ML20154L394
| ML20154L394 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 09/17/1988 |
| From: | Lieberman E KLD ASSOCIATES, INC., PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
| To: | |
| Shared Package | |
| ML20154K393 | List: |
| References | |
| OL-1, NUDOCS 8809260168 | |
| Download: ML20154L394 (18) | |
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September 17, 1988 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL j NEW HAMPSHIRE, et al. ) 50-444-OL
) (On-Site Emergency
)
(Seabrook Station, Units 1 and 2) ) Planning and Safety
) Issues)
)
AFFIDAVIT OF EDWARD B. LIEBERMAN I, Edward B. Lieberman, being on oath, depose and say as follows:
- 1. I am the president of KLD Associates, Inc., and am
) responsible for the development of the Seabrook Station Evacuation Time istimates and Traffic Management Plan Update, h In addition, I have testified regarding such matters before the Licensing board impaneled to hear offsite energency planning issues in this docket. A statement of my professional qualifications is attached hereto and marked "A".
G 443 PDR
- 2. The purpose of this affidavit is to address allegations in Contention Basis A.5 rygarding the effect of heavy traffic, nigitttime conditions, and snow and ice associated with adverse winter conditions, on vehicle speed in general, and hence on the transit times of the VANS vehicles traveling pre-designated routes.
- 3. I have reviewed the empirical data of TRANSIT times which were tabulated on forms provided to the drivers performing a transit time study in April, 1988. The VANS vehicles were driven repeatedly from their respective ctaging areas to their acoustic locations; a total of 726 of such runs were ptrformed to a total of 14 acoustic locations. The number of runs to each such location varied between 45 and
- 59. For three of these locations (Nos. 1, 9 and 12) one run exceeded a TRANSIT time of 10 minutes (10:05, 11:08, 14:18, respectively).
- 4. I have also reviewed the results of similar test runs which were performed during July and the first week in August, to quantify TRANSIT times during the summer (tourist) season. A total of 671 randomly distributed test runs to 14 acoustic locations were performed. A total of 48 runs to each such location was performed (except for 47 runs for No.
14). For one of these locations (No. 1), five runs, four of which took place on weekends, exceed a TRANSIT time of 10 minutes.
- 5. It is my understanding that a new Satellite Staging Area located within 0.6 miles of Acoustic Location 1, will be manned on summer weekends. The route from that Satellite Staging Area to Acoustic Location 1 utilizes a road that is not a beach access road. It is my opinion that this route would not be congested by beach traf fic and, in any event, the transit time of the VANS vehicle from this Satellite Staging Area to Acoustic Location i should be far less than 10 minutes.
- 6. It is my opinion that the study methodology of the test runs described in itemw 3 and 4 quantifies the average TRA14 SIT times of the VANS vehicles for both summer and non-summer seasons, and includes the effects of nicar weather, inclement (rain) weather, and a range of traffic and nighttime conditions.
- 7. The transit studies do not provide direct empirical data detailing the VANS transit times during winter adverse road conditions. Winter adverse road conditions represent
- he situation where there is an agcumulation of snow on the pavesent which exceeds one-half inch in depth and the roads remain passable.
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- 8. It is very unusual for roads to be impassable for a significant amount of time. During the preparation of the j seabrook station Evacuation Time study I interviewed the Police Chiefs of all Massachusetts towns in the 10-mile EPZ l except Amesbury, and of all but two New Hampshire towns within the EPZ. These discussions indicated that snow i plowing equipment is mobilized and deployed during the
. snowfall after an appropriate amount of snow has accumulated, (
in order to maintain passable roads. The general consensus was that snow plowing efforts are generally successful in maintaining roadway passage for all but the most extreme i blizzards and icing conditions.
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- 9. As detailed in George Harper's af fidavit, a review l
i of historical weather data shows that one half inch or more l of snow falls on about 20 days or on about 5 percent of the l
- days per year. While more than % inch of snow remains on the ground the speed reduction factor remains in effect.
