ML20236J400

Transcript of 871102 Evidentiary Hearing in Concord,Nh Re Offsite Emergency Planning.Pp 4,660-4,815

ML20236J400
Person / Time
Site:	Seabrook
Issue date:	11/02/1987
From:	Atomic Safety and Licensing Board Panel
To:
References
CON-#487-4804 ASLBP, OL, NUDOCS 8711060053
Download: ML20236J400 (200)

Text

{{#Wiki_filter:- e ORIGINAL UNITED STATES i NUCLEAR REGULATORYiCOMMISSION i , = = = _ = = = = = _ = = = = _ = = = _ = = = = _ = = = = = _ = = = = = = = _ = = = = = = = _ = = _ = = _ _ _ = = = = = = _ = _ _ = =, IN THE MATTER OF: DOCKET NO: 4 50-443-OL EVIDENTIARY HEARING. ) 50-444-OL ) OFFSITE EMERGENCY PUBLIC SERVICE COMPANY OF ) PLANNING ) NEW HAMPSHIRE, et al ) ) (SEABROOK STATION, UNITS 1_AND 2 ) O LOCATION: CONCORD, NEW HAMPSHIRE PAGES: 4660 through 4815 DATE: November 2, 1987

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4660 r0 ~ 1 UNITED STATES NUCLEAR REGULATORY COMMISSION 2 ATOMIC GAFETY AND LICENSING BOARD PANEL Sec50T&I 3 1 4 In the Matter of.: ) ) Docket Nos. 5 PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et al., ) 50-444-OL 6 ) I (SEABROOK STATION, UNITS 1 AND 2) ) 7 8 Monday 9 November 2, 1987 10 Hall of Representatives New Hampshire Statehouse 11 Concord, NH 12 The above-entitled matter came on for hearing, 'p' 13 tv. pursuant to notice, at 1:01

p. m.

14 BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN 15 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission 16 Washington, D. C. 20555 17 JUDGE JERRY HARBOUR, MEMBER Atomic Safety and Licensing Board Panel 18 U. S. Nuclear Regulatory Commission Washington, D. C. 20555 19 JUDGE GUSTAVE A. LINENBERGER, J R., MEMBER 20 Atomic Safety and Licensing Board Panel U. S. Nuclear Regulatory Commission 21 Washington, D. C. 20555 22 23 24 25 Heritage Reporting Corporation (202) 628-4888

1 N.) ~s, 4661 1 APPEARANCES: 2 For the_ AppJj. cant. : 3 ' THOMAS G. DIGNAN, J R., ESQ. GEORGE H. LEWALD, ESO. .4 KATHRYN A. SELLECK, ESQ. J Ropes _& Gray 5 225' Franklin Street Dorton, MA' 02110 Egr thp_NRC' Staff: 7 ? SHERWIN E. TURKy ESO. 8-Office of General Counsel j U. S. Nuclear Regulatory Commission ] 9 Washington, D. C. 20555 j \\ I 10 Egf the FederaLF.Jmey_genqyjianagement ' Aqeng.y 11 H. JOSEPH FLYNN, ES9. ] GEORGE WATSON, ESQ j j-v X_) 12 Federal EmerDency Management Agency 500 C Street, S. W. 13 Washington, D. C. 20472 14 For the__. State of New Hampqhirel 15 GEORGE DANA BISBEE, AGST. ATTY. GEN. GEOFFREY M. HUNTINGTON, ESQ. 16' State of New Hampshire f-25 Capitol Street 17 Concord, NH 03301 f 18 For the Commonwealth of Massachusetts: 19 CAROL SNEIDER, ASST. ATTY. GEN. STEPHEN H. OLESKEY, ESQ. 20 ALAN FIERCE,_ESQ. One Ashburton Place, 19th Flcor 21 Boston, MA 02108 22 Eor the New Enaland Coalf_t_ ion Against Nuclear Pollution: 23 (No appearances entered) 4 24 I ' [5~)?"$ - j l l gg 1 Heritage Reporting Corporation 1. (202) 628-4888 l t-

v '4660 ~ 1 APPEARANCES: (Continued) .Enr tte seseoast Anti-Pollutipn t,e_qquei 2 L 3 ROBERT.A. BACKUS, ESG. Backus, Meyer, & Solomon-4' 116 Lowell Street Manchester, NH 03105 5 JANE DOUGHTY' -6 Director Seacoast Anti-Pollution League 7 5 Market. Street Portsmouth, NH 03801 G Egr the Town of Hampton: 9 PAUL MCEACHERN, ESO. 10 MATTHEW T. BROCK, ESO. Shaines & McEachern .11' 25 Maplewood Avenue P.A. Box 360 } 12 Portsmouth, NH 03801 4 13 For the Towns of Ha%RIAD_ Falls and North -)7' ' Symp_t_g_n and South Hamojty n 14 ROBERT A. BACKUS, ESQ. 15 Dachus, Meyer & Solomon 116 Lowell Street 16 Manchester, NH 03105 17 For the_ Town of Amesbunyl 18 WILLIAM S.

LORD, Selectman.

19-Town Hall Amesbury, MA 01913 20 E9r tile Town of Keng_iAqton: 21 l SANDRA F. MITCHELL ] I 22 Civil Defense Director L KensinDton, NH 03827 23 f I 24 l 25 1 Heritage Reporting Corporation (202) 628-4888 %_______._m_... .. l

s ,e y G1 i' 4662 ) 1 J_ N _D___E X L2 WlINESEER REEGI CBRM BEDIREGI BERBRSR E10M 3 SHELDON SULLIVAN by Mr.L Backuu. 4G76 .4 by Mr. Dignan-4715 by Mr.. Brock 4726 4 5 by Mr. Disbee 4728 1 by Mr. Backus 4732 l 6 EsthAl_2_ '7 JOHN BONDS (prefiled) 4740. j PAUL FRECHETTE 0-RICHARD STROME 1 L WILL'IAM WALLACE 9 WILLIAM.COLDURN' ANTHONY CALLENDRELLO 10 JAMES MACDONALD 'by Mr. Lewald 4733 .1.1 by_Mr. Backus 4742 l 12 '14 15 16 j 17 1e i 19 20 21 -I ^l ee q ) 23 4 24-i 25 l I) i Heritage Reporting Corporation l (202) 628-4888 ) i l 1 w---_-_-_ J

i r^' i L.. 4664 1 INDEX (continued) 2 EXHIBITS MARKED RECEIVED DESCRIPTION 4 3 BPPLICANTS: 4 No. 1-A 4685 4685 One page corrected Table 3.1-1, state 5 agencies personnel resource summary 6 SAPLt 7 l No. 3 4790 4809 Three page memo, 8 Feb. 6, 1987, Colburn to staff, with survey L 9 questionnaire and cover letter 10 No. 4 4796 4809 Two page computer 11 printout entitled fq Survey WK-1 r l t.,,,) 12 No. 5 4797 4809 Two page survey 13 results, reasons for not participating in i 14 ESus 15 16 17 18 19 20 21' 22 23 24 O 'I 25 i Heritage Reoorting Corporation j' (202) 628-4888 L

i 1 4665 .1 1 J.tl-Q E X (Continued) i 2' INSERTS 3 pesqn12t_ ion P_a_qe 4-BAPL cross-examination plan for Sheldon Sullivan 4675 3. ,5 Applicants'. ENhibit.1-1, in evidence, .j Table 3.1-1,. state agencies personnel resource 6 summary-4685 7 Resume of James MacDonald 4736 6 Resume of William Colburn 4737 'I 9, Applicants' direct testimony.No. 4 on decontamination and reception centers' 4740 ' 10 l 11 i 12 13 ,ck 14 15 (( - 16 17 18 1 19 .j 1 20 21 ga /> 23 ) 24 l l' 25 Heritage Reporting Corporation (202) 628-4888 9___..____.__.___Ai_-

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1 4666 c1 PROCEEDINGS 7 % r a .i I (.Gi, ' :2 j; JUDC$E ) SMITH: Afew.preliminaryitems.[1would like 45p t> t,-. 'I'had one .g i, G r.3 to report on t'wc/ ex parte telephore conversations. u et. s .i .y Oleskey concerning. ari account of. what the pending 4 with Mr. t kf, / ys> a $a

rptions were with respect, to objections in limine.

-I had not 1 , }- < ty t. g. l 1 %vtp,,. 7 y. position on Mr. Luloff,'and,also discussed with..him the j W: % ; ' w. p ! T, ,,d ~ i 1 8' $ 6ailability of. hearing space in Boston. /c .y s y g., b r s. r iMk .9 I ' had an ex parte (' conversation with 5 Mr. Turk in which )/ r

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,D' 1 I ' asked ; hitil if.he. intended to filet a staff position-on the-; i . and. l g on in limine with< respect to the Sho11ey - Beyea panel, t .. !n ? j y jjy 12. they infh med me that'they wished to-be heard or' ally.' '/ t-qy ( I don' t know if everyone has received the memorandum ,I I. 13 Y ',1; y - ? :). 't c : y y p-e. issued,f n last week in which we reported that(hihere:are two 11 i ' ~ 14 we k< f 1 ', 15s additiond!'%seks' available in thits room. Has everyoner! received n, 16 "' } '.;. G' , r,y, J that7 lyou haven' t received that? No,'Your Hont% 'y, 7 s ztf MR.-BROCK: g ~ ( 'i , - 18 JUDGE SMITHr,g I' m sorry, ' we > should have telephoned. / ci c- /. [ 19 We have tihk week begikoing November 30th, then off a week," t it. f, -~ .,, r. 1 20 then the' week beginning whatever that would'be,. December 14th e'. r 21' is available to us i,n this hearing room, and we plan to use it. ] l } *. y 22 We also shktbf,that it will noimn11y be.our practice ,[' l . br } ,,6 i 23 to adjourn at abouti$B.:30 on Friday af ten ncons.

