ML20153G616
| ML20153G616 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/09/1988 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#288-6316 OL, NUDOCS 8805110295 | |
| Download: ML20153G616 (84) | |
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O'T' G"\ A O UNITED STATES NUCLEAR REGULATORY COMMISSION
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In the Matter of:
- PUBLIC SERVICE COMPANY OF ) Docket Nos.
NEW HAMPSHIRE, et al. ) 50-443-OL
) 50-444-OL (SEABROOK STATION, UNITS 1 AND 2) 0FF-SITE EMERGENCY
, PLANNING EVIDENTIARY HEARING )
(BY TELECONFERENCE) )
l O
Paaes: 11040 through 11121 Place: Bethesda, Maryland Date: May 9, 1988 gb\
D\ HERITAGE REPORTING CORPORATION opkW Rewtm O 1224 L Street, N.W., Seite 600 Washinston, D.C. 244H (202) 628-4888 86 05110295 eE:ogo9 PDR ADOCK 0$000443 T DCD
4 11040 (s
\ 1 UNITED STATES NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD 2
3 In the Matter of: )
4 )
PUBLIC_ SERVICE COMPANY OF ) Docket Nos.
5 NEW HAMPSHIRE, e 't al., ) 50-443-OL
) 50-444-OL 6 ) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING 7 )
EVIDENTIARY HEARING )
8 (BY TELECONFERENCE) )
9 Monday, 10 May 9, 1988 11 Room 428 West Tower 12 4350 East West Highway Bethesda, Maryland 13 O 14 The above-entitled matter came on for hearing, 15 pursuant to notice, at 2:17 p.m.
16 BEFORE: JUDGE IVAN W. SMITH, CRAIRMAN Atomic Safety and Licensing Board -
17 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 18 JUDGE GUSTAVE A. LINENBERGER, JR., MEMBER 19 Atomic Safety and Licensing Board i U.S. Nuclear Regulatory Commission 20 Washingten, D.C. 20555 1
21 JUDGE JERRY HARBOUR, MEMBER Atomic Safety and Licensing Board 22 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 23 24 25
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11041 1 APPEARANCES:
2 For'the Applicants 3 GEORGE.LEWALD, ESQ.
Ropes & Gray 24 225 Franklin Street ,
Boston, Massachusetts 02110
'5 For the NRC Staffs 6
SHERWIN E. TURK, ESQ.
7 Office of General Counsel U.S. Nuclear Regulatory Commission 8 Washington, D.C. 20555 l 9 For the Federal Emergency Management Agency:
10 GEORGE WATSON, ESQ.
Federal Emergency Management Agency 11 500 C Street, S.W.
Washington, D.C. 20472 12 For the State of New Hampshire:
4 13
() 14 GEOFFREY M. HUNTINGTON, ESQ.
State of New Hampshire 25 Capitol Street 15 Concord, New Hampshiro 03301 16 For the Commonwealth of Massachusetts:
l 17 CAROL SNEIDER, ASST. ATTY. GEN.
STEPHEN OLESKEY, ESQ.
- .18 Commonwealth of Massachusetts
!~ One Ashburton Place,~19th Floor 19 Boston, Massachusetts 02108 L
20 For the New England Coalition against Nuclear j Pollution:
21 ELLYN R. WEISS, ESQ.
22 Harmon & Weiss 2001 S Street, N.W.
I 23 Washington, D.C. 20009 l
24 25
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11042, h
[O 1 APPEARANCES. (Cont'inued) 2 For the Seacoast ~ Anti-Pollution Leagues 3 (No Appearance) 4 For--the Town of Hamptons
- 5- MATTHEW T. BROCK, ESQ.
Shaines & McEachern 6 25 Maplewood Avenue P.O.-Box 360 7 Portsmouth, New Hampshire 03801 8 For the Town of Kensington:
9 SANDRA FOWLER MITCHELL, EMERGENCY PLANNING-DIR.
Town Hall.
10 Kensington, New Hampshire 11 For the Towns'of Hampton Falls and North Hampton and South Hampton:
12 (No Appearance) 13
() 14 For the Town of Amesbury:
l (No Appearances) 15 i
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,2 WITNESSES DIRECT CROSS RLDIRECT c'l.sOSS' EXAM 3 ORTWIN.RENN (Resumed)
'4 By Mr. Lewald_ 11046
<5.
By'Mr. Turk 11089
- ;6 i -By Ms. Weiss l'1105
! By Ms. Sneider 11112 B
By Mr. Lewald 11114 9
, By Judge Harbour 11115 10 l
11 12 i 13 14 l.
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l L -( ' , 4 11044 1 PROCEEDINGS 2 JUDGE SMITH: This is'for the purpose of continuing 3 the cross examination of Dr. Renn, Ortwin Renn.
4 Whereupon, 5 ORTWIN RENN 6 was recalled as a witness herein, nnd-having been previously 7 duly sworn, was examined, and testified further, as follows:
8 JUDGE SMITH: And I understand that, Dr. Renn, that 9 you are on the conference call?
10 THE WITNESS: Yes, I am.
11 JUDGE SMITH: And where are you?
12 THE WITNESS: I am in the office of the Attorney 13 General of Massachusetts.
O 14 JUDGE SMITH: Do you understand, Dr. Renn, that you 15 are continuing your testimony under oath?
16 THE WITNESS: Yes, I do.
17 JUDGE SMITH: Exactly as it was when you were 18 testifying in person up in Concord.
19 THE WITNESS: Yes.
20 JUDGE SMITH: All right. Is there anything 21 preliminary until we continue the cross examination.
22 MR. HUNTIN'.iTCN: Yes, sir. Geoff Huntington of New 23 Hampshire Attorney General's Office. Both Dana Bisbee and I 24 have a scheduling conflict which will arise in about an hour, 25 and I may have to es ise myself. If we don't want to interrupt
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L 4 11045 1 the proceedings, that's fine if it continues and give us a 2 transcript when it arrives.
3 But I am going to have to go in about an hour unless 24 I get somebody else to fill in.
- 5 JUDGE SMITH
- Your transmission's breaking up, too, 6 and I guess that you're using a speaker phone, aren't you?
. 7 MR. HUNTINGTON: No. I'm using a receiver right now.
8 I can understand all of you fine. And I'm not asking any 9 questions. I was going to listen in. So it won't be a' problem 10 so long as I can hear you.
11 JUDGE SMITH: All right.
12 Anything further before we proceed?
13 MS. SNEIDER: Just that Ms. Sneider, and Dr. Goble is O 14 also in attendance at the Massachusetts's Attorney General's 15 office.
16 JUDGE SMITH: That was Ms. Sneider speaking?
17 MS. SNEIDER: Yes, it is.
18 JUDGE SMITH: All right. We'll have to be very 19 careful to identify ourselves when we speak up and make 20 objections.
21 Are you prepared to proceed, Mr. Turk?
22 MR. TURK: Your Honor, I thought I would go back to 23 the usual order of things and let Mr. Lewald resume his cross.
! 24 MR. LEWALD: I'm indifferent. I'm ready to go ahead
! 25 where I left off on Friday.
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'11046 1 JUDGE SMITP: All right. All right, go ahead, Mr.
2 Lewald.
3 MR. LEWALD: All right, fine.
14 MS. SNEIDER: Your Honor, this'is Carol Sneider. It 15 seems like-it would be more appropriate for Mr. Turk to at 6 least finish with his cross since that's where we left off on 7 Friday.
8 JUDGE SMITH: Let it up to the principals involved.
9 .I see no prejudice to anybody, so let's go with the 10 requirements of the cross examiner. And Mr. Lewald will.
11 proceed.
12 MR. LEWALD: Thank you, Your Honor.
13 CROSS EXAMINATION O 14 BY MR. LEWALD:
15 Q. Dr. Renn, I would like take up where I'd left off on 16 Friday. And I was examining you on your testimony as it' 17 appeared on page 69 of the Panel's testimony.
l 18 And I'd like to address my first question to your 19 question on page 79 to construct a hypothetical situation, not 20 rely on the actual situation.
21 Now, am I to understand that you conducted your 22 study, that is, your time estimate study, with the premise that 23 ten percent of the beach population could not be sheltered.
24 A. This was really difficult to understand. Could you 25 please repeat the question. We had some breakup here. So I i
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GOBLE\RENN PANEL - CROSS 11047 n
N/ 1 couldn't understand particularly the last part of the question.
2 Q. Well, the question was, did your study begin with the 3 premise that ten percent of the beach population could not be
!4 sheltered.
'S A. The study shows or the study implies that 90 percent 6 of the persons at the beach that are exposed to message would 7 go to find shelter in the hypothetical situations that are ,
8 outlined. I did not make any cpccifications.about the-9 remaining ten percent.
10 Q. And yet your study just dealt with 90 percent of the 11 beach population, is that what I am to understand?
12 A. Well, the thing is that it is kind of difficult for 13 anyone to forecast what a hundred percent of a population will O 14 do, and particularly if the population at large is the one that .
15 you're talking about. And therefore I felt more comfortab'a to 16 preclude ten percent because among those ten percent might be 17 people that may do nothing, for example, and then of course, it 18 will never be completed. This then I felt more safe to go with 19 the 90 percentile.
20 Q. What effect would adding the ten percent and making ;
21 it 100 percent have on your time estimate?
l 22 A. That is very difficult to say. As I said, there ,
23 might be a person that just disregards the danger et al and 24 wouldn't do anything.
25 Q. Would be the same timing? -
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, GOBLE\RENN PANEL - CROSS 11048-
\/ 1 A. Of course the time would be infinite and that of 2 course wouldn't have made much. To answer this question would 3 rely that I make some kind of an assumption about the last t4 person on the beach, and I would feel very reluctant to do so, 25 because apparently we'd be talking about at large population 6 that maybe a very few people that wouldn't do anything. So in-7 this respect, it will never be 100 percent complete.
8 Q. Now, you go on to say that you condition your 90 9 percent on the fact that the owners of the shelters will 10 provide access to their buildings for the beach population.
11 And then you ask the question, is it a real possibility that 12 the owners of shelters refuse to let people in their buildings.
13 And your answer is that it's difficult to predict O 14 what the owners of potential shelters will-actually do, and 15 then go on to say that the general notion is that people,may 16 voice a negative opinion in an opinion poll but still not 17 refuse to give shelter to other individuals if a real disaster 18 occurred.
19 Do you follow that?
20 A. Yes. I have it right here on page 18.
21 Q. And this is the general rule, isn't it?
22 A. Yes. I mean, what I said here, and I think that is 23 very much in accordance with also what Dennis Miletti has said.
24 In many disastrous situation, people may have another verbal 25 opinion of what they would do, of what they actually will do in O Heritage Reporting Corporation (202) 628-4888
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- GOBLE\RENN PANEL - CROSS 11049 O(/ 1 the emergency situation. But later on I qualified that the 2 general rule that is still applicable may be not applicable for 3 this specific situation, or only partly applicable. What I am 4 claiming is that there are a lot of reasons that may overrule
- 5 this general tendency which does mean that everyone will behave 6 against this rule, but that I could foresee a substantial 7 proportion of owners of potential shelters that would refuse 8 entrance to the beach population.
9 Q. So do I correctly understand that you are not 10 suggesting anything more than that Seabrook problems which 11 possibly could result in a departure from the general rule.
12 MS. WEISS: Pardon me, Mr. Lewald, I couldn't hear i
13 that question at all.
3 O 14 JUDGE SMITMt All right. Mr. Lewald, your voice does 15 have a slight tendency to break up. I think that the problem 16 may be that these speaker phones have a voice activated 17 preemption type of mechanism in it. If you can avoid using the l 18 speaker phone, please do that, i
19 The Board doesn't have much choice. The three of us 20 are in this office and we all have to be here, and the i
21 Reporter. Mr. Lewald? Are you there, Mr. Lewald?
22 Did we lose Mr. Lewald? Did we lose everybody. Is 23 anybody there?
24 MS. WEISS: Yes. I'm here.
25 MR. BROCK: Yes, I'm here. I can hear, Your Honor.
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GOBLE\RENN PANEL -LCROSS 11050 l
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'h/- 1 MS. SNEIDER: Attorney General's Office is here.
. JUDGE SMITH:
2 Mr. Lewald?
3 Okay. Hang on.
- 4 (Pause) f5 -}UI. LEWALD: Should I go ahead?
6- JUDGE SMITH: Yes, please. ,
7 BY MR. LEWALD:
8 Q. Dr. Renn,.do I correctly understand that you are not 9 suggesting any more than that the Seabrook problem-that could 10 result in a departure from the rule?
11 A. Fhat I said in ?.iy testimony, and'that is what'I'm 12 saying today, is that the specific situation in seabrook and 13 the specific circumstances that I've outlined in my testimony O 14 are enough reason to believe that there may be an exception 15 from the rule, yes.
