ML19332D701

Affidavit of AA Kelsey.* Discusses 1989 Edition of Arbitron Radio County Coverage Rept for Essex County,Ma.Few People in Geographic Area Listen to Whav & Wlyt.W/Certificate of Svc

ML19332D701
Person / Time
Site:	Seabrook
Issue date:	11/22/1989
From:	Kelsey A ARBITRON CO.
To:
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ML19332D685	List: ML19332D684 ML19332D701
References
OL, NUDOCS 8912050139
Download: ML19332D701 (19)

Text

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-UNITED STATES OF AMERICA i

. NUCLEAR RPGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before Administrative Judges:

Ivan Smith, Chairman Dr. Richard F. Cole Dr. Kenneth A..McCollom ,

)

'In the matter of ) Docket Nos. 50-443-OL

) 50-444-OL .i PUBLIC SERVICE COMPANY -) (Off-Site. Emergency OF NEW HAMPSHIRE, ET AL. ) Planning Issues) ,

)

(Seabrook Station, Units 1 and 2) -)

) l AFFIDAVIT OF A. ANTHONY KELSEY I, A. Anthony Kelsey, being duly sworn, state as follows:

1. I am the Vice President and General Counsel of The Arbitron Company. My office is located at 142 West 57th Street, New York, New York 10019.

2. The Arbitron Company'is the leading provider of radio audience estimates studies and reports for commercial radio stations in the continental United States. As part of its tegular and ongoing business, it provides, for a fee, to

_1 censed subscribers, and others, studies and analyses estimating the relative market share of commercial radio stations in a given listening market area wnich meet " minimum reporting standards" for the tabulation of available data. All Arbitron' studies, reports, databases and analyses are based upon data collected, compiled, analyzed and projected by The Arbitron Company.

8912050139 891122 PDR ADOCK 05000443 g PDR.

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=3.- I have worked as General Counsel for The Arbitron L

Company for nearly 11 years, and have been Vice President and General Counsel since 1984. I am thoroughly familiar with the methodology that Arbitron uses to compile.and project its research data, and I am also~ familiar with the manner that such data is analyzed and expressed in its reports which are derived from raw collected data. A resum8 reflecting my professional qualifications is attached. l

4. -I have' reviewed the 1989 Edition of Arbitron's Radio I County Coverage Report containing data and audience estimates f

.for Essex County, Massachusetts. That report reflects Arbitron's professional estimate that during an average quarter I

hour between 6 A.M. and Midnight on any day of the week, for all persons over'the age of 12 years, the combined listenership of' radio stations WHAV-AM and WLYT-FM comprises less-than one ,

half of one percent (0.5%) of the 12+ persons population in j that listening area. In contrast, the combined estimated share of.listenership for WHAV, WCCM, WLYT, WCGY and WSSH, which  ;

1 comprise the Merrimack Valley Operational Area Emergency i Broadcast System ("EBS") stations that appear in that report, is over 10 times as great. It is also our research experience i'

that better than 98% of all persons listen to radio at least once a week. -

5. Based upon a fair reading of the 1989 County Coverage Study, it is my opinion that an emergency message transmitted on WHAV-AM and WLYT-FM alone would have the potential for reaching a relatively small segment of the population in that i L l

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ra'dio coverage area at any point in time. It appears from our sampling research that relatively few people in that geographic

area listen to WHAV and WLYT. Furthermore, it is conceivable that relatively few people would tune.their radios to those two-stations in the event that they heard sirens _or otherLaudible p

warnings. Based upon the data available, it appears to me that at least-ten times as many, and theoretically geometrically _

even more people would hear emergency messages if they were O transmitted simultaneously-over the combined facilities of the entire Merrimack Valley Operational Area EBS network.

-The foregoing is true and correct to the best of my knowledge and belief.

