ML20235F222
| ML20235F222 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 07/08/1987 |
| From: | George Minor, Sholly S SUFFOLK COUNTY, NY |
| To: | |
| References | |
| OL-3-I-SC-014, OL-3-I-SC-14, NUDOCS 8709280463 | |
| Download: ML20235F222 (12) | |
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In the Matter of
)
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LONC ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3 l
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(Emergency Planning)
(shoreham Nuclear Power Station,
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l (Unit 1)
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J REBUYTAL TESTIMONY OF GREGORY C. MINOR AND STEVEN C.
SHOLLY I
ON BEHALF OF SUFFOLK COUNTY I
I REGARDING LILCO'S RECEPTION CENTERS (ADDRESSING TESTIMONY OF LEWIS G.
HULMAN)
May 27, 1987 8709280463 870708 PDR ADOCK 05000322 O
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UNITED STATES OF AMERICA NUCLEAR HEGULATORY CCHMISSION l
Helgfr e. t h q_ Atom i c SMg ty_a n d L i_qe n s i n<LJaaI_(1 l
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In the Matter of
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l LONG ISLAND LIGHTING COMPANY
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Docket No. 50-322-OL-3 j
)
(Emergency Planning) l (Shoreham Nuclear Power Station,
)
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(Unit 1)
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TESTIMONY OF GREGORY C. MINOR AND STEVEN C. SHOLLY ON BEHALF OF SUFFOLK COUNTY REGARDING LILCO'S RECEPTION CENTERS (ADDRESSING TESTIMONY OF)
L EE_IJ_G _. HULMAN I.
IDENTIFICATION OF._.NITNESSES Q:
Please state your names and positions.
A (Minor)
My name is Gregory C. Minor.
I am Vice President of MHB Technical Associates of San Jose, California, a
consulting firm specializing in energy related issues.
A:
(Sholly)
My name is Steven C.
Sholly.
I am a consul-tant with MHB Technical Associates of San Jose, California.
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a 0:
Ifave you previously testified in this proceeding?
A:
(Minor)(Sholly)
Yes.
Our testimony was part of the testimony of Stephen Cole, Susan C. Saegart, James H. Johnson, Jr., David Harris, Martin Mayer, Gregory C. Minor and Steven Sholly on behalf of Suf folk County Regarding LILCO's Reception Centers (Planning 3 asis) (April 13, 1987).
Descriptions of our qualifications and copies of our vita may be found in the Direct Testimony of Stephen Cole at al Regarding LILCO's Reception Centers (Planning Basis).
II.
QV ERVJ_E'd 0:
What is the purpose of this testimony?
A:
(Minor) (Sholly)
This testimony is provided in rebut-tal to the testimony submitted in this proceeding by Lewis G.
Hulman of the U.S. Nuclear Regulatory Commission on April 13, 1987 ("the Hulman testimony").
Mr. Hulman's testimony estimates the conditional probability of the number of people within the 10-mile Errergency Planning Zone (EPZ) who could be within the plume of an accidental release of radioactivity from Shoteham.
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Re refers to this evaluation as a " footprint assessment."
FN i ma n restimony at 1.
To make this footprint assessment, Hulman 1
uses t-ht ee set.s of calculations which he labels as " Cases" 1
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y through 3.
Hulman Testimony at 5-7.
Mr. HulmanLasserts that these three Cases "show'the range'of the number of people who could be in the plume in the event of an accident" at Shoreham.
Hulman Testimony at 9.
Based on his calculations, Mr. Hulman 1
concludes that "the planning basis 20% wouldLbe a conservative L
estimate of the number of people who might be within a plume."
Hulman Testimony at 9.
Mr. Hulman's calculations of the number of people that-might be expected to be exposed to the plume are not accurate, because he uses unrealistic assumptions and the three Cases.he postulates generate calculations which'are misleading.
.Indeed, Cases 1 and 3 are so flawed that they should be totally. ignored, and Case 2 needs substantial modifications to present a realistic estimate of the number of people who may be exposed to a plume: in l
j the event of a Shoreham accident.
l III. THE HULMAN_ ANALYSIS IS FLAWED Q:
As a general matter, what are the unrealistic assump-tions in Mr. Hulman's approach?
A.
(Minur) (Sholly)
It is our view that several factors l
r.end to be taken into account which have not been addresced by 1
Mr. Hu3 man's calculations.
First, Mr. Hulman uses a straight-line Gaussian acdel which fails to account for the fact that~ wind
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- e, shif t is very likely during any Shoreham accident.
As we testi-fled'in our direct testimony, LILCO's environmental report indi-cates that winds are persistent in one direction for periods of six hours.or longer only about 14% of'the time.
This means that changes in the wind direction are likely to occur over the period of release following'an accident at Shoreham.
Given that a pos-
-tulated' release of radioactivity is a stochastic phenomenon, it is clear that there is a substantial chance of one or more wind MX direction changes over any given.Loer-hour period.
This could greatly increase the number of people exposed to the plume.
l Mr. Hulman's second unrealistic assumption is his failure to account for precipitation.
Precipitation must be considered because. it has an impact on dose levels at dif ferent distances from the plant, as compared with the no precipitation cases.
Third, Mr. Hulman also fails to include consideration of scenarios involving evacuation during a release.
Such scenarios are significant because an ill-timed evacuation could significantly increase the number of people potentially contaminated by the plume.
As we testified in our direct testimony, the location of the reception centers West of the EPZ increases the likelihood that evacuation might increase exposute t o the plume for releases in certain directions (e.g. Southwest).
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Finally, Mr. Hulman states that his data shows that 46,000 l
people, or 20% of the EPZ population, is a conservative estimate for the number of people who would be exposed to plume.
