ML20214S077
| ML20214S077 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/01/1987 |
| From: | Simon G SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20214S063 | List: |
| References | |
| OL-5, NUDOCS 8706090123 | |
| Download: ML20214S077 (8) | |
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June 1, 1987 UNITED STATES OF APERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear. Power Station,
)
Unit 1)
)
)
REBUTTAL TESTIMONY OF GARY A.
SIMON ON CONTENTIONS EX'15/16 ON BEHALF OF SUFFOLK COUNTY Q.
Please state your name.
A.
Gary A.
Simon.
Q.
What is the purpose of this testimony?
A.
This testimony addresses certain issues raised.in the testimony of LILCO witness John Hockert.
I have reviewed Dr. Hockert's testimony on Contentions Ex 15/16 and find that one of his conclusions is unsupportable.
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Q.
Please describe the Hockert testimony to which you refer.
A.
In his prefiled testimony (particularly pages 29 and
- 30) and at the oral hearing (particularly Tr. 6148, gi ggg.),
Dr. Hockert testified that it was possible, based upon the results of the IEAL Report, to ascribe meaningful weights to particular FEMA standard exercise objectives.
From these weights, Dr. Hockert testified that conclusions could be reached to the effect that particular exercise objectivec had importance
" values" or weights.
As part of this weighting,
< 90ckert testified further that the importance of one objeevi.e with a particular weight was approximately equivalent in importance to two or more other objectives which, together, had the same value or weight as the one objective.
Sgg, for example, Dr. Hockert's
- prefiled testimony at page 30 where he states that standard FEMA Objectives 16, 17, 22, 24-28, 34, and 35 are together only as important as any one of the IEAL Report's seven most important objectives.
O.
Why do you believe that.Dr. Hockert's conclusion is l
unsupportable?
A.
The weights which appear in Dr. Hockert's analysis are derived from people making judgments.
For the purpose of this testimony, I assume that Dr. Hockert has in fact followed 4
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properly the procedures of Dr. Saaty in distilling these opinions.
But Dr.'Hockert goes much too far in subscribing to the idea that
- the weights derived in the IEAL Report have some real meaning.
The Saaty methodology merely maps the perceptions of the subjects into a set of numbers.
This " perception space" may or may not correspond to any physical reality.
If the perceptions deal with an obvious reality (such as distances between cities), then the.
weights will correspond closely to real distances, the closeness depending on the abilities of the subjects.
Where there is no physical reality against which to correlat'e results -- such as the topics investigated in the IEAL Report where people are asked to make iudaments about relative importance of exercise objectives -- there is no means to ascribe real weights to particular topics (or objectives).
Dr. Hockert's analysis appears to do an adequate job of mapping out the perceptual space in which his experts are working.
It does no more than this.
The weights identify only locations in the perceptual space of the evaluators.
This, in essence, results in an opinion poll; and different persons, if polled at the same time or at a different time, could very well reach different conclusions about the importance of particular objectives.1 Is there a corresponding physical reality?
No.
Is 1
In this regard, I note in reviewing the transcript that FEMA personnel in draft GM EV-3 have apparently ascribed significantly different weights to some of the standard objectives.
This underscores the point that the weights in the IEAL report do not correspond to any physical reality.
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it true that an objective with weight.10 is twice as important as an objective with weight.05?
Only in the perceptual space of the persons chosen for this survey; not in any real sense.
Accordingly, the statements by Dr. Hockert in his testimony about particular objectives substituting for other objectives -- and the similar discussion by Dr. Hockert to the effect that the Shoreham exercise tested (depending on how much credit is given for disputed test areas) between 77 and 85 percent of the total importance of the standard objectives (Tr. 6148, at agg.) -- is-not supportable on the basis of the statistical and analytical tools used in the Hockert analyses.
The Saaty techniques do not permit any such conclusions to be drawn on the basis of the judgmental samples used by Dr. Hockert.
