ML20010E205

Unofficial Transcript of 810901 Hearing in Bethesda,Md. Pp 1-47

ML20010E205
Person / Time
Site:	05000471
Issue date:	09/01/1981
From:	NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP)
To:
References
NUDOCS 8109030199
Download: ML20010E205 (50)

Text

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(Pilgrim Nuclear Generating Station, )

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5 In the matter ef:

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Docket No.5C-471 (Filgri: Suclear Generatin; Station, a

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O ALCEDSON PEPCAT,NG COVP AV. NC.

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4 1 with you, Mr. Wri;ht.

2 SE. "EIGHT:

Yes.

.M y name is Frank Wright.

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j 3 Special Assistant Attorney General, r e p r e s e n t.i n g the 4 Intervenc C o r r.o n w e a lt h of Massachusetts.

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GC7DEEEG:

Jack Goldberp with the Office of 6 the Executive Legal Director for the NFC staff.

With me is 7 Larry Chandler.

3 ME. DIGNAN:

Mr. Ch ai rma n, metters of the Board, 9 my name is Thomas G.

Dianan, Jr.

I an a memher of the firn 10 of Ecpes and Gr'y, 225 F anklin Street, Eosten, 11 Massachusetts.

WitP te te my right is Willia: S. Stowe with 12 t h e 90ston Edic0n Cc.pany legal department.

..' e a pp e~tr for 13 t h e Applicants.

O 14 CHAIRMAN MODEE:

Mr. W ri g h t, you ra y preceed, and 15 reserve any ti.te that you need.

16 ME. WFIGHT:

Thank you, Mr. Chairman.

17 The issue, the single iscue that I wish to address 18 t 0 d a y, ronrerne the EC-called Class 9 accident

i a l y si s.

19 M assach u sat t s, as you ay know, is one of the mest populous 20 sta tes in the nation.

Indeed, it is third Tost populous.

21 And there has always been a concern in the Attorney 22 General's office on behalf cf the people of Massachusetts

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400 VIRGINIA AVE., S.W, WASH.NGTCN. O C. 20C24 dC2) 554 2345

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c 1 surroundia: the FlymoutP area.

2 Dur concern thus far in +hese proceedinas has teen 3 manif ested in two ways.

Firrt of all, ence again, as you 4 may know, we have a con'ention, a number of contentions, l

5 pen ding wtth recpect to ere rgercy planning tha t the 6 Licenring Scard is going to be ccnciderin; in the vety near 7 f uture.

8 In addition, from the inception of these 9 procaedings we havo pursued cur air of trytnc to convince 10 the staff, the Licensing Eoard, to conduct what has come to 11 be known as a Class 9 accident analysis.

In fact, before we 12 g e t -- I get started en the cutstantive nature of my 13 p rs sent a tion today, ! Would l i.' _ e to take a moment cut to O

14 a dd rece one of the ircuet raised by the staff in their brief 15 to this Beard, 16 That is their centention that we are barred from 17 raising t.i i s issue tefere you today becauce it has not teen 18 a part of the proceedin;s below.

I take excepticn to that.

9I think it tc ctrewn throughout the proceed in gc relow, 20 sta rting with our contention number 12 itself, which was to 21 the effect that the Apclicant and the staff erred in not 22 consido ring alternative sitec that micht be more superior 23 f r c a a population density rtandpcint.

24 That particular ccncern witP rarpect to population 25 d en ti ti wa3

r. a n i f e s t e d in a nunber of wayc, one of which was O

ALOEASON REPORT!NG COMP ADY. INC.

400 VIRGINI A AVE., S/N. W ASHINGTcN, O C. 20024 (202) 654-2345

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1 our plea to tbs staff and to the Peard that the censequences 2 of cerious reactor accidentc be locked at in a syctematic

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4 DR. EUC.<:

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Vright, are ycu concorned about 5 Class 9 acrident.s only because of population?

Do you see 6 any other exceptional circumstancer about the reactor?

7 MR. WRIGHT:

Yec, I was going to addresc them a 8 tit later, sir, but however, just ve ry triefly, in addition 9 to population density i tre lf, we are concerned about the 10 distribution of tnat populatien within the --

11 DE. BUCK:

That is populatien.

I an talking about 12 exceptional circumstancer on the reacter itcelf that would 13 cause one to conrider Clars 9 accidentc.

14 YR. WEIGHT:

In addition to population, our other 15 concern, as we attempted te point out tc the licensing 16 Boa rd, concerned transportation networks, crecifically the 17 f a c t that Poute 3A, which passes -- which ic the main 18 tho rough f a re in that particular a r '_ a, as the Applicant 19 itself has noted, it is ccngested in the curmertire becauce 20 o f tho large influx of touristc that rc e into that area.

21 And recondly, the reactor itsalf is but ten milec 22 f r:r the Cape Ccd Canal, the whole Cape being connected to 23 the mainland !y two bridger, one of which ic right on the 24 perimeter of that ten-mile ccne.

Therefcro, any react?r 25 acciden t may implicate the Capr either by eans of O

ALOEHJCN REPORTING iP ANY. !N O.

400 VIRGIM A AVE., S W.. W ASHINGToN. O C. 20024 (2 2) 554 2345

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1 spontaneous evacuatior Or planned evacuation.

2 The ovement of people eff the Cape is going to 3 have to come --

4 DE. EUCK:

Why do you have to route pecple off the 5 Cape?

6

13. WEIGHT:

In terms of spontaneous evacuation, l

7 you may not have any choice.

In terms Of the --

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What do you mean b y " spontaneous l

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't E. WEISFT:

People who, hearing en their radics i

11 that there is a sericus accident underway at Filgri 1 or 2, 12 m a y decide to try tc escape the effects of that accident by 13 jum pina in their cars a n '. heading --

0 14 DE. EUCK:

Eut they are all reycnd the ten-mile 15 limi t, a re they not?

16

v. E. WEIGHT:

Yer, the Cape is.

"cwever, the 17 em e rconcy plannin; con te n ti on tnat is -- will be under t

I 18 con sideration ti the Licensing Ecard in the near futura 19 s till leaves it open whe the r Or no t under these ; articular 20 circunstances perhaps nore than ten miles may be necessary.

i 21 D?. ?UCK:

For evacuation?

22

12. WEIGHT:

For evacuatien.

Under the NEC's rule 23 t e n miles is cet as the norm.

"cwever, the re is also a O

24 recognition 0; *he fact that under certain circu.:ctances 25 t h a t tan-Iile Cone may have to be e :< p a n d e d cr contracted, lO l

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2 DE. EUC<:

Well, they also consider whether cr not 3 stayin J there would be the best thing or not, don't they?

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5 DE. FUCK:

A vast majority of th e peo ple on the 6 Cape are far beyond the ten-mile zene.

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WEIGHT:

That is correct.

8 DR. BUCK:

That is correct.

Go ahead, sir.

9 ME. WEIGHT:

So w have the transportation 10 problens,

7d in addition, once again, it pe rha ps nigh t be 11 population density, but navertheless, as you are probably 12 a wa re having reviewed the record, a large nunter of people 13 com e into thic area in the summertime both as tcurists and O

14 as bathers and what have ycu, which further complicates 15 m a t t e r s becaure, of course, those pecple will have had no 16 prior traininc in evacuation or sheltering, or indeed have 17 any place in which to chelter thenselves.

"+ those are the kind of special --

18 19 DE. EUCK:

Well, isn't -- I at a little disturbed 20 a bou t Mringine this up at the cresent tino, becausa you have 21 not yet considered the energency plan it. th e hearing; is 22 t h a t not correct?

23 1r. WEIGHT:

That is correct.

24 DE. EUCK:

So are we act just speculating at the 25 presen t moment as to hcw th e 20ard is going tc handle the O

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think that my p resen ta tion today

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O ar 4 and the ssue raised before you is tirely because the NEPA 5 considerations of which this 1s pa rt is now tefere you.

The 6 Board h as reached a decision on it.

Ncw, there may be --

7

• S.

KOHL That is a conditional decision, is it 8 not ?

The Board explicitly states that they intend to 9 reassess the cost-benefit balance at the conclusion of the 10 h ea rinc.

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'e' E I G H T :

That is ccrrect.

