ML20147D631
| ML20147D631 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 01/07/1988 |
| From: | Earl C RESOURCE MANAGEMENT SYSTEMS, INC. |
| To: | |
| Shared Package | |
| ML20147D594 | List: |
| References | |
| OL, NUDOCS 8801200239 | |
| Download: ML20147D631 (26) | |
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January 7, 1988 00 K EO UNITED STATES NUCLEAR REGULATORY COMMISSION 38 J@l 19 A11:06 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD
)
OfflCE Of SECEtiAa -
00CMET. r ijvicg In the Matter of
)
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Public Service Company of
)
New Hampshire, et al.
)
Docket Nos. 50-443 OL
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50-444 OL (Seabrook Station, Units 1 & 2)
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OFFSITE EMERGENCY
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PLANNING
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REBUTTAL TESTIMONY OF CLIFFORD J.
EARL REGARDING CONTENTIONS NHLP-2, SAPL-8, SAPL-8A, AND TOWN OF HAMPTON REVISED CONTENTIONS IV AND VI QUESTION 1:
Please state your name and qualifications.
ANSWER:
My name is Clifford J.
Earl.
I am the President of Resource Management Systems, Inc.
I am an expert in the area of public sector resource planning and management, including public sector staff resource needs planning.
I submitted written direct testimony in this case on September 11, 1987.
A resume detailing my qualifications is attached to that prefiled testimony.
QUESTION 2:
What is the purpose of your testimony today?
NEW:
My purpose is to discuss my evaluation of Applicants' oral and written testimony in this proceeding regarding Applicants' Personnel Resource Assessment Summary (hereafter "Summary") and the underlying survey they conducted in order to determine the adequacy of personnel to carry out an offsite emer-gency response at seabrook.
I have also evaluated documents used by Applicants in conducting the personnel resources survey.
These documents were identified and provided by Applicants, l
through the discovery process, in December of 1987.
l l
hk fjylK9 800107 050004 3 T
F
-2 QUESTION 3:
Please summarize your prefiled testimony of September 11, 1987, and state whether the oral and written testimony submitted by Applicants has affected your evaluation and conclusions in any - ay.
ANSWER:
My testimony of September 11, 1987, evaluated the reliability of the Summary prepared by Applicants in support of their conclusion that adequate personnel are available to support an offsite emergency response during an accident at the Seabrook nuclear power plant.
The principal focus of my evaluation was the methodology used to determine (a) staff requirements or needs and (b) staff availability.
Essentially, I found four serious weaknesses in the Summary: (1) failure to provide definition of the key term "availability;" (2) failure to quantify the workload for each position to be filledt (3) the ambiguity of the "walk-through" procedures performed by Applicants for the purpose of assessing staffing requirements; and (4) the apparent lack of consideration of potentially critical variables, such as the amount of time required to implement protective actions.
Based on these defects in the methodology, I found unreliable the Summary's principal i
conclusions that a) the ',ocal governments in the Seabrook Emer-gency planning Zone ("EPZ") have sufficient personnel to ade-quately respond to an emergency at Seabrook, and b) the State of New Hampshire has adequate personnel to provide assistance to local governments, as discussed in Volume 2, Appendix G of the l
New Hampshire Radiological Emergency Response Plan, Revision 2.
l I
. My evaluation and conclusions have been confirmed by Applicants' testimony.
The testimony also revealed the lack of consistent data sources, and a weak managerial and supervisory structure for conduct of the survey, which further undermined the reliability of the Summary.
Finally, I do not believe that the methodology used to gather the data is defined well enough that it can produce reliable results in the future, when Applicants have testified that it will be used to update the personnel data and possibly form the basis for decisions during a radiological emergency at Seabrook.
QUESTION 4:
Please explain your answer.
ANSWER:
The overall purpose of staff resource assessments is to assure that sufficient personnel resources are present when needed in order to achieve the objectives of an organization.
It is generally accepted that staff resource essessments are con-ducted in two phases:
first, staff requirements or needs are specified; second, the availability of required resources is determined.
The results of these analyses are then used by deci-sionmakers to determine the capacity of an organization to achieve its stated objective or objectives.
Reliable staff availability assessments are dependent on the results of the staff requirements assessment.
