ML20247M587
| ML20247M587 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 03/26/1989 |
| From: | Adler T MASSACHUSETTS, COMMONWEALTH OF, RESOURCE SYSTEMS GROUP |
| To: | |
| Shared Package | |
| ML20247M539 | List: |
| References | |
| OL, NUDOCS 8904060085 | |
| Download: ML20247M587 (21) | |
Text
_ _.
UNITED STATES OF AMERICA
{
NUCLEAR REGULATORY COMMISSION -
]
b ATOMIC SAFETY AND LICENSING BOARD Before the AdministrativeJudges:
Ivan W. Smith, Chairperson Dr. Richard F. Cole Kenneth A.,McCollom In the Matter of PUBLIC SERVICE COMPANY OF NEW Docket Nos.
50-443-444-OL (Seabrook Station, Units 1 and 2)
(Off-site EP)
March 26,1989 AFFIDAVIT OF DR. THOMAS J. ADLER REGARDING INTERACTION OF COMMUTER FLOW AND EVACUATION TRAFFIC FLOW WITHIN THE SEABROOK EPZ Department of the Attorney General Commonwealth of Massachusetts One Ashburton Place Boston, Massachusetts 02108-1698 (617) 727-2200 970406 oc t r tio33.p!
?DR Abeck-orcee w3 4
c, FDL v
l
r Thomas J. Adler deposes and says as follows:
- 1. I am President of Resource Systems Group and author of testimony in the New Hampshire Plan hearings regarding the Seabrook Evacuation Time Study. My background and qualifications are a matter of record in this proceeding. This affidavit responds both to the general concerns raised by the Atomic Safety and ucensing Board (ASLB) regarding the effects of commuter traffic on Evacuation Time Estimates ("ETEs")
in the Partial Initial Decision and to the specific arguments addressing this concern listed by Edward B. Ueberman in his affidavit of 25 January 1989.
- 2. The ASLB received a substantial amount of testimony on the issue of commuter I
traffic flow effects on ETEs in the hearings on the New Hampshire Plan. The Massachusetts Attomey General ("MassAG") presented testimony which demonstrated that the amount of commuter traffic and its potential effects on evacuating traffic flow warranted explicit consideration of the commuter traffic in the ETE simulation model calculations. The Partial Initial Decision concurred in part, stating at page 256 that, "[tlhe New Hampshire decisionmakers are entitled to the most accurate ETE reasonably achievable."
- 3. Explicit modeling of commuter traffic flows is both possible as a modest extension of the ETE work completed to date (NHRERP, Vol. 6) and is necessary for accurate estimation of Seabrook ETEs. In my opinion this commuter traffic could extend the ETEs for some of the evacuation scenarios by as much as several hours.
Having reviewed Mr. Uberman's affidavit, I find no clear evidence to the contrary. To determine the effect more accurately will require explicit modeling of the commuter traffic flows.
- 4. Examples and calculations described in the affidavit of Edward Ueberman purport to show that commuter traffic will have little effect on Seabrook ETEs. These calculations make several key assumptions and omit certain factors which I believe lead to substantial underrepresentation of the effects of this traffic.
L l.
]
Adler Retuming Commuter Amdavit 2
- 5. In 42, Mr. Lieberman compares the characteristics of beacn evacuees and
)
commuters, but does not include resident evacuees. Beach evacuees account for only 30% of the evacuating traffic, even on a Summer weekend. The majority of the remaining traffic is resiriential. He implies that understanding the characteristics only of the beach
. traffic will allow us to reasonably estimate interactions. His Exhibit A estimate of time to
<'i commute home implicitly assumes no interaction beyond what occurs during normal l
J rush hour. For some individuals, such as those who commute from the Hampton village _
l area to locations in the EPZ to the north and west and who thus must move with the evacuating traffic stream, the commute home could extend as long as the full EPZ evacuation time (over 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />).
- 6. Mr. Lieberman's 43 and 45 assert that only certain " critical pais" for summer scenario full-EPZ (Region 1) ETEs are of interest in this matter. However, the NHRERP Vol. 6 includes ETEs for six non-summer evacuaticon scenarios and for evacuation of nine sub-regions of the EPZ. The accuracy of each of these ETEs, as well as the peak summer scenario considered in Mr. Lieberrran's affidavit, are all of concern. ETEs for evacuation of sub-regions which include substantial employment centers such as Portsmouth (16,570 employees according to NHRERP Vol. 6), Newburyport (9,477 employees) and Amesbury (7,483 employees) will be affected much more heavily, proportionately, than will the ETE for summer scenarios for the entire EPZ. For example, the evacuation times for the off-season mid-week mid-day Scenario 5 evacuation are estimated as only 4:05 for most of the sub-regions (NRC Staff E. No.1 fol. Tr. 6742). The " Traffic Congestion Patterns" diagrams in NHRERP Vol. 6 for Scenario 5 show the downtown areas of Portsmouth, Newburyport and Amesbury as being heavily congested only 30 minutes into the evacuation and this congestion persisting in Portsmouth and Newburyport throughout the evacuation (diagrams attached at "A").
