ML20237G808
| ML20237G808 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 06/18/1987 |
| From: | SUFFOLK COUNTY, NY |
| To: | Atomic Safety and Licensing Board Panel |
| References | |
| OL-5-I-SC-110, NUDOCS 8709020418 | |
| Download: ML20237G808 (6) | |
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W D S 2 - H0 June 1, 1987 87 AUG 25 A9:23 UNITED STATES OF AMERICA
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NUCLEAR REGULATORY COMMISSION ijacr Bffore the Atomic Safety and Licensino Board
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In the Matter of
)
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LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322-OL-5
)
(EP Exercise)
(Shoreham Nuclear Power Station,
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Unit 1)
)
)
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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.
l Q.
What is the purpose of this testimony?
i 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 insupportable.
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s 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 ef fect that particular exercise objective:s had importance
" values" or weights.
As part of this weighting, Dr. Hockert I
testified further that the importance of one objective 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.
See, for exaraple, 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 l
objectives.
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Q.
Why do you believe that Dr. Hockert's conclusion is i
insupportable?
j A.
The weights which appear in Dr. Hockert's analysis are derived from people making judgments.
For the purpose of this i
testimony, I assume that Dr. Hockert has in fact-followed 2-
l-s properly the procedures of Dr. Saaty in distilling these opinions.
But Dr. Hockert goes much too far in subscribing to the idea that f
the weights derived in the IEAL Report have some real meaning.
The Saaty methodology merely maps the perceptions of the subjects ir.to a set of numbers.
This " perception space" may or may not correspond to any physical reality.
If the perceptions deal with i
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 realit / against which to correlate results -- such as i
the topics investigated in the IEAL Report where people are asked to make iudaments about relative impo:tance of exercise objectives -- there is no means to ascribe real weights to particular topics (or objectives).
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Dr. Hockert's analysis appears to do an adequate job of mapping out the perceptual space in which his experts are 1
working.
It does no more than thi!;.
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 l
objectives.1 Is there a corresponding physical reality?
No.
Is l
1 In this regard, I note in reviewing the transcript that FEMA l
personnel in draf t GM EK-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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r it true that an objective with weight.10 is twice as important as an objective with weight.05?
Only in the perceptual space of 1
the persons chosen for this survey; not in any real sense.
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Accordingly, the statements by Dr. Hockert in his testimony about j
1 particular objectives substituting for other objectives -- and j
1 the similar discussion by Dr. Hockert to the effect that the
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Shoreham exercise tested Idepending on how much credit is given l
for disputed test areas) between 77 and 85 percent of the total impcrtance of the standard objectives (Tr. 6148, gt sec.) -- is not supportable on the basis of the statistical and analytical tools used in the Hockert analyses.
The Saaty techniques do not 1
l permit any such conclusions to be drawn on the basis of the j
judgmental samples used by Dr. Hockert.
Thus, the final step in the Hockert analysis -- his idea that objectives are somehow funcibl.g -- should be accorded no weight by the Board, as this idea is unsupported by the techniques on which Dr. Hockert has constructed his analysis.
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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 i
best of our knowledge) which would assist us in deciding how well judgmental data l
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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Chance fluctuations in opinions certainly occur, but the method does not assess the magnitude of these fluctuations.
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