Once the critical staff requirements have been established, a variety of staff availability assessment techniques may be used.
They can be very
[
simple or very complex.
As with staff requirements assessments,
-4 the selection of an appropriate methodology depends on a number of factors.
One particularly important factor is the degree of importance placed on aa. urate data.
In this case, the circumstances appear to require that the data produced by Applicants' survey be highly accurate and reli-able.
It is my understanding, based on NUREG-0654, that the results of the staff needs and staff availability assessments should demonstrate the capacity of the emergency radiological response organization, including its plans, procedures, and staff, to fulfill their reason for being, i.e.,
to provide dose savings (and in some cases immediate life saving) for a spectrum of accidents that could produce offsite doses in excess of Pro-tective Action Guides (PAGs).
The importance of the data pro-vided by the Summary is confirmed by the Summa;y itself, which states that it is intended to show that
"... reasonable assurance is provided that a radiological emergency response can and will be implemented in response to an emergency situation at Seabrook Station."
Summary at 4-1.
This statement suggests a high degree of reliance at both the initial decision-making phase and the implementation phase in the event of a radiological emergency.
Given the foregoing conclusion, it is not unreasonable to expect a high degree of reliability in the data generated by the survey.
The degree of reliability, and consequently the degree of confidence which a decision maker may have, in the numbers gener-ated by a resource assessment, is highly dependent on the techni-
. ques used to formulate the prediction.
In general, the better the technique the more reliable the prediction.
In this case, the techniques used did not meet even the minimum standards employed by resource planners to predict personnel resource needs or availability.
These minimum standards include (1) use of con-sistent data sources, (2) the definition of key terms, (3) the definition of key assumptions, (4) clear and consistent defini-tion of the methodology to be used, and (5) the use of controls to assure the consistency and accuracy of data collection and analysis.
My testimony addresses each of these factors in rela-tion to the staff needs assessment and to the staff availability assessment.
1)
Lack of consistent data sources It is an important precept of personnel resource planning that data sources should be consistent.
By this I mean that planners should attempt to use the same sources cf information for each organization surveyed, and that they should also use the same sources as they update their surveys over time.
This is important for a number of reasons:
(1) it minimizes the variability in the reliability of information obtained from dif-ferent organizations; (2) it helps ensure that the same data sources can be used over time, particularly in the case of an "ongoing program;" (3) it is susceptible to verification; and (4) it helps ensure that the data can be secured on a regularly scheduled basis without committing substantial numbers of person-nel to engage in time-consuming data-gathering activities.
. In this case, the data sources and collection procedures
-varied among state agencies, among local agencies, and between stste and local agencies.
They also varied across time.
For instance, the survey materials used for the Division of Public Health Services included a letter from the Director to agency l
employees, seeking their agreement to participate in an emergency response, [Tr. at 3409-3410), and the responses to that letter.
SAPL Exhibit 3, Tr. Post 3433.
The contacts with personnel who were asked to serve resulted in numet us refusals, thus having a significant effect on the availability data reported for that agency.
In contrast, no such letters or responses were provided for other state agencies or for any local agencies.
Rosters used for personnel planning purposes, which were provided to NECNP in discovery during December, also differed significantly between state agencies.
While the New Hampshire Department of Trans-pertation roster contained a list of named individuals with their geographic assignments, the National Guard roster omitted names but consisted only of unit assignments, location, and number of personnel.
On the other hand, the Bureau of Emergency Medical Services apparently provided no list at all.
Moreover, the sources of personnel data for full-time, part-time, and volunteer workers were not consistent between organizations, or jurisdic-tions.
Finally, as evidenced in the Applicants' testimony, a number of the personnel requirements and availability estimates provided w
-7 in the survey and Summary have changed over time.
While change in itself does not necessarily reveal error in the survey, it would be difficult to verify the reliability of the changing data because of the variability in the data sources.
The Applicants' heavy reliance on oral representations, which tend to be more
.subiective and variable between individuals, makes the data espe-cially difficult to verify.
Further, due to the absence of a common understanding of the key term "available" or "availability," the data were susceptible to variations in individual interpretations applied by persons gathering, compiling, and/or verifying the data.
In my opinion, these were critical flaws which rendered unreliable the data obtained in the Survey.