Were commuter flows in these areas modeled explicitly, it is likely that new " critical paths" would appear within these
Adler Returning Comrnuter Affidavit 3
l.
densely-populated areas and that the evacuation times would be extended considerably.
- 7. At T4, Mr. Ueberman lists several beach evacuation paths. The Route 51 path is described only partially. In fact, there are two paths which u-~ 2 ponion of Route 51. As shown in NHRERP Vol. 6 Traffic Control Post diagram D-HA-02, traffic from the Hampton beach area using Route 51 is directed into a reverse-flow lane in the I-95 interchange area and is continued west along Route 51. A separate, " critical path" route involves traffic evacuating along Route 101C from the Hampton beach and Hampton village areas which is directed onto Route 51 and from there to the I-95 northbound on-ramp. This latter route directly affects the Region 1 Scenario 1 ETEs and is the one specifically referred to in my earlier testimony outlining the effects of 200 additional commuter trips on ETEs.
- 8. At 38 Mr. Ueberman argues that commuters will use secondary and tertiary roads to travel home, based on their " consummate knowledge" of the area's roads. If true, then evacuating residents, who presumably have the same consummate knowledge, will also use these roads and they will not be as uncontested as Mr. Ueberman implies.
At any rate, most secondary and tertiary roads at some point intersect with the congested primary routes.
- 9. At 49 Mr. Ueberman again asserts that most commuters will arrive home within two hours. This assertion is at best unsupported. Commuters returning from outside the EPZ (42% of the total, according to NHRERP Vol. 6) will in many instances be forced to cross heavy volumes of evacuating traffic. Commuters returning to locations which require travel along with evacuating flow will similarly be impeded substantially.
Explicitly modeling this traffic flow would allow a determination of how important this effect is in the Seabrook EPZ.
- 10. At 410, Mr. Ueberman deals only with "with the flow" commuters and does not consider counter and cross flows. The employment location calculations shown in
Adler Returning Commuter Affidavit 4
Exhibit B rely on 1980 Census data. However, employment growth has been very high in the EPZ, as noted in Vol. 6. and thus these location data are likely to be inaccurate.
- 11. With reference to Mr. Ueberman's ill, according to the more recent (1987) survey conducted by MassAG (Social Data Analysts), over 1,800 EPZ residents work in Hampton but do not live there, compared to 641 as estimated by Mr. Ueberman.
- 12. At 312, Mr. Ueberman argues that commuter trips from Hampton to the west and south would not use evacuation routes. While he references Rt.101C, which in fact tervices a substantial portion of the Hampton village area, he fails to note, as described in my 37 above, that Rt.101C is a critical evacuation route. He also assumes that commuters heading south out of Hampton would use Rt.1, a route which would bring them through very slow-moving traffic and within less than one mile of Seabrook, Station, instead of I-95 or another route to the west.
- 13. At 313, Mr. Ueberman says that commuters headed west will find "less congested paths" to get home. This implies that: (1) there is a more optimal evacuation route and, (2) that residents have not already saturated those routes. The most obvious "other route" is Rt.101C which, in the Vol. 6 ETE calculations is already saturated and is a
" critical path."
- 14. At 314, Mr. Ueberman discusses Hampton to Exeter traffic. This origin-destination pair was an example used in my earlier testimony to illustrate the type of traffic movements excluded from the Vol. 6 ETE calculations. There are many such origin-destination paire that, all together, amount to substantial flows of traffic which will affect not only the Region 1 evacuation times, but also sub-region ETEs. For this l
particular origin-destination movement, the MassAG survey identified over 180 commuters compared to the 72 estimated by KLD using 1980 Census data. In addition,
)
there are numerous other destinations that will be accessed using this critical bottleneck, from Hampton: for example, Newfields, Stratham, Brentwood, Kensington and other
Adler Retuming Commuter Affidavit 5
towns to the southwest. Finally, there are other origins such as the commercial strip along Rt. I through Hampton Falls and Seabrook which will likely be served by Rt.101C.