16 Q. Okay. Now, the reasons that you set forth follow 17 beginning on page 80, do they not?
18 A. Yes.
19 Q. And the first one, you talk about the data from 20 Quarantelli, correct?
21 A. Yes.
22 Q. This is what we discussed on Friday, right?
23 A. Partly, yes.
24 Q. And secondly, you say that the surveys of the shelter 25 owners revealed an unexpectedly high degree of verbal refusal O i Heritage Reporting Corporation (202) 628-4888
,, GOBLE\RENN PANEL - CROSS 11051
-} 1 to grant access to their buildings.
2 A. Yes.
3 Q. Is that correct?
4 A. Yes.
!S Q. -Now, you go on to say that.more than fifty percent of
'6 those surveyed were not willing to host people from the beach 7 in case of an emergency.
8 Is that right?
9 A. Yes, that's the second sentence there.
10 Q. This doesn't surprise you, does it?
11 A. Oh, I think it's a surprising high number of people 12 that refused to give people shelter in case of an emergency. I i 13 think it's a surprisingly high number.
O 14 Q. Isn't the surprise really the other way? Doesn't 15 this survey response really call for a hundred percent since it 16 self selects the anti-Seabrooks and excludes the pro-Seabrooks?
17 A. I don't think so. I think there will have to be two 18 things to take into consideration. One thing is that people do 19 not always act non-altruistically in verbal behavior. I think
- . 20 that if you reiterate that sentence that they are more 1
21 altruistic in real behavior than in speech, it does not mean 22 that they're all the way non-altruistic in speech. That many 23 people do care even in verbal behavior for their fellow 24 countrymen.
25 And secondly, I think that you have to be aware of l (:) Heritage Reporting Corporation
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GOBLE\RENN PANEL - CROSS 11052 C's (J 1 the fact that many of those people surveyed were not quite sure 2 what their obligation is and they wanted to be cautious. So I 3 think that if you get fifty percent refusal, I think it is a 4 very high number of refusal, but I concede that if it would be 5 more than it would be more surprising. But I definitely 6 believe that fifty percent is a high number.
7 Q. Was the nature of the survey, if you were an anti-8 Seabrook person, you have the choice of filling it out, and if 9 you're not, why would you make a return?
10 A. Well, I think there are lots of different motives to 11 fill in the returns. First thing, I think, I'm not sure and I 12 don't think that it's true that the people felt that the survey
,_ 13 was undertaken by a group that allegedly is antinuclear. I
'\-) 14 think that the people felt that this was a neutral survey, 15 Secondly, I think that you know even if people are 16 antinuclear, the people that have actually filled out the 17 questionnaire they may feel that they're antinuclear but still 18 would give other people shelter. I think the two things are 19 not totally independent from each other, but for many, they 20 are.
21 Q. Doctor, do you have Attachment 12 to the Panel's 22 testimony at your disposal?
23 A. Just a second, please.
24 MS. SNEIDER: It'll take a couple of minutes to get 25 Attachment 12. If you want to wait, I will go get it.
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1 (Audio beeping sound) 2 JUDGE SMITH: That was the sound of Ms.'Sneider.
3 departing to get Attachment 12.
4 MR. LEWALD: I think so. That was the elevator, I
!S guess, going down three floors.
- 6 (Pause) 7 JUDGE SMITH: Ms. Sneider, have you returned?
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- 8 (No response) 9 BY MR. LEWALD
10 Q. . Dr. Renn, do you have now before you Attachment'12, 11 which was associated with your testimony?
- 12 A. Yes.
is Q. And could I ask you if you would turn to the first or O\' '
14 the third page of the Exhibit which contains the first survey I 15 document.
. 16 A. Yes.
17 Q. And on the right hand corner, just so I'm sure that l 18 you have what I have, a name, Robert Hurley?
I ,
i 19 A. Yes.
. 20 Q. Can you hear me, Dr. Renn?
21 A. Yes, I can hear you.
22 Q. Does that show on your copy as well as mine?
23 A. Yes, it says, Robert Hurley, on the right hand 1 24 corner.
l l 25 Q. Thank you.
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GOBLE\RENN PANEL - CROSS 11054 l~h 1 D' 1 JUDGE SMITH: May I interrupt just.a moment?.-Is Mr.
i 2 Brock on?
r 3 We'll proceed without him. I'll get him on as' fast i
4 as possible.
- S BY MR. LEWALD:
96 Q. Dr. Renn, directing your attention to.the survey 7 questionnaire and to the introductory paragraphs, which are the ,
8 first two, the first paragraph asserts that New Hampshire 9 Yankee identified its owner or manager's building as a shelter.
10 Now, the second paragraph identifies the survey as i
11 being taken by the Massachusetts, or being taken for'the 12 Massachusetts Attorney General. Now, you would agree, would !
13 you not, that both groups, New Hampshire Yankee, and the
() 14 Massachusetts Attorney General have value positions towards 15 Seabrook which are well known?
16 A. I know that, yes.
i 17 Q. Now, identifying a survey with --
18 JUDGE SMITH: Whoa, whoa. May I interrupt?
19 What is it that you know, Dr. Renn?
20 THE WITNESS: Pardon me? I 21 JUDGE SMITH: Your last answer was, I know that, yes.
. 22 What is it that you know?
23 THE WITNESS: I know that the Attorney General's i 24 Office has a specific --
, 25 OPERATOR: Mr. Brock, go ahead, please.
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GOBLE\RENN PANEL - CROSS- 11055 19 k/ 1 THE WITNESS: I'm sorry?
2 JUDGE SMITH: Mr. Brock, are you back?
3 JUDGE SMITH: Yes,-Judge Smith, I am.
4 JUDGE SMITH: Dr. Renn, would you answer my question,
'S please, now?
!6 THE WITNESS: Yes. I know that the General 7 Attorney's office has a specific view towards Seabrook, and I-8 believe that the New Hampshire Yankee has a specific view on .
9 Seabrook.
10 I'm also aware that probably a lot of the hotel 11 owners and a lot of.the people that have been surveyed may~be 12 not so well informed as I am about those affiliations of the 13 two institutions mentioned in the letter.
O 14 JUDGE SMITH: Go ahead, Mr. Lewald.
15 BY MR. LEWALD: _.
16 Q. Well, doctor, identifying a survey with a value 17 position group such as in this case, the Massachusetts Attorney 18 General, implies correct answers to the respondent's,.in this 19 case, anti-Seabrook and. biased results, doesn't it?
20 A. Not necessarily. I agree with you in the sense that 21 it's the sponsor of the specific survey is being mentioned that 22 according to the literature about methodology that we have that 23 this kind of nominating a sponsor may actually affect the 24 responses of the people that are being addressed. But it 25 presupposes that everybody who answers this written Heritage Reporting Corporation (202) 628-4888
_ COBLE\RENN PANEL -' CROSS 11056
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1 questionnaire is aware of the fact that the Attorney General's 2 Office in Massachusetts is actually opposing and an intervenor 3 in this process. ,
4 I'm~not quite sure. I mean, I don't, I haven't 5 conductedthesurveyandI'mnotsohellinformedaboutthe.
36 knowledge of each of the respondents about who is the 7 intervenor and who is the proposer. I think they know about 8 the proposer but I'm not quite sure if everybody that has been 9 interviewed was knowledgeable that the Attorney General's 10 Office in Massachusetts is opposing the nuclear power plant in 11 Seabrook.
12 Q. Well, let's go on, doctor, then. On Question 2, 13 defined shelter, and therefore I suggest to you, biases people O 14 who own buildings that do not meet this definition of shelter 15 in Question 2. And so that they consider their buildings i .
16 unacceptable as shelter space and therefore they're biased 17 toward a no answer.
4 18 Would you agree with that?
- 19 A. Not necessarily, again. I think there is some good 20 points in your assertion. But on the other hand, what we know 21 about attitudes towards nuclear power, and I've expressed that 22 already in my testimony, that many people look at those 23 questionnaires as an expression or to express their own 24 feelings towards Seabrook in this case.
25 Now, if one of those hotel owners is an advocate of O Heritage Reporting Corporation (202) 628-4888
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\~/ 1 Seabrook, he would probably try to make that expression clear, 2 and particularly because this person might think that his 3 answer may be relevant for the issue. So even if let's say a 4 person that knows that the Attorney General's Office is an 5 opponent to the licensing of the nuclear power plant at 6 Seabrook, he may as well say, well, I'll give them a lesson and 7 tell them that I will let people in it, that I think my shelter 8 is good because I think that Seabrook Nuclear Power Plant is a 9 good plant.
10 Now, I think it goes in both directions. What we can 11 say in general is that the more people are affiliated to a 12 position, the more they are likely to show that position in f, 13 surveys regardless whether the pro or the con side is b 14 conducting the survey, 15 Q. Would you characterize the survey as value free, 16 doctor?
17 A. That's very difficult to determine a question what is 18 value free and what is not value free. I would definitely say 19 that telling the respondents the source is certainly one way to 20 give some kind of, or to elicit distorted answers. But I would 21 say that it can go in both directions. So I would be very 22 careful about a conclusion that the direction is only in favor 23 to the Attorney General.
24 I have to come back to my earlier view, the more 25 polarized the debate is, the more people are going to express O Heritage Reporting Corporation (202) 628-4888
,d i i- , GOBLE\RENN PANEL - CROSS '11058 1 that view regardless who the source of the survey is.
I, '2 Q '. Well, let's take another one, Dr.-Renn.
3 In Question 3, this question. implies that' shelter 4 -with direct access from outdoors is acceptable and other type 5 -of access is' not. And thereforza biasing the ~ people who own "
- 6 buildings without direct access toward a, no, answer.
- 7 Would you agree with that?
[ 8 A. I don't think that is true.
9 The question reads, if you have shelter space, does i 10 it have access directly from outdoors? It does not include,any 11 evaluation that it has to have an access from outdoors. It's 12 just asking the question if it has access from outdoors, and
,. 13 there are only two categorius to answer: yes and no.
.' ]4 I do not think that this inserts any bias on the 15 questionnaire. It is in my sense just an informational 16 question, and it may trigger thoughts about if that is a 17 necessity or not. But the question in itself does not include 18 any bias that outdoor access is absolutely mandatory for being
! 19 a shelter. That question does not include that notion.
I 20 Q. Doesn't the question imply that shelter without 21 access on the outside is less valuable than the other shelter?
22 A. It does not say that in any way. It just asks if you 23 have shelter space, does it have access from the outdoors. And 24 it does not imply that it must have it. It just asks the 25 question if it has or if it has not. And I don't see any bias
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.1 in the specific question.
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2' Q. How-would I find-out from this question whether or !
3 not a building owner had shelter but the shelter was not ,
4 accessible from the outdoors?
5 A.- From this question, number three, you cannot make 6 that assertion. Question No.'three just gives you the answer
,7 if the chelter space has access from the outdoors or not. And-r 8 that is what the question.is asking..
Now, Question 4,'which is a question on behavioral i 9 Q.
10 intentions, I submit?
11 A. Yes.
12 Q. It does not simulate or it does not attempt to 13 simulate in any fashion the emergency context or emergency -
0 14 information that would exist when people would be actually !
15 engaged dn letting people into their building.
i 16 Would you agree that it does not do that, would you :
17 not?
18 JUDGE SMITH: Did you answer that?
19 THE WITNESS: I didn't get the content of the l 20 question. Could you specify your question, Mr. Lewald?
) 21 BY MR. LEWALD:
22 Q. All right, let me do it over again, i 23 The question on behavioral intentions, which is l
l 24 Question 4, doesn't even attempt to simulate the emergency l 25 context or emergency information that would exist when people Heritage Reporting Corporation (202) 628-4888 t.
GOBLE\RENN PANEL - CROSS- 11060 Q
\' 1 -would actually be engaged in letting people into.their 4
2 buildings or not letting them in. But this would reduce, would 3 it not, the validity of the behavioral intention survey by 4 definition as admitted in earlier testimony, I believe, by 5 other Massachusetts Attorney General witnesses.
- 6 A. Well, I think, you know, we had brought up the issue 7 of bias and I think one of the things that we have learned in 8 survey techniques is to be very careful about indications on a-9 specific situation. If we try to do things like role playing 10 and giving a specific background, like an environment, somebody 11 is knocking at your door and asking, can I get in, would you 12 let him in. Or would give other specifications, that might 13 insert another bias, either pro or con, depending on how the O 14 specific situation is framed.
15 So I think it is a valid solution to say, be as
. 16 neutral as possible and just ask would you leave somebody in.
