ML20246N679

Rebuttal Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Interaction of Commuter Flow & Evacuation Traffic Flow within Seabrook Epz.* W/ Certificate of Svc.Related Correspondence

ML20246N679
Person / Time
Site:	Seabrook
Issue date:	06/30/1989
From:	Adler T MASSACHUSETTS, COMMONWEALTH OF
To:
References
CON-#389-8849 OL, NUDOCS 8907200022
Download: ML20246N679 (14)

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'[O( h[ II 0 UNITED STA~IES OF AMERICA

• NUCLEAR REGULATORY COMMISSION

~ ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges: GFF!Ct '.< S m e -

Ivan W. Smith, Chairperson Dr. Richard F. Cole WN W I# t""' N L Kenneth A.McCollom 1

In the Matterof-PUBLIC SERVICE COMPANY OF NEW- Docket Nos.

HAMPSH'"" ET AL. .

50-443-444-OL (Seabroot u.ation, Units 1 and 2)

(Off-site EP)

June 1989 REBUTTAL TESTIMONY OF DR. THOMAS J. ADLER ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OFMASSACHUSETTS.-

CONCERNING INTERACTION OF COMMUTER FLOW Aht EVACUATION TRAFFIC FLOW WITHIN THE SEABROOK EPZ Deparueent of the Attorney General .

Commonwealth of Massachusetts One Ashburton Place Boston, Massachusetts 02108-1698 (617)?27-2200 ga72gggg ggg3 3;;;

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g ce I. IDENTIFICATION OF WITNESS

- Q. What is your name and current occupation?

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

Q. Are your professional qualifications as set forth in the testimony and attachments

- filed for this case on September 14,1987 and summarized in testimony submitted on February 21, 1989?-

A. Yes, they are.

II. TESTIMONY.

_Q. Have you had an opportunity to review the Supplement to Applicants' Rebuttal Testimony No.16, as submitted on June 13,19897 ,  ;

A. Yes, I have. That testimony seeks to address the somehat narmw issue over which the Board has retained jurisdiction by focussing on the impact on ETE's of returning commuters whose trips pass through certain critical intersections or along constraining roadway sections used by beach area evacuees. We were provided both with a written copy of that testimony and with additional technical materials supporting the analyses described in the testimony. Specifically, the

. Applicants provided printed and computer-readable copies of output from the IDYNEV sensitivity run described in the testimony and a supplementary " link-node" map that serves as an index to the outputs.

Q. Would y,u begin by summarizing briefly your understanding of the Applicants' June 13,1989 Supplemental Testimony?

A. That supplemental testimony includes sections which: 1) identify the focus of at:alysis as being on the effects of commuter traffic on " critical paths" which are dermed generally as tho:e evacuation routes which constrain evacuation times,2) describe why a representation of commuter flows through all parts of the network may be unnecessary and represent that the effects of commuter flows are accounted for by an area-wide 15% capacity reduction factor,3) describe

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, , V Adlef Reicming Commuters Rebuual - 2

" preliminary analyses" which estimate the effects of commuter traffic on ETE's,4) describe a

" sensitivity study" modeling these effects directly in IDYNEV, and 5) present a comparison

- between the commuter database compiled fmm a survey conducted in 1987 by Social Data Analysts for the Massachusetts Attorney General and commuter data derived from KLD's 1985 survey.

l Q. Do you agree with the chosen focus on " critical paths"?

A. I agree that, in practice, the most important effects of commuter traffic flows in the

- Seabrook EPZ will be along a limited number of evacuation routes. While it would be desirable conceptually to include explicit representation of all commuter traffic flows, the chosen focus on a

-1 limited number of constrained paths is a practical and cost-effective attemative which, if properly -

- applied, can accurately represent effects on ETE's. .,

Q. Do you agree that it would be substantially more effort to model all commuter traffic flows than to model selected, major flows?