- 15. The calculation shown in Mr. Ueberman's 315 is based on the unsupported assumption that only one-third of the Hampton-to-other-EPZ-town trips would use this interchange area and uses a base commuter volume only one-third of that estimated in the MassAG survey. Also, as noted in 314 above, there are other major origins and destinations of commuter traffic that will add significantly to these volumes.
- 16. At 316 - 321, Mr. Ueberman describes the effects of cross-flow traffic, using the example of Salisbury commuters. This example also uses dated locational data and unsupported assumptions about directional distributions of the traffic. More importantly, it does not include any of the traffic from the substantial employment centers in seabrook to the immediate north and Newburyport to the immediate south.
Using the same method of calculation employed by Mr. Ueberman and based on NHRERP Vol. 6 data, Seabrook would add 1,495 Seabrook-to-other-EPZ-town commuter vehicles and Newburyport would add 1,490. Even if only 20% of the Newburyport trips went through the Salisbury Center intersection (and none from Seabrook did), they would more than double the volume of counter-flow traffic as calculated by Mr.
Ueberman.
- 17. In his calculations of delays at 319, Mr. Ueberman ignores the " start-up" delays of approximately 2.5 seconds per platoon and the " clearance times" necessary to open and hold a gap in the evacuating traffic. Depending on exactly how these counter-flow movements are managed by the TCP guides, these additional delays could be substantial.
- 18. In 319 and 320, Mr. Ueberman argues that the effects of commuter traffic are within the 15% capacity reduction factor applied by I-DYNEV and therefore can be
{
assumed to be subsumed by the " conservatism" of the model. First, it is likely that the
Adler Retuming Commuter Affidavit -
6 fulleffects of returning commuters will be much higher than estimated by Mr.
Lieberman, as described above. Second, the 15% reduction factor is included in the I-DYNEV model to approximate the effects of congested flow, not to account for counter-flow or other commuter traffic. According to the testimony of Dr. Avishai Ceder (fol.
Tr. 5169 at 15-19), the 15% factor is not sufficient even to account for this congestion-related effect. Third, the differential effects of commuters on evacuation progress over time and across different locations within the EPZ are not represented at all by this uniform factor and thus evacuation times for different sub-regions and different evacuation scenarios will suffer greater inaccuracies.
- 19. At 322 - 426 Mr. Lieberman discusses Town of Seabrook commuters, but j
deals mostly with his " conservative" approach in treating roads as " rolling terrain",
rather than " level" This argument uses " conservatism" as the umbrella for effects not considered in the Seabrook modeling. Mr. Lieberman states that his " conservative posture" is a "[p]rudent approach in the face of uncertainty. However, uncertainty is not properly accounted for by superimposing still more levels of conservatism." The more appropriate alternative approach, suggested by the ASLB in its Partial Initial Decision, is to " superimpose" reality in this process by explicitly modeling the returning commuters. Otherwise, it is difficult to know exactly what the ETEs represent and whether they are overly conservative or underestimates of expected ETEs.
- 20. The ETE calculations assume a single 90/10 split for volumes of evacuating versus opposing commuter traffic flows. The ASLB in its Partial Initial Decision notes at
- p. 250-251 that the Highway Capacity Manual contains factors to represent the effects of different directional splits on roadway capacities but, "[dloes not believe the matter is of serious consequence." In fact, since commuter traffic will represent an increase of between 35% and 50% over total evacuation traffic volumes (see 425 below), a split closer to 50/50 in early stages of the evacuation (representing saturation of both directions) is
l s
Adler Returning Commuter Affidavit 7
more realistic than the 90/10 split assumed in Vol. 6 calculations. At a 90/10 split, total L
roadway capacity (both lanes) for an otherwise " ideal" two-lane road is 2800x0.75 - 2100 vehicles per hour ("vph"). Of this, 0.9x2100 - 1890 vph is available for the evacuating flow lane and the remaining 210 vph is available for opposing flows. At a 50/50 split, the Highway capacity Manual's directional factor is 1.0, meaning that 1.0x2800 - 2800 vph is the total available capacity and 0.5x2800 - 1400 vph is available for each travel direction.
For the evam*ing flow direction, this represents a 26% reduction in capacity below the conditions assumed in the Vol. 6 ETE calculations. By contrast, at a 100/0 split (no reverse flow) evacuating capacity increases by only 5% above that available at a 90/10 split. Thus, assumption of a 90/10 directional split for the full evacuation sequence substantially overstates the capacity of any roads which carry significant reverse-flow commuter traffic. This is clearly a significant effect that must be explicitly represented in order to obtain accurate ETEs.
