ML20008D468
| ML20008D468 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/23/1989 |
| From: | Paolillo J, Sikich G HAMPTON, NH, MASSACHUSETTS, COMMONWEALTH OF, NEW ENGLAND COALITION ON NUCLEAR POLLUTION, SEACOAST ANTI-POLLUTION LEAGUE |
| To: | |
| References | |
| OL-I-MAG-100, NUDOCS 9003020311 | |
| Download: ML20008D468 (91) | |
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eA3/r9 cgt,tw c UNITED STATES OF AMERICA 10 Jnl 18 - P4 05 NUCLEAR REGULATORY COMMISSION FrtCE OF SECRETARY ATOMIC SAFETY AND' LICENSING BOA CK[IlNG & SLHylCI.
BRANCH Before the Administrative Judges:
Ivan W. Smith, Chairman Dr. Richard F. Cole Kenneth A. McCollom
- (
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)
In the Matter of ) Docket Nos.' 50-443-OL
.) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)
)
(Seabrook Station, Units 1 and 2) ) April 10, 1989 )
) !
TESTIMONY OF GEARY W. SIKICH AND JOHN PAOLILLO l ON BEHALF OF ATTORNEY GENERAL JAMES M. SHANNON, l TOWN OF HAMPTON, NEW ENGLAND COALITION ON i NUCLEAR POLLUTION AND SEACOAST ANTI-POLLUTION <
LEAGUE REGARDING TOH/NECNP EX 1(a) AND (b) .,
PROCEEDINGS Q.1. Please state your name, occupation and experience.
(Sikich) My name is Geary W. Sikich. I am the .l managing director for Emergency and Environmental Advisory j l
Services for the firm of Laventhol and Horwath. I am j responsible.for their consulting services with regards to
} emergency advisory services and environmental advisory services.
(Paolillo) My name is John Paolillo. I am an investigator for the Massachusetts Attorney General's office.
I 9003020311 090523 PDR 0 ADOCK 05000443 PDR
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t I e Q.2. please summarize your testimony.
A.2. (Sikich) I will testify as an expert witness in support of Contention TOH/NECNp EX 1(a) and (b). -I will opine
, that the scope of the June 28-29, 1988 pre-license Exercise of l
the New Hampshire Radiological Emergency Response plan (plan or NHRERp) was so limited that it could not and did not yield i valid or meaningful results regarding the capability to implement the plan, procedures, or protective actions involving j New. Hampshire students and school personnel. In addition, I ;
I L will testify that the Exercise did not address the l l'
l availability, training, capability, or adequacy of performance j
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of school personnel, that the Exercise did not evaluate major
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a reNcit.A.:4 ,
portions of emergency response capabilities and responsibilities involving New Hampshire schools, as described-in the Emergency Response plan for each school, and that the l Exercise did not meet with my understanding of a " full i
,i participation" Exercise, as addressed in 10 CFR part 50,
- 1. ;
Appendix E IV.F.1.
} Finally, I will testify that FEMA _is in error in 1
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! finding that the Exercise met OBJECTIVE 19, which required a i .<
l demonstration cf the ability and resources necessary to !
implement appropriate protective actions for school children !
within the p}ume EpZ.
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(paolillo) I will testify that I conducted 1
interviews of certain New Hampshire school personnel. These interviews are contained in Attachment 9 to this testimony, and to my knowledge are true and accurate.
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[ Q. 3.. please summarize your past professional experience ]
and education. .
A.3. (Sikich) A narrative summary of my past professional
{ and educational experience has previously been filed in this proceeding. This summary, together with my curriculum vitae, are included in Attachment 1 to this testimony.
In addition, i for purposes of this testimony, I wish to highlight certain of my experiences regarding the preparation, conduct, and .
'1 evaluation of emergency Exercises for nuclear power facilities.
In 1980 and 1981, I consulted on emergency planning-g g gruW and exercise development and evacuation for Detroit Edison at the FERMI 2' ouclear power plant. I was responsible for all emergency response training for compliance with Nuclear i Regulatory Commission emergency preparedness regulations.
While at Detroit Edison, I also participated in designing the scenario for that facility's first pre-license Exercise, in consultation with utility, state, and FEMA officials. I was also involved in evaluating the performance of various facilities and response organizations in the E;:e rcise , and evaluating compliance with FEMA and NRC regulatory requirements.
Subsequently, I consulted to Texas Utilities regarding the Comanche peak nuclear power plant where I was involved with preparing the initial pre-license exercise scenario which was submitted to the Nuclear Regulatory Commission and coordinated with the Federal Emergency Management Agency
?le In assisting in the development of the Exercise
- scenario, and emergency plans and programs for this facility,
! 1 j as with others, I routinely reviewed the regulatory requirements in NUREG-0654 and the Code of Federal Regulations, l as appropriate, which describe the elements for an emergency l I
plan. For Comanche peak I was involved in evaluating the 1 management functions performed by personnel at various facilities that respond during an emergency. I evaluated such i L l aspects as off-site notifications, protective action 1 1
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recommendations and communications. i In 1985 and 1986, I was engaged as a consultant to wCG4DkW W Carolina power and Light to provide emergency planning services j
at the Shearon Harris plant. I assisted a former NRC site i' i inspector who was developing the scenario. I also oversaw '
several consultants involved in the development of pre-exercise s
scenarios and evaluation process and in preparing the )
evaluation criteria for the full participation exercise. I s 1 also performed controller / evaluator functions during the full '
l participation exercise, i 1
- In 1986, I was engaged as a consultant to Georgia power Company for the Vogtle I project, that conducted its full l scale, full participation Exercise in April of that year. My involvement included coordination with FEMA evaluators in one of the South Carolina counties, in which I acted as evaluator i
for the particular county to evaluate and review Er.ercise
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performance.
.gc 11n general, for each Exercise in which I have been.
' involved, I have regularly interacted with representatives of i
j the NRC-and FEMA, and_have acquired a working knowledge of the I
l Exercise evaluation process, procedures and criteria by which I
! the NRC and FEMA grade the Exercise. In my involvement in j i- emergency exercises, scenario development, and evaluation of exercise performance, I focused on the management function ~in i
emergency response. In this regard, I was concerned with I
1 notification and communications involving entities such as i off-site response groups, schools, and special facilities.I I l j have also evaluated the process of. protective action j decision-making, and how PARS are transmitted to the affected 1 i
- entities responsible for taking action from an off-site !
- perspective.
ggMy A.3. (Paolillo) My name is John Paolillo. I am employed t
as an Investigator for the Public Protection Bureau of the Massachusetts Attorney General's. Office. I have a B.A. in Mathematics from Boston College. After graduating in 1987, I J .
Ii was a Research Assistant for the Middlesex County ;
(Massachusetts) court system. I came to the Attorney General's t
! Office in December, 1988 and have worked'as an investigator for I
the Public Protection Bureau since that date. ,
f Q.4. Please explain the purpose of a pre-license Exercise I
! j for a nuclear power facility.
, A.4. (Sikich) In my view, the purpose of a pre-license exercise is to test the ability of the on-site and off-site organizations to adequately protect the plant personnel and the l
a A. ,
a general public under simulated emergency conditions. A pre-license exercise is designed to test the' functions and j roles of personnel who would respond in an emergency, both from l the on-site perspective and the off-site perspective, including specific groups who normally perform emergency functions, such f
as police, as well as groups that would not normally perform emeroency functions, such as school personnel. An exercise
\ should test communication linkages between those entities i
i identified in the plan to see how these entities and i
{ individuals analyze information and respond.
In addition, an exercise should measure the
{appropriatenessoftheresponseofemergencypersonnel, and ltheir-abilitytoprotectthepublicat'largeaswellasplant personnel. In my view, this opinion is consistent with 10 CFR
'Part 50, Appendix E. IV.F.1, that is cited in the Contention.
That regulation provides in part:
- 1. A full participation exercise which tests as much of i the licensee, state and local emergency plans.as is i reasonably achievable without mandatory public ~;
i participation shall be conducted for each site at which a power reactor is located for which the first operating license for that site is issued after July 13, 1982.
" Full participation" when used in conjunction with emergency preparedness exercises for a particular site l means appropriate offsite local and State authorities l and licensee personnel physically and actively take i part in testing their integrated capability to i adequately assess and respond to an accident at a l commercial nuclear power plant. " Full participation" includes testing the major observable portions of the onsite and offsite emergency plans and mobilization of i
State, local and licensee personnel and other resources in sufficient numbers to verify the
- capability to respond to the accident scenario.
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[ An exercise, therefore, must demonstrate sufficient' .
, involvement, coordination, and " play" among utility, government l
and "other resources" to meet these full participation objectives, f An Exercise also must demonstrate the ability of the i
l emergency response organization to appropriately integrate an l emergency response through such activities as communications,.
j' protective actions, emergency classifications, and activation f of off-site facilities.
The Exercise should test the major portions of each emergency response organization to demonstrate an adequate
, ability to protect plant personnel and to protect the general f public.
The Exercise should also test the major portions of the plans and emergency resources to ensure the on-site response and the off-site response are fully integrated. The flow of information and action among the response organizations ,
should be clear, well defined, easily and readily understood by all organizations that form a part of the emergency response.
l The-personnel from each emergency response organization'must )
- participate in sufficient numbers during an exercise to demonstrate that they have adequate training, can perform under 1 simulated emergency conditions, and have the capability to provide an efficient and coordinated response in an actual '
i emergency. An exercise must verify this capability to respond ,
to the Exercise scenario. l 1
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/ Q.5. Please state the purpose of your testimony.
I (Sikich, paolillo) The purpose of our testimony is A.S.
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'J to support Contention TOH/NECNP 1(a)'and (b) (Contention). A^ ,
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' copy of, the contention is included as Attachment 2.
.j (Sikich) The Contention alleges that the scope of ,
the June 28, 29, 1988 exercise for Seabrook Station did not 3 provide an evaulation of major observable portions of emergency response capabilities involving New Hampshire schools, and did not address the availability, training, capability or adequacy of performance of school personnel, who are relied on in the NHRURP to protect students in a radiological emergency. I agree with these allegations. My opinion is based upon my 3
knowledge, experience, and understanding of the purposes of a wW@MWpre-license
- i. exercise, to which I have already testified. I also reviewed school plans. contained in Attachment 5 to this a , testimony, My opinion is also consistent with my understanding of certain guidance'provided by FEMA as to the proper conduct and level of participation involving schools and school personnel in a pre-license exercise. That guidance is addressed in FEMA Guidance Memorandum EV-2 and is entitled Protective Actions for School Children.
Guidance Memorandum EV-2 provides in part:
Puroogg
{ This Guidance Memorandum (GM) is intended for Federal Officials to aid them in evaluating emergency plans and
- preparedness for school children during a radiological emergency. This guidance is also intended for State and local government officials and administrators of public and private schools, including licensed and government i supported pre-schools and day-care centers, for developing
\ emergency response plans and preparedness for protecting the health and safety of students.
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1-6 School Evacuation Considerationg ,
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. Evacuation to RelacR11Qn_Centar1 - The evacuation of school children under the continuous supervision of teachers and administrators from a school to a relocation center is.a r viable and reasonable approach when confronted with a radiological emergency. The decision to implement a ;
f i protective action recommendation to evacuate to a :
i relocation center should be tied to the nuclear power i
plant's emergency action level classification.