A. Anthony Ke l Sworn to and subscribed before me l this 21st day of November, 1989.

,/ mn, fr,.i:<b Notary Public l

My Commission Expires:

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V A. ANTHONY KELSEY r Attorney and Counsellor at law Residence: Office:

717 The Parkway , 845 Third Avenue  ;

Mamaroneck, New York 10513 8th Floor (914) 698-3332 New York, New York 10022 (212) 826-5000 (212) 230-0383-

• Curriculum Vitae

s .-

EXECUTIVE

SUMMARY

was recently '

Candidate has been admitted to the Bar for 15 yean andb.- -- y Of Counsel to the law firm of Oppenheimer ,

Wolff & Donnelly, a 200 attomey firm engaged in general practice with offices in 5 U.S. and 2 European locations.

Candidate is now Vice President and General Counsel of Arbitron Ratings Company, a nationwide radio, television and market research company.l 5

?

A s-CURRENT POSITION Vice President and General Counsel, The Arbitron Co rrpny : ,

1 ADDITIONAL POSITIONS Of Counsel, Oppenhet ner, WolfI & Donnelly; Assistant General Counsel,~ Control Data Corporation Member, Board of Directors, Arbitron Ratings Company Member, Board of Directors, Burke Marketing Services, Inc.

General Counsel, Assistant Secretary, ScanAmerica, Inc.

General Counsel, Magnicom Systems EDUCATION tegal - Fordham University School of law -

Received Juris Doctor Degree: June,1972 -

, College - Fordham College of Fordham University -

L Received B.A. Degree: June,1968 L

PROFESSIONAL ACCREDITATIONS .

Admitted to:

Practice: New York; February 1973 United States District Court, Southem and Eastern Districts of New York; 1973 Second Circuit Court of Appeals; 1975 Sixth Circuit Court of Appeals; 1980 United States District Court, Northern District of Califernia: 1986 i+ , _ - __ _ _

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A. ANTHONY KELSEY

,: Page 2-PROFESSIONAL EMPLOYMENT HISTORY September,1986 OPPENHEIMIR, WOLFF & DONNELLY to Dece trber,1988 !

Primarily responsible in the continuing representation of Arbitron Ratings Company (see below) with additional personal clients as folbww Sinrod Marketing Group, inca Owens Calbemetrics, Inc4 Donohue Researth and Marketing, Inca RadioTeleMail, Ine; Dial Marketing Services, Inc.; R.M. Lord & Associates, (advertising); and Automotive .

Strategy Corporation.

Engaged in the private practice of law in the areas of: audience and market research, broadcasting, adversiting, corporate law, commercial law, intellectual property law and htigation i

December,1978 ARBITRON RATINGS COMPANY to September,1986 142 West 57th Street, N.Y, N.Y.10019 l

and Dece nber 1988 to Present ,

. VICE PRESIDENT Sole internal legal resource for nationwide radio and television rating and research GENERAL COUNSEL company with annual revenues in excess of $170 Millica, having 1,000 employees in 8 BOARD OF locations.

DIRECTORS Personally responsible for all legal activities and concerns of the Company, which is a .j wholly-owned subsidiary of Control Data Corporation.

l Significant areas of legal responsibility for Arbitron included: ,

e Antitrust counseling, htigation and preventive action; e Acquisitions, divestitures, and technology investigations; e Advice and counsel regarding Communications law; e Drafting, administration and enforcement of all Subscriber IJcense Agreements and Vendor Contracts for all services and products; e Advice, claims and htigation regarding Copyright and non-subscribers

• unauthorized use of Arbitron audience estimates;

• Protection and licensing of on line and syndicated data bases:

.

• Counsel of record for, or direct supervision of, all htigation matters including methodology, policies and procedures, rating complaints, rating distortion, improper station activities, sample security and significant collection actions; e One of four members of a .*New Venture Review Board" which was chartered to review and pass upon all new technology, inventions, and business opportunities pre-sented to the Company; e Attentions to compliance with Federal Trade Commission Consent Decree and Elec-tronic Media Rating Council accreditation, including preparation and review of all of Arbitron's " Descriptions of Methodology", and all documents in which claims are l' made concerning Arbitron audience estimates; I; e Patent and Trademark counseling and advice;

• General Corporate and Personnel counseling and advice; 1

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A. ANTHONY KELSEY a- Page 3 Also September,1963 to September,19tM GENERAL COUNSEL to Magnkunt Systerns a Control Data Corporation venture engaged in the development, manufacture and marketing of computer systems for cable W franchises. Personally 4 responsible for the dissolution of the venture and the windmg up of its affairs, includmg r.ettlement with the venture's partners, customers and third pames.