L 17 Now, we know, and I've put that in my testimony, that this 18 question on its own does not allow a specific conclusion about 19 what percentage of homeowners will actually do what they say in 20 this specific question.
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T l 21 But I think the question, how it is phrased, is the
! 22 most valid and unbiased way of doing so. Any other way of
- 23 simulating a situation usually introduces more biases in a 24 question than doing it in a very neutral fashion as has been f 25 done here.
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GOBLE\RENN PANEL - CROSS 11061 tm 5- 1 Q. But doesn't it present to the owner of a building an 2 opportunity to voice his opposition to th olant's licensing, 3 and to a situation quite apart from that as to whether or not 4 he'd actually let someone in his building seeking shelter?
5 A. Yes. I offered the same interpretation in part that'
'6 I said certainly given the opportunity to express one's own 7 behavioral intentions is part of way of saying of what my own 8 attitude is according to the basic literature on attitudes and 9 behailor.
10 In this respect, I definitely think that saying, no, 11 to Question 4 or saying, no, to some of the other questions, 12 specifically Question 4, is also an expression of attitude.
rs 13 But I think for the issue that is at stake right here, 14 attitudes are also important. It is not so that attitudes and 15 actual behavior are correlated directly with each other.
16 According to the literature that we have, the extra correlation 17 is between point 3 to point 6 which zueans literally that if you 18 take a ball point figure, that around ten percent to 30 percent 19 of the people that actually have a strong opinion or strong 20 attitude act according to this attitude.
21 Now, if you just take the ten to 30 percent of the 22 people that we know from just general attitude on a study and 23 specifically the study by Wittacker that was also mentioned by 24 Miletti, and then while we have a substantial percentage of 25 people in this area that might actually do what they say in an O Reporting Corporation Heritage (202) 628-4888 i
GOBLE\RENN PANEL - CROSS 11062
() 1 attitudinal survey, so I-think it is not so that we can say 2 .that 60 or 70 percent of the people say they would not let 3 people in that it will be 60 or 70 percent, but it will 4 definitely not be zero.
5 Q. Well, doctor, isn't the attitude that is expressed 6 toward the facility where the behavior would be toward the.
7 individual seeking shelter?
a A. Well, there are two issues involved. And the one 1 issue that is very important is thot one issue is that 10 opposition to the nuclear power plant and opposition to its-11 operation has also an impact on the behavior in an emergency.
12 The second thing is, and I think that is what your 13 quest!on is based on, is that people might feel a moral O 14 obligations if other fellow citizens are in danger, to help 15 them. And I think that is a very very strong motive. But in 16 the case of Seabrook, I've lined out four reasons that this 17 kind of moral obligation may be over-compensated. That people 18 have a lot of moral justification not to let people in without 19 feeling guilty. And I think that is my major part of my 20 argument that I'm saying, while if you have this attitude, you 21 have an inclination, for example, to leave imn.ediately because 22 you're fearful.
23 Now, 12 you can compensate your guilt by letting 24 other people not come into your building, then you are in 25 accordance with your own attitude and that diminishes your O Heritage Reporting Corporation (202) 628-4888
9 GOBLE\RENN PANEL - CROSS 11063 (9> 1 cognitive dissonance. And I think that is what my argument is 2 based on, that there are mechanisms to compensate for the moral 3 obligation to help other people.
4 Q. Are you implying that we could have a situation here 5 where someone would dislike the utility so much that he would 6 slam the door on somebody seeking shelter, even though he
'7 planned to sue the utility the following week after allowing 8 shelter?
9 A. Well, what I'm saying is that a person that has a 10 very negative feeling towards nuclear power or even distrust to 11 the operator of this power plant, may be first inclined to do 12 this. In a second thought, then he runs into his moralizing 13 argument and what I'm claiming right here is that if that
\' 14 second thought gives him enough of a justification to slam the 15 door, as you said it, then I think it is more likely for a 16 person that has a negative attitude towards nuclear power to do 17 this than a person who has a very positive attitude towards 18 nuclear power.
19 Q. Wouldn't you agree that anyone who would do this 20 would be decidedly in a minority, that is, allow his hatred of 21 the utility to justify his slamming the door from a poor soul l 22 seeking shelter?
l 23 A. Well, I don't make any clear indication whether this 24 will be a minority or a majority. I think all the ways to 25 actually forecast the behavior in this specific incident is O lieritage Reporting Corporation (202) 628-4888 l
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4 GOBLE\RENN PANEL - CROSS 11064 g\ . 1 based on qualitative reasoning and the argument, the' arguments 2 that I lined out, that there are a lot of moral arguments to 3 just.do this, what you have.said, slam the door, and leaving.
4 Now it is difficult to say how many people will 5 actually use the compensational methods and arguments,~but I 6 would definitely think.that it is at least a substantive
- 7 minority that would jeopardize the realization of the
'O sheltering plan.
9 JUDGE SMITH: Mr. Lewald, may I interrupt a moment, 10 please?
11 MR. LEWALD: Yes, Judge Smith.
12 JUDGE SMITH: I'd like to take a specimen-roll here.
13 Ms. Weiss, are you still on?
O 14 MS. WEISS: Yes, sir.
15 JUDGE SMITH: Mr. Brock?
16 MR. BROCK: Yes, Your Honor.
17 JUDGE SMITH: Mr. Huntington?
18 MS. WEISS: He said they had to leave, remember?
19 JUDGE SMITH: Yes. I didn't know that they'd 20 actually left.
21 Ms. Mitchell, are you still on?
22 MS MITCHELL: Yes. I'm leaving in 20 minutes, Your 23 Honor.
24 JUDGE SMITH: All right.
25 Mr. Turk?
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\/ 1 MR. TURK: Yes.
2 ' JUDGE. SMITH: Okay. Go ahead.
3 BY MR. LEWALD:
- 4 Q. Moving on to page 81, or the bottom of 81 of your 5 testimony, you say that these surveys, these Salmon Falls.
6 surveys indicated that around 30 percent of those interviewed 17 stated they would leave the area immediately if any kind of
'8 emergency were to be declared.
[ 9 Is this 30 percent a calculation that you did? '
10 A. Could you just tell me what you're referring to?
11 It's page 81?
i:-
12 Q. The bottom of page 81 and the top of page 82 of the 13 Panel testimony.
O 14 A. I. don't recall right now whether that was taken
. 15 directly from the survey, or if that was given to me by the 16 surveyors, themselves. I'm sorry, I don't recall exactly what 17 that number came from, but I'm sure that it's a correct. number.
t.
18 Q. You're sure.
! 19 You didn't do the calculation if indeed there were a 20 calculation, I take it?
l l 21 A. I didn't do that specific calculation, no.
22 Q. And you think this is a reasonable response, you say, 23 considering the fact that the first ones to leave will be the I 24 first ones out of the EPZ, correct?
25 A. Yes. And let me qualify this. I think it is a
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GOBLE\RENN PANEL - CROSS 11066 O- 1 reasonable response because most of the owners of'these 2 facilities or the managors of these facilities are quito aware 3 that the sheltering factors that was discussed, for example, in 4 the newspaper, is just a ten percent protection.
1^
5 Now, if I consider a ten percent-protection in 6 something that it is not adequate to protection my own health,-
i 7 then I would assume that it would not be an adequate protection 1
8 for anybody else. And this is one of the justifications, the 9 moral justifications to leave earlier. ~Because if I stay, I j 10 wouldn't help people a lot by just giving them ten percent 11 protection. And even that may not be believed because I have l
12 outlined earlier, most of the buildings do not match the 13 imagination or the images of people about shelters, so that 14 they even might not believe the ten percent.
15 Q. Doctor, would your answer be the same if I called to 16 your attention that the Salmon Falls survey was directed to 1 17 designations on the Stone and Webster March Study which was 1
18 identifying buildings with a protective shielding factor of 19 something in the vicinity of .4 to .6 percent and not .9 l 20 percent which you have just referred to.
21 A. That was the first survey, but not the follow-up, as
- 22 far as I remember.
! 23 Q. Yes. My question to you was that the Salmon Falls 24 Survey, though, was directed to the owners of the March Stone &
25 Webster, buildings listed in the March Stone & Webster study
(:)
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() 1 and not the August - September 1987 study.
2 A. Well, I think, you know, I'm not a health physicist 3 and I don't want to get into the argument about shielding 4 factors. That is not my expertise. What I would like to 5 stress out and to point out here is that apparently this .9 has 6 been reported in the press and will probably be 1 ter on 7 reported even more than it is today. And this is the figure 8 that people are going to live with.
9 I doubt that people have a lot of knowledge about the 10 first or the second draft of the Stone & Webster report, and 11 we're talking here about perception, not about reality. And I 12 don't want to go into the question whether the shielding factor 13 is more or less. That is not part of my expertise.
14 What I'm referring to is how people perceive their 15 own homes as shelters. And apparently from the survey, just as 16 well as from the published opinions that they find in the 17 press, they feel that the protection is very low, probably 10 lower than the ones that Stone & Webster has indicated in their l ') first survey.
20 Q. You make no mention of anything published in the 21 press in your panel testimony, though, do you, doctor?
, 22 A. Well, not -- I've just recently read in the Boston 23 Globe, I can't give you the exact date -- which the .9 24 shielding factor was mentioned, and I believe that a lot of 25 people in this area read the Boston Globe, i
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1 0 Doctor, would you go back to the Salmon Falls 2 Survey, which is Attachment 12?
3 A. Yes, I have it in front of me, 4 Q. And can you tell me what study is identified in that 5 survey?
6 A. In March of 1986, Stone & Webster Engineering 7 Corporation completed a study entitled, "Study to Identify 8 Potential Shelters in the Beach Area Near Seabrook Station."
9 JUDGE SMITH: All right, let's take another roll.
10 Ms. Weiss?
11 MS. WEISS: Yes.
12 JUDGE SMITH: Mr. Brock?
13 MR. BROCK: Yes.
O 14 JUDGE SMITH: Mr. 7trk?
15 MR. TURK: Yes.
16 JUDGE SMITH: Ms. Sneider and Dr. Renn?
17 MS. SNEIDER: Yes.
18 THE WITNESS: Yes. .
19 JUDGE SMITH: Mr. Lewald?
20 (No response.)
21 JUDGE SMITH: Mr. Lewald?
22 (No response) 23 JUDGE SMITH: Mr. Brock?
24 MR. BROCK: Yes, Your Honor?
25 JUDGE SMITH: Mr. Huntington?
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j GOBLE\RENN PANEL - CROSS 11069 1 (No response) 2 JUDGE SMITH: They're off, I know.
3 And Ms. Mitchell?
4 MS. HITCHELL: Here, but I'm leaving in fifteen.
5 minutes.
6 JUDGE SMITH: Okay.
'7 Mr. Lewald, are you on?
28 (No response) 9 JUDGE SMITH: I think he dropped his equipment.
10 BY MR. LEWALD:
, 11 Q. Dr. Renn?
. 12 A. Yes, I am here.
i 13 Q. Doctor, the question before last I was inquiring
, 14 about the 30 percent of the people interviewed, which it says 15 interviewed on the bottom of page 81 of your. testimony.
16 A. Yes.
17 Q. And these were the peonle presumably interviewed 18 under the survey that was conducted at Salmon Falls on the 19 basis of Stone & Webster's March 1986 sttidy, true?
20 A. I've just looked through -- used the break to look i 21 through this Appendix 12 again, and I've seen that from i
22 November 3rd where some additional surveys have been made, 23 there's a reference to the August 1987 Stcne & Webster j 24 Corporation.
i 25 Q. What was your reference on the bottom of page 81, the O
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GOBLE\RENN PANEL - CROSS 11070 I O' 'l top of page 82 in your 30 percent? '
i 2 A. Pardon me? The connection's very bad. Could you' !
3 speak up a little bit. It's very difficult to listen.
]
4 Q. On the bottom of page 81 and the top of page 82 of ;
i 5 your testimony, you talk about 30 percent of those surveyed. '
6 A. Yes.
.7 Q. And am I to understand that you are talking about j those who were surveyed in September or August, September,
'O l 9 October and November? j i
i 10 A. I told you that thin 30 percent was given to me by ;
11 Dr. Eckert who had conducted the survey. So I don't really c 12 feel justified to give you that exact answer. As far_as I can f t
recollect it, Dr. Eckert told me that he got this number from o
a 13 {
14 the written responses that people had given him in the rubric
! 15 on written comments. But I'm not absolutely certain about 16 that, f i l l 17 But I have that number directly from the researcher. I
- 18 So I did not calculate that number by myself, but also it seems i l
19 to be consistent with what we know about shadow evacuation. !
f 20 But that is not where it comes from. I just made this i
reference because I t hought this might also be helpful, but !
21 22 basically, this number is a number that was given to me by Dr.
?