I
- 10. It is estimated that snow reduces mean free-flow l I speed by 25 percent. (NHRERP Evacuation Time Study, p. 3-1) i l
! Traffic demand does not influence roadway capacity unless the I 1
demand rises to a level which exceeds capacity, i.e. when f i
traffic flow operates at level of service F. Traffic volumes j i in the winter under normal (i.e. , pre-ovacuation) conditions I
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l rarely reach the levels of roadway capacity (see discussion in item 4, pages E-2, E-3 of Vol. 6, NHRERP Evacuation Time Study). Since the VANS vehicles are mobilized prior to the 0, - order to evacuate, roadway capacity would not be affected by evacuating traffic volumes.
- 11. The 25 percent speed reduction to represent the affect of inclement winter conditions on speed, should be applied tc free-flow (unimpeded) speeds associated with clear weather and dry pavement conditions. The average speeds listed in Table 2-2 in seabrook's TEMA-REP-10 report are based upon an April 1988 VANS Route Transit Time Study.
- 12. On this basis, the AVERAGE TRANSIT TIME, 2T , during adverse winter weather conditions (i.e., snow), is estimated from the empirically determined AVERAGE TRANSIT TIME, T,1 as follows:
T2 = T1 /(1-0.25) = 1.33 Ti Applying this expression to the values of Ti in Table 2-2, yields the following estimates of TRANSIT times during adverse winter weather conditions, T 2:
(T2 )
ADVERSE (T1) WINTER AVERAGE AVERAGE ACOUSTIC TRANSIT TRANSIT LOCATION . TIME TIME VL-01 8:34 11:24 VL-02 4:56 6:34 VL-03 6:21 8:27 VL-04 0:00 0:00 VL-05 0:00 0:00 VL-06 3:01 4:01 VL-07 5:07 6:48 VL-08 6:28 8:36 VL-09 7 43 10:16 VL-10 7:45 10:19 VL-11 8:05 10:45 VL-12 8:33 11:22 VL-13 7:59 10:37 VL-14 0:54 1:12 VL-15 3:01 4:01 VL-16 12:15 16:18
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.>hMm Af' e ,, ..,
Edward B. Lieberman
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l Septeaber [d,1988 l The abcVe-subscribed Edward B. Lieberman appeared before me i and made oath that he had read the foregoing affidavit and that the I statements set forth therein are true to the best of his knowledge.
Before me, i r
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RocNsLLs LAssosedAm h h b ObL,b Kotary Public m t)
_j j f Not*'Y pM 'My Commission Expirest 73c/f Quelmed in Sunet Osway e cm e, wee naeren at 1 ^
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Licbormen Attcchmont A, 1 of 11 PROFESSIONAL QUALIFICATIONS l
EDWARD B. LIEBERMAN Vice President
- KLD ASSOCIATES, INC.
My name is Edward B. Lieberman and my business addrosa is KLD Associates, Inc., 300 Broadway, Huntington Station, New York 11746. I am presently Vice President of KLD Associates, Inc.
I received the Bachelor of Science degrae in Civil Engineering in 1951 from Polytechnic Institute of Brooklyn. .
I was awarded the Master of Science degree in Civil -
Engineering in 1954 from Columbia University and in ,
Aeronautical Engineering in 1967 from Polytechnic Institute of Brooklyn. I am currently working on a Doctorate degree in Transportation Planning at the Polytechnic University. I am a member of the Chi Epsilon Honorary Traternity.
With almost 30 years of professional experience, I have managed a number of major projects. I pioneered the development and application of traffic simulation models, making major state-of-the-art innovations in the traffic engineering profession. I have also been responsible for many engineering studies involving data collection and analysis and design of traffic control systems to expedite traffic flow and relieve congestion.
I have developed simulation models to study traffic performance on urban networks, freeways, freeway corridors
tieborman Attcchment A, 2 of 11 and two-lane, two-way rural roads. These programs include consideration of padestrians, interaction with vehicular traffic, truck and bus operations, specia? turning lanes, and vehicle fuel consumption ano emsssions; both pretimed and actuated traffic signal cor.trols are represented.
I was the Principal Investigator for the development of traffic signal control strategies for congested conditions in mid-Manhattan. These strategies were implemented and evaluated in the field. Field tests indicated substantial reductions in delay combined with increased vehicle throughput.
I was the Principal Investigator in the development of an interactive computer graphics (ICG) software system for displaying traffic simulation results generated by tra NETSIM model. I designed the overall structure of the software for implementation on PC AT computers and, subsequently, on larger IC3 vork stations. This work was sponsored by THWA.