GENERAL COUNSEL to ScanAnterica, inc, originally a wholly-owned subsidiary of Burke Marketing Services, Inc.

of Cincinnati, Ohio. ScanAmerica is a new technology venture of Arbitron, directed toward the creation of a national state of-the-art interactive television metering system designed to capture household and individual television viewing together with product purchase behavior.

MEMBER, Burit Marieting Semces inc, the largest supplier of Custom Survey research in the United BOARD OF States. Research includes advertising tests, product tests, usage-attitude awareness i DIRECTORS tracking studies, market definition segmentation studies and qualitative group and individual interviews. ,

January,1977 NEW YORK TELEPHONE COh0'ANY to 1095 Avenue of the Americas. N.Y, N.Y.10036 ,

< December,1978 ASSISTANT One of seven in-house trial attomeys for a self insured telephone operating utility with GENERAL COUNSEL operating revenues of $7 Billion annually. Responsible for a personal local trial caseload of 250+ cases (excludmg collection cases), together with supervision of upstate counsel. Trial of both Plaintiff's and Defendent's tort and commercial htigation; claims relating to the'-

Company's furnishing of telephone service, the Company's tanffs, directory listings and Yellow Page directory advertising; defense of no-fault arbitration claims: Workmen's Compensation appeals, tnal of general commercial and real estate litigation; insolvency counseling and htigation.

September,1971 WHirMAN & RANSOM. Esqt to 522 Fifth Avenue, N.Y N.Y.10036 December,1976 ASSOCIATE ATTORNEY with a fum of 140 attomeys. Area of specialization: Utigation and Trials. A substantial amount of time expended in the htigation of fire and casualty insurance defense and subrogation cases, especially where arson, fraud and/or false swearing were suspected.

Other areas of substantial experience include: commercial and general litigation; s bankrupey and insolvency matters; matnmonials; federal secunties htigation; arbitrations; state environmental litigation; some estate and trust, real estate and appellate practice.

PERSONAL DATA Age: 42 IIcight: 6'2*; Weight: 220 lbs. -

llealth: Good Married; one child a

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. Fieldwork Conducted 1988 t' 1989 The acertme Ceacany -

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PANEL NO. 7. - CROSS . 0; 1.- Q Okay.

2' So that you have never been in the beach areas in the 3

(.p day time for the purpose assembling information.on the basis-of -

4 which you'could' provide recommendations to the utility?

5 A (Mileti) No.

p 6 Q Bau you have been there in the evening driving 7 through, and you based your recommendation on that?

8 A (Mileti) I was there in the evening and observed 9 that most of the people I saw were young; what I observed when s

10 I was there during the day was that the population appeared 11 much more heterogeneous. i 12 Q And is that a significant fact,- that it appeared.more  ;

i 13 heterogeneous?

14 A (Mileti) It did not appear that.everyone was i n onc- 1 ;

l1 15 particular -- I don' t know that it is significant' at all, it f 16 just looked like people on the beach, which I don' t got to see j 17 very much, given that I live in Denver. .l 18 Q One last point, does it matter that the people in the 19 ~ summer months, a healthy percentage of the people in the beach 20 areas, are transient and non-resident from the perspective of 21 designing an adequate emergency information system, .tc that a 22 relevant consideration? .

23 A (Mileti) It certainly is one thing that you would 24 want to take into account in designing a good emergency warning 25' system. For example, the thing that would make visitors to an L)

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- - - =1D area different,. be they hotel or motel dwellcrb. or ocoolo on a beach, is that'they may not have had access to pec-emer'gency 2 1 3' information, for example, brochures.