) 23 Eckert as or;e of the results of the Salmon Falls survey, i t
24 Q. And it's got nothing to do with the November 25 inquiries, has it? ,
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GOBLE\RENN PANEL - CRObs -11071'
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- 1 A. I have no idea'because I said this number was given:
2 to me by the Salmon Falls.research associate, and I don't know 3 whether they just took-that number from the August-September 4 survey or from the on-going survey. .That is something.that you.
5 have to ask-Dr. Eckert directly.
6 Q. Well, you~know that the November survey doesn't ask 7 people whether or not they're going to cut and run, does it?.
- 8 A. Pardon me?
9 Q. You don't understand the question?
10 A. I couldn't understand it. There was distorted noise 11 in the amplifier.
12 Q. What does the November survey pertain to?
13 A. Well, it's the same one as the other ones, too. It O
4/ 14 has questions four. It says in the event of an accidental 15 r_diation release at the Seabrook station, would you let people 16 into your building. It had exactly the same four questions.
17 Q. Are we looking at the last page of Salmon Falls 18 research?
19 A. No, 1:o we are not. I'm sorry. Maybe I have given 20 you, should have given you the reference. If you just take the 21 last third of the answer shoet, the reply sheet, you'll find 22 out that some of them have been labeled, November 3, 1987, and 23 it is basically the same letter, it just has been sent later.
24 Also, some in September 29, have already identified 25 in March of 1987, and in August 1987, so from what I can see O Heritage Reporting Corporation (202) 628-4888 w_
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1 here, around 50 percent of all the questionnaires.have that 2 ' additional information in it.
3 Q. The November survey questions, the: Introductory.
4 matt'er is somewhat different, isLit not,'than the. August --
5 A. Yes. I have seen that, yes.
6 -Q. -- introductory matter?
7 JUDGE SMITH: Gentlemen, be careful not-to over: talk j 8- on the speaker phones.
9 MR. LEWALD: That is too loud, Your Honor?
10 JUDGE SMITH: No. Overtalking in much-more damaging 11 to the transcript when you're using speaker ph'ones. l Don't.
12 interrupt.
13 Go ahead, Mr. Lewald.
.O 14 BY MR. LEWALD:
15 Q. My question, doctor, was the November survey contains 16 quite different introductory material than the August survey 17 questionnaire, does it not?
The wording of the introduction is'different.
~
18 A. Yes.
19 Q. And the November survey directs the business owner or 20 manager that his or her answers to the questions are crucial to 21 the evaluation of the evacuation plan proposed by New Hampshire 22 Yankee, does it not?
23 A. Well, it says, "your answers to the following 24 questions are crucial to evaluation of the evacuation plan !
25 proposed by New Hampshire Yankee." That is the exact wording.
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1- Q. 'And we're talking about shelter, are we not?
2 A. 'Yes.
3 Q. Now, going back to the top of page 82, you make the 4 response'that the 30 percent interviewed said they would leave' 5 the area immediately if any emergency were to be declared, and' 6 you find this to be a reasonable response for the reasons 7 you've stated.
?8 Now, when we are looking at shelter here at Seabrook, 9 we are looking at a fast breaking accident scenario. Am I 10 correct in that?
11 A. I think1so, yes.
12 Q. Now, is it your view that it's reasonable and 13 -realistic to think of a hotel owner and restaurateur as i
14 rowing out the guests that might be business invitees that 15 niight be in their establishments and locking the door and then 16 running out of town? Is that a reasonable reaction that you 17 feel that a hote1~ owner is going to follow in the event of 18 shelter being ordered at the beginning of a fast breaking 19 accident?
20 A. Well, what I would assume, and I'd again say that I 21 can't say this for all hotel owners, but if I think about 22 reasonable scenarios, I could imagine a very reasonable 23 scenario in which a hotel owner would give a message to all the 24 hotel guests who are still there saying, well, we know that the 25 protection is very inadequate in our hotel, that is what we O
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- ( ) 1 have heard from the press and that is'what our preconceived 2 notion is, I think it is.much better to get into the car and 3 get out as soon as possible, then our chance to be better.
e, 4 protected is better than staying in here, and so he'would 5 probably warn the guests who are available at that moment, and-6 then would leave.
7 I think another incentive for him to leave, and that
!8 again is in accordance with what Dennis Miletti has said, is 9 there is no official role for ha.m to stay, and I think that is 10 -one of the common grounds of knowledge that we have about 11 behavior in an emergency situation, he might not feel obliged 12 to do this other than warning his own guests, but not letting 13 total strangers coming into his hotel rooms. Or if_he happens 14 to see some coming up, saying, well, dont come into my house.
15 I don't think it's a good idea. Just leave the area. It is 16 much better leaving in a fast developing accident.
17 Q. Is it your suggestion that the~ hotel owners and 18- restaurateurs are emergency workers?
19 A. They assume a specific role if they hold shelters.
10 And I think as I do something to protect the public, this is a 21 kind of a public role that they are actually fulfilling.
22 Q. And you think it's a public role for a hotel keeper 23 to recommend evacuation when the authorities are recommending 24 shelter?
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k 2- 1 for his or her guests. In many other instances, for example, 2 in fire, they certainly would.do, give some advice to the 3 people inside the hotel. So I think that a hotel owner would 4 feel obliged in this situation, to give the best advice that 5 she or he can give and I could imagine from what we know right 6 now about the feeling of those hotel owners about what I'have 7 read in the survey, what other circumstances are that have been 8 conveyed to those people in the press, that a reasonable, 9 approach would be to say, I don't think that sheltering in my 10 house is a reasonable answer to this specific. threat, and I 11 would recommend in contrast to what has been recommended in the 12 radio to evacuate spontaneously.
13 -Q. Is it your view that this advice would be given not 14 with a view to trying to clear the hotel so the hotel owner 15 could run, but-in a good faith effort to tell .the hotel guests 16 what the hotel keeper thought was the best protective action 17 that he could take, that his guests could take?
( 18 A. I suppose again I would assume that most of hotel l 19 owners would act altruistically in this situation or 20 altruistically in their own perception. That means that they 21 would go through their hotel and ask people that are there or 22 advise them or give them a recommendation to do the same thing 23 that they are intending to perform in a minute.
24 Q. Now, assuming, doctor, in a situation in which 25 shelter was ordered or recommended, the authorities would have l
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-( L 1 1: made a determination that the greatest dose reductions could be 2 had with shelter. Is that not so?
3- A. What was the question?
4 Q. We're assuming that when shelter was ordered'or 5 recommended by'the authorities as'the better protective action 6 to be pursued, the authorities had already canvassed evacuation 7 as a protective action responso and decided that shelter would
- 8 afford more protection. And what you're telling me is that 9 the hotel keepers are going to reverse that decision and 10 suggest that the guests-in the hotel evacuate irrespective of 11 what the public authorities are suggesting?
12 A. We had a very similar situation at TMI. Thera are a 13 lot of people, actually thousands of people did do some kind of O 14 protective action on their own in spite of what had been said 15 to them officially. Now, they were not said officially not to 16 evacuate but they were not told to evacuate with the exception 17 of pregnant women.
18 Nevertheless, we know that a lot of shadow evacuation 19 has taken place in this specific event. And there are other
! 20 instances in which this exactly has happened. And in natural 21 hazards, for example, the opposite is very often true, that 22 people are advised to dc some protective action, but that 23 people just decide to stay there.
24 Now, I think another important factor there is that I 25 in the past those people have been told that a severe accident, (1m) l Heritage Reporting Corporation (202) 628-4888 {
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e GOBLE\RENN PANEL - CROSS 11077 1 specifically by the utility, is excluded. It's-not a potential 2 or possible accident. Now, if that accident-does happen and 3 with the attitude that they have-towards the utility, for 4 example, they may feel that they can't have trust in this 5 specific authority, and they may feel that the information for 6 ordering the sheltering option was given by the utility and 7 just conveyed through the state-agency.
8 So I could very well imagine a situation by which a 9 hotel. owner says, well, I do not really trust those utilities 10 with the kind of information that they have given. I don't 11 think it is a very good idea to stay here. They admit that the 12 protection factor is very small. That's the perception that g ,s 13 the people have and therefore it seems more reasonable for us U] 14 to do something different. And I think there have been 15 incidences in the past that give credence to such a scenario.
16 Q. Doctor, does your shelter time study assume in any 17 respect that the owners of a building will be seeking better 18 shelter elsewhere?
i 19 A. Well, that is an interesting thought. I don't think 20 I have assumed that, but it certainly is an interesting thought 21 that the people that think that they are in very inadequate 22 shelters, in buildings that have a lot of glass windows or not i
l 23 enough basement space would think of going somewhere where 24 they'd find a better space. I don't think is a very probable 25 behavior because I think that either people stay in the way l
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, GOBLE\RENN PANEL - CROSS 11078 I where they are, if they're already in a building, or that-they 2 are leaving. But it is certainly conceivable also that some of 3 the people that definitely feel that their houses are not-4 suited for sheltering might look for another shelter.
S Q. Doctor, moving over to page 84 of your testimony, you 6 make the statement that contrary to popular belief, natural and 7 technological disasters are not usually accompanied by panic or 8 total confusion.
9 Is this what we generally find to be the case?
10 A. Yes.
11 Q. Now, you talk about two exceptions to the-rule and 12 you cite Tiryakian and Killian for these positions, do you not?
q 13 A. Yes.
k 14 Q. And also Bahno-Behnson, is it? ,
15 A. Oh, Bahne-Behnson.
16 Q. Bahne-Behnson.
17 A. Yes.
18 Q. And Form and Nosow?
l l 19 A. Yes.
! 20 Q. Now, what was the article by Tiryakian about that you 21 cite?
l 22 A. Just let me get to the article again so that I can 23 refresh my recollection. Just a second.
l 24 JUDGE SMITH: All right, gentlemen, you're over 25 talking.
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(-) 1 THE WITNESS: Oh, I'm sorry. The article is number 2 49 by Tiryakian, and it's called, "Aftermath of a Thermonuclear 3 Attack on the United States, Some Sociological Considerations,"
4 and that article was published in Social Problems in 1959.
5 BY MR. LEWALD 6 Q. And I take it tbnt what you're doing here is 7 comparing what Tiryakian hypothesized as following an imagined 8 thermonuclear attack on the United States with a shelter 9 situation, a scenario that we're conceptualizing at Seabrook?
10 A. Well, that's not quite true. What Tiryakian is 11 actually saying in that specific article is that he takes some 12 sociological insights from a lot of other studies and he 13 summarizes it, and then applies it to a hypothetical event
!C
14 which is in this case a thermonuclear attack. That is not a 15 simulation of a thermonuclear attack and then applying the 16 specific settings that I have referenced to tu.3 hypothetical 17 situation.
18 The article starts with a description of sociological 19 insights into emergency behavior. I do recall that Tiryakian 20 rests heavily on emergency behavior issues discovered directly 21 after the War, during the War. The war-type disaster behavior 22 is his predominant subject in this article. But he concludes, 23 as far as I can recollect, that those are general traits, and 24 then he applies those general proporties to a thermonuclear 25 attack, p]
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,m.
k~) 1 Q. Well, these are behaviorisms following a 2 thermonuclear attack, are they not?
3 A. Well, what he is saying is that he first tries to 4 distinguish what are sociologically derived facts about
-5 people's behavior and then he assumes that this behavior will 6 also be prevalent after thermonuclear attack, and what that 7 would mean. So it is not that he says that it had to be the .
8 thermonuclear attack as a trigger and this is what we expect.
9 The reasoning is just the ether way around. He says, 10 this is what we know from the literature, and so when a 11 thermonuclear attack would occur, this would be probably the 12 consequences and if that are the consequences, what would be 13 the secondary and tertiary impact.
7_.
~' 14 Q. All right. Is the Killian 1952 reference a wrong 15 reference to Killian? You mean 1954 instead of '52?
16 A. Which one are you referring to?
17 Q. I'm referring to the one you cite, and my inquiry is 18 whether or not it's reference is to the correct Killian 19 article.
20 A. Are you referring to Tiryakian or to Killian?
21 Q. I'm referring to Killian.
22 Q. Oh, to Killian. I'm sorry. It's very difficult to 23 understand the different names. Killian is significant of 24 multigroup membership in disaster. That is the reference that 25 you're referring to.
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- 1. Q. You're making the reference.- I'm aEking you:whether-2 or-not-thefreference is correct, and you're not intending-to refer to'a Killian article in 1954'.
3
.4 A. I'm.not quite.sure whether this is a typo or not. I 5 <do have the reference at~home. I: don't have.it right here with: '
6 me. I-have a copy of it and I mean, '52'and '54-wouldnt make 7 -a big difference in the argument. I do.not recall whether.that
.8 is the right number or not. But I can prove-it if you like~me 9 to.
