15 only two of the potential -- and we counted them up 16 yesterday and I don't want to repeat that, we went through 17 Appendix J and saw a whole series of regions that do contain 18 either ERPA B or ERPA E. - 19 My question is: why aren't additional regions 20 provided?
- 21 MR. DIGNAN: I object, asked and answered.
22 One of the first things that Mr. Callendrello was 23 asked about was, why not more? And he went into, we' re 24 trying to give them something they can use, we don't want to 25 complicate. 9 Heritage Reporting (202) 628-4888 Corporation
REBUTTAL PANEL NO. 16 - CROSS 27068 1 JUDGE SMITH: I think you' re right. 2 Isn't it correct? 3 How does this question differ from the, to me, 4 almost the exact question -- . 5 MR. FIERCE: I'm trying to speed up some. . 6 I withdraw the question. JUDGE SMITH: 7 Withdrawn. 8 9 10 11 l 12 13 l 14 15 16 17 18 , l 19 .., 20 21 - l 22 . 23 . 24 25 Heritage Reporting Corporation i (202) 628-4888
p., I
-c REBUTTAL PANEL.NO. 16 -' CROSS 27069 l' 'Q Number 3 therecin the list says tha ETE scenarios-N7 ,
are.the-same ones used in the NHRERP. 2 .I see that.
. ]. ...
3 It says,.No. 6, "Under most conditions, evacuation l ; %. . 4: would beEthe preferred' PAR for the Seabrook EPZ." 5 Can you tell me, . Panel,.what other conditions 6, would need to exist such that evacuation would not be the L - 7L preferred PAR 7 8 'Briefly. . I. don't need a whole lecture on 9- ' protective ~ action decisionmaking. .But you've got some 10J conditions in mind.
.11' AD (Callendrello) In general, and I think again I 12; went through this back in the New Hampshire proceeding.
13: In-general, if you're faced with that situation 9 s ,14 ' where he: release -- the time to the start of the release is
; s Aj
- 15 ' -short,.the release duration'is short or slightly shorter 16 'than the evacuation time estimates, then the dose savings 17' analysis would lead you to a shelter recommendation .versus
- 18 an evacuation recommendation. .
19- Again, assuming that you hadn't taken some prior - 20_ . protective action. Because once you start an evacuation,
. 21' you don't shut it off.
22 Q For purposes of that calculation, is a release 23 which is of a short duration for a particular population, 24 let's say we're looking at Salisbury, is there any
- a .'
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1 REBUTTAL PANEL NO. 16 - CROSS 27070 1 which calms and then stops and another release which is a 2 plume that because of wind shifts swings through the town? 3 Is there any distinction for -- 4 JUDGE SMITH: I just can't imagine why you are not .- 5 objecting your head off on this. l 6 MR. DIGNAN: It's -- 7 JUDGE SMITH: I just don't believe we're going 8 into this sheltering versus evacuation debate again. 1 9 MR. FIERCE: Can I explain myself, Your Honor? 10 The relevance of this line of questioning is going 11 to be -- again, there are going to be proposed findings from 12 my opponents regarding the need for -- the degree of 13 accuracy of ETEs which need to be provided. That's a matter 14 that still has not quite yet been resolved, the degree of 15 accuracy. 16 JUDGE SMITH: I thought that the Board pretty well 17 addressed that in our initial decision. 18 Now, you're saying a different concept applies in 19 Massachusetts? 20 MR. FIERCE: Well, I think you touched on it, but 21 I sure don't -- - 22 JUDGE SMITH: Touched on it. Wow. 23 MR. FIERCE: If an ETE -- , 24 JUDGE SMITH: We touched on it with a sledge 25 hammer. Heritage Reporting Corporation (202) 628-4888 1 l l - _ _ _ _ . I
I l. i l
, 4 REBUTTAL PANEL NO. 16 - CROSS 27071
; 1 l. ' .l'
'(Laughter)
.1k ,/ 12 MR. FIERCE: Is an ETE which is off by an hour 13 going to make-a difference.
. ~4 MR. DIGNAN: All right, then I've got a simple 5 objection.
6 Asked and answered. 7- .Mr. Callendrello has testified that in.his - 8 judgment as much as an hour and a half doesn't rattle it c
- 9. very much..
10 MR. FIERCE
- Well, I am testing what he's saying 11 by asking vhat the scenarios are in which the ORO would 12 consider a sheltering so that we can assess whether in fact 13' that's true. Whether an hour and a half is going to make 14 the difference, or an hour or what.
f ( lt
..15 MR. TURK: But that's not in the scope of his 16 testimony.
17 MR. DIGNAN: In my defense, Your Honor, the reason
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18 I'm not objecting my head off is it takes more time to argue - 19 an objection than to let Mr. Callendrello handle it in his 20 usual capable fashion. 21 JUDGE SMITH: The item under cross-examination is 22 that the protective action is relatively insensitive to the
,. 23 ETE. That's what they are saying why the ETEs are good 24 enough, because the protective action is not highly 25 sensitive to the evacuation time.
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REBUTTAL PANEL NO. 16 - CROSS 27072 1 And if that's what they are saying, I think that's i 2 appropriate cross-examination. - j 1 3 And now you're talking about how does the ORO 4 approach that problem, is that it? 5 I mean, am I right? Do I understand what's , 6 happening? 7 MR. FIERCE: Well, I think we can't really talk 8 about protective action decisionmaking in the abstract. Wo 9 need to see what it is the ORO is doing and why they need 10 numbers of a particular range of accuracy. 11 JUDGE SMITH: Or better, why they don't need 12 numbers of a particular range of accuracy. 13 Is that what you are saying here on 67 14 THE WITNESS: (Callendrello) There's two things, , 15 Your Honor. 16 One is, we have built into the procedures and the 17 decision-making process the mechanism to make a protective 18 action based on plant conditions and wind direction prior to 19 there being a release of radioactivity from the plant. , 20 We' ve got a big source term bottled up in containment. We 21 get a reading on an in-containment radiation monitor. And 22 we make a recommendation based on that prior to there being , 23 any release. - 24 So we've got that whole spectrum of events that 25 would be treated prior to ever looking at evacuation time Heritage Reporting Corporation (202) 628-4888
. _ = _ _ _ _ __ __
4 e
> REBUTTAL PANEL NO. 16L- CROSS 27073 estimates and the dose savings comparisons between
,p.~:N 1- ]
j 2~ sheltering.and' evacuation. .So you remove that whole 3 spectrum.of accidents.
~e <4 You look at the ones where we're now not l 5- considering accidents where there is a release of 6 radioactive material or there is one projected in the near 7 future,, tad we e_re now starting to weigh the dose savings.of -
8 sheltering versus evacuation
- 9. It's only' going to be those accidents where the
'10 - combination of time to release, or time until release 11 ' starts, travel time and release duration exceed the 12 evacuation' time estimates, or excuse me, are shorter than 13' the evacuation time estimates that we would consider J ' 14 - sheltering.
l 1 ' 15' So you've taken that whole spectrum of accidents 16 'and you've lopped off some because they are covered by the 17 in plant parameters. And of that remainder, it's only those 18 accidents,where you know that that total of the time is . 19 going to be shorter than the evacuation time estimate. 20 And in' talking to people who understand how
< :21 - accident sequences operate and how releases operate, I think 22 that third category, the release duration, is probably the 23 most speculative and the most nneertain.
24 So I would think that for nearly all accidents you 25 are going to be driven to evacuation through one path or the
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REBUTTAL PANEL NO. 16 - CROSS 27074 1 other, although the mechanism exists to evaluate the dose 2 savings for those accidents where it's appropriate. 3 JUDGE SMITH: And the evacuation time estimate can 4 be relatively short or relatively long and the same PAR will 5 be selected under your -- 6 THE WITNESS: (Callendrello) That's correct. 7 I just did a -- 8 JUDGE SMITH: Well, you read what we found based 9 upon the testimony in New Hampshire. 10 Is your reasoning any different than that? 11 Do you recall? 12 THE WITNESS: (Callerdrello) Slightly different. 13 JUDGE SMITH: How is that? 14 THE WITNESS: (Callendrello) There the issue -- 15 JUDGE SMITH: You put in the nature of the 16 release, too. 17 THE WITNESS: (Callendrello) Yes.
~
18 As I recall, I testified, when asked what scenario 19 would lead rae to a shelter recommendation, I testified in 20 almost exactly the same words I did today about if you add 21 up the times. If they are shcrter than the evacuation time - 22 estimate, it would lead you to a shelter recommendation. 23 There was one other consideration. There we were . 24 talking solely about the beach population. 25 JUDGE SMITH: Oh, all right. Heritage Reporting Corporation (202) 628-4888
l 1 REBUTTAL PANEL NO-. 16 - CROSS 27075 j
'l MR. FIERCE: I think I have enough information. l<
;s i \
(m.,/ 2 My question has been answered so I'm going to move on again. 3 Moving into the next section which is a discussion of real 4 time ETEs, Panel. 5 BY MR. FIERCE: > 6 Q There are in fact a very large number of 7 situations, aren't there, Panel, where decisionmakers are 8 given no way of knowing what the realistic ETE is for that 9 time, correct? 10 A (Callendrello) I guess I don't understand the 11 question. 12 Could you just please restate it? 13 Q I think I said, there are a very large number of g-') 14 situations where protective action decisionmakers are given (
\~ -) 15 no way of knowing through these ETEs in the SPMC what the 16 realistic ETE for that time is, for the time at hand for 17 them.
18 A (Callendrello) No, I can't agree to that. - 19 We said in our testimony there are 10 scenarios 20 which represent a variety of conditions that can be present 21 at the Seabrook site. 22 And to that extent, I consider these evacuation
. 23 time estimates that are appropriate to use in the protective 24 action decisionmaking process.
