ML19208C327

Corrections to Pb Herr May 1979 Testimony in Support of Contention 12.Corrections Relate to Max Risk to Population & Reflect Population Data Analysis Performed After Preparation of Testimony.Certificate of Svc Encl

ML19208C327
Person / Time
Site:	05000471
Issue date:	08/22/1979
From:	Burt L MASSACHUSETTS, COMMONWEALTH OF
To:
References
NUDOCS 7909260068
Download: ML19208C327 (4)

Text

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,. NRC PUBLIC DOCUMENT ROOM UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

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In the Matter of: )

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BOSTON EDISON COMPANY et al_.

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(Pilgrim Nuclear Generating ) Docket No. 50-471 m i' Station, Unit 2) )

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CORRECTIONS TO TESTIMONY OF PHILLIP B. HERR.

The following corrections should be made to the Testimony of Phillip B.-Herr submitted by Intervenor Common-wealth of Massachusetts in support of its'. Contention 12.

1. Page 8, line 7, delete the first and second sentences of the paragraph following "III.

MAXIMUM RISK TO POPULATION", and substitute:

"When in the site selection process a decision-maker is assessing the comparative risk resulting from a hypothetical major accident, a question of critical concern is what the worst consequences might be at each alternative site. In order to rationally evaluate alter-native sites, a decision-maker must be able to assess the most severe consequences which are reasonably likely following an accident at each site, measured by the max-imum, not average, number of people who might be exposed to risk."

2. Page 9, line 17: delete the last sentence in the first full paragraph, beginning with "If the objective" and substitute:

"If the objective of the decision-maker were to minimize maximum potential population at risk, or to avoid exceeding an acceptable threshold of population at risk, Site A is a far superior selection."

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3. ,Page 17, line 5: delete the word " annual", and substitute " annular."

4. Page 20, line 18: delete the last sentence of the second "

paragraph, beginning with "A few natives may

, . . . , and substitute:

"A few natives may thread their way to Glen Charlie Road in Wareham, Head of the Bay Road in Bourne, or other by passing routes, but their numbers cannot be large."

5. Page 22, foctnote 11: delete " Table B" in tite second line from the bottom, and substitute " Table C".

The following corrections reflect further analysis of population data performed by Professor Herr subsequent to prepara-tion of his alternative sites testimony in May 1979.

1. Page 11, line 16: at the end of the third sentence appearing in the paragraph under "A. Temporal Anal-ysis", insert an asterisk (*) after the number "4,300. " and add reference to the following footnote:

• Analysis based upon the ' Pilgrim Station Environ-mental Report' (ER) as amended through May 20, 1974, suggests that in Zact peak 1990 population within five miles may be nearly 63,000 persons.

2. Page 12, line 7: insert an asterisk (*) after the word " summertime", and add reference to the following footnote:

• Analysis of the Environmental Report indicates a 1990 total of nearly 180,000 persons at peak summer periods.

3. Page 22, footnote 11: add to the end of footnote 11 the fc11owing sentence:

• Analysis of the Environmental deport indicates a 1990 peak seasonal total in excess of 50,000 persons.

Respectfully submitted, LAURIE BURT Assistant Attorney General Environmental Protection Division Commonwealth of Massachusetts August 22, 1979 One Ashburton Plac'e, Boston, MA 02108

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD D

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In the Matter of: )

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BOSTON EDISON COMPANY et al. ) Docket No. 50-471

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(Pilgrim Nuclear Generating )

Station, Unit 2) )

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CERTIFICATE OF SERVICE.

I, LAURIE BURT, hereby certify that the attached

" Corrections to Testimony of Phillip B. Herr" submitted by the Commonwealth of Massachusetts, was served on the following by depositing copies in the U.S. mail, first class postage prepaid, or by other method so indicated, this 22nd day of August 1979:

(notifiedb ANDREW C. GOODHOPE, Esq. BARRY H. SMITH, ESQ. (phone Chairman, Atomic Safety and MARCIA E. MULKEY, ESQ. (8/22/75 Licensing Board Office of the Executive U.S. Nuclear Regulatory Commission Legal Director Washington, D.C. 20555 U.S. Nuclear Regulatory Comm'n

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Washington, D.C. 20555 DR. A. DIXON CALLIHAN Union Carbide Corporation ATOMIC SAFETY AND LICENSING P. O. Box Y BOARD PANEL Oak Ridge, Tennessee 37830 U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 DR. RICHARD F. COLE Atomic Safety and Licensing Board WILLIAM S. ABBOTT, ESQ.

U.S. Nuclear Regulatory Commission 50 Congress Street, Suite 925 Washingten, D.C. 20555 Boston, MA 02109 ATOMIC SAFETY AND LICENSING OFFICE OF THE SECRETARY APPEAL BOARD Docketing and Service Section U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Comm'n Washington, D.C. 20555 Washington, D.C. 20555 1015 163

MR. DANIEL F. FORD MR. AND MRS. ALAN R. CLEETON 1208 Massachusetts Avenue 22 Mackintosh Street Cambridge, MA 02138 Franklin, MA 02038 -

HENRY HERRMA$'N, ESQ. DALE G. STOODLEY, ESQ.

151 Tremont Street Boston Edison Company Boston, MA 02111 800 Boylston Street Boston, MA 02199 CHIEF LIBRARIAN Plymouth Public Linrary GEORGE H. LEWALD, ESQ. (Hand-del'd)

North Street Ropes and Gray Plymouth, MA 02360 225 Franklin Street Boston, MA 02110 EDWARD L. SELGRADE, Deputy Director Governor's Mass. Office of Energy Resources 73 Tremont St.

Boston, MA 02108 CluAll LAURIE BURT Assistant Attorney General Environmental Protection Division Commonwealth of Massachusetts One Ashburton Place, 19th Floor Boston, MA 02108 (617) 727-2265 e

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