- 21. At 327 Mr. Lieberman states that it is reasonable to conclude that some commuters will experience higher than normal delays in getting home. If comrauters are delayed by evacuees, it is only logical to assume that evacuees are delayed by commuters. Lieberman states in 42 that his purpose in submitting Exhibit A was to obtain "{nlecessary insight into any interaction between the two traffic streams."
However, his analysis suggests that interactions are limited to effects of evacuees on commuters, and not vice versa. He asserts in 327 that for commuters who live and work in the same town and for those who commute on non-evacuation routes, commuting times will not be increased. This ignores the " compressed" nature of the commuter surge that will have the effect of causing congestion on many roads not normally congested and ignores the delays that will occur at points where evacuating traffic streams must be crossed.
- 22. At 328 - 429 Mr. Lieberman states that his sensitivity runs revealed no effect
Adler Returning Commuter Affidavit 8
on ETEs of longer trip generation times for commuters to reach their homes. These tests are not realistic because they ignore me extreme ranges in commuting tirnes that will occur (for example, for commuters attempting to return home with the flow of evacuees), because they test the effects on only one scenario (presumably Scenario 1 which is very insensitive to trip generation times) and because they do not report sub-region evacuation time differences.
- 23. At 430 - 435, Mr. Lieberman wrongly assumes that we added ccmmuters for our sensitivity runs to Route 51 by increasing Hampton Beach loadings. In fact, they were loaded to Rt.101C and created delays at the I-95 on-ramp. Loading eniployment related trips to Rt.101C is consistent with KLD's use of two worker load nodes on Route 1 in Hampton, well away from the beach area. These worker loadings are not covered under the " beach count" umbrella and therefore, do not represent any double or triple counting. Mr. Lieberman's argument holds only if every job in Hampton is at the beach.
His own model says that they are not and in particular that there is a substantial employment area that would access Rt.101C, as we modeled.
- 24. In its Partial Initial Decision, the ASLB similarly inferred at p. 252 that, "The commuters working at the beach would clearly constitute a major portion of the problem, but should not be considered in Dr. Adler's hypothesis." In fact, the major employment center of concem is that within the village area of Hampton, away from the beach and along the substantial Rt.1 commercial strip. Route 101C will be used by the large number of retuming employees and shoppers who are located along Rt. I south through Hampton Falls and into the Town of Seabrook. During an emergency, employees and local shoppers (whose retum home is also not modeled in the Vol. 6 ETE calculations) along Rt. I north of Rt.107 would be unlikely to travel south on Rt. I toward Rt.107 because that route would take them past the " main gate" to Seabrook Station, a point less than one mile from the nuclear plant itself. Instead, these employees and I
1 Adler Returning Commuter Affidavit 9
shoppers would likely head nonh on Rt.1. In the center of Hampton Falls, this Rt.1 northbound traffic is encouraged by the NHRERP's Traffic Management Plan to continue north on Rt.1. (See TCP A-HF-01 in Vol. 6 at I-7.) According to the NHRERP's Traffic Management Plan (see TCP D-HA-05 in Vol. 6 at I-42) when these returning commuters and shoppers heading north on Rt. I reach Rt. 51, traffic barricades will " discourage" them from accessing Rt. 51 westbound and " facilitate" their continued northbound travel on Rt.1. The next intersection they reach is Rt.101C (see TCP D-HA-01 in Vol. 6 at I-38) where traffic controls will permit those employees and shoppers who so wish to turn left onto Rt.101C, heading west toward the the intersection with I-95, where the Rt.101C traffic is routed onto I-95. (See TCP D-HA-02 in Vol. 6 at I-39.) Except for those employees and shoppers who live in Portsmouth or Rye, all others who live to the west, northwest or south will use this route. Thus, Rt.101C is very likely to be used by a large number of these returning employees and shoppers, and their presence on this bottleneck link has not been explicitly modeled. Volume 6 indicates only that some effort was made to estimate the number of transients who would be parked at lots servicing retail establishments outside the beach area. That effort yielded small numbers because it was based on data collected prior to 1981 as compiled in the NRC's "Kaltmand report. Since the time at which those data were collected, however, commercial growth along the Rt. I commercial strip has been dramatic. Thus, one cannot argue that the estimate of transients along Rt.1 is so " conservative" that it is reasonable to ignore the t@c generated by returning employees and local (EPZ-resident) shoppers.