I j e e a Acceotance Criteria f
Requirements are set forth in FEMA (44 CFR 350.9) and NRC (10 CFR 50, Appendix E.IV.F.1-5.) rules for conducting periodic exercises and drills. Under these requirements, "
organizations with assioned responsibilities for protecting L , students are required to demonstrate through exercises l their ability to implement emergency procedures contained L in their emergency response plans. However, the public [
(e.g., school children) are not required to participate.in exercises. Further, the actual use of school vehicles is optional. The demonstration of each organization's capability to implement these measures in exercises will be
, evaluated by FEMA and other Federal officials. The <
l following functions should be demonstrated and evaluated in
,7 . exercises in which the evacuation of students is .
i necessitated by events in the exercise scenario:
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a na y d% t?w%
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- 1. Alerting'and notification of appropriate school l
officials by local emergency officials with respect to '
status of radiological emergency and need to implement l protective actions, including evacuation; L ,
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l With respect to simulating the evacuation of school
- children in an exercise, the following guidelines are i provided.
1 1 l
- 2. An exercise evaluator will interview the relevant l personnel at the EOC's, the School Superintendent's office, the School Principals' i ;
office, and the Dispatcher's office, as well as i
3 the bus driver to determine their awareness of j and preparedness for the evacuation of the school children...
n a a
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- l a
chool Superintendent 's Of fice
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/ 1. When and from whom did the superintendent receive f protective action instructions or recommendations?
What specific instructions or recommendations did the superintendent receive?
- 2. What actions did the superintendent take to implement j these instructions or recommendations? Whom did the superintendent contact and when?
j School Principal's Office 4
i 1. When and from whom did the principal receive
- protective action instructions? What specific instructions did the principal receive?
- 2. What means of communications (e.g., telephone, tone alert) were used to provide these instructions? Did this means of communication function adequately to provide accurate and timely information?
- 3. What actions did the principal take to implement these 4
instructions? Whom did the principal contact and when?
g gg@v In my opinion, GM EV-2 contemplates a level of l participation by schools and school personnel in a pre-license Exercise greater than that demonstrated during the June 28, 29, 1988 Seabrook exercise. In view of the purposes of an Exercise, I believe that level of participation i" necessary, i
l Q.6. What is your understanding of the provisions in the l
- NHRERP regarding the responsibilities of school personnel to !
respond and protect students in a radiological emergency?
A.6. From my review of certain portions of the plan, it appears that the NHRERP provides an essentially generic i
emergency checklist for each public, private, day care, and
. nursery school in the New Hampshire EPZ. These checklists are entitled Emergency Response Plans. I will refer to them as plans for the purpose of my testimony. A listing of the l schools, with estimated student populations, is also contained l 4
in Volume 4 of the NHRERP. Attachment 4. The NHRERP indicates there are 35 public schools and 78 private, daycare, and nursery schools in the New Hampshire EpZ. In the NHRERp, generally, each school is provided with the above cited emergency response plan. This plan provides a rudimentary checklist and roughly outlines responsibilities for school personnel in the particular facility to follow in an emergency to protect students. See Attachment 5.
ghyg Under the plans, for public schools, the status of emergency conditions and protective action recommendations (PARS) are generally transmitted from government officials to each of the 5 school Superintendents, who are responsible for the 5 school administrative units (SAUs) located in the New Hampshire EpZ. According to the plan, each Superintendent is l responsible for communicating with the principal of each school within the Superintendent's jurisdiction. According to the
, plan, the school principal will in turn direct teachers to i
implement protective actions and supervise students throughout the emergency response. If evacuation is ordered, the plan indicates that teachers will assemble, board, and accompany students on buses for transport out of the EpZ to designated reception centers. These emergency plans appear to contemplate that, collectively, the school personnel at each facility are
} intended to form an integrated and coordinated emergency i response, and implement pars to protect their students.
Attachment 5.
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For private, day care, and nursery schools, the Emergency Response plan for each facility generally follows the same process of protective action implementation as provided for public schools, except there are no school Superintendents for these private facilities. Communication and PAR coordination therefore appear to flow from government officials utT%tMvh4 directly to each private, day care, or nursery school.
Attachment 5.
}
Q.7. Based on your understanding of the functions and
-responsibilities of school personnel to protect students, as provided in the plans, what is your opinien concerning participation by these personnel An a pre-license Exercise?
Basedonthelevelofparticipationrequirdby
.7.
these p'ans for an actual emergency, the Exercise hould N
include participation by a sufficient number personnel from each school erStity or organization to veri y the capability of each school to cobrdinate and integra an adequate emergency (yCLUDQ response for studentis\ This woul nelude full participation by the relevant school s'uperir endents to demonstrate appropriate notification a ycommunication, as well as implementation of the otective action process.
In addi on, principals.or directors at each of the public, privat day care or nursery ' schools, located in the New Hampshi EpZ, should participate i'n the Exercise not only from th standpoint of demonstrating that they can be
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con)4cted, but also to show that they have a '61 ar !
y a
i u tanding of what is eaTh emergency g .5 M classification 5 well as how to properly coordinate the O *S C.L prot actions that are being ended.
I aseo believe a representative sample of teachers who will be implementing protective actions should participate to verify their understanding of the plan, and demonstrate their ability to carry out pars for students. I do not believe, however, that it is necessary to have school children participate in the Exercise. It is rather the emergency response personnel charged with coordinating and implementing protective actions for students who should demonstrate their ability to properly impisment their plan in an exercise.
Q.8.
gwp What is your understanding of the level of participation by school personnel from public schools, and from privat.e, day care, and nursery schools, in the June 28, 29, 1988 Seabrook Exercise in New Hampshire?
A.8. (Sikich) On this issue, I have reviewed certain responses to discovery requests prepared by the Applicants, Attachment 6, and the State of New Hampshire, Attachment 7.
Although these responses do not appear fully consistent, the l responses suggest that actual participation by EpZ school ;
! personnel was minimal for a few schools, and that most schools, and their personnel, did not participate at all in the exercise. )
l For example, both Applicants and the State of New Hampshire indicate that "no teachers participated in i demonstrating protective actions for school children during the Exercise as schools were not in session." Attachments 6, 7, at
8 e
response to Interrogatory #1. Yet the Exercise scenario ggg depicted events as if the schools were in session. (e.g.)
]ttachment10.
In addition, according to Applicants, on1 1 princ- 1 (Swazy School) out of 35 for the New H pshire EpZ public set. a, and only 1 staff member for a ay care facility (Country Kid out of 78 private, day car , or nursery schools ggg was ever contac ed during the Exercise Attachment 6, at g Response to Inter ogatory #5, and a Applicants' letter dated March 20, 1989, p.2. /
The State f New stopshire concurs with Applicants' statements,exceptthe\ t asserts that 1 additional public school (East Kingston E entary) was ectually contacted during
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the Exercise. Attachment at March 16, 1989 letter from State of New Hampshire Ip/ addition, these discovery responses suggest that
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even these' limited contacts did not generate any test of the schoo,1 plans or procedures, b e y'o n d a r e s p o n s e o f " n o s ool". Id.at Attachments 6, 7.
. In short, virtually none of the r i-e!; 1:,
ggg teachers, = cthu sch;;l perre" el employed at 113 school facilities in the New Hampshire EpZ participated in the Exercise.
nowle hnel n aaoY e1 participate in the r - to which you have alread ified? --
L . _ _ _ _
- l. A 4
.10 (Sikich) For the 78 private, day care, and nurs, pry
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school and based upon the discovery responses in Attachments
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6 and 7 t this testimony, it does not appear that any' school personnel fo these facilities participated further/ n Ithe Exercise, with the possible exception of Phillips/Exeter Academy, discusse below. j For the public schools, it appedrs there was additional, limited paKticipation by certain school personnel.
(paolillo) On March 3 and 6, 1 89, I conducted
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interviews with certain EpZ \school Supe'rintendents.
s The Cyct v%D N '
gpg content of these interviews are contained in Attachment 9, and -
04 O t A- /
are true and accurate to the best,,of my knowledge and belief.
As 6ppearing in Attachment 9, thdse. interviews are adopted by
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me, and made a part of this testimony', as if fully set forth I
herein. /
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(Sikich) My review of certain depositions and
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statements taken from ea'ch of the 5 school Superintendents in the New Hampshire EpZ and from the Dean of the phillips Exeter Academy, Attachment 8 and 9, and of Mr. paolillo's testimony, indicates that, w th one exception, the extent of 'this further limited partici ation by school personnel apparently, consisted c of only a pho call to each Superintendent's office.
Apparently e State official calling each SAU office ,id not request t at any action be taken regarding the Exercise, nor did the recipient take any action in response to the call.
Ther ore there was no demonstration in the Exercise, nor eve'n
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L an attempt to demonstrate, that school personnel understand the
h t A St,an a or are capabable of implementing protective actions for stud ts, in the context of a full participation exer'cise scenari Indeed, in the case of SAU #16, and SAU #17, which comprise 7 of 5 School Administrative Units in th'e New
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Hampshire EPZ, it appears that the one phone, call made by the State to each SAU was received by a Secretar'y, who simply acknowledged the call and hung up. Attac$ ment 9 at Statements of Superintendents Joyce and Clancy. ,
In the ca'se of SAU #21 and'SAU #50, the State
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apparently was able to reach the Su'perintendent or his assistant, yet no follow'up conta t to individual schools, coordination of response, or de onstrated capability to b implement the relevant emergency plans was requested or cgfg,A attempted. Attachment 8 at' Katner Deposition; Attachment 9 at Durgin Statement. This ,was so even though most SAUs have, historically, compliedIrith requests to cooperate or i participateinplannibgorexercise;e.g. Id at Katner Depositionp.26;M$nahanDeposition,p.21;Seealso
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Attachment 9 at Joyce statement; and even though there were, or may have been,fadministrative personnel in certain EPZ schools
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during the esercise, Attachment 9, Statement of Mark V. Joyce,
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P. 4; and tatement of George Tucker, p. 3, even though schools were closed.
/ For the Portsmouth SAU, the Superintendent sent two
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representatives, apparently to a local EOC, who, to s the knowledge of-the Superintendent, "didn't do anything other than b Attachment 8, Monahan Deposition, p. 14. In f serve."
E' l
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a dition, following notification that the Exercise had,, begun, !
i Mr. onahan later personally received a call from the State, i but to k no action in response. Id at 17.
i For the phillips Exeter Academy, with an enrollment ;
of almost 1 00 students, Attachment 4, the statement of George Tucker, Dean 6{ Students,indicatesthathisschooldidnot participate at a{l in the Exercise, and that Mr. Tucker was not ,
even notified tha an exercise had occurred until he was contacted by the Ma'asachusetts Attorney General's Office in March 1989. Attachment 9, Statement of George Tucker pp. 1,
- 6. Mr. Tucker also spoke with people in his immediate office, g g and with fellow dean Susan Hornep, but these individuals were ,
D not aware that the school had any involvement in the Exercise. !
oit.QCS '
Id at p. 1.
This contrasts with statements made by Applicants in response to discovery requests'i . As stated by Applicants:
Identificatiom of persons participating in the Exercise cannot be made in the form requented because information.is not available to Applicants. Based on a review of/ existing player and controller materials generated _during the graded exercise, at least one administrative representative of each of tho five Supervise'ry Administrative Units and an administrative represesitative of the phillips.Exeter Acedemy partic ' Applicants are unaware of tho'fpated in theofexercise.
identities these personnel with the exception of George Tucker, Dean of Faculty, phillips Exeper Academy. The administrative representatives regeived at least one telephone call from New
) Hampshire emergency response personnel during the exercise. Attachment 6 at Response do Interrogatory
.#2(a). 's
/The State of New Hampshire "incorporateyd) and
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adopt (ed) Applicants' voluntary responses to TOH's Informal
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Discovery Requests (hereinafter " Applicants's Respon e"),
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, Rehonse2(a), and concurs with the information provid t erein."