25 Q I understand your position on that.
~[es
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REBUTTAL PANEL NO. 16 - CROSS 27076 1 But the truth is, the ETEs for that given 2 situation are not known, correct; the situation at hand? 3 A (Callendrello) You wouldn't know the evacuation 4 time until after the evacuation was complete. .- 5 This is an estimate. Whether it is within five 6 minutes or an hour of what actually occurs, you don't know 7 until the evacuation is complete. This is our best estimate 8 of what the evacuation time is given a combination of 9 season, daytime and weather. 10 Q Do you have any idea, Panel, what the ETE is for 11 Salisbury for a weekday evening in the first week of June, 12 let's say, about 9:00 p.m. after it's been raining two solid 13 days and it's still raining? 14 What's the ETE? 15 MR. DIGNAN: Exactly. 16 BY MR. FIERCE: 17 Q I'll take it plus or minus 30 minutes? 18 A (Callendrello) I don't know what the ETE is. I 19 know which one I would use in the calculation. 20 Q I know you would know which one you would use. 21 But I'm asking if you have any idea what the real ETE would - 22 be for that situation, an estimate of it. 23 MR. DIGNAN: I object to the form. 24 What do you mean by "any idea"?
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25 And I'm serious now. What do you mean? l t l
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, REBUTTAL PANEL NO. 16 - CROSS 27077 i:
f;j~g e 1 I'll stipulate with you that we have no idea what r
)
(/ . .. 2 -it exactly is. 3' But do'you mean by "any idea", he's to look at --
- 4 he says he can pick out which one he would use and he's got 5 an' idea, obviously.
6 What do you mean by "any idea"?
~*
7 What degree of accuracy are you looking for? 8 MR. FIERCE: Maybe we should do it Mr. 9 Callendrello's way. 10 JUDGE SMITH: Mr. Fierce, there is no secret about-11 what you are getting to. You're are going right down the 12 testimony.. 13 Why don't you just come right out and -- 14 Well, I'm going to try-to establish
- f"N
+
MR. FIERCE:
\- 15 -that there are a variety of -- he says there are not. I say 16 there are, and now he's given me one example where he's not 17 sure what the ETE is.
18 JUDGE SMITH: In any event, you are going to be
- 19. able to put him to the -- I mean the debate is.you say there ,
20 are not enough scenariosoor can't be enough scenarios. They 21 need something else, right? 22 What.is that something else, and get right to it.
. 23 Otherwise, you're going to miss that opportunity.
24 25 ( Heritage Reporting Corporation
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i REBUTTAL PANEL NO. 16 - CROSS 27078 1 1 JUDGE SMITH: We've had this debate many times. 2 MR. FIERCE: Okay. 3 BY MR. FIERCE: 4 Q There are other situations where you don't know - 5 what the ETE is as well? . 6 An estimate is not even within the realm of plus 7 or minus an hour or two? O It's not available to you, ic it? 9 A (Callendrello) Scenarios are available. 10 Sufficient scenarios are available for me to make an 11 estimate, for my purposes, in evaluation of protective 12 action recommendations. 13 Q You now have a Region 13 ETE for a summer weekend 14 midday rain situation, which I believe is over nine-hours; 15 correct? 16 A (Callendrello) Correct, nine-hours and 10 minutes 17 on our Attachment D to the testimony. 18 Q Now, if it's a summer weekend, it's midday, it's - 19 been raining for three days and it's still raining and . 20 there's not a sole out on the beaches, the Region 13 2TE is 21 not going to be nine-hours and 10 minutes; correct,. Mr. 22 Callendrello? . 23 You would know that as a protective action . 24 decision-maker because this was for a sudden rainstorm when 25 the beaches are at capacity. Heritage Reporting (202) 628-4888 Corporation 9 ( _ _ _ - - - a
i REBUTTAL: PANEL NO. 16 CROSS 27079-
- ,s, .1' A (Callendrello) That's correct. ,
i 2 0- LIlo you have any way.of making an estimate of what 3 the ETE is-for that situation you're looking.at?
. '4 JUDGE SMITH:. It has been raining for days.
5 THE WITNESS: (Callendrello) I understand. 6- BY MR. FIERCE: 7- -Q It could be hours less than nine-hours and 10 8 minutes, couldn't it? 9 A (Callendrello) Could be. 10 I would say that the evacuation time astimate will 11 be somewhere in the range of five to six-houra. 12 Q 4th of July weekend, Region 13, 4 o' clock in the
-13 morning, nobody is out on the beach but you've got all of g-s 14 the transient weekenders there.
\/ % 15 What's the ETE that you would estimate?
16 MR. DIGNAN: Where are they? 17 JUDGE SMITH: These are non-day-tripper 18- transients. . 19' MR. FIERCE: Where are_the people? - 20 MR. DIGNAN: Yes. Are they in the motels these
- 21 transients? It excludes the day-trippers?
22 MR. FIERCE: Yes. 23 JUDGE SMITH: On your last answer, did you arrive 24 at your last answer between five and six-hours based upon -
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25 baseline from the scenarios? [' Heritage Reporting Corporation ( (202) 628-4888
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REBUTTAL PANEL NO. 16 - CROSS 27080 1 THE WITNESS: (Callendrello) Yes. 2 I look at scenario 3 which is summer midweek, 3 midday and it says, beach area and tourist population is at 4 75 percent of capacity. I understand that the beach day- - 5 trippers are about 50 percent of the population there, so I , 6 think that would be a reasonable representation. 7 I don't think it will be much less than that, 8 because even if I look at the off-season scenarios they' re 9 four to five-hours roughly. The off-season, midweek, 10 midday, good weather is five-hours and 30 minutes. 11 JUDGE SMITH: That's fine. I just wanted that answer. And the upcoming 13 answer is where you're getting your ETEs to be established. 14 If it is the fact that they are the use of the scenarios. 15 ETEs associated with the scenarios? 16 THE WITNESS: (Callendrello) Mr. Lieberman 17 reminds me, I'm working off of what was Attachment 4 to
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18 IP-2.5, those numbers have been updated. I've been using 19 the wrong numbers. 20 And I've forgotten what the question was. It was 21 the 4th of July, 4 o' clock in the morning. 22 BY MR. FIERCE: . 23 Q 4 o' clock in the morning, it's the 4th of July . 24 weekend? 25 A (Callendrello) Good weather. Heritage Reporting Corporation (202) 628-4888 I i
p. L REBUTTAL PANEL NO. 16 - CROSS 27081-
,-c :1- 'O Good weather?.
;f
-( 2 A (Callendrello). I would use the scenario 1 time, 3; roughly'seven-hours.
. 4' .Q This is'for Region 137 5 .A (Callen'rello) d Yes..
6 Q And for Region 87 7 A (Callendrello) Six-hours and 10 minutes. -
, 8 Q It's your view, Mr. Callendrello, that you don't 9 need a real-time system -- I.know that and I don't want to
'10 argue thatl with ~ you -- but if we have a PRA decision-maker 11 -who wanted to know ETEs to a degree of accuracy that puts
~
12 him within an hour to an hour and a half, some sort of a 13 real-time system would be helpful, wouldn't it?
.14 - A (Callendrello) Let me understand ~the
(
\, - 15 hypothetical.
16 - LThe decision-maker. feels the need to have ETEs
- 17. accurate to within an hour?
18 Q An hour to an hour and a half? - lL 9 A (Callendrello) 'I don't know if a real-time system 20 would achieve that goal. 21 I know accuracy is a major concern of yours about
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Q 22 the real-time system. 'I can read the testimony. 23 Let's just get into it. At page 54, Panel, you do 24 'make a reference to really an irrelevant situation, in the 25 middle paragraph there, the discussion of the HMM pneumatic
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l L REBUTTAL PANEL NO. 16 - CROSS 27082 1 counters. l 2 We now know that those counters are not anywhere 3 state-of-the-art; correct? . l 4 A (Lieberman) They're not state-of-the-art, but .- l 5 they're accurate. 6 Q They're accurate? 7 A (Lieberman) Oh, you bet. 8 Q Subject to error? 9 A (Lieberman) No , they're not -- they're pressure 10 detectors which are essentially tubes encapsulated within a 11 construct for the purpose of longevity which have been shown ; 12 to be, for counting purposes, of comparable accuracy to a 13 loop. 14 Q You say "to a loop." Induction loop detectors? 15 A (Callendrello) Right. 16 For counting purposes. The reason they use loops 17 generally for other reasons. 18 Q Has the panel done any investigation to determine i 19 what, in fact, the best quality detectors are least prone to 20 error? 21 MR. DIGNAN: I'm going to cbject to the form. ' 22 JUDGE SMITH: Okay. 23 Let's go back here a little bit. If you recall, . 24 we did allow that contention in recognizing that we did not 25 see a regulatory requirement for a real-time calculation, Heritage Reporting Corporation (202) 628-4888 i 4
REBUTTAL PANEL NO. 16 - CROSS 27083 1 and very emphatically putting the burden upon the Attorney 2 General to come in and demonstrate that they're useful and 3 practical and reliable.
- - 4 We did that because we wanted to approach this as 5 a more traditional case where people were cooperating and 6 really wanted the best possible protective action. And so 7 we didn't want to slam the door to the Attorney General 8 coming in with something useful, which maybe they would 9 cooperate out the backdoor unbeknownst to anybody or 10 whatever.