- 25. Mr. Lieberman concludes at 436 that the expense of explicit modeling of commuter traffic, "[wlould be entirely disproportionate to the minor amount, if any, of additional accuracy which would result." This conclusion depends on two critical assumptions: 1) that the additional accuracy would be inconsequential, and 2) the expenses would be disproportionately large. As noted in detail above, the assertion that
Adler Returning Cornmuter Afndavit 10 no significant improvement in accuracy would result is seriously flawed by a combination of omissions and unrealistic assumptions in his analyses. According to the data and
. analyses presented in NHRERP Vol. 6, approximately 35,000 returning commuter trips would be generated, above those already accounted for in the Seabrook ETE calculations.
For the summer scenarios, the excluded commuter traffic amounts to an increase of 35%
in the network traffic volumes. For the off-season scenarios, this traffic represents more than a 50% increase. Mr. Lieberman's affidavit deals explicitly with only a very small.
fraction of this total. It ignores completely the major employment centers of Portsmouth, Amesbury and Newburyport.
- 26. The expense of explicit modeling of commuter flows is not even estimated in Mr. Lieberman's affidavit. The MassAG has conducted an extensive survey which includes up-to-date information on EPZ resident commuters' origin and destination patterns. Using a Bayesian statistical estimation procedure 1, these data could be combined with the employment data already compiled by KLD and U.S. Census joumey-to-work data to from a complete, reasonably accurate estimate of commuting pattems.
According to NHRERP Vol. 6, KLD has already conducted an extensive survey of, "[tlhe entire highway system within the EPZ and for some distance outside." These data could be used directly to extend the network coding to include important commuter routes.
- 27. The ASLB's statement that decisionmakers are entitled to the most accurate ETE reasonably achievable will be effected only if the Seabrook ETEs are modified to explicitly reflect returning commuter traffic.
l l-Signed under the pains and penalties of perjury Y
Thofnas J. Adler 26th day of March,1989 1 Bayesian estimation is an approach commonly used to combine two or more sample datasets in order to obtain new estimates of random variables or parameters.
I
a, i
l ATTACHMENT A 1
. o.., g J'
n
, :..i w-
-f y
~
ij..
.2. :,/
.a.
.~
1 an,
.S. /.
1
~ ",.
\\
~g,#..
7 "'.,
s f
- \\.
_j. /-.
~
.a.'
em
.a
.S. 4 r
- g*
.2.
~
p.-.
i i g x
1
'V.
.o
... h 'I ' 4
... y
.- S.
'g*
g ' i
)a,,,, = -
'a
\\',. y =. ;
'g' ~.. ~.*
l,
't=
- I -
,2.
. S
,',t, -L*.,;.
a.
==
\\/
,1 '.3
=%.
(,i "N
~
- a...\\
..,g f T..
2..
,2.
%. j
..a* '.#.. (7
,,' N
==
a
'3'
.?.
g/A
- r'i TJ'a
)
~
w A.s
,, =. '. '. *
- s,. e,
s.6Ls
+/>.
.a.
~ s*.
C
"'.:g.
.f..
P /
- "#g
. p,,t s
'$=
/.=== era.1
's..
g
.g s
g 4
s*a
~
u&
T
,,2
=
j
- \\.=..pa
..i I.
.R.
../
~
e
, 2.
I'
.$., ~*
- u. 3-
..y-s 8.a,. art a.s.... 1 l (,,
m n
/
p"r c'v, f..,
s
/
.a.
.a.
g
". "f'?:
"\\.,
.?*;- -...
A
./ ;
~
"I' A
. rg.
.g g,.
g
,,,'"3 e 2=
t.;.
.e e
=
,e..
./
.g,.
../
~
A n.,..
.g.,
(
. N: /
9,t;
. t...
.a
,/
/'-~~---------
J i
Figure iU-3a.
,g,
/
=***'
Traffic Concestion Patterns for Poqicn 1, scenetrio 5,
',.S
,/
.u at tiro 0: 30 after Order to E'vacuate
,t.
~~
5 10-29
,s en ma
' ' ' F..e.n.
.n
/"..
- ..t
...?
.. 4
- j/
4
.v 6..
.. <e~4'
\\--
7 '".,
- l n.
0
/
m, 4
=
/.
..o
...e
.a n..
s e
e
.e e,,, = a
.t e
- = u I
i a'*
1
'3' '. =,,
/
g.
.m
- =.
w.
ak.e.arve.
I 1
" m%.
I
./
3 e
o i.
"'". g :/..y..
'" g.,
. = " ".,.
N.,.
\\ f
'E..
/
e j'
\\/.