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( ..f \\ 24 The Board is now ready to hear oral arguments on 25 three of the motions to strike testimony, - -l.. >j g ) 't.. f,, the Sbc.dley " Beyea \\ i l l . p) 1 LL l ?" l Heritagn Reporting Corporation l '(202) 628-4888 ,. W ri s I ~ l // _._______d

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a s ~ 4667 / r c j We are j) + 1, panel, the Lulof,f: testimony and the FEMA testimony. .g

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E . prepared any time thee parties. In there any n:vdticular time +,, 3 tMt the pacties w.atId ifke? j 7 L' 4 I propose that : naybe ' iti de finish early-this s [< { \\- 's \\r 5 a f ttsnoon, we' 11 takqsupiany of them. Otherwistp. schedule for il \\.. .!J l + s. 6 first thing tomorrow'inoe ing, iWould ev rybo,4 h,e, ready by'that 7 time. N .!l 8 MR. OLESKEY: I, think the time tomorrow mening would it. I 9 be fina from our perspective. s.~' ) 10 t JUDGE SMITH: You would prefer 6 morrow morning? 9 11 MR. OLGKEt t Yes, because one on'the asd stant ,I -s .s '/ '/ ) 12 attorney genera 4s who has done the princF#al work had, asked to 13 argue that, and.be is not here tc' day, Mr. Trafico e. h' ) \\- 14 JUDGE GrtITH: Okay, that would be the case witt) the 15 Sho11ey - Beyea ,g " t, 16 MRb OLESKEY: Yes. -/ ~ l \\ \\ 17 } JUDGE SMITH: -- panuI. But how about the ottier two, \\ i c. i. 18 could yo ktd e.those this afternoon? . t I s \\' i 19 itit. OLESKEY: Sure. e. 20 JUDGE SMITH: Sure..All right,'.well, it'we have an 7 s / 1 9) y i 1 2'J bp,portunity t' nit, a?.ternoon we will take cr.e of 1.he other two. -\\ s s ef i @P,, If not, we will schedulte them, 'all three for the fi<st order of .,) i 'E3 business tomorrow morning. i r s y g J 24 Is there any preliminary matters to be raised by the ( f 2':3 pitrtles? [, / Heritage Reporting Corporation (202),628-4888 , { o. i,, l 's ) / i h1 i I q___ /

h.l: ( i. I I 466Ei \\ VM-L "_[ ! 6 1; MR.. BROCK: Your Honor, I had -- Matt Brock for 1 l l~ 2 Hampton, Your Honor. 3 We have a witness, Dan Trahan, who was to testify on f 4 th'e special needs panel. I believe he could be available 5 Wednesday, Thursday or Friday. I understand Mr. Dignan does 6 not want his panels interrupted, but it would help if I could 7 get some guidance now as to when he should be here this' week. 8 JUDGE SMITH: I don' t know how we could help. Are 9 you talking:about interrupting the Applicants' Direct' Testimony k 10 No. 47 11 MR. BROCK: Well, Your Honor, I could have him here 12 Wednesday morning to testify first thing if that's agreeable to 3 13 the parties.

f j A_2 14 JUDGE SMITH

I really don' t know what'you are asking 15 me. -I mean, you are asking for us to guarantee that he could 16 be heard first thing' Wednesday morning? 17 MR. BRDCK: I' m not -- 18 JUDGE SMITH: It seems like a reasonable time. I 19 That's fine. 20 MR. BROCK: That's fine. Okay, Your Honor, I will 1 21 have him there then. 22 And one other matter, Your Honor. I have already 23 distributed copies of a motion filed on behalf of the Town of 24 Amesbury to the parties, and I should just like to pass those 25 on to the Board. They are being filed through the mail, but I Heritage Reporting Corporation (202) 628-4888

7_~ l l 4665 '~' 1 am providing copies, because it concerns the shelter issue, and 2 1 would like to bring that to the Board's attention now. 3 JUDGE SMITH: Okay. i 4 MR. FIERCE: Your Honor, Alan Fierce from the Mass. t, 5 AG's of fice. l l 6 Defore Matt finally concludes that he want to bring 7 that witness in on Wednesday morning, I was going to propose i 1 i B that the parties get together after the end of today's ( 9 proceedings to see where we were so that we could try to gauge i L 10 what the schedule would be for bringing in the rest of the l l 11 witnesses that we have this week that we want to, hear. f 12 I had indicated I have one of my witnesses in from es - 13 Israel who is here this week, Avi Ceder. I know that the ETE ( 14 panel has, the Applicants' ETE panel has some folks who are 15 coming in from out of town, and I would propose that perhaps at ) i 16 5:00 today Matt, myself and Tom Dignan get toDether and try to 17 work out some schedule that would be convenient for all. 18 JUDGE SMITH: Yes, that's always the Board's 19 preference is for the parties to try to work out informally the 20 most efficient and least burdensome appearances. And we should 21 try to schedule only when there is an impasse. 28 MR. BACKUS: Your Honor, we have two pieces of f 23 testimony we would like to make available to the Board and the 1 24 parties today. One is supplemental testimony of Donald 25 Herzberg which is occasioned by the changes in the Applicants' 1 <~1 xr 1 i l Heritage Reporting Corporation L (202) 628-4888 L { i 1 l

g' l 4670 1 testimony on decontamination and reception centers. And Jane I 2 DeuDhty will hand that out. 3 The other is rebuttal. testimony of Joan Pilot 1 4 regarding emergency services, particular ambulance services, 5 and both of those individuals will be available this week. Mr. 6 Herzberg will be available -- Dr. Herzberg will be available 7 tomorrow afternoon which is our present expectation of when we 8 think he would be likely to be logically fit in. 9 JUDGE SMITH: Okay. 10 (Pause.) 11 MR. BISBEE: Your Honor, this Dana Bisbee. 12 JUDGE SMITH: Mr. Bisbee. p 13 MR. BISBEE: You' 11 recall a couple of weeks ago we N2 14 brought up to your attention the request for a subpoena of a 15 certain state police colonel by SAPL. And the State of New 16 Hampshire and Mr. Backus had agreed to the resolution of that 17 request whereby the state would produce a different witness to ~ 18 testify in three distinct areas. That witness is Captain 19 Sheldon Sullivan. He is here this morning. Mr. Backus has 20 been notified of his availability today and indicatud to me ) 21 last week that today would be an opportune time for him to 22 examine Mr. Sullivan on the various questions of state police 23 personnel availability. j f 24 If that were acceptable to the Board and the parties, 25 it may be most appropriate to begin with that examination, p~i iL l Heritage Reporting Corporation f (202) 628-4888 I

4671 ,] N_ 1 JUDGE SMITH: Was that discussed with the parties?. 2 MR. BACKUS: Yes, the issue was discussed with me,. 3 and that's perfectly aDreeable to me. i 4 JUDGE SMITH: Well, do you have any objections? 5 Anybody have any objections to.that? 6 MR. DIGNAN: No, I've got another preliminary matter i '7 I would like to bring up before we -- 8 JUDGE SMITH: All right. But as to the testimony, f 9 would it be all right with you then if we lead off with that 10 this afternoon? f 11 MR. DIGNAN: Sure. 12 JUDGE SMITH: Okay. Mr. Dignan. 13 MR. DIGNAN: Your Honor, I would like to distribute a s 14' corrected version of the ETE testimony and it's got an errata 15 sheet with it. It basically cleans up a bunch of typographical 16 errors and so forth. I don' t think it's any matter of 17 substance, but the other parties can make that judgment. 18 (Pause.) 19 JUDGE SMITH: Any other preliminary matter? 20 MR. TURK: Your Honor, Sherwin Turk. 21 I would simply note for the record that I have 22 distributed this morning a copy of the final rule adopted by 23 the Commission last week dealing with emergency planing where 24 state or local governments are not cooperating in the planning ( 25 process. I l Heritage Reporting Corporation ) l (202) 628-4888 l i I I l l l U I

i 1 1 1 i l l 467E E"i. I 'f - q 1 JUDGE SMITH: Thank you. We appreciate that. 2' All right, anything further preliininarily? l 3 M R. DIGNAN: Your Honor, on the theory that you have 4 asked that counsel advise the Board at the earliest possible j 5 moment of any change in theory of the case, or any other matter i 6 that may come up that have to be dealt with by the Board, and 7 following on Mr. Turk' s indication that he has distributed the 8 new rule and the statement of considerations in connection 9 therewith. issued by the Commission, I think one matter the 10 Board may want to give some consideration to, and I'm quick to i 11 say I filed no motion. I realize this, and I' m not sure what l 12 the natura of the motion would be. Is that the Commission has l y3 13 possibly stated in this rule that a certain ame.unt of testimony l ls2 14 that has already come in in this proceeding and is slated to l 15 come in in this proceeding may be irrelevant. And this is the 16 statements -- it's made twice. I' m reading from page 17. "The 1. 17 presiding licensing board should not hesitate to reject any la claim that stato and local officials who refuse to act to 19 safeguard the health and safety of the public in the event of 20 an actual emergency. In actual emergencies, the state, local 21 and federal officials have invariably done their utmost to 22 protect the citizenry as 200 years of American history amply '3 demonstrates." 24 And what I am raising, granted a preliminary matter, 25 is does this mean the Commission has in essence said this whole Heritage Reporting Corporation l (202) 628-4888 i __.m.-_

J ti. m' 1 1 1 4673 /~T -[ 1 issue of human response is out of emergency planning licensing 2 cases at this point. I' m not prepared to address it fully 3~ today, nor am I asking anyor,e to. But I did want to advise the 4 Board that my reading of this indicates that it may well be 5 that a determination can and should be made at some point in 6 - this proceeding as to whether we haven' t got a big block of 7 testimony, some of it already in, certainly some of it to come, f 8 some of it mine, as to whether or not the Board feels it has to 9 receive and undertake to listen to cross-examination on it in -10 light of the Commission's pronouncement in this latest 11 rulemaking statement. 12 JUDGE SMITH:. So this afternoon you are giving as .i 13 much notice as you can to the parties that you may be raising . (ag. (/ l 14 that. 1 l 15 MR. DIGNAN: That's my only purpose, Your Honor, and 16 to the Board. I thought this wasa't one to spring the last day 17 of the hearing or the day before a witness took the stand or f i 18 something like that. i ( t 19 MR. TURK: Your Honor, along the same line I would 20 note that on page 27 of the statement of consideration the 21 Commission addressed the standard of adequacy for emergency L 22 planning vis-a-vis what is necessary in the way of dose j L 23 reductions, and whether the emergency planning rules have any l l l 24 standard for dose reduction built into the emergency planning I i 25 regulations. l I (~') v Heritage Reporting Corporation j (202) 628-4888

.I ,,, :D "j g,-4 467L 1Q. .1 And during argument on the motion to exclude the 2-Sholley' testimony, I will be referring to that language. 3 JUDGE SMITH: All right. The Board had noticed both ~ 4-statements and both categories of statements in the statement 5. of consideration,.and recognize their relevance, 6 Anything further before we proceed? 7 All right, M r. Bisbee, is your witness present now? 8 MR. BISBEE: Yes, he is. 9 JUDGE SMITH: It's Mr. Backus' witness, I. guess it .10 is. i 11 MR. BISBEE: Yes. 12 JUDGE SMITH: Do you want a subpoena for him? 13 MR. BISBEE: No, that's not necessary. 14 JUDGE' SMITH: Okay. i '15 MR. BISBEE: Why don"t I call Sheldon P. Gu11ivan to 16 the stand. l' 17 JUDGE SMITH: All right. This is Captain Sullivan? 18 MR. BISBEE: Yes. 19 Whereupon, 20 SHELDON P. SULLIVAN 21 having been first duly sworn, was called as an adverse witness l 22 herein and was examined and testified as follows: l 1 ] 23-JUDGE SMITH You might, if you will please, state i 24 your name and your position. j I i .25 THE WITNESS: My name is Sheldon Sullivan. I am a i r-c_) 4 Heritage Reporting Corporation (202) 628-4888 j L I L l __________--____A c

L: L' L 4675 4 $ f-]). { 1 state' police captain for the New' Hampshire State Police. I { 2 have been so employed for 22 and a half. years, and at the 3. present: time I.am a division commander. 'l 4 JUDGE SMITH: Mr. Backus, you may proceed. 5 (SAPL Cross-Examination Plan a 6 for Mr. Sheldon Sullivan l 7 follows:) 6 9 10 11 12: ( 14 15 16 17 18 s 19 20 21 22' 23 24 25 (:) { Heritage Reporting Corporation (202) 628-4888 1

(e, ) i L 1 3- [Q l UNITED STATES OF AMERICA - E NUCLEAR REGULATORY COMMISSION L before the h ATOMIC SAFETY AND LICENSZNG BOARD i In the Matter of ) Docket No. 50-443-OL ) -) PUBLIC SERVICE COMPANY ) (Offsite Emergen?y Planning OF NEW llAMPSHiRE, et al ) Issues) ) (Seabrook Station, Unit 1) ) SEACOAST ANTI-POLLUTION LEAGUE'S PLAN FOR C110SS EXAMINATION OF CAPTAIN SHELDON SULLIVAN l 1

1).Ilow many State Police are currently stationed at Troop A in Epping? How many officers from Troop A are on duty at any one time? How many other police are available statewide and where are they stationed? How many State Police are on duty j

V at any one time statewide? Do you agree with the numbers at Table 3.1-1 of the Personnel Summary?