11 But this isn't what you're doing now. You're 12 quarreling with the panel and you're assuming it is their 13 burden to establish that real-time counters are not useful. 14 And I recognize that's in their testimony. 15 But I just wanted to explain to you just how we 16 viewed the contention. And I think we expressed some of 17 those thoughts, most of those thoughts in our ruling 18 accepting the contention. - 19 MR. EIERCE: Well, we presented evidence on this, . 20 Your Hcnor. In fact, in discovery we were asked, what's the 21 system that you would offer and we offered some information 22 on that, estimt.tes of cost and what not. 23 And we presented some information through Dr. 24 Adler, and I'm not cross-examining this panel -- 25 JUDGE SMITH: On the rebuttal to Dr. Adler. Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO. 16 - CROSS 27084 1 MR. DIGNAN: Your Honor, may I just be heard on my 2 objection as to form. 3 My problem with the question is " error." 4 Do you mean by that error in counting assuming the 5 thing is working or are you talking about errors that might 6 arise because there's a breakdown? 7 To me that's two different kinds of error. 8 MR. FIERCE: I agree. 9 MR. DIGNAN: I want to be sure which one you're 10 putting to the witnesses. 11 MR. FIERCE: Well, I was looking at an overall 12 kind of error to the extent that you know you have better 13 systems that generate less error when they're working and 14 breakdown less readily than some of the others. I would 15 assume that would be a better kind of system, the kind of 16 system you would want to have. 17 THE WITNESS: (Lieberman) Well, pressure counters
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18 offer better accuracy than loop detectors for counting 19 vehicles under heavy traffic conditions. , 20 BY MR. FIERCE: 21 Q Are there particular models or particular 22 manufacturers that you're aware of that produce? l . 23 A (Lieberman) There are a number of them. 24 They're not used all that much. You will find 25 them, for example, in garages where all they' re interested Heritage Reporting Corporation k (202) 628-4886 4 L____________________________ _ _ _ _ . _
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l REBUTTAL PANEL NO. 16 - CROSS 27085 f The reason they're not used all that much i 1 in is counting. 2 is because they only provide counts; they don't provide 3 other information which are used in traffic control and
~
4 surveillance systems. 5 Q Well, can these counters that you're describing, . 6 Mr. Lieberman, be linked together to form a corridor around 7 the beach areas and gain some information about the beach 8 vehicle populations? 9 Linked to a computer and -- 10 A (Lieberman) Can it physically be done? Yes, it 11 can be done. 12 Again, the problems I have with it are enumerated 13 in this testimony. And the fact that it can physically be 14 done doesn't mean it's necessarily feasible. 15 Q And you describe in your testimony concerns about 16 accuracy and error rates to some length; correct?- 17 A (Lieberman) Right. 18 I was going to say that traffic control and 19 surveillance systems don't use input / output for data 20 collection. They just don't do it, because of the 21 aggregation of errors of the type that Dr. Adler documented 22 in his testimony that we referred to. There's just a lot of , 23 leakage in input / output analyses, and that's the problem . 24 here. 25 Q There is compensatory software that can be used to Heritage Reporting Corporation (202) 628-4888 O,
i i C . 1
. REBUTTAL PANEL NO.f16f- CROSS 27086 l h ..
kge-C 1- . reduce error rate?. j s 2 A -(Lieberman) .The_ compensatory. software' can 3 ' compensate-for.the' microscopic signals for loop detectors. J
)
4, In other-words, the signal you;get is a very; ;] l 5; jagged one. And'there's a threshold involved which says J
- - )
6 .that if the signal rises above,this threshold there's a 7 ping,.it means there's a count. If it doesn't arise above 8 that threshold, there is no count. 9 JAnd this compensatory software is designed L10 'especially for a measure called occupancy. Occupancy is the 11' ' length of time that a vehicle dwells in its passage over 12 . loop detector. 11 3 And occasionally what happens -- more than g L 14 ' . occasionally is that the signal from the loop detector falls
\~ i 15 below the threshold. And then the question becomes: has
'165 that car already passed cn: is it'still there and'we got a 17 problem with the tuning of the detector.
11 8 So there is software'which says, well, let's wait 19 .before' we make the do :ision and see what other signals are , 20 coming in, that kind of thing. 21 22 l1.. 23 lL 24 g 25 I~ i O Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27087 1 A (Lieberman) (Continued) But the aggregation or 2 this leakage has nothing to do with the -- well, I shouldn't - 3 say it has nothing to do -- it is not related only to the 4 functioning of the individual detectors. 5 Q The Panel describes a survey, mentions a survey . 6 reported in NCHRP Report No. 233. 7 Do you know when that report was done? 8 (Witnesses review document.) 9 A (Lieberman) June of 1981. 10 Q And the state of the art in countertechnology and 11 computer software have advanced since then, hasn't it? 12 A (Lieberman) I would hope so. 13 Q And the paper entitled " Traffic Detector Errors in 14 Diagnostics" reported on page 56 of your testimony, these 15 are the horror stories, are they not, Mr. Lieberman? 16 A (Lieberman) They are some of them. 17 Q Reporting some real problems that have cropped up 18 using detectors in the past. 19 Are you saying that this is a fair and accurate ', 20 portrayal of the typical failure rates experienced using the 21 best detectors available today and state-of-the-art 22 compensatory software and placing the detectors in locations 23 that you know to be favorable rather than less favorable? . 24 Does this give us a real fair representation of 25 the state of the art? l Heritage Reporting (202) 628-4888 Corporation O1 ; 1 I l 1
F r i REBUTTAL' PANEL NO; '16 - CROSS' 27088 F y~c 1 A (Lieberman) I think it.does.
'I
\ ,._ / 2 I think the figures given in NCHRP 233-about-3 probability of each detector failing of .3, that says that.
I JF the mean time between failures _is on the-order of three to 5: four years. That's about right, and it varies over a wide 6 range. l 7 'The detectors that have a mean time between 8- failures of a year can go up to 10 years. Depends upon'a 9 lot of factors, and it's not technology as much as it is-the 10 -workmanship ~in installing the thing, and the structure of
.11 the pavement, the sealant, the weather conditions, the
.12 frost-heave, all these are factors which enter into how well 13 the loop detector works, because the ' loop detector: itself is -
,/"'g 14' just a loop of three wires. It's not high tech.
~\ ' j 15 Well, assuming we've got compete't installers Q
16 here -- we're not talking the Keystone Cops laying these
- 17. things down.-- who know where they need to be placed.
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18 MR. DIGNAN: What are "these things"? - 19 MR. FIERCE: These detectors. , 20 MR. DIGNAN: Are these the tubes that run across
.21
- the road?
22 MR. FIERCE: Tubes and wires. s 23 MR. DIGNAN: And the wire is in the tube. 24 MR. FIERCE: Well, they are induction loops which 25 I believe are more accurately described as wires.
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l-REBUTTAL PANEL NO. 16 - CROSS 27089 1 MR. DIGNAN: And they lie on the surface of the
.2 roads?
3 MR. FIERCE: Yes.
'4 MR. DIGNAN: Oh, okay.
5 MR. FIERCE: Or they can be -- , 6 MR. DIGNAN: I've always been curious what you do 7 when the snow plow comes by. That's, I guess, what -- 8 MR. FIERCE: They can be embedded in the roadway 9 surface. 10 BY MR. FIERCE: 11 Q Isn't that true, Mr. Lieberman? 12 MR. DIGNAN: That's what I thought. 13 THE WITNESS: (Lieberman) That's right. You 14 essentially make a saw cut in the pavement, generally 6 by 15 6. Sometimes the small ones are 4 by 4, and you just -- 16 you have to clean it up, put some material in the bottom to 17 make it level, drop the wires in very carefully, seal it
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18 very carefully, of course you test it before you seal it, 19 and then you have it. , 20 I would say the mean time between failure of three
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21 to four years is about right. It's representative of what 22 you are going to get. , 23 BY MR. FIERCE: . 24 Q So for three to four years you're going to get 25 fairly -- Heritage Reporting Corporation (202) 628-4888
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;) REBUTTAL PANEL NO. 16 - CROSS 27090-7"s , 1'- A1 (Lieberman) That's mean time between failure forL h 9 '
- 2. a single detector.
3 When-you start' installing a. system of detectors,. 4' each one of them having a mean time between ~ failure of that . 5 amount a.distributional property around that mean, i- 6 And when you require an input / output process, what.you are 7- saying'is that every single one of those detectors has to be' 8 functioningcin order for the input / output to be complete, 9 because.what you have is a closed cordon. 10 You break that cordon at one point, you are out of 11 -the ball game.
- 12. You understand the problems now?
Q- I understand the problem. 14 A (Lieberman) That's why they don't use N- 15 input / output systems in traffic control systems. It too ~I I 16 unreliable. 17 0 Until you recalibrates.the system, which is 18 possible to do with a set of aerial over-flights, correct? 19 .A (Lieberman) That's far-easily said, more easily , 20 said than done for the reasons cited. 21 Q Well, I understand this Panel isn't going to 22 accept anything having to do with that kind of a real time
. 23 system using detectors and computers to signal back to 24 Seabrook. Let me just explore another option with you.
25 Dr. Adler testified to a much simpler method I 1 Heritage Reporting Corporation N ,/ (202) 628-4888 i
I l 1 REBUTTAL PANEL NO. 16 - CROSS 27091 j 1 involving the use of a series of aerial over-flights on 2 different days, at different times of day, with different . 3 weather conditions. It's on page 28 of his testimony. 4 Has this Panel had an opportunity to look at 5 that? , 6 A (Callendrello) I've read his testimony. 7 Q That's a feasible methodology, isn't it, Panel? 8- JUDGE SMITH: $20,000 he says it costs. 9 MR. FIERCE: No. 10 I think,Your Honor is looking at the computer 11 system. 12 JUDGE SMITH: Oh. 13 BY MR. FIERCE: 14 Q You've read the testimony, Mr. Lieberman? 15 A (Lieberman) Yes, I have. 16 Q And with the data collected, using some 17 statistical analysis, you could come up with what .I think 18 Dr. Adler callt a template of the conditions which would 19 give you some estimates for a variety of circumstances, 20 nighttime, early mornings, different weather conditions,
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21 different times of the year that would give a protective 22 action decisionmaker at least a table, a chart, a list of , 23 ETEs for a much wider range or set of circumstances than . 24 they have now, correct? 25 A (Callendrello) It may. I don't see how it's s Heritage Reporting Corporation (202) 628-4888 Oi ! l
p g: REBUTTAL PANEL 1NO., 16 - CROSS 27092 ] 4 1 going to help very much. k_sh . 2 Q And it;would be very inexpensive, correct? 3 A (Lieberman) Well, no.
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4 You've jumped along withcut letting me comment on
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6 Until you.do this, you don't know the breadth of 7 your confidence interval. By_this L mean suppose he decides 8 that he wants to correlate or regress on temperature, just 9 to cite one case. You may find that.over summer the beach
'10 population for a given temperature range may vary from 15 to 11 30,000 cars.
12 What.do you do in a situation like that? 13 Essentially what I'm saying is that the
.,/g 14 correlation coefficient may be down to .3. You may have
-- 15 done a wonderful job in fly-overs and very accurate data 16 collection off the pictures, and found that, by golly, the 17 variability of the system with respect to the independent 18 variables he has selected is so wide that you haven't gained. -
19 what they call an explanation of the. variance. You haven't ', 20 gained any intelligence.