=a s j" ) A '_"
j N
- / g" ""g g.t -
.n
='*
A4
,,,,;7...,,.,'
.g.
, it 8
A s
ga p '"
'r'
,t -
8j
,,,,, m,
.e r. s' a.
n.
7 A '.s f
C y
=..
' *' ft.. l9 /
'N
./l.'
3.El'"
.-. \\
c'/
,,:8 s.,..
T=
...,"a
- h~ e i
w,g 8 N
/g*
- s.==
,5=.
.m r
~
g
\\
o -Q '
"' R;....
s w _ >--
.n
..i
. \\
,_pa st. '
[I
.a,
,q
.f..
\\r
,2.,
- N
\\
,/
i, s
- s. a m
, g,,
==
= '.,.
f
= e.\\,,7,,aa
. t*g.
A
.a* N u
,,..*.,*'e "
s Q, < ;
,, #','A ',g '* d,,
a*=
,g,
\\.
.r.
,I "s
,g
.f
\\
=,
I"g=
n.
~$,
e"P.,,
,p..
,,,, 3.
i y...- i e
.g -
g T*
.=
we.
/
\\,,"C, $,.4' 1
1..
f--~~~~~------~~
);
I t
\\
l i/
l.
....., ;8
/
=
.Rs
.f.,
Figure 10-3b.
Traffic Congestion Patterns
/
- /
..n~ms n
for Region 1, Scenario 5, at time 1:00 after a*,
f,.
Order to Fvacuate f
y
.t%=
~ 't y.
m s.. 4
.A/
' -.J.
~~ "4..
\\
7' A!
. A
- -a
= =*mu
.A ;=; g
,4
~~
\\
t
~
A Q.
y a
It g p,,,g A
g 1
man==
s 9 " " " " * '
s e
t
~
~
,t,
.g.
o i
-ag '# -,.
l
?.
s
=.
e e
u.r=
-. 1,a"ll>_, 4
... +,, !
- 3..,*
2 e,
"N 1 '"
aa='- =
,3\\\\...
N f
A
b,g, A.=. -
i
.g.
,,'A 8
~...
s' f.
pt,
,,p
.y.
,j
===f=*W",~. ~
o A
$<; t..
..[p /
N*
' .,g.;*.3.
/
==, \\
./!.#
s 8 A l
\\.s.<s..=.e=,g,,
.g s-1..];
3 3M.
.,,,.x. - _ N.
.i
\\
=,
....g-
-,7 f. k,'.
+
Xs.
b
~~
4 s,
- \\.=. a.
\\ p.=
a
/
+
i N
g 3
,2.
ki
- g. T "s
. ;- ~
- i
~ s..
\\
i
,5.. e.,.
'-~
A
\\.. *-. ",
s i
=
~
-e
=
c
.s.,
..., g, A N e
=, j' >,,
_t,,
,g, 5... f 8
g
.,, g A
v a
,.3
\\
.=8
,e,,
s p.
. s..
"* 4,-
e A
'"3, P."
' "* ;~
,/
T 4
_ 7' g
k,1 I8,
,a Y
f.
L
\\
,a 8
1
- - ~ ~ ~..
- w. = w.uns
/,l
,f,,
)*
/
" 4,,,
,3, Figure 10-3c.
..,, ;s Traffic Coroestion Pattoms N:.-
.,y l
.w a
for P.cqion 1, scenario 5, m
at tim 2:00 after Order to Cvacuate
-e"'
10-31
t 1
S u
\\
A n.
A
..... l N
. /.
....i t,,'=
/,,
=-=.m.,
d
,f y.
us 4
ee.,
.cef Utw ug/
. /
au u=
., g
\\
7' a,J..
"4 i
~~
a A.
=
f
} '-
\\.
.,,e.
A.
e..
....=.-w...
u
,4.g
'~
o y
,3,
. --re
.6,!
.4 s
v o
.'E
,,I
. r.
\\ /
T ?.!
T t.;
.g"3
\\,/,,,,
,9,,.
. ~..
1
.. ro m
'a..
y \\,...
.g N
I A '% 3,; A aa
,,.,,ft....,-
a
,A 7
.,.',t,,., W. x
,a,
,/,,,
I
/
.\\,
. *.s.
4",,'
/ j.[.
" a"*'.'
=
A~"
A'%
.,"'.g.
c s
, /-
- ...~
,,,. ='a m,q
,t j.; r 8
"s
= "a" a = ' " * -
l,.,,,(.
s
.==s
. 't.
-.3 j
\\
s., a.
e s
a-
~\\
,,,,,)
3-h
~"
T 4
s.