I would note that my criteria do not include complete accuracy of data obtained.
As Mr. Strome noted during the pro-ceedings, the numbers are unlikely to ever be "totally accurate."
Tr. at 3336.
The key considerations are whether the numbers are sufficiently reliable to (1) predict personnel resource needs and availability in the event of a radiological emergency, and (2) permit decision-makers to make an informed judgment.
Based on my review of the testimony and the survey documents provided by Applicants, I find there is no basis for such a conclusion.
2)
Failure to define concept of "availability" Applicants' testimony demonstrated a lack of clear and con-sistent understanding of the term "availability" throughout the
-8 preparation of the Summary and underlying survey.
Although one of the principal goals of the survey was to determine the "availability" of personnel, no written definition of the term "available" er "availability" was provided to the parties gather-ing or compiling data for the Summary.
Tr. at 3253.
No defini-tion of the term is given in the survey materials that Applicants apparently used to interview state and local officials regarding-the availability of their employees to perform emergency response functions.
One might reasonably anticipate some variance in definitions of the term as provided orally by interviewers and/or their supervisors.
In fact, this was borne out by the testimony, as discussed below.
The lack of a common understanding of the key term "availability" is a serious deficiency in a study such as this one, where many different people were responsible for gathering and evaluating the data assembled in the survey.
Tr. at 3201.
These responsibilities included a) gathering staff availability data, b) providing staff availability data to reviewers, c) com-piling staff availability data, and d) assessing staff availability data.
Ultimately, the data must also be relied upon for decision-making purposes.
At each of these stages, and by each individual participating in the survey and Summary prepara-tion, a different concept of the term "availability" might be applied.
The lack of a common understanding of the term would apply equally to situations where every person participating in
- the assessment process had extensive staff assessment or emer-gency planning experience.
Applicants' failure to apply a common understanding of the term "availability" was illustrated in the oral testimony of Applicants' witnesses.
When asked to define the term "avail-able," Applicants' witnesses gave definitions that were ambiguous and subject to varying interpretations -- or misinterpretations.
Mr. Renz, the person responsible for assembling the Summary and partially responsible for the conclusions, stated the definition from an emergency planning perspective:
"...the term denotes persons that are candidates for fulfilling, or are on hand for fulfilling emergency response positions."
Tr. at 3254.
On the other hand, Mr. Callendrello, who had general cupervisory respon-sibility for the survey and Summary, testified that "[t]he definition that we used is those personnel that are at hand; these personnel that are within the organizations that we identified as potential personnel resource pools."
Tr. at 3314.
There is significant room for variation in the interpreta-tion of the terms used by Mr. Renz and Mr. Calendrello.
"On hand" or "at hand" could mean any number of things, including people who are physically present at the site of the emergency, people who are capable of eventually being present, or simply the total number of peopic in a given employee population, regardless l
of location.
Similarly, the term "candidate" could mean someone who meets the qualifications for a task, or simply someone who l
l
. might conceivably meet them.
It is notable in this context that another witness, Mr. Bonds, expressed uncertainty regarding the qualifications of laboratory workers to fulfill their responsibilities under the New Hampshire RERP.
Tr. at 3438.
None of the terms employed by Applicants' witnesses to describe the concept of "availability" necessarily includes a clear under-standing of which people will respond to a Seabrook accident, whether they are competent to carry out their assignments, how they will become available, or how and when they will appear at their duty stations.
As I testified earlier, Applicants should have demonstrated a clear and consistent understanding of these considerations in preparing this personnel study.
Further, persennel rosters were used for scme towns but not i
others, and off-shift availability was not considered.
The assessment personnel relied heavily on verification meeting dis-I cessions for confirmation of assessment findings.
For example, Mr. Callendrello was asked if full-time employment was the uniform criterion in defining the term availability.
He stated "No, that was not."
Tr. at 3315.
Subsequently, he stated that
"(1]t varied from organization to organization. In some cases, the entite pool of personnel were utilized if the emergency response individuals indicated that they would norma?
1se them.
For example, volunteer fire fighters...if consistent with that community's wishes, those were listed as available resource pool for the purposes of emergency response."
Tr. at 3315-16.
While I
l
. the witnesses stated that an effort had been made to identify persons with potentially conflicting commitments, there was only a limited effort to determine leave or disability status.