I was responsible to a large extent for the theoretical development of DYNEV, a Dynamic Network Evacuation model.
The DYNEV model consists of two major components: an equilibrium tra.ffic assignment model and a macroscopic dynamic traffic simulation model designed for all types of roadway facilities (urban streets, freeways, rural roads).
DYNEV is designed to be used as a tool to develop and organized evacuation plans needed as part of general 2-e
Lioborman Attcchment A, 3 of 11 disaster preparodness planning. DYNEV was used to analy:e an existing evacuation scenario at the con Edison Indian Point Nuclear Power Station and is corrently being used to develop an extensive evacuation plan for the LILCO Shoreham Nuclear Power Station on Long Island, New York.
In developing this evacuation plan for the Seabrook Nuclear Power Station, my activities include definition of evacuation scenarios, definition of the evacuation network, development of traffic control treatments and of traffic routing patterns, analysis of trip tables, analysis of simulation results, optimization of evacuation strategies and the preparation of formal documentation.
I was responsible for the development of the I-DYNEV model, an intsractive version and enhancement of the DYNEV model, under centract with the Federal Emergency Management l Agency (FEMA). !-DYNEV, in turn, was integrated into the ;
Integrated Emergency Management Information System (IEMIS),
developed by FEMA. I-DYNEV was applied to estimate the evacuation times for the Emergency Planning Zones (EPZ) for eight nuclear power stations.
I developed courne material and conducted training for emergency planning personnel at the National Emergency 1 Training Center (NECTC) in Emmittsburgh, Maryland.
I was also responsible for the designs of the NESIM microscopic urban traffic simulation model (formerly UTCS-1) and of the SCOT freeway traffic simulation model. The I 1 .
Lioberman Attachmont A, 4 of 11 NETSIM microscopic traffic simulation model developed for the Federal Highway Administration, enables agencies to evaluate traffic oporations in urban environments. The sco; model was developed for the Transportation Systems Center of the Departnent of Transportation. This program includes a dynamic traffic assignment algorithn which routes traffic over a network in response to changing traffic flow characteristics to satisfy a specified origin-destination t able . In addition, I have developed advanced traffic control policies for urban traffic for the FNWA-sponsored UTSC Project, as well as a bus preemption policy to enhance the performance of mass transit operations within urban environs.
I designed and programmed the advanced "Third ;
generation" area-vide, cycle-free control policies for -
moderate and congested traffic flow for computer-monitored t
real-time systems. I also developed a cycle-based, off-line computational procedure named SIGOP-!!, to optimize traffic signal timing patterns to minimize system "disutility."
I led a group of traffic engineers ant. systems analysts in uoveloping a system of macroscopic traffic simulation medels designed to evaluate Transportation Systems Management (TSM) strategies, This software system, named TRAFLo, also includes an equilibrium traffic assignment model. This model has been distributed to other agencies including FEMA.
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Licbarman Attacnment A, 5 of 11 l i
l I designed an "Integrated Traffic Simulation System,"
named TRAF, which will eventually incorporate all the best t Using structured traffic simulation models available.
programming techniques, TRAF integrates: NETSIM, TRAELO, and ROADSIM, a microscopic rural-road simulation model.
I served as Principal Investigat6r on NCHRP Project 3-20 entitled, "Traffic Signal Warrants." This project involved both field data collection and the application of the NETSIM model to study intersection delay as a fynction of traffic volume, a type of control and geometries. In turn, I developed and documented new signal udrrants, some of which '
will be incorporated in the next version of the Manual on Uniform Traffic Control Devices (MUTCD), i Under NHTSA sponsornhip, I directed a research study to evaluate a Driver Vehicle Evaluation Model named DTRVEM.
This model simulates the response of motorists to hazardous avents. This effort included analysis of the model formulation and software and sensitivity testing. A t workship was designed, organized, scheduled and conducted by myself and other KLD professionals; experts from all over the U.S. were invited to recommend specific NNTSA research activities for the further development of the model. A recommended research program constituted the major output of the contract.