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21- You cannot a priori make the assumption that you '1 1 22 are going to be successful. W
. 23 0 Couldn't you come up with a set of ETEs that would 24 provide decision-makers a better sense of what the ETE for 25 the' time at hand is for a whole range of conditions where r Heritage Reporting Corporation
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I ( ) 1 i REBUTTAL PANEL NO. 16 - CROSS 27093 f 1 nothing is provided to them now? 2 A (Callendrello) I disagree with the assumption, or l 3 your representation that there is nothing provided. 4 We went through this on several cases where I 5 indicated that there are times provided for a variety of , 6 scenarios. 7 0 Times provided for a 100 percent of beach i 8 capacity, I believe 75 percent of the transient-beach 9 capacity, and zero percent of the transient-beach capacity, 10 correct? 11 A (Callendrello) In essence, yes. 12 Off-season would represent zero beach capacity. 13 Q And for mirlday in each case in the summer, not 14 evenings, not mornings, you don't think there is a better 15 set of numbers using that system that could be provided than 16 you have now? i t 17 Okay, if that's the testimony, I'm not going to 3 18 quarrel with it. 19 A (Callendrello) I do not feel that getting numbers , l 20 that may be more precise within that range would provide any ; i 21 benefit in the protective action recommendation decision l 22 process. , 23 Q Panel, it would not be too difficult to calculate - { 24 special facility ETEs for the two hospitals in the EPZ, 25 correct? j J l Heritage Reporting Corporation i (202) 628-4888
y REBUTTAL PANEL NO. 16 - CROSS 27094 1 It's not impractical to do that? You could-do it?' l j
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2 A (Callendrello) Well, I think that would not be i
- 3. something I would calculate. That' would be something that-
~- 4 'you would work with the facility on-developing.
5 Q Right. j
. j 6 A (Callendrello) And if they would work with us, 7 and they wanted a special facility.ETE'for some reason, then
'8 we.would do it.
9 At present, as I explained to Ms. Greer when she 10 cross-examined me on the special population panel, we do not
,11 make protective action recommendations on a facility-by-12 facility basis. We make them on an ERPA basis.
.13 And to the extent that a facility'is within that d 14- ERPA, it is. subject to the same protective action
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recommendation that'the ERPA is' subject to. 15 16 Q .I'm well aware of all of that. I'm trying to
-17 establish, at least, that it can be done. It can be done
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18 for those two hospitals. You could come up with an ETE. 19 And-I think you just said so. ', 20 A (Callendrello) What I said was I wouldn't 21 calculate it. I would work with the administrators at that 22' facility to establish what it is based on in their
. 23 experience.
- 24. Q And it could be done for the nursing homes in the 25 EPZ as well, couldn't it?
O
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REBUTTAL PANEL NO. 16 - CROSS 27095 1 There is more of them, but working with those -- 2 MR. TURK: This is if your office would not impede 3 the hospital's efforts to cooperate? 4 5
- 6 7
8 9 10
, 11 12 13 14 15 16 17 18 19 20 21 22 .
23 . 24
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= REBUTTAL PANEL NO.'16 - CROSS 27096
)# 1 MR. FIERCE: We have not impeded private hospitals
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tN 2' Ifrom doing anything, Mr.. Turk.' We.have not. impeded nursing 3 homes from'doing anything. And I. resent'the implication. 4 BY MR.' FIERCE: 5 Q Assuming you go to a nursing home andLthey have no L reason not to want to cooperate with you, you could working 6 7- with a nursing home come ty) with a special facility ETE for 8 that nursing home? 9 A (Callendrello) I wouldn't see any reason why we 10 would want to do that. 11- Q Okay. 12 You admit, you don't have special facility ETEs 13 now in the plan? ['~N . 14 A (Callendrello) We don't have individual facility 15 , ETEs. 16- - As I explained several weeks ago to Ms. Greer, we 17 have analyzed the provision of transportation to special 18 populations and have satisfied ourselves that it's contained - 19 within the envelope of times associated with the general , 2 0_. population. 21' Q On page 63 you present an argument perhaps why you 22 don't need to have a'special facility ETE.
. 23 And isn't it true that here you're assuming a 24 release which is not projected to stop in the near future?
25 A (Callendrello) No , this would be projecting a
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REBUTTAL PANEL NO. 16 - CROSS 27097 1 release that's longer than the evacuation time estimate. 2 O But as I understood your explanation earlier, 3 you're only going to be concerned about ETEs in those 4 situations where the times are close, where you do have a 5 plume that's projected or a release that's projected to , 6 cease either because it's going to actually cease at the 7 plant or it will have blown over that community and be 8 heading in a different direction by some time estimated? 9 A (Callendrello) I don't think that's what my 10 testimony was. 11 I didn' t say the only time you' re concerned with 12 an ETE is when it's close. 13 Q Well, if you had used in this discussion here an 14 assumption of a release which was projected to cease, you 15 could have come up with a situation, couldn't you, where it 16 would have been helpful to have special facility ETEs? 17 A (Callendrello) No, because we would make the 18 protective action recommendation for the ERPA, for the 19 population within the entire ERFA. 1 20 Q I don't want to quarrel with you about what you 21 would do. I know you would do what you would do. 22 A (Ca11endre11o) I'm sorry, I don't understand the , 23 question then. . 24 Q On an institution-by-institution basis you, 25 nevertheless, could make a calculation whether to shelter or Heritage Reporting Corporation (202) 628-4888 I l ! l l l t
REBUTTAL PANEL NO. 16 - CROSS 27098
,-. 1 to evacuate -- no,.it's not there. But you could do it if i / 2 you had a special facility ETE and there would be some 3 circumstances where it might be useful to make a decision to 4 shelter versus evacuating in a special facility?
5 A (Callendrello) You couldn't do it based on the 6 information you have given me. 7 As we said in the testimony, you need more than an 8 evacuation time estimate. You would need a dose reduction 9 factor -- 10 Q Yes. 11 A (Callendrello) -- for the specific facility. 12 Q If you had established that in advance for the 13 facilities, would it be possible to make institution-by-rs 14 institution decisions? I
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15 A (Callendrello) It would be possible. 16 I don't think it would be prudent, but it would be 17 possible. 18 Q There are also other issues with regard to 19 evacuation of hospitals, in particular, that need to be ', 20 taken into account, aren't there, Mr. Callendrello, such as 21 the difficulty in moving a large hospital population quickly 22 and the risks attendant to the patients in moving them?
. 23 A (Callendrello) Yes.
24 As we indicated in our testimony No. 6 there are 25 other considerations for the taking of protective actions. (A)
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REBUTTAL PANEL NO. 16 - CROSS 27099 i 1 We would expect the administrators of those facilities to be i 2 aware of the conditions of their patients and whether they 3 should be evacuated if evacuation is the recommended 4 protective action. 5 And if they feel in their medical opinion those , 6 individuals should not be moved, then we would make whatever 7 arrangements are needed to support that administrator's 8 decision and provide whatever assistance they would require. 9 I see on page 65 of the testimony in the j Q 10 discussion of the special population ETEs as opposed to the 11 special facility ETEs, mention of the use of Northern Essex 12 Community College as a staging area for buses -- a place for 13 buses to mobilize in the event of a fast-breaking accident 14 of the type used in the ETE planning basis. 15 And I'm wondering, as I recall the plans I don't 16 see NECC in the plans currently; correct? 17 A (Callendrello) That's correct. 18 Q You have it listed here as a " proposed procedure?" 19 A (Callendrello) That's correct. . 20 They will be included in the next amendment of the 21 SPMC. 22 Q That was my next question. , 23 This is something you are going to include in the . 24 next amendment? l 25 A (Callendrello) Yes, it is. l Heritage Reporting Corporation (202) 628-4888 i I _ a
T , ; l i-" REBUTTAL PANEL NO. 16 . CROSS 27100 I Ll9 x- 1 Q How much -- when didLthis become the intention of ~ t -f .
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Es 2: the Applicants to include this in the plans? 3 A (Callendrello) I would say late 1988, early 1989. 4 Q How much space does NECC have which is available 5 for the buses to assemble in?. 6' A (Callendrello) They have parking for 7 approximately 2000 cars. 8 Q And where is this space located? 9 Is this the parking space -- just the parking lots 10 for the college? 11 A (Callendrello) Yes. 12 There are number of parking lots. There are some 13 paved lots. There are some new lots that they've just 14 recently added. N- 15 0 ,Is there a particular lot that the Applicants have-16 in mind to use for this function? 17 A (Callendrello) I'm not aware of any particular 18 parking lot, no. 19 Q It's normal uses for parking the faculty and ',, 20 students at the college? 21 A (Callendrello) That's correct. i; e 22 Q Okay.
.- 23 And they could be using, in fact, that parking lot 24 at the time the emergency occurs?
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25 A (Callendrello) They could be. ) I l ( Heritage Reporting Corporation (202) 628-4888 I L______--_-_-___-
3 REBUTTAL PANEL NO. 16 - CROSS 27101 j Though in discussions with the president of the ! 1 2 college he indicated he would suspend classes and send his 3 students home. 4 Q Is that who your discussions were with, the 5 president of the college? , 6 A (Calle.ndrello) That's correct. 7 0 Is there a letter of agreement? 8 A (Callendrello) No , there is not. 9 He indicated that the college is a state facility 10 and would not be able to sign a letter of agreement. 11 Q And what assurance do you have that it will be 12 available? 13 A (Callendrello) I would expect that in the event 14 we needed that facility and we communicated that to the 15 governor he would make that facility available. 16 Q Are there any plans to have any traffic guides go 17 there in order to direct and control the bus traffic in and 18 out? 19 A (Callendrello) None that I'm aware of, although , 20 there will be many route guides and bus dispatchers. And 21 the bus dispatcher certainly could provide that function. 22 MR. TURK: Just for clarification. , 23 This college is located? . 24 THE WITNESS: (Callendrello) In Haverhill. 25 MR. TURK: Haverhill, Massachusetts? Heritage Reporting Corporation (202) 628-4888 l
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REBUTTAL PANEL.'NO..16 - CROSS 27102 Jav 1 .THE WITNESS: (Callendrello) Yes, just on the L{ \ (/ 2 edge of the EPZ. J3 MR.~ TURK: So it's a state. facility within the
'4 . Commonwealth of Massachusetts?-
51 THE. WITNESS: (Callendrello) That's correct. 6 BY MR. FIERCE:
'7 Q- Would that be'inside or outside that access 8' ' control' point?