Tr. at 3318.
In placing substantial reliance on a community's "wishes",
or on the opinions of "knowledgeable persons," without applying any independent criteria, Applicants demonstrated a failure to apply a consistent definition of terms.
In effect, they allowed local officials to determined the meaning of "available" on a case-by-case basis.
Such an.ad hgs and inconsistent approach cannot be expected to yield reliable information.
An example of the problems inherent in this approach is that 24 temporary employees, most of whom are high school students employed to pick up trash, are considered "available" to perform emergency response functions of the Hampton Public Works Department.
Tr.
at 3341.
Despite the obvious inadvisability of using high school students as emergency response workers, Mr. Strome testified that he considered reliance on the students acceptable if it was con-sistent with the wishes of the Hampton Director of Public Works.
Tr. at 3341-42.
The absence of a common, consistently applied definition of the term "availability" renders unreliable the numbers (i.e.
data) produced by the personnel survey and any numbers derived l
from the survey.
Consequently, the validity of any conclusions which rely on the numbers is questionable.
l l
l 3)
Ambiguity of the "walk-through" procedure Applicants relied substantially.on so-called "walk-throughs" to quantify personnel needs for an emergency response at Seabrook.
Applicants' testimony demonstrated, however, that there is no basis for noncluding that (a) there was a common understanding of the term "walk-through," (b) that the walk-throughs were consistently executed, or (c) that the procedures would in fact produce the intended results, i.e. reliable quantification of the number of personnel needed to fulfill emer-gency response tasks.
The lack of a common understanding of the term walk-through was made clear in the testimony.
The term was not defined in writing, and there were no written procedures for completing the walk-throughs for the staff persons conducting the assessment.
According to Mr. Renz, "not having Written instructions on l
how to perform a walk-through is not out of the ordinary."
Tr.
at 3252.
However, there seems to be some significant variance in the term as used by these emergency planners.
According to Mr.
Callendrello, an emergency planner, the basis for assuring a com-mon understanding, and presumably execution, of the walk-through procedure was that "...each of the persons who were working through these procedures are emergency planners, and they are used to dealing with a procedure in this manner.
That is, to look at the step, perform an evaluation of whether somebody is needed to perform this step or not.
And if there is a function
. that needs to be performed, assessing whether more than one indi-vidual is needed to perform that function.... all somebody needs to do is read the step and evaluate whether the person whose pro-cedure it is can perform that step alone."
Tr. at 3277.
Mr. Renz, an experienced emergency planner, defined "(a) walk-through in the procedure, one goes through the procedure to see if it works...."
Tr. at 3252.
This testimony showed two fundamental problems with the Applicants' concept of a "walk-through."
First, Mr. Callendrello and Mr. Renz apparently differed in their understanding of what constitutes a "walk-through."
Reading a procedure is not the same as going through a procedure to see if it works.
One might analogize the difference to the distinction between reading a recipe to see if it will yield a satisfying cake within a cortain amount of time, and going through the steps of making the cake.
Obviously, the second approach yields a far more reliable result.
In this case, the testimony showed that the emergency planners responsible for the personnel survey did not necessarily share the same conception of the term "walk-through."
The second major problem is that a "read-through" is an inadequate means for determining staffing needs for an activity as complex as an emergency response to a nuclear accident.
It cannot reveal such factors as the time necessary to prepare to implement a procedure, to make communications links, to marshal resources necessary to carry out a procedure, or to effectively
- 14 carry out a procedure.
Moreover, while a "read-through" may be an appropriate way to discover whether procedures appear to fol-low each other logically, it cannot be used effectively to determine whether procedures actually work.
Nor is it a suitable means of quantifying work-load, as was allegedly done here.
As I testified earlier, however, there is no evidence that the actual work-load for each emergency response position was in fact calcu-lated in this study.
Neither the Summary nor any of the docu-ments subsequently provided by Applicants contains any calcula-tions of individual work-loads.
Mr. Strome's testimony demonstrated the potential for variability and unreliability of results that are inherent in Applicants' failure to apply a consistent definition of the term "walk-through."
For example, with respect to the one person in the Town of Hampton RERP who was aos!.gned F.ultiple positions, Mr.
