ML20154H631
| ML20154H631 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 04/21/1988 |
| From: | Sholly S LONG ISLAND LIGHTING CO., MHB TECHNICAL ASSOCIATES |
| To: | |
| References | |
| CON-#288-6330 OL-3, NUDOCS 8805260013 | |
| Download: ML20154H631 (52) | |
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NUCLEAR REGULATORY CO!1 MISSION BEFORE TiiE ATOMIC SAFEI'Y AND LICENSING BOARD
. ________ _ _ _ _ _ _ _ _ _ _x In the Matter of:
Docket !!o. 50-322-OL-3 LONG ISLAND LIGliTING CO!!PANY (Emergency Planning)
(Shoreham Nuclear Power Station, Unit 1)
________x 0
DEPOSITION OF STEVEN C.
SHOLLY Washington, D.
C.
Thursday, April 21, 1988 ACE-FEDERAL REPORTERS, INC.
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Washington, D.C. 20001 (202) 347 3RX)
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1 UNITED STATES OF AMERICA 2
NUCLEAR REGULATORY COMMISSION BEFORE THE 3
ATOMIC SAFETY AND LICENSING BOARD 4
.. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 5
In the Matter of:
Docket No. 50-322-OL-3 6
LONG ISLAND LIGHTING COMPANY (Emergency Planning) 7 (Shoreham Nuclear Power Station, Unit 1) 8
- - - - - - - - - - - - - - - - -x 9
DEPOSITION OF STEVEN C.
SHOLLY 10 II Washington, D.
C.
s s-12 Thursday, April 21, 1988 13 Deposition of STEVEN C.
SHOLLY, called for examination 14 pursuant to notice of deposition, at the law offices of Hunton 15 and Williams, 2000 Pennsylvania Avenue, N.W., Conference Room 16 Two, Ninth Floor, at 11:08 a.m. before WENDY S. COX, a Notary 17 Public within and for the District of Columbia, when were present on behalf of the respective parties:
18 l
19 LEE B.
ZEUGIN, ESQ.
l DAVID S.
HARLOW, ESQ.
20 Hunton & Williams T
707 East Main Street 21 P.
O.
Box 1535 Richmond, Virginia 23212 22 On behalf of Long Island
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Lighting Company.
continued --
ACE FEDERAL REPORT ERS, INC
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APPEARANCES (Continueci) :
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RONALD R.
ROSS, ESQ.
j Kirkpatrick & Lockhart 3
i; South Lobby, Ninth Floor 1800 M Street, N.W.
4 (l Washington, D.
C.
20036-5891 li On behalf of Suffolk County.
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2 WITNESS EXAMINATION i
3 Steven C.
Sholly 1
by Mr. Zeugin 4
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6 SHOLLY DEPOSITION NUMBER IDENTIFIED i
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1 PROCEEDINGS 4
2l Whereupon, 3 fl STEVEN C. SHOLLY 4 h was called as a witness and, having first been duly sworn, 9
ii 5 h was examined and testified as follows:
3 69 EXAMINATION L
7 '-
BY MR. ZEUGIN:
i 8j Q
Good morning, Mr. Sholly.
My name is Lee Zeugin.
91 With me is David Harlow.
We are both from the law firm of 0
10 Hunton & Williams.
We ere representing.in the Ghoreham 11 h proceeding Long Island Lighting Company'.
We have called this
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12 deposition today to discuss your upcoming testimony in the 3
13 Shoreham proceeding on the realism contentions, and, more 14 j particularly, the so-called immateriality arguments that your 15 C counsel has represented to us are the areas in which you are a
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testifying about.
1 17 0 If at any time during this deposition you don't 9
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understand my question, or I have been less than clear, l
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please let me know and I will try to rephrase the question.
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L 20 ?
Let me begin by having you state your name and 0
21 h business address for the record.
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A My name is Steven C. Sho11y, MHB Technical lO i
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3, Q
Mr. Sholly, could you explain for me what is your 4
understanding of the areas you have been asked to testify 5g about in the upcoming Shoreham proceeding?
f 6
MR. ROSS:
Are you asking him what h> is 7
testifying on?
8 MR. ZEUGIN:
His understanding of the areas he is b
9 testifying about.
10,
MR. ROSS:
Is the question clear to you?
11 THE WITNESS:
I will give it.a shot.
If it's not
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12 what he is looking for, I am sure he will tell me.
Basically 4
13 we are looking at whether the difference in controlled or i
14 uncontrolled evacuation makes a difference in terms of either 15 4 reducing the amount of dose savings you get from emergency 16 response, or precludes one or more emergency response 17 i options.
l 18 BY MR. ZEUGIN:
l 19 Q
Mr. Sholly, I am sure I will get into more detail l
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20 what that general comment means, as we go on.
21 "
Let me ask you, to try to make sure I completely j
I 22 understand, I take it, then, it is your understanding you are j
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O Ih going to be testifying only on contentions 1 and 27
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A That's my understanding, yes.
1 3 jj Q
You are testifying about those two contentions 4 0 only with regard to the immateriality argument?
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A That's my understanding, yes.
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Could I ask you, and I take it you are going to be a
I 7h testifying as an expert on those contentions; is that 0
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correct?
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A Yes.
9 10 [
Q Let me ask you to briefly describe for me your i
11 understanding of LILCO's immateriality argument.
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A My understanding of it is that it's your position, l
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13 h or LILCO's position that the difference.in evacuation times 14 j between a controlled and uncontrolled evacuation is so short 15 e that the dose consequences will not be materially different.
l 16 q Q
All right.
That's the extent of your l
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understanding?
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A That's the way I understand it.
That's the way I l
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read it.
l 20 Q
The testimony you will be preparing on that issue I
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-- could you describe for me how your expertise in the areas i
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which you are going to cover may differ from those of lO L
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W 1g Mr. Minor, who is also at MHB7 2 l0 MR. ROSS:
Counsel, I want to clarify.
Are you hl 3,
asking him to describe testimony he will prepare?
- j 4l MR. ZEUGIN
I am asking him a more general 5
question.
I am just simply trying to figure out his areas of 6
expertise in responding to LILCO's immateriality argument, 7
versus those of Mr. Minor.
I am trying to figure out whether 8
their expertise is essentially identical or whether it's 9'
different.
10 MR. ROSS:
I think the way to approach this, since l i
6 11 q you are going to depose Mr. Minor, is simply to ask him about O
12 l his areas of expertise.