2) Have State Police practiced or in any way been familiarized with setting up the traffic controls at Access Control Posts (ACP's) and Traffic Control Posts (TCP's)?

What priorities have been assigned to the ACP's and TCP's,.in other words, list which posts will be staffed first?

3) Have you any concern about State Police coverage in other parts of the state if personnel are concentrated in the Seabrook EPZ area?

3

4) How quickly could State Police personnel from other areas be brought in to supplement the Troop A officers? From what barracks?

y 5) Have State Police practiced putting the towing services at Appendix E to procedures for Troop A in Volume 4B of the NHREPP on stand by as per #5 of the Dispatcher Procedure?

6) State Police report in 15 minutes (Applicants' direct #7, page 45,10/1/87).

Where will they come from? Where will they go first?

7) On National Guard, page 66, what training do they have?

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8) On 15% capacity reduction, do you subscribe to this?

What is tne " driver fg) uncertainty"? 1 I

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9) llave State Police had training in the use of dosimetry? What did the training

'k1 consist of? What is the upper limit for State Police to remain on duty?- (Appendix B .to Troop A procedures indicates 20R. Is this still true?)

10) Have State Police been instructed in the proper use of Kl?

11) Do you believe that State Police from other areas of the state can appropriately direct traffic in the Seabrook EPZ? a f i e 1 ~h~y .~ i

.l, ,.,[,<( -!!:U N 4l 4 I' ,s ! 4 gco . e a .., s !, :p i l 1' E .SULLIVAN.- CROSS 4676, l~1J" 1-CROSS-EXAMINATION 2 BY MR. DACKUS 3-D. Good afternoon, Captain. 4 A (Sullivan) Good afternoon, Mr. Backus. l 1 5 O I am Attorney Backus.

1. represent the Seacoast Anti-t s

6 Pollution League. 7 Captain, I am led to believe that you are'the person 6 primarily knowledge about state police resources in regard to-9 the New Hampshire Radiological. Emergency Response Plan; is that s 10-correct? 11 A (Sullivan) That's correct. 12 O What work have you done with emer gency management 13 generally to provide input intoLthat' plan? 7-)q n~ i ? 14 A (Sullivan) Well, all my experiente came about as the i 15 Troop A commander which covers Rockingham and Strafford County, j i o 16 and of course Seabrook is located in Rockingham County. My { 17 experience and my expertise is 22 years with the New Hampshire f i 18 State Police as far as state police resources. 4 19 Q And what is the current staffing levels at Troop A, k 20 Captain? 21 A (Sullivan) At the present time Troop A has 36 sworn 22 personnel. 1 - 23 O And in any particular time how many of those 36 are { 24 on duty? 3 i 25 R (Sullivan) Well, that will vary as the time of day, [( ) l Heritage Reporting Corporation j (202) 628-4888 J l _____________-___a

f ] SULLIVAN - CROSS 4677 i 1 day of week and many factors. enter into.that. 2 'O Okay. Say on a summer weekend, how many troopers 3 would be on duty with Troop A typically? 4 .Sullivan). Day shift, night shift? You are going to ( 4 A 5 have to be a little more explicit as to 'what you are looking 6 for. 7 Q Okay, let's say a day shif t. 8 A (Sullivan) On the average, you will have somewhere 9 approximately seven men on duty at a given time, six - seven 10 men. l. ( 11 O How about the' night shift? 12 A (Sullivan) Dasically the same. Basically what you 13 have is one-third'on, two-thirds off. i 14 O How about during the week? f I f 15 A (Sullivan) It's basically the same for seven days a 16 week. }. l 17 0 Now what is the availability of the men who are'not 18 on duty, not making up these six or seven that are typically on 19 duty you have mentioned? { 20 A (Sullivan) If it is a duty day, they are on call and 4 21 subject to response. 22 O And what is a duty day then? 23 A (Sullivan) In a given week you are responsible for 24 42 and a half hours a week, five days a week. So you have two 25 days off a week. If you worked a particular shift on a day, l O l Heritage Reporting Corporation (202) 628-4888 i 1 l' l'- r l l

o. n l t .SULLIVAN _ CROSS 4670 . f/ i 'l then that is'your.' duty day. 2 O' All right. So if we could'again'take,a similar -- 3 just to' take a hypothetical,'a summer weekend during the' day, 4' there would be six or seven men, you have said, on duty, and 5-how many would be on call as you have described it? 6 A (Sullivan) It would basically be another third.. f i 7 Q Another third. 8 And then the final third would be on free time.for-l 9 them at that time. - 10 A (Sullivan) Days off. 11 Q Is that right? .i . 12 A. (Sullivan) Right. 13 O 'Just looking quickly here, it looks that if you add -] M 14 up these one-thirds, one-thirds, I don' t get.to 36. Would you 3 J 15 care to explain -- { 16 A (Sullivan)- Well 17 Q -- what the other members of the troop might be 18 doing? 19 A (Sullivan) Annual leave, sick leave, special duty. s,_, - - - l 20 Q Okay. 1 21 A (Sullivan) There are seven patrols in the troop, and k 22 those seven patrols are manned during a given shift. { 23 Q Now when you say typically on these shifts it's a 24 third of the -- the available troopers are duty roughly a third j 1 c 25 are on call, and roughly a third are on their own free time, j j Heritage ReportinD Corporation ] (202) 628-4888 l. 1 ._-____________________________O

'},, I SULLIVAN - CROSS 4675 l'% 'I 1 the' men on duty would be' typically in cruisers out on the 2 highways? 'f i 3 A (Sullivan) That is correct. 4l Q And the. men on call, are they required to be in any 5 part'icular proximity to the troop headquarters? 6 A (Su1~11 van) We have a resident troopers system. The '7 men do not report to the troop station. They have their 8 cruisers at home and would be responding from their residences. ( 9 Q Now am I correct, Captain, that Troop A is the only } 10 troop with its actual headquarters within the emergency 11 planning zone, the area approximately 10 miles around^the - 12 plant? q 13 A (Sullivan) Troop A is not within 10 miles of 1 iO- -4 14 Seabrook plant. -) ( 15 O How far away is it? l 16 A (Sullivan) It would be a guess on my part, but it's ] 17 not:within the 10-mile EPZ. 18 Q And where is the headquarters of Troop A, sir? i 19 A (Sullivan) Route 125, Epping. I 20 Q What would be the next closest headquarters for the I 21 state police, to Seabrook? ] l 22 A (Sullivan) To Seabrook? The nearest ones would be j i 23 Troop B, Bedford; Troop D, Bow; Troop E, Tamworth. Those are 1 24 the headquarters for those troops. i. l 25 Q It was Troop B in Bedford, and what was the next one { 1 i Heritage Reporting Corporation l (202) 628-4888 I l l l I I u--.

.t' -1 l: o-0 I p I SULLIVAN - CROSS .4680 I? ,:n t ' 1 you ment ioned? 8 A (Sullivan) Troop D in Bow, and Troop E in Tamworth, i -3 Q And would each of these troops have the approximate 4 same roster that Troop A doos? 5 A (Sullivat.) B and D are approximately the same. _E is 4 6 smaller. '7 O And,just in terms of geography if I am correct, Troop ] 8 E in Tamworth would be the most distant from the Town of 9 Seabrook;.is that right? ,j i { 10 A (Sullivan) That's correct, f -11 Q You have given us an outline, Captain Sheldon, of tne i 12 numbers that are on duty at Troop A at.any one time. Is this n 13 approximately the same system for the other troops? It's about j 3v! 14 one-third, one-third, one-third in a typical -- 15 A (Sullivan) Basically. l 16 0 -- time? 17 A (Sullivan) Basically. 18 Q And it also looks like in giving us these figures you f 19 were allowing for six or seven men that would be unavailable 20 because of illness or personal leave or vacation, things like 21 that; is that right? 22 A (Sullivan) That would certainly vary. But as I 23 stated, when I talked about one-third being off, t hat's -- I' m i 1 24 planning on annual leave, sick leave. When I say seven { 1 25 personnel on an average shift, those are troopers. And then j Heritage Reporting Corporation (202) 628-4888 l 1 I ll

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supervisor._ You could also have troop 1..

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youLhave a-shift e s n, -2 detectives, and troop comman' der. !; EndT1 3 (Continued on next page.) 4.. , 1 5 <a '7 8 .9 10 Li t. .] 12- .l 14 ~. f 15 16 a 17 18 19- <s 20 21 1

22 i

23 { l -24 1 l. 25 LO l l Heritage Reporting Corporation l l-(202) 628-4088 L

l 1 i l 4682 dDMAR 1 0 Captain, are you familiar with the table attached to a what we are referring to here, as Applicant's Exhibit Number 1, 3 the Summary of Personnel Resources? l 1 4 The table that sets forth the totals said to be ] 5 available from various agencies to carryout the emergency plan? 6 A (Sullivan) No, I am not familiar. j i 7 MR. BACKUS: Well, is there anybody who has a copy of { O the Revised Table 3.1-1 that could make it available to the 9 witness? 10 MR. DIGNAN: Mr. Backus, did you say the revised -- 11 do you mean the one that we distributed at the end of the 12 break? 13 MR. BACKUS: Yes, the one that you distributed. 7s t ~/ 14 MR. DIGNAN: Well, the problem with that is that it 15 is not in evidence, yet. 16 Do you want to stipulate it in with me, and we will 17 go from there? 18 MR. BACKUS: Well, maybe I should just grab the one ] 19 out of the one that is in evidence. I 20 JUDGE SMITH: Well, okay -- 1 i l 21 MR. DIGNAN: I would be willing to sti pulate with you 22 and get it in now, if that will make your life easier? 23 MR. BACKUS: I just have not checked it against the 24 figures of the one that is in evidence. 25 M R. DIGNAN: Well, there is one line changed. j l f) \\ l Heritage Reporting Corporation j (202) 628-4888 1 i o_

t-4683 . P*~ 1 MR. BACKUS: Just one? ] 2 JUDGE SMITHt Well, wouldn' t it be better if want to 3 cross-examine the Captain on one of them, it should be the 4 better of'the two, the most accurate of the two. 5 MR. BACKUS: Okay, I am sorry? 6-JUDGE SMITH: If you are going to cross-examine on j 1 7 one of the two tables, it should be the most accurate and up to 8

date, t

9 So, why don' t you take a moment, if you have to and 10 stipulate? '11 MR. DIGNAN: Mr. Backus, can we just have a second, 12 Your Honor? yq 13 I think that we can clear it up. k-) 1 -14 (Counsel confer.) 15 MR. BACKUS: I guess we are prepared to stipulate 16 this in but I just want to make it clear that the purpose of 17 the stipulation is to agree that this is the Applicant's 18 updated figures for Table 3.1-1. And in so far as these 19 figures have changed, we will want to reserve our right, of ) 1 20 course, to cross-examine the changes. 21 But my understanding is that the changes do not i l 22 affect the Department and the Gtate Police. 23 MR. DIGNAN: That stipulation is fine, with the 24 exception of the word, update, I would prefer to call it a i 25 correction. The initial numbers were just plain wrong, that ] I'.J l i l B. l Heritage Reporting Corporation (202) 628-4888 I I l 1 l