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Liobormen Attcchmont A, 6 of 11 Over the years I have been involved in a number of other studies to evaluate traffic operations on large-scale road networks, using one or more of the models described above.
Prior to 1960 I applied my skills to the areas of stress analysts, vibrations, fluid dynamics and numerical analysis of differential equations. These analyses were programmed for the IBM 7090 and System 360, CDC 6600 and 7600, C.E. 625 and UNIVAC !!05 digital computers in assembly languate, FORTRAN and PLI. I also designed the logic and real-time programming for a sonar simulator built for the Department of Navy and monitored by a PDP-8 progess-control digital } .
cor puter.
I am a member of the American Society of Civil Engineers, the Institute of Transportation Engineers, the Association of Computing Machinery and the Transportation Research Board (TRB). I am also a member of the Traffic Flow Theory and Characteristics Ccmmittee of the TRB. I am a licensed Professional Engineer in New York, Maryland, and Florida.
The following list comprises selected publications of my studies and findings:
"DYNET - A Dynamic Network Simulation of Urban Traffic Flow," Proceedince. Third Annual Simulation Symposius, 1970.
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Lieberman Attachment A, 7 of 11 "Simulation of Traffic Flow at Signalized Intersections: the SURT System," Proceedings, 1970 Summer Computer Simulation Conference, 1970.
"Dynamic Analysis of Freeway Corridor Traffic," SKE paper, Trans. 70-42.
"Simulation of Corridor Traffic: The SCOT Model," "Highway Research Record No. 409, 1972.
"Logical Design and Demonstration of UTCS-1 Network Simulation Model,"
Hi,qhway Research Recprd No. 409 , 1972 vi ch R. D. Worrall and s'. M.
E ru gge rman) .
"Variable Cycle Signal Timing Program Volumes 1-4," Fins 1 Report of Contract DOT FN-11-7924, June, 1974.
"Traffic Signal Warrants," KLD TR-51, Final Report on NCHRP Project 3-20/1, December 1976 (with G. F. King and R.
Goldblatt).
"Rapid Signal Transition Algorithm,"Transportation Research Record No. 509 , 1974 (with D. Wicks).
"Subnetwork Structuring and Interfacing for UTCS Project-Program of Simulation Studies," KLD TR-5, January, 1972.
"Development of a Bus Signal Preemption Policy and a System Analysis of Bus operations," KLD TR-11, April, 1973.
"SICOP-II - Program to Calculate optimal Cycle Based Traffic Signal Timing Patters, Volumes 1 and 2 " Final Report, Contract dot-TH-11-7924, KLD TR-29 and TR-30, December, 1974.
Summary report inTransportation Research Record 596, 1976 twith J. Woo).
) "Developing a P:edictor for inghly Responsive Syste.w-Based contro,"
Transportation Research Record 596, 1976 (with W. McShane and R. Goldblatt).
l Lieberman Attachment A, 8 of 11 '
"A New Approach fo'e Specifying Delay-Based Traffic signal Warrants,"
Transportation Research Special Report 153 - Batter Use ofExisting Transpertation Facilities, 1976.
"Network Flow simulation for Urban Traffic Control Systems," Vols. 1-5, PB230-760, PB230-761, PB230-762, PB230 '63, PB230-764, 1974 (with R.
Worrall), Vols. 2-4 updated 1977, KLD TR-60, TR-61, TR-69 (with D. Wicks and J. Woo).
"Extension of the UTCS-1 Traffic Simulation Program to Incorporate Computation of Vehicular Fuel Consumption and Emissions," KLD TR-63, 1976 (with b. Rosenfield).
"Analysis and Comparison of the UTCS Second- and Third-Generation Predictor -
Models'" KLD TR-35, 1975.
"Urban Traffic Control System (UTCS)
Third Generation Control (3-GC) Policy,"
Vol. 1, 1976 (with A. Liff).
"Design of TRAFIC operating System (TOS), KLD TR-57, 1977.
"Revisions to the UTCS-1 Traffic Simulation Model to Enhance operational Efficiency," KLD TR-59, 1977 (with A.
Wu).
"The Role of aspacity in Computer Traffic ContrCL," in Research Directions in Computer Control of Urban Traffic Systems, ASCE, 1979.