When Mr. Minor is here this 13 afternoon, you can ask him about his and make those x
1 14 4 determinations.
15 J MR. ZEUGIN:
I would like to have the witness tell
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me what he views as the difference between his own expertise i
17 and Mr. Minor's.
j 18 MR. ROSS:
If he is able.
19 THE WITNESS:
The area of expertise that I think I l
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22 assessment perspectives.
I think Mr. Minor's background is O
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probably broader, or his experience is broader on emergency I
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3 BY MR. ZEUGIN:
4 0
When you talk about risk assessment, are you 5
talking about the probability of accidents at the plant 6
itself?
l i
7 A
Not just the probabilities of accidents, but the l
8 entire scope of a risk assessment.
That would include the 9
probability of accidents, the timing of accidents, the l
10 containment failure modes and resulting source terms, and the l i
11 dose impacts of the source terms.
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In terms of off-site consequence?
l 13 A
Right.
l 14 Q
Mr. Sholly, when were you first contacted to i
l 15 potentially be a witness on contentions 1 and 27 I
16 A
I think I learned about it the morning of the 7th i
17 of April.
l 18 Q
At that time, were you told you were going to be a 19 witness or asked to be a witness?
20 A
Yes.
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And you agreed at that particular time?
22 A
Yes.
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Since April 7, how much time have you spent, give 2
me a rough estimate, preparing to file your testimony on 3
these issues?
4 A
Probably a day.
5 Q
Have you begun to draft any testimony yet?
6 A
Not yet.
7 Q
Could you explain for me briefly what you did in 8
that day, in particular, the documents you may have reviewed, !
9 the things you may have looked at?
10 A
I will try to remember.
I looked at the motion 11 that LILCO made for a summary judgment on contentions 1, 2 l
(1) 12 and 9, the county's response to that motion.
There were, I l
13 think, three board orders, the most recent of which was April l 14 8, that related to the contentions.
A little bit in the 15 office on the 1983 full power risk assessment.
That's all I 16 have looked at so far.
Of course the pleadings had 17 affidavits attached to them, and I have looked at those as 18 well.
19 Q
So, for example, you have reviewed the affidavit 20 of Mr. Minor that was attached to Suffolk County's response?
I 21 A
I have looked at it, yes.
22 Q
Before we really get into that, the more detailed
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t 11 aspects of your testimony on contingents 1 and 2, let me just l l
2 briefly cover your professional qualifications with you.
Let 3
me have marked as Sholly Exhibit 1 a statement of 4
professional qualifications that I will represent for you i
5 were attached to your earlier testimony in the Shoreham l
l 6
proceeding on reception centers, which I believe occurred in I
1 7
the early part of 1987.
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8 (Sholly Exhibit 1 identified.)
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BY MR. ZEUGIN:
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10 Q
I would ask you if these are, in fact, your i
11 statement of professional qualifications?
12 A
Yes.
Of course, since early 1987, there might be l
13 a few additions to it.
This is the document I am familiar 14 with.
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15 0
Could I ask you to briefly roview it and tell me 16 any new information that you may add to this statemennt 17 A
There would be some specific pieces of testimony 18 that would have been filed on one or more rate cases.
19 0
Could you tell me what proceedings those may have 20 been in?
21 A
I am trying to think, Beaver Valley unit 2, the 22 case before the Pennsylvania Public Utilities Commission, O
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filed testimony on behalf of the consumer advocates office 2[
there.
In addition, another MHB employee and myself prepared l
ll some detailed comments on NUREG-1150, that's the NRC's 3[N 4?
reactor risk reference document, and that was done for the 5]
Illinois Department of Nuclear Safety.
6 Oh, yes, there's also testimony in the Diablo 7
Canyon rate case on quality assurance.
This was filed by 8
myself and Mr. Hubbard.
We have also filed comments on 9o behalf of Suffolk County on, I think, NUREG-0956, source term I
10 l report, and on NUREG-10 -- I forget the number -
u 79, which 11 was on the containment loads working group report.
Those are O
12 the principal ones.
There may be one or two others.
But 13 without having my updated list, it's hard to say.
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14 Q
That's fine, I didn't mean it as a quiz question.
15 u Mr. Sholly, have you prepared a more updated statement of 16 professional qualifications than the one I have had marked as I
17 '
Sholly Exhibit 1?
l 18 A
Yea, I think one has been prepared, in fact, i
l 19 relatively recently.
20 MR. ZEUGIN:
Mr. Ross, I am not aware we have 21 f that, in which case I would request we be sent the most 22 updated version of Mr. Sholly's statement of professional O
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i li 2h MR. ROSS:
I will go back and check our files.
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3f MR. ZEUGIN:
All right.
l 4t BY MR. ZEUGIN:
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Mr. Sholly, as I understand it, you have only I
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testified once previously in tho Shoreham proceeding; is that il i
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A I think that's correct, yes.
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Q And that involved the reception center lasues; i
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A That was basically an assessment of how many l
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I 14 L Q
Mr. Sholly, let me ask you to identify for me what 15 i aspects of your educational background you feel particularly 1,
16 R qualify you to present expert testimony on contentions 1 and 17 2?
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Brief educational background is that of a broad l
19 7 background in science and interdisciplinary work, integrating \\
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I think that's the gist of it.
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No particular educational training either in h
2 nuclear engineering or radiation health physics?
k 3y A
Nothing that specific.
There was some course work a
4 1 in college, I really did get into aspects of radio-ecology, 5y but I am not an engineer.
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Q Or a health physicist?
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A Or a health physicist.
8' Q
All right.
Either in your preparation to date or 9
the preparation that you envision between now and the date in 10 which you file your written testimony on contentions 1 and 2, l
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do you plan to look at any of the, I guess, 35 publications l
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that you have listed in your statement of professional 13,
qualifications as perhaps relevant background that you may 14 '
want to review before preparing that testimony?
15 A
I will certainly be looking at the reports I 16 prepared on the source term work, NUREG-0956, 1079 and 1150 17,
reviews.
3 18 9 Q
Could you give me the specific numbers of those i
19 [
reviews?
I' 20 L A
Well, the 1079 and 1150 were two that I mentioned 21 ;
orally here this morning.
22 Q
All right.
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The other items would be Number 32; I would also il i
2D be looking at my Indian Point testimony.
This would be items 30 17, 18 and 19.
I think that's it.