Nevertheless,

4. s 12 f a r as the '; E F.; concerns, as far as p:pulaticn dene ty and 13 a s it relates to the '; EPA alternativo site analysis and O

14 environnental inpict analysis, the Feard has clcsed the 15 record on that natter.

And therefore, that is why this 16 issue is hare before you today.

17 If I

.ay return to the staff'c contention, it is, 18 a s I say, that we have not raised this issue ir the past.

19

?. S. KOHL:

As ! understand it, the tener of your 20 Cla ss 9 accident argunent here before us is that in view of 21 the Connis sion 's June 1990 policy statenent, there is sore 22 basis in ycur view for the agency conridering Class 9 23 acrid ent s.

T h ?. t was not the rcntention tha t you ; resented 24 a t the cutset cf the hearina telow, wac tt?

25

v. F. U:GHT:

Sc.

Of course, the statement of O

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1 interim p o li cv. came well after the filing of contentions.

2 MS. '.OHL:

Did you make any effort at all after

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3 that pclicy statement was issued to bring that before the 4 licensing Ecard?

.\\.o, no, we a1d not.

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.n 6 statement of interia policy, it was incumbent upcn the staff 7 to conduct a reviaw of the cutstandinc sites to make a 8 determination whether there were any special circumstances.

9 "S.

KOHL Did you request the staff to do that?

10 Y. E. WEIGHT:

No, no, we did not.

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Eecause the statement cf pclicy 13 its elf instrurted the staff to de so.

And a certain ancunt m) 14 o f time passed, the staff did nothina, the Ecard issued its 15 d ecision, and therefore we find ourselves here today.

16

$5. KOHL:

Have you cade any effort, since th e 17 hea ring is centinuing, albeit on the other contentions 18 b e l o w, have you ade any effort in that centext to raise 19 + s..s e o.

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20

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WEIGHT:

No, not while this case has been here i

21 before this Board.

The matter -- of course, the Ecard has 22 the power to either r e m a n." the matter for t>12 purpose or to 23 rea ch an independent decision itself.

But it was our b,

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a determinaticn as to whether it felt there 2 were any special circumstances.

3 And by its silence I assure, at least as far as l

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4 Pilgrim is concerned, the staff felt th e re were no special 3

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We, hcwever, do.

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These were issues even befcre the statement of l

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Now, at that point we were flying in the face, of

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13 However, ever the years a nutter of exceptions 14 s e r e ca r v e d out of that particular policy s ta teren t by the 15 s ta f f, the Ferryman application being the nest relevant to 16 t hi s pr oce edin g, becauce in tha t proceeding the staff felt 17 t h e population density surrcunding Ferryman was cufficiently 18 h ig he r than those of an elternative site to warrant this 19 Com miscion analysis and went ahead and '. i d so.

20

.S.

KOHL:

Mcw does the population density at the 21 Perryman site cc pare to the population density at 22 Ply cuth ?

23 wE. UEIGHT:

I am sc rry, I do not have those 24 f i;urec with me.

That is cne of the thingc when I reviawed 25 my no te s list night I diccovered I did not have.

O ALCERSON REPORTL.G CCMPANY, INC.

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400 V RGiNI A AVE., S W, W ASHINGTON. O C. 20024 (202) 554-2345

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1 It 'as been our position all along, however, that 2 we have our own share of peculiar population problems and 3 those were the issues that

.e were trying to raise before gw i

the Licensinc Ecard.

We raised then in our comments to the 5 draf t supplement to the FES tha t was filed.

We rtised then 6 in testimony filed on behalf of the Connonwealth by 7 F ro fessor Ph ilip Herr of the Massachusetts Institute of 8 Technology.

And

.e attempted to raise the-by way of 9 cross-examination cf staf f witnesses, but were prevented 10 f rom d ain; so by a Ecard ruling to the effect that the 11 proposed annex prohibited any consideration of Class 9 12 acciden t ccnsequences.

13 DR. EUCK:

Well, you did -- t h e population romes (m

t ss 14 in t o play, does it not, on a Class 7 or a Clars 9 accident, 15 a n y accident?

!t is a risk situation that you are concerned 16 w i t h.

17 MR. WEIGHT:

It is the risk rituation and the 18 con seq ue nc es of those accidents, for which the plant has not 19 been designed; in other words, those accidents that go 20 beyond the desi;n basis of the plant ir relf.

And we 21 a t t e m p t e d to show that there were there concerns that chould 22 have prompted the staff to t ak e a -uch closer and moro 23 scientifically derived look at population differences

()/

24 between Pilgri-and its alternative sites, as well as w

-be^l c

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i"

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b ALrERScN REPORTING COMP ANY,INC, 400 VIRGINIA AVE. S W WASHINGTc 4. O o. 20C24 (202) 554 2345

12 O

xs. <out:

cc=14 7oc eret==ste n wee: the 2 par ticular circumstances are that you think distincuish 3 Filgri i?

4 ME. WEIGHT:

Yec, all ri;ht.

As you know, under 5 the statement of interin policy the staff and the licensing 6 Board has been precluded in those cases where an FE~ has 7 been completed fron delving into the consequences of Class 9 8 accidents.

Accordine to the Commission, with two metters 9 dissenting, it is no cause for reopening of the record, this 10 n e w change in pclicy with respect to Class 9 accidents, 11 abcent special circumstances.

Althcugh we have sore --

12 ME. KOHL:

I am trying to discern what the 13 pa r ticula r aspects of the population surrounding Filgrim are O

14 that take it stand out.

15

15. WRISHT:

All right.

In this case, we are 16 conc rn e d about, first of all, the tremendo us influx, as I

i 17 opposed to most of the reactor sites.

We find that at 18 Pil g rin, in any event, it has been located in such a place 19 t h a t experience-1 large seasonal influx of tourists and 20 ba the rs a nd seasonal residents, all of wher flock into this 21 area and vastly increase the sice ;f the population in the 22 surser monthc.

23 In the event Of an accident, of cource, those 24 peo ple berome of special concern, primarily because they 25 will have nad no prior training in energency responses to O

ALCERSCN PEPORTING CCMPANY. iNC, 400 V;RGINIA AVE., S W., WASHINGTCN. O C. 20024 (202) 554 2345

14 1 the accident, nor places to shelter th e r sel ve s.

2 MS. KOHL:

"ow, as I understand it, your brief C.s 3 tak es excep tion to the staff's use of temperal weighting.

4 ME. WEI3HT:

Yas.

5

.M S. KOHL 4 In that -- to explain what tha t is, the 6 sta f f attributed certain weight to the summer residents and 7 other transie..ts on the basis of the time spent in the 8 area.

m 9

dE. WEIGHT:

That is correct.

10 MS. <DHI :

Does the Commonwealth ebject to all 11 wei gh ti n g Of that nature?

What would your alternative be, 12 f ull credit for those individuals?

13 ME. WFIGHT:

"' h e testineny that we presented

>L 14 through our expert witnenc that the Ecard in its opinion did 15 n o t bother to discuss one way or the Other was to the affect 16 t h a t when you ". ave thase vast fluctuations in population, 17 tempo ral fluctuations in populaticn, that wherea s weighting 18 n a y make sence to a i ve ycu a feel for the average, it is 19 only half of the picture.

20 If the purpece of th e staff in lockinc at 21 p o p ul a t ion dansity, as it riains, is to determine the 22 residual riskc that exist, it is not encugh just to lock at j

23 S ve rages Wnen you h a ve there wide f luc tua tions.

You have to 24 look at experience as well.

25 MS. MCHl:

What would the C00mcnvealth prefer, ALCERSCN REccRTAG COMPANY. INC.

400 VIRG NI A AVE., S W, W ASHINGTCN. O C. 20024 (202) 554 2345

1c O

,th>n2 21 tng f=11 =re411, the=2 Hevinc th. =cru1etio=

2 density measured by the maximur population at the peak of 3 the summer tcurist season?

4 YE. WEIGHT:

What we have to keep in mind here is 5 that this is a trigcerinc device only.

Whether or not 'ou

1. weight the: or not is not nearly as important to us as to 7 whether -- as to whether or not you perform this Class 9 8 acciden t analysis which allows you te get in in a much more 9 sophisticated way than just looking at population density to 10 t h e conseguancos of an accident, looking at metecrology and 11 road conditions and topology.