A. At this point, for the Seabrook EPZ, yes, I do.

Q. ,

Do you believe that the effects of returning commuters are adequately accounted in 1 i

the use of a 15% highway capacity reduction factor? 1 A. As reiterated in the Applicants' Supplement to Rebuttal Testimony No.16 (page 8),

this capacity reduction factor was originally applied to "intemipted flow" facilities to account for

- the effects of driver uncertainty and short-term disruptions during an evacuation. Interruptions in congested traffic flow caused by vehicles which run out of gas, become overheated, or otherwise become disabled by accidents, by drivers stopping to ask for directions or obtain information about

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the evacuadon, and by the unfamiliarity of drivers with the routes are not amenable to explicit I modeling but could certainly account for the full 15% capacity reduction. The effects of retuming commuters, on the other hand, are simply additions to the traffic stream that can be modeled directly. In my opinion,it would be prudent to use the 15% reduction factor to account for all l uncertainties which are not amenable to modeling and to estimate the ETE effects of retuming commuters using properly executed sensitivity runs.  ;

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i Adler Returning Cornmuters Rebuttal 3

Q. Do you agree with the preliminary analyses outlined in Applicants' Supplement to Rebuttal Testimony No.16, pages 12 to 25?

A. I agree that it is possible,in concept, to develop a rough estimate of the effects of returning commuters by the types of calculations presented, but I disagree with several very imponant details of the calculations presented. For example, at the bottom of page 16, the i Applicants assen that, at the Rt.1/Rt. I A/P.t.110/Mudnock Rd. intersection in Salisbury, it is appropriate to consider the effects of only the commuter trips from the south since commuters heading nonh and south will " time-share the intersection and the number of trips from the nonh is lower. This would be an appropriate assumption if the intersection were managed by a traffic signal or by an efficient traffic guide system. However, during the portion of the evacuation (the first two hours) for which commuter flows are highest, this intersection will be unstaffed by tra guides and will operate with existing traffic controls. The existing traffic controls allow free movement along Rt.1 north and south but have stop sign control for traffic eastbound and westbound along Rt.1 A. Thus, for the firs: two hours until the guides arrive, each carload of westbound Salisbury Beach evacuees will have to stop and wait for gaps in the total nonh-south i traffic before proceeding. This means that the capacity for this evacuation route could be reduced by as much as the total of the nonh plus south Rt. I commuter traffic. Funher, the lost and clearance times for Rt. I A traffic will be even much greater than assumed in the Applicants' analyses which have given the same priority to westbound Rt.1 A traffic as to the Rt. I traffic. In other words, in their analyses most of the vehicles heading westbound on Rt.1 A do not stop at Salisbury Square intersection. In actuality, a great deal of time will be lost by this traffic stream when each vehicle stops at the stop sign there. Together, these effects will more than double the extent of capacity reduction calculated by the Applicants.

In the Town of Hampton calculations (beginning page 19), the Applicants use 641 inter-torn internal commuters as the base for calculations, based on their 1985 survey data. The more recent survey conducted by consultants to the Massehusetts Attomey General shows over 1800 such commuters, a difference of almost three-fold. (See Attachment F to the Supplement to

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' Applicants' Rebuttal Testimony No.16.) Accounting for only this difference would increase the computed effects on iost capacity to over 15%. Several other points included in the Applicants' discussion of Hampton commuters deserve further comment. First, on page 20 to 21, they note -

that Rt.101C is not a critical path for Region 13, Scenario 3; that Rt. I congestion spillback effects  !

from evacuations of Nonh Hampton, Rye and Ponsmouth cause the Rt.101C capacity constraint.  !

If this is the case, then Portsmouth commuters, which comprise the largest single concentration in the EPZ, should also be modeled. The Applicants' testimony assens that Routes 101C and 101D are more likely to be used by commuters than is Rt. 51 because the former roads would be less congested. This assenion is contradicted by the Applicants' previous IDYNEV runs which show  !

Routes 101C and 101D being heavily congested through the period when commuters would be attempting to return home. (Recall that the beach closing occurs before employees are advised to return home.)

Q. Did you have an opportunity to review the IDYNEV sensitivity study reponed on pages 28 to 36 of the Applicants' Supplement to Rebuttal Testimony No.16,7 A. Yes,I did. Sufficient information was provided by the Applicants,in addition to t% written testimony, to permit me to review the assumptions made and the detailed outputs from that stucly. i q

Q. Do you agree with the assumptions and inputs to IDYNEV used in that study?

i A. Although I was unable to replicate all of the inputs provided to IDYNEV, I was able to verify that the general methodology used to represent returning commuters is an appropriate one.