10 Q. Well, I. don't know if '52 and54.make much 11 difference, but it's an entirely different article,.is it not?
12 A. It's in the American Journal of Sociology. .I don't 13 think so.
O '14 Q. .You're not intending to refer to, "Some i
15 Accomplishments and Some Needs In Disaster Study," by Killian.
16 in 1954, are you?
17 A. No. I'm referring to a "Significance of Multigroup 18 Membership in Disasters."
19 Q. Could you give me a cite in that, doctor?
20 A. Yes. It's American Journal of Sociology, 57 1952, 21 pages 309 to 314.
22 Q. Thank you.
23 Now, the Bahne-Behnson work, is that not a recount by 24 the author of being in a group which was herded in a house in 25 -Copenhagen during the Nazi occupation of Denmark during World O
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! 1 x> 1 War II where the author describes his recollection of observing 2 the Gestapo approach his hideout? Isn't that the theme of that 3 article?
4 A. The them of the article indeed is about behavior in 5 emergency situations during war time. I think it's more 6 general than you point out, but it's definitely based on war 9 time experience.
8 Q. And war time experiance of somebody hiding from the 9 Nazis in Denmark, is it not?
10 A. I think that is the example that's being referred to 11 frequently, but I believe that the general conclusions go 12 beyond that specific example.
,_s 13 Q. Do you really believe that this source provides any
('
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14 light on the behavior in a Seabrook emergency?
15 A. What I'm doing here in this specific answer, and I 16 think that's what I want to do as honestly as I can, to give a 17 small review about what we know about panic behavior and I do 18 not that in any way one sided way. As you cited before, I 19 tried to summarize it in a neutral non-partisan manner. And 20 what I could find in this literature, as well as in other l 21 literature, and that's what I feel it proves is that there are 22 some exceptions to the question of when panic occurs.
23 And some recent occurrences, for example, is the 24 disaster in the Brussels Sports Stadium, show very clearly that i 25 those two exceptiens are true outside of the area that there l :
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. 1 GOBLE\RENN PANEL - CROSS 11083 s- 1- are claims to. And I think if you'll read very carefully 2, through some of the literature, even the ones of your own 3 business, that is, Miletti, Quarantelli or Sorenson, that this 4 is very much in accordance with what.they are saying. The 5 reason why I'm quoting these very earlier articles is I'think 6 those were the first ones who mentioned-this specific concept.
7 And I think that is the usual way in academia that you want to 8 give credit to the ones that first came out with it.
9 But if you look into those studies that take general 10 summaries and conclusions of the research field, I think you 11 will find absolutely the same kind of results. And I really 12 would like to stress out that it's not that I seek out fs 13 something that is absolutely unreasonable and want to put it in U 14 the connection of Seabrook. I think the things that I've 15 written down on page 84 could be just as well written by 16 Miletti or by anybody else. It is just a summary of the total 17 field. And the controversy may be if that.is applicable to 18 Seabrook or not. And I think those two might be applicable. I 19 don't say they will definitely be applicable.
20 Q. I underatand you're trying to give a compendium of 71 the literature on panic --
22 JUDGE SMITH: Mr. Lewald, you interrupted.
23 MR. LEWALD: Did I?
24 JUDGE SMITH: Yes.
25 JUDGE SMITH: Did you finish?
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(,j 1 'THE WITNESS: Yes. That the two exceptions that I've 2 mentioned for panic behavior or that would actually trigger 3' panic behavior are assumptions or are insights that would 4 probably be approved by all behavioral scientists in this 5 field.
6 BY MR. LEWALD:
7 Q. Doctor, I'm told I interrupted your answer earlier.
8 Let me ask you again. Is what you are trying to do is give us 9 a compendium of anything that appears anywhere on panic?
10 A. You want to have a reference for-panic? Is that what 11 you like, a reference on panic behavior?
12 JUDGE SMITH: Repeat your question, Mr. Lewald.
13 BY MR. LEWALD:
14 Q. Doctor, do I understand what you have told us in this 15 long answer that you gave me that what you have tried to do in 16 your testimony is to give us, or the reader, a compendium of 17 panic situations where panic has been mentioned anywhere in the 18 literature?
19 A. Well, it is a very short compendium of two pages, but 20 that is indeed the intention, to give a compendium on pages 84 21 and 85 of what we know about panic behavior and my major claim 22 towards Seabrook then is that some of these factors may well 23 apply to the Seabrook situation, but they don't have to apply 24 to it. And I do agree with the mainstream of the literature 25 that panic is the less likely benu 17e:1 rosponse.
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GOBLE\RENN PANEL - CROSS 11085 p) m 1 Q. Now, doctor, you refer on page 83 to the way you 2 think people may act as a result of their fear of radiation.
3 A. Yes.
4 Q. And then you cite a magazine article of an event that 5 occurred in Goiana, Brazil.
6 A. Yes.
7 Q. That, as I read it, is an event that involves 8 contamination and people were dying in the stages of 9 contamination. Do you equate the fear of-radiation with the 10 fear of contamination?
11 A. Well, I think in public perceptions that those are 12 very much interconnected. I think it takes a very 13 sophisticated argumentation from a health physics and a medical O 14 point of view to make a clear distinction between tha fear of, 15 radiation and the fear of contamination. I think those are 16 very much related to it, and as far as what I could see from 17 this article that had been published in Science which'I think 18 is much of the normal magazine, one of the best reputable 19 science magazines in the United States, a very clear indication 20 .that people have the fear of contacting other people, even if 21 it was not clear whether they were contaminated or not.
22 And I think that gives us some indication that there 23 is a special infection concerning radiation because you can't
, 24 smell it, you can't see it, it's not essentially detectable and 25 that increases the fear of people, and I don c think it's so
. (:)
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} 4
_. GOBLE\RENN PANEL - CROSS 11086 UJ ' ('j' 1 much the factor of contamination but'the factor'of non-2 visibility that triggers and initiates this fear and avoidance 3 response.
- 4. Q. Doctor, doesn't it suggest somewhat an 5 irresponsibility to suggest that the actions of'the poor 6 unfortunates who are contaminated in Goiana, Brazil, is in some 7 way analogous to somebody seeking shelter at Hampton Beach?
8 A. Well, there are some analogies in the specific case 9 studies. I would be a little hesitant to make a clear cut 10 situation between people behaving in Brazil and people behaving 11 in the United States. As I've cited earlier, there is some 12 indication that people in South America act in many disasters 13 more emotional than Americans would do.
O 14 But I do think that since we are all talking about 15 hypothetical situations here, that this is a situation in which 16 we do have clear evidence from what I have read about this 17 specific issue that people have not helped other people in this 18 situation, that they deliberately short doors in front of them, 19 that they even tried to avoid that people are being buried, all 20 things that are typically non-altruistic and so that there are 21 some justifications for non-altruistic behavior if radiation is 22 involved. And this is an indication for me that radiation is 23 one of the factors that people are most afraid of.
24 Q. It would be fairer to say that where acute 25 contamination is involved, and not radiation. Isn't that O
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1 GOBLE\RENN PANEL -~ CROSS 11087' r-o L/ 1 correct, doctor?
g 2 A. Well, contamination, as I said, I think we have to' 3 distinguish here between what the perceptions are and what the 4 real-perils are. The perception is that radiation is radiation 5 regardless if it comes from inside-of a body or it comes from 6 products that attach to that body, or it comes from somewhere 7 else. I think that people are afraid of radiation and think of 8 radiation as a wave that can do them harm.
9 And I do not believe and I do not think there's any 1
10 evidence that I could recall that people actually make a 11 distinction between contamination as a part of something much 12 more worse than radiation that might be attached to a person.
13 'Q. Have you made any search for this kind of O
\/ 14 information,. doctor?
15 A. I don't have any empirical evidence to prove exactly-16 that this is true but there is no evidence that it's not true.
17 Q. Doctor, on the last page of your testimony,'you say 18 sthat in the event of an order to the beach population to 19 shelter, what must be expected is that many people will find 20 themselves in unsuitable sheltering space, and then others will 21 be, their ways will be blocked from entering shelters because 22 they're already filled. And then you end up by saying that 23 there'll be large crowds of upset and confused people milling 24 around outside unprotected.
25 Do I understand that you are asserting on the basis O Heritage Reporting Corporation l
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GOBLE\RENN PANEL - CROSS 11088 O' 1 of your professional training and education and experience that 2 this is what must be expected and is inevitable and that in the 3 last~ analysis, there'll be large crowds of upset confused' 4 people milling around outside totally unprotected, and people
.5 under these situations won't rise to the occasion as history 6 has shown that they generally do?
7 A. Well, this last sentence is a conclusion of a lot of 8 arguments that have been presented before and that they just 9 didn't count. What it says, and I think that it's fairly 10 obvious is that in specifically we have a situation where 11 shelters are not labeled and a situation where a lot of shelter 12 owners might have left earlier because of the reasons I've just 13 stated.
O 14 In a situation where people might have the perception 15 that the shelters are not very suitable to protect themselves, 16 and in a situation where people would run first to the shelters 17 that seem to be better suited for them than others, we do have 18 the problem of over crowding. That if all these factors come 19 together, that there is a high probability that we will have i
20 confusion and that crowds of people -- and we're talking about 21 a quite substantial number of people -- will be confused and l 22 they'll have difficulty in finding the appropriate protection.
i l 23 MR. LEWALD: That concludes my examination, doctor.
l 24 Thank you.
25 THE WITNESS: Thank you.
l l
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.-s., i GOBLE.\RENN PANEL - CROSS 11089_.
- 1 JUDGELSMITH: Mr.nTurk?
2 -MR. TURK: Yes. Shall I proceed?
-3 JUDGE SMITH: Yes,'please.
4 CROSS EXAMINATION (Resumed) 5 BY MR. TURK:
6 Q. .!Br. Renn, I'd like start off today first of al.1 by.
7 asking whether you had any input into the formulation of the 8 Salmon Falls questionnaire?
9 A. No, I didn't.
10 Q. When did you first become aware that it had been-11 conducted?
12 A. Could you speak up a little bit? I couldn't hear it.
13 Q. When did you first become aware that that 14 questionnaire had been utilized in a survey?
15 A. I think, well, I couldn't recall exactly the date 16 when this information was given to me, but it was certainly in 17 the late fall last year.
18 Q. Were you asked as to whether or not you had an 19 opinion as to the validity of the questionnaire?
20 A. No, I was not consulted for that.
21 Q. Were you asked after the fact?
22 A. Pardon me?
23 Q. Were you asked after that survey had been conducted?
24 A. If I had any input about the validity of the 25 questionnaire?
l }
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\/ 1 Q. No. Let me ask you again.
2 Were you asked to comment on whether you felt that 3_ survey-was a good one?
4 A. No, I was never asked about~that.
5 Q. Not even after the fact? ,
6 A. No. ,
7 Q. Could you tell us your opinion of that survey 8 questionnaire?
9 A. Well, I think I've said that some of the things 10 already.were mentioned in Mr. Lewald's questions. If I had to 11 do the same survey, I might have done it a little different.
12 Q. What would you have done differently?
13 A. Well, I would.have not for example said about what 14 the sources would be, just to make very sure that the source is 15 not mentioned. And I would again state that --
16 Q. Well, when you refer to sources, --
17 MS. WEISS: Would you let him finish his answer.
18 MR. TURK: I want to be sure I understand you, Dr.
19 Renn.
20 BY MR. TURK:
21 Q. When you say, sources, do you mean references to 22 Stone & Webster or New Hampshire Yankee, or Massachusetts 23 Attorney General's Office?
24 A. Yes. But I would like to qualify that in this way, 25 that this bias does not say that the answers are biased towards Heritage Reporting Corporation l (202) 628-4888
GOBLE\RENN PANEL - CROSS 11091
( 1 the alleged interest of the Attorney General.. It may actually 2 -be exactly the opposite.
- 3. But in order to rule out any bias, regardless.from 4 which side it is, I would,.if I had done the survey, I would 5 have_left out any reference to a source.
'6 Q. In order to avoid the possibility of a bias?
7 A. The possibility of a positive or negative bias.
8 Q. All right. What else would you have done 9 differently?
10 A. That's.a very hypothetical question. I've done a lot 11 of' surveys and I'm :ot quite sure what I would exactly have i
- 1:2 done in this specific instance. I should have given more 13 thought to this. I think the procedure was well done, and I 14 don't think there's any problem in'having a written 15 questionnaire sent out. I think the sar.pling was okay because
- 16 it was a total sample of everyone being identified there.
17 I think the questions were unbiased, as I've stated s 18 before. So the only thing that comes to my mind right now was l.