9 '(Witness reviewing document.) 10 THE WITNESS: (Callendrello) Do you.have a 11- specific access ~ control point -- 12 'BY MR. FIERCE: 13 -Q We'll, there.is the one I'm familiar with. (~N , 14. MR. TURK: :While Mr. Fierce is looking, Your h ~ 15' Honor, I just want to note it's 4:30'and we do expect, at 16 least at Mr.' Fierce's. representation, that we'll finish this 17 panel and Dr.-Urbanik today. 18' MR. FIERCE: Dr. Urbanik today? l 19 I never made that representation. I said by ", 20' Friday.- l 21 MR. TURK: Oh, no,'it was by1today. 22 MR. FIERCE: I will certainly have-both of them
. 23 out of here by Friday.
is l 24 MR. TURK: It was by today, Your Honor. 25 - JUDGE SMITH: That was my memory, it was by f Heritage Reporting Corporation
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REBUTTAL PANEL NO. 16 - CROSS 27103 I i 1 Friday. I only expect him to complete this panel today. I 2 MR. FIEhCE: I am definitely going to complete 3 this panel today.
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4 JUDGE COLE: I think he might have said, possibly 5 Thursday. , 1 6 MR. FIERCE: We had that possibility. ! 7 MR. TURK: He at least made the representation to 8 me that he would be -- 9 JUDGE SMITH: Maybe he did, I don't know, but I 10 didn't hear him. 11 BY MR. FIERCE: 12 Q There are five access control posts in Haverhill. 13 The one I was thinking of is the one on 495 at the 14 interchange with Route 110, EA-4. 15 (Witness reviewing document.) 16 - THE WITNESS: (Callendrello) Northern Essex 17 Community College is at that interchange. It's just south 18 of there on Route 110. 19 So that it is, in essence, at that access control , 20 point. 21 BY MR. FIERCE: 22 Q Okay. 23 Have the bus drivers been given any training at . 24 all regarding the use of this facility in the event of a 25 fast-breaking accident? Heritage Reporting Corporation (202) 628-4888 ;
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REBUTTAL PANEL NO. 16 - CROSS. 27104' l11 A' : (Callendrello) . I-don't know if-they have q D,O 2 'specifically. l i
.3 .'As I indicated, it's.not yet been added to the
,4 . plans. 'But I' don't know whether!'they have been told of this
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.- 5 or not.
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7 8 f i ,, g 10 11 L
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j i l b 1 l REBUTTAL PANEL NO. 16 - CROSS 27105 1 Q In a slower-breaking accident the procedure will 2 still be as it now is in the plans with route guides 3 traveling to the bus yards, meeting up with them there, 4 assembling them and traveling in convoy fashion back to the l 5 EPZ7 ~ l . 6 A (Callendrello) Yes 7 Q What is the distinction in this proposed plan 8 between fast-breaking and slow-breaking? 9 A (callendrello) As I recall the distinction is i' 10 that when the bus company liaison arrives, if a protective 11 action recommendation has been generated or if a general 12 emergency has been reached, then he will implement the fast-13 breaking accident procedure. 14 Q Now I understand you have done a bus mobilization 15 study and you've got it attached here. But it doesn't carry 16 all the way through to an evacuation time estimate for 17 special populations. 18 Has that not been done? 19 A (Callendrello) We took it to the point consistent 20 with whr.t chapter 11 of the ETE had in the way of special 21 facility evacuation time estimates. From that point the 22 loading time and others are -- we wouldn't expect it to be 23 any different than what is currently in chapter 11. . 24 Q Do you know what the special population ETE is 25 for, say, ERPA B on a weekday in the winter? Heritage Reporting Corporation (202) 628-4888
1 k ( REBUTTAL-PANEL NO'. 16 - CROSS 27106 (1 MR. TURK: 'A_special facility?
=I, m):-
( ,/. 2 BY MR. FIERCE: j
.3 Q Special-population?.
4 A (Callendrello) For ERFA B? 5 Q ERPA B in the winter? 6 A (Callendrello) We haven't done evacuation time estimates'by ERPA'B. We've'done them by regions. 7-8 Q -So again, you only have them.for regions. 9 The times that are provided-there, again, _those 10 would include New Hampshire times as well? 11 A' (Callendrello) That's correct. 12 -Q Do you know whether, in fact, the special 13 population.ETE'for ERPA B on a weekday'in the winter is less
g 14 -
greater.than or less.than four-hours and 30. minutes?
\-s 15 I'm looking.at your new ETEs-for scenario 6 which 16' .is a -- that's not the one. 7 is what I wanted.
17- Is it less than six-hours? 18 Scenario 7 is your off-season midweek, midday 19 snow. , 20 (Witness reviewing document.) 21 THE WITNESS: (Callendrello) I'm looking at the 22 tables in Volume 6 of the'New Hampshire plan. I don't see
. 23 times for scenario 7 present there. I see 1, 2, 3, 4, 5, 6, 24 8 and'9 and I just don't see 7.
25 MR. FIERCE: Let me just withdraw that. Heritage Reporting Corporation (202) 628-4888 L l '. O__ __ _-
REBUTTAL PANEL NO. 16 - CROSS 27107 1 I'm trying to move quicker here. 2 BY MR. FIERCE: 3 Q Gentlemen, you've got for Region 8 ETEs for 4 scenario 8 of three-hours and 55 minutes; correct? 5 Scenario 8 is for -- . 6 A (Callendrello) Correct. 7 0 -- off-season -- 8 A (Callendrello) 3-35. 9 Q -- off-season, midweek, evening, good weather? 10 MR. TURK: 3-357 11 THE WITNESS: (Callendrello) 3-35. l i 12 BY MR. FIERCE: 13 0 3-35. 14 Aren't the special population ETEs for 15 Massachusetts going to be longer than that, for that 16 scenario? 17 (Witness reviewing document. ) 18 THE WITNESS: (Callendrello) I don't know whether 19 they will or not. 20 When I look at table 10-10D they are shown as the 21 same times as the general population evacuation time. I 22 don't know if that's because tney become embedded in the 23 general population evacuation flow or if that's because they . 24 have a separate evacuation time estimate that would make it 25 three-hours and 55 minutes. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27108-1 BY MR. FIERCE:
- 0 2 O Well, as I take a look at figure 1 in your Attachment 3, in your bus mobilization analysis, what I see t
l l 1 3 4 here is that we've got buses at the EPZ boundary between 5 one-hour and 40 minutes and two-hours and 55 minutes. 6 Now is that after the SAE, gentlemen? 7 A (Ca?.lendrello) Yes, that's after the site area 8 emergentf. However, that's 149 minutes and 255 minutes. 9 Q Okay. 10 If we wanted to calculate the time from -- 11 MR. DIGNAN: That's two-hours. 12 BY MR. FIERCE: 13 Q -- from the order to evacuate it's about two-hours 14 t o --- 15 MR. DIGNAN: Are you talking about 1497 16 MR. FIERCE: Yes. 17 MR. DIGNAN: It's about two and a half hours. 19 MR. FIERCE: On the short end to how many hours on 19 the long end? It would be two-hours and 30. , 20 MR. DIGNAN: About five. 21 MR. FIERCE: It's 230 minutes. 22 BY MR. FIERCE: _ 23 Q This is just to get to the EPZ boundary and not to 24 load up the passengers; correct? 25 A (Ca11endre11o) That's correct. 9 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27109 1 1 1 Q And not to drive them out of tha EPZ? ! i 2 A (Callendrello) That's correct. 3 C Now, assuming that we had a general population ETE 4 of three-hours and 35 minutes, special facility ETEs are 5 going to be longer, aren't they? . 1 6 A (Callendrello) Not necessarily, t 7 Q Explain that, please? 8 A (Callendrello) The times you see listed are for 9 all 461 buses to report to the EPZ. 10 For the scenario you have given me, Region 8, the 11 demand for buses would be far less than that, and I don't 12 recall what scenario we' re on anymore, whether it's off-13 season -- I believe it's still off-season. I don't recall 14 whether it's midday or even.ing. 15 MR. TURK: Midweek, evening, or weekend all day? 16 THE WITNESS: (Callendrello) If it's midday, 17 schools are in session, we would be -- 19 MR. TURK: No, it's not. 19 It's midweek, evening, or weekend all day, so 20 schools are -- there's not school -- 21 THE WITNESS: (Callendrello) School is not in 22 session. So the bus demand -- for the entire EPZ the bus 23 demand would be about 140 buses. - 24 (Witness reviewing document.) 25 THE WITNESS: (Callendrello) Region 8 would be a Heritage Reporting Corporation (202) 628-4888 l l j
REBUTTAL PANEL NO. 16 - CROSS 27110 1 a small part of that. I would estimate about a third. So 2 it's about 50 buses. 3 So the first 50 buses that arrived would be 1 ^ 4 dispatched in and I would think they could achieve that j 5 evacuation time estimate or achieve evacuation within that i 6 envelope. 7 BY MR. FIERCE: 8 Q Region 13, evacuation for that scenario, if I read 9 the chart right, is exactly the same? 10 A (Callendrello) Yes, it is.
,1 Q Okay.
12 That seems a little unusual to me, but I'll accept 13 that. 14 Now you.need buses for the entire EPZ? 9 15 A (Callendrello) Except for school. 16 So that's about 140 buses I think I had indicated. 17 And those times you see are for the mobilization of 461 of 18 the -- 19 Q Panel, don't you really need to calculate your } 20 special population ETEs to see if, in fact, for some of 21 these scenarios where the ETEs are shorter the general 22 population ETEs are, in fact, still longer than the special
. 23 population ETEs?