4 4
Q Could I briefly have you describe for me in a
5 $
particular why it is that you have selected those six things t
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as things you would like to review before preparing your l
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8 A
Well, it's previous testimony or reports I have c
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written in the general area dealing with risk assessment that 10 h. may or may not be applicable here.
I doubt that the Indian l
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at it.
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4 13 1 Q
That's fine.
14 h A
That's for a different type of plant.
Indian 15 Point is a pressurized water reactor, and of course Shoreham 16 4 is a boil water reactor.
There may be something in there i.
17 that may be useful to review.
18 Q
Let me ask you one last general question about l
19 your resume, and then I will proceed on.
l 20 I had noticed that you have presented testimony in 21 '
a number of NRC proceedings.
Is it fair to characterize your,
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prior testimony as, without ex sption, being testimony that i O i
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1 was not presented in support of an applicant's license 2
application for that plant?
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A Well, you should understand the difference between I' 4
the two proceedings.
Catawba was a licensing proceeding.
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5 The testimony I presented there was to expand the emergency i
I 6
planning zone to encompass, I think it was Charlotte, North l
7 Carolina.
l The Indian Point proceeding was somewhat unique in l 8
9 that both of the units under question there were already i
10 licensed and had operated for several years, and that the 1
11 case grew out of a shutdown petition filed by the Union of l
O 12 Concerned Scientists, and I think probably several other j
t 13 groups.
That was the basic issues there were emergency l
i 14 planning, risk assessment.
i 15 Well, the testimony I prepared was to require 16 installation of a filtered vented containment system for the 17 plants, and to make revisions to the risk assessment that had 18 been prepared for the licensees by their consultante to take 19 into account some factors that hadn't been considered.
20 0
I take it those revisions of the risk assessments 21 would basically suggest that there was a higher risk from 22 operation of the plant than that predicted by the licensees' O
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N 2h A-In most cases, that's true.
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Q I take it those ure the only two other NRC i
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proceedings you have testified in other than Shoreham?
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A That's correct.
Those are the only ones I have I
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testified on, and filed testimony in Seabrook.
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Q Could you briefly describe for me that testimony li I
8) and its purpose?
6 9f A
It dealt with the emergency planning basis route l
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in NUREG-0396 and WASH-1400.
It was strictly a piece of f
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by other witnesses.
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13 Q
I take it, Mr. Sholly, that you are familiar with 14 [
both NUREG-0396 and WASH-14007 h
i 15 l' A
Yes.
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Q Do you intend to agree with the rulemaking that j
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17 g came out of those documents that essentially established f
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18 i emergency planning zones of 10 miles for plume exposure f
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19 pathway and 50 for ingestion pathway?
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i 20 g MR. ROSS:
Counsel, I am going to object to that i
21 as being irrelevant and outside the bounds of his testimony.
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You can answer, Mr. Sholly.
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A I think conceptually the rule makes sense.
It's 4,
not clear to me that it optimizes emergency response.
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5l think you are going to have -- and the WASH-1400 results tend a
6 to bear this out.
While there is a spectrum of accident 7d sequences covering very severe to very minor, the ones for 9
8; which emergency response is most relevant are for the severe 9
end of the spectrum, and in those cases the emergency 4
10 p responses may be necessary beyond the 10 milo plume zone and l
11 ;
beyond the 50 mile ingestion zone.
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of greater significance because the ingestion planning tends
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to involve one or more states, and while the planning basis i
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is limited to 50 miles, in effect you have the entire state; l
l 16 and frequently neighboring states involved.
So it would be j
i 17 easier to expand the zone of response; where with a 10-mile 18 EPZ you tend to quickly involve additional counties,
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prepared, would make things difficult for them.
o 21 1 So, I think it's more likely, in my judgment, a 4
22 larger plume zone would be justified, not specifically for l
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1 evacuation, but I think a sheltering zone ought to have been 2
considered, perhaps out to the range of 15 to 20 miles.
3 0
I take it that conclusion is based on your 4
technical -- basically your interpretation of the technical t
5 data that is presented in WASH-1400 and NUREG-0396?
l l
6 A
Yes, among other things, yes, j
7 Q
Mr. Sholly, in your prior work on the Shoreham 8
proceeding, could you briefly describe for me any Shoreham i
9 specific documents you may have reviewed?
And by this 10 question, I really mean technical documents, things like risk 11 assessments that may have been prepared, evacuation time
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I 12 estimates, emergency plan, i
13 A
I think the only Shoreham specific document I 14 would have looked at would have been the 1983 risk assessment 15 study.
16 0
You have never looked at any of the evacuation 17 time estimates that have been prepared?
18 A
Not the studies.
Mr. Lieberman's affidavit 19 summarized two different sets of estimates.
All that was 20 there was some summary data and some information as to how 21 they were prepared.
But I never looked in detail at the time 22 evacuation estimate studies.
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With regard to the Shoreham '83 risk assessment,
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0 2 !i could you give me some feel of how much time you spent il 3 (i examining that particular set of documents?
4q MR. ROSS:
Counsel, are you asking him how much-e r
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time he spent in preparation for this, or are you asking him i
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6 6 y how much time he spent on this document?
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MR. ZEUGIN:
Ever.
I am just trying to find out f
11 80 how familiar he is with the document.
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THE WITNESS:
At least several weeks.
Somewhere r
10 ij between a month or two, at various times, not all at once.
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BY MR. ZEUGIN:
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Q Have you reviewed any of the more recent risk t
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13 j' assessments that have been done for the Shoreham plant; in j
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14 L particular, have you reviewed the risk assessments that have I
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been prepared for operation of 25 percent power?
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I have read them.
I have not spent a great deal t
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of time with them.
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Could you roughly approximate how much time you i
19,
may have spent with him?
i 20 MR. ROSS:
You are not required to speculate.
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THE WITNESS:
It would be in the order of days, fi l
22 How many, I am not sure.
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1 BY MR. ZEUGIN:
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Q Have you looked at any other risk assessments that l 3
you can remember for the Shoreham plant?
4 A
There is a document prepared for IDCOR that 5
summarizes the review of their individual plant examination, 6
IPE, and just within the last few days, I have received the
}
7 summary report of reassessments of risk at 100 percent power f
8 with and without the proposc(1 settlement containment system.
9 I spent one or two hours looking at that, maybe one or two.
10 Q
Have you spent any time reviewing the Shoreham 4
11 off-site emergency plan?