19 the mentioning of the source. But as I said, this bias can go 20 in both directions.
l 21 Q. Have you had occasion, particularly in light of Mr.
i 22 Lewald's examination, to consider the questions asked in the 23 survey?
24 A. Do I consider other questions, is that your question?
25 Q. No. Have you had an opportunity now to look at the i
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GOBLE\RENN PANEL - CROSS 11092
( 'l questions which'are raised in the survey?
2 A. 'Yes, yes. I've seen all four questions.
3 Q. Would you.have asked those questions in the way they 4' are asked?
5 A. Well, everyone has a different way of framing-But from my' view on the questions, I don't think
'6 questions.
7 that those questions are biased. For example, in Question No.
8 1, I might have, because if I didn't mention New Hampshire 9 Yankee or Stone & Webster, I couldn't mention them of course in 10 Question 1, too, because if I leave out all sources, I can't 11 put them in in the first question.
12 So I would have erased that reference to New 13 Hampshire Yankee and Stone & Webster, and just had it a-general 14 question if they would have known if their building has been 15 designated as a potential shelter, leaving it open by whom.
16 Q. What do you understand to have been the purpose for 17 this survey?
18 A. I think the purpose of the survey was to find out 19 what the hotel owners and managers would respond to being 20 designated, or their spaces being designated as a potential 21 shelter, and specifically I think it focused around Question 22 No. 4 which is if they would actually let people into their 23 building or not.
24 Q. And essentially then you believe that the purpose of 4
25 the survey was to determine in advance what these persons' O Heritage Reporting Corporation l (202) 628-4888 t.
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GOBLE\RENN PANEL - CROSS 11093 q'- 'l response might be in an emergency?
2 A. Well, as I said, a verbal response and we are all-3 very cautious about verbal responses that I think a verbal 4 response is better than nothing.
5 Q. Do you know what the persons who were interviewed or 6 who responded to the survey, do you know what their 7 understanding was of the term, shelter?
8 A. I have not made any study about their images of 9 shelters. And what I can see from some of the answers sheets 10 here that they qualified their answer in the rub'ic r of written 11 comments. For example, the first one that I have right here by 12 Robert Hurley said something about a wood. frame building, 13 balloon construction since 1900, in the event of a release, I 7-14 plan to abandon my house and use one of the. bikes, and so on 15 and so on.
16 So what I can see, and I mean, this is just an 17 example is that the respondents did understand what shelter 18 means and were able to qualify the quality of their shelters 19 and give some additional information about what the shelters 20 looked like, and if they felt those shelters were adequate or 21 not.
22 Q. I take it then that you have not spoken with any of 23 the respondents personally?
24 A. No.
25 Q. So your only way of knowing whether they understood O
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~ - the use of'the term, shelter, is based upon their written l 1
2 response to'the survey?
3 A. .That is correct.
4 . Q. .Would you believe that it's Important for the 5 respondents to the aurvey to have an understanding of the' term, 6 shelter?
7 Q. Well,~I do think that most people have a fairly clear 8 connotation of what shelter is. I don't think that there is a-l 9 lot of ambiguity in this term. Also, I usually think it is i
10 good to define terme in public surveys. I do not think that it 11 is necessary for this specific survey. I think that the term,
( 12 shelter, as a non-native English speaker, I'm not absolutely l
l 13 sure about it, but there's no indication that I've ever found O 14' in the' literature that the term, shelter, in English is not 15 well understood by the public.
16 Q. So you' don't think it's important that they 17 understood how their building is to be used as a shelter, 18 that's not important in your mind.
19 A. Well, it's important that as a designated shelter 20 against or for the protection against radiation and I think 21 that has been clearly stated, but I do not think it is really 22 necessary to give a more elaborate definition on shelter.
23 Q. Do you think it would be important for the 24 respondents to understand the way in which New Hampshire Yankee 25 or Stone & Webster intended the use of the word, shelter?
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- 1 A. Well, I come back to my first point, actually. I 2 think if no mentioning would have been made to Stone & Webster 3 and to New' Hampshire Yankee, and also the the Attorney General, 4 I would think that we wouldn't go into this kind of argument.
5 Now, after this has been done, I think any more 6 information on the Stone & Webster report would probably have 7 introduced more-biases to this questionnaire in the sense that 8 if you say, well Stone & Webster were asked to do this or to do 9 that, this would already give the bias that they have done j 10 this. And while there may be some contentions on this side.
11 Or if you say, Stone & Webster have been asked by New Hampshire 12 Yankee to find enough suitable shelters, that would more or 13 less imply that there are enough shelters.
O 14 So I think regardless how you phrase the specific 15 purpose of the Stone & Webster Engineering Corporation study, 16 you would have dealt with a lot of ambiguities, and I think in 17 this sense, it might be better as it has been done here, just 18 to say that it was a study to identify potentini shelters in 19 the beach areas, and not give much more qualification to this 20 specific study.
21 MR. TURK: Your Honor, I don't feel that that's a 22 responsive answer. I'd like to move to strike it, please.
23 MS. WEISS: The answer was clearly responsive to the 24 question.
25 JUDGE SMITH: We'll get the question back and rule.
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/,,)
k- 1 Would you read _it back?
2 (Reporter plays back the question.)
3 JUDGE SMITH: That was the question, Mr. Turk?
4- MR. TURK: Yes.
5 JUDGE SMITH: And you say it's not responsive?
6 MR. TURK: Right. The question is would it be 7 important for the respondents to understand the use of the 8 term, shelter.
9 MS. WEISS: No, no. The question was was it 10 important for the respondents to understand what use Stone &
11 Webster or New Hampshire Yankee intended to make, shelter. And 12 his answer was, no, because if you introduce some explanation 13 of what Hampshire Yankee wanted to do with it, it would have 14 introduced more biases and made it worse than -- it would have 15 made it worse rather than better.
16 JUDGE SMITH: It's not-precisely responsive but it is 17 sufficiently responsive to his understanding of the question to 18 let it remain.
19 MR. TURK: Let me see if I can clarify it a little 4
20 bit, Your Honor.
21 BY MR. TURK:
22 Q. Dr. Renn, what I'm asking you is do you think that 23 the outcome of this survey could be affected by whether or not 24 the respondents, and each of them, understood the use of the
- 25 term, shelter?
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/'N-k-) 'l A. Well, --
2 JUDGE SMITH: Wait.- Let me go on just a little bit 3 better, if I may.
4 The use of the term shelter, as understood by Stone &
5 Webster, not necessarily identifying Stone & Webster with the 6 survey, but using their understanding of the term.
7 Is that what you meant?
8 MR. TURK: Yes.
9 JUDGE SMITH: To take out the element of bias but to 10 get the communication of meanings. Is that what you mean?
11 MR. TURK: Yes, Your Honor. .
12 THE WITNESS: Your Honor, I think that most people 13 have a specific image of shelter and I think that will be O 14 sufficient to state on any surveys. In the specific 15 questionnaire that have been used, there have been two 16 qualifications, precisely the one of physical characteristics 17 of material used in construction and the size of your building, 18 specific. amount of shelter space was determined. So there have 19 been two qualifications right in here that shelter space refers 20 to physical characteristics and to size of buildings, which 21 coincide very well with what peoples' images is about shelters.
22 So I do not see any need for a further qualification 23 on the specific shelter. And I also, I mean, if you look into 24 this questionnaire, there's also another qualification we said 25 that sheltering would be for a short period of time, possibly O Heritage Reporting Corporation (202) 628-4888
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, GOBLE\RENN PANEL - CROSS 11098 s ,1 three to six hours, which I think might even include a pro-2 sheltering bias, meaning that it is only for a short --
3 JUDGE SMITH: : Forget bias.
4 THE WITNESS: -- time.
5 JUDGE SMITH: Forget bits in this question.
6 THE WITNESS: Pardon me?
7 JUDGE SMITH: I said forget bias in this question.
8 That's not the thrust of the question. The thrust of the 9 question is, would it be desirable if the responders of the 10 survey had in mind sheltering as envisioned by Stone & Webster.
11 THE WITNESS: I don't think so.
12 JUDGE SMITH: Not knowing any identity with Stone &
13 Webster necessarily, but the concept of sheltering employed by O 14 Stone & Webeter. And you don't think that-would be important?
15 THE WITNESS: What I'm thinking is that if you would 16 include a definition or the image that Stone & Webster were 17 using in identifying shelters would not help very much in a l .
I 18 survey. What we want to do in a survey usually is to find oct 19 what people believe about shelters, and if they feel whatever l
20 has been designated as shelter is in their perception a 21 protective measure against radiation.
22 If that coincides with what Stone & Webster or other 23 companies have envisioned as a good shelter, that is, I think, 24 not important for a survey. A survey is really a recollection 25 of peoples' perceptions about images. And I think that !s O
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_. GOBLE\RENN PANEL - CROSS 11099: 1
, L i i 'l exactly what it does.
2 BY'MR. TURK:
3 Q. Let me see if'I can summarize, Dr. Renn.
4 You understand that the purpose of.the: survey.was to-i 5 try to_ gauge in advance whether people who own:hotelstor 6 restaurants or other commercial establishments would'make_their 7 bi11 dings available as-shelter in an emergency? Do you agree' 8 that's the purpose?_ [
t 9 A. That is the purpose, yes. !
10 Q. And it's also your testimony that you don't believe 11 the respondents have any reason to understand the way in which 12 those buildings would be used as' shelters? That's correct, i' 13 too, isn't it?
() 14 A. No, I don't think that is correct.. :
1 15 12 Then is it correct that they should understand the 16 use~to which1that but1 ding will be made as ' shelter?
4 17 A. They should understand that the building should be 18 used as a shelter, but it is not absolutely for them to know in ,
f 19 which way these shelters have been envisioned by the Stone & L 20 Webster survey.
f t
21 Q. Well, what should they understand? [
22 A. They should understand that their building has been t'
23 desigriated as a shelter in a nuclear emergency and this 24 sheltering would take place from three to six hours and that I i
l 25 they've been asked in the case of an emergency to let other i
i
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-1 people in to take shelter in their own buildings.
2 And I.think that is sufficient for getting a good 3 response.
4 Q. And in your mind if the respondents, or any of them, ,
-5 did not understand the use to which their building would be put- !
6 as a shelter, then that would make their response to the survey 7 questionable?
8 A. I think it introduces more b'iases than'it would if we t
9 just leave it the~way it is. And I do_think that if you l-10 include the_ specific qualifications that Stone & Webster put 4
11 into this designating shelters is not a part of the survey. I 12 mean, that is what Stone & Webster have done, and that is'a l F
13 part of an objective or inner subjective study or hat is a f_
- V 14 good shelter or not a good shelter.
15- What I am concerned with, and I think what the survey 16 is concerned with, is how people perceive their own buildings ,
17 as shelters, regardless if Stone & Webster says they're good 18 shelters or bad shelters. That is not the point unless this l 19 communication changes their own perception. And I doubt that.
20 I don't think that this kind of communication would have >
21 changed the per eption. It might change response to the ;
22 questionnaires, but not perceptions. ;
23 0 So to summarize then, can you answer yes or no to the 24 following question: do you believe it's important that people ,
l 1
l 25 understand the use to which their buildings would be put as a I (:) !
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t GOBLE\RENN PANEL - CROSS '11101
( il shelter?
j '2 -
MS WEISS: Objection. That's been asked and 3 answered four times.
4 JUDGE SMITH: I believe it has been, Mr. Turk.
5- MR. TURK: The response that I heard before, Your 6 Honor, was, no, it's not important.
7 JUDGE SMITH: That's my understanding, yes.
8 MR. TURK: The more recent response tended to confuse 9 that.
10 MS, WEISS: In your mind, perhaps.
11 JUDGE SMITH: Well, what aspect of the response did 12 you find confusing, Mr. Turk?
13 MR. TURK: The last response that I got from Dr. Renn 14 indicated that it wasn't important that the people understand 15 the use to which the building would be put, but rather that 16 they have a feeling as to whether or not they consider their 17 building to be adequate shelter.
18 JUDGE SMITH: Yes, I understand that. Then he
, 19 introduced one other factor, however, and that is, he goes back 20 to whatever need there may be for them to understand the actual
- 21 use to which the shelter may be put would be outweighed for its 22 potential for bias.
23 MR. TURK: I don't see the logic in that.
MS. WEISS: Well, that's the whole sine qua non of '
24 25 constructing a survey instrument is to avoid bias. So when he O Heritage Reporting Corporation (202) 628-4888
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() j1 answers your questions about would it be good or would it be
- 2 bad to add a definition, yes, he's thinking in those terms, 3 would it create a bias or not.