24 A (Callendrello) No. You need to compare the 25 special population ETEs with those of the general G Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27111 1 population. , i 2 Q Now, what are the assumptions regarding the i 3 mobilization of school bus companies in your mobilization
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4 study? That the school buses are there ready and available? 5 A (Callendrello) No. . 6 Q Or that they're out on their runs? 7 A (Callendrello) There's two parts to the analysis. 8 First, is the contact of the school bus company. 9 And for this analysis we assumed that the bus company 10 liaison has to make a telephone call to those school bus 11 companies once he arrives at the staging area. Excuse me, 12 at the EOC. 13 We have changed the procedure per I believe a 14 stipulation with the Attorney General to put the bus 15 companies on the automatic paging system, so that those bus 16 companies would automatically be notified and could begin 17 their mobilization process earlier than what we have assumed 18 in this analysis. 19 The mobilization times for the drivers were 20 developed based on the evaluation FEMA did of the 21 transportation suppliers to New Hampshire Yankee ORO. And 22 there the FEMA evaluators asked the que ation: response time, 23 should Seabrook request dispatch of your buses? 24 And they asked it in two ways: right now or for 25 off-duty employees? And we used a range of times based on ( Heritage Reporting Corporation ! (202) 628-4888
1' I REBUTTAL PANEL NO. 16 - CROSS 27112'
- 1 the answers that'were given to that survey.
7( N._ , 2 Q HIf the school' bus companies are out on their 3_ school runs at the time, the mobilization times for those 4 buses is going to be longer than estimated here, isn't it? 5 A (Callendrello) Not necessarily. 6 The FEMA survey asked how long the times were? 7 How long mobilization times were?. 8 Q Right now -- 9 A (Callendrello) And were given a range of times. 10 Q And the "right now" question was asked at
. l 11 different times of day; correct? !
12' AL (Callendrello) It said, "right now"; and then for 13 off-duty employees. j'>s 14 Q The mobilization times assumed here for this T N 15' capidly escalating accident assumed that there will be no 16 convoys from the bus yards, but that the individual buses 17 would be leaving from each yard as an individual driver and 18 an individual bus can be paired up; is'that's what's 19 happening? , 20 A (Callendrello) I don't think we made any explicit 21 assumption as to that. 22 No, I don't recall us making any assumption
. 23 whether they would convoy or whether they would drive 24 tpdiv4 92 ally .
25 Q Driving times assume to be nonrush hour times? rs
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l l REBUTTAL PANEL NO. 16 - CROSS 27113 i 1 A (Callendrello) Well, the driving times are 2 spelled out in Attachment 2 to Attachment E of our 3 testimony.
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4 Actually Attachment 1 uo that explains the basis 5 for the analysis and Attachment 2 provides the details. . 6 Q So you're not sure whether these times are rush 7 hour times or nonrush hour times? 8 A (Callendrello) Well, we've explained, as I said, 9 on Attachment 1 what speeds we assume the buses would 10 travel. 11 Q 50 miles on interstates; 40 miles per hour on
-12 primary. roads; 35 miles per hour on secondary roads?
13 A (Callendrello) And 25 miles per hour on tertiary 14 roads, that's correct. 15 Q That's the information you have? 16 A (Callendrello) That's correct. 17 MR. FIERCE: I have no further questions of this 18 panel. 19 JUDGE SMITH: All right. 20 Redirect? 21 MR. TURK: I have a few questions, Your Honor, if 22 I can have a minute unless the Board wants to go before me? 23 JUDGE SMITH: No, we don't have any questions. i 24 (Pause) 25 i t Heritage Reporting Corporation j (202) 628-4888 1 t _ _ _ _ _ _ _ _ _ J
REBUTTAL PANEL NO. 16 - CROSS 27114 e - - -: l'- CROSS-EXAMINATION
;j
. f. 2 BY MR. TURK:
3 Q Good afternoon, Panel. 4 There,was'some discussion earlier today about the 5' current.modeling of 4400 cars for the first, I believe 1.t's 6 established now to be the first hour and 25 minutes'in each 7 direction.
.8' Has that number of cars ever been, to your 9 knowledge, observed?
10 Is that based on empirical data or is that a 11 modeled assumption? 12 A (Lieberman) As I explained in the context of how 13 that number was used for the set of runs whose ETE are 14 listed in Attachment D, we' re talking about the case of the 7-~ 5s_/ - 15 staged assignment of guides at the TCPs.
' 16 At that time we were not considering commuters 17 explicitly.
19 And the use of 4400 represented the expected 19- number of returning commuters, plus some discretionary , 20 . trips. And that's how we arrived at the 4400, and then we 21 corrected that or extended it to include another 2000. 22 So that is roughly the number of returning 23 commuters on the interstates. 24 Q I guess I just want to clarify in my own mind the 25 difference between that number and the 3000 through-vehicles y Heritage Reporting Corporation 3, (202) 628-4888
REBUTTAL PANEL NO. 16 - CROSS 27115 1 that had been assumed in the initial set of testimony that 2 you presented in New Hampshire. 3 And tell me if I'm wrong, but the assumption of 4 those additional vehicles in the prior modeling that you 5 did, was that based on empirical observations or is that an . 6 assumption made that this additional number of cars would 7 account for increased trips? 8 Simply put, were 3000 vehicles observed in I-95 or l i 9 are they simply modeled in to account for extra trips? 10 A (Lieberman) Three thousand represents the number L 11 of through-vehicles on the highway system at the time that 12 the OTE takes place, and it's what we call an initialization 13 process. 14 That is, we load up the system with cars before 15 the simulation model starts making its computations, which 16 in effect sets the stage and represents the existence of 17 cars on the highway system at the time the -- in this case 18 it would be the site area emergency. 19 Then at the site area emergency, or when the folks 20 at the beach first start moving, we then add 4400 vehicles 21 per hour for an hour and 25 minutes, followed by, in our 22 sensitivity study, 2000 vehicles per hours for an hour. 1 23 Q To reflect your expected number of returning . 24 commuters? 25 A (Lieberman) And whatever discretionary trips Heritage Reporting Corporation ) (202) 628-4888 l l
l REBUTTAL PANEL NO. 16 - CROSS 27116 h l Lfqc , 1 . accompany them. I k ,)' 2 . Q There was some discussion ~ earlier today about the 3 fact'that if you assume that 40 percent of the vehicles in 4 ' beach areas were located in Massachusetts as opposed to.30 5 percent being located in Massachusetts, what effect would-6 that'have on the Salisbury ETEs. And I wantito ask you the L
- 7 other side of that coin. ,
l L 8 If.you.did assume 40 percent of vehicles in beach-l- 9 areas were in Massachusetts, what effect would that have on 10 the number of the cars in New Hampshire and what would be 11 the resulting impact on ETEs for New Hampshire areas? 12 A (Lieberman) Well, again,'I would preface my
- 13. answer by saying I wouldn't do it that way.
1 14 But clearly, if you fix the total number and
'N 15 assign more to Massachusetts, then you would have fewer in 16 New Hampshire. And the potential would be to load the ETEs 17' overall because the critical paths are New Hampshire.
18 However, there is a swing facter involved, because - 19 you are increasing the beach area vehicles in Massachusetts } 20 and you are reducing by the same number the beach area 21' vehicles in New Hampshire. And the effect of the swing 22 factor possibly could shift the critical paths to 23 Massachusetts. 24 Q Also, there was a question earlier about the 25 protective action recommendations that were issued during i
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REBUTTAL PANEL NO. 16 - CROSS 27117 1 the exercise in 1988. 2 And I would like to understand to what extent did 3 the various organizations consider ETEs in the issuance of 4 protective action recommendations. l 5 A (Callendrello) There were three organizations at , 6 issue, protective action recommendations. 7 The first was the onsite organization, the ERO. 8 In reviewing the exercise records, they did consider that, 9 at least in their analysis via METPAC of protective action 10 recommendations. And I'm not certain whether they did 11 further analysis through hand calculation or not. 12 But the METPAC analysis would have compared a 13 shelter and evacuation dose using evacuation time estimates. 14 The offsite response organization did not utilize 15 evacuation time estimates for that second general emergency 16 protective action recommendation, again namely because the 17 release was not blowing towards their communities, their 18 communities in Massachusetts. And, in essence, there would 19 have been no dose savings to trade eff, because there was no 20 dose yet there. 21 As far as New Hampshire goes, I'm not certain what 22 they used in the way of evacuation time estimates. They did 23 have the capability to run METPAC, and I believe they did 24 run METPAC independently. So to that extent, they would 25 have used evacuation time estimates in their execution of Heritage Reporting Corporation (202) 628-4888
e REBUTTAL PANEL NO. 16'- CROSS 27118 y I
'1: 'the'METPAC model..