12 MS. KOHL:

Let's just focus en population density, 13 because that ir the principal concerr throughcut your 14 b ri e f.

Are you opposed to weightinc in any forn?

,,uide h,,i :

,, s. e weighting cones,ro

.eg 15 v

a :u o 16 4.7, and it is our con ten tion, especially ir these kind s of 17 cir cunc t an cer,

_t just is Oct encuch.

18

15. F0HL:

And what do you succest should have 19 been done?

20 ME. FEIGHT:

The triggering device here should 21 have been weichting plus ccncern for any -- the paak 22 pop ula tions, if you will.

23

15. KCHL:

ut i s r. ' t that ccr.cern nanifest in th e O

24 f a c t that it is taken inte account, indeed, in the weichting 25 process 1.self?

Those individuals that sre t ". o r e d u ri ng the O

ALDERSON REPoATING CoVP ANY. INC.

400 VIRGINI A AVE., S W.. W ASHINGTON. O.C. 20C24 (202) 554 2345

l

[

16 1

, ()

1 summer Icnths cr other tines cf the year are taken into 2 account, and there is -- ir a quantitative sense, they are

()

3 not discarded.

4

f. d. WRIGHT:

So, they are not discarded.

Eut tre 5 problem is that. hen you ;et these vast numberr of people 6 coming in, that their impact -- the impact of an accident if I

l 7 it were to occur durinc those summer months is obscured by 8 the weighting that goes on.

9 For example, I de not have the precise figures in 10 f r o n t of me, but if my memory serves me correctly within the 11 two-mile -- five-mile cone, or is it t wo -mi lo cone -- in a n y 12 e ve n t, in close p-cximity to the reactor thera are in the l

13 su m m er months rote 10,000 people residing, and there are

(

14 b o t h seasonal and permanent people.

We are not even talking 15 a b o u t transients, the day-trippers and the tourists and what 16 have you.

17 Ihere are 1C,000 people reciding in that area.

18 B ec aure most of those people are seasonal residents, when 19 t h e staff wei; hts that the number they come up with is 20 3,000, and that is he nunter, more or less, that is the 21 number that gets cc pared against these alternative sites.

22 A n d it would be ocr contention that, wheread that is useful, 23 i t is by no means the be-all and the end-all of this, what

(

24 sho uld be a prcper tricgering device, because if ycu do have 25 t h a t accident in the sur er months ther you aro going to O

ALDERSCN AEPORTING CCMPANY. :NC.

400 V! AGINI A AVE, S W., WASHINGTON O C. 20024 (202) 554-2345

17 1 have to deal with 10,000 pecple and not 3,0C0 pecple.

And 2 that was the extensive testimony that was offered by 3 Prof essor Herr with respect to risk analysis and the 4 deficiencies that exist in the staff's approach to this.

i 5

MS. K C '". s Put aren't you cetting there into the I

6 area of emer;ency planning?

Aren't these things more l

7 pro perly explored -- when you talk alcut actually dealing 8 with the 13,C00 pecple in the event of an energency, isn't i

l 9 that the sort of thing that might be more properly explored

(

I 19at the continuation cf the hearing before the licensing i

11 Board on your rer. lining contentions?

12

?. E. WEISFT It certainly will be, there is no 13 question about it.

Put we are talking here about scDathing 14 t h a t is quite diffe.ent fror that.

We are talking here 15 a b o u t what is a prcper triggerinc device that would cause 16 t h e staff to lock ir a quantitative way at the consequences 17 o f Class 9 accidents.

18

?. S. KOHL:

You just said tn a qua ntita tive way.

19 I f you do not like the wei g h ti ng that the staff has 20 e mp loyed, again what w o u l:1 you suggest as sc:ething 21 preferable?

You apparently do recognize the need to anploy 22 some quantitative device.

23 9 0.. WRI3FT:

Nc, I havo no ;uarrel with avGraging O

24 a s long as, in addition to averaging, something elre is used 25 as well.

O ALDERScN PEPcATING COMP ANY. INC.

400 VIRGiNI A AVE., S.W., WASHINGTcN. o C. 20024 (202) 554-2345

i 18

/~T 1

New lot me give you another e'.a ple.

In the V

2 pacticula r d e:c gripnic rircunstances of Pilgri:

2, a la rge 3 number of individuals are located in a snall number of f-

~-

4 sectors.

Indeed, acccrding to Profescer Herr's testimony, 5 more than half cf the people within 30 miles of the plant 6 are loca ted in just two of those 15 degree secters that the 7 sta f f em ploys.

8 Once again, when the staff comparec Filgrim with 9 these other sites, it is losing that particular aspect.

And 10 min d you, it is doing this only as a triggering device, only

• hether they should gc further and get 11 as an attempt to see 12 int o Cla ss 9 accidents.

And that pa rticula r aspect is lost 13 alt oget h er hecause they average it out through the whole n-14 rin g.

s-15 Now, granted, if the accidents -- unless you can 16 s h o w that the wind direction is sucn that it is always going 17 t o be blowing tn that d irec tion, the averaging over a ring 18 h el ps you to a certain extent because it allows you to 19 com pare the avera;e here wi th the average there.

All we a re 20 saying is that this is one more of the special circumstances 21 that should have triggered a closer look at the consequences 22 o f a Class 9 accident.

23 It is not like the rando distribution or the more 24 o r less even distribution that you Often find arcund si tes.

)

25 It ic heavily cenrentrated ir certain areas.

There is a i

~j ALCERSCN REPORTING CCVPANY, INC, 400 VIRGINI A AVE., S.W. WASHINGTON. D.C. 20024 (202) 554-2345

19

()

1 strip, for example, jurt south of the plant where there are 2a number of beacher wi th se a s o n a l re sid en ts.

There are some

(}

3 7,000 seasonal residents lccated within two T.iler cf the 4 plant along a very narrow corridor.

If an accident were to 5 occur and the plune were to drift in that directicn, there 6 would be /ery serious concequences.

7 And once again, in terms of a triggering device as

(

l 8 to whether the staff should icok closer at those 9 consequences --

10 D ?.. EUC'<:

Mr. "right, we have that sort of a l

11 situation in several of the plants I can think of, San 12 O n o f r e for exaople, Seabrook to an extent.

There are 13 several otherc.

icn has a very similar situation.

And as O

14 far as I csn see, this is being taken care of in the 15 consideration of the evacuation plans or the ererger f 16 pla n s.

17 Now, I would like to go back, if you do not mind, 18 t o the other, to the thcught of exceptional circunstances, 19 because this ves first brought up by tne staff cn the 20 of f shore power plants, where the idea was if ycu had a 21 m el td o wn of th e core that went througr the bettem of the 22 vessel it ended up in the ocean, which would have serious 23 ef f ects, possibly, on the cce an bicta and so en, and on a

(

64 land-based plant you could have the same accident where the 25 m a terial would just go down into the ;rcund and have no O

i l

ALCEPSON REPORTING COMPANY. INC.

I l

400 VIRGINI A AVE., S W. WASHINGTON. O C. 20024 (202) 554-2345

j 1

l 20 1 particular serious effect, pa rticula rly if it did not get i

2 into the water t20le.

l 3

Now, that is the sort of exceptional circumstances 4 that cauced the Commission to h a ve the staff look at i

1 5 of f shore from the point of view of o -- Class 9 accidents.

6 And they said at that time, if I recall the Commission's i

1 7 sta temen ts, that these 'ere entirely di ff erent than a i

8 land-based plant as a general rule.

9 Now what I ar looking for here, a re there any 10 oth er e xce p tional -- let's for et population for the moment 11 -- are there any other exceptional circumstancos about the i

12 Pilgrim location that you feel should trigger a Class 9 i

i 13 review?

1 14 ME. WRI3HT:

I ar sorry to differ with you, sir, 15 in one respect, and that is in talking ahout special I

.1 16 rit cumsta n re s, in addition to ci tin; ca ses like Offshore i

17 Powcr Syctenc, the Commission also citad Ferryman, where the 18 special circumctance --

's _.. U " "s *

" i '. c" . ". h. * * ?.

O 19 e

20 MF. WRIGHT:

Th e Ferryman applica tion, where the 21 special circumstance that prompted the ctaff to do a Class 9 22 acciden t analycis was po p ul a tio n.