. However, there are four specific inputs which I believe should be corrected. First, the Rt.1/Rt. '

1 A/Rt.110/Mudnock Rd intersection is modeled during the early stages of the evacuation when i

the intersection is unstaffed as allowing direct movements without stop control on Rt. I A westbound. This problem was discussed earlier in this testimony. Second, at this same intersection, Rt.110 west of the intersection is modeled as having two lanes westbound (for evacuees) and one lane castbound (for returning commuters) when, in fact,it has only a two-lane total cross section just to the west of the intersection. Third, the capacity reduction factor was s

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' Adler Returning Commuters Rebuttal 5

decreased from 15% to 10% on all links. Even if one does not agree with me that this fraction should be retained to cover other effects (see above), there are two pmblems with doing this; 1) the capacities are now overestimated for expressway ramps and mainlines for which the 15% capacity j reduction was intended to represent actual deterioration of flow under congested conditions, and 2) this increase in roadway capacity confounds the comparison of ETE's with and without I l commuters, in effect masking a 5% EE increase in the retuming commuters run. And fourth, the p q

number of Hampton commuters used is only one-third the number identified in the more recent Massachusetts Attomey General's survey. This last item, in particular, is quite important in terms of the effects on ETE's. '

Q. If these four factors were properly accounted, would the effect of retuming ii '

i commuters on ETE's be amplified?

A. Yes, it would, particularly if the full population of Hampton commuters were added.

Q. Did you conduct a more detailed comparison of the IDYNEV outputs from ,

- equivalent Region 13, Scenario 3 runs with and without returning commuters.

A. Yes,I did. I mentioned earlier that we were pmvided detailed outputs from these  !

runs, and with those outputs were able to construct a more detailed portrayal of the effects of returning commuters, as modeled by KLD.

Q. Would you please describe these effects?

A. As correctly noted in the Applicants' testimony (page 36) the overall ETE increased from 6:00 to 6:05 after commuters were added to the network. (As I noted earlier, the 6:05 l

includes an effective 5% capacity increase; were an apples to-apples comparison made, the retuming commuters scenario ETE would be approximately 6:25.) This relatively small change in i overall ETE, however, presents only part of the picture; there are significant changes in the l evacuation times for critical beach areas and for the Massachusetts portion of the EPZ caused by the addition of retuming commuters even as modeled by the Applicants' consultant. For example, the Applicants' own I-DYNEV output files indicate that the ETE for the Massachusetts portion of

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' Adler Returning Commuters Rebuual 6

i the 5 mile ring increases from 5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> to 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> - an increase of 20%. Furthermore, the +

Applicants' output files indicate substantial changes in the rates at which the beach areas evacuate - 4 when the effects of return commuters are included. Figures 1,2, and 3 compare the "with commuter" and "without commuter" fractions of beach traffic remaining in the Salisbury.

Seabrook, and Hampton (south of Rte 51) Beach areas for each hour after a simultaner os beach  !

closing in New Hampshire and Massachusetts. As shown by the Applicants'own sensitivity ru l

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the presence of retum commuter traffic significantly reduces the rates at which the beach areas can

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be evacuated during the first 3 to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> of an evacuation. 'Ihese runs show the following changes in Beach area ETE's:

1 Beach Area ETE's , l i I (relative to OTE) l

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Beach Area i w/o Commuters w/Co nmuters ETE Increase Salisbury 4 Hrs 30 Mins 5 Hrs 35 Mins 24 %

Seabrook 4 Hrs 45 Mins 5 Hrs 45 Mins 21 % '

Hampton 5 Hrs 5 Mins 5 Hrs 50 Mins 15 %

These changes in ETE's indicate that the umbrella assumptions currently being used to represen ,

the effects of commuter flows mask important effects. Clearly, the inclusion in these runs! ofju limited portion of the total return commuter traffic bears out the claim that more explicit (but still short of complete) modeling of all commuter traffic is required to adequately anticipate the effects  ;

of these conflicting flows. i l i

Q. Do you believe that ETE's based on the modeling of returning commuters as demonstrated by the type of sensitivity study Applicants have now done, should be incorporated i

into the NHRERP and the SPMC7  !'

A.