12 A
Only to the extent that the emergency plan 13 implementing procedures might interface with that, with the l
14 off-site plans.
l i
15 Q
How much time would you have spent looking at the 16 off-site plan?
17 A
None.
l 18 Q
So, I take it you are not familiar at this time 19 with the manner in which protective action recommendations i
20 are made by the off-site organization?
21 MR. ROSS:
Counsel, I am willing to state for you I
22 here, Mr. Sholly is not being presented as an expert on the O
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1 procedures in the plan.
He designated the subject matter of 2
his testimony, and I think you should move on to that.
5 3[
MR. ZEUGIN:
Mr. Ross, I will conduct this 4
deposition as I see fit.
I believe it is very important as i
5 0 to whether or not he has any knowledge of how off-site 1
6i protective action recommendations are made, because it is my n
1 7y understanding that his testimony may well include testimony 8 0 concerning the fact that certain response options will be li 9 !!
excluded because of longer evacuation times.
I think, to be.
.1 10 lj able to draw any conclusions ate t that, one needs some h
11 !)
understanding of those procedures.
That's the reason for my
}
12 (
question.
ll 13 h MR. ROSS:
Ask it.
0 14 ;i THE WITNESS:
I think I remember the pending t
- l 15 ]
question.
4 16 6 BY MR. ZEUGIN:
n 17 Q
Okay.
18 A
To the extent that is cc cred in the EPIPs, I havo l l
19 looked at that; that was probably a year ago.
I don't know n
20 j to the extent to which the EPIPs may have changed since i
I!
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22 Q
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the EPIPs; or, in other words, the on-site procedures prior 2 h'lto drafting your testimony on contentions 1 and 2?
n 3]
A I may.
I don't regard that as particularly U
4]
necessary for this particular piece of testimony.
50 0
Can you explain why not?
lt 6
A Certainly.
What is important here is the general 7 ii progression of accidents at full power and the ability of
!i 8j operators and emergency technical staff to interpret the 4
9/
accident progression as it goes forward.
It's my view that 0
10 0 that ability is rather limited.
I think there's a fair 1
i i
11 [
chance they will understand what type of accident sequence
()
b 12 j they are in.
E 13 y In other words, obviously, if you lose off-site 14 power and your diesel generators all fail to start, and you s
15 1 don't have any AC power to operate systems, it's rather easy 16 to figure out that you are in a station black-out sequence.
I
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Similarly, if there's a transient of some sort, i
18 and the scram system doesn't work, there are indications in f
19 L the control room that that has happened, and they will 20 understand they are dealing with an ATWS, or an anticipated 21 $
transient without scram sequence.
22 I think it's very unlikely that you will be able I
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4 1 d to accurately predict, at the time an accident is in process, l
2y when a release is going to occur, where the release is going s
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to occur from, and how large the release might be.
As a 4
4]
result, the specific detailed procedures and mechanisms that 9
il 5j are in place to make protective action decisions, aren't
]
6j really important for this particular piece of testimony.
We 7
are only looking at the incremental effect of delay and 8h evacuation.
That's how the issue is presented, and what 9[
impact that might have on accident consequences or 10,
foreclosing other possible response options.
k 11,
Q Could you explain to me how, in your view,
()
1 12 ',
extension of total evacuation time may affect or preclude 13 '
certain responsa options?
14 A
If it's recognized or concluded that you are 15 j dealing, let's say, with an uncontrolled evacuation, and have 4
16 q a general understanding of what evacuation times might result f 17 h from that, that will certainly temper your choice of 18,
protective actions.
There are some type of accident j
i 19 d sequences that proceed rather quickly.
ATWS is one of those, :
20 where you should -- the plant operators and staff should have i i
1 l
21 a an understanding that if they are in that type of sequence, j
l 22 it can proceed rather quickly.
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If the evacuation times are significantly longer i
2 j, than the time from the start of the accident to protective li 3 f actions that were being made and the type that it takes to 4
implement that protective action, that will limit your choice 1
5[
of options.
e 6y For instance, the accident may proceed so quickly, 3
7 h or have the potential to proceed so quickly, that evacuation H
8 might be precluded because of lengthy evacuation times.
9Q That's a hypothetical example.
Now, generally, with s' vere d
10 E accidents, for areas within 10 miles of the plant, and for il 11 h those areas impacted by the plume, you are talking about
(
12 L radiation dose fields in the range of a few rem to perhaps as 13 much as 100 rem per hour depending upon the severity of the a
14 release end the weather conditions, and the terrain.
15 k It's that sort of general understanding that will 16 9 form part of the background for the testimony, and the 17 -
significance of an additional delay.
18 Q
Let me ask you to look for a second at -- I will 19 represent for you this is the affidavit that was attached to 20 Suffolk County's response to LILCO's earlier summary 21 disposition motion on contentions 1 and.2 of Mr. Minor.
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this point is making sure we have a common vocabulary with li 2 i; which to talk about risk assessments, because I know it gets b,,
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i 4 Il I would particularly have you look at item 3 of P
5h Mr. Minor's affidavit.
There he talks about fast-developing n
6 accidents.
Is that a term that has some meaning to you?
7, A
Yes, it's a general term, but if you were to say a n
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fast-developing accident, to a person familiar with risk p
9j assessment, they would have an understanding of what is meant 10 there.
You are talking about accidents that would proceed y
11:j from initiation to a release in the span of a few hours.
O k
12 lJl Q
Can you be more specific, a few, two, three, four?
13 !
A Generally 1 to 10 is the area of significance.
If l
14 ;
you have a core melt accident and the containment is not ll 15 breached for a period of roughly eight hours or so, and it 16 tends to take on the order of an hour or two to get to core 17 '
melt; if the containment holds for the order of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />, you 18 do get a substantial reduction in the release by various 19 naturally proceeding mechanisms that would tend to deplete F
l 20 L the airborne source term, particularly particulate sources.
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21 l:
And so the release would tend to be less severe, and you 22 would have more time in those scenarios to do something in O
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1i the way of emergency response.
The fast-developing ones are n
d 2f the ones that proceed to a release to the environment within i'
3h a few hours.
l 4)
Q Now, in your earlier answer to me, you said that 5
some accidents proceed rather quickly.
When you said that, d
6F were you referring to a set of accidents that you would t
7 i; otherwise define as fast-breaking accidents?
H 8k A
Yes.