23 DR. EUCK:

What did they say ahout Ferryman; do t

L

' " =* "'='

O 25 M9. WR13HT:

The Ferryman case involved population O

ALCERSON REPCRTING CCVP ANY. :NC, i

I 400 VIAG:NIA AVE., S W W ASHINGToN. O C 20024 (202) 55 t-2345 1

---nn-

21 1 d en ti ti e s that were su f ficier. tl y high tc concorr the ctaff 2 that they should do this Clars 9 --

3 DR. 9CCK:

You do not re r e '.t e r what the 4 r el a t i o n s". i p was between that population and the Pilari-5 pop ula tion ?

6 ME. WFIGHT:

No, those figures I cannet give you.

7I would be glad to supply ther as scon ac I get back.

8 DF. EUCK:

Do you have anything on the 9 relationship Of the Filgrim population with any other plants 10 around ?

Lat's taka Zion, for example, San Cnofre, Oconee, 11 some of these others.

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.y head, that Zicn is a classic example of a O

14 v e r y, very hint -- and Indian Point as well -- very high 15 pop ula tion.

16 D?. FUCK:

Ecw abcut Ean Oncfre and sc e of the 1,,

e s.o_

e.

18 VE.

WEIGHT:

I a-not aware of thoce.

I am 19 talkinc '. e r e ore atcut our concern with these, not tha 20 num ber sc 7uct as this influx; first of all, the influx of 21 tourists that arn coming in, and secondly this abnormal

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ALCEPSON P EPCPT.NG COVP ANY. 'NC.

400 vtPG;N! A AVE.. S W. W ASNNGTCN. O C 20024 (202) 554-2J45

4. s.

1 other plants in a teach situation?

And there are others, 2 many others.

There are some in Florida, th ere are some in 3-well, tnere are two or three in Florida.

There are ccact 4 pla nts that have the same sort of rituation.

5 MR. WFIGHT:

I have compared them with -- there 6 a re p resen tl y six applications pending for construction 7 per mits where FES' have been completed, and I have looked at 8 the population figures between those and they are not in the 9 record.

That is the problen.

I felt I could not fully get 10 i n t o that <ind of thing today because this whole issue of 11 special circur.s tances came up after the record was closed.

12 Eut in any event, there are six applications 13 o utst andin g.

All of those involve -- this is off the O

14 r e c o r d, I guess, tore than anything elre -- pcpulation 15 levels that are less than thoce at Pilgrim 2,

and that ir 16 all I can say.

17 DR. 2"CK:

Eut you know of no otner exceptional 18 circumstances at P i l g r i m. Other th a n pcpulatien?

19 MF. WEI3HT:

The population distribution, mind 20 y o u, not ;ust numbers, distribution.

21 DE. BUCK:

Population distribution.

let's put 22 t h a t in there.

23 Do you know of any other?

24 xs

s::ar:

t-the=

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t**

1 = et4==ee O

25 before is the roai netwcrks.

O ALDERSCN REPCRT;NG CoMDANY. NC.

400 VIRG;NI A AVE., S W, W ASHINGTON. O C 20024 (202) 554-2345

23 1

DF. EUCK.

That is part of the evacuation system.

2 Let 's cet off of that.

.re there c the r e xcep tions, such as 3 other particular envircamental problems cr anything eine l

4 o th er than population, population distributicn?

i 5

v. R. WEI3HT:

Fopulation dictribution and the road l

\\

6 n e t wo rk s tae:selves.

I 1

7 DE. EUCK:

All right, thank you.

R I O E T :

The othe r special circumstance that 8

MP.

9 goes beyond the factors at the site itself that we raised in t

10 o u r brief is with respect to the adequacy of the staff's i

I 11 h andling of population, the demography, if you will, the 12 first time around.

I ccvered that rather extensively in the 13 brief and I nead not belabc r the point now.

O 14 We were concerned primarily about its averaging, 15 the point, Ms. Kohl, tr t you trcught out, both temporal 16 averaging and spatial averaging, that we felt unfairly I

17 minimized the risk tha t exists at Pilgrim 2.

18 And in addition, we were concerned about the 19 se-called facter of twc, which we could find no basis for in 20 a n y NRC publication, other than a brief sta temen t in the FES 21 in this case.

Under the factrr of two approach to things, 22 th e staff is ;cin; to require population differences ietween l

23 sit es of tso or more before it will take any action as to 24 whe ther er not to conduct a Class 9 accident consequence 25 analysis.

t O

I A1.CERSCN REPCRTiNG COMPANY. INC.

i

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400 V!RGINI A AVE., S.W. W ASHINGTCN. O C. 20024 (202) 554 2345 I- - -

24 1

! r at a loss to find out where this factor of 2 two comes from.

It flies in the face cf logic to use 3 pop ula ticn dencity figures, at they say, ar an admittedly 4 crude indicatcr of risk and then

one step further and 3,

5 aake it even me re crude by requiring that there te a 6 significant difference in population before it is goin: to 7 consider any other site as preferable as far as pcpulation 8 is concerned.

9 That I would contend once acain is a deficiency in 10 t h e staff's analysis that has been conducted thus far, and 11 therefore se sculd sai and ask this Ecard to find that, in 12 addition to these population figures that I discursed 13 e a r lier, tais amounts to another kind of special O

14 circumstance that would warrant this Ecard either remanding 15 t h e matter to the Licensing Board er directly ordering the 16 s t a f f to conduct the Class 9 accident analysis, that which 17 i t is new doing on every other FES it is undertaking.

And 18 presumably it would not be that much of an additional drain 19 o n s t a f f 7.an; wer.

I 20 Mcwever, it would saticfy our concerns and the 21 people of Massachusette in knowing precisely what wouli 22 happen in the event cf a Class 9 accident at Pilgrim and 23 wh e ther or not there ir some other site of these alternative O

24 sit s thet

<=o=

tue r 12:

view or =.esor =eeto: cic>1 25 acciden ts doul: te far preferable to rilgrin.

O i

l ALCERSON AEPORTiNG CCMP ANY, ;NC.

400 VIRGINIA AVE., S W. W ASHINGTCN. O C. 20024 (202) 554 2345

_ _. _ _ _.. -. - ~.. _ _ _. _ - _ _.. _ _ _ _ - - - _ _ _,...,

n 1

3E. EUCK:

Do you have a preferred site?

2

E. WEISET We do net, because the analysis has 3 not been done by the staff.

We know, for example, that i

4 Yon tague has co nsid e ra ble less population surrcunding it

3. t i

5 the varicus radial rings.

Eut the staff did not cet into a 6 close look at these differences because it did not comply 7 with the so-calle! factor of two.

8 In the absence of the staff analysis, which it is 9 now doing, of c0urse, for all the o ther sites --

10 DE. EUCK:

Eut if you eliminate the population 11 just a moment, dcasn't Montague have sc:e other pro blem s,

l 12 environmen t al problems, for example?

1 1

13 ME. WEIGHTS Montague has some environmental O

14 pro blems that may give weicht to the balance.

Cur point is 15 only tha t before that balancG can be properly struck a nuch l

16 m o r e quantitative and scientific look has to te given to the 17 con sequence s of major accidents at the varicus sites, and 18 t h a t has not toen done.

We feel that is the responsibility i

19 o f the staff.

I 20 DE. EUCK:

One of the ;rchiers wi th Yontague, as :

21 recall it, is some endangered s,ecies, and ycu dc not weigh 22 those in the

t. a l a n c e, as I recal]

I 23

'E.

WE!3HT:

Well, there 1

-- there are certainly 24 9itiga t in; teasures that may te taker in order to avoid that 25 p rob le.

I 10 not know.

O ALDERSON AEPORT;NG CCMPANY. iNC, 400 VIRG!N! A AVE., S W, W AShiNGTCN. O C 26024 (2C2) 554-2345

t 26

(}

1 DF. ?"CP:

That is the only othar site that you 2 can think of in Massachusetts?

3 TF. WRIGHT:

That is the only site in 4 Massachusetts that displays significant differences in 5 popula tion, and it is one that we would have preferred the 3 staff to look at clocely, but it did not because of this 7 f actor of two.

8 DR. EUCM:

And r.c other site in Maccachusetts has 9 a pref erable population situation as far as you are 10 concerned?

11 MR. WPISHT:

Well, that is the problen, sir.