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I ttachment 7 at Response 2(a). Even if Appficants and the State to correct that a call was madeA he Academy,
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it is clear from r. Tucker's statemenp and from those of the
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School Superintendent that this Yhone call " participation" in
(_ x C L V M D f Sg the Exercise was perfunc3 y, often did not reach responsible O personnel, and did,not' test, d did not attempt to test, the plans or per blintheschoolti, or their capability to responA o an emergency.
p Q.10. In order to meet the purposes and objectives for a I
full participation Exercise, is it necessary to conduct the Exercise when schools are in session?
A.10. (Sikich) No. As I stated, the purpose of the Exercise is to verify the capability of the emergency response organizations, and personnel responsible for implementing the
. plans, to respond to the exercise scenario. participation by the general public, including students, however, is not necessary to verify these capabilities.
.AbM Whether or not school is in session, a sufficient number of school personnel f
responsible for emergency response should participate in the Exercise to demonstrate that these objectives can be met. In my view, this would include participation by all Superintendents, each principal or director, an[asampleof teachers from each school facility, in the case of public schools. For private schools, this would include all of the same personnel, except Superintendents.
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Q.11. Do you agree with FEMA that the Exercise met Objec ve 19 which provides:
Demonstrate the ability and resources necessary to )
(> JIM M.MN ~iinplement appropriate protective actions for school children within the plume EPZ.
\ ,
FEMA Report, p. 172.
A.ll. N An Exercise should test emergen communications and coordination involving th schools. This requires a two-way in'tegrated exchange of nformation. The information flows from the government o icials through to the schools, and should be received by th appropriate-individual
{>ttt.UDCD who actually has responsibility to c/arry out the response ;
D functions stated in the plans. here must be sufficient OTt.MTL interplay among school personnel at each school to demonstrate p
the capability to respond );[ the' scenario, implement protective
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action recommendations arid take appropriate actions as i
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necessary to protect the health and' safety of school children i and school related ersonnel. A full' participation exercise i
should test the c pabilities of identified school resources (responsible s
/ool personnel) at each sc'hool.
These school
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personnel mu verify their ability to respyd in an integrated and coordi ated manner to an emergenc he <une 28, 29 1988 Exercise did not attempt to verify these capabi ties, prior to op ation, these capabilities should be demonst sted and (Ot eva) ated in an Exercise. Until that time, there is ot reasonable assurance that adequate protective measures can and
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e taken in a radiological emergency.
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NUCl. EAR-REGULATORY COMMI'SSION ! s 3 Do:kel No. ---
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ATTACl! MENT P 9(f,! ,
. - i Re In the Matter of Public Service Company of N. H., et al (Seabrook Station Units 1 & 2) i DEPOSITION OF NORMAN KATNER i I N D E X Interrogatories by Mr. Brock 3-Signature page 27 4
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(
- i. l UNITED STATES OF AMERICA h
Nuclear Regulatory Commission Before the Atomic Safety & Licensing Board i t i In the Matter of Public Service Company of New Hampshire, et al (Seabrook Station Units 1 & 2) :
2 DEPOSITION OF NORMAN KATHER Deposition taken by subpoena and agreement of the parties at the law offices of Shaines a i
McEachern, 25 Maplewood Avenue, Portsmouth, New Hampshire, on l
l Monday, March 13, 1989, commencing at 9:15 o' clock in the fore-*l l
noon.
~< )
APPEARANCES:
For the Commonwealth of Massa- {i chusetts Attorney General's Offied l Matthew Brock, Esq., Assistant Attorney General Nuclear safety Unit One Ashburton Place "
, Boston, Massachusetts 02105 For Public Service Company of New Hamoshire: '
Ropes & Gray 1 International Place Boston, Massachusetts 02110 by Geoffrey Cook, Esq.
For the State of New Hampshire Attorney General's Offices v
Geoffrey M. Huntington, Esq.
Assistant Attorney General
~
L
s 649 &&
0 Stenocrachers Donald E. Lamont, CSR 25 Maplewood Avenue
{
Portsmouth, New Hampshire '
1 It is stipulated and agreed that 1 l
the deposition may be taken in the first instance by i Stenograph and later when transcribed may be used as and for the deposition of the deponent for all !
purposes insofar as competent.
The reading and signing of the '
deposition by the deponent is expressly waived.
(Deponent duly sworn by Mr. Lamont)
INTERROGATORIES PROPOUNDED BY MR. BRCCK: !
I, Norman Katner, on oath, depose and say as follows:
Q1 Would you state your name and address.
A Norman Katner, 10 Blueberry Lane, Rye, New Hampshire.
Q2 How are you employed? '
A I'm employed by the School Administrative Unit Number 21 in Hampton.
Q3 And how long have you had that position?
A July 1st, 1984.
Q4 And your job title is?.
A Superintendent of Schools.
v Q5 Would you summarize the responsibilities you have as m._ - -
9 l
'Cr7v /&& l superintendent for SAU 21. !
A Well, by law I'm the chief executive officer of the 1 l
six school districts that compose the School Admini- l r
strative Unit.
Q6 Well, could you be a little more specific as to on i
a day by day basis as superintendent what your l responsibilities are via-a-vis these six schools that comprise the District?
A Well, it varies. If you've got three thousand three hundred and fifty-nine children and five hundred and i twenty-nine employees and a twenty-one million budget it's going to vary on a day to day basis. I i
Some days it deals with personnel other day it deals with roof leaks, other days it deals with snow days. Today, for example, it deals ,
with a luncheon at eleven-thirty to discuss what we're going to do in the school district that lost a bond issue in South Hampton, do for the kids for next year ,
So it varies on a day to day basis. '
Q7 Who hired you as superintendent?
(
// A The joint board of the School Administrative Unit Number 21.
Q8 And you were hired in 19847
_ A '84, right.
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9 49 1 /L.6
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Q9 What are the responsibilities of the School Board, as distinct from your own responsibilities, with respect to the schools within SAU 217 A
They hire the superintendent, the assistant superin-tendents. They establish the SAU budget. That's about it.
Q10 Who sets policy for SAU 217 A The joint board.
Q11 And you administer that policy?
A That policy plus the policies of the six othar school districts.
Q12 So there's a joint school district board.
A Right.
1 Q13 And each school in addition has their own boards? :
A Right.
Q14 The school boards are elected?
A Yes. I Q15 Would you identify the scheols in SAU 217
~
i A Jouth Hampton, Seabrook, Hampton Falls, Hampton, I North Hampton and Winnacunnet.
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Q16 And the principals for each one of those schools are under your supervision and direction, is that correct P A Generally speaking, but because it's a dual type of
_ situation, they certainly can't disagree with their
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local boards, so they take direction from them as l
well as from the superintendent. *
- - 017 And the faculty would in turn at each of these schoor I i take direction from the principals in the respective schools? .
A Yes.
i Q1t Are you familiar with the procedures for schools set i forth in the New Hampshire Radiological Emergency Response plan for Seabrook Station?
A Vaguely. -
- Q19 What is your understanding of those procedures? ;
A My understanding of those procedures are that given i a particular type of warning, that the students would be evacuated from sites, some going south'toward 1
Nashua, others going north toward Manchester.
Q20 Do you have an understanding of your responsibilities '
as superintendant specifically under that plan?
A Well, yes.
Q21 okay. Was the question not clear? '
il A oh, no. The question is one that involves profes-I sionalism and three thousand three hundred and fifty- l l
nine students. There is no question in my mind as !
l to what the role of superintendent is in any emer-gency, and that is that it's his primary function to j l
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see that those children, whether it be a hurricane !
or whatever it be, are taken care of up until such {
i timeashispositionisassumedbytheNationalGuard[
or other agencies such as the police department gives orders to leave the area.
Q22 And--
i A
Tornadoes, for example, that's what I'm speaking of, ;
that's what I am familiar with. The responsibility of the superintendent has always been, as far as I !
know, the element of responsibility is the well-being; of the children that have been placed in his trust l by state law.
Q23 And is that your general understanding with regard to the responsibilities of yourself as superintendent under the New Hampshire Radiological plan.
A I, yes, I wouldn't see any difference. Now I'm j talking professionally. If it's an emergency, it's an emergency.
Q24 You're not aware of any more specific procedures than i what you just described?
A Well, other than that we're notified in light of a--
certainly, there are different levels of warnings i
and we do certain things during those, we either cover up or evacuate. As far asa-there may be some i
.t I
o n ? /&G-c in between that I'm not familiar with.
Q25 Are you aware of any specific responsibilities under that plan?
And when I'm referring to the plan it's the New Hampshire Radiological plan. Are you aware of any specific responsibilities under that plan for principals of the SAU 21 schools?
A The principals have certain duties to report periodi-cally.
We notify them right in the building. They in turn notify their staff and their students. I think it varies on what they do depending on the severity of the warning.
Q26 Is it your understanding that you would be part of formv.lating whatever the appropriate action would be for these students in the event of--
A Yes.
Q27 --an emergency at Seabrook?
A Uh-huh.
Q28 Yes?
A Yes. With the exception of the Hampton School Dis-
.I trict, which as you well know, Matt, because you I-worked with the town, has refused to let the super-intendent of schools participate. On whose legal advice that was, I don't know, but that did occur.
So I do not participate in the Hampton school simply
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l because the Hampton board, I believe through legal !
i counsel, was advised, advised me not to participate l
in the emergency plan. !
029 With respect to any of the other schools in SAU 21 have you received a similar direction? !
A No.
Q30 So you were Superintendent of Schools in February '
of 1986, for SAU 21, correct?
A Yes.
Q31 Do you recall that there was an emergency exercise of {
the plan at that time?
A Most of the, most of the responsibility for the plan has been delegated to Fred Engelbach who is the assistant superintendent for buildings, transportatio n4 4t cetera.
I vaguely recall a February 26th .,
but I don't recall what year. I know there was one in the winter. Beyond that there's not very much t
I can tell you.
MR. BROCK: Could we go off the record for a second.
[A short recess ensued at this point) 032 So if I understand your answer, your best memory is
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there was an exercise sometime in the winter a coupli !
years ago, correct? !
A Yes.
l Q33 But you don't recall details about that exercise? '
A Not really.
b Q34 Do you re,:all whether you or your office participated in that exercise? t i
A well, if you define participation, if a phone call from someone is a participation, then yes we parti-cipated.
Q35 And do you recall receiving such a phone call?
A Yes.
Q36 Do you recall who made the phone call to you?
A No.
Q37 Did it come to you personally?
A I took it, I don't think it was personally directed
-to me.
Q36 Do you recall the content of the phone call?
A Just that there was a--there's a term that's used, ,
mark or whatever, and we knew what was coming. I h believe we knew what was coming.
You're asking me questions, we keep no records of these, so you're asking me t'o w rely on my mind which was battered about in a recent
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' /%~S /L D l 6 j accident so I am unable to remember a lot of the details I once was able to, Q39 That's fine, I'm just looking for your best memory.
l Just to pursue that February or pursue that exercise 1 which occurred sometime in*the winter a couple years ago, other than that phone call do you recall any j involvement or participation by your office in that .
exercise? l A
There are two things we've been involved in. One we'v been involved in the review of the plans. That's been on-going over a period of time, with various consultants from PSHN.
In fact I believe that our involv.
ment led to a change in the plan. It seems to me if memory serves me correctly that we were heading all j, of our students south toward Nashua and I requested that they be sent north because sending some of them south would send them by the plant and there was no need to do that. So I think we were then changed to go to Rochester or Dover or up that way.
If you mean that kind of involve-ment and participation that's been on-going. If you mean that particular day when that phone call came in, our involvement at that time, I believe, was t
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simply either as a recipient of the call or we alert !l our building principals.
Q40 Do you recall whether you took action after.receivinl the phone call, such as alerting your principals, or do you remember?
A No, I don't.