This
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i statement is totally arbitrary and is not explained.
It appears, however, to represent roughly a 90 percentile criterion.
Even using Hulman's flawed assumptions and the resulting unrealistically low estimates of population exposure, it is equally possible to conclude that a 95 percentile or a 98 I
l percentile criterion represents a conservative estimate of the
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nu.mber of people who would be exposed to a plume.
Based on Mr.
I Hulman's curves this would correspond to 60,000 to 100,000 people who would potentially require monitoring.
i Q:
Please identify what you consider to be the deficien-cies in each of the cases Mr. Hulman presents.
Calg No,_1 l
l A:
(Minor) (Sholly)
For Case No.
1, Mr. Hulman assumed a narrowed plume which moves in a straight line and never achieves core than 3,000 meters in width even as it moves out to a 10 mile distance.
The failure to account for plume expansion makes this I
scenario highly unrealistic.
Coupled with the high probability of wind shifts during a Shoreham accident, Case No. 1 grossly i
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i underestimates the potential number of individuals who could be
.I within the plume.
Nevertheless, Mr. Hulman deems this calcula-j tion conservative on two grounds.
First, Mr. Hulman contends Case No. 1 is conservative because a narrow plume concentrates the potent.a1 exposure and therefore increases the dose which people would receive.
1 However, an analysis of dosage is ir relevant to the purpose of his testimony, which purports to be assessing the likely number of people who would be exposed to the plume -- not the maximum dosage.
Indeed, to the extent Mr. Hulman's testimony is relevant
/t must to analyzing the adequacy of LILCO's reception centersj Cocus on how many people may have been in or near the plume's path -- not how high their doses would be.1/
ll Hulman's second argument is that conservatism is obtained in Case No. 1.by adding to his weighted population assumptions the
" number of people out to 2 miles in all directions not under the pluce."
Hulman Testimony at 6.
The addition of the people with-i in the 2 mile EPZ is a relatively insignificant addition because they represent only 6% of the population in the 10 mile EP2.
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benMr.
Hu an acknowledges that the narrow plume assumption rep r esents NRC staf f practice for calculations for design basis
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accidents.
Hulman Testimony at 5.
The purpose of design basis accident calculations is to conservatively estimate dosq, not to 1
est icate the numbe r of people exposed, j
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Accordingly, the calculation's presented in Case No. 1 do not represent a conservative estimate of the number.of people who might be exposed to a Shoreham plume.
In fact, it represents a non-conservative estimate of the numbers involved and should therefore not be used in assessing a planning basis number.
B.
Ca s e_,,,N_o_._2 Q:
Please describe the deficiencies in Hulman Case No.
1 1
2.
1 A:
Case No. 2 in Mr. Hu' man's analysis is similar to Case No.
1, but it allowed the plume to expand as it moves away f rom the plant.
The plume thus becomes wider than it did in the Case No. 1 scenario, where plume width was artificially restrained.
1 Although this part of the case is more realistic, Mr. Hulman fails to account for other factors which are necessary for a realistic estimate.
In particular, the key factor not accounted for is that the wind direction on Long Island is likely to change.
Thus, Mr. Hulman's calculations assume that the plume-travels in a straight line (it does not account for treandering or l
1 wind shif t), and his calculations also assume a lack of rain.
Accordingly, Case No. 2 does not account for the exposure of more than one sector of the EPZ.
As we stated in our direct l
testimony, wind direction changes are more likely to occur ihan
{
not.
Thus, during the course of the development of an accident and t he releane and movement of the plume away from the plant,
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there is likely to be a wind shift.
This would cause the plume i
to meander across more than one sector which would involve a much greater portion of the population.
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Hul:ran stated that he believed he compensated for this f ail-ure to include likely wind shifts by (1) including within :he i
exposed population all those within 2 miles of the plant and (2) ignoring emergency response.
(Hulman Testimony at 8.)
Mr.
Hulman provides no basis for this assertion, and we believe these i
two factors do not ccmpensate for failure to include wind shifts.
l As was indicated' before, the pooulation within 2 miles of the plant is only 6% of the total EPZ population, so this adds little or no conservatism to the calculations.
Moreover, wind shifts are likely to occur outside this two mile zone, which is the area in which the vast majority (94%) of the population resides.
As to the failure to account for emergency response providing a 1
source of conservatism, we indicated in our direct-testimony that emergency response could conceivably increase the number of l
people exp9 sed to the plume.
Failure to account for emergency response therefore provides no conservation to Hulman's calculations.
91-Case No. 1 j
0:
Please r tate your under standing of case No. 3 as prc~
sented by Mr. Hulran.
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A:
In all three cases, Mr. Hulman divided the population into sixteen sectors.
Case No. 3 presents the same scenario as Case No. 1, except that Mr. Hulman weighted each of his 16 population sectors by the percentage of time the wind would be expected to blow in that direction.
In essence, Case No. 3 is little more than another way of looking at the site population distribution by simply weighting the population distributed by wind rose probabilities.
This effort is fundamentally flawed l
because underlying this calculation is an assumption that the l
l plume will never occupy more than one of the sixteen compass sectors.
This is an unproven assumption and one which fails to account for wind direction changes during the duration of the l
release.
Therefore, it is our belief that Case 3's. calculation should be totally ignored as misleading and not useful for the l
l purposes of determining the number of people exposed to the l
plume.
!V.
CONCLUSION Q:
What does your testimony conclude?
A:
We conclude that none of Mr. Hulman's cases is repre-sentative of the consequences of an a t at Shoreham and l
therefore should not be relied on to e number of people poten-tially exposed to a Shoreham plume. l i
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Does this conclude your rebuttal testimony?
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A:
Yes it does.
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