That's an acceptable term for defining it, h
9[
yes.
i 10 y Q
Do you have a time bound that you would put on l
I I
3 11 what is a fast-developing accident versus accidents of
()
12 4 somewhat slower development?
i 13 p A
It's more of a conceptual bound, although there 14 are times involved with it typically.
I would characterize a 3
15 fast-breaking accident as one which proceeds to a release and 16 i results in a release out through the environment in a time 17 )
period before emergency response actions might be able to be 18,
fully completed.
19 For instance, let's say you have an accident that j
i 20' proceeds to core melt in two hours or so; it takes the order I
21 I of an hour to an hour and a half to recognize the problem and 22 decide that a protective action needs to be taken, take some
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additional time to do the actual emergency alerting of the i
2W public, and it takes an additional increment then to complete 4
a 3
that action.
4 If most of your dose can be delivered in that time i5j or less, that's what I would characterize as a ti 6y fast-developing accident, generally speaking, the ones that 7h can develop much before you can get the response under way.
H b
8 il Q
Mr. Sholly, let me ask you to explain for me or d
9I give me an example of an accident in which the difference in 10 evacuation times -- and I will provide you two numbers which h
11 $
are the numbers you will 1.ud in Mr. Lieberman's affidavit --
, ()
12 '
that is a controlled evacuation that requires essentially n
l 13 1 five hours to complete, and an uncontrolled evacuation that i
14 3 requires five hours and 35 minutes to complete.
Is it your I
J 15 g testimony, or going to be your testimony, that there are a j
16 d set of accidents which are so sensitive to that time l
i 17 '
difference that they will preclude, potentially preclude l
J 18 '
evacuation as a viable protective action recommendation?
i 19,
MR. ROSS:
Counsel, I am not sure that question is I 20 all that clear.
If you want to ask him about the affidavit, 21 i perhaps it might be helpful to just provide him with a copy j
e 22 of that, so that he can see the figures that you are
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3 Q
He can just accept my figures.
Mr. Sholly, did d
4p you understand my question?
5f A
I think so.
I will try to answer.
There will be 6
some set of accident sequences where the additional 35 b
7 minutes you postulated might be quite significant.
The most il 8p easily understood example is one which that extra 35 minutes il 9j results in some portion of the evacuating public being caught 10 I in their cars in the plume.
Automobiles offer very little l!
11'l dose' reduction in terms of a sheltering factor.
If you O
12 l
conceive of a shelter factor of 1 meaning no protection, i
13 essentially standing out in the open, an automobile will give 0 75 14 tj you sheltering factor of something like E &, very little 0
15 j shelter dose reduction.
Consequently you get all of the dose n
l 16 0 that's going on at that time when you are caught in a 1
17 '
vehicle.-
18 Under that circumstance, a better response option 19 may be shelter and then relocatien from contaminated areas.
20 1 You could wind up with a lower dose that way.
h 21 )
It's well recognized in accident consequence n
22 ;
modeling, that if your population is caught in the tail of O
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1g the plume, as the plume proceeds out from the plant, that you D
2 can wind up vith substantial consequences from that, i
3 Q
Have you attempted to in any way quantify the m
li 4;
probability of accidents having the kind of time sequence f
5[
that may have that type of effect in the 35-minute span that 1
6, has been hypothesized?
7 A
I haven't yet.
I may try tha';.
The problem with 8
doing that is that there are substantial uncertainties 9
involved with the risk assessment, due to a number of 10 reasons, phenomenological factors, completeness questions n
11 4 about the suite of accident sequences that was examined, that 0"
T 12 ^
sort of thing.
They may attempt to provide some perspective h sequeces 13 of that nature, what fraction of all core melt act cate might 14 g be in that class.
15 0
If you were to prepare such an analysis, can you 16 describe for me what documents you would look at as you go in 17 doing that?
i 18 MR. ROSS:
I would object as calling for i
i 19 speculation.
But he can answer if he can, 20 THE WITNESS:
The only Shoreham specific document J
21 j that is really available is the original of the 1983 risk 22 assessment.
The full report of the update has not been made I
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It's a summary report,4well recognized by people W il sta M) 2j who have looked at risk assessments A summary report is not) V 1
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So I would look to th U
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'83 risk assessment study on Shoreham, also the more recent n
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risk assessments that NRC has done, NUREG-1150 in particular 0
6l and the related background documents for that.
O 7[
BY MR. ZEUGIN:
4 Q
And how, in particular, would you attempt to 8 [}
l 9j quantify this from those documents?
10 q MR. ROSS:
Same objection.
l 11 [y THE WITNESS:
Generally one would have to look at l
O k
12 4 the set of accident damage states, source terms, plant damage 13 bins, however you want to characterize it, and their relative h
14 l!
likelihoods, and take a look at those that would result in 15 '
the plume catching up with population before it could 16 evacuate under varying circumstances.
17 )
I would also look to NUREG-1150 for more recent 18,
perspectives on various types of containment failure modes, 19 and their likelihoods, as a more recent analysis that takes 20 g into account more factors than the original Shoreham PRA.
21 BY MR. ZEUGIN:
22 Q
Let me pursue with you a few minutes the O
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incremental effects that the length end evacuation times may i
2 ;l have on total population dose.
Could you describe for me 3
3 !l your views on that particular issue?
k A
There are two populations one needs to consider in 4,c 5h looking at the effectiveness of emergency response in B
1 6'
reducing total population dose.
It's wall recognized that i
7(
total population dose is largely -- this is for the entire 8,
population of the world, is going to be driven by emergency 0
9 ll response actions that take place beyond the 10-mile plume 0
10 [
emergency planning zone, and those actions are dealt with and 11 0 ingestion planning would involve things like interdiction of
()
0 12i!
crops before they reach market, destruction of contaminated I
13 h crops, decontamination of land, decontamination of water, 14 that sort of thing.
That's one population of concern.
h 15 Q
I take it that population is not going to be 16 affected significantly one way or the other as a result of l
t 17 longer evacuation times; is that correct?
18 A
They wouldn't be affected at all, because they are :
l I
19 1 not in the area which is being evacuated.
20 Q
All right.
21 A
And the type of exposure and mode of exposure you 22 are concerned with there are more chronic long-term i
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The area within the emergency planning zone, and P
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perhaps somewhat outside it is an area of concern for acute h
3h exposures, early exposures that might result in various j
4 ij health effects, radiation injuries and that sort of thing.
5 That is the population for which sheltering, relocation, l,
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6" evacuation are at issue.
That's the population for which the 7'
ef fectiveness of those actions can be evaluated.