But if that was part of the plan that- i ;
we agreed to, then that was done. However, some of l
% these drills have taken place when school has not i r
been in session. And_I can't tell you on what given ;
date that happened two years ago. February--I can't :
tell you whether we were in school that day or not. l Q41 You are aware there was an exercise of the plan last !
June 28th and 29th, 19887 A Yes.
Q' 42 When did you first become aware that there was to be ,
an exercise on that date?
A I believe it was before but I can't tell you when l before.
Q43 Do you remember how you were notified that there was to be such an exercise?
A I believe I had a personal visit from Helen Wilson.
Q44 Who?
A Helen Wilson. But again I can't, I don't make notes s,
of these so--
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Q45 Who is Helen Wilson?
A Helen Wilson is a contact person, I believe a con-sultant for PSNH who dealt with local schools. Wait i
a minute, no, she may have been, she may have been ;
with the state emergency defense or a state _ agency.
I can't tell. I think she is or was Q46 Do you recall approximately when Helen Wilson advisec you there was to be an exercise? i A No.
1 Q47 And do you remember anything specifically about what ,
she said about the exercise other than it was to occur?
A What I said when I was advised that there would be one? ,
Q48 That is correct. Did you have any reply?
A I think I indicated that we would- be out of school.
Q49 And what was her response to that?
A That, I don't recall.
Q50 Do you recall yourself saying anything further to her about the exercise or the date it was to be scheduled g A No.
Q51 And your best memory is that contact occurred before the exercise but you don't recall when it occurred?
A That's my best memory. I wouldn't attest to the
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G accuracy of that statement because I really don't know.
Q52 Do you recall other than--well, strike that. Was that; communication from Helen Wilson by phone or how did
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i you receive that?
)
A I can't tell you.
Helen Wilson has been a contact I person, she has stopped into my office by appointment on several different, on many different occasions. 1 I
I don't believe I talked to her at all on the tele- l phone.- I think I talked with her primarily in my Ii 1
office so I would have to think it was in my office prior to.
But perhaps by going back to my date calendar, I could give you some idea of'when that occurred.
Q53' Do you recall receiving any written materials, docu-ments, from her or anyone else regarding the exercise prior to its being held?
A That specific exercise?
Q54 That is correct.
l A
No. But we did receive constant updates to the plan.
4 055 Let me just clarify. You did not receive written materials regarding this June, '88, exercise to the best of your recollection?
.. A To the best of my knowledge, no. I got all the
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materials from whoever was representing the agency.
l We discussed that. I think that occurred a long time ago.
We got all of those plus we did not get--any,thi I believe that we got from PSNH was when the plan was revised.
i Q56 Now this exercise occurred on June 28 and 29, 1988, that's your understanding?
A Yes.
057 School was not in session at that time?
A No.
i Q58 Where were you at that time? I A At the Red Jacket Inn here in Conway.
Q59 New Hampshire.
i A Yes.
Q60 And what were you doing there?- i A That's the Commissioner's annual conference, the '
Commissioner of Education.
- Q61 And you as a school superintendent would attend ~that?
A Yes. -
063 Were other SAU superintendents attending that as
( well?
); .
A There's only one SAU superintendent.
Q63 I'm sorry. There are ' superintendents for other SAU's, correct?
l
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O l A Yes. They would be attending. !
064 And is your best memory that--strike that. Did any-one else from your office or SAU 21 attend that '
conference?
l A No. Wait a minute. Last year? There may have been s one assistant superintendent Mr. Wilson. I think he ,
did attend.
Q65 And what was his name? -
1 A Leon Wilson.
1 066 And he is an assistant to you?
A Yes.
~
067 And you testified that schools were not in session on June 28-29, 1989, correct?
l i A yes.
l Q68 Would there have been still administrative staff, principals or. other school personnel, at any of the SAU 21 schools on those dates even though school was not in session?
A Yes.
Q69 You would expect that that would be true with respect-
) to--
f A All except South Hampton. The principal of South Hampton is a teaching principal and pretty much
- follows the contract with teachers, but he may have
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been or he may not have been. I can't say. I don't !
l l
l know what closing date he finished last year. I 070 But with the exception of South Hampton, you would l expect there would have been school personnel 4t.the other SAU 21 schools?
I A
?
Well, that's hard to say in a blanket type of state '
ment, because some of the principals may have asked for and been granted vacations. So I can't tell you.
In the high school there would have been an admini-trator there.
There would have been an administrato at the Hampton Academy junior high school. There would have been an administrator at the seabrook elementry school. There would have been an admini- '
strator at Hampton Falls. The Hampton schools other than North Hampton I really can't tell you. I could tell you, Matt, by looking at the vacation schedule I whether or not they were there, or whether or not they were supposed to be there.
Q71 Do you recall being asked by the State of New Hamp-shire or New Hampshire Yankee or anyone else involved with seabrook Station to be present on either the l
28th or 29th?
A No. '
072 To your knowledge were any of the school personnel I
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at the various schools in SAU 21 requested to be present on those dates?
A Not to my knowledge. I had left it with Helen Wilson that she had free access to contact the principals in the various districts because I didn't think it wad expedient for her to go through my office each time-i she wanted to talk to them. And so she may have '
contacted those principals in those buildings. If '
she'did I do not know of that. N i
Q73 And subsequent to the exercise you never had it l
l t
reported back to you by anyone that those contacts-had been made?
A Well, with my not being there, Mr. Engelbach handled' I thj 11 and I talked with him just before I came up i accepted the phone calls, he could not remem-w
. aether or not he then fanned out those phone calls to the buildings. He doesn't know, because we do not write things down as these tests come in.
i I think there was a test that '
preceded that one in which they sent buses in from f
k Manchester, over that way, into Hampton Falls. I think that was the first test that we entered into, was the buses. The second was in the winter, ' s
- s. third one was in June as I recall.
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Q74 Let'sjustfocusonlastsummer'sJune28-29 exercise!
so if I understand it, you personally were in Conway.,
attending a conference on those dates, correct?
t A- Yes.
Q75 And your assistant a Mr. Engelbach was at your office on those dates?
1 A Yes.
Q76 And you spoke with him before coming to the deposi-tion this morning? - t A Yes.
Q77 And he--
A No, I spoke to him- Friday. When I got the summons -
at four-thirty in the afternoon I spoke to'him.
Q78 And what did Mr. Engelbach--well, Mr. Engelbach told you that he recalled receiving a telephone call?
L A Right.
L Q79 He received one telephone call?
[ A It was a very fleeting, he was on his way out the door when I asked him if he had participated in the drill and he said yes, he had received a call. Now
~ l whether that was one or more you'd have to ask him.
l 1'
Q80 Did he tell you who he received that call from?
l A, No.
- s. QB1 Did he tell you what the content of that call was?
l p_ _ -_ _ _ _ - _ _ . - - - - - - - - - - - - - - - - - - - - - - - -- ^ - -
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A Just that it was a--well, we all knew inLadvance that we were having a test on those two days.- So in-the conversation I had with him I just asked him if' he received a phone call from PSNH regarding a test on those days and the answer was yes.
Q82 And he couldn't recall whether he took any action ,
. subsequent to receiving that phone call?
A No.
Again, we were on our way out the door when the.
subpoena was delivered. He was on his way home Friday, I was on my way home. So there really wasn't
~
a 1cng time to talk to htm about it. It was just, t
i maybe, Fred, you ought to go up in my place because .
you know more about this than I do, and I told'him what it is. He suggested that I knew more about it i than he did. .
Q93 At least Mr. Engelbach did not tell you anything that i he did further than receiving the phone call?
A 1 He didn't tell me that he did anything or didn't do anything.
I Q94 Are you aware of any involvement, including phone contacts, concerning this exercise last June with regard to the principals at any of the SAU 21 schoolsP A
That would be not within my purview of knowledge because that again would have to be asked of Mr.--
? {s
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O I I'm not-aware he did, I'm not aware he didn't.
Q95' And you're not aware that the principals were con--
tacted directly, for example, by the State of New
~
Hampshire during that exercise?
A No.
1 Q96 And you're not aware of any contact or any involve - '
ment of any of the teachers in SAU 21 during this exercise?
A Teachers are not normally in school when school--when the kids leave, the teachers leave, almost concurrent So on the 27th, 28th and 29th the teachers would not have been in school.
097 And would not have participated in this exercise as far as you know?
A They have indicated via the union that they will not !
participate in the drills, although I have been led to believe that I will have staff in the case of emergency.
Q98 And what staff would that be?
A Those are staff members who are saying an indication they will not, but they indicated to me that if the kids are in danger they would participate.
Q99 And were any of--when you say staff do you mean s.
faculty?
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L A Faculty.
Q100 And to your knowledge, were any of those faculty involved in the exercise last summer?
A No, because their year had ended. They were out of j school around the 15th or 16th, sometime in that June era.
Q101 Would you expect it to.be brought to your attention if any of the teachers or principals of SAU 21 schools had been contacted or involved in the exer-cise? Well, I imagine I would if the teachers par-ticipated because we would all be. wondering what:the);
wou15 ne doing there. But as far as the principals l
i that would not be brought to my attention.
Q102 Following the exercise on June 28-29, were you con-tacted by any Federal officials regarding:the exercise? ,
A By that time, if there had been any contact it would
, have been with Fred.
Q103 And you did not personally receive such contact to the best of your knowledge?
A June of 1988, that's a long' time ago.
Q104 Anytime from the conclusion of the exercise.
A I don't recall any. That does not mean it could not have occurred but I do not recall.
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O Q105 And you're not aware that Mr. Engelbach or anyone else on your staff received such contacts following the exercise?
A well,The has not indicated that to me but that's not uncommon.
Q106 So he may have, he may not-have.
A That's right.
Q107 And that would also be true for contacts by state officials or anyone else, you personally haven't received such contacts since the exercise but Mr.
L Engelbach may have received such contacts.
L A I again would have to check my calendar to find out l -.
1 to make sure that I had not. Most of those would have gone to him had there been any.
Q108 You today sitting here,. you don't recall any contact you personally received?
A No, because I don't have my date book with me and .
therefore I can't confirm whether I did or didn't..
Q109 And your best memory is that you have not received
). any questionnaires or documents since the conclusion '
of the exercise, again sitting here, to the best of-your knowledge?
A It seems to me that a questionnaire came in and'it wa s s
sent on to Mr. Engelbach.
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Q110 Do you recall who sent that' questionnaire?
A No.
Q111 Do you recall anything of the contents?
A No.
Q112 Do you know whether'Mr. Engelbach did anything with that questionnaire? '
A No.
Qll3 Aside from the exercise of last June 28th and 29th, '
since that date have you had any contact or involve-ment regarding any emergency plans or exercises for Seabrook Station?-
A' I can't answer that. I'd have to check at the office.
n 1
Q114 You don't recall any sitting here though?
A It seems to me that there were two or three attempts,'
or maybe four attempts, to set up a meeting, but we could not, it'just didn't work out according to schedule. But there were Helen Wilson once or twice and a consultant from the Pittsburgh area, I can't remember her name.
l Q115 We're just asking for your best memory.
A I think there were attempts to establish meetings, I think meetings were scheduled, but I think the meetings were cancelled.
v
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I Qil6 Can you tell me what training you or your office or' l SAU school personnel have received with regard to emergency plans or procedures for Seabrook Station? 1 A- Training?
Q117 . Correct.
f Sc A Actual-training. None to my knowledge. Offered but ;
refused.
Qll8 Now the District school board is the one who hired i
you, is that correct?
A The joint board.
l Q119 And the joint board.as.the policy maker for-SAU 21 .
did thay ever tell you not to participate in the exercise last summer? 1 i A No. t Q120 Did they ever tell you that.your office or the school'
!e-personnel in SAU 21 should not participate? '
A No. Only the Hampton board by resolution said we should not participate in any of the activities ,
related to the Seabrook evacuation plan.