That 12 i s precisely the rreblen.

We do not knew, because the staff 13 h a s declined to do this analysis.

Now, in the future, if O

14 they were tc core into the state right now and prepare to do

(

15 a n FES for Pilgri, 3,

say, or Filgrin 2, if they were to do 16 it again, they would be obliged to lock at each cf these 17 sites usin; th o n?thodology that they have developed and 18 n a t e a precise determination as to which of these is goinc 19 to be preferable frcn a population standpcint.

20 D?. EUCK:

Are fou telling me tha y did not look at 21 the population at all on any of the alterna te sites?

22 VP.

WRI;HT:

All they did was look at population, 23 a nd resecrer that they use:1 populatics as a tricgering

()

24 dev ice.

If population density satisfies certain criteria, l,

25 then they will ;o that ad di tion a l step and take a closer f

(S)

I ALDERSCN AEPoRTiNG CCMPANY 'NC, 1

400 VIRGINI A AVE, S W. W ASHINGTON. D C. 20024 (202) 554-2345

l 27 O

1 1 look at the conseguences of a reactor accident at each of V

2 those alternative sites.

Thir is what was not done in this 3--

s 4

DF. BUCK.

What trigger would you use?

5 TE. W F.I G H T :

I would use a trigger cf both the 6 weich ting methed the staff uses plus these extrenes that you 7 find -- when you find those kind of extremes as you find at 8 Pilgrim, then I would call for that analysis, the extrenes 9 being the abnormal distribution of people around the cite 10 a n d the influx of people, seasonal influx of people.

11 DE. EUCK:

Ckay, thank yeu.

V WEIGHT:

Thank you very nuch.

12 13 TS. {CHL:

I have one further questien.

Does the d

14 C om.monwealt h dispute the need for power finding?

15

'E.

WEIGET:

No.

Tha t matter has been dropped.

16 W e did net trief that matter.

17 MS. KOHL:

Thank you.

18

'3.

DISSAN:

"r.

Chairman, members of the Scard:

19 For once my trief before one of the boards down 20 here was trief, and my arounent I think will le brief, 21 especially in light of the fact that two of the Intervenors 22 have elected not to present oral arguments.

Unless the 23 Sca rd has specific questions as to tatters ccvered in ny J

24 brie f i th respect to those twC Intervenors, I do not intand 25 to address any ar:utent to ther today.

%-)

A DERSON PEPORTING COMP ANY, INC, 400 VIRGINIA AVE.. S W. WASHINGTcN. O C, 20024 (202) 554 2345

,e-1 WitP respect to the argument of the Ccmmonwealth, 2 as indicated in oar trief, we see this as alocst puraly a 3 l e g a l I r. t t e r.

t MS. XCHL:

Mr. Signan, before you get tco far into 5 tha t arautent, does Eosten Edison really intend to build l

l 6 Filgrim Unit 2?

7

.1 F. DIGNAN:

Ecsten Edison Company has stated t

l 8 publicly in its filings befcre the SEC and otherwise that l

l l

9 the quostion of whether Pilgri 2 will be built is 10 constantly under review.

I can say to the Ecard the review 11 is ever-on:cin:, that the company has indicated tha t as th e y 12 g o t close to the tire when they had a real fix en when they 13 w o u ld have in hand the necessary permits a final decirion O

14 w c u l d he made.

15 I think it is fair to say that the corpany now 16 f eels it is close to that time.

The re is a review ongoing, 17 a n d it goes without sayin; that this Ecard will be advised 18 imm edia tely upcn any action cf the managenent or the 19 dir ector or directors with respect to that.

20 MS. KCHL:

Since you --

21 M9. ;IGNAN:

More than that I cannot cay at this l

pcsitien to know, 22 tim e because : do act -- I am net in 23 ei t her.

24

5. <CHL:

! an just wondering whether perhaps ycu 25 kne w remothing that everytedy else does not, since you O

ALCERSCN REPORTING CCMP ANY, INC, l

400 Vi AG;NI A A% E., S W. W AS%NGTCN. O C 20024 (202) 554-2345

29 1 yourcelf ra ise d the issue of the short -- the shortness of 2 yoar 'rief.

I was wondering whe the r er not your rather

("]

3 cursory handlinc Of the iscues in this care, particularly s

v 4 those raised by the Commonwealth, is some indication of 5 perhaps a lack of interest by Ecston Edison in diligently 6 pursuing this Tatter.

7

13. DIONAN

'a' e l l, I apologize --

8 dE. KCHL:

Is that a subtle indication that maybe 9 there is not a need for power and that perhaps this might 10 well te a waste cf our collective time?

11 ME. DIONAN:

Certainly if the Ecard feels that my 12 t rief was cursory, I apologine.

It was not intended to be 13 Cu r sory.

It was intended to te to the point.

w \\

d 14 My view of the Co Dcnwealth's arpunent is very 15 sim ple.

The i n t e r i x.

policy sta tem en t binds this Board, and 16 t h e Commonwealth

?, a y be upset about the interim pelicy 17 sta temen t and that is an argument to make to the Commission 18 or perhars to a C:urt cf Appesis.

This Eoard is beund by 19 t h e interi: policy statement.

20 The interim policy statement is clear:

no Class 9 21 analysis except in "special circurstances."

And the special 22 cir cumstances are not simply special circumstances; they are 23 sta ted by the Con?.issicn to be similar special s

)

24 cir cums t ances, and the; list three types and thei have added a

25 One more in a decision since the ;clicy statenent, trexinity D

I v%d ALCERSCN REPCATiNG COMP ANY, INC.

400 VIRGIN:A AVE.. S W., WASH 6NGTON. O C. 20024 (202) 554 2345

30 1 to unusual hazard.

2 MS. KOHL.

Eut one of those special circumstances 3 listed in the policy s t a t e.'. e n t is th e 0:cryman case, which I

4 doe s involve the matter of population density.

Population 5 density was explored at the hearing, alheit perhaps not in 6 the context of a Class 9 analysis.

Eut the re a re a rguments 7 and challenges that the Commonwealth raises to the l

8 par ticular methodology of the staff in determining the 9 population density.

10 And I find really no reference to any of the 11 specifics of that argument in your brief, and I a.m wondering 12 whe ther or not, if you are goin; tc hang your hat entirely i

13 o n the pclicy statement matter and juct concede the rest.

l 14

" P.. DIGN A' :

No, absolutely.

" hat the policy

{

l 15 sta temen t referred to was the Perryman case.

Dr. Euck 16 add resse d the attorney for the Commonwealth, did he have any l

17 com pa ricens between the twc.

Cne comparison you can make is 18 ? ? r r y a n tripped the staff guidelinec, Filprim deer not.

19 And the Conmission ir th? interi policy statement 20 ::ci a te d to the Parrymar and approved wha t the staff had 21 done.

And what the staff has is a set cf guidelines that 22 either a re t r. ' p e d or not tripped.

Now, pecple can step up 23 a n d arcue for a long time over whether you should ever have i

24 a regulation that has a trip ;oint.

Eut this Com-ission has 25 n a d thor for !=ars.

l lO 1

l i

l i

ALCER$CN AEDCATING COVPANY. iNC.

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400 VIRGIN! A AVE. S W. W ASHiNGTON. O C. 20024 (202) 554 2345

31 1

It goes back to when energency core cocling 2 sys tems were the Oig issue.

We put terperature en them.

I 3 think it was 1198 degrees.

4

35. KOHL One of the principal argurents the 5 Co nonwealth takes is they apparently do not like the 6 so-called tripping factor, the triggerinc type of analysis.

7 MR. DIGNAN:

I ar aware they nake that argument, 8 and the answer to that is, all lawyers cccasionally run into 9 the fact tha t the court has ruled and in this case the 10 Com mission is the court and the Commission has approved the 11 staff methodology, it is binding and tha t is it.

12 MS. KDHL:

We are bound by Feg Guide 4.7.

13

E. IIGNAN4 No, jou are bcund by the interin 14 policy statement and the interim policy statement 15 specifically approved, in y judgment, the handling of the 16 Per ryman ca se.

And it said that the staff -- that was a 17 spe cial circumstance, and Ferryman was set off by virtue of 18 t h e fact tnat the staff's guidelines were tripped.

And I 19 think that is a complete answer to the Comecnwealth's 20 a rg umen t.