"Traffic Simulation: Past, Present and Potential," in Hamburger, W.S. and Steinman, L., eds., Proceedings of the international Symposium of Traf fic Control Systems, University of California, Berkeley, 1979.
"TRAELO: A New Tool to Evaluate Transportation System Management Strategies," presented at the 59th i
m- .
Lieberman Attachment A, 9 ef 11 Annual Meeting of the Transportation Research Board, 1980 (with B. Andrews).
"Determination of the Lataral Deployment of Traffic on an Approach to an Intersection," presented at the 59th Annual Meeting of the Transportation Research Board, 1980.
"Service Rates of Mixed Traffic on the Left-Most Lane of an Approach,"
presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with W. R. McShane).
"Development of a TRANSYT-Based Traffic Simulation Model," presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with M. Yedlin).
"Hybrid Macroscopic-Microscopic Traffic .
Simulation Model," presented at the 59th Annual Meeting of the Transportation Research Board, 1980 (with M. C.
Davila).
"A Model for Calculating Safe Passing Distance on Two Lane Rural Road,"
presented at the 60th Annual Meeting of the Transportation Research Board, 1981.
"The TRAF System - Anayltic Formulation and Logical Design of the Roadsim Model," KLD TR-129, June, 1983, i
"PREDYN User's Guide," KLD TR-131, June, 1983.
I "The TRAF System - Technical Report,"
KLD TR-136, August, 1983 (with M.
Yedlin, B. Andrew and K. Sheridan).
"Application of the I-DYNEV System to Compute Estimates of Evacuation Travel Time at Nuclear Power Stations -- Four Demonstration Case Studies," KLD TR-142, December, 1983.
"Users Manual for the Interactive Dynamic Network Evacuation Model:
I-DYNEV,"KLD TR-144, February, 1984.
Lieberman Attachment R, 10 of 11 "Formulations of the DYNEV and I-DYNEV Traffic Simulation Models Used in EESF,"
KLD TR-154, March, 1984.
"PREDYN/IDYNEV Training Guide," KLD TR-155, April, 1984 (with R. Goldblatt).
"Specifications of Recommended Interactive Graphics Hardware Configuration and Graphics Support Software for the Netsim Graphics Display Package," KLD TM-93, July, 1985.
"Metering of High-Density sectors Comparison of Traffic Operations Along Fifth Avenue in Mid-Manhattan: Metering Control vs. Existing Control," KLD TM-94, July, 1985.
"Description of an Integrated Traffic Assignment and Distribution Model (TRAD) ,
for the IDYNEV System," KLD TR-187, -
1 April 1986. .
"Evacuation Plan Update (Robert G. Ginna
"'-lear Power Station)," KLD TR-189, Jf, 1986 (with R. Goldblatt).
"E.vacuation Plan Update (Davis Besse),"
KLD TR-190, July, 1986 (with R.
Goldblatt).
"Seabrook Station Evacuation Time Estimates and Traffic Management Plan Update," KLD TR-174, August, 1986.
"Reducing Traffic Congestion at Herald S qu a r e , " ITE Journal, September, 1986, pp. 27-31 (with A. K. Rathi).
"Congestion Based Traffic Control Scheme for High Traffic Density Sectors,"
Transportation Research Record No. 1057, TRB, National Research Council, Washington, D.C., 1986, pp. 49-57 (with A. K. Rathi and G. F. King),
"overview of the Evacuation Plan and of the Evacuation Time Estimtaes for the Secbrook Nuclear Power Station," KLD TM-98, October, 1986.
l Lieberman Attachment A, 11 of 11 I s
l "Overview of the Evacuation Plan and of the Evacuation Time Estimates of the Ginna Nuclear Power Station," KLD TM-99, November, 1986 (with R. Goldblatt),
"Overview of the Coastal Region within the Pilgrim Station Emergency Planning ,
Zone," KLD TM-100, November, 1986.
"Enhanced Freflo Program: Simulation of Congested Environments," paper submitted for presentation at Transportation Research Board's 66th Annual Meeting, January, 1987 (with A. X. Rathi and M.
Yedlin).
"The Netsim Graphics System," paper submitted for presentation at Transportation Recearch Board's 66th Annual Meeting, January, '987 (with B.
Andrews and A. Saat$ago). ,
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