,. ; y . - ;. i.. 4; s K s i y '. ' y . \\ k" ?l. d y 4684 -a + J .f h fl. we cha'ged,',andfit'is'not an update,..it is'a correction. n y La ' JUDGE SMITH:..,Well, how are,you going to mark this? 'l

)

,3 M R.1 D I G N A N s.- Welle.I was going to ask your' advice, - 4.' Your: Honor. ] 5 I'would make ths.following-suggestion. I. don' t know j 6' if=it is possible to have it just substituted in the original ~7. document-and-that probably would'not be'a good-idea.. .l 8-I would beEinc1ined to mark it as Applicant's Exhibit-9 Number 1-A,- thus, vindicating that it was part-.of 1, and in- .10 addition toioffering.it an one Exhibit, with three copies for l 11' the record,talso to' request the Reporter to fold it and bind.it 12.. into-the transcript at this juncture. .m 13 And'I'think that way, you minimize-the possibility, b 14 asayou have. expressed concern about, that the thing gets lost l 15 in the: shuf fle. That would be my suggestion. -16 JUDGE SMITH: I don' t know if they have the 17 capability of folding here, in.the -- let's go off the record i 18 for just a second. 19 (Off the record.) 20-MR. DIGNAN: Your Honor, at this point, I would ask 21 that there be admitted'into evidence, subject to the l, 22 stipulation that I have made with Mr. Backus, a one-page { 23 document entitled Table 3.1-1, Summary of State Agencies and 24' Supporting Organizations / Personnel Resource Assessment, and i i 25 that it be admitted as Applicant's Exhibit Number 1-A, and also L. q l i Heritage Reporting Corporation (202) 628-4888 i { 4

SULLIVAN - CROSS 4685 IO 1 at this point, be bound into the transcript of the proceeding, 2 as if read. 3 JUDGE SMITH: All right, the Table is received as 1 4 described. 5 (The document referred to, was 6 marked and received into 7 evidence, as Applicant's 8 Exhibit Number 1-A.) 9 (The Applicant's Exhibit 10 Number 1-A, was bound into 11 the transcript.) 12 13 14 15 16 17 18 19 20 21 22 23 24 25 (O Heritage Reporting Corporation (202) 628-4888

s.. TAB

SUMMARY

OF STATE AGENCIES AND SUPPORTING ORG 8 AGENCY / LOCATION SlgE ST,AfE S E DA E EME G CE , ghE D RE EF GOVERNOR SjFFigF EMERGENCY 26 26 0 2 o o o

Jeni, o

NEW HAMPSHIRE DIVISION OF PUBLIC HEALTH e 24 o o 24 o o o o SERVlCES STATE POLICE 4 2 o o o o o o 2 civil AIR PATROL 2 o o o o o o o o DEPARTMENT OF TRANSPORTATION 2 2 o o o o 42-J!!s;3 o DEPARTMENT OF RESOURCES & ECONOMIC 2 2 o o o o 41 c o DEVELOPMENT DEPARTMENT OF FISH & GAME 2 2 o o o o 24 o oe PUPIL TRANSPORTATION SAFETY 2 o o o o o o o o', AMERICAN RED CROSS 2 0 o o 8-o o o DEPARTMENT OF AGRICULTURE 2 0 o o o o 12 o o DEPARTMENT OF HEALTH AND HUMAN SERVICES 2 0 o o 428 0 0 0 o EMERGENCY SERVICES UNIT NATIONAL GUARD 2 2 o o o o 50-d!! sis o' WATER SUPPLY & POLLUTION CONTROL 2 0 o o o o 6 o o U.S. C0AST GUARD o 2 o o o o 9 o o DEPARTMENT OF EDUCATION 2 o o o o o o o o EMERGENCY MEDICAL SERVICES 2 0 2 o o o o 72 o PUBLIC UTILITIES COMMISSION 2 2 o o o o o o o ROCKINGHAM COUNTY SHERRIFF'S DEPT, o o 23 o o o o o o AND SUPPORT ORGANIZATIONS VEHICLE PROVIDERS o o o o o o o sis-o y (j TOTALS 64 64 25 2 452 8 184 587 26 I

T1 3A1 APERTUllE CARD 2ATIONS/ PERSONNEL RESOURCE ASSESSMENT Also AvahJ31e on UIst RE0VYRE0 AvhhlE REMARKS 0 0 0 54 75 +21 SEE VEHICLE PROVIDERS FOR REQUIRED ORIVERS TOTALS INCLUDE 12 VOLUNTEERS 0 0 6 62 66 44 4 LOCATED AT THE DPHS LAB IN CONCORD 2 RADIATION HEALTH MANAGERS IN CONCORD 48 0 6 86 185 +99 TOTALS INCLUDE 6 COMM.,2 FROM ADMIN.,AND 74 FOR TCPS/ACPS 0 0 25 27 80 +53 25 WILL PROVIDE GROUND AND AIR TRANSPORTATION ADDITIONAL PERSONNEL WILL BE USED IN A SUPPORT ROLE ONLY

• FIELD PERSONNEL l0 SET UP TCP S/ACPS AND IMPE0iMENT HEMOVAt 0

0 0 46 90 +44 168 00T PERSONNEL ARE AVAILABLE TO ORIVE BUSES; NUMBER AVAILABLE SHOWN UNDER VEHICLE PA0V10ERS 0 0 0 45 182 +137

• NUMBER AVAILABLE REFLECTS TOTAL DRED EMPLOYMENT, WHICH FLUCTUATES SEASONALLY 0

0 0 28 48- +20

• TOTALS INCLUDE 20 FIELD BIOLOGlSTS AVAILABLE AS BACK-UP ASSISTANCE O

O O 2 2 0

• • ^

5 ' '"^tNE

SwttTER, 0

0 0 10 10 0 MGRS. EASTERN LPS. OF ARC VILL SUPPLEMENT REQ'D ERS 6 OTHER PERSONNEL TROM THROUCHOUT NATION 2 EhENSIOF 'SEREE REPS. FROM ROCKMAM COM C0WX 0 0 4 18 183 +165 2 EXTENSION SERVICE RE.PS. FROM UNH 561 STAFF INCLUDE THE STATE E0C POSifl0NS AND STAFF FROM HOST 0 _0 0 430 561 + 131 COMMUNITY PR) MARY AND $0PPORT UNIIS PLUS SUPPLEMENTARY STAFF AVAILA8LE FOR ASSICNMENT 2510 NAll0NAL GUARD MEMBERS.196 MEM8ERS ARE AVAILABLE TO ORIVE BUSES 0 0 0 54 2314 +2260 AS SHOWN UNDER VEHICLE PROVIDERS.

• NUMBER INCLUDES 3b DECON PERSONNFL.

TOTALS INCLUDE 3 SUMMER INSFECTORS 0 0 0 8 16 +8 THE OTHER 6 WILL BE USED AS BACK-UP SUPPORT c 0 0 0 11 'NA

• 0
• C0AST GUARD WILL NOT PROVIDE A ROSTER OF PERSONNEL THEY llAVE EN0 UGH PERSONNEL TO PERFORM REQUIRED FUNCTION y

0 0 0 2 2 0 ANY ADDITIONAL PERSONNEL WOULD BE CLERICAL =

• TDTAL INCLUDES 8 PERSONNEL AVAILABLE FROM 4 OTHER EMS REGIONS AND 0

0 0 76 134' +58 126 PERSONNEL UNDER LETTER OF AGREEMENT 0 0 0 4 6 +? o o 6 29 51 +22 TOTALS INCLUDE 17 SHERIFF'S DEPARTMENT PERSONNEL 10 OlSPATCHERS AT ROCKINGHAM CO. O!SPATCH CENTER AND 24 OTHER COUNTY SHERIFFS DEPARTMENT PERSONNEL

• 70fAL INCLUDES DRIVEa3 AVAILABLE FROM VEll!CLE PROVIDERS, TEAMSTERS, 0

0 0 515 1228 +713 D0r, NAT'l CUARD, & ODER VOLUNTEER OROS. UNDER AGREEMM 48 0 47 1507 5233 NA 87I/Ofe 00S3 - C I

,h E p'- 4 e, b .i' L i. L SULLIVAN'- CROSS 468E l L j-- 1 MR. DIGNAN: lAnd may.the record reflect that I.have '2 - given the Reporter four copies, Your Honor; three for.'the I f 3 Exhibit part of it, and one for the' binding'into the, .i 4 transcript. "5 ' Thank you. 1 i G .MR. BACKUS: 'Is there one that could be furnished to 7 the witness? If'there is an extra? ) 1 8 (Witness:in preffered document and examines'it.) l 9 BY:MR. BACKUS: -10 0 Captain,.you now have before you what has been marked L 11-as Applicant's Exhibit Number 1-A. I. l' 12 I believe that you had said that you werc.not 13 familiar with this document? L. O-L' 14-A (Sullivan) It is the first time'that.I have:seen it,- 15 sir. 16 O And you do see there,

a. column over there, on L t he

( 17' left-hand side, labeled' Agency / Location, correct? la A (Sullivan) .That is correct. l l-19 Q And the third agency listed under that column of l 20 titles is the State Police, correct? 21 A (Sullivan) Correct. 22 Q And then as you read across, you see that the State 23-Police are designated, or numbers are designated for certain 24 functions? l 23 A (Sullivan) That is also correct. O i 1 Heritage Reporting Corporation (202) 628-4888 L_

i l { SULLIVAN - CROSS 468Y 1 Q And you were not familiar with the assignment of { l 2 these numbers to these particular functions in connection with 1 3 the radiological ~emerDency response plan? 4 4 A (Sullivan) I believe what I said, Mr. Backus, I was 5 not familiar with this document. I< contributed to those 6 figures. 7 Q Okay. ) 8 So, the designation of four State Police, to State 1 9 EOC, or Emergency Operations Center, for example, you 10 contributed to that figure? f f 11 A (Sullivan) My opinion was asked in all of those 12 figures. 13 O And was that your opinion of the number of State j 'q

J 14 Police that should be at that particular function?