Yes, more explicit modeling of retuming commuters should be incorporated in a

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Adict Returning Commuters Rebuttal 4 7 l revised base run for all scenarios and regions. The results presented in NHRERP Vol. 6 should be updated, as appsopsiane. A set of ETE's for the Massachusetts communities alone should be j

t prepared for Massachusetts decision-makers. The methodology used by KLD for the commuter i sensitivity study appears to be an appropriate one and, with the changes in input assumptions noted i ;

. l carlier (including some representation of Portsmouth commuters), would produce more reliable lI ETE's. t i

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i Region 13 Scenario 3 1.0 0.9 0.8 E w/ commuters E w/o commuters Vehicles Remaining 0.5 Along Sallsbury Beech 0.3 0.2 0.1 0.0 0 1 2 3 4 5 6 7 8 Time afterM(Hours)

BeneA desiny Figure 1

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Region 13 Scenario 3 1.0 0.9 0.8 5 w o e m ut rs Fraction of 0.6 Vehicles Remaining 0.5 Along Seabrook Beech 0.3 0.2 0.1 0.0 -

i i i i 0 1 2 3 4 5 6 7 8 Tirne anorm( )

Figure 2 l

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Region 13 Scenario 3 1.0 0.9 0.8 0.7 E w/ commuters Fraction of 0.6 l Vehicles Remaining 0.5 Along Hampton Beach 0.3 0.2 0.1 0.0 ,

i i i- i i 0 1 2 3 4 5 6 7 8 Time afterM( urs Figure 3 i

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UNITED STATES 0F AMERic;.

NUCLEAR REGULATORY COMMISSION 39 Ji -5. A10 :37 ATOMIC SAFETY AND LICENSING BOARD cri , .

DCChi. i n 4 Before the Administrative Judges: I*'

'Ivan W. Smith,-Chairman-Dr. Richard F. Cole Kenneth A. McCollom

)

.In th e. Matter of ) . Docket Nos. 50-443-OL

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

OF NEW HAMPSHIRE, _E T_ _A _L . )

)

(Seabrook Station, Units 1 and 2) ) June 30, 1989

)

CERTIFICATE OF SERVICE I, Leslie B. Greer, hereby certify that on June 30, 1989, I made service of. REBUTTAL TESTIMONY OF DR. THOMAS J. ADLER ON BEHALF OF JAMES M. SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS, CONCERNING INTERACTION OF COMMUTER FLOW AND EVACUATION TRAFFIC FLOW WITHIN THE SEABROOK EPZ and MOTION FOR THE 3

BOARD TO ACCEPT AN EXHIBIT via Federal Express as indicated by [*]

and by First Class Mail on June 30, 1989 to:

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

.U.S. Nuclear Regulatory Stillwater, OK 74075 Commission East West Towers Building Docketing and Service 4350 East West Highway U.S. Nuclear Regulatory Bethesda, MD 20814 Commission Washington, DC 20555 l'

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

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

Atomic Safety & Licensing Board Katherine Selleck, Esq.

U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place 4350 East West Highway Boston, MA 02110 Bethesda, MD 20814 H. Joseph Flynn, Esq. Sherwin E. Turk, Esq. 1 Assistant General Counsel U.S. Nuclear Regulatory Office of General Counsel Commission Federal Emergency Management Office of the General Counsel Agency 15th Floor 500 C Street, S.W. 11555 Rockville Pike Washington, DC 20472 Rockville, MD 20852 Atomic Safety & Licensing Robert A. Backus, Esq.

Appeal Board Backus, Meyer & Solomon j U.S. Nuclear Regulatory 116 Lowell Street  !

Commission P.O. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Board Jane Doughty U.S. Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 Charles P. Graham, Esq. Barbara St. Andre, Esq.

Murphy & Graham Kopelman & Paige, P.C.

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

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

Harmon, Curran, & Towsley 145 South Main Street i Suite 430 P.O. Box 38 2001 S Street, N.W. Bradford, MA 01835 l Washington, DC 20008

l

. 1 Senator Gordon J. Humphrey Senator Gordon J. Humohrey U.S. Senate One Eagle Square, Suite 507 -

Wasnington, DC 20510 Concord, MH 03301 -

(Attn: Tom Burack) (Attn: Herb Boynton) -

)

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

office of the Attorney General Assistant Attorney General 25 Capitol Street Department of the Attorney .)

Concord, NH 03301 General Augusta, ME 04333 i 1

William S. Lord Board of Selectmen Richard Donovan Town Hall - Friend Street FEMA Region 10 Amesbury, MA 01913 130 228th Street, S.W.

Federal Regional Center Bothell, WA 98021-9796 i COMMONWEALTH OF MASSACHUSETTS JAMES M. SHANNON ATTORNEY GENERAL L b']

Leslie B. Greer Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED: June 30, 1989

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