Strome testified that "I would prefer that separate individuals assume those responsibilities."
Tr. at 3347.
Although Mr.
Strome was not performing a walk-through (i.e., read through) at the time, it appears that there is some room for variations in interpretation of the number of personnel required to perform emergency response functions even among experienced emergency planners.
Applicants' testimony also showed that they made unreasonable assumptions in conducting walk-throughs of the emer-gency plan.
I believe that the methodologies, and the resultant
. f l
data, were influenced and rendered unreliable by these planning assumptions.
Applicants' witnesses provided important informa-tion regarding two key planning assumptions which may have influenced the planners in the conduct of their walk-throughs to determine staff requirements.
First, in some instances, Applicants assumed that emergency response personnel are at their emergency response duty stations when the need for their function arises.
Tr. at 3286.
No appar-ent consideration was given to notification or travel time.
In my opinion, these are critical factors which would affect the quantification of workload and therefore per:onnel needs in an emergency response.
The Summary gives no explanation of why these factors were not considered.
Moreover, there is no mear.s of determining in what instances mobilization and travel times actue.lly were considered.
Although the survey materials sho'w that for some functions, Applicants attempted to determine mobilization and travel times, they did not do so for all func-tions.
See, for example, Tr. at 3282.
In addition, it is in.possible to determine whether and to what extent mobilization and travel times were considered in performing walk-throughs and other personnel needs calculations.
The second assumption, that everything would go according to plan if the procedures were implemented in full, (Tr. at 3288),
is unreasonable, and certainly it is not a rational basis for determining resource requirements.
It does not encourage the
. kind of detailed analysis which is necessary to produce reliable data.
The basis for both of these assumptions, indeed the assump-tions themselves, was not stated in the Summary.
Norma 31y, I would have questioned the validity of the assumptions on those grounds alone.
However, when I reviewed "The Final Exercise Assessment, Joint New Hampshire State and Local Radiological Emergency Response Exercise for the Seabrook Station Nuclear Power Plant", dated February 26, 1936 to gain some insight into the possible basis for these assumptions, I did not find actual experience in this regard reassuring.
The result of the exercise
-- that many of the required functions were not successfully ful-filled -- would reasonably lead a resource plannar to assume that in any given accident scenario, not all emorgency personnel would be where they were needed when they were needed, and the emer-gency response weald not go according to plan.
This is the oppo-site of what Applicanto assumed.
4)
Failure to consider potentially critical variables Applicants' testimony demonstrated a failure to adequately i
consider potentially critical variables in reaching their conclu-l sions regarding emergency response personnel availability.
As discussed above, for example, the question of whether emergency response workers will arrive at their assigned posts in time to i
fulfill their responsibilities is certainly a matter of concern.
t
(
During the discussion of the walk-through procedures that were l
l l
- 17 conducted in order to determine staffing requirements, Mr. Cal-lendrello agreed that there is some relevance and importance to when the work is begun.
Tr. at 3286.
However, Applicants' testimony demonstrated that in performing walk-throughs, they failed to consistently consider arrival times at duty stations in estimating how many personnel were required to successfully com-plete a given task.
Id2 The Summary does not contain sufficient information to either support the basis for this assumption, or to demonstrate that either local or state compensatory staff could, in fact, arrive at their assigned posts in time to fulfill their responsibilities.
The survey's failu?!e to adequately consider arrival times was highlighted by Mr. Strome's response to a ques-tions posed by Mr. Brock during the proceedings concerning Ju3 availability cf State Police personnel.
While Mr. Strome alleged that some personnel that are within n "reasonable diste,nce," he conceded that "I'm not sure that I have a clearly defined empiri-cal standard for reasonable distant:e."
Tr. at 3372.
The Summary also failed to srow consideration of mobiliza-tion times, even where they had been estimated during the underlying survey.
For instance, while the Summary states that 185 State Police will be available during a Seabrook emergency, the survey documents provided to NECNP during discovery in Decem-ber show that on an average day, only 100 will be available within the first three to four hours.
See Menorandum from G.
Willant to J.
Enoch, dated July 16, 1986.
. 5)
Lack of quality control in managing conduct of surv2y Applicants' testimony demonstrated a failure to manage the conduct of the survey in such a way as to achieve reliable results.