4 JUDGE SMITH: Which isn't exactly responsive-to the f 5 question.
6 MS. WEISS: Well, it is in the terminology of i 7 surveys. I think he's explained that for the past 15 minutes.
8 JUDGE SMITH: I think you have his answers all 9 collected in those last questions and answers. I think I '
10 understand what his position is.
11 MR. TURKt All right.
12 JUDGE SMITH: I would like to ask at that point, 13 however, if he could explain along that line, what was the O 14 purpose of Question No. 2. ;
15 THE WITNESS: You ask me? ,
16 JUDGE SMITH: Yes, sir. ,
17 THE WITNESS: Oh, I'm sorry.
- 18 JUDGE SMITH: Question No. 2. Let me read it. "Does :
19 your building have a basement or rooms with four stone or 20 masonry walls which could be considered an emergency shelter?
r 21 THE WITNESS: I think that question too is also i
l 22 referring to the image of a shelter, and that image of a 23 shelter contains a notion that it should be a basement or a f 24 very thorough construction. And I think that is what Question j 25 2 is referring to.
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4 GOBLE\RENN PANEL - CROSS 11103 1 1 Now, just coming back -- I'm sorry, I don'*. want to
~2 lengthen the process -- but I think the misunderstanding might 3 be about the purpose of surveys. I think it is always good to 4 educate people about what a good shelter is. And I don't think 5 it is bad to educate people about this specific information of 6 education them about what Stone & Webster'had in mind. But the 7 second thing is that if you want to make a survey, you want to 8 have the unbiased "non-educated" view of the people about what 9 they think their shelter is or is not, and how they would 10 respond in a hypothetical situation.
11 And if that is the purpose of the survey to have this 12 kind of unbiased view, then I think too much qualification of 13 what has been done in the past is detrimental because that O 14 would bias the outcome of the survey. And that is the general 15 rule of all surveys, never give information about what the 16 "objective" answer is because that biases your outcome and that 17 is not the purpose of a survey.
18 JUDGE SMITH: Go ahead, Mr. Turk.
19 BY MR. TURK:
20 Q. Dr. Renn, I'm going to leave this for a moment, and 21 perhaps I'll pick it up again.
22 I want to turn back to the table you have on page 78 23 of ycir testimony. ,
24 A. Yes.
25 Q. Am I correct that this table has absciutely no O Heritage Reporting Corporation (202) 628-4888 s
GOBLE\RENN PANEL - CROSS 11104 1 dependence upon the size of the population? That was your
'2 testimony previously, isn't it?
3 A. No. That is wrong. -I said that some of the stages 4 in that time frame are insensitive to size of population.. But 5 others of course are not. And in particular implementation 6 time is highly sensitive of population sizes.
7 Q. And is that the only one of these categories that is?
8 A. No. Access time is certainly. Notification-is 9 insensitive. Recognition is probably -- it's not totally 10 insensitive but it is not a very vital factor that is being 11 influenced by population estimates. Preparation time is 12 sensitive to population. Orientation is, not as strong,,
13 certainly as implementation and access. Those are the two that O 14 are most sensitive to population size.
15 Q. Have you ever. attempted to run an analysis or to do 16 an estimate comparable to this one if you were to assume that 17 the population of the beach was on the order of 25,000 to 18 30,000?
19 A. No. I just kept within the range which I have 20 outlined, which is 60- to 100,000. Certainly, it would be 21 possible to do this for 25,000 or for any other number but I l l 22 don't have those results available.
23 Q. You'll agree though that for a population on the 24 order of 25- to 30,000, the times would be shorter than the 25 times you indicate in this table?
C)
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/~~
L- 1 A. Definitely, yes.' ;
i2 MR. TURK: Your Honor, I have.nothing further. .
3- JUDGE SMITH: Mr. Watson, FEMA's already passed on
. 4 this.
5 MR. WATSON: I have no questions,' Your: Honor.
6 JUDGE SMITH: Ms. Weiss, do=you have any?
7 MS. WEISS: I have about ten minutes,-Your Honor.
8 JUDGE SMITH: Mr. Brock, how about you?
9 MR. BROCK: No questions at this time, Your Honor.
10 JUDGE SMITH: L1.. Weiss?
11 MS. WEISS: Yes.
-12 CROSS EXAMINATION r
. 13 BY MS. WEISS:
14 Q. You were asked, continuing with the Chart en page 78, 15 you were asked some questions on Friday about what would happen ;
16 if you. changed the rate of spontaneous evacuation from 25 17 percent up to 50 percent, and you responded that implementation 18 time would go down perhaps by a half.
I ,
- 19 And I wanted to pursue that a little bit. Would not 20 some of those spontaneous evacuees also be owners and operators 21 of motel 1, hotels, and other shelter facilities?
I 22 A. Yes, definitely. Now, what I have done with this l
23 specific model is that I assumed that people will find shelter, 24 and you'll find that in my testimony, because if that would not 25 be the case, the time estimate wouldn't make any sensa. So I i (
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'% l 1 excluded from the model, this hypothetical moddl, that not j2 enough space would be available for the baach population.
3 Now, if we take into account a more realistic picture 4 .that.as I've outlined later on and justified in the testimony 5 that quite a few hotel owners might leave, that could add 6 additional time to implementation and access specifically and 7 that could of course then be coming back to let's say'the 8 original numbers that I have outlined here. Now, I cant't give 9 you a real quantitative answer to this because then we have to 10 insert a lot of assumptions about how many hotel owners would 11 leave, what kind of buildings they would leave behind, what the 12 strategy of people would be in the case that a lot of hotels 13 were just being blocked.
O 14 I could for example imagine that if you find out that 15 three hotels that you get into that the owners had already
- 16. left, that this might be an incentive for you to leave also 17 because you think, well, if the residents leave, that may be an 18 indication that I should leave too. So there are a lot of 19 dynamics that will take place.
20 But I think that if you take that into account, we 21 have to add additional time, because all the time has to be 22 added where you stand in front of the door and nobody lets you 23 in.
24 0 Would it be accurate then that just changing the 25 assumption of the proportion of spontaneous evacuees from 25 O Heritage Reporting Corporation (202) 628-4888 l
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GOBLE\RENN PANEL - CROSS 11107 L 1 percent to 50 percent wouldn't necessarily reduce 2 implementation time by a half? ,
~3 A. Not necessarily if you take into account that we 4 change the assumption of the model.
5 Q. Now, it's my understanding that your chart represents 6 ranges of times'for 90 percent of the people to gain access to 7 shelter. Is that correct?
8 A. Yes.
9 Q. Do you have an estimOte for what it would take for 10 the median person to get in a shelter from the time of -
11 notification to access?
12 A. I don't have an immediate number for that but I could 13 certainly try to give you a range of answers there. What we O 14 have to take into account of course is that we just cannot 15 multiply let's say .5 now with the appropriate number, because 16 what happens is that the last ten percent that seek shelter l 17 have a lot of more time consumption to find the appropriate i
18 shelter than the first ten percent. ,
19 So we don't have just a proportional relationship 20 here. And I should make a kind of estimate right here what it 21 might be to have let's say a 50 percent percentile and I would 22 suppose that around a third of the time that I have written
! 23 down as the sum would probably be adequate. And for the first [
24 five I think it should be a little more. I would suppose it ,
I 25 would be around 40 to 45 minutes.
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\> 1 For the maximum time, I think it would be a little 2 less than a third because that would account for that because 3 the maximum is really one in which a lot of those last ten 4 percent have a lot of difficulty so I think I would qualify my 5 answer to around 1.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> instead of 4.5 hours5.787037e-5 days <br />0.00139 hours <br />8.267196e-6 weeks <br />1.9025e-6 months <br /> and the median 6 value would be I'd say around 55 to 60 minutes.
7 Q. Would you take a look at the survey instrument on 8 Attachment 12, 9 A. Yes.
10 Q. We were talking about Quc~ tion 2 in particular.
11 Would the fact that many people answered, no, to Question 2, 12 and then went on to answer, yes, to Question 3, ir dicate that 7, 13 they did not define the term shelter as limited to buildings U 14 with four stone or masonry walls?
15 A. Could you repeat that question again?
16 Q. Yes. Many people -- maybe I'll break it into two 17 parts -- many people answered, no, to Question 2, and then went 18 on and answered, yes, to Question 3.
19 Correct?
20 A. Yes.
21 Q. And Question 2 contains, one might argue, a l
22 definition of shelter and Question 3 does not. Is the fact 23 that many people answered, no, to Question 2, and then went on i
24 to answer, yes, to Question 3 indicative that they did not 25 define, for purposes of this survey, the word, shelter, as
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() 1 requiring a building with four stone or masonry walls?
2- MR. TURK: Objection, Your Honor. Speculative'and
,3 argumentative. The witness has already stated that he has no 4 knowledge of the respondents' understanding of the survey 5 beyond what's contained in the written' response. Anyone'can 6 make an argument as to what the answers mean.
7 MS. WEISS: Well, he's been asked about whether he 8 thought that that Question 2 introduced a bias, and I think we 9 can ask him if the responses to 2 and 3 auggest that there 10 wasn't a bias.
11 MR. TURK: There's no foundation for'her postulate.
12 JUDGE SMITH: Overruled.
13 MR. LEWALD: I'm going to object, if I might, Your 14 Honor. There's no foundation from Ms. Weiss' question.
15 MS. WEISS: The witness answered, yes, many people 16 answered no to two and yes to three.
17 MR. LEWALD: I don't find that as a fact anywhere 18 unless you're goir.g to so testify.
19 MS, WEISS: The witness answered, yes, that~was true.
20 MR. LEWALD: He did answer, yes?
21 MS. WEISS: Yes, he did.
22 MR. LEWALD: Okay.
23 MS. WEISS: Is the objection overruled, Your Honor?
24 JUDGE SMITH: Yes.
25 BY MS. WEISS:
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~- 1 Q. You can answer that, Dr. Renn, or if you want,.I can
- 2 repeat it again.
~3 A. Let me first say that-to Question 2 on page 63 of the 4 testimony, we said that only one in three indicated that they 5 felt that they should answer, yes, in this Question No. 2. And f for Question 3,-it was 56.8 percent. So this qualified my 7 answer that there are irideed people that said, no, in the 8 second question, and, yes, in the' third question.
9 Now, what my understanding of that specific question 10 that was just addressed to me is that is that a contradiction 11 if people say, no, to Question 2, and, yes, to Question 3.
12 Q. No. The question was wheteuc that would suggest that 13 people when they were answering number 3, did not have in mind O 14 necessarily that shelter meant, four stone or masonry walls?
15 MR. TURK: Your Honor, I get'back to the same 16 objection. How do we know what people may have had in their 17 minds. The witness has stated he only can go on what the 18 written responses say.
19 MS. WEISS: And that's what we're asking. What would 20 the written responses indicate.
21 MR. TURK: You're asking for an indication what's in 22 peoples' minds. That's speculative.
23 MS. WEISS: No more than you did, Sherwin.
24 JUDGE SMITH: Overruled.
25 THE WITNESS: My feeling is that if they answer, yes,
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( 1 on Question 3, that does not contradict any quantification or
- 2 qualification in Question No. 2. I think that people have a.
43 feeling of what a shelter it and what it should be, and if that 4 has direct exit from the outdoors, it's a specific question
~
5 about access, and nothing else. And in this respect, I can't 6 seen any inconsistency between Questions 2 and 3.
7 BY MS. WEISS:
8 Q. With regard to the reliability of statements of 9 behavioral intentions, you answered a number of questions about 10 that today.
11 Is this situation -- and by that, I mean the Seabrook 12 situation -- distinguishable from others in the historical 13 record because there may be a conflict in people's minds over b
ss 14 what constitutes altruistic behavior?
15 A. I think that is true. I think we have a lot of
- i. 16 evidence about the connections between verbal intentions to do 17 something, and the actual behavior. And there's a whole school 18 of thought that we should also ask questions about attitude i
19 towards a specific situation. Now, I think if you qualify the 20 specific situation, then it could be what we consider the i 21 motive for people not to do what they say to do is that they 22 are more altruistic or more supportive if they see any kind of 23 a disaster or any kind of emergency or crisis situation.
24 And if that specific situation can be resolved in a 25 moral way, meaning that there is an altruistic behavior also by O Heritage Reporting Corporation l (202) 628-4888 1
GOBLE\RENN PANEL - CROSS 11112 n-K/ 1 leaving that area, then I assume we have a much higher
-2 proportion of people that would do what they said they would do:
- 3 than otherwise. And the reason for having this kind of moral 4 judgment'is that people might'not feel first obliged to have 5 any role in this emergency. Secondly, that they feel that the 6 protection they can offer is not sufficient to jeopardize their 7 own health, for example, and thirdly, that they feel that 8 everyone, including themselves, may be better off by leaving 9 the area.