15 A (Sullivan) That is correct. f 16 O Now, moving along, there is another one for State 17 I FO, or Incident Field Office, I believe, of two troopers, is 18 that correct? 19 A (Sullivan) That is also correct. -l 20 Q And was that also based on your recommendation of the 21 numbers of troopers that should be involved in that location? 22 A (Sullivan) That is also correct. 23 O And then there is no further indication of State 24 Police personnel being used, until we get to access control, f 25 when we see 26. 7~U HeritaDe Reporting Corporation (202) 628-4888

SULLIVAN - CROSS 468E U. l 1 And were you involved in the. determination that there 2 should be 26 State Troopers used for access control?- 1 3 A (Sullivan) That is correct. ] 4 Q And then the next one is traffic control, where the 5 figure is 48, and again, you were involved in the development i 6 of that number? 7 A (Sullivan) That is also correct. 8 Q And the last one is under other, and there are six 9 listed there, and I am just wondering what functions those six 10 are to perform? 11 (Pause.) I 12 THE WITNESS (Sullivan): I recall being involved in. ,g 13 discussions and that particular number being discussed, but (/ 14 right'at the moment, there is a certain set of circumstances l 15 that would require those additional six, and right at the 16 moment, I don' t recall what the circumstances were, but I am in 17 agreement with the final total. 18 DY MR. BACKUS: 19 Q That being the total required, was 867 20 A (Sullivan) That in correct. 21 Q And did you, Captain, also have a role in deciding on j ( j 22 the number and location of access control points, and traffic 23 control points? 24 A (Sullivan) I did. f 25 Q And am I correct, that it was the determination of ("h %J Heritage Reporting Corporation (202) 628-4888 1 1. l N_.

l l %j c(: ~ 468?yl L SULLIVAN - CROSS (i ' l: 1 the number of access control points, and traffic control i L 2 points, that drives the number of troopers that are said to bei 3 necessary, or described as necessary in this document? 4 A (Sullivan) I am afraid that I don' t underhtand your 5 question. 6 Q Okay. 7 Let me withdraw it. i 8 If you look over in the remarks column, over-on the 9 right-hand side, there is a figure there of 74 for TCP's and 10 ACP' s, and my understanding is that that is an abbreviation for 11 traffic control points, and access control points,'is that-12 correct? Mj 3 A (Sullivan) That is correct. ~,-)- i^_z 'q, 14 Q And that would be the addition of 26 at access 15 control and 48 at traffic control, is that right? 16 A (Sullivan) That is correct. 17 Q Now, is it, therefore, the decision as to the number 18 of access control and traffic control points, that determine 19 the number of State Police personnel that are required? 20 A (Sullivan) For that particular function, yes. 21 O Okay. 22 Now, in making that determination that there were 23 going to be 26 access control points, and 48 traffic control 24 points, or personnel to serve those points, did you take into 25 account, the role that the State Police might play in providing l f r/~) i LL_ 1 Heritage Reporting Corporation >l (202) 628-4888 1 4 1 f

n = r; g, 4 4 \\ ')tl t t q: 4690 i / y, < SULLIVAN M CROSS ' r ' '., t. l f~') 2, f, L 1 compensatory personnel for lo'dhl police that were, for any l f f, ' ~ 2 -- reason, unable to respond within local communities? 3 M,Y (Sullivan'r*'I believe that figure was reached with ] 4 ;., 1 T 4' thought to compensatory role for six towns not playing. l ,b ./' S O And so these f'2gures,_just to be' clear, assume no !i '. (6 local police personnel, mannir.g access control points, and 7,. 7 local / control points, within the cix, what has been described ( , /, s a, j is that correct? as the six non-pr.pticipating towns, 8 9 MR. BISBEE2 Ob.j act ion. .j 10 This witness hhs said that he is not familiar-with j / 11 this document and he has been quizzed at some length, about,$ }ie, ,a !.,i 8 j was pertait ing' t<f,)nis docum9nt.) '. t ,,and I think-you said there have been some training for L 8 the officers? 9 THE WITNESS: (Sullivan) _May I ask the panel a f L ( 10 question? I don' t understand how training is involved in the l. 11 state' police providing resources. I agreed that I was j 1 L 12 qualified to testify as to number of people responding. I have L l P 13 not been involved in the training, and I really shouldn' t be i 14' testifying as to what training specific personnel have had. I 15 could make a general statement. 1 16 JUDGE SMITH: Well, Captain, I would regard your 17, interests being protected here by the New Hampshire Attorney 18 General. If you want a moment to discuss with them, we will l o 19 give it to you. If you feel there has been a breach in the 20 understanding, why I think that's something the Boarci would 21 entertain, but normally we do allow counsel to protect the 22 witness. inquire of Mr. Backus as to 23 MR. BISBEE: Coule 4 24 whether he is Doing to pursue this? I 25 The witness has already said what his involvement is. ?'R j Heritage Reporting Corporation l (202) 628-4888 L

a >" i,( 1. SULLIVAN - CROSS 4717 A2 1 MR. BACKUS: I just want to find out what the 2 witness' knowledge about any training that may have been,a 7[ 3 conducted is. And if he has that knowledge, I want to find out q 4 what the training is. 5 MR. DISBEE: Could I confer with the witness justffor 6 a minute, Youi Honor? 7 JUDGE SMITH: Sure. f 8 (Witness and counsel confer.) ( 9 MR. BISBEE: I don' t know what use there is ' t:o 10 proceed. The witness has already answered what his knowledge 11. is of training, but I have no objection to him trying to tl{, 12 establish. precisely what this witness' knowledge is of the. { 13 training of the state police personnel. 7-] M4 14 JUDGE SMITH: Well, I do think it would be helpful to 4 15 overybody if we knew -- so far we have guessed correctly at 16 least once where you are going, and your cross-examination plan 17 didn' t really take us there. 18 Now, what issue are you covering now? 19 MR. BACKUS: In reference to the cross-examination 20 plan? 21 JUDGE SMITH: No, with reference to your question 22 concerning training. ' 23 MR. BACKUS Oh, I' m just trying to find out if the 24 police have had particularized training in regard to the 25 radiological emergency plan. I' m sure the captain's personnel

i l-Heritage Reporting Corporation (202) 628-4888 i

i L=i__--- I

g]lf j )' .w y ~ lit i ; t it a [(...

• A...

s n l f 2n( r f j ";1 < o ,5 H if' ,4 SULLIVAN - CROSS' 471E 1 have extensive' training in general police duties.- I. am jusk', '/! il, t .o y _..,l hf $1 4,p.:g ' ' -2' wondering if there has been any specialized. training in ,s1 Q. - ' 3 h. ' connection with the plan. ' / t y,, s 4- ? JUCCEcEMITH: Yeah,.but why? q. 9' 'y MR. BACKUS: Because I think it may be an important Q u a

d. W part of geeing that the plan is in fact adequate..

I' m curious.

-1/

,r No know', for: e>(agple, 'whether the state police have been Nc 7 8 advised in thez use of dosimetry, that sort of thing.;;

d.,

l3 - cf .? [ G 9 JUDGE SMITH: Well, okay, but then this is perhaps d, 10. a " we did hot understand why you were calling the,, state w 11 police official. This is a part of your case in chief then. ?; .f'p - 12 This is not rebuttal. This,.ss.a part of your case in chief, &, l ;. 9 13 and across the board. 3 14 MR. BACKUS: Wel1,-I think it'goes to the whole issue y tW of~ resource availability, that the personnel not only be there \\ 'iG as a number, but hhvo the capability of response. '/j 17 JUDGE SMITH: There are no ob.jections. You may ji 1 i 1 38 answer, Ca pt~a i n. There is no objection.either based upon the. I / 19 understanding as to his appearance here..as I understand it. f 1 5 20 THE WITNESS: (Sullivan) Would counsel repeat the 3 21' question, please? l + 22 MR. BACKUS: Surely. 4 s .i, ; r o 23 BY MR. BACKUS: 24 O I was asking, Captain, if you are aware if the stattr j 25 police would - if the state police Mave had any specialized g ,y i 7& { Heritage Reporting Corporation ,,1 (202) 620-438e, s - {: J.. u-___.____----_=---

.,a j il \\ \\ -/ g* .g l ci x; i .) l} _{h A { 1 I 'f-Q EIULLIVAN - CROSS 4719 1 p# thhining in re garding to carryinD out a radiological emergency +s, s h,- j k-l' 'J 'r 'b, \\ ( l ( reqph1feplan. '4 ),'f { l p y (Sulliha + < ( 3 A They' ve had sorg i And d[ yp,u know anything $h,out ij that training has 4 Q (}f y g w (k, l J' 't 3 f 1, consiststd of?, \\ i \\, t ,(; 5 a \\ r

\\

( A (Syl h iva;M f it consideired dosimsyce training, { j s s </. 7 radiological training.,\\ An to the number of people and extent, N \\' ' 'j e,g..s >!p that*s. what I don' t know.< \\ F} }9 You, havb; ( '.;\\ ; 1 Q no idea of the number hhat have'had that .l } i 10 sort of training at this point? I v. tads point ' m going to 11 MR. BISBEE: 'Obj ect i on. At j g ( .) i f c f g 12 object to the continued lineqfinquiry. He coveqert ' t raining Qm; 13 earlier. He has done it agansi.kecchdtime, and N ihink we Y) .t, 14 have established where this witnes,% ttands with regard to 3 U 15 training. 16 JUDGE SMITH: Sur.t a i ned. \\ 17 (Pause.) e-3 18, MR. BACKUS: liiat's all. j 1 l l Who W shes/to i'.'6q u i re ? i 19' JUDGE SMITH: { 20 Mr. Dignaq. ) { l f 21 CROSS-EXAMINATION', ( i s 22 BY MR. D TGtlAN : 3 ] 1 i yoytjorrecI.ly,and E3 Q Captain,'if I' heard if I mi shirard I 24 you, please.so state and I gill apo19gize all around. You { 25 indicated that lthe figure of 86 tota: Tequired state troopers s i .m L. i p? \\ Yul fi l i Heritage Reportinq, Corporation l (202) 628-4688 'e \\ i / / 1 a l xn r

H i. l.; ; I SULLIVAN - CROSS 4720 ~(-R'l ~ 1-that' appears on this Table 3.1-1, which has been marked as f '2 Exhibit 1-A, included those' officers who would be'needed in-I i ,3 case certain"of the-town'did'not participate? y 4 -A (Sullivan) That is correct. 5-G Okay.~ I would like to try to refresh your 6 recollectioniin this matter, and what-I' m going to put before .l 7 you, Captain, 'is Table 3.1 from Applicants' Exhibit 1, and -i ~8-ask you to review that if you would. j 9 (Witness reviews document.) g 10-Now, Captain,;what I have put in front of you is 11-Table 3.1-4, andL it's titled Overview of Personnel Requirements 12. for= State Agencies Required to Assist Municipalities Unable to f-13 Respond to_an Emergency. And I direct your attention i LA specifically, sir, to the third line which starts out, "The 14 ~15 agency being NH State Police". 16 Do you have that in front of you, sir? l l 17 A-(Sullivan) That's correct. 18 Q And that shows 86 as total personnel required for 19 normal RERP duties; is that right? Y 20 A (Sullivan) That's correct. a 21 Q That's the same figure that appears in the table 22 which has been marked Exhibit 1-1, Applicant s' Exhibit 1-A; is [fy 23 that correct? ' li (% 24' A (Sullivan) That's correct. 3 t 25 Q Now next to that is a column which says, A. I k.b) I .. t. Heritage Reporting Corporation (202) 628-4888 t 1