The techniques used by Applicants to determine staff requirements are rudimentary and subjective when compared to the techniques which could have been used.
In order to assure the reliability of data, Applicants should have taken steps to (1) assure a common understanding of key terms used in the survey, (2) assure the appropriateness and consistency of data sources used for all organizations, (3) assure that personnel are suffi-ciently experienced in staff assessments, (4) assure that staff conducting the study are effectively supervised, (5) assure that the analysis and interpretation of the data is consistent, and that the results are cbjectively verifiable (i.e., different per-sons utilizing the methodology woul6 produce the same results).
Applicants' testimony showed ttat none of these important steps were taken to assure the reliability of the personnel data collected.
As a result, there is no assurance that staff availability data produced by the survey are reliable.
The testimony showed a lack of coordination in the man-agerial and supervisory structure for the conduct of the survey.
Mr. Callendrello directed and supervised the resource assessment progran.
Tr. at 3198.
He supervised the gathering of the information presented in the Summary by directing the activities of the lead individuals who were responsible for assembling the
-o material in the Summary.
Tr. at 3198.
These lead individuals (planners), in turn, provided subsequent supervision of staff level people.
Tr. at 3198.
For example, for the people who did the local interviews, Mr. Callendrello stated that "[t] heir activities were directed by their normal supervisor."
Tr. at 3203.
According to Mr. Cal-lendrello, their normal supervisor "...would have been the super-visor within the New Hampshire Yankee Emergency Preparedness Department."
Tr. at 3203.
That is Mr. Frechette "[r]eporting directly to me."
Idz Mr. Frecherte said that he was the supervisor of the 7eople who went and gathered the information.
Tr. at 3204.
Mr.
Frechette said "I supervise those individuals who work either directly or are consultants for New Hampshire Yankee.
There were individuals who worked for the State of New Hampshire involved in this program as well.
And I do not have supervisory capabilities for those individuals."
Id.
This was confirmed by Mr. Strome.
Idi According to Mr. Strome, state survey personnel were super-vised by Mike Nawoj, Chief of the Technological Hazards Division.
Tr. at 3205.
It is thus clear that direct supervisory responsi-bility for the entire group of personnel conducting the assess-ment surveys was divided betwee.1 two supervisors, Mr. Frechette for New Hampshire Yankee and consulting personnel; Mr. Nawoj for the state personnel.
Mr. Nawoj was noc consulted by Mr. Frechette about (1) the methodology to oe used, (2) any common assumptions, or (3) proce-
.. dures to be used in the interviews with local officials.
Tr. at 3206.
Mr. Callendrello indicated that he did not consult with either of the direct supervisors to determine whether those indi-viduals who were responsible for conducting the interviews were using the same procedures and the same unuerstandings of terms.
This wes also true for the walk-through approach used for determining staff requirements.
Tr. at 3207.
According to Mr. Callendrello, Mr. Enoch, a private consul-tant, was responsible for "... assuring that those people collect the data that is needed to provide the input into the program.
The data being the personnel resources'which is gathered by a survey...."
Tr. at 3246 (also for the walk-throughs).
It is not clear from the testimony how Mr. Enoch (1) provided instructions to the persons gathering information or (2) how they were sup-posed to accomplish the task.
According to Mr. Callendrello, "I
think that it was a cooperative effort between Mr. Enoch and the planners in determining the types of information that was needed to be gathered....he has no direct supervisory responsibility over those people.
That responsibility rests with Mr.
Frechette."
Tr. at 3246, 3247.
When asked how Mr. Enoch actually (1) supervised a process, involving approximately 25 staff persons from different organizations, and (2) assured that every one of those 25 people had a consistent understanding of what it was that they were supposed to do, Mr. Callendrello stated that he did not know.
Tr. at 3247.
a
o The Panel was asked if anyone else knew how Mr. Enoch managed the process.
According to Mr. Renz, an independent con-tractor for Aidikoff Associates and the person responsible for compiling the Summary (Tr. at 3246), "my understanding from working with Mr. Enoch is that early on in the process, be sat down with several different emergency planners and developed a methodology...on the local and on the state level for going out and compiling and gathering information...." (this also applies to needs assessment)
Tr. at 3247.