21 And I understand the Cortonwealth's concern for 22 the staff's methodology and the Cc:missicn's approval of it, 23 and I do not quartel with their right to make that argument 24 to the Ccamission cr, as I say, tc a court.

Eut in this 25 forum, at this time, I think the interi-policy sta tenen t s

ALCEASCN REPORT.NG CCVPANY, iNC.

400 VI AG.N! A ANE., S W.. WASHINGTCN, O C 20024 (202) 554-2345

._m-___-

1 32 1 ends the discussion.

2 And : cartainly hcpe -- I have had the honor of 3 appearin: before boards of this C o s ?. ir c i o n many times and I 4 certainly no board thinks I an handing them a cursory 5 brief.

It was short, yes.

It was chcrt.

It was short 6 because I thoucht it treated the entire local argument to be 7 :n a d e.

I intended no disrerpect and no inference chould be 8 dra wn that herausa a brief ! filed war short indicates that 9a plant is not going to be built.

10 MS. KOHL:

Is the projected operatior. date still 11 Decenter 1955 or has it beer pushed back?

12 MR. O!3 NAN:

No, it could not -- 19EE I think at 13 this point would te extremely tight, becaure if ycu had a 14 per mit in hand new I de not cee hew you could do it in

'95.

15 MS. XCHL Eut there has been no new projected 16 d a t e.

1 17

E. DIGNAN:

No.

The company har indicated it 18 i o a s n o t. Int to do projecticns of that nature again until 19 t h e i are in a position to have the permite in hand and know 20 where they are ;oing.

They have been very candid before the 21 EEC in filings about this matter and it is one that will 22 have tc te resolved.

23

can pr: tire thi r Poa rd,

.'h e n, ar and if any h

24 definitiv decisi:n act to build Pilgrir ir ever e,

e, the 25 Bo ard will be on the list o f the first people to know that.

t O

l 1

i ALOERSON REPORT:NG COVPANY. lNC.

400 VIRGINIA A%E, S W. W ASHINGTON, O C. 20024 (202) 554 2345

-. ~.

i 1

i i

i 33 1

l 1 Eut I have no authority to come up here and say Filgrim 2 ir j

2 not being built.

And certainly nc inference chould be drawn 3 from the 1 snc +

of ry brief.

j 4

I know that Dr. Buck is on another Eca rd I a r_

l 5 b e f o r e e. n d I think he would to able to inform you that thic 6 is not the first tire I have filed a rhort brief.

I 7 sometines file short brieft if I think they deal with the 8 issue.

l 9

CHAIFMAN M00FI Your answer to the Cormonwealth l

l 10 i n reward t0 their criticism of staff nothodology is that

[

11 they should be making their argument, one, in this care 12 b ef ore the Commission, in an appeal precunably frca anything 13 w e do with the case, or did you have comething else in 14 mind ?

15 MB. DIONAN:

Or a Court of Appeals.

I mean, 13 eventually --

17 CHAIEMAN MC0rI:

Do they have a 2.206 remedy 8 here?

19 MF. DIONAN:

Thay have a 2.206 reredy, but I do 20 n o t think. a 2.206 renedy co uld be relied on here becauce 21 there is no conrtruction pornit to bting a 2.205 acainst.

22 So I do not think they have a 2.2C5 at this time.

23 The ether peint, I wanted te distin;uish ca ref ully h

24 between two thinas.

The Perry?.an methodclogy ir a set 25 methodology and it is that that I think is a matter of law.

G ALCERSON REPORTING CCMPANY. INC.

400 V;RGINl A AVE., S W, WASHINGTON. O C. 20024 (202) 554 2345

- - ~. -. -

l 3h O

1 :h-other arru en:, er : uneersta=d enat the Cc==.onees1th is i

2 saying, they want to create a special circurstance cut of

.i 3 the

-t tnat in their jud; tent the staff did a clipshed job j

4 analyzing site, and they say the first time er any tire.

C

'a' e ll, if that be so -- and I do not think it is --

i 6 the remedy is not to hold a Class 9 analysis of a lunch of i

7 si tes.

The recedy is, under NEFA, to say t h a '. the staff did 8 not do its job under NEPA, which has been said in this case i

I 9 cnre before.

10 The fact that the staff did not do a good job I

11 analycing other sites does not set off Class 9 analysis.

i 12 Th e remedy fcr that is an e x e p tion tc the Scard'r finding 13 a s to alternates, pressin; the appeal on that basis, and 0

14 asking this Ecard under :EFA to reverse the decision and 15 rem and for another look at alternate sites.

So if they 16 re ally intend that as their special circumstance, I 17 respectf ully suggest they have not got it up he re on this 18 record the way they have appealed the case.

19 I guess through the able questioning of Ys. Kohl I 20 h a v e pretty.urt rovered everything vished to and, unless 21 the Ecard has any ethor further quastions, that is all I l

22 have.

l l

23 (Board ronferrin:.)

24 TE. G01.02EEG:

• r. Chairmar and mechers Of the 25 AP0031 20 aria IO i

l ALCERSON REDCATING COVP ANY. INC.

400 VIRGINi A A%E, S W, W ASHiNGTcN. O C. 20024 (202) 554-2345

-- --m

i 4

1 35 l

1 I would like to addrass the Clarc 9 accident iccup l

i 2 raired by the Commenwealth, and then I would be clad to 3 answer any quertions on any other aspect of the appeal in i

9 4 this case.

I 5

The main a rg ument raised by the Commonwealth is t

l 6 that the population density currounding the proposed site is I

7 a s pecial ; rcumstance.

8 CHAIRMAN MCCFE:

To you agree with the Applicant I

9 tha t the Commonwealth has merely appealed the wrong t h i ?. g I

10 h e r e ?

i i

i 11 h3. GOLDEEEG Well, I think there are certain I

12 aspects cf the appeal which spill over from tha Class 9 t

i

(

13 a cciden t irsue per ce into alternate sites.

A particular i

14 example of that is the factor of two.

Tha* was something i

15 th a t the staff used in this cace in comparinc alternate 16 sit er, not in determining whether er not to do a Class 9 17 acciden t analysis.

18 And I would point out that the staff did not just 19 look at pop ula tion when it Iceked at alternate cites and did 20 n o t reject alternate cites on the basis of population 21 alone.

Population war merely one factor that the staff uced 22 in comp a rin; alternate sites.

!t conpared a host Of other 23 f ac to rs, and one by one looked at each alternativa and g

24 com pared it to the pr0 posed site.

25 MS. XCHL:

Is thic the first time that tha staff i

t ALrERSCN AEPoRDNG CCMP ANY, lNC f

400 VIRGINI A AVE, S W, W ASHINGTON o C 20024 (202) 554 2345 1

E----.-

i I

i

.o. c.

l 1 has relied on renethin; like this facter of two, as the 2 C o m.9 o n w a a ' t h rounrel argurr?

i 3

• E.

00LDEEFGs I believe it is.

The staff I

4 stadies, w1ich ! believe were completed not toc long pric:

l l

5 to this case, shesed that relatively large differencer in 6 population would be required before there w0uld be any 7 significant difference in risk, and so that it was not 8 unreasonable to require an alternate cite to have a 9 population dencity which was lower by a facter of two before 10 s a y in g, on the basir of perulation alone, that that 11 alternate site is inferior to the prerosed rite.

12 Etill, that wouli enly be one facter.

We would 13 n o t reject a site solely tecause, en the ba sic cf the factor 14 o f two, it had si;nificantl y hi;he r pcpula tion a t the 15 propcsed sit e than at an alternate site.

16 MS. KOHL:

Are there underlyinc studies in the 17 rec ord in thic case?

18

F. COLDEEFG:

30, they are not.

19 I wculd Point out again, with respect to the 20 f a c t o r o f two, the Corncnvealtn enpharizec the

?. c n t a g u e rite 21 and points at that as an example Of where this factor of two 22 yields improper recultr.

! would urgc the Ecard to compare 23 t h e population densities for the prep sed sites which are h

24 :On taine d in Staff Exhibit 66 and corpare these to the 25 population density figure in the FEE for the Xentague O

ALOE ASCN AEPcRilNG COYPANY. 6NC, 400 VIAG:N1 A AVE.. S 'N, 'N ASHAGicN. O C 20024 (202) 554 2345

- -.. -. ~. _ - -.,.