hs_/ 2 Q .Possibly more, but'you don't know? 3 A. (Callendrello) That's correct. 4 Q There was also sorae questioning about the planning 5 basis'which is presented in Volume 6 of the NHRERP, in which 6 an order to. evacuate is assumed to occur 25 minutes after
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7' the beach closing recommendation.. 8 Is that, and I guess thiu should be directed to 9 lit. ' Lieberman or Mr. Callendrello, whoever feels it's most 10 appropriate. 11 What's the origin of that assumption? 12 Was that an idea that you came up with 13 independently, or was that suggested to you by some other e 14- source? k]/ ' 15 A (Lieberman) Well, it.happens in' stages. 16 The first thing that-we did, and I mentioned it 17 dates back to the Shoreham proceeding based on discussions 18 with planning folks there. And I asked the question,.uell, 19 how do I represent a rapidly escalating accident. , 20 And the reason I asked that question is that, as I 21 read Appendix 4 of 654, there is no precise guidance given 22 'as to how to establish a planning basis for the development a 23 of ETEs. They do provide curves which indicate the sequence 24 of events which in fact we adopted, but there is no scale in 25 the temporal framework. And you have to establish, in my
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1 REBUTTAL PANEL NO. 16 - CROSS 27119 j i 1 view, a temporal framework. 2 And the temporal framework which I felt j 3 appropriate to apply is that of a rapidly escalating
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4 accident, and I have to put some numbers to it. 5 And so the numbers that we use, namely, 15 minutes - 1 6 followed by 10 minutes, was suggested by the planning 1 7 personnel at LILCO. And that's totally independent of the l 8 beach area. That decision was made, as I say, a few years I 9 before I started work on Seabrook. 10 Now separately, my recommendation was to get the 11 beach people moving as quickly as possible, even before the 12 OTE, to provide them with the opportunity to get a head 13 start so to speak. Not as an evacuation, but as a beach 14 closing activity which would effectively stimulate a de 15 facto evacuation. 16 Beaches are closed. People are going to leave, at 17 least to the extent that the outbound roadways are 18 saturated. And that, after discussions with Seabrook 19 personnel, it was decided that, for New Hampshire anyway, it 20 was to be undertaken at the alert stage. And on that basis I l 21 I conducted the study. j i 22 Now the alert stage happened to 1x: coincident with 23 the time of 25 minutes prior to the OTE,. consistent with the 24 planning basis that I established. 25 Q Did you have any conversations with the Heritage Reporting Corporation l (202) 628-4888 I
REBUTTAL PANEL NO. 16 - CROSS 27120 1 Commonwealth of Massachusetts about that planning basis? 2 A (Lieberman) Oh, absolutely. 3 Q And what was their view of it? I 4 A (Lieberman) It was acceptable to the them. l 5 MR. FIERCE: Objection as to the form of the I 6 question. "Them", without identifying --
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7 MR. TURK: Well, too late on that question. 8 BY MR. TURK: 9 Q But I will now ask you to particularize it. 10 And can you tell us with whom you had discussions 11 among Commonwealth of Massanousetts officials? 12 A (Lieberman) My primary contact was -- his name 13 just slipped my mind. Buzz Hauser. And, of course, I spoke 14 to Mr. Boulay. 9 15 Q Could you identify who they are? 16 A (Lieberman) Mr. Boulay is the head of the 17 Massachusetts, or was at least, the head -- I think still 18 is -- the head of the Massachusetts Civil Defense Agency. 19 Mr. Hauser was, I believe, a consultant working for the , 20 MCDA. 21 Q And what was his function as a consultant for the 22 MCDA? 23 A (Lieberman) I can't tell you what his complete 24 function was, but as far as I was concerned he was the man 25 to whom I reported and held conversations with. O Heritage Reporting Corporation (202) 628-4888
I REBUTTAL PANEL NO. 16 - CROSS 27121 1 Q And both he and Mr. Boulay accepted and agreed 2 with this planning basis? 3 A (Lieberman) Well, the planning basis was 4 documented in one of the progress reports which I submitted 5 for review. And they had some comments over the phone on 6 these reports, and that issue did not arise. 7 So I guess there is a tacit acceptance. 8 Q All right. 9 And in fact, you had done several -- I forget the 10 word you used -- several iterations of your work in 11 consultation with Massachusetts. 12 Isn't that right? 13 4 (Lieberman) Well, yes. 14 There were.seven progress reports. There were 15 several meetings where members of the MCDA attended at 16 Seabrook, I believe, at places near Seabrook, in Framingham, 17 where we discussed the ETE. 18 Q And throughout these progress reports, was the 19 same planning basis within your study?
- 20. A (Lieberman) Yes, there has been only one planning 21 basis.
22 Q And there was objection to it by Massachusetts 23 officials? . 24 A (Lieberman) That's correct. ' 25 Q There was also some discussion about the Loss of I l Heritage Reporting Corporation (202) 628-4888 O i 1
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} - If REBUTTAL-FANEL'NO. 16 - CROSS 27122 g 1 . Service Level E and Loss of Service Level F. And I.believe
'Mr. Fierce asked you why you don't use a 15 percent-
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capacity reduction factor at Loss of Service E. And in that 4 regard, I just want to clarify one thing. 5 You indicated that there are five-minute sweeps i t 6 being done within the I-DYNEV modeling that you have done. 7 A- -(Lieberman) Time steps. 8 Q Would each of those five-minute sweeps then 9 identify changes in. Loss of Service levels at particular-10- nodes as they go from E to F7 11' A (Lieberman) Yes, of course. 12 (Counsel confer.) 13 Q. I'm sorry. If I said Loss of Service Level,_I
- f s. 14 should have said Level of Service Level.
( V )^ '15 .In that context, that's your answer, correct? A 16 (Lieberman) Yes. 17 The reason I didn't pick you up is that engineers 18 often phoneticize L-0-S as LOS, and I thought you were doing 19 that. . 20 JUDGE COLE: He's not an engineer. 21 (Laughter.). 22 BY MR. TURK: 23- Q That's the acronym, LOS. 24 Mr. Callendrello, I want to ask you one question ) l 25 about the use of evacuation time estimates by 1'
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REBUTTAL PANEL NO. 16 - CROSS 27123 1 decisionmakers. And I wasn't sure of the context in which 2 you were giving your answers in that regard. 3 Would a decisionmaker be free -- let me give you a 4 hypothetical. 5 Assume that it's a summer l early morning on a . 6 weekend, good weather, for which there was no specific 7 scenario in Volume 6 of the NHRERP or in your testimony. 8 Would a decisionmaker be bound to follow a 9 particular one of these ETEs that have been calculated, or 10 could he use his own judgment in determining to what extent 11 that ETE is appropriate? 12 A (Callendrello) I'd say he could use his own 13 judgment. There is no requirement that absolutely one of 14 those scenarios be selected. , 15 Q So, for instance, hypothetically if the scenario 16 which closely resembled the situation at a particular time 17 predicted an ETE of six hours, the decisionmaker would be 18 free to adjust that up higher or lower, depending on his 19 perception of how actua3 conditions modeled that predicted 20 scenario? 21 A (Callendrello) I think to some limited extent. 22 As I indicated to Mr. Fierce, the range of ETEs is 23 not that large. And I think in the situation that we are 24 operating under, we want to use the scenarios that are there 25 as much as possible, because our interest is to make a Heritage Reporting Corporation (202) 628-4888 l
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REBUTTAL PANEL NO. 16 - CROSS 27124 1 protective action recommendation and to make it in a fairly 2 short amount of time. 3 And as I indicated through some other questions, I 4 don't see that the protective action recommendation would 5 necessarily turn on an evacuation time estimate that is 6 within 15 minutes or 20 minutes accuracy, or even an hour,
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7 an hour and a half. 8 So that you would pick a reasonable scenario for 1 9 the conditions that you ar7 faced, with the knowledge that 10 there are other conditions out there, but I don't think 11 there would be a detailed analysis of those other 12 conditions, i l 13 Q Just to get a sense of the bounding of it, let me ( 1 1.4 give you two extremes and I'll represent to you almost 9 15 absolutely impossible situations. l I 16 If there had been a prior evacuation, for 17 instance, for whatever reason, and then an accident occurs 18 at Seabrook and the decisionmaker turns to the ETEs, but he - 19 knows there has already been an evacuation of the area, he . 20 would be able to consider that in his judgment and adjust 21 downward the predicted time for the actual evacuation for 22 Seabrook, right? 23 A (Callendrello) Yes. 24 MR. FIERCE: Objection. Confusing statement. 25 JUDGE SMITH: Too late. He's already answered. O Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - OROSS 27125 1 BY MR. TURK: 2 Q And your answer was yes. 3 And then let me give you the other extreme. 4 Assume that it's a winter snowstorm w:'.th extreme icing so 5 that roads are absolutely impassable. . 6 The decisionmaker would be able to use his 7 judgment to know whether or not the predicted ETE would 8 apply. 9 Is that right? 10 A (Callendrello) Yes. And, in fact, you may never 11 even get to that step where you consider an ETE. 12 As I indicated, those attachments are designed to 13 prompt the decisionmaker to ask the questions, should I 14 recommend a protective action, and can I recommend a 15 protective action. 16 So in that case, it's likely you would never even 17 get to the consideration of evacuation time estimate. 18 MR. TURK: No further questions. 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 i
REBUTTAL PANEL NO. 16 - REDIRECT 27126
,_s 1 MR. DIGNAN: Just one very brief subject, Mr.
I ') ( ,/ 2 Callendrello, to make sure I heard something right. 3 REDIRECT EXAMINATION
" l 4 BY MR. DIGNAN:
5 Q You, in your discussion with Mr. Fierce of when 6 you might order or recommend shelter as opposed to
)
7 evacuation, you indicated that you could conceive of a 8 situation where three factors added up to less than the ETE. ; i 9 I believe those were the time to release; the release 10 duration; and what was the third one you put in that 11 equation? 12 A (Callendrello) The. travel time of the release to 13 the location-of-interest. ; { 14 Q In making that decision would you have to have a 7w
? / 'N_/ 15 very high confidence level in the release direction 16 projection?
17 A (Callendrello) You would want to have some l 18 confidence in that. 19 And I would say, you would want high confidence, , 20 yes. 21 MR. TURK: I' ra sorry, I didn't hear that. 22 Was that release direction? l 23 MR. DIGNAN: Duration. Duration. 24 THE WITNESS: (Callendrello) Correct.