According to Mr. Callendrello
...at least in the case of the survey form, that methodology is written down and is documented by the survey form itself.
So that is the end result of the determination of the methodology.
It culminates in a development of a survey form."
Tr. at 3249.
Furthermore, Mr. Callendrello indicated that he fel*. that the various steps were adequately described in the personnel survey to support a conclusion that accurate data were generated.
Tr.
at 3251.
I have already testified, in my direct testimony, regarding the lack of adequate information provided in the Summary.
In addition, I have reviewed the survey forms that Applicants pro-vided to NECNP through the discovery process in December of 1987.
In my opinion, those forms do not adequately document the exis-tence of an adequate or consistent methodology for conduct of the survey.
As discussed above, the key term "availability" is nowhere defined, although it is used throughout the materials.
s
. There is thus no-indication that the interviewers who used the forms, or the people that they interviewed, shared a common, clear, and consistent understanding of the term; or that the planners who analyzed the data obtained by the interviewers had the same understanding as the interviewers and the interviewees.
Moreover, there is no reference whatsoever to "walk-throughs,"
which allegedly constituted the principal means of determining staffing resource needs.
In addition, the survey forms provided no comprehensive methodology for the gathering of information; in fact, most of the personnel resource questions asked by the survey forms were quite selective, and appeared designed only to confirm informa-tion already gathered by some other, unspecified, means.
No criteria are provided for comparing the previously gathered information to the information provided in the local interviews.
Thus, there is no means for evaluating the reasons why some of the data provided in the Summary differs from the data provided on the survey forms.
Finally, the survey forms fail to provide interviewers or evaluators with meaningful criteria for defining the type of information they are to obtain.
For example, Question # 2 on the survey form entitled "Resource Analysis, Requests /Questiona for EPZ and Host Towns," instructs interviewers to Ensure there are primaries and alternates for each EOC position designated in the plan as 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing.
Attach a list / roster identifying positions which require primar." and alternate staffing.
(Interviewer i
y
. to obtain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing information.
Refer to Sec-tion III, Selectman's Emergency Preparedness Responsibilities and Appendix A.)
There is no instruction to the interviewer as to how to obtain 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> staffing information, how to determine staffing needs for each position, or what it means to "ensure" the existence of primaries and alternates for each position.
Absent any instruc-tion, there is great room for variability in the conduct of these tasks.
Moreover, there are no means for assessing whether the steps chosen by the interviewers were adequate to provide reli-able information.
It also appears from the testimony that a significant por-tion of the staff responsible for conducting the survey may have been inexperienced in the field of personnel resource planning.
While Applicants' witnesses are emergency planners, none of them have any special expertise in personnel resource planning.
More-over, according to Mr Strome, some state trainees were used to perform the survey.
Tr. at 3257.
Although Mr. Strome's answer is not clear as to how many, if any, of the State personnel were very experienced, somewhat experienced, or entry level trainees, it is possible that some of the persons participating in the sur-veys were at or near entry level.
It is clear that (1) the individual who was responsible for the overall assessment program did not personally take steps to assure a common undarstanding of either the terms applied or the methodology used among the direct supervisors of the staff con-
- 24 ducting the survey, and (2) the direct supervisors did not con-sult to assure a common understanding of either the key terms or the methodology.
Further, the consensus of the Panel was that the terms were not reduced to writing.
Given the large number of people performing the survey, and the in' experience of some of them, there was an especially high potential for variability of survey methods and results.
The lack of managerial and super-visory control over the many individuals participating in the study, as well as the many levels at which data were accumulated and acsessed, renders unreliable the meaning and accuracy of the numbers obtained in the survey.
Question 5)
Based on the testimony you have heard, what are your conclusions about the reliability of the data produced by the Survey?
ANSWER:
Given the lack of a sound and systematic methodol-ogy or consistent data sources in this case, I do not believe that the Applicants have produced data sufficiently reliable to support a conclusion that adequate emergency response personnel are available to respond to a nuclear accident at the Seabrook nuclear power plant.
For the same reasons, I do not believe that Applicants have demonstrated the capability to obtain reasonably accurate data if and when they update the assessment in the future.
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CERTIFICATE OF SERV BRANCF-I certify that on January 7, 1988, copies of REBUTTAL TESTIMONY OF CLIFFORD J.