SULLIVAN - CROSS 4721 . __10 I-1 "SupplementalLpersonnel required to assist specified 2 mun'icipalities," and-in there appears the' figure-11; is that. 3 correct? 4 A. (Sullivan). That's correct. 5 G' And tiien the total required is 97, correct? .6 A (Sullivan) That's correct. 7 Q Does that refresh your recollection that in fact if I 8 the six towns do not. participant, an additional 11 troopers to 9 the 86 will be necessary? J 10 (Pause.) 11 JUDGE SMITH: While he is studying that,-could.I have 12 that question'back, please?' T'~1jT4; 13 (Accordingly, the pending question was read

• 6-a i

1 14 back by the court reporter.) T5 15 JUDGE SMITH: I' m missing something. There is 16 something.that:I didn' t hear. You asked it and I didn' t -- I 17 does that refresh your recollection. 18 Would you. restate the question? 19 MR. DIGNAN:

Yes, I' d be glad to, Your Honor, to the j

20 best of my ability. 21 BY MR. DIGNAN: 1 22 Q Does that refresh your recollection that in the event l. 23 the so-called six nonparticipating towns don' t participate, an 24 additional 11 state troopers to the 86 will be necessary? ( 25 JUDGE SMITH: Got you. l Heritage Reporting Corporation (202) 628-4G88 I 1

I-E________.____

I SULLIVAN - CROSS 4722 ' (N. \\ 1-THE WITNESS: (Sullivan) I' agree that that's what is 1 i 2 indicated there.' I~am. familiar with this chart.. And i f,I' m l 3 gett'ing the. impression'that my testimony here today was 4' differently, I believe I testified without using the 11 figure 5 that the total is 96. 6 Did I mislead someone? 7 BY MR..DIGNAN: I 8 Q. I think you may well have,. Captain, but as I said I' !~ 9 think there'was a question you accepted and answered indicating I 10~ that the lH5 did'it all,.and I just wanted to;be sure where you 11 want to leave your testimony. 12 ~And my understanding is if the six towns don' t (% 13 participate, we' ll need 97 troopers. -d 14 'A (Sullivan) I thought it was 96, and they agr'ee to 15 97. 16 O All right. And'my question is, is the figure -- you 17 talked with Mr. Backus about a figure was supplied to you as'to 18 what the additional numbers would be. 19 Does this refresh your recollection that the figure 20 supplied was this figure of 11? 21 A (Sullivan) To be honest with you, I don' t recall 22 specifically. I recall this chart, or agreeing to it. I agree 23 to it now. Whether it was 11 or not, I only recall that if 24 they did not participate, I believed at the time I would need 25 96 peopic. l l D y Heritage Reporting Corporation i (202) 628-4888 E _____

i -l SULLIVAN & CROSS 4721 l

J+

.1 Q. All right. In any event,_ do you have any. doubt as to. 1 r a-2' the' ability of the.New Hampshire State Police to supply the 97 l 3 required'should that be the requirement?. j i 4-A (Sullivan)- I don' t think 97 is unreasonable out of a 5 total ofE247. 6 0 'Thank.you, sir. 1 s 7 You were asked a series of questions concerning when a certain troopers would become available,'. leading up to you 9 would have 100 within five hours. 10. My question to you, sir, is, is it your understanding is il that the notification to Troop A of the possible need'for 'n 12' troopers may well come at a time before an evacuation has 'rN 13 actually been ordered? [*%) '14 A (Sullivan) I believe if an -- there,would' definitely j 3 ' be an alerting of those units before an actua1' evacuation. 15 t 16 There were certain procedures to be followed whether -- 17 naturally,.in an unusual event, we take no action. If it's an 18 alert, and it would be at.that point, and I believe it would be 19 before any evacuation was ordered, that's when we would start i 20 to muster our people. 21 Q All right, that's what I wanted to be clear on. In 22 other words, those times you gave us, 15 minutes, 45 minutes, 23 two to three hours and then five hours, that is from the time 24 you fitst are told we will need -- we may need troopers at 25 these points. t l L Heritage Reporting Corporation (202) 628-4B88 l [ l.

l.~ p- + i,p, s .SULLIVAN CROSS 4724

• h

~ 1' A' (Sullivan) )That'many, if no't more, would be alerted, 2 and would be available. In other.words, we would make sure ln 3 that-we had that number of people notified or alerted.long' 4-before'anyone said to.us, you are definit $1y going to have to f 5 evacuate. Those people would be notified at the' alert level. 6' G .All right. And when would they be dispatched to.the l 7 traffic control points? 8 A-(Sullivan) As the events were to occur. That wou'id 9 be a decision for someone like myself, or if the governor were 10 to declare an emergency. I 11 Q Now assuming they are alerted,.is it-your testimony 12 thatlit would take five hours after the order to dispatch them, it'would be five hours from the time they were alerted 13 or that 14 that the 100 could be on' duty? ~l15 JUDGE SMITH:- Is your question would be or could be? 16 ' MR. DIGNAN: It should be "would be", I think, Your I 17 Honor, because I am asking about his testimony. If I said la "could", deem the question so changed. '19 THE WITNESS: (Sullivan) Could I have the question 20 again, please? f 21 BY MR. DIGNAN: '22 O Yeah, let me try to put it in context, because I want i 23 to be clear here. ] \\ 1 24 You do recall you testified that you had committed to I 25 the concept there could be 100 troopers on station within five l l 1 Heritage Reporting Corporation I (202) 628-4888 l l l 1

.s o] e 1 - b i if' f ~ 't p i f-SULLIVAN - CROSS 4720 - ! I f' >h - , ' l-i 1 hours. And'what I'm interested in getting at is'when-does the' L 2 five-houriperiod'begin.- -1 ] 3 Now you indicated' earlier that there might be an. 4 alert,to troopers well before any time there was an evacuation f i 5 .actually ordered. .l i '6 A (Sullivan) That's correct what you said. ] .8 '7 "O Right. 1 8 A (Sullivan) Now let us assume that set of facts. l L an alert goes.out before any. evacuation is l- .9-That 'is to say, l l . 10> ordered.- Assuming an evacuation is goinD to take place, there' L 11' will come a time when an actual order is given to dispatch j' E 12 troopers.to various points; is.that correct? ( ~. 13 A (Sullivan) That's correct. t o,s L 14 G -Did you.nean.to say that even assuming the alert had. l 15-taken place well before that time, it would still take five l ^ 16 hours to get those'100 troopers in place after the' order l l 17 actually dispatching them? 18 A (Sullivan) When I gave that.100 figure, and - it's 19 based on five hours from the time.they are told move into the 20 area, not from the a'iert. We would alert them. We would 21 determine how many we have available. That was a very 22 conservative number, and I had to feel comfortable with that 23 100 from the time they are told to move into the Troop A area, 24 I could provide 100 within five hours. 25 O And you are very comfortable with that figure. ?R LI Heritage Reporting Corporation (202) 628-48E8 L L l l L____ __ _ -. -.

fi.; r l) SULLIVAN -' CROSS 472E j. J! ohik. i A '(Sullivan) I stayed very conservative with what I 2 be l i eved. - t f 3 MR.'DIGNAN: Thank you, that's all I have.

4 JUDGE SMITH:

Mr. Flynn? 5 MR. FLYNN: No questions, Your Honor. f 6- ' JUDGE SMITH: P. r.- Turk? '7 MR. TURK No questions, i 8 JUDGE SMITH: Well, Mr. Brock, do you have questions?- 9 ~ MR. BROCK: I had a couple, Your Honor. i 10 JUDGE SMITH: All right, would you take them now, 11 please? 'f 12 MR. BROCK: Yes. 13 CROSS-EXAMINATION pv 14 BY MR.. BROCK: 15 O Captain, to your knowledge, as Troop A ever requested f 16 the-Town of Hampton to-provi.de police officers to respond to a 17 problem such as a traffic accident? f 18 A (Sullivan) Yes. i 19 O And would you -- how often would you estimate that 1 20 those kinds of requests have been made? l 21 A (Sullivan) You' re talking yearly, monthly. This 22 goes on every day, if you' re talking traf fic accidents. If i 23 you' re talking requests for them to come and assist us at 24 Seabrook, that's also occurred. You would have to be a little 25 more. specific. l O I Heritage Reporting Corporation l (202) 628-4888 j l

{ SULLIVAN - CROSS 4727 f 1 Q Well, how often would Troop A request Hampton po, lice 2 personnel to respond.to some problem, traffic accident or 3 whatever? 4 A (Sul l i' van) It could happen every day for a week, and q 5 then not happen for months. It would depend on circumstances. .6 'O All right, it's not an uncommon occurrence, is that { 7 fair to say? 8 A (Sullivan) They help us. We help them. 9 Q Is.it also fair to say that the reason that Troop A requests police personnel from the Town of Hampton is that L 10..' k 11 Troop A itself does'not have sufficient personnel In the- ' 12 particular circumstance? >q 13' A (Sullivan) That is not correct. k4 14 Q Explain to me why then Troop A asks assistance from j i 15 Hampton if it han adequate personnel. ] 16 A (Sullivan) Because if we had a traffic accicirnt on 17 Route 1 in'Hampton, and we had one trooper for the seacoast 'j 18 patrol, it certainly seems to be more reasonable to ask a 19 Hampton cruiser to come over, and for me to draw from the seven 20 units that are on duty in two counties, doesn' t it? l 21 Q Those requests for assistance from the Hampton police' l 22 department also occur for accidents say on Interstate 95, do j 23 they not? l } 24 A (Sullivan) It would have to be a major accident, b 25 yes. Heritage Reporting Corporation (202) 6E8-4888 I _ _ _ _ _ _ _J

d I I 4 SULLIVAN - REDIRECT 472E mb k_)- 1 -Q But;suchurequests are made; isn' t that? correct? 2 A-(Sullivan). That's correct. I 3 Q And that is because Troop A might not have sufficient 4 personnel in that area to respond - to the accident on Interstate 15 95. 6 A. (Sullivan) That's not correct, and I believe I -7 answered the question it's not that we wouldn t have sufficient. 8-personnel. It's just ' ut ilizing the resources which are 9 available. 10 Why would I bring someone down from Northern 11 Strafford, which is.available, which is a resource of Troop A, 12 when I.can have a local offxcer come out on assist? It's just -jg ~ .13 being practical. It does not mean that Troop A does not have V 14 the resources to handle that accident. 15 O But because they are deployed at such a distance, 16 it's easier-to have the local police respond; is that correct?' 17 A (Sullivan) That's correct. 18 MR.. BROCK: Nothing further, Your Honor. 19 JUDGE SMITH: Mr. Bisbee? 20 MR. BISBEE: Yes, would you like me to go now? I do 21 have a couple of questions. 22 REDIRECT EXAMINAT1dN 23 BY MR. DISBEE: i 24 Q Captain Sullivan, I would like to delve back into the 25 topic of numbers of personnel that we spent some time on f l Heritage Reporting Corporation (202) 628-4888 1