- 5.. ;..i.
s
\\f!
..t. '
.s A
\\
=N
"( _
'=...s.,,
g" a
- e..=m.
,,,;,.',,.N* b
//
c "r p y" 7..'
~
/
a
'a' N **u==v...
t .,,.
(
.),
f..
..'., Y, v
"%*,,,..,r.
~
. <s s.
\\
,,,"p s.
4 A
a
===,
,,3
.e.
I
.s -
m.
'"M,i e
a, A
"),.,,,f';
%g.
- y*
=
w. *M /,.. ?,,
.=
=p 7
} E ^~.n)..-
=
7
. 'l '#5 y;"v
//
---pr
~
u.....
\\
s f
- us r
R.
, a
?.
,-~~----..
.,_,, ~
5
_i
- ~
./
.. = =,
Figure 10-3d.
Traffic Cen4cstion Patterns Ki
"" aa'"
N for Regien 1, Scenaric 5,
"'et at tiro 3:'10 after
~~
Order to Evacuate f,"
10-32
N N... T, j q,s,,
j o
.n j...
n
,..r v..,-
...?
~
\\f -. 4
/
.?.
.g. [
e...
a,
.2.l "y.~\\
,3* /.*.
=
7' g
/
")
O \\.e. -
g,
_,,,./ 3.
=='=*/
- =
, A,3
,..,7 g
an k-
.l,
- =
y-t
.3..'** --
I
- "**8" 8
{
'*j
.... A.z,..
- m
..., -.,. ?
-1
\\,
' j !.;. ~...., Z. ci.-:.c. b v '.'.
1
~
- 1,.
......s,.
.s.
....s# E."I ps.
a.p.a..'
\\
A
.a. '
J,.2.
- 4. +r,
. x.
.,. 9 z..
p__
2-
,x
/,1,.
... ~ e.
\\
.a
- 2) %c. 3, e.,T h - l.. f Lk
,,7.g p.
a +
.r
_.\\..
~
c l
u\\s s. x
- m. ;.
,A
-,3., ".'
'"s '"3.,,
Q
(' -
(,, '
A
- '"""*.p -
. " h M t.: ?-,..".3.\\
?-
a
.~
/
.\\
.,,, 3... -
- y. -
N.
.s..... j;.f-Q
.= F* -- _f
,g, 5*v...,/
g g
43
\\
,~
A
,,3,
-..' g' '
-/,
.'k
===v T
6'g, -~ L*.c,,
t.
.. e,
. g,
'g,
.g ga
. oe.-
A "3, et.,
' d..P.,,,,_ f,.ag,
/. ' '-
l T
- ~
,q j/
.g
)
v kr
%}, -.
\\
- / eg
'" N
/.
w o' g.
f
,e--------
q'-
p f,
m -
,?.,
i:
- e. =w.*s i./
r
""' I
- Figure 10-3e.
.=
Traffic Congestion Pattorno for Region 1, Scenario 5, I"
at time 4:00 after
,,,a Order to Evacuate
,'=
[.'~
aw.
10-33 j
L--__-__-_____-_.
n.
4 ts
.,. m"ig,
~/
r
.n,
~
.,e
~
.e we.as. t h'
,g,
\\
,f u
mr P
.e.ovres
,8. /
. - =
/
,. - v.,.
\\
^.g.p.~.1 s
o\\,g
/ t.
.3..
Q, /.*=,, ~.
.. e./
e-
,,,,,s.
,A j,
- s.,q
- 7. -
,,8,, s
=
y l
'2* %''""
., n. n e s
a x
i.r
'4' T
'.D 8-
'E '
4,,
-h,,...".1.
a
,t
..g.' i,,,,
j.,, *..
a.
y
.t.
y
,,?, f
'5' *.,..= ". *N 8 i
't' *
- sa m a
=. ;,
3
-y \\...
....,=t ;
u.
'a,.
(,, /
N
{:
,R.
<== ~*.'
y'..t g
a."
'.'".y Y,,
'F,'j *:"" N.
~. ) 1.
,.,?..
,.s A
gj.
,J
=.
6,,.$.
""*a
.u, e
8
,g,.s
,.s
.T.
?
e.
21
.t.
y s
I
- '* \\
. l.i-e~ -
9 e
e.== ===. t f.*a/
vg'S-'
f-A s
g as===r T
a.
s na s
,e
\\
I'
. 3-
,S, *
M,'
s
- ,* x g s. *,=
s m.
g
\\
,,...*/
yl, g
7 /*.
s 7
- ". -, s,,/
,s a
a
=.v
\\(
,,.s i
~
,v
- g
?,,7,y.t :g,,-- p,,
==
/
~-
7
%/
.2.'