EARL REGARDING CONTENTIONS NHLP-2, SAPL-8, SAPL-8A, AND TOWN OF HAMPTON REVISED CONTENTIONS IV AND VI, were served on the parties to the attached service list by first class nail or as otherwise indicated.
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a Diane Curran
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SEABROOK SERVICE LIST OFFSITE LICENSING BOARD
'Ivan W. Smith, Chairman P.O. Box 710 Backus, Meyer & Solomon hiaplewood Ave.
Atomic Safety and Licensing North Hampton, NH 03826 111 lowell Street Portsmouth, NH 03801 Board h1anchester, NH 03105 U.S. NRC J.P. Nadeau Edward A. Thomas Washington, D.C 20555 Town of Rye
'Sherwin E. Turk, Esq.
FEMA 155 Washington Road Office of General Counsel 442 J.W. McCormack
'Dr. Jerry Harbour Rye, New Hampshire 03870 U.S. NRC (POCH)
Atomic Safety and Licensing Washington, D.C. 20555 Boston, MA 02109 Board Richard E. Sullivan, Mayor U.S. NRC City Hall Mr. Angie Machiros, Sandra Gavutis Washington, D.C. 20555 Newburyport, MA 01950 Chairman RFD 1 Box 1154 Town of Newbury East Kensington, NH 03S27
'Gustave Linenberger Alfred V. Sargent, Chairman Town Hall,25 High Road Atomic Safety and Licensing Board of Selectmen Newbury,MA 01951 Charles P. Graham, E<q.
Botrd Town of Salisbury, hiA 01950 McKay, Murphy and Graham U.S. NRC H. Joseph Flynn, Esq.
100 Main Street Washington, D.C 20555 Senator Gordon J. Humphrey Office of General Counsel Amesbury, MA 01913 U.S. Senate FEMA Atomic Safety and Licensing Washington, D.C 20510 500 C Street S.W.
Board Panel (Attn. Tom Burack)
Washington, D.C. 20472 U.S. NRC
- By hand Washington, D.C 20555 Selectmen of Northampton George Dana Bisbee, Esq.
Northampton, New Hamp-Geoffrey M. Huntington, Esq.
" By Overnight Mail Atomic Safety and Licensing shire 03S26 Office of the Attorney General Appeal Board Panel State House Annex U.S. NRC Senator Gordon J. Humphrey Concord,NH 03301 Washington, D.C 20555 1 Eagle Square, Ste 507 Concord, NH 03301 Allen Lampert Docketing and Service Civil Defense Director U.S. NRC Michael Santosuosso, Town of Brentowood Washington, D.C 20555 Chairman Exeter,NH 03833 Board of Selectmen Richard A. Hampe, Esq.
Mrs. Anne E. Goodman Jewell Street, RFD # 2 1
Bo:rd of Selectmen South Hampton, NH 03S42 Hampe and McNicholas 13-15 New Market Road 35 Pleasant Street Durhim, NH 03842 Judith H. Mizner, Esq.
Concord,NH 03301 Silverglate, Gertner, et al.
William S. Lord, Selectman SS Broad Street Gary W. Holmes, Esq.
Town Hall-- Friend Street Boston, MA 02110 Holmes & Ellis Amesbury,MA 01913 47 Winnacunnent Road Rep. Roberta C Pevear Hampton,NH 03842 Jane Doughty Drinkwater Road SAPL Hampton, Falls, NH 03844 William Armstrong 5 Market Street Cisil Defense Director Portsmouth, NH 03S01 Phillip Ahrens, Esq.
10 Front Street Assistant Attorney General Exeter,NH 03833 Carol S. Sneider, Esquire State House, Station # 6 Assistant Attorney General Augusta, ME 04333 Cahin A. Canney 1 Ashburton Place,19th Floor City Manager Boston, MA 02108 "Thomas G. Dignan, Esq.
City Hall R.K. Gad II, Esq.
126 Daniel Street Stanley W, Knowles Ropes & Gray Portsmouth, NH 03801 Doard of Selectmen 225 Franklin Street Boston, MA 02110 Matthew T. Brock, Esq.
Shaines & McEachern Robert A. Backus, Esq.
P.O. Box 360
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