1 Q121 And caide from that there would be five other local
- f. district school boards under SAU 217 A Right.
Q122 And could you just refresh my memory and identify tho. r (s five?
,. o c ' 1% ) ')bb p.
A South Hampton, Seabrook, Hampton Falls, North Hampton!
Winnacunnet and Hampton.
Q123 And with the exception of the Hampton' local board, to your knowledge have any of the district boards l
directed the schools in their respective jurisdic-tions not to participate in the exercise last summer?
A No. Not by board resolution.
L Q124
- 1. And again with the exception of Hampton, you and your office have not refused requests by the state to.
(-
cooperate or participate in planning or exercise?
=i A No.
You are here by subpoena, is that correct?
Q125 1 A Yes. '
Q126 And~that subpoena included a request for certain documents, did it not?
1 A Yes. i Q127 Were you able to locate any documents within the
. request?
A Not--the staff leaves at four, well it was after the office closed, but we couldn't find any relative to what we thought you would want to talk about today ,
any and all documents relating to the involvement of myself and 21 in the June 28 and 29 emergency s,
exercise for Seabrook Station. We could not think
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iii9 ]hb aof any that we would have.
Q128 And was Mr. Engelbach involved in trying to decide- '
A No, well, for about three minutes.
Q129 Okay. Let me just finish the question.
A Okay. ;
Q130 so last Friday you and.Mr. Engelbach were trying:to determine whether there were documents within the scope of that request and concluded there were none?
A Right, that we could find in the'three minutes that !
i we had available to us. You asked about a survey, i we weren't sure that there was a copy kept of that.
Normally, we do not keep copies of surveys.
- i. s. ,
MR. BROCK: That's all I have, l.
MR. COOK I have none.
L I
MR. HUNTINGTON: 'I don't have I any questionsefor the state of New Hampshire.
[Whereupon'at 9:55 o' clock in the forenoon, the within deposition was then ,
concluded) -
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- THE STATE OF NEW HAMPSHIRE ROCKINGHAM, SS. 1 I
I, Donald E. Lamont, a certified: '
shorthand reporter, in and for the State'of New i Hampshire, do hereby. certify that the' foregoing ;
twenty-seven pages contain a full, true'and correct -
transcript of all of the testimony of the witness-NORMAN KATNER, to the best of my knowledge and belief.
IN WITNESS WHEREOF, I have-here-unto set my hand and seal this ' day of
_,1989.
t
, N/. ;
Donald E. Lamont, CSR
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Re In the Matter of Public Service' Company of N. H., et al (Seabrook Station Units 1 & 2) l DEPOSITION OF TIMOTHY F. MONAHAN s
I N D E X .
Interrogatories by Mr. Brock 3
l Monahan Dopo Exh'for Iden.-
Introduced at-Description paget t
1 Letter from Helen Wilson 7
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h UNITED STATES OF AMERICA Nuclear Regulatory Commission Before the Atomic Safety & Licensing Board
- a In the Matter of Public Service Company' of NewfHampshire, et al :
(Seabrook Station Units 1 & 2) .:
- i DEPOSITION OF TIMOTH'l F. MONAHAN
/
Deposition taken by subpoena and agreement of-the parties at the law offices of Shaines-E-
.McEachern, 25 Maplewood Avenue, Portsmouth, New Hampshire, on Monday, March 13, 1989, commencing at 10:15 o' clock in the fore _
noon.
s APPEARANCESr For the Commonwealth of Massa- l chusetts Attorney General's Offic o Matthew Brock, Esq., Assistant .
Attorney General Nuclear' Safety Unit One Ashburton Place Boston, Massachusetts 02108 For'Public. Service Company of New Hampshire:
Ropes & Gray E 1 International Place Boston, Massachusetts 02110 by Geoffrey Cook, Esq.
For the State of New Hampshire Attorney General's Offices !
v Geoffrey M. Huntington, Esq.
Assist. ant Attorney General
- 3. i 13< 1 h.fi g
Stenographer:
Donald E. Lamont, CSR ,
25 Maplewood Avenue -
Portsmouth, New Hampshire It is stipulated and agreed that; the deposition may be taken in the first instance by ;
Stenograph and later when transcribed may be used- ,
as and for the deposition of the deponent for all i
purposes insofar as competent.
The reading and signing of the deposition by the deponent is expressly waived.
(Deponent duly sworn by Mr..Lamont)
INTERROGATORIES PROPOUNDED BY MR. BROCK:
- l. s I, Timothy Monahan, on oath, depose and say as follows: .
Q1 Would you state your name and. address for the record 4 please.
A Timothy Monahan, 604 Elwyn Road, Portsmouth.
. Q2 How are you employed?
l A Superintendent of Schools in Portsmouth.
I l
Q3 How long have you held that position?
A Fifteen, sixteen years.
Q4 Would you summarize your responsibilities as Super-intendent of Portsmouth schools?
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A In charge of all the schools'from an educational point of view, from a financial point of view, and t I
i whatever other fires come down the line. I QS Who hired y'ou? -l A The Board of' Education'.
Q6 The Portsmouth Board of Education.
I A Uh-huh.
1 Q7 And that is an elected body?
A Yes.
l I
Q8 Who sets policy for the Portsmouth Schools?
A The Board of Education. l Q9 And you implement that policy?
A Yes.
Q10 would you identify the-schools in the Portsmouth School system for which you are responsible?
A Thehighschool,thejuniorhighschool,thefollowind i
elementary schools: Little Harbour, New Franklin, l
, Wentworth, Brackett, Jones, Sherburne, Dondero.
I 1
Qll Each of the principals of those schools that you've !
identified answer to you, is that correct?
A Yes.
Q12 Are you familiar with the plans and procedures in the New-Hampshire Radiological Emergency Response Plan for Portsmouth Schools?
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f1 A Yes.
Q13 And-for-shorthand purposes in this depositions I'll' just be referring to that as the plan.
A Okay.
Q14 - What is your understanding with respect-to your responsibilities as superintendent under that plan-in an event of an emergency at seabrook?
A If I am notified that there is an emergency, to the point where I have to consider evacuating the schools-or sheltering the students, then I make that decision-The decision, the information is given to me I assume from the City Manager who gets it from somewhere else:
Q15 And it's your decision as to what protective actions the students should be taking?
A Yes, but they advise me.
Q16 And when-you say they, that's your' staff?
A No. That's the, I don't have the right word, the headquarters that are set up here in the city which contains the mayor, me--but I don't go--the police chief and so forth, that group. They're the ones that advise me and I would assume that advice is coming from the state.
Q17 But you make the final call, that's your understand-
, ing?
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i A- Yes.
Q18 Were you. involved in an emergency exercise for l
l Seabrook in February of '86, if you recall? l 1 A I would guess yes. '
Q19 Do you have a memory of doing that or--
A I have a memory, and I can't pin them down, but-approximately that long ago I was down at the head-quarters here. Would I be right in saying that's tha EEO, does anybody know?
Q20 Whatever your best memory is.
A But anyway, the central area here in the city, I have-a memory of going down there to a drill. '
Q21 And what was your involvement or participation _ at tha-time? I A At that time I sat there, listened to the informationJ that was coming, and sometime around1one or one-thirth I was told that it had been upgraded. What comes back; into my head was when we were told, when it was sug-gested to us that we evacuate, we were already evac- t I
unting because it was so late in the day that the buses were rolling. No' students had left the buildini
- but the buses were moving to pick up the students to-take them home. And so, therefore, we just let naturi s take its course.
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.e - -U-q Q22 And what you've just described is your involvementL I with the 1986 exercise?
A I believe, yes, j
Q23 Now you are aware there was an emergency exercise for Seabrook last summer June 28th and 29th? 1 1
A Right. "
Q24 And when did you first become aware there was to be- ?
an exercise at that time?
A May 14th.
Q25 You're looking at--
A I'm looking at a' letter.
Wait a minute now--as we. ,
discussed I will be i'nmy office on- the June 28th date. I wrote on May 14th, so it was prior to.May. I 14th.
Q26 May I see that letter please.
A It's from me to Helen Wilson.
Mk. BROCK: Okay. I'd like to mark this as an exhibit. Let's go off the record.
(An off-the-record discussion ensued at this point, whereupon the cited document was then received by the reporter and marked as Monahan Deposition Exhibit 1 for identification]
I Q27 Okay, Mr. Monahan, I'm referring to what's been marked as Deposition Exhibit 1 and that is the
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letter. dated May 19, 1988,-from you to Helen' Wilson, is that correct?
A Yes.
Q28_ Who is Helen Wilson?
A-She's out of the office of Emergency Management--oh,-
what's her' title? She's the director of, I guess- '
I don't know. I mean I don't know here exact title.
she's the person that I always deal with concerning-any of these matters.
029 And that would include the exercise?
A Uh-huh. No, once the exercise is under way--on that-particular day?
Q30 Let me withdraw the question to be clear. In terms of getting information that the exercise was going to occur, Helen Wilson was your contact?
A Yes.
Q31 Okay. And that would also be true as to planning issues as well?
A Oh yes. Many meetings with her.
Q32 All right. Now in the letter, exhibit 1, you indicati three dates when you would be available to participati correct?
A Yes. I-Q33' Those are May 24, June 10 and June 28th?
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.4-A I would assume-that she gave me those dates.
I don'-
have--probably Helen arrived.in my office and{gave ,
1 me some dates and I= wrote back and said, yes, any of them.
Q34 So your best memory is those' dates were potential ,
dates for the exercise? .
A' Yes.
Q35 And you indicate in'that letter that you would be availabin for all three of them. #
A Yes. 1 1
Q36 Do you recall the discussions with Helen Wilson that .
-l led up to your writing the letter of May 19th? -i A I can't recall them. I would only be guessing, j
\
Q37 Do you recall any discussions with anyone from-the l
state of New Hampshire, or New Hampshire l Yankee, concerning'the exercise before it occurred?
A No. I, my, I would be sure, quite sure, that Helen
, Wilson was always my contact.
Q38 And other than this letter, do you have a memory of any, either yourself or anyone from your office, beine
[ involved or planning for this exercise?
A Well, I think that depends on how deep you want to go-into that because two years prior to that there'was
,, constant interaction or my people and the city, the l
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- s police and Helen Wilson and many people in putting" together the-evacuation plan,-or whatever it is, that f we have on file right now, which would include Helen l and others meeting with my principals gathering information and so forth. .
t Q39 And so you and the Portsmouth school system have had 1 input into those emergency plans for Portsmouth s
schools?
A Yes, no question on that.
Q40 Did you or. school personnel from~the Portsmouth schoo system have input into when.the emergency exercise <
would be scheduled or what would occur during the ;
exercise? i 3
A Wedidnothaveinputastothedateoftheexercise.j.j; What would occur would be that which was in the plan.
Q41 And the exercise we're referring to iu the one last summer.
l A Correct. '
Q42 Do you recall specifically any suggestions or recom- I mandations which either you or your staff or.anyone from the Portsmouth schools may have made to the stat o or to anyone about the conduct or content of the l
exercise? l
- s. A Well, no, and I doubt very much that we did because I
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school was closed. The year was over, the students were gone. And as I recall--first of all you should-i know I do not go to the headquarters down here. I wasI h n originally scheduled to do that and I; petitioned Heltl I'm sure, to remove me'from that and I said I would i
P L send a couple of other people down. I felt'that was:
not the proper place for.me.
I-I have.long looked at this entire l exercise and plan as having something obviously to do with Seabrook, but several years ago we had a_hur j ricane coming and we were not prepared.for that. And-I looked at this as a' plan that would fit any emergen not just Seabrook.