10 MS. WEISS: I have no further questions. Thank you 11 very much, Dr. Renn.
12 THE WITNESS: Thank you.
13 JUDGE SMITH: Massachusetts Attorney General?
O 14 MS. SNEIDER: Yes, I have just a couple of redirect 15 questions.
16 JUDGE SMITH: Just a moment. I wasn't quite ready.
17 Do you have questions?
( 18 All right. Go ahead, Ms. Sneider.
l 19 REDIRECT EXAMINATION 20 BY MS. SNEIDER:
21 Q. Dr. Renn, Mr. Lewald asked you some questions on l 22 Friday which referred to the studies of natural hazards recited 23 on page 71 of your testimony. Is that right?
I 24 A. Yes.
l 25 Q. And I believe he asked you if those studies dealt l
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k- I with post-emergency response. Is.that correct?
2- .A. Yes, that's correct.
~
(3 Q. Do those studies also include pre-emergency response?
4 A. In'part, they do. Now, if.you specifically 5 considered the stud!es on hurricane.and flooding, they also 6, .contain behavioral' responses to pre-flooding and pre-hurricaneo 7' warnings so in this respect they cover both the pre-emergency.
, 8 and.the post-emergency. situations.
9 Q. Now,_just to get this clear, the 60,000 to 100,000 10 people you considered in your study, that was-the size of the 11 beach population for the entire EPZ, including Massachusetts, 12 is that right?
13 A. That is correct.
(])
' 14 Q. And the basis for those populations is stated on page 15 10 of your testimony, is that right?
16 A. Yes. On page 10, the estimates were a given, and as 17 I said before, that the lower boundary is the one that we took-18 basically from the numbers of the applicants and the upper ones 19 the numbers that the researchers that were testifying in this 20- Court had come up with, specifically, Adler.
21 So those were the two boundaries. And my major
- 22 argument was that if you take the one set of numbers or the i
23 other set of numbers, it does indeed make a difference as we 24 can see, but in those cases, it gives rise to considerable 25 doubt about the feasibility of the sheltering option.
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(). 1 Q. You weren't assuming then that-there are 60,000 to 2 100,000 people in the New Hampshire portion'of the EPZ?
>3 A.- No. No. Definitely not.
'4 Q. Okay. One last question. .Have any of the EBS 5 messages that you have read indicated whether or not an 6 . accident is fast developing.
7 A. As far as I read the messages and I know that they're 8 still not in a. final stage as far as I've heard in this hearing 9 but I haven't heard any reference to the qualification of the 10 accidents that have occurred. So I don't think there is 11 mentioning is that is n' fast developing or a non-fast 12 developing accident.
13 MS. SNEIDER: That's all I have, Your Honor.
14 JUDGE SMITH: Any further questions of Dr. Renn by 15- anybody?
16 MR. LEWALD: This is Mr. Lewald, again, Chairman 17 Smith. I have one question that came up in Ms. Weiss' 18 examination, if I might ask the doctor, t
19 RECROSS EXAMINATION 20 BY MR. LEWALD:
21 Q. And that's, doctor, referring to your table on page 22 68, you talk about a minimum maximum median number. How are 23 you using the term, median, here? Are you using it in the 24 statistical median sense?
25 A. The median refers to a situation which I think is the O Heritage Reporting Corporation (202) 628-4888
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GOBLE\RENN PANEL - RECROSS 11115
() 1 most probable one. That is what I would call it. I think that 2 you have a distribution. As you can see is that the maximum is 3 much more' remote from the median than the minimum from the 1 median.
5 So what I felt was that the distributed is cued to 6 the minimum size, meaning that the maximum amount that I 7 referenced on page 78 is much less-likely than the median so 8 that the median is closer to the minimum. So the median 9 represents the point of the distribution of all scenarios that 10 I feel is most likely.
11 Q. You didn't necessarily take the one that was in the 12 middle of the distribution, but --
13 A. It's the mode of the distribution, also. It means 0 14 the distribution with the highest probability.
15 Q. Considered to be most reasonable is that what I take 16 it?
4 17 A. Not the most the reasonable. I think it's the most 18 --
19 Q. Most probable?
20 A. -- Probable, yes.
21 EXAMINATION BY JUDGE RARBOUR 22 JUDGE HARBOUR: This is Judge Harbour. I have just a 23 question or two of the witness.
24 Dr. Renn, do you know who actually prepared the 25 different versions of the survey forms?
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11116 1 THE WITNESS: Well, I have talked to a Dr. Eckert who 2 seems to be the person that has supervised the whole thing.
3 And I have no knowledge what type of people he has involved and~
4 who actually did the survey.
5 JUDGE HARBOUR Do you have any knowledge as to why 6 the repeated mailings were sent out?
7 THE WITNESS: No. I would like you to ask that 8 Dr. Eckert directly because I don't feel competent to answer 9 that question.
10 JUDGE HARBOUR: In the questioning by Ms. Weiss, I 11 think the question was, assume or take it that a number of 12 people, a large number of people answered, yes, to Question 2 13 and, no, to Question 3. And what was the basis for your O 14 assuming that that was true?
15 THE WITNESS: There is on page 63 as far as I recall 16 there is a statistical break up and it says on Question 2 that 17 two-thirds indicated, no, and 43.2 percent indicated, yes, on 18 No. 3, so they had to be a percentage at least of well, 20 l 19 percent around that said, no, on Question 2, and yes, on 20 Question 3.
i
- 21 JUDGE HARBOUR
- Even if ther9 were many non-responses 22 to the questions?
23 THE WITNESS: Well, I haven't really made up, you
- 24 know, that is very fast response. It's just looking into the 25 distribution of answers on Question 2 and 3 assuming that the l Heritage Reporting Corporation l (202) 628-4888 i
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t 11117 1 non-responses for Question 2 and 3 are around the same.- If 2 that is not true, then certainly we have to reconsider that 3 answer.
14 JUDGE HARBDUR: All right. Thank you. That's all-I-l 5 have.
6 THE WITNESS: Thank.you.
7 JUDGE SMITH: Are there any further questions of Dr.
8 Renn, now?
9 (No response) 10 JUDGE SMITH: All right, Dr. Renn, you're excused.
11 (Witness is excused.)
12 ~ JUDGE SMITH: Now, I understand that we are' going to 13 meet tomorrow. There was some confusion. First the time was l() 14 set at 2:30, and then it was, as we understand it, changed to 15 3:00. We don't have our transcript yet. t 16 But is that the understanding of the parties? l 17 MS. SNEIDER: Yes, it is, Your Honor. ,
f-18 JUDGE SMITH: All right. We'll meet tomorrow and I .
19 will try to assure that the better method of connecting us on 20 the telephone is used. I will talk to the operator in advance.
21 In the meantime, I regret that so much of your time 22 was wasted earlier.
I 23 Is there anything further this afternoon? i i i 24 MR. TURK: Your Honor, just so I'm clear on E 25 tomorrow's conference call, I assume the purpose is to argue ;
(:) -
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( 11 the subpoenas and I hear we're probably going to be going into 2 the written pleadings that we; filed on the subject?
U JUDGE SMITH: The:
- 3 Yes. That will be correct.
i4 pleadings, however, as you'll recall, do'not take.into account-5 the Board's own observations and our.own requirements. And 6 that probably will be equally important.
7 We also hope to give our rationale.for our ruling 8 .that we will not accept the Sholly-Beyea testimony. And we 9 also want to discuss if it would be practicable to start the 10 hearing next week at 9:00 on Monday, rather than at 1:00 as we 11 previously had, but we will take that up for discussion 12 tomorrow. So it will be a busy time following 3:00.
13 Is it still necessary to wait 'til 3:00? Are your O 14 plans still intact, Mr. Turk, you're going to be busy earlier?
15 MR. TURK: Yes. I wish I could predict when I'd get l
16 free. I'm on a motion calendar and I just don't know when the 17 motion will be argued. And --
18 JUDGE SMITH: If there's any chance that you luck out 19 and you get done very early, how about informing us and we'll
- 20 see if we can pick up the parties earlier.
21 MR. TURK All right. Shall we ask the parties then 22 to stand by for a possible earlier commencement?
23 JUDGE SMITH: Well, I hate to ask them to stand by 24 but --
25 MR. TURK: For a telephone call advising them one way
(
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11119 ,
C_f 1 or the other.
2 MS. SNEIDER: Your Honor, this is Carol Sneider from f
- 3 the Mass Attorney General's Office. I have.an appointment that !
,4 would at least take me until 2:30 which I made in light'of the.
~
5 earlier. representation that the conference call wouldn't start ;
. 6 unti1~3:00 o' clock.
l 7 JUDGE SMITH: Are you going tv) represent the Attorney '
8 General in this matter, too?
9 MS. SNEIDER: I will be here with Mr. Oleskey 10 tomorrow.
2
- 11. JUDGE SMITH: Woll, if we could get an earlier start, ,
l
- 12 Ms. Sneider, it would be very helpful if you'd let Mr. Oleskey 13 handle it by himself. I O 14 MS. SNEIDER: Mr. Oleskey isn't here. I don't know [
15 what his calendar is like now. We have been assuming that the. ;
- 16 conference call would take placeoat 3
- 00 and then arranging our 17 schedules accordingly. j 18 JUDGE SMITH: So what's your position?
i 19 MS. SNEIDER: All I'm saying is I can't speak for Mr. I 20 Oleskey who I know has a very busy calendar and that we have r
! 21 been arranging our calendars in light of the representation on
[
! 22 Friday that the conference call would take place at 3:00 l 1
l
, 23 o' clock. I 24 JUDGE SMITH: Well, I understand that, but you're not [
- L
! 25 able to go earlier, is that it? Is that what you're saying? ;
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11120 1- MS. SNEIDER: Yes.
2 JUDGE SMITH: All right. We're adjourned until 3 tomorrow at 3:00.
4 MR. BROCK: Your Honor, if I could, I just ..ad one 5 point of~ clarification. Is the motion to compel on the Ed 6 Thomas that was filed in conjunction with getting further 7 testimony from him, will that also be addressed tomorrow?
8 JUDGE SMITH: Mr. Thomas' appearance will be 9 addressed. So in that context, yes, it will be.
10 MR. BROCK: Thank you, Your Honor.
11 MS. SNEIDER: Your Honor, I have one question for the.
12 Reporter. I wanted to arrange for a transcript from today's 13 hearing, I mean, cross examination. ,
O 14 JUDGE SMITH: Ms. Sneider, I've been thinking about 15 what I think is unnecessary inflexibility. I think you should 16 consult with your colleagues tomorrow and ascertain definitely -
17 that you could not be present any earlier. We have a lot of ;
18 work to do. You have a lot of people that could represent you 19 on it.
J 20 Would you do that, please? ,
21 MS. SNEIDER: I will do that.
]
22 JUDGE SMITH: And inform Mr. Turk. r 23 MS. SNEIDER: I will do that.
24 JUDGE SMITH: All right, thank you. l A
25 I'm sorry, did I interrupt? ,
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s 1 MS.-SNEIDER: I just had a question for the Reporter
~ ~ ~
i 2 about getting today's transcript.
i i
3 -JUDGE SMITH: Tomorrow, i
i4 Well, do you want to talk to him after we adjourn?-
5 MS. SNEIDER: Yes.
6 JUDGE SMITH: . All right. Anything further?
7 (No response.)
8 JUDGE SMITH: Nothing further. Then we'll adjourn [
9 until tomorrow at 3:00 or at an earlier time if it can be 10 arranged. l 11 Ms. Mitchell? Oh, she's off.- That's right.- It 12 would be helpful if the parties would reduce their reliance 13 upon the speaker phones. !
O 14 All right, we're adjourned. .
i 15 (Whereupon, at 4:57 p.m., the hearing in this matter [
16 was recessed, to reconvene the following day, Tuesday, May 10, j 17 1988, et 3:00 p.m., in the same place.) ;
18 ;
19 i
20 i 21 22 j 23 24 25 i
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1 CERTIFICATE 2
(:) This is to certify that the attached proceedings before the 3
4 United States Nuclear Regulatory Commisr, ion in the matter oft S Name: PUBLIC SERVICE COMPANY OF NEW HAMP3 HIRE, et a1/
(S abrook Station, Units 1 and 2) 6 7 Docket Number 50r443-0 8 Place: BETHESDA, MD 9 Date: May 9, 1988 10 were held as herein appears, and that this is the original 11 transcript thereof for the file of the United States Nuclear 12 Regulatory Commission taken stenographically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reporting company, and that the tranocript is a 0 15 true end ccurete recp d of he f soin er ceedines.
16 /s/ h v 17 (Signature typed): KENT ANDREWS 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 O Heritage Reporting Corporation (202) 628-4888
,