_ _ _. _. _ _ ~ _ _ _ _

l l

I 37 l

1 1 sito.

And ! thin <. the conclusion is clear that even on the j

l 2 basis Of pop ula tion thoca sites are comparable.

i 3

The Commonwealth's brief had come selected figures I

4 which I believe gives one a cici:pression a s to what a true j

l 5 compa rison of the two sites would te en the basic of 6 population.

I point cut, f or example, that in a number of l

l 7 sectcrs, 0 to 3,

0 to 4,

C tc 5 miles, the

.M o n t a g u e i

8 population figures actualli exceed the popu la tion figures at i

I 9 the prcrosed site.

l 10 I think the staff's conclusion that on the ba sic l

l 11 of population the sites are comparable is based on the 12 record.

13 0F. EUCK:

Mr. Scidterg, when you say " exceed " is i

O 14 that cr your weignted population :r actual population?

15 P. F. GOLDEEFC:

That is the weighted population.

16 N o w, we considered transients.

Wo did not ignore the 17 t ra nsien t popalations in this case.

We considered seasonal 18 reside n ts, and concluded that on an annual tasis they are 19 a p p ro xim a t ely there cna-fcurth Of the time.

We considered 20 d aily vicitors ani uced a factor of one over 365, which 1

21 gives

.033,,

nnd used that ac an apprcpriate weighting 1

l 22 f acter when looking at the pcpulation densities for purposas l

23 o f whether or not the Eeg Guide 4.7 trip levels were O

24 e x=eee ee -

"1=

1=

'1 i= '=c==e

==e

'it"

=e scie

' 7-l 25 DE. EUCK.

Ycu assumed your daily visitor.? ware l

O l

ALDERSON PEPCRTlNG CcMP ANY. INC.

l l

400 VIRGlNIA AVE., S W, WASHINGTON. O C 20024 (202) 554-2345

l I

2e l

G i

l 1 there for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, ic that correct?

I i

2

^37.r..:a^.-

'.'..s.

4e

--.--=.c+.

-+

~

l 3

OE. EUCK:

Iet te just chan;e the cubject for a O

4 nonent.

.t c. Kohl arked you a ~uectier atcut underlying 5 studies being in the record.

I an not quite cure that the 6 record it riear as te what underlying studies you were 7 talking about there?

Is this the studies to get the factor 8 of two?

Is that shat you are talking about, and only 9 those ?

10

.5 S. KOHL:

Yes.

11 DE. EUCK:

Okay.

Thank you, i

12

'S.

<0E1:

And ha Gaid they were not in the 13 r e c o r d.

l O

14 u. 00t:E E::

he facto: or two te seiressee in i

I 15 t h e FES and the reasoning was stated there as to why we 16 t h o u c h t it was appropriata tc use a factor of two, and t

17 men tion was made Of these studies.

The studiec themselves

[

18 1r? not a P3rt of this record.

19 OE. EUT(

I var afraid -- I did not know whether 20 y o: Ieant the underlying studies On the population of 21 alt er na te sites were in tne record.

22

15. (CEL:

Does Montague have a ceasonal or 1

23 t ra nciant Posulati0n at all?

24 YE. G3LDEEEG:

I do not think that there is any 25 ci;nificant ceas0;al populatice.

l O ALOERSCN REPORTING CCVP ANY, ;NC,

(

400 VIAGINI A AVE., S W. W ASWNGTON. o C 20C24 (202) 554-2345 l

r r

i I

I I

I JY i

1

• S.

K C E *.

Se te.peral weighting was not a factor, t

t i

2 then, when you computed t '.4 e population density for that 3 particular site?

4

• E.

GDL??EES:

"at is correct.

~ 5-'ieve that is i

5 correct.

6 MS. KCHL:

What dater were used in this case as i

t 7 the basis f o r your population projections?

r I

l 8

1R. OJLDSEF3:

19E5 was used as the estimated r

.artur date for the plant, and then 2020 as a subsequent 10 d at e to l o o k.

at populations.

11 TS. KOHL:

Now, in view of the fact that those are 12 n o t any longer realistic operation dates for Eilgri Unit 2, 13 w h a t does that say abcut the data that is in the record en O

14 this case so far?

Is it somehow less reliable?

!n other i

15 word s, if you were using population projections for further 16 in the future night not tha t give you data that would j

17 trigger er tri; the :eg Guide u.7 criterion?

ts M?. GOLDEEEG:

It is possible that if we used 19 f u r t h er projections of population, further into the futura, 20 t h a t we would.

I an not certain cf that.

21

v. 3. KOHL:

As I understand the data, yce were 22 getting pretty close to the 1,000 person per square mile at l

23 t h e time of retirement.

I think your ficure was 370 and 24 some thing.

+'n D i 1 ~ 'i -

t

.. g- "c cCc =+

• O

-~ v v:

--+n

+.

l 25

~

l0 ALCERSON REPOAT!NG CCMP ANY. !NC.

l l

400 VIRG:NI A AVE.. S W. WASHINGTON. O C. 20024 (202) 554 2345

J 1

30 i

1 sito.

l 2

MS. K3Hl:

It was pretty c1Cre to the 1,000 cark.

I i

3 Perhaps if you were lookina at a 2330 retirement date you O

4 migh t well be in the 1,000 persen rer square T.ile range.

i 5

ME. COLDPERG:

That is certainly a possibility.

I 6 would like to c:phasize that Tuch of the C0mmenwealth's 7 argunent today was concerned strictly with emergency i

8 planning problems, and I wculd point out that the staff is i

I

(

9 not ignoring peak populations.

The staff ic not ignoring i

l 10 hig h concentrations of population in radial sectors and the 11 oth er items tha t were monticned tod a y as a particular i

12 con cern of the Comronwealth.

That analysis will te 13 ca ref ully done as part of the emergency planning hearing, 14 which 10 s:hedulai to begin soon.

15 Those typec of consideratienc, however, are not 16 a pp ro pri ate to the issue of whether or not a Class 9 17 accident analysis should be done for the Pilgrir rite.

That 18 de te rmina tion is done by icokinc at the Eec Guide 4.7 trip 19 lev elc, something which is a screening tool that the staff 20 h a s consistently used in making itr determination as to 1

21 whether er not to do a Class 9 accident analysis.

l 22 MS. KDHL:

In that what hartened in Perryman?

23 ME. COLD 9EPS:

Ycs, I believe sc.

24 M. S. KOHL:

Eeg Guide trip levelc were tripped?

25 ME. GCLDEEFG:

Yes.

I would peint cut also that ALOERSON REPCATING CCMP ANY INC, i

400 V:AGlNI A AVE. S W, WASHINGTON, D C 20024 GC2) 554-2345

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. ~. - - - -

c1

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1 the Fe; Gaide 4.7 and its use by the staff in makinc 2 judgrents ibout vnether er not to conduct a Cla ss 9 accident 3 analysis is scnething that the Comrission is well aware of.

}

4 There is a line of direct decicions which explicitly rely on 5 the Ee; Guide 4.7 trip levele and use that as a basis for 6 den ying rotions to do Clars 9 a ccident analysis.

Under our 7 rules, the Commission has the opportunity to review those l

8 and has not disapproved of the staff's uce of Peg Guide 94.7.

10 MS. KOHL:

It has not specifically approved it 11 though, either, correct?

12 MP. GOLDEEFG:

That is correct.

It did in its 13 pclicy statenent, of course, me n tien the Ferryman case and

(

14 explici tly reccgnized that population density might be a 1

15 s pecial circumstance, and we do not argue that it is not.

16 I t clearly might be in a given case a special circumstance 17 a n d order a Class 9 accident analysis.

Eut not in this

{

18 c a s e, not wtth th e record e ha ve here.

t 19 MS. KOHL:

After the Commission issued its June 20 1990 interim poli:y statement, did the staff take any 21 special efforts to review this particular case to see if it 22 sigh t fall within the special circunstances, an exception?