I mean, 1
8]
that dichotomy is recognized by the emergency planning rule U
9j and the underlying technical basis as well.
J 10 Q
As part of your testimony on contentions 1 and 2, 1
11.i do you expect to quantify the potential dif ference in dose
(
12 '
that may result to that second population you described for 13i me as a result of the lengthened evacuation times?
14 g MR. ROSS:
I am going to object to that question.
q Again, you are asking for speculation.
You are entitled to 15 16 "
ask him what he knows.
We are not going to get into 17 discussions of future testimony that he may or may not i
18,
present.
19 MR. ZEUGIN:
Are you instructing the witness not l
I l
20 to answer?
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21 MR. ROSS:
No.
He can answer the question.
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22 THE WITNESS:
The questi.1n loses me at the
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Could you repeat it.
2 ll BY MR. ZEUGIN:
3 [!
Q Yes.
Let me try again.
l 4 lI Do you envision attempting to quantify the b
il 5p increase in population dose that may occur to the second 3
6 [i population you have described for me that would be affected
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n I?
8 li MR. ROSS:
I am not sure I understand the question 9i now.
i 10 MR. ZEUGIN:
If you would let me complete the
!i 11 l
question.
It's really up to your witness to decide whether
()
12 or not he understands my question or not.
13 4 BY MR. ZEUGIN:
14 Q
Let me start over again.
J 15 !l Do you intend to attempt to quantify the change or 16 e increase in population dose that may result to the population J
17 j that would be affected by increases in total evacuation time?
10 A
Not very precisely, given the time that is
}
19 available and the resources available for the testimony, I I
20 think it will be possible only to provide a -- shall I say, a d
21 semiquantitative perspective on what the increased times l
22 might result in in terms of dose.
And in order to really do i
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a detailed analysis, one would have to have a set of release I
2 categories or source terms which confidently represented the 3J accident, and run comparison risk calculations at the time i
4 ;;
and compare the results.
We do not plan to do that.
5I MR. ZEUGIN:
Ron, why don't we take a break for d
6 five minutes.
I may be nearing the end of what I want to ask 7 il Mr. Sholly.
And if I could have a few minutes with my y
8L colleague, we may be able to wrap this up.
9[
(Recess.)
h 10 1 BY MR. ZEUGIN:
h 11 Q
Let's go back on the record.
I think I have just r's V
12 h a few more questions, Mr. Sholly.
Just so I am perfectly 13 clear, I take it you do not envision your testimony in l
14 contentions 1 and 2 to deal in any way with the accuracy of l
15 4 the controlled and uncontrolled evacuation time estimates 1
16 !
that currently appear in the LILCO plan?
17 A
No, I don't envision dealing with that.
l 18 '
O Let me ask you, you have described for me in some l
19 L detail this morning your views about the potential l
l 20 differences in terms of doses that may be experienced as a I
21 result of longer evacuation times, potential preclusion of 22 certain response options.
What I would like to know is l
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views and apply them to the NRC regulations to draw some kind a
3i of concl'usions about whether or not the longer evacuation 4
4 times meet those regulations or not?
l 5,
A I think I could do that.
I don't think that's the 3
j 6,
issue presented by the contentions in that part of it that we 7"
will be testifying on.
We have a limited role in responding 8!
to these two contentions.
There's going to be other pieces 9
of testimony, and we will be simply, as I.nderstand it, 1
10 C expressing a conclusion about whether or not the difference i
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11 [:
in evacuation times hypothesized by Mr. Lieberman could make O
f 12 j a material difference to the dose reduction that could be a
13 achieved by evacuation, and whether or not that difference g
14 may lead to precluding one or more response options.
I don't 1
15 think we are going to get to a regulatory compliance issue in 16 h the testimony.
17 Q
I just want to make sure, when you talked about 18 materiality, that word can have several~ meanings.
One could 19 be material in a technical sense, which I take it your l
20,
testimony, you envision your testimony to cover that 21 l particular issue, whether or not it will be material i
22 technically in terms of the increase in dose or limitation of !
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response options; is that correct?
i d
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MR. ROSS:
Counsel, perhaps you will define your ii 3
terms.
You are making some distinction.in the definition of
!I 4
materiality.
Perhaps you ought to define what you have in 5
mind.
4 6
MR. ZEUGIN:
I am just trying to understand how 7
Mr. Sholly just used that word, because he talked about it 8j materiality.
All I am really trying to figure out is whether o
9j Mr. Sholly feels expert to take his, essentially, views of I
10 '
what would happen technically as a result of longer 11 L evacuation time and apply those conclusions to the NRC's
()
~
12 h regulations.
13 MR. ROSS:
Regardless of what Mr. Sholly used as 14 technical expertise, I think that's a board determination.
f 15 :
If you would like to know what Mr. Sholly knows, why don't I
i 16 '
you ask him to tell you.
Otherwise we are wasting time on this.
17 18 MR. ZEUGIN:
I am asking him if he drew those l
19 -
conclusions.
l 20 THE WITNESS:
If I were to make that testimony, 21 yes.
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2 Q
What would be these conclusions?
3 j; MR. ROSS:
Are you asking him to draw them?
41 MR. ZEUGIN:
He said he could draw them, yes.
k, 5 ji THE WITNESS:
We are sitting here hypothesizing
- i 6k what the analysis might look like and the conclusions might d
7' look like.
I haven't done it yet.
8t BY MR. ZEUGIN:
.t il 90 0
Could you quantify for me the total dose savings 10 that you would find unacceptable from a regulatory point of e
11 y view?
)
12 A
It all gets back to the objective of emergency 3
1 3 ii planning.
The objective of emergency planning is to provide 1
14 d dose savings for a spectrum of accidents that could yield i
15 (
doses in excess of the EPA protective action guideline s
16 doses.
For whole body exposure, we are talking about a range i
17 [
of 1 to 5 rem whole body dose.
If the increase in evacuation I
18 time between controlled and uncontrolled would yield doses in 19 the range of 1 to 5 rem under the planning basis, the l
20 a objective or emergency planning, that could be characterized D
21 0 as a material difference.
22 Q
You are talking about the difference to some 3
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1 individuals, is that right, when you talk about 1 to 5 rem?
I i
2 You are nodding.
3 ll A
Yes.
Il 4h Q
Are you able to quantify, again, in terms of II 5 jj regulatory importance, the amount of response options that ll 6[
would need to be precluded, in order to not find regulatory
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7[
compliance?
il 80 MR. ROSS:
Counsel, I am going to object to the 9 j{
question as being vague.
