ML20236E729

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Rebuttal Testimony of M Lindell Re Suffolk County Witnesses Misinterpretation of Author Work & Mischaracterization of Prof Opinions in Proceeding Re Emergency Planning.W/ Certificate of Svc.Related Correspondence
ML20236E729
Person / Time
Site: Shoreham File:Long Island Lighting Company icon.png
Issue date: 07/24/1987
From: Lindell M
LONG ISLAND LIGHTING CO.
To:
References
CON-#387-4109 OL-3, NUDOCS 8708030065
Download: ML20236E729 (6)


Text

l

. YN RELATED CORRE@EUN LILCO, July 24,1987 6

[qViip UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 87 JUi. 27 P3 :35

( ri Before the Atomic Safety and Licensing Board DX In the Matter of

)

)

LONG ISLAND LIGHTING COMPANY

) Docket No. 50-322-OL-3

) (Emergency Planning)

(Shoreham Nuclear Power Station,

)

Unit 1)

)

REBUTTAL TESTIMONY OF DR. MICHAEL LINDELL 1.

Q.

Please state your name and business address.

l A.

My name is Dr. Michael K. Lindell. I am an Associate Professor of Psychol-ogy at Michigan State University. I am a consultant to LILCO on human behavior in emergencies.

2.

Q.

Please briefly summarize the purpose of this rebuttal testimony.

A.

The purpose of this testimony is to respond to written and oral testimony given by Suffolk County's witnesses that misinterprets my work and mischaracterizes my professional opinions in this proceeding.

3.

Q.

Dr. Lindell, during their oral testimony, Suffolk County witness Dr. Cole stated that your Nuclear Safety article, " Protective Response to Technolog-leal Emergency: Risk Perception and Behavior Intention," is " entirely one hundred percent consistent with my work." Do you agree?

A.

No. While I have conducted surveys in my work and consider them very useful, I do not use them for the same purpose as Dr. Cole does. Dr. Cole i

has used his measures of evacuation intentions to predict how people will behave in the future. In my Nuclear Safety article I used a questionnaire to I

measure the evacuation intentions and risk perceptions of individuals l

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concerning two technological hazards. At no point in this study were data collected on an actual evacuation. Thus, these data, like Dr. Cole's, pro-vide no basis for determining whether evacuation intentions would be at all predictive of actual evacuation behavior.

1 4.

Q.

Why did you study behavioral intentions and risk perceptions?

I A.

As we stated in the introduction of our Nuclear Safety article, our main purpose in studying behavioral intentions and risk perceptions was to pro-

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vide the initial step of an approach for determining whether evacuation in-i I

tentions data collected prior to an emergency can be explained by the per-I

)

ceived characteristics of a hazard. As we stated in the conclusion of the article, we believe that the data we collected would be useful to cmergency planners not to predict how many people would evacuate but in helping the planners to understand what types of cues or characteristics of the hazard would be most shlient to local residents. By knowing what these character-istics are the planners will be more able to arouse the concern of the resi-dents for their safety and prompt them to take appropriate protective ac-tion during an actual emergency.

I 5.

Q.

Suffolk County's witnesses also state that it is improper to compare the public's response to a radiation release to other types of disaster responses, l

In suppGet of this position they cite two statements in your Nuclear Safety article that conclude that your data confirms the results of other studies in

" demonstrating how negatively radiation hazard is used." Do you agree with their use of your article for this purpose?

A.

No, I don't. While it is true that our research showed that radiation hazard is viewed quite negatively, Suffolk County's witnesses f ailed to note that the concluding sentence in this paragraph stated that radiation ar.d dioxin hazards are nonetheless viewed similarly. This result is consistent with

' data from a previous study I conducted that showed the risk of a nuclear t

i power plant to be viewed by the public as similar to those of facilities han-dling toxic chemicals. Lindell and Earle, "How Close is Close Enough: Pub-lic Perceptions of the Risks of Industrial Facilities," Risk Analysis, Vol. 3

- No. 4, pp. 245-53 (1983), This study showed the perceived risk of a nuclear j

power plant to be less than those of a toxic chemical disposal f acility.

Thus, Suffolk County's statement that radiation hazard is perceived by the public entirely differently from other hazards is incorrect.

6.

Q.

In your opinion, is your Nuclear Safety article consistent with your previous works and with your written testimony in this proceeding?

i A.

Yes, it is. There is nothing in the Nuclear Safety article that is inconsis-tent with my previous works or my written testimony in this proceeJng. It is clear from reading their written and oral testimony that Suffolk County's witnesses have been quite selective in their choice of quotations from our i

Nuclear Safety article and have used these to bolster a position that lacks 1

an adequate scientific foundation. As I have stated in my written testimo-ny and in my AIF report," Planning Concepts and Decision Criteria for Sheltering and Evacuation in a Nuclear Power Plant Emergency," evacua-tion intentions data should be interpreted cautiously.

7.

Q.