23 MR. GOLDEEFG:

The staff 1ccked at all reactor

, ()

24 si tes in the count ry and co m par ed One againct another in 25 daterninin; which cites might 4 arrant a s p e ci al 10 c '<. at r

i ALCERSON AEPCR"NG CCMP ANY, 'NC, 400 VIRGIN! A AVE, S.W., WASHINGTON. O C 20024 (202) 554 2345

i 42 1 Class 9 accident analysis, and this is not ene which in the

()

2 s t a f f 's judgment req ui res a Class 9 accident analysis.

i l

3

f. 5. KOHL:

00 jou happen to know if the staff f

4 found any raser that fit within the special citcunstances a s

(

i 5 descri ed in the policy statement?

6 P. R. COLDPEFG:

I ac not certain about that.

7 Another ar unent of the Cc:ronwealth is that, of 8 course, if the sta f f 's demogrsphic analysis had been done 9 correctly, then the Peg Guide u.7 trip levels would be 10 exceeded.

The Co:nonwealth asserts that there are a number 11 of flaws ascociated with the staff's demographic analysis, 12 a nd for tha t reason the population figures are too low.

13 We hava addressed the staff's weighting of the

(

14 tra nsien t population, and I would point out again that that 15 is in accordance with the terms of Reg Guide 4.7 16 Another aspect of tne demographic analysis which 17 t h e Commonwealth attacks is the staff's inclusion of the 18 w a t er area in calrulating these avera;e population 19 d en sitiec.

Once again, I would say that this is the staff'-

20 reg ular practice, ce nsisten t practice when it locks at all 21 the sites in the country in determinin; whether or not to do l

22 a Class 9 accident analysis.

There was nothing unusual 23 about the staff's ".andling cf the water area in this case

()

24 compared wit h other cases on large water bodies.

25 The Commonwealth also suggects that the staff's j

i l

ALCERSCN REPCRTING CCMPANY, iNC, 400 VIRG;NIA AVE. S W., WASHINGTON. D C. 20024 (202) 554-2345

e 1

43 1 democraphic analysis is flawed becauca we averace out the 2 population without conciderin: hich concentrations of 3 population in certain radial sectors.

Once again, thic is 4 something that is not igncred as far ac emergency planning 5 issues and in terns of concerns tho Commonwealth has 6 expressed today.

But it is comethin; :nat is dcne by the 7 sta f f in its analycic as to whether or nct population is a 8 rea son why a Class 9 accidont analysis ought te be done.

9 Again, thic is done conciatently from one site to 10 a n o t h e r.

And I think if the Ecard reviews once again the 11 retuttal tectirony of rtaff witnesset Mant0r 3nd Soffer, 12 which addracced the flawc that have teen alleged by the I

13 C om monw ealt h in the st af f 's demographi-analysic, tt is l

0 14 clear that from a risk standpoint, ac oppoced tc a 15 con seque nces ctandpoint, this technique of averacing 16 including water area, including the total average regardless 17 o f the high concentrations in radial rectors, thic is the 18 a pp ropria t e technique with recrect to the risk that sta f f 19 u se s in determininc whether or nct to de a Clico 9 accident 20 a na lyuic.

21 MS. KOHL:

Well, in tecidin: wh=re the risk is, I

22 don ' t you necessarily have to first look at the 23 consequ encas ?

h 24 SE. GOLDEEEG:

les, and multiply that by the 1

1 25 pro bability, which is the definition of risk th.3t the staff 1

1 O

l ALCERSON REPCAT:NG COMPANY, LNC, 1

1 400 VIRG NIA AVE., S W, W ASHINGTCN. o C 20024 (202) 554-2345 I

l 44

()

1 uses.

And for an a priori analycir, not knowing at what 2 time of the yea r sn accident - tcht occur and in which 3 direction the wind will be blowing, for example, this is tho

()

4 correct technique in multiplying the probability of 5 occurrence tires the consequences.

6 hS. KCHL:

I guess I am just a little confused by 7 something you say in your brief.

It is page 27.

You say 8 tha t the nethodology was designed to address the risk, not 9 the conse;2ences.

10 t'.

GDLDEEF3:

Yes.

11 MS. KOHL:

How can you have one withcut the other 12in that sense, since you just said that risk is the product 13 o f consequenco and the probability of an event?

You cannot 14 --

15 5?. GOLDEEFG:

I t hi r. k the Comronwealth focuses 16 solely en the consequences.

And if ycu look at the example l

17 in Prcfessor Herr's te stin o ny for the Commonwealth, he gives 18 a n example where there is a high concentration in a 19 p ar ticula r sector and points cut, if you have an accident 20 a n d the wind is blowing in that direction, there will be 21 v e r y high consequences of the accident.

22 MS. {OHL:

Ec your argument is that the staff's 23 m et hodolo7y is broader and more encompassing?

24 MF. GOLDEEFG:

T '. a t is correct.

It not only lockr 25 a t the consequenc?c, but aise the pretability of wind I

(:)

l l

l ALCERSCN REPORT:NG CCMP ANY. tNC.

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400 VIRGIN!A A'v E, S.V., WAS ANGTON. D C 20024 (202) 554 2345

US 1 direction, for exsaple.

And not anowin: teforehand which

(])

2 2.t z % ion the vini will be blowing in, it is equally 3 probable the wind will be bleving in any direction.

As 4 opposed to emergency planning proble:c, when we have to 5 consider tne possibility that there will be an accident when 6 there is a peak Population and the wind will be blowing i

7 towards a high concentration of population, we do not do 8 tha t analysis with respect to an a priori 1cok at the site 9 in deternininc which ones are special, which ones require 10 special attention.

11 That is the issue that is really raised by the 12 Com monwe alt h 's brief with rerrect te population tatters in 13 t h e interi: policy statenent.

And the staff's treatment of l

O v

14 this case was concictent with its treatment of all caces, I

l 15 a n d was strictly in accordance with Foc Guide u.7.

1 l

16 DE. EUCK:

Do you factor in the windrese data into l

17 you r probability or do you assune thera is an aqual chance 18 o f the wind blowing in any direction at that particular 19 t i t e, that particular time of an accident?

20 2.

ODLD3EEG:

I think we make the arsumption 21 there is a7 equal probability.

Eut in fact that assumption 22 is supported by the re cor d in this case.

There was a look 23 a t the meteorolepiral conditions and it was determined tha t,

()

24 f or example, the aind blews enshcre ateut 50 percent of the 25 tim e and offshore aboct 50 percent of the tira.

And so for O

(

ALCE.RSoN REPCRiiNG COMPANY, INC.

i 400 V;AGIN!A A%E., S W., WASHINGTON. D C. 20024 (202) 554-2345

US 1 example, inciccion o f the water area in our averacing 2 techniques certainly is appropriate in this case tased on 3 the meteorological data.

O t

I 4

DE. EUCK:

All right, thank you.

i I

5 MP. GOLDEEFG:

I have no further renacks, unless 6

• ae Ecard has other questions they wish to ask.

t 7

CHAIFMAN MC0FE What is the schedule for the

(

8 emergency plannin; hearing?

l 9

MP. GOLOPEEG:

We are scheduled to begin the 10 eme rgency plannin; meetin; on Octoher luth.

11 CHAIEMAN MOOPE:

Any projections on when -- would 12 you care to take a guess when it all will te concluded?

13 MF. GOLDEEFG:

We are also scheduled to he;in 14 hea rings on !?.I-2 issues on Cctober 27th.

I think the

' ill be 15 assumption is the emergency planning hearin; 16 a pp roxina tely that length of time, a week and a half or 17 t w o.

And it is hard to specula te en the TMI issues since we 18 d o no t have contentions yet.

I c'nnot say how long a 19 hea rin; that ni;ht be.

20 CHAIEMAN MOORE:

All right, thank you.

21 MB. GOLDEERG:

Thank you.

22 CHAIFMAN MOOFE:

Mr. Wri;ht, any rebuttal?

23 ME. WEIGHT:

No, I do not, r. Chairran.

l 24 C H A I F A N MCCFE The Board will t ak e the case 25 u n t er advisement.

We stand ad:

rned.

l 0 i

1 i

ALOERSGN REPORTING CCMPANY, INC.

ADO vlRGINIA AVE, S W. WASHINGTON. O C. 20024 (202) 554 2345

.___m._

I I

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1 (Whereupon, at 10:27 a.n.,

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2 a d journed. )

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I ALCERSON REPCRTl?4G COMP Af4Y. NC.

400 ViRGlNI A AVE., S W. W ASHINGTON. C C. 20024 (202) 554-2345 l

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