\\.,, 'g. /
,, yif
.a.s
,,...**.~
~:rg:$yw- ',
.n. 4.::/-
.a.
/
.r..
,,, gg ca.
.,",*f.e-
==t
..,j,-
g..
- *t h
-3* g'. p.
"*%l<
g=
g
.s'e"".
T
'~
y./
I
\\l) E
.e r I ,
/
- , t, t..
..5 l
t
~
f --~-----..
.='s,
(
r I
',i 2
. 'I
....u.,
.3, Figure 10-3f.
Traffic Conqestien Patterns i
for Region 1, ccenario 5, N
at tirac 5:00 af ter
~*
y order to evacuate 10-34
L
[ OMi I! '
& M1
. UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFn.
00(. h W > t
- i BL MIL
)
In the Matter of
)
Docket Nos. 50-443-OL
)
50-444-OL PUBLIC SERVICE COMPANY
)
(Off-Site EP)
OF NEW HAMPSHIRE, ET AL.
)
)
(Seabrook Station, Units 1 and 2)
)
March 27, 1989
)
CERTIFICATE OF SERVICE I, Allan R. Fierce, hereby certify that on March 27, 1989, I made service of the within MASSACHUSETTS ATTORNEY GENERAL'S RESPONSE ON THE ISSUE OF RETURNING COMMUTERS AND THEIR IMPACT ON EVACUATION TIME ESTIMATES and the CORRECTED TESTIMONY OF DR.
THOMAS J. ADLER ON BEHALF OF JAMES M.
SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS CONCERNING CONTENTION JI-4 (TRAFFIC MANAGEMENT), by first class mail 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 4350 East West Highway Bethesda, MD 20814 Dr. Richard F. Cole Docketing and Service Atomic Safety & Licensing Board U.S.
Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission East West Towers Building Washington, DC 20555 4350 East West Highway l
Bethesda, MD 20814 i
Robert R. Pierce, Esq.
Thomas G.-_Dignan, Jr., Esq.
u Atomic Safety &. Licensing" Board Katherine ~Selleck, Esq..
J.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.
Assistant; General Counsel.
U.S. Nuclear Regulatory y.
Office of General Counsel
-Commission
-Federal Emergency Management Office:of the GeneralfCounsel' 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 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 LSeacoast Anti-Pollution' League Washington, IX:.'20555 5 Market Street-Portsmouth,1NH 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.
79 State Street Lagoulis,. Hill-Whilton.
2nd' Floor
& Rotondi Newburyport, MA 01950 79 State Street.
Newburyport,'MA 01950 Dianne Curran,-Esq.
Ashod N. Amirian',- Esq.
Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W.
Bradford, MA 01835 Washington, DC 20008 a
Senator Gordon J.
Humphrey Senator Gordon J.
Humphrey U.S.
Senate One Eagle Square, Suite 507.
Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack)
(Attn: Herb Boynton) _
f George Dana Bisbee, Esq.
Phillip.Ahrens,iEsq.
Assistant. Attorney General Assistant Attorney General Off. ice of the Attorney General Department of the Attorney L
25 Capitol Street General-Concord,ENH 03301 Augusta, ME 04333 Sandra Gavutis, Chairperson Calvin'A. Canney Board of Selectmen City Manager RFD 1, Box 1154 City' Hall Rte. 107 126 Daniel Street Kensington' NH 03827' Portsmouth, NH 03801 Gary W.
Holmes, Esq.
Richard A. Hampe,'Esq.
Holmes & Ellis Hampe & McNicholas 47 Winnacunnet Road 35 Pleasant Street Hampton, NH 03842.
Concord, NH 03301 Robert Carrigg, Chairman J.P.
Nadeau Board of Selectmen Selectmen's Office-Town Office 10 Central Road Atlantic Avenue Rye, NH 03870 North Hampton,.LNH 03862 William S. Lord' James H. Carpenter, Alternate Board of Selectmen Technical Member Town Hall - Friend Street Atomic Safety & Licensing Amesbury, MA 01913-Board Panel U.S. Nuclear Regulatory Commission Washington, DC 20555 JAMES M.
SHANNON
' ATTORNEY GENERAL COMMONWEALTH OF MASSACHUSETTS Allan R.
Fierce Assistant Attorney General Nuclear Safety Unit Department of the Attorney General One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED:
March 27, 1989