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l REBUTTAL PANEL NO. 16 - REDIRECT 27127
- 1. BY MR. DIGNAN:
2 Q And from your experience and from your 3 relationships with, as you said, people who are experts in 4 accident scenarios, is it your judgment that there are any 5 large number of accidents where you could have a high - 6 confidence of a projection of the duration of a release? 7 A (Callendrello) No, I know of -- I know of a few 8 accident scenarios where you would have high confidence. 9 Perhaps, if you were in a controlled release situation you 10 would have high confidence as to the duration of the 11 release. 12 And I think Dr. Bores mentioned a scenario where e 13 you had a scenario such as a waste gas rupture and you knew 14 the volume of the tank, and therefore knew the amount of gas 15 that could be released. 16 But other than those limited scenarios, I think 17 the information I have been provided is that it is difficult 18 to project the duration of the release. 19 MR. DIGNAN: That's all I have. 4 20 JUDGE SMITH: Do you have recross? 21 MR. FIERCE: I did have one or two questions, Your 22 Honor. 23 24 25 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - RECROSS 27128 I
-1 RECROSS-EXAMINATION 2 BY MR. FIERCE:
3 0 In those discussions with the Massachusetts 4 officials it was assumed all along that there would be a 5 simultaneous beach closing in New Hampshire and 6 Massachusetts with an OTE that would follow 25 minutes 7 later; correct? 8 MR. TURK: That's beyond the scope of my 9 questioning, Your Honor. 10 MR. FIERCE: Certainly is not, Your Honor. 11 MR. TURK: My question was whether the short time, 12 the 25 minute time frame, that part of the planning basis 13 was ever objected to by Massachusetts. 14 MR. FIERCE: And I just want to clarify -- 9 15 MR. TURK: And that is, which areas would be 16 evacuated when. 17 MR. FIERCE: I just want to clarify that. 18 JUDGE SMITH: Overruled. 19 You may answer it. , 20 BY MR. FIERCE: 21 Q In those discussions, Mr. Lieberman, the 22 assumption was that there would be a simultaneous beach 23 closing in New Hampshire and Massachusetts which would occur 24 25 minutes before the OTE; correct? 25 That's what the Massachusetts officials had no G Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 16 - RECROSS 27129 1 objection to; correct? 2 MR. TURK: That -- 3 THE WITNESS: (Lieberman) No, I wouldn't 4 characterize it that way. They had no objection to using - 5 that as a planning basis. 6 BY MR. FIERCE: 7 Q Correct. 8 Just to clarify. I thought I had gone over one of 3 these points with you, Mr. Callendrello, with respect to 10 what the protective action de;ision-makers would do, and I 11 know Mr. Turk is trying to get you to agree and I think you 12 did agree that they're not bound, you know, to use the ETE. 13 But what are they trained to do in their training 14 and in their procedures with respect to referencing an ETE7 15 I thought you told me they were trained and would 16 reference one of those numbers that is in the table and use 17 that in the protective action work sheet in IP-2.57 18 A (Callendrello) That is what they are trained to I 19 do. 20 But as Mr. Roberts indicated in his deposition and 21 I've indicated today, that if you've got some better 22 information and you feel that you need to interpolate { i 23 between ETEs, you're certainly free to do that to provide ) 24 better information. 25 Q Do I understand your last answer with respect to i noritage Rcperting Corporatzen (202) 628-40b8 I I i E_____
= = - - -- c N, REBUT'TAL PANEL NO. 16 - RECROSS' 27130 l 1 - the , question Mr. Dignan asked you to mean, essentially, the i f
\ 2' ORO .1 never really. expects to implement a sheltering PRA?
3-' 'A (Callendrello) I wouldn't say "never."
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4 I would say, evacuation is the likely protective 52 action recommendation. 6 Q It's so remote that it's essentially vanishing 7' though out there some place; is that what you're saying?
- 8 A (Callendrello) I would say it's less likely than 9' evacuation. .
- 1 10 MR. FIERCE: No further questions.
11, JUDGE SMITH: Anything further? 12 (:No response) 13 0WOGE SMITH: All right, you're excused. 14 (The witnesses were excused.) i' 15 JUDGE SMITH: Anything further before we adjourn? 16, (No response) 17 JUDGE SMITH: We're adjourned until 8:30 tomorrow. 18 (Whereupon, at 5:16 p.m. the hearing was adjourned - 119 ' to reconvene tomorrow morning at 8:30 a.m., Friday, . 20 June 23, 1989.) 21 22 23 24 25 Heritage Reporting Corporation j (202) 628-4888 r.
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MASSACHUSETTS ATTORNEY GENERAL'S CROSS EXAMINATION PLAN FOR APPLICANTS' REBUTTAL TESTIMONY NO. 16
+
(EVACUATION TIME ESTIMATES) I. Establish what Mr. Collendrello brings to this testimony - 3 II. Review that the history of ETEs for Massachusetts gave us this sequence of numbers: -
- 1. Volume 6
- 2. NRC Staff Exhibit No. 1
- 3. SPMC
- 4. Attachment D to this testimony I
III. Why are only ERPA's 8 and 13 provided for Massachusetts? Establish what towns each contains. What about Regions 4, 5, 1 1 ', 12, 14, 16 and 177 (See Appendix J at J-163 through J-196.) The critical paths are in New Hampshire? (See p. 14 of testimony.) IV. CallendrEllo: Practically speaking, how does a Massachusetts PAR decision-maker reference on ETE for Salisbur.y in a situation in which (all he knows in that New Hampshire is considering evacuating some portion of th New Hampshire EPZ, but whether it vill do so out to 2, 5, or 10 miles is not yet knowable? V. Establish that the numbers provided inat^he SP,MC's ETEs are for the last car to clear the ester bundary ' of the region? (NH or Mass.). VI. Establish that a Mass. decision-maker who is hahded - the SPMC's ETEs has no way of knowing . .(d for Region 8, whether the time provided is the ktime for Amesbury and Salisbury to evacuate or the time to evacuate Suabrook, e.~e (z) 4.h rugi n, 4 % :) L. W y y %y VII. Establish tht ETEs for just the Mass. towns could have been provided using IDYNEV VIII. (Pane 5). Why did you apply a 0.9 directional split over the duration of the evacuation? What will the split be during the first few hours at mid-day during a weekday in the offseason? 1 O i
IX. How do you know, roughly, what cycle length would be I actually implemented by the traffic guides? (p.6) ( ) X. Regarding B-AM-06, in calculating your latest ETE, for
' - ' the SPMC, what % (1) turn right, (2) go straight, (3)
U-turn? All those who "go straight" come from areas
. assigned to the Beverly reception center, correct?
XI. Questions about 4the Capacity reduction factor. XII. Questions about the permanent resident populatin used. s O XIII. Questions about the allocatin of the 31,000 beach area -
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vehicles. XIV. (P.22) Regarding Amesbury's fireworks, Lieberman says the " minimum" area required to park one car in a lot is about 250 sq. feet? Where do you get this figure?
+k-,
XV. (P.23) When h&yhe fireworks occur on a summer weekend evening, what is (the Region 13 ETE? 9 Might the TOA ETE be longer than this? XVI. (P.23) IDYNEV output for TOA (3:30) kwas determined how? What scenario? : XVII. Questions about the Pro Beach Volleyball Tournament
/ speculation on P.24.
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XVIII. (P.25) How was the est. of 671 transit vehicles in Newburyport arrived at? Kaltman? XIX. (P.26) What is the Newburyport ETE for a summer evening? What is the Region 13 ETE for a summer evening? - XX. Some questins about through vehicles. XXI. Some questions about vehicles from Seabrook Beach. XXII. If there are confusing and/or. conflicting messages issued to the public, there could be a numbr of consequences besides delayed mobilization, including ; hevacuees taking different routing, increased shadow j evacuation, greater driver uncertainty. Sensitivity I truns were only done for summer scenarios, not for ! offseason scenarios, which may well have longer ETEs if these things occur.
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XXIII. Questions about the planning basis (p.33-34). XXIV. Exkplore how delays in PAR decision-making process would affect the planning nasis ETEs, which assume only 25 minutes between the SAE and the OTE. )p.35) See also p. 37). XXV. Delays in the PANS system could affect the planning - basis ETEs: simultaneous Alert and SAE with people on the beaches moving to their cars immediately. XXVI. (P.35) Establish that they assume the ORO Traffic guides will implement traffic control and facilitate movements of traffic just as efficiently as police officers. $No basis for this judgment. If they were 10% less efficient, this would affect ETEs by 10%. XXVII. Explore the " rolling terrain" road capacity issue. Why was it done? Isn't it an unneeded conservation that tends to lengthen ETEs for beach area unrealistically? (p 36). XXVIII. Some questions about Traffic Guide mobilization and Muse of TRAD. XXIX. Revised ETEs (p.43) questions. a) Input problems still exist. b) ETEs in Region 8 & 13 are for critical paths from NH. XXX. Whatdb$ewayoperationsdataarereferencedonp.45? Explain how the reduction factor kworked previously? How low? In earlier runs, the 15% capacity reductti>n factor wasn't always there, correct? Yet you used that 15% factor to argue that there were no ETE concerns abot 1) aberrant driver behavior, @) returning commuters. Explain "for the most part" on line 17 of page 45. XXXI. Why does panel assume that Seabrook Police will late-Staff its posts.along Seabrook beach (p.46). If this does not happen, EIEs rise. XXXII. (P.46) The table shows NH critical paths. What are the numbetrs just for Mass.? Explain the inconsistency for Scenario 5. 'l l l O
i l L. b i
/-~s 33. Ho. staffing points (2 & 3) on p. 47.are traffic ;
l 1 management points. (Move to strike.) i
'N // (If in) ... What routes. selected (were any away from )
designated reception centers)? l
. 34. ,Some questions about TRAD's impact.on the ETEs. (Sea-
- p. 46 and p. 48.) ]
..: 35' Explore'the difficulties PAR decisionmakers in Massachusetts will have in assessing PARS for E Massachusetts using these ETEs for only ERPAs 8 &-13.
- 36. Explore the first sensitivity test described on o. 50.
- 37. Explore the limitations of the 2nd sensit-ivity test descrioed on p. 50.
- 38. (p. 51) What about advising the RHA about mat ters which may reduce the estimated ETE? Is this not done? Why nave the discussion at all if "no adjustments need to be made to the ETEs."
- 39. (p. 52) While the ETE scenarios are the same as those used in the NNRERP, the SPMC contains'only 2 of the potential applicable regions.
(~'s 40. (p. 52) Questions about the conditions in which ' 1( ,) evacuation.would not be.the preferred PAR (No. 6).
- 41. Some questions about Real Time ETEs, their
, " counter"-phobia, and t he use of ~ the photo-based real-time system suggested by Dr. Adler on p. 28 of i his ETE testimony.
- 42. What is the % which is left out of t he scenar'io description in Attachment A?
'43. Establish that Special Facility ETES could be.
calculated and-that there are situat ions in which thev would be useful.
- 44. Some questions about the use of Northern Essex Community College.
- 45. ETES f or the special populat ions (non-facility) have still not been calculated for Massachuset ts.
- 46. Some questions about the 3us Mobilizat-ion st ud" 1525n
.(
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CERTIFICATE O This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of: l Name: Public Service Company of New Hampshire, et al. (Seabrook Station, Units 1 and 2) Docket No: 50-443-OL 50-444-OL (Off-site Emergency Planning) Place: Boston, Massachusetts Date: June 22, 1989 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken stenographically by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings.
/
f' / 4 i I'
/S/ !L /r
/ / rd //iq- v~
6/ / (Signature typed) : Donna L. Cook ,
*1 Official Reporter
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Heritage Reporting Corporation HERITAGE REPORTING CORPORATION (202)628-4888 . . . __}}