And I wanted to be in my office,-
not down there.
Down there I found, because'I- ,
did participate in the one, all-I did was sit around, I all day and then they told me things. And when I decided to do something or I wanted to inform my people, I picked up a telephone and called my office and had somebody disseminate that information.
And I made the point to them--thi is a long story, I don't know if you're interested in it--but I made the point _I don't want to be down there anymore, I can stay in my office. I can just
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, __as well be told to reen---nd avacuation in my office,' -
I have the ability;to use an intercom to call any .
principal from my office, I-have the ability to call them on private numbers that.wouldn't be' tied up.-
And so I thought I should be there and so'I said give:
>o me a sort of conference call. And-so they agreed. -i And so on that June 28th exercise -
I was in my office, which gave me nothing to do becau l we didn't have any students. So my people went down there, they. sat around all day, and'I don't remember' whether they recommended evacuation, or sheltering-or what that day. Whatever it was I took-the phone call and I said thank you and we didn't have any
~
students and that was the end of it.
Q43 Let me just back up a minute. Prior to the exercise u
then, your best memory is that you were aware there was to be an exercise but you didn't have-input into the date and it was your understanding that the exercise was to ganically test what the plan provided 4
1 for in terms of procedures, is that correct?
h A-Yes.
Q44 Now you said schools were not in session on June 28 and 29 of last year, correct?
s, A Yes.
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Q45 When.did they get out for the summer?
A About a week before.
Q46 So that if I'm looking at Exhibit 1, deposition ^
Exhibit 1, where you say you would be available.
May 24, June 10 or June 28, at least with respect j to those first two dates, school would__have-been'in session?
A Yes. )
/ i l Q47 !
on the day of the exercise, the first day of.the. '
exercise June 28, you were in your office, is that: 1 correct?
A res.
Q48 And you had sent some of your subordinates somewhere' i .
else in town to be part of this exercise?
i A Yes, i,
Q49 And who was that? ~
A William Hartwell and Richard Pecunies Q50 And what are their titles or functions? l A Dick Pecunies is my personnel director. William Hartwell is my director of adult education. '
MR. HUNTINGTON: Could you spell !
his name please.
A P-e-c-u-n-i-e-s.
(By Mr. Brock)
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Q51 Were there any other school' officials in'the Ports-mouth school system who you directed to be involved in this exercise-in some way?
l A No. l l
Q52 okay. Are you aware of any other Portsmouth school officials who were involved in this exercise?
A No.
Q53 Where did the two individuals you-just identified go 4 to and what did they do?
A The upper level of the Fire Department. .And, to the best of my knowledge, which is my asking~them to-t rem'ind me what they did, they simply did what'I did t first time. They listened and they relayed any-i information to me that they were told. 1
- Q54 So periodically during-the day you would have a con-4 versation with these two individuals by phone?
A No, I was wondering what-happened to them, I didn't from them. They could have took the day off on me.
Q55- Do you know of anything that they did in -the fire station in terms of the exercise other than observe?-
i A I believe they didn't do anything other than observe, listen. It was not their role, that's why I'm saying that.
Q56 Now you were in your office. Did you have some
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f involvement, contact, in terms of the exercise?
A only through them.
Q57 All right. So you personally did~not receive a-phone!
call? ,,
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.A From them I did. I received a call from one of them$
sometime during the day, and I don't remember'when,-
advising me either to shelter or to evacuate. And as I.said, no students, so we stopped right then.
Q58 You didn't take any further action because there were no students,7-A That's.right.
Q59 Other than that 'one phone call from one of your i subordinates from the fire station, did you receive phone calls or.otherwise have a role to play in this i
exercise?
A No. I believe the way it's set up, I would receive phone calls only from them. And I might have received more than one, you know, as they upgraded the thing, but I just don't remember.
Q60 But you know you received one call, you could have received more?
A Yes, yes.
Q61 To your knowledge would any of the principals'who
- s. were school officials in the Portsmouth schools
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that are part of your system, did they receive' calls-or would they--
A No, no they would not. .
Y Q62 Let me just finish'the question.
A Okay.
Q63 Did they receive calls or did they otherwise parti-cipate in this exercise? t s
A No, they didn't.
When the date was set and I knew that school was closed, I knew that it would end-with me because some of them would even'be on v_acation. .
Q64 And you never heard back that any of them had '
received calls?
A No.
Q65 When'you. received this telephone call from the i
subordinate at the fire station, if I am correct, he was relaying some recommendation about the protec- 1 tive action which should be made for students, 'is that correct?
A Yes.
Q66 Either to shelter or evacuate?
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A Yes.
Q67 Do you recall which one was the recommendation?
m A No.
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Its )c /w q Q68 Other than receivino that call acknowledging and the information relayed. did you t k a e any action after receiving that call?
A Ng4 Q69 Was there anything that was goi ng on that made you aware that there was an emergency exerci se for Seabr<
that day other than the phone call which you've already described?
A Nothing that I remember.
Q70 After the exercise was completed J une 28 and 29, well let me just back up a second, strike that. The answers you've given with respect to Jun e 28, that is the same as for the 29th, we've b een talking about those two days.
A Right.
Q71 You received one phone call in that A two-day period. i I don't know that.
When my people were down there I received at least one phone call .
If I received another one, that could be but--
Q72 Following the exercise--
A Excuse me.
I had to receive another phone calle t llin me that the emergency was on and I had spatch to di those two people down there.
w So there's two phone cQ.
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Q73 so you recall a phone call at the beginning of the ;
exercise which said, we're now in the exercise. !
- - A Yes. -
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Q74 How did you know the exercise was concludgj? '
A I don't think I knew that and I don't think I was i concerned because I didn't have students, and when ,
they got to the point of either shelter or ovacuatior..
that ended it for me and in fact I would guess rv ,
eeople even left there then.
Q75 If the schools had been open that day would you have taken further action or do you know? :
e A I would have participated in.the plan in whatever that would be, s Q76 And do you know as you sit here what the plan would have called for you to do?
A If they had, if we moved to evacuation I'm
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guessing they may have wanted to run some buses _to the schools. And if that was the case, that would ,
have been the extent of it. _,_
We would not have moved students.
Q77 After this exercise was concluded, June 29, were you contacted or interviewed by any federal, state offi-cials, New Hampshire Yankee officials or anyone else
, for your opinions about what occurred or to obtain d '
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information from you?
A I'm sure that Helen Wilson visited wich me because Helen Wilson visits with me often, and I'm sure we discussed it.
Q78 Do you have a specific memory or--
A Well, I do have a memory _because I think there were representatives there evaluating everything, and my memory tells me I said to Helen, how did it a_ll go. I don't remember her answer. But I would have been curious.
Q79 And do you recall when this meeting might have occurred?
A No. I could dig that out of my appointment book if I had to.
Q80 And your best memory is that this involved Helen L Wilson and some other officials?
A It could have. My contact has constantly been with
, Helen. Yes, sometimes she brought other people with ,
her, but that would be unimportant. It would be ;
Helen that would make the appointment with me, it
)~ would be Helen I would talk to.
Q81 And do you recall any more specifically than you've already described what you may have discussed with
- s. Helen or any officials following the exercise?
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A No, I don't. And the reason being is that what woult have to tell me, because I didn't move students, I
)
didn't shelter students. i i
QB2 Do you recall whether you received any written i materials or questionnaires or other documents, since the exercise, relating to the exercise? :,
A No, I honestly don't remember. That's very possible l
if they distributed some questionnaires, then I l
probably filled it out and sent it back to them.
Q83 so if a questionnaire or that kind of material was provided to you, you would have completed it?
A Yes, yes.
Q84 Sitting here though you're not sure whether or not in fact you received such material?
A That's right.
Q85 Since conclusion of the exercise of June 29, have you had any contact or involvement regarding planning I or the exercise for Seabrook beyond what you've already described?
A Yes.
j Q86 What was that?
A Last week my principals met concerning that. I was in Washington, I can't even tell you what they did.
s, Helen came down, she said, I'd like to meet with l
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them and discuss some things. I think it was more
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updating the plan and the names of people and so forth. And I said okay, and I set a date of last :
Wednesday at one o' clock at which time they all i met with Helen. And it hasn't been the biggest l thing on my mind so I haven't asked as to exactly what went on.
Qt7 Am I correct that you as superintendent of .Portsmouth '
schools, and the Portsmuvth school system, have !
r cooperated with the state of New Hampshire when asked regarding plans and exercises for seabrook? :
l A Yes.
Qtt Do you know any reason why the exercise was scheduled i
on June 28 as opposed to an earlier date?
A No.
MR. BROCK: Thank you. I have '
nothing further.
MR. HUNTINGTON: No questions.
MR. COOK: No questions.
(Whereupon at eleven o' clock
) in the forenoon, the within deposition was then concluded)
/W sf Art.
THE STATE OF NEW HAMPSHIRE ROCKINGHAM, SS.
I, Donald E. Lamont, a certified shorthand reporter, in and for the State of New Hampshire, do hereby certify that the foregoing twenty-one pages contain a full, true and correct transcript of all of the testimony of the witness TIMOTHY F. MONAHAN, to the best of my knowledge and belief.
IN WITNESS WHEREOF, I have here-unto set my hand and seal this / / day of n 1989.
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Donald E. Lamont, CSR
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/Vi /i a m w.- m Oma w m ea pommacWM NewHAneses casm ames e ne asensassessmems meessem ere mem May 19, 1948 Mrs. Malen Wilson Offiae of Baergemey Management State Off tee Park South 107 Pleasant street -
Concord, MM 03301 Dear lietoa As ta awe drilldieeussed, on May 26,I June will be10,taand ey offtee and available to partistrate June 24.
I hope that by my agreenest I as not devoting three days in the seat month to drille.
However, I will de the best I saa and will be participating.
Yours truly TA Me.~ 3 Timothy F. Monakaa Superintendent of Scheels paw '
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ATTACHMENT 9 f Tot Seacrook From: John S. Pao'illo Date: March 24, 1989 on 3/3/89 I interviewed Mr. Durgin in his office located in Rye, N.H. Mr. Durgin is a school superintendent within the state of N.H. responsible for School Administrative Unit.(SAU) 450. At my request, Mr. Durgin advised me of his involvement in the Seabrook evacuation plan and emergency exercise conducted last June 28 and 29, 1988.
There are four towns which Mr. Durgin is responsible for as a school superintendent:
- 1. Rye
- 2. Greenland
- 3. New Castle
- 4. Newington
'According to Mr. Durgin, as of now, the town of Rye is not participating in anything to do with the plan. The town of Greenland will not participate until commuting and transportation problems are resolved. The town of New Castle has agreed to participate fully in plan activities. The town of Newington is not located within th's evacuation zone.
Mr. Durgin stated that on 6/28/88, Mr. Durgin received a phone call (at his office) from the State Department, and was. i advised that an active exercise was presently taking place for the Seabrook Nuclear Power Plant. Mr. Durgin was not !
. _- ~ -. . - - .-
- Ivyj l instructed to do anything. He did not do anything in response to the call.
After the phone call was completed, Mr. Durgin left his office to attend a meeting held at the New Castle school. The meeting weas not related to the exercise. As he entered the parking lot at the tiew Castle school he noticed a school bus parked in the lot.
He did not inquire as to why the bus was ,
there.
Mr. Durgin does not recall if any principals were '
present in the schools at the time of this exercise. However, ne stated that there could have possibly been some school !
administrators present within the building at the time of the exercise. On 6/29/88, Mr. Durgin did not receive any notification of an exercise being demonstrated that day, and nad no involvement in the exercise. .