Thus, the final step in the Hockert analysis -- his idea that objectives are somehow funcible -- should be accorded no weight by the Board, as this idea is unsupported by the techniques on which Dr. Hockert has constructed his analysis.
Finally, I note that there is no provision in the Saaty methodology for chance variations.
Dr. Saaty made this point clear in his 1977 work:
As yet there is no statistical theory (to the best of our knowledge) which would assist us in deciding how well judgmental data correspond to reality.2 2
- Saaty, T.L.,
"A Scaling Method for Priorities in Hierarchical Structures," 15 J. Math. Psych. 234, 247 (1977).
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-4 Chance fluctuations in opinions-certainly occur, but the method
. does not assess the magnitude of these fluctuations.
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i C0(nEirp June 1, 1987 UWC 17 JW -4 N1 :43 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION OFFK:.
E - W Before the Atomic Safety and Licensino Board 00cKEi m a a w a.
BRANCH
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of SUFFOLK COUNTY MOTION FOR LEAVE TO FILE PEBUTTAL TESTIMONY have been served on the following this 1st day of June 1987 by U.S. mail, first class, except as otherwise noted.
John H. Frye, III, Chairman
- Dr. Oscar H. Paris
- Atomic Safety and Licensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Mr. Frederick J.
Shon*
William R.
Cumming, Esq.*
Atomic Safety and Licensing Board Spence W. Perry, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C.
20555 Federal Emergency Management Agency 500 C Street, S.W.,
Room 840 Washington, D.C.
20472 i
e Anthony F. Earley,.Jr., Esq.
Joel Blau, Esq.
General Counsel Director, Utility Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175_ East Old Country Road Suite 1020 Hicksville, New York 11801 Albany, New York 12210 Ms. Elisabeth Taibbi, Clerk W. Taylor Reveley, III, Esq.**
Suffolk County Legislature Hunton & Williams Suffolk County Legislature P.O. Box 1535 Office Building 707 East Main Street Veterans Memorial Highway Richmond, Virginia 23212 Hauppauge, New York 11788 Mr. L. F. Britt Stephen B.
Latham, Esq.
Long Island Lighting Company Twomey, Latham & Shea Shoreham Nuclear Power Station 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792 Ms. Nora Bredes.
Docketing and Service Section Executive Director Office of the Secretary Shoreham Opponents Coalition U.S. Nuclear Regulatory Comm.
195 East Main Street 1717 H Street, N.W.
-Smithtown, New York 11787 Washington, D.C.
20555
-Mary M. Gundrum, Esq.
Hon. Michael A.
LoGrande New York State Department of Law Suffolk County Executive 120 Broadway, 3rd Floor H.
Lee Dennison Building Room 3-116.
Veterans Memorial Highway New York, New York 10271 Hauppauge, New York 11788 MHB Technical Associates Dr. Monroe Schneider 1723 Hamilton Avenue North Shore Committee Suite K P.O.
Box 231 San Jose, California 95125 Wading River, New York 11792 Martin Bradley Ashare, Esq.
Fabian G. Palomino, Esq.
Suffolk County Attorney Richard J.
Zahnleuter, Esq. **
Bldg. 158 North County Complex Special Counsel to the Governor Veterans Memorial Highway Executive Chamber, Rm. 229 Hauppauge, New York 11788 State Capitol Albany, New York 12224 Mr. Jay Dunkleburger Edwin J. Reis, Esq.*
New York State Energy Office U.S. Nuclear Regulatory Comm.
Agency Building 2 Office of General Counsel Empire State Plaza Washington, D.C.
20555 Albany, New York 12223 f
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David A. Brownlee, Esq.
Mr. Stuart Diamond Kirkpatrick & Lockhart Business / Financial 1500 Oliver Building NEW YORK TIMES Pittsburgh, Pennsylvania 15222 229 W.
43rd Street New York, New York 10036 M
Lawrence Coe Lanpherr KIRKPATRICK & LOCKHART 1800 M Street, N.W.
South Lobby - 9th Floor Washington, D.C.
20036-5891 By Hand (6/2)
By Federal Express (6/1)
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