4 However, that sort of information, rarely, if ever,

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5 has an effect on what people do in response to an emergency set 6 of warnings, and that would suggest, again,-that one issue' 7 warnings frequently.

8 And that is built into the emergency warning system.

3 Q So, if-I understood that testimony, the fact that the

10. transients would be relevant in that they'may not have had'the 11 pre-emergency broch,ures and information available but such' 12 information is not particularly important, in-any case, is thst 13 what you Are saying?

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'14 A (Mileti) What I -- I don' t believe that-I:said, 15 available, I said that they may not.have read it,_ prior to 16 receiving emergency warnings.

17 And then-I did suggest, which is the case, that that 18 sort of pre-emergency education or information, if you will, 19 'has not been empirically demonstrated to have an effect on what=

20 people do in response 'to subsequent emergency warnings.

21 I am not suggesting that pre-emergency education is 22 not important but suggesting that emergency warnings are very 23 important.

24 Q I am sorry, did you say, not suggesting that at is 25 not important?

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1 A (Mileti) That.is correct. I would not receramend I'-

.2 that,we g'ive.up the effort to supply people with brochures,. for 3 example.

.4 Q' In fact, you would make the recomroendat ion that - pre-5 emergency brochures and information should be disseminated, 6 i sn' t that correct?

7 A (Mileti) Yes.-

8 Q And what steps have been taken, if you know, to 9 disseminate pre-emergency information to transients on the- '

10- beaches in the EPZ? 4 11 A (Mileti) I - don' t know.

12 -Q Have you made such a recommendation?

~ 13 A (Mileti) That they hand out brochures to beach 14 goers?  !

15 Q No, I did not say'that.

16 I said pre-emergency information?

17 A (Mileti) No, nor would I suggest that they do it.

18 Q Why not?

19 A (Mileti) It is not needed in terms of getting the

• 20 public to engage in a good, emergency warning response.

21 Q- But you would recommend that, generally it is your

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22 recomrtendat ion, that such pre-emergency information be

'23 distributed 24 A (Mileti) In general, yes, to the general population 25 who lives in an EPZ.

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< H- 'i Q Dut-to'a transient population.in the CP2. vou would 2 not' recommend that it be distributed?

I 3 A- -(Mileti) I wouldLnot recommend that people be handed 4- brochures as they go onto a beach, no.

5 Q Well,-in any other form that human invention can come

'6 up with, would you recommend that pre-emergency information be IF' 7 made-available to.the transient population on.the beach?

8 A (Mileti) It in general, would not hurt, although I 9- don' t know if it_would help if signs were posted regarding 10 where' emergency information could be obtained in an actual i

11 emergency..

12 However, whether people turn to EBS stations, for 13 example, is probably more a result of the warnings that they 14 get during an emergency.

t 15 And I would recommend to this utility or anybody else 16 planning for any emergency of any sort, that the emphasic be

17. placed on adequate emergency warnings during an emergency.

18 Q .Now, I understand that is the t'ocus, one of the main-19 foci of_your testimony. -

20 But would you then recommend that pre-emergency 21 information be made available to transients or not?

22 A (Mileti) I think emergency information, such as, 23 maps, routes, that sort of thing, should be available to pooolo 24 in the EPZ in some form.

25 For example, phone books or that sort of thing, etc. l

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.1. But-I would not--hand out..~ brochures to people at they weni'.:n q: , , 2 theibeach,- no.

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. UNITED STATES OF AMERICA NUCLEAR REGULATORY-COMMISSION I fj. . , . ..f[

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U- -ATOMIC SAFETY AND LICENSING. BOARD E,

- Before:.the Administrative Judges:

. -y . Ivan'W.' Smith,-Chairman -

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Dr. Richard F. Cole "" $N,.iig # # .

Kenneth A. McCollom I "3 1 4

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In the Matter of ) Docket Nos. 50-443-OL

) 50-444-OL.

PUBLIC SERVICE COMPANY )

OF NEW HAMPSHIRE, ET & ) l

')  :

(Seabrook Station, Units 1 and 2) ) November 22, 1989 4

) JI l

q CERTIFICATE OF SERVICE .'!

i I, Leslie B. Greer, hereby certify that on November 22, 1989,.I ..