Can you identify the regulations
(
10 i!
that you are trying to get him to respond concerning?
u 11 h MR. ZEUGIN:
I think the witness has been
(:)
1 12 h responding just fine.
He seems to understand my questions e
U 13 y very well.
If he can answer this, I would like to have him 1
P 14 g answer.
d 15 [
MR. ROSS:
If you can answer.
Do you know what 9
b 16 ll regulations he is talking about?
n 17 j THE WITNESS:
If you have a specific one in mind, 1
18 that would make answering easier.
But just generally 19 speaking, there are only a limited number of response actions j 20 c that one can take.
One can evacuate -- and here I am 4
21 q thinking of whole body exposures.
I am not concerned with e
22 thyroid, potassium iodide, that sort of thing.
One can O
ace-FEi)Ei( Ai.11El>olt liti chemical tests on wastewater streams, maintenance and operation of plant equipment, and maintenance of the collection system.
September 1976 - June 1977 Science Teacher - West Shore School District, Camo Hill, Pennsylvania Taught Earth and Space Science at ninth grade level.
Developed and im-plemented new course materials on plate tectonics, enyf ronmental geology, and space science.
Served as Assistant Coach of tha district gymnastics team. _ _ _ _ _ _
(
September 1975 - June 1976 Science Teacher - Carlisle Area School District, Carlisle, Pennsylvania Taught Earth and Space Science and Environmental Science at ninth grade level.
Developed and implemented new course materials on plate tecton-ics, environmental geology, noise pollution, water pollution, and energy.
Served as Advisor to the Science Projects Club.
EDUCATION:
B.S., Education, majors in Earth and Space Science and General Science, minor in Environmental Education, Shippensburg State College, Shippens-burg, Pennsylvania, 1975.
Graduate coursework in Land Use Planning, Shippensburg State College, Shippensburg, Pennsylvania, 1977-1978.
PUBLICATIONS:
1.
"Determining Mercalli Intensities from Newspaper Reports," Journal of Geological Education Vol. 25, 1977.
2.
A Critioue of: An Independent Assessment of Evacuation Times for Three A
Mile. Island Nuclear Power Plant, Three Mile Island Public Interest V
Resource Center, Harrisburg, Pennsylvania, January 1981.
3.
A Brief Review and Critique of the Rockland County Radiological Emergency Prepareoness Plan, Union of Concerned Scientists, prepared for Rockland County Emergency Planning Personnel and the Chairman of the County Legis-lature, Washington, D.C., August 17, 1981.
4.
The Necessity for a Prompt Public Alerting Capability in the Plume Expo-sure Pathway EPZ at Nuclear Power Plant Sites, Union of Concerned Scien-tists, Critical Mass Energy Project. Nuclear Information and Resource Service, Environmental Action, and New York Public Interest Research Group, Washington, D.C., August 27, 1931.
- 5.
"Union of Concerned Scientists, Inc., Comments on Notice of Proposed Rulemaking, Amendment to 10 CFR 50, Appendix E, Section IV.D.3," Union of Concerned Scientists, Washington, D.C., October 21, 1981.
- 6.
"The Evolution of Emergency Planning Rules," in The Indian Point Book: A Briefing on the Safety Investigation of the Indian Point Nuclear Power Plants. Anne Witte, editor, Union of Concerned Scientists (Washington, D.C.) and New York Public Interest Research Group (New York, NY),1982.
7.
"Union of Concerned Scientists Comments, Proposed Rule,10 CFR Part 50, Q
Emergency Planning and Preparedness:
Exercises, Clarification of Regula-tions, 46 F.R. 61134," Union of Concerned Scientists Washington, D.C.,
January 15, 1982. *. - - -
8.
Testimony of Robert D.
Pollard and Steven C.
Sholly before the Sub-committee on Energy and the Environment, Committee on Interior and Insular Affairs, U.S. House of Representatives, Middletown, Pennsylvania, Q
March 29, 1982, available from the Union of Concerned Scientists.
9.
"Union of Concerned Scientists Detailed Comments on Petition for Rulemak-ing by Citizen's Task Force. Emergency Planning, 10 CFR Parts 50 and 70, Docket No. PRM-50-31, 47 F.R.
12639," Union of Concerned Scientists, Wa shington, D.C., May 24, 1982.
10.
Supplements to the Testimony of Ellyn R. Weiss, Esq., General Counsel, Union of Concerned Scientists, before the Subcommittee on Energy Conservation and Power, Comittee on Energy and Commerce, U.S. House of Representatives, Union of Concerned Sciantists, Washington, D.C.,
August 16, 1982.
- 11. Testimony of Steven C. Sholly, Union of Concerned Scientists, Washington, D.C., on behalf of the New York Public Interest Research Group, Inc., be-fore the Special Comittee on Nuclear Power Safety of the Assembly of the State of New York, hearings on Legislative Oversight of the Emergency Ra-diologic Preparedness Act, Chapter 708, Laws of 1981, September 2,1982.
12.
"Comments on ' Draft Supplement to Final Environmental Statement Related to Construction and Operation of Clinch River Breeder Reactor Plant',"
Docket No.
50-537 Union of Concerned Scientists. Washington, D.C.,
September 13, 1982.
- O 13.
un4en' of Concerned Scientists Comments on ' Report to the County Commis-stoners', by the Advisory Comittee on Radiological Emergency Plan for Columbia County, Pennsylvania," Union of Concerned Scientists, Washing-ton, D.C., September 15, 1982.
14.
"Radiological Emergency Planning for Nuclear Reactor Accidents," pre-sented to Kernenergie Ontmanteld Congress, Rotterdam, The Netherlands, Union of Concerned Scientists, Washington, D.C., October 8,1982.
15.
"Nuclear Reactor Accident Consequences:
Implications for Radiological Emergency Planning," presented to the Citizen's Advisory Comittee to Re-view Rockland County's Own Nuclear Evacuation and Preparedness Plan and General Disaster Preparedness Plan, Union of Concerned Scientists, Wash-ington, D.C., November 19, 1982.
l 15.
Testimony of Steven C. Sholly before the Subcomittee on Oversight and Investigations, Committee on Interior and Insular Affairs, U.S. House of Representatives, Washington, D.C., Union of Concerned Scientists, Decem-ber 13, 1982.
17.