SULLIVAN - REDIRECT. 4729 , _) V-1 earlier. But.Just to be absolutely clear that the record 2 reflects accurately your testimony, when the document which you '3 have before you, Ap pl icant s' Exhibit 1-A, was done up', is it 4 your' testimony that you had available to you within thn entire 5 force'of state troopers and.other sworn personnel a total of {it 6 approximately 226 personnel? 7 A (Sullivan) That is correct. ) 8 'O And that number has been increased by approximately. 9 21 since then, so the total complement now that you have f 10 available to you is 247? 1 11 A (Sullivan) That is correct. la O And the number that's included in the column entitled 13 " Total Available" in Exhibit 1-A is'in the document at 185; is 14 that correct? 4 15 A (Sullivan) That's correct. -i 16 0. Now you are saying that that number would also be 17 increased to accurately represent what would be available now? 18 A (Sullivan) Can we go back and would you repeat the / 19 last question relative to the 185? / 1 20 0 Yes. All I asked was whether the number of total r l l 21 available in that document in 185. Excuse me, a total -- yes, 22 total available. 23 A (Sullivan) That 185 were uniformed troopers which 24 were available. The number of personnel which were available ) l 25 when I gave them the 185 was 226. l l j. Heritage Reporting Corporation l (202) 628-4888 I i != iL_ - - __-

gn-r- 1 L l b' 1 L i L I SULLIVAN - REDIRECT 473C i ' /"'N 1 L U 1 -Q

Okay.

But the number 185 reflects the available i 2 uniformed personnel as of August of;this year? l 3 A (Sullivan) That's correct. j 4 Q. Would that number be different today? 5 A (Sullivan) It would be greater. 6; Q And did you say that that would be around.205; 206 if 7 you Increase it by 21? 8 A (Sullivan) Basically, yes. 9 Q Okay, now, Captain Sullivan, the request for the 10. subpoena of Colonel Iverson for whom you are here today i 11 indicated another area of inquiry about the New England State l l 12 Police Compact. 13. 'And I would like to ask you briefly whether there are f-) i v l 14 additional personnel available to the New Hampshire State \\ l 15 Police from or through that compact? l l 16 A (Sullivan) Under the New England State Police l l 17 Compact, there is a considerable -- considerably larger number .10 of troopers available. 19 Q Could you describe generally what that number is, and 20 how they would be called up? 21 A (Sullivan) If we were to have an emergency, and 22 there was a compact in existence with the New England states 23 where the director of state police does not feel he has 24 sufficient manpower, he can ask the governor from the State of 25 New Hampshire to contact the governors from the other state, l.l Heritage Reporting Corporation (202) 628-4888 l I I l l

I H SULLIVAN'- REDIRECT .4731 l 'gn mj 1,, New Er gland. states, and ask that they send state police 2 personnel.. 3 At the1present. time'the maximum resource of troopers 4 4. in.the New England states number 3300. (? ' One final. question,. Captain. 0-2 6 'You indicated, I think, in your testimony that if. f -1 i -7 Seabrock were to be-operational and there were an accident-i 8_ fthereithat involved alerting the: state police,'that the .9 supervisory personnel in the state police'would have the' plan = l 1 10' available to them to guide them as to where they should place .I 11 personnel. 12 I take:it you are not referring to the 36 volumes. 'f 1 behind the judges here. 13-iv 14 A (Sullivan) No, I' m not. I' m talking to the -15 requirements or needs for the police for the disbursement of 16 personnel for traffic control and access control points which 17 would be available to Troop A communications, headquarters .f 18 communications.. Our plans are that every supervisor in the 19 Troop A area will have that' document in their cruiser. They i 20 will be subject to bimonthly inspections. And if the problem 21 were to occur, it's not necessary that these supervisors have 22 committed these traffic control and access contrcl points to l 23 memory. They would refer to the plan, as I would have to do. 1 l 24 Q Okay, and the plan you are referring to would be the l l l 25 traffic management manual? L i l I l Heritage Reporting Corporation i I (202) 628-4888 l _____.__________m.

\\a i, + s c.79 ,tp- .SULLIVAN - RECROSS 4730 b' 1 A (Sullivan) ThatLis' correct. i 2 MR. BISBEE: Thank you, Captain. I have no further 3J questions. 4 ' JUDGE SMITH: Anything further for Captain Sullivan. l-5 ' RECROSS EXAMINATION-l l 6 BY MR. BACKUSs' l l 7. O Just one other thing, Captain. You saldo-- you were: L-i 8 describing the interstate police compact and responses. l l 9' When you gave us-an estimate that you could have.100 L F 10 troopers on station within five. hours, you were assuming'those-h 11 were from the New' Hampshire State Police, I take_it.. 6 {. [ 12 A (Sullivan) They would all be from New Hampshire-13 State Police. 1' l MR.- BACKUS:- That's all. 14 15 JUDGE SMITH: All'right, thank you, Captain. '16 THE WITNESS: (Sullivan).Thank you. 17 (The witness was thereupon excused.) 18 JUDGE SMITH: All right, let's take a 15-minute c 19 break, and would you have the next panel ready to go,-please? 20! (Whereupon, a recess was taken.) EndT5 21 (Continued on next page.) 22 1 23 24 l 25 (2) i Heritage . Report ing Corporation ) (202) 628-4888 i L I I \\ L__~L2-_-________________-._ i

,7-i !- 1 t, 4733 Ta6-bmar 1 Whereupon,- -1 2 WILLIAM COLBURN j S JAMES MACDONALD l 1 4 were called as witnesses,'and after having been'first duly ) 5 sworn, were examined and testified as follows: -6 Whereupon, I '7 PAUL FRECHETTE-8 ANTHONY CALLENDRELLO. 9 RICHARD STROME 10 WILLIAM WALLACE 11 JOHN BONDS 12 were recalled as witnesses, and having been previously duly k ?"< 13 eworn, were examined and testified as follows: i b-14 JUDGE SMITH: I think that we can go ahead with the 15 preliminaries, but Massachusetts AG has not returned yet. 16 We are waitinD for somebody to represent the 17 Massachusetts Attorney General has not come in. Go ahead with j ) 18 whatever preliminary matter you might have. l 19 MR. LEWALD: Your Honor, I can proceed with the l 1 1 20 qualifications of the two new witnesses of the panel. l 1 21 JUDGE SMITH: All right. ) 22 DIRF.CT EXAMINATION l l 1 23 BY MR. LEWALD-l 1 24 Q Mr. MacDonald, I have placed before you a one-page j l l 2S docutaent and 1 ask you whether or not this contains your resume L j l Heritage Reporting Corporation j (202) 628-4888 l l l l I E_ __. _ l

r- ' n I ;' s ~i; ] l l PANEL NO. 4 - DIRECT' 4734 i

(')v-.

1 h -1' of.yourttraining,-6ducation and experience? I 2 A. (MacDonald) No, I am sorry, Mr.1Lewald, itidoes not. 1 3 This one here just has' William'Colburn. Did.somebody el'se.get-4 mine? ~ 1 5 JUDGE SMITH:

Well, did'-- well,. go ahead.

) 6 (Witness-is' proffered document.and examines it.) 7' BY MR. LEWALD: 8 Q Do-you now have before you, a one-page document which 9 does what I' indicated that the other document did, Mr. 10 MacDonald? I l 11 A (MacDonald). Yes, it does, Mr.;Lewald, that is. L 12 correct. i L information on there, true'to,the best of~your 13 G Is the 14 knowledge and belief? 15 A (MacDonald) Yes, it is. 16 MR. LEWALD: And I would like to offer the document 17. as the qualification resume of James MacDonald.- 18 JUDGE SMITH: Now, we will have to wait a moment. 19 Mr. Oleskey, did you see any of your colleagues out 20 there, in the hallway? 21 MR. OLESKEY: I think that the FEMA representatives 22 were downstairs as well, Judge. Obviously we all misjudged the 23 time and I apologize myself. 24 JUDGE SMITH: That is all right, there is no problem 25 there, but 1 just don' t want to proceed with any exception to O Heritage Reporting Corporation (202) 628-4888 L

4 PANEL NO. 4 - DIRECT 4735 pz !( j - 1 it. 2 Mr. Brock is not here, either. I 3 MR. GLESKEY: 3 don' t know where Mr. Brock is. I was 4 downstairs using the phone in the vicinity of Mr. Flynn and Mr. 5 Thomas. 6 MR.. TURK: Your Honor, if you will take a moment, I 7 will head.out real quickly and get everyone back here. 8 JUDGE SMITH: They should be coming here in a moment. 9 (Pause.) 10 JUDGE SMITH: This relates solely to SAPL l 11 contentions, however, so that l et ' s -- no, let's wait, wait 12 until Mr. Flynn gets here. /"N 13 Mr. Flynn, we are ready to proceed. 8d 14 I think that the Board threw everybody off when we j! 15 ret urfied on time. 16 (Laughter.) 17 MR. FLYNN: I am sorry. I 18 JUDGE SMITH: All right, proceed. 19 BY MR. LEWALD: ] 20 0 I am not sure where we left off, Mr. MacDonald, but I 1 21 hand you a document of one page, and the top of which appears 1 22 the name, James A. MacDonald, and I asked you whether or not 23 this document contains a resume of your training, education, 24 and experience? 25 A (MacDonald) Yes, sir, it does. f r ~7 ! L) l Heritage Reporting Corporation (202) 628-4888 t

[ i _ j :.f.-,' g } -- f x --

-i, PANEL NO.'4 - DIRECT 4736 y [' \\.