Mr. Durgin also discussed his role in the evacuation plan, After Mr. Durgin receives a phone call notifying him of an t alert, his first respnse is to contact all the principals of the schools within his region. The principals in turn spread the word throughout their schools and take proper steps in evacuating. In the event that Mr. Durgin is unable to be contacted, a designated contact person takes his place and acts as a substitute. This contact substitute would most likely be.
Mr. Durgin's secretary Mary Lou Stevens.
According to Mr. Durgin he was aware of 3 to 5 prior exercises.
-Further pertinent comments made by Mr. Durgin are listed D'10W' . _ -_ _ . __.
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E If principals of these schools are not available, their assistant principals would then assume their role during ,
tne time of an actual emergency.
Mr. Durgin has received letters in the past from Seabroon, but does not recall the date of these letters or the ,
s content. ,
Mr. Durgin has in his possession a copy of the Seabrook Station Response Manual.
Mr. Durgin periodically receives written updates on procedual changes in the plan.
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i To: Seabrook From: John S. paolillo ,
Date: March 24, 1989 ,
1 On 3/6/89 I interviewed Mr. William Clancy over the phone, i Mr. Clancy is a achool superintendent of School Administrative i Unit (SAU) # 16 within the state of New Hampshire. The i
interview regarded the emergency exercise conducted last June 28 and 29, 1988 and Mr. Clancy's participation in the Seabrook evacuation plan.
The following towns fall under Mr. Clancy's jurisdiction:
L. Exeter ,
- 2. Stratham j
- 3. Newfield
- 4. Brentwood ,
- 5. Kingston
- 6. Kensington At the time of the 6/28/88 exercise, Mr. Clancy was away on vacation. However, Mr. Clancy's secretary did receive a phone call notifying the office of an exercise.
According to Mr.
Clancy, no_ action was taken by his secretary except for
__receivina the phone call. Thisphonecallwastheobly u
involvement of Mr. Clancy's office in the June 28-29 Exercise,
/
If something further had occurred, Mr Clancy expects that he would have been informed.
Mr. Clancy's understanding of the evacuation plan is as follows:
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i He receives a phone call notifying him of an emergency.
Mr. Clancy contacts the principal in ecch individual school within his district.
The schools handle the dispersement of students to buses for evacuation.
Students are taken to designated areas.
Mr. Clancy suggested that the exercise be conducted during a time when school was in session.
Helen Wilson agreed with Mr. Clancy's idea of conducting the exercise when school is in session.
1 or 2 prior exercises have taken place; one of them included a telephone exercise.
Mr. Clancy has in his possession a copy of the Seabrook Station Response Manual.
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l61 j INTERVIEW JOHN pAOLILLO, INVESTIGATOR ,
MARK V. JOYCE, SUPERINTENDENT OF THE l
SANBORNE REGIONAL SCHOOL DISTRICT, N.H.
MARCH 6, 1989 i
ATT: State your full name. I i
JOYCE: Mark V. Joyce.
lt ATT: Okay, and your position? ,
JOYCE: Superintendent of Sanborne Regional School District.
ATT: Okay, now what schools or what town are you primarily designated to as a superintendent?-
JOYCE: It's a cooperative school district formed of the towns of Newton and Kingston, N.H.
(-
ATT: Okay, now I'm going to proceed to last summer, particularly June 28th and June 29th. Do you recall that there was a mock evacuation performed?
JOYCE: Yes, although that was prior to my assumption of my -'
duties as superintendent. At that point I was .
assistant superintendent.
ATT: You were? Okay, now you say you were aware of this mock evacuation. Tell me, how were you made aware of t it?
JOYCE: I believe it was scheduled for sometime in May or June and there.was a preliminary date that had been delayed and the final dates were in late June. i ATT: Okay, now is this notification a phone call or was !
it...
JOYCE:
I was not familiar with that; it was shared with me by my predecessor. .
ATT: Okay.
Now at the time, particularly June 28th the first day, can you recall any events that transpired that you were involved in?
JOYCE: No. I was not here at that time. I was at a state meeting, but as I spoke to Matt Brock the other day, in checking with the office staff here, what happened on that day was that we received a call through the' network that activated our process locally for verifying the number of students in school and so ,
forth. At that time, late June, all schools were closed. So the call was received here but no action '
was taken beyond that,
. . . - _ ~ _ . _ _
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ATT: Okay, do you recall who particularly made that phons ;
call to your office?
1 JOYCE: I don't. Nor does my office staff.
ATT: You don't. Okay, to your understanding what is your I office's procedure on a phone call like this?
JOYCE:
On the first level it's to consult with the schools to get the attendance that day to verify the number of buses that will be used for evacuation purposes.
t ATT: Okay, now you contact the schools directly yourself? i JOYCE: One of my office staff would.
ATT: So you wouldn't be handling that part of it? '
t JOYCE: You would probably do it simultaneously to get that information as soon as possible.
l ATT: Okay, now the contact. people at the school; who would they be? Anybody particular?
t JOYCE:
't The principals.
ATT: Okay, now say they're not available at the time?
JOYCE: The secretaries.
ATT. Okay, now if the call came to your office and you weren't that time?
available; who would then take over for you at ;
JOYCE: Did you hear my response?
ATT: No, I didn't.
JOYCE: Did you hear what I said? My assistant would take over.
ATT: Oh, your assistant would.
JOYCE: Yes.
I ATT: Okay, and he would act along the same lines you would if you were there?
JOYCE: Yes, she would.
ATT: Oh, she would. Now, getting back to the second day of that evacuation, the 29th. Were you made aware of any l proceedings then involving your office?
l l JOYCE:
The extent of the recollection was that there was a call, one call.
, _ . , _ - _ _ _ . _ . ~ _ _ _
- i ATT: :
On the 29th?
JOYCE: ;
It was late June and that because schools were closed. Our follow-up network was not used, as I previously stated. They don't recall who called other ,
than it was part of the plan testing that they were aware of.
i ATT: Okay, so it was only the one call. What do you particularly expect as far as your office's -
involvement goes in something like this? Do you >
understand fully what your role is to be? !
JOYCE: Well, in terms of the test, it was my perception that we understood what our role was. Once we know we got i the final procedure all established and we know that Seabrook is going to be a working entity, then we would review those and make sure that we were crystal clear on it, But it's been six, seven, eight months since the test date and we haven't really had any follow-up discussions following that. ;
ATT: You haven't. Have you received any documentation since then?
JOYCE: I have not, no. I have had a meeting with a couple of ;
individuals from Seabrook. I think it was in i October. At that point they were awaiting the final desposition of, I believe, both the elections and the future of Seabrook. Since that time, I've had no future meetings with anyone from Seabrook, nor from the evacuation nor from the State.
ATT: Okay, so there's been no written documentation that's been sent to you directly, JOYCE: Not since my tenure here in this position,here, no.
That was effective July 1, '88. {
ATT: Okay, to your knowledge is anybody in the schools that fall in your district been involved directly?
JOYCE: Since that time?
ATT: At that time and since that time. '
JOYCE: Not since my involvement in my roll as
\ superintendent. We have received, let me think here,
) over the summer we've received the radios, dispatch radios that would be used in each school. But I don't believe any communication has gone directly to principals to my knowledge. l ATT: Okay, so the first initial step would be contacting your office and...
l
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In torms of the notification procedures?
ATT: l Exactly, exactly. i word down, Then you're expected to filter the t
JOYCE: Yes, sir. .
ATT: Okay. Back on June 28th, !
I'm just going to back up for just a second; to your knowledge, were any of the principals in the schools at the time of the demonstrations?
JOYCE:
I can't be precise about that. -
I know that several of that was the state's superintendent meeting,us w state's principals came. so the ,
ATT:
Okay, schools, do at you those knowtwo whos the principals were at those the same people now or.chools ..
at the time? Are they JOYCE:
Yes, they're all the same individuals.
to whether or not they were in school that day.I can check The as school was district closed; there were no students in the at that time.
ATT:
Okay, so there could have been people but to your T
knowledge you're not sure right now.
JOYCE:
There were no students.
ATT: ,
Okay, a>! ministration... I didn't mean students, I meant faculty or JOYCE: There was no faculty. There may have been administrative or maintenance personnel.
ATT: Okay.
you wereNow that particular day, the day of the 28th, at, meeting? as you say, a state superintendents' l JOYCE: Yes, sir.
ATT:
! And where was that held?
JOYCE: North Conway.
ATT: Okay.
that you work in?Now how far is North Conway from the district JOYCE:
An hour and a half ride.
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ATT: Okay. At any time during that day that you were at the meeting, did you notice anything that was ;
transpiring as regards to this evacuation, any buses or anything that you might have noticed?
JOYCE: In North Conway? :
ATT: Anywhere in particular that you were that day. No?
JOYCE: No.
L ATT: Okay. Prior to last June, to your knowledge, has your '
office been involved in any other contact regarding a mock evacuation? i JOYCE: Yes.
There's been estensive involvement over the last couple of years in terms of receiving training from the Seabrook personnel. I participated in a community '
test done Saturday in Kingston as a representative of the office. I participated in the Newton test on another Saturday and regulations in terms of our i responsibilities were reviewed in meetings with, I '
believe, Helen Wilson and another lady named Becky...I forget her last name....throughout that kind of ,
development phase. We also have a training program j for administrators and then we have a subsequent training program that was volunteer for staff members ,
who were interested.
- ATT: Okay. Do you recall how many of these training programs or exercises were offered...
JOYCE: I don't.
ATT: ... prior to the June 28th date of last year.
JOYCE: There were several but I don't recall how many. .
ATT: Okay, I just have to back up on one of the questions again. To you knowledge again, the schools were not contacted directly as far as an evacuation goes?
JOYCE: On the June date of 19887 h ATT: The June date or any other date.
JOYCE: prior to that time we practiced calling, yes, but not on the June date.
ATT: Not on the June date. Now on the prior dates would they have been possibly contacted directly?
JOYCE: No, they would have been contacted though our office.
L.--. _ - - _ - _ _ _ _ _ ____- _ _.___ _ _ _ _ _ _ _ _._________m ___.m., _ _ _ _ . _ . . m., y -_. ,_ .,, ..__.,,,.,., .-.__.-.,,--__,--.._--,....,,._r.,
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ATT: i Okay, so the procedure trould've been the same.
Contacting your office ~, then you contact them. I JOYCE: Correct.
ATT: Okay.
schools To-vour knowledan. were any orincioals ne +he !
or the faculty or anybody who works at the school directly been involved in any one on one contact with the Seabrook people 7 ,
JOYCE:
Yes, they were all part of a training program. l ATT: ;
Okay, now particularly on the 28th, to your knowledge. I JOYCE: 28th, to my knowledae, no. ;
ATT: Okay. t Now you say you just took the post of superintendent over recently, correct? t i
JOYCE: Yes.
ATT: How recent?
JOYCE: July 1, '88.
ATT: July 1, :
'88. Now any documentation that your office received before then regarding this evacuation, was l' that facillitated to you?
JOYCE: Yes. A whole file of changes were being sought.
ATT:
Okay, did you talk to your predecessor regarding this evacuation plan? i JOYCE:
He was here prior to that date so I wasn't aware of the other training programs that we've had and we had ,
that prior to the transition with my predecessor and the representatives of Seabrook last spring. ;
ATT: Did you talk to him about the June 28th exercise in particular? ,
JOYCE: At the time I can recall meeting there,-it was...the date wasn't yet established; it was sometime in May or June and as I've previously identified, those dates were changed.
ATT: Okay.
y Do you feel comfortable about speaking with your predecessor and your entire staff as far as ,
identifying the participation on June 28th?
JOYCE: I feel comfortable. Well, I spoke to them about it.
and degree to their Irecollection that's what occurred and to that feel comfortable. ,
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ATT:
Did you speak to your predecessor after this excercise?