- m'ade~ service of the within INTERVENORS' MOTION TO ADD AN ADDITIONAL BASIS TO THE LATE-FILED CONTENTION, ATTACHED TO THE~ MOTION OF NOVEMBER 9, 1989 by Federal Express as indicated with (*) and by first class. mail to:

• Ivan W. Smith, Chairman *Kenneth A. McCollom i

LAtomic Safety & Licensing Board 1107'W. Knapp St.

U.S.. Nuclear Regulatory Stillwater, OK'74075 p -Commission L East, West Towers Building

• Docketing and' Service L 4350 East West Highway U.S. Nuclear Regulatory l Bethesda, MD 20814- Commission L Washington, DC 20555  ;

. *Dr. Richard F. Cole Paul McEachern, Esq.

l' Atomic Safety & Licensing Board Shaines & McEachern L U.S'. Nuclear Regulatory Commission 25 Maplewood Avenue East West Towers Building P. O. Box 360 4350 East West Highway Portsmouth, NH 03801 Bethesda, MD 20814

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• Robert R. Pierce, Esq.

• Thomas'G. Dignan, Jr. , Esq.

Atomic Safety & Licensing Board Katherine Selleck, Esq.

.U.S. Nuclear Regulatory Commission Ropes & Gray East West Towers Building One International Place 4350 East West Highway Boston, MA 02110 Bethesda, MD 20814 3 H. Joseph Flynn, Esq. *Mitzi A. Young, Esq.

Assistant General Counsel Edwin J. Reis, Esq.

Office of General Counsel U.S. Nuclear Regulatory Federal Emergency Management Commission Agency Office of the General Counsel 500=C Street, S.W. 15th Floor ,

Washington, DC 20472 11555 Rockville Pike Rockville, MD 20852

' Atomic Safety & Licensing Robert A. Backus, Esq. '

Appeal Board Backus, Meyer & Solomon U.S. Nuclear Regulatory 116 Lowell Street Commission P.O.. Box 516 Washington, DC 20555 Manchester, NH 03106 Atomic Safety & Licensing Board Jane Doughty U.S. Nuclear Regulatory Commission Seacoast Anti-Pollution League Washington, DC 20555 5 Market Street Portsmouth, NH 03801 Charles P. Graham, Esq. Barbara St. Andre, Esq.

Murphy & Graham Kopelman & Paige, P.C.

33 Low Street 77 Franklin Street I Newburyport, MA 01950 Boston, MA 02110 l Judith H. Mizner, Esq. R. Scott Hill-Whilton, Esq.

79 State Street Lagoulis, Hill-Whilton l 2nd Floor. .

& Rotondi ,

Newburyport, MA 01950 79 State Street Newburyport, MA 01950 Dianne Curran, Esq. Ashod N. Amirian, Esq.

Harmon, Curran, & Towsley 145 South Main Street Suite 430 P.O. Box 38 2001 S Street, N.W. Bradford, MA 01835 Washington, DC 20008 l

l Senator Gordon J. Humphrey Senator Gordon J. Humphrey l U.S. Senate One Eagle Square, Suite 507 Washington, DC 20510 Concord, NH 03301 (Attn: Tom Burack) (Attn: Herb Boynton) i L u l

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' John Pk. Arnold, Attorney General :Phillip Ahrens, Esq.-

Office of-the Attorney General- Assistant Attorney General 25 Capitol 1 Street-

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Department of the Attorney'

, Concord,LNH 033011 General Augusta, ME 04333 William'S. Lord. Board of Selectmen Town Hall-- Friend Street Amesbury, MA-.01913 COMMONWEALTH OF MASSACHUSETTS .

' JAMES M. SHANNON ATTORNEY GENERAL l

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$hd Lesl'ie B. Greer Assistant Attorney General -

Nuclear Safety Unit Department of the AttorneyLGeneral One Ashburton Place Boston, MA 02108-1698 (617) 727-2200 DATED:: November 22, 1989 I

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