Q 1 'O . And 'is the information' in the document true to the i-4 .- 2 best of your knowledge.and belief?. i -3 A' (MacDonald) Yes, it is. 4 MR.'LEWALD ' I would like to offer this..one page-5 document as the resume of James A.'MacDonald's-qualifications-6~ and ask that it be bound into the transcript as'if read? 7 -JUDGE SMITHS Are there any objections? s 8-(No' response.)- l '9 JUDGE SMITH:~ The resume'is received. 10 (The document representing .j 11' the resume of Mr. ; James 12 A. MacDonald was' bound into -(h - ~ 13 the transcript.) / 14 .(Witness is proffered document and examines it.) 4 1 15' ~) 16 <t 7 18' i 19 i 20 21 22 23 24 l l 25 llO l [ Heritage Reporting Corporation 1 l (202) 628-4888 l lj'

l ,q , ( D'j ) SB 1 & 2 A=endment 58 FSAR April 1986 { 1 JAMES A. MacDONALD I RADIOLOGICAL ASSESSMENT MANAGER Mr. MacDonald received his Associate in Nuclear Engineering from Wentworth Institute in 1965, his Bachelor of Science in Nuclear Engineering from Lowell Technological Institute in 1968, and his Master of Science in Radiological Health from Harvard University in 1970. In the summer of 1969 he completed the Health Physics Training Program sponsored by Brookhaven National ) Laboratory and the USAEC. While completing the last three years of his undergraduate studies, Mr. I MacDonald worked for Sanders Nuclear Corporation in Nashua, New Hamsphire. as f an Engineering Assistant. His time was devoted to performing analytical j design of various systems employing radioisotopes as heat sources. This work 1 included the feasibility evaluation of the application of radioisotopes for { these systems, and devices by analytically designing and optimizing fuel capsules, energy conversion systems, and shielding. ] In addition, Mr. MacDonald worked on establishing and implementing a facility radiation safety program. This included work on the design and 1 licensing of a remote-handling hot cell and a radiochemistry laboratory. j l I \\ () Mr. MacDonald joined Yankee-Westboro in May of 1970 as an engir.eer within ) the Radiation Protection Section. In this capacity, Mr. MacDonald assisted ) in obtaining plant operating licenses in the areas of radioactivity source j term analysis and dose evaluations, environmental radiological monitoring l emergency planning, and in-plant radiation protection programs. j I In September of 1972, Mr. MacDonald transferred to the Saf ety Analysis Section where he worked in the source term and dose evaluation areas. These i evaluations were performed for radioactivity releases associated with normal plant operation and for releases associated with accident conditions. l In October of 1973, Mr. MacDonald was appointed to the position of Manager of-the Radiation Protection Group. In this capacity, Mr. MacDonald directed the activities of the group which include both licensing assistance in the radiation protection area for plants under design and construction and oper-1 ational health physics assistance for operating plants. Mr. MacDonald joined Public Service Company of New Hampshire in August of 1983 as Radiological Assessment Manager with the responsibility for implementation of the Seabrook Station Radiological Emergency Plan. 1 Mr. MacDonald is a national and New England chapter membar of the Health Physics Society and is certified in the field of health physics by the American Board of Health Physics. 9 5 13A-7 !^

Q ', i w p el b ' QL )" i y sls o cl 1 PANEL NO. 4 -' DIRECT-4737

o ' ^y, ff

,~ ?!L / De '1. BY MR. LEWALD-a '2 Q" Mr. Colburn, I have placed,before you,:'a document in. 'i 3 two pages, entitledi Resume of' Work. Experience.and Educational: 11 4 Background, and below which' appears.the name William M.

5 Colburn,u2OO Boyce. Road,-Canterbury, New Hampshire, 03224.'

'6 And'I'ask you, Nhether or not this" document contains: 7 a resume of your education, training and experience,' sir?- 8 'A -(Colburn) Yes, it does. l 9 Q And is-the information' contained in'the document, 104 true:to the best of your knowledge, and belief? 11 A. (Colburn) Yes, it.is. 4 12 ,MR.:LEWALD: Your Honor, I would like to offer the 7 '/"Y 13 two-page document that.has been identified by Mr. Colburn, as $m2 'I 14 the resume.of his work experience, training and education, into q .I 'a: 15 evidence, and ask.that 'it be bound into the transcript, as if '1 i 16 read? { 17 JUDGE. SMITH: All right, are there any objections?' a i 18 (No response.) q l 19 JUDGE SMITH: It is received. ] 1 20 (The document previously i i 1 21 referred to as William M. j a 22 Colburn's resume was bound 1 l 23 into the transcript.) 1 24 25 ~ Heritage Reporting Corporation (202) 628-4888 i i 1 l

r l n A'df:3 - i g.s l .s ! I .Rtsume'of Work Experience and Educational' Background d' \\ l WilliamN.,Colburn' 200Boyce Road [ ' Canterbury, NH 03224 i ..s. Work Experience .6/22/84-present' Coordinator of' Emergency Services i -New Hampshire Division of Human Services'(DHS)- Department of Health and Human Services (OHHS) ~ l Develop / maintain plans for several emergency. services . functions assigned to the OHHS; train volunteer staff'to carry (out specific tasks'related to these services: manage j staff during exercises and implementation of these programs. I i 5/12/76-6/22/84'- Staff Development / Training Specialist } New Hampshire Division of Human Services /0HHS Responsible for development and implementation of training ~ '\\ programs for agency staff. I -l l .3/6/70-5/12/75 Assistant Director of Assistance Payments New Hampshire Division of Welfare (now Human Services)- ) '.i. I Responsible for. administering the program for eligibility j determinations for financial and medical' assistance under the State public assis'tance programs. ) 1 NOTE: Other work experience includes: Supervisor of Wcrk Experience / Training Program Vocational Rehabilitation Counselor Disability Determination Adjudicator I l,. Occupational Therapist p: l 9 C/BK1617 o

g-I 2 i 4 i ^ y e .,.I' E Y O.; W, WilliamIN. Colburn Page'2 .. ' 's /L 1 l- ' Educational Backaround 1 .g, . Northeastern-University. LGraduated 6/58-Boston,' Massachusetts . School of Liberal' Arts (Sociology major; Psychology. minor) i i Northeastern UniversityL Graduate School of Education ' Boston,, Massachusetts- .12 Sem. Hours - - 1058.1959 L i 180ston University-Graduate School of Education Boston, Massachusetts 9 Sem. Hours - 1960-1963 1 . University.of New Hampshire " Individual Testing" 4 Sem. Hours - 1962-1963 Durham, New Hampfhire Northeastern University Graduate School of Education

Boston, Massachusetts

" Group Development" ,3 Sem. Hours .1964-1965 .1 ( Specia'l Seminars: " Individual / Family Grant Workshops" - 1984 and 1987 National Emergency Training Center 1Emmitsbury, Maryland I NOTE: Numerous 'other work-related seminars and courses not listed here. 1 Q C/BK1617.1 i l i

n m 1 n .i i l' PANEL NO. 4 .9IRECT 473E . ' /'T f l '%.) and examines it.) l 1 (Panel-is proffered-docuhlent O { 2 BY MR. LEWALD:- l s l 3 0 -I would like to address this question to the panel. l 4 Gentlemen, I have placed before you, a copy of a document 5 entitled Applicant's Direct Testimony. Number 4, with the 6 subtitle Decontamination and Reception Centers. 7 The document is some 25 pages, together with 10 pages' l I 8 of attachments and I ask each of you if you recognize the l 9 document, and if I could start with Mr. Bonds, and proceed down i 10. the list of the panel, as named in the direct testimony? l l '11 A (Bonds) It does. t .I 12 Q Mr. Callendrello? 13 A (Callendrello) It does. I 14 O Colburn? -i 15 A (Colburn) Yes, it does. 16 Q Mr. Frechette? i 17 A (Frechette) Yes, sir, it does. la Q Mr. MacDonald? 19 A (MacDonald) Yes, it does. 20 0 Mr. Strome? 21 A (Strome) Yes, sir, it does. 22 O And Dr. Wallace? 23 A (Wallace) Yes, it does. 24 Q And I ask each of you if the matters contained in the 25 testimony are true to the best of your knowledge and belief, i es Heritage Reporting Corporation (202) 628-4888 l

3 'I i 77,%. PANEL'NO; 4 - DIRECT 4739 '1 and that you adopt the testimony as.your testimony-in these 2 proceedings? 4 3-Mr. Bonds? 4 A (Bonds) It is and I do. 5 O Mr.'Ca11endre11o? 6 A (Ca11endre11o) Yes, sir, I do. 7 O Mr. Colburo? 8 A (Colburn) Yes, sir, I do. 9 O Mr. Frechette? j L 10 A (Frechette) Yes, sir, I do. l l 11 O Mr. MacDonald? l l it. is, and I do. i 12 A (MacDonald) Yes, sir, 1 13-Q Mr. Strome? I ]/'. j e 14 A (Strome) .Yes, sir, I do. i l 15 Q And Dr. Wallace? 16 A (Wallace) Yes, sir, I do. 17 MR. LEWALD: Your Honor, at this point in time, I i 18 Would like to introduce into evidence, Applicant's Direct 19 Testimony Number 4, as described and ask that the testimony be 20 incorporated into the transcript as if read. 21 JUDGE SMITH: What is the date on the top of the 22 testimony? 23 MR. LEWALD: The date on top of the testimony is 24 October 21, 1987. This is the last corrected version, Your 25 Honor. Heritage Reporting Corporation (202) 628-4888 1 1

1 i PANEL NO. 4 - DIRECT 4740 ("h ^> l' JUDGE SMITH: Yes, I am aware. i \\ 2 If there are no objections, the testimony is 3 received. l 4 (No responses.) 5 .(The document previously-6 referred to as Applicant's 7 Direct Testimony Number 4 I O and was bound into the 9 transcript.) l l 10-I I L 11 l l l .i e. l l 13 q-

f. b i

'14 15 16 17 18 19 20 21 22 j .23-24 25 Heritage Reporting Corporation (202) 628-4888 1 I L-___________________.

n. , /. 4

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1 Dated:- October 21, 1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD ) I In the Matter of ) j ) PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL OF'NEW HAMPSHIRE,.ET AL. ) 50-444-OL ) (Seabrook Station, Units 1 ) (Offsite Emergency and'2) ) Planning Issues) ) Y) APPLICANTS' DIRECT TESTIMONY NO. 4 (Decontamination and Reception Centers) ' Panel Members: John D. Bonds, Assistant Director for Planning, Division of Public' Health Services, New Hampshire Department of Health and Human Services Anthony M. Callendrello, Manager, Emergency Planning, New Hampshire Yankee William N. Colburn, Coordinator of Emergency Services, Division of 1 Human Services, New Hampshire Department of Health and Human Services I Paul R. Frechette, Jr., Senior Emergency Planner, New Hampshire Yankee James A. MacDonald, Radiological Assessment Manager, New Hampshire Yankee j Richard H. Strome, Director, New ) hampshire Office of Emergency [ - (. Management ") William T. Wallace, Jr., M.D., M.P.H., %/ Director, Division of Public Health Services, New Hampshire Department of Health and. Human Services i L m_ [

f 9 i ,4 5 This testimony. addresses ~ Seacoast Anti-Pollution League .? . Contenti'ons 7 and 33. These challenge the adequacy of personnel' - and equipment available to the.four' designated' host communities 7 to meet'the registration, monitoring.and' decontamination requirements associated with assistance provided to emergency workers and' general public evacueesLarriving at' reception centers and'to provide for adequate disposal of waste water. PLANNING BASIS Personnel,cequipment, and facilities necessary to ( l prov'ide. registration, monitoring,-and decontamination j functions at. reception l centers and monitoring and a decontamination'fac.ilities have been analyzed. Critical to' l ): - the. scope of:these needs is the number of emergency workers and evacuees that can be expected to present themselves at:

[

i .the several reception centers. The bases for the. j f determination of the." load" to be placed on host community centers are described below. The results of'these analyses j will be reflected in NHRERP Volume 4A, Appendix F and Volume 4B, Division of Human Services precedures. ,1 Since the direction of the plume is not known, the planning basis provides for the simultaneous and independent 1 operation of the host community reception centers. j Therefore, for.the purpose of estimating the staffing and I equipment requirements for registration, monitoring, and

D l