JOYCE: No. I spoke to the office staff who were here. ,
ATT:
Okay, then before this exercise or following them afterward, his involvement was eliminated totally? :
JOYCE: Yes. Yes, he was gone from the cistrict.
ATT: Okay.
7
_Do you remember ~who got that phone call that __
JOYCE: Yes.
ATT: Can you tell me who that was?
JOYCE: Karen White. .
ATT: I'm sorry. Can you repeat that? Karen White?
JOYCE: Yes.
ATT: Okay, and she is...
JOYCE: She is the secretary in my office. .
ATT:
Okay, and you've talked with her about this, about that particular phone call and about the June 28th proceedings? hello?
JOYCE: Yes.
ATT:
Have you spoken to Karen White since then about that particular phone call?
JOYCE: Yes.
ATT: Okay. Since the June 28th exercise, has there been any other phone contact made to your office regarding any upcoming drills or any upcoming training programs or anything involving...
JOYCE:
Then the meeting in October which I previously talked about and that's the extent of my contact with anybody from...
ATT:. Okay, so that's the latest that you've received anything.
JOYCE: Yes, sir.
ATT: Have there been any briefings regarding the June 28th exercise?
i
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.o JOYCE: :
Not to of.
a part my knowledge; not that I've been invited to or ATT:
Okay, I'd like to ask you right now, Dr. Joyce, to advise me that you had knowledge that this conversation was taped. '
JOYCE: Yes.
ATT: Okay, would you just state that?
JOYCE:
I had knowledge that this conversation was taped.
ATT: Okay, that's fine.
for taking the time to....I just want to thank you very much JOYCE: Okay.
ATT: ...to speak to us....
JOYCE: You bet, t
ATT: ...and everything like that. I'm going to turn the conversation over to Matt Brock. ,
JOYCE:
How Matt can speak loudly rather than just whisper.
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/
INTERVIEW JOHN PAOLILLO, INVESTIGATOR GEORGE TUCKER, DEAN OF STUDENTS pHlLLipS EXETER ACADEMY, EXETER N.H.
MARCH 6, 1989 ATTY:
Okay, can you please state your full name please?
TUCKER: Yer. George Tucker ATTY: Okay, and your position?
TUCKER:
I'm a Associate Academy. Dean of Students at phillips Exeter ATTY: Okay. Now, the district that you are in charge of?as Associate Dean, w TUCKER:
about 1,000 students.It's just a single private school in New H ATTY:
Okay, so it'scorrect?
jurisdiction, just one school that falls under your TUCKER: Yes.
ATTY:
Okay, Mr. Tucker, are you aware that last June, specifically June 28th and June 29th, there was a mock exercise?
TUCKER: I'm not, I I was away for summer vacation at the time.
that that drill tookabout left the academy June 15th, so I wasn't aware place.
ATTY:
date itself?Okay, you were not aware of that drill previous to the TUCKER: No. {
ATTY:
Okay, that day? to your knowledge was your office contacted on TUCKER: No, not to my knowledge, I've asked people in the immediate office and they don't recall that any call was made about June 28th or 29th.
ATTY:
Would you expect to know about it or informed about if communication had taken place at that time? it TUCKER:
Well the contact person here is Mrs. Susan Herney who is Dean of Students and second on that list would be' my thatnamecall.and neither one of us received a note about l
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ATTY:
What specifically is your school's involvement in this plan or you yourself? What is your-specific involvement?
TUCKER:
I'm not sure rephrase on that? how to answer that...could you ATTY:
Well, in the evacuation plan itself, do you understand the evacuation plan I'm talking about?
TUCKER: Yes.
ATTY: Okay. What is your responsibility in this plan?
Your's specifically?
TUCKER: We are responsible for following whatever recommendation the N.H. Civil Defense makest it could be to shelter our students in the dormitories or perhaps move them to the gymnasium for evacuation. In the plan there are several responsibilities that the Dean of Students office has. Generally, it's attendance taking and notifying dormitory faculty about the steps that have to be taken.
ATTY: Okay. What are the specific lines of communications if such an evacuation were to take place?
TUCKER:
Through the Dean of Students and the principal's office and ourtosafety dormitories and other facilities on campus department.
ATTY:
Okay, who would contact the Dean of Students?
TUCKER:
I understand that representatives from the N.H. Civil Defense Students. would initiate the calls to the Dean of I ATTY:
Okay, so they would either contact you directly or the dean itself.
TUCKER: That's correct.
ATTY:
Okay, and from there you would contact the principals and that would filter down the .line?
TUCKER: That's right.
ATTY: Okay.
Now, specifically on the June 28th exercise, you've advised me that you had no recollection that this was taking place. Was there any follow-up in this that...
evacuation, any documentation that made you aware l
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TUCKER: No, not that I recall.
at least. Not that came directly to me, '
i ATTY:
How did you find out that there was one? ,
TUCKER: i The call f rom your colleague a couple weeks ago.
ATTY: Okay, so no one else in your office or anyone else from N.H. school board or anything else made you aware '
of such an evacuation?
TUCKER: No.
ATTY:
Now at the time on June 28th the schools, I assume were not in session.
i TUCKER:
That'sabout June, right;.I thethink 22nd,the public schools ended in last year.
ATTY: Okay, the answer's the 22nd.
your specific school at the time?Was there anybody in TUCKER: Were there any students? I'm sorry, I didn't hear that. !
ATTY: l Was there anybody present in the school _on June 28th '
or 29th whether it be students or faculty...
TUCKER:
There wauld-have been a maintenance staff and a small !
group of administrators working but no teachers or stuaents in session. .l ,
1 ATTY: 4
, Okay, this staff that could've been working at that !
t
' time, to your knowledge were they contacted in any way?
TUCKER: !
i Not to my knowledge.
i' ATTY: !
l Were there any administrative officials in the school st that time, to your knowledge? ,
TUCKERr 1 Yes, there of that week would have been administrators working at the year. ' i l
ATTY: But as far as you know, they were not?
TUCKER: They were not contacted?
ATTY: They were not there. .
TUCKER:
No, I would expect that between ten and a dozen school administration people were working that week.
ATTY:
Okay, but they were not contacted to your knowledge?
l
/62 )
TUCKER:
I have been able to learn from conversation with them.
ATTY:
Okay, now if they were contacted, would you expect to be advised of that?
TUCKER: Yes, I would expect at least a note that the call's been made.
ATTY: That the call's been made. Okay, say supposedly that :
a call did come through and you and...who was the other contact person you mentioned?
TUCKER: Susan Horney.
ATTY: Okay, is thereif anyone the twowithin of you weren't available at the time, would take over as a...your office, in your roleanyone or in yourelseplace?
who TUCKER: Well, the other that might be contacted are the Vice-principal or principal or the Director of Safety.
ATTY: Okay, they would be the people after you cannot be contacted, correct? Do you understand what I just asked? '
TUCKER: L'e s .
ATTY: Okay, so if you weren't able to be contacted, then 9
whoever is below you in the line of administration. '
would be contacted.
1 TUCKER: That's right.
ATTY: Okay, so everyone is made aware of your school's role in this plan...the actual role that you'd take...the procedures.
Okay, now do you have specific '
documentation f rom Seabrook outlining the procedures of this plan?
- TUCKER
- Yes, we do.
ATTY: Okay, does the booklet have a name or does '
it...
l TUCKERr Well, I don't have it here right in front of me but '
we're a special facility within the town of Exeter.
ATTY: Okay, this outlines your role, you know, that specific part of the plan, outlines your role in this evacuation, correct?
l TUCKER: Yes.
l ATTY: Okay. Have there been any updates, documentation you might have received since then...since the June 28th mock drill?
l
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TUCKER: No, I haven't 4
June. received any current information since ATTY:
You information, haven't received correct? any written documentation or Is that correct? ;
TUCKER: That's correct. i ATTY: Okay.
What about any phone contact of any kind to update any proceedings in any way?
TUCKER: No, I haven't received any communications from N.H. or Seabrook about this.
ATTY:
Okay, prior to the June 28th, Jun's 29th mock drill, do youanything or recall any other previous regarding this case?or any training programs ,
TUCKER:
There was a drill, I think it was about January 20th or been 23rd '87and andI not just '88.
remember that date, but it may have So it was a phone drill in which we center. did receive a call from the Exeter emergency ATTY:
Okay, were you present at the time of this call?
TUCKERT: Yes, I was. '
ATTY: Okay.
l the call came through?
What exactly transpired, do you recall after TUCKER:
It's just a call indicating that they were testing the phone tree and that we just acknowledged receipt of the call. That's really all it was.
ATTY: This was not the 28th? ,
TUCKER: No.
This was not the 28th of June. This was in January...it January '87.
may even have been not January of '88 but ATTY:
So, previous of the June 28th mock exercises only been one conducted?
other exercise to your knowledge that's been
+-
TUCKER: That's right.
ATTY: And that was a phone exercise, correct?
TUCKER: Yes.
ATTY:
Okay, prior to that particular phone exercise, did you receive any information pertaining to that exercise?
I mean, were you made aware that this was going to take place?
_ _ _ _ - . . - - --- ~ ~ ~ ~ ~~ ~
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TUCKER: Yes, we were.
I remember notification that this drill, the one in January, was going to take place.
ATTY: Were you made aware of this by phone or by written contract?
TUCKER: By phone.
ATTY: Who exactly called you, can you tell me? !
TUCKER: I don't recall. It may have been...we've had a series of meetings over the past several years that may have :
been a woman who was working for the New Hampshire i Civil Defense. I can't recall her name at this point but it may have been that person.
ATTY: Okay, so the phone call is made to your office and ;
they made you aware that a mock exercise was taking place, correct? t TUCKER: Correct.
t ATTY: But you did not get a similar notification for the L June exercise that took place last year? .
i' TUCKER: No, I didn't.
s 4
ATTY: Okay. Let me just go back to the June exercise for a second. I know you were away at the time, but did anyone from your office or anybody from your faculty staff observe any activity relating to this exercise? -
TUCKER: I don't have any record on that, but I really can't speak for other people who might've seen activity in town. It's a very big school with 300 employees so :
l they may have seen something but I couldn't tell because I was away.
ATTY: Okay, now this exercise that was conducted last June...your understanding was that school was not in session at this time. Did you in any way point this out to any of.the Seabrook contact people, that possibly they should conduct an exercise when school was in session?
x TUCKER:
The first notification that I had about this drill on
/ the 28th was the call from your colleague a week or so ago scheduling this conversation. Otherwise, I hadn't heard about it at all.
ATTY: Okay, I think that's about all I have to ask you. I' !
just want to ask you one more thing. To your knowledge this conversation has been taped; can you just state that you-do understand that this conversation has been taped?
d
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TUCKER:
Yes, I am aware that this conversation has been taped.
ATTY: Okay. Well, I thank you very much for your time. l I'm going to turn the tape off now and I'm going to turn i the conversation over to Matt Brock. But thank you jl Very much for your time, Mr. Tucker.
TUCKER: Your welcome.
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ATTACHMENT 10 DOGEY WOLATICMS 4'.1 SAGE FGW Criginator Msg.
- seer: E-1 Date: 4hr8P Time: //,') 7
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Messeos Class: Action Class:
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C Routine:
Info To:
i O Governor a CAP Pupil Trene. C Utilities C C.D. Director C Agriculture O Red Cross C Fed. Aar. (Scotify]
C St. Police C EMS C ORED C C Putdic Health C Fish & Game C WSAPC C N.H.C.D.A. (Specify]
C Nat'l Guard C Highway C Welfare C l C Status Boards C Other (Specify]
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Dats/ Time Group Date/ Time Group: -
Operator.Numa, Operator Name:
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