According to thr.dr oral testimony (OL-3 Hearing Transcript at 17,840),

Suffolk County's witnesses interpret your research and specifically your Nuclear Safety article as supporting their position that individuals consider personal safety as the only significant f actor to look at in making a deci-sion to evacuate. What is your opinion about this characterization of your research?

A.

While I certainly agree that the personal safety f actor tends to prompt evacuation, it is not the only f actor that must be considered when trying to understand whether or not local residents will evacuate in an actual emer-gency. Disaster research suggests that there are many other f actors which 4

____._____.-_.x______-----__U

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. will influence an individual's choice among evacuation, sheltering, informa-i tion seeking, and continuation of normal activity. For example, residents will consider such barriers to evacuation as destination, means of transpor-tation and routes to travel, financial costs such as time away from work, various social costs, fear of looters, and other disruptions of normal activi-ties. If emergency planners take these factors into consideration I believe i

that most people will comply with protective action recommendations so long as it is explained to them what they should do and why they should do it, as well as what they should not do and why they should not do it.

8.

Q.

Does this conclude your testimony?

A.

Yes.

J l

A O O f hs. I ? Y O LILCO, July >24,"1987 l

'87 JUL 27 P3 :35 crt s

DOCM s a CERTIFICATE OF SERVICE p H.4 In the Matter of LONG ISLAND LIGHTING COMPANY (Shoreham Nuclear Power Station, Unit 1)

Docket No. 50-322-OL-3 I hereby certify that copies of REBUTTAL TESTIMONY OF DR. MICHAEL LINDELL were served this date upon the following by hand delivery as indicated by one asterisk, by Federal Express and/or telecepy as indicated by two asterisks, or by first-class mail, postage prepaid.

Morton B. Margulies, Chairman

  • Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Panel Board U.S. Nuclear Regulatory Commissicn U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l

East-West Towers, Rm. 407 4350 East-West Hwy.

Atomic Safety and Licensing Bethesda, MD 20814 Board Panel U.S. Nuclear Regulatory Commission Dr. Jerry R. Kline

  • Washington, D.C. 20555 Atomic Safety and Licensing Board Richard G. Bachmann, Esq. **

U.S. Nuclear Regulatory Commission George E. Johnson, Esq.

East-West Towers, Rm. 427 U.S. Nuclear Regulatory Commission 4350 East-West Hwy.

7735 Old Georgetown Road Bethesda, MD 20814 (to mailroom)

Bethesda, MD 20814 Mr. Frederick J. Shon

  • Atomic Safety and Licensing Christopher M. McMurray, Esq. **

Board Herbert H. Brown, Esq.

U.S. Nuclear Regulatory Commission Lawrence Coe Lanpher, Esq.

East-West Towers, Rm. 430 Karla J. Letsche, Esq.

4350 East-West Hwy.

Kirkpatrick & Lockhart j

Bethesda, MD 20814 South Lobby - 9th Floor

)

1800 M Street, N.W.

{

Secretary of the Commission Washington, D.C. 20036-5891 j

Attention Docketing and Service i

Section i

U.S. Nuclear Regulatory Commission 1717 H Str&t, N.W.

Washington, D.C. 20555 j

~ New York, New York 10278 Fabian G. Palomino, Esq. **

Richard J. Zahnleuter, Esq.

Jonathan D. Feinberg, Esq.

Special Counsel to the Governor New York State Department of Executive Chamber Public Service, Staff Counsel Room 229 Three Rockefeller Plaza State Capitol Albany, New York 12223 Albany, New York 12224 Ms. Nora Bredes Mary Gundrum, Esq.

Executive Coordinator.

Assistant Attorney General Shoreham Opponents' Coalition 120 Broadway.

195 East Main Ftreet Third Floor, Room 3-116 Smithtown, New York 11787

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New York, New York 10271 Gerald C. Crotty, Esq.

Spence W. Perry, Esq. **

Counsel to the Governor William R. Cumming, Esq.

Executive Chamber -

Federal Emergency Management State Capitol l

- Agency Albany, New York 12224 500 C Street, S.W., Room 840 Washington, D.C. 20472 Martin Bradley Ashare, Esq. **

Eugene R. Kelly, Esq.

Mr. Jay Dunkleberger Suffolk County Attorney

~

New York State Energy Office H. Lee Dennison Building Agency Building 2 Veterans Memorial Highway k

Empire State Faza Hauppauge, New York 11787 Albany, New York 12223 i

Dr. Monroe Schneider Stephen B. Latham, Esq. **

North Shore Committee Twomey, Latham & Shea P.O. Box 231 33 West Second Street Wading River, NY 11792 P.O. Box 298 Riverhead, New York 11901 Mr. Philip McIntire Federal Emergency Management Agency j

26 Federal Plaza 1

kW L 4/A ay g

Hunton & Williams 707 East Main Street P.O. Box 1535 Richmond, Virginia 23212 DATED: July 24,1987

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