Testimony of Gordon R. Thomp) son and Steven C. Sholly on Commission Qu tion Two, Conte.itions 2.1(a and 2.1(d), Union of Concerned Scientists and New York Public Interest Research Group, before the U.S. Nuclear Reg-Q ulatory Commission Atomic Safety and Licensing Board, in the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket l
Nos. 50-247-SP and 50-236-SP, Decerber 28, 1982.
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- 18. Testimony of Steven C. Sholly on the Consequences of Accidents at Indian Point (Comission Question One and Board Question 1.1, Union of Concerned Scientists and New York Public Interest Research Group, before the U.S.
O "ucieer aesuietory co-issioa Atomic serety ead 'iceasias soera ia the Matter of Consolidated Edison Company of New York (Indian Point Unit 2) and the Power Authority of the State of New York (Indian Point Unit 3).
Docket Nos. 50-247-SP and 50-285-SP, February 7, 1983, as corrected February 16, 1983. *
- 2) and the Power Authority of the State of New York (Indian Point Unit 3), Docket Nos. 50-247-SP and 50-286-SP, March 22, 1983.
- 20.
"Nuclear Reactor Accidents and Accident Consequences: Planning for the Worst," Union of Concerned Scientists, Washington, D.C.,
presented at Critical Mass '83, March 26,1983.
- 21. Testimony of Steven C. Sholly on Emergency Planning and Preparedness at Commercial Nuclear Power Plants, Union of Concerned Scientists, Washing-
- ton, D.C., before the Subcomittee on Nuclear Regulation, Committee on Environment and Public Works, U.S. Senate, April 15, 1983, (with "Union of Concerned Scientists' Response to Questions for the Record from Sena-tor Alan K. Simpson," Steven C. Sholly and Michael E. Faden).
22.
"PRA:
What Can it Really Tell Us About Public Risk from Nuclear Ac-cidents?," Union of Concerned Scientists Washington, D.C., presentation to the 14th Annual Meeting, Seacoast Anti-Pollution League, May 4,1983.
23.
"Probabilistic Risk Assessment: The Impact of Uncertainties on Radi-ological Emergency Planning and Preparedness Considerations," Union of Concerned Scientists, Washington, D.C., June 28, 1983.
24.
"Response to GA0 Questions on NRC's Use of PRA." Union of Concerrad Sci-entists, Washington, D.C.,
October 6,1983, attachment to letter dated October 6,1933, from Steven C. Sholly to John E. Bagnulo (GAO, Washing-ton,D.C.).
- 25. The Imoact of "External Even,t' on Radiological Emergency Resoonse Plan-ning Considerations, Union cf doncerned Scientists, Wasnington, D.C., De-cemoer 22, 1983, attachment to letter dated December 22, 1983, from Steven C. Sholly to NRC ComLdssioner James X. Asselstine.
26.
Sizewell
'B' Public Inquiry, Proof of Evidence on: Safety and Waste Man-agement Imolications of the Sizewell
- PWR, Gordon
- Thompson, with supporting evidence by Steven Snolly, on behalf of the Town and Country Planning Association, February 1984, including Annex G,
"A review of Probabilistic Risk Analysis and its Application to the Sizewell PWR,"
O Stevea Sho'1x ead coreoa ThomPsoa-
<^usuit it-2983)- ead ^aaex o-
"Emergency Planning in the UK and the US: A Comparison," Steven Sholly and Gordon Thompson (October 24,1983).
5-
- 27. Testimony of Steven C.
Sholly on Emergency P'.anning Contention Number Eleven, Union of Concerned Scientists, Washington, D.C., on behalf of the O
Palmetto Alliance and the Carolina Environmental Study Group, before the U.S. Nuclear Regulatory Commission Atomic Safety and Licensing Board, in the Matter of Duke Power Company, et. al. (Catawba Nuclear Station, Units 1 and 2), Docket Nos. 50-413 and 50-414, April 16, 1984.
- 28.
"Risk Indicators Relevant to Assessing Nuclear Accident Liability Premi-ums," in Preliminary Reoort to the Indeoendent Advisory Committee to the NAIC Nuclear Risk Task Force, Decemoer 11, 1984, Steven C. Sholly, Union of Concerned Scientists, Washington, D.C.
29.
"Unf or, of Concerned Scientists' and Nuclear Information and Resource Ser-vice's Joint Comments on NRC's Proposal to Bar from Licensing Proceedings the Consideration of Earthquake Effects on Emergency Planning," Union of Concerned Scientists and Nuclear Information and Resource Service Wash-ington, D.C., Diane Curran and Ellyn R. Weiss (with input from Steven C.
Sholly), February 28, 1985.
- 30.
"Severe Accident Source Terms: A Presentation to the Comissioners on the Status of a Review of the NRC's Source Term Reassessment Study by the Union of Concerned Scientists," Union of Concerned Scientists, Washing-ton, D.C., April 3,1985.
- 31.
"Severe Accident Source Terms for Light Water Nuclear Power Plants: A O-Presentation to the Illinois Departtnent of Nuclear Safety on the Status of a Review of the NRC's Source Term Reassessment Study (STRS) by the Union of Concerned Scientists,"
Union of Concerned Scientists.
Washington, D.C., May 13, 1985.
- 32. The Source Term Debate: A Review of the Current Basis for Predicting Se-vere Accident Source Terms witn Soecial Emonasis on the NRC Source Term Reassessment Program (NUREG-0956), Union of Concerneo Scientists, Cam-bridge, Massacnusetts, Steven C.
Sholly and Gordon Thompson, January 1986.
33.
Direct Testimony of Dale G. Bridenbaugh, Gregory C. Minor, Lynn X. Price, and Steven C. Sholly on behalf of State of Connecticut Department of Pub-lic Utility Control, Prosecutorial Division and Division of Consumer Counsel, regarding the prudence of expenditures on Millstone Unit III.
February 18, 1986.
34.
Implications of the Chernobyl-4 Accident for Nuclear Emergency Planning for the State of New York, prepared for the State of New York Consumer Protection Board, by MHB Technical Associates, June 1986.
35.
Review of Vermont Yankee Containment Safety Study and Analysis of Containment venting Issues for the Vermont Yankee Nuclear Power Plant, prepared for New England Coalition on Nuclear Pollution, Inc., Decemoer Q
16, 1986.
Available from the U.S. Nuclear Regulatory Commission, Public Document Room, Lobby,1717 H Street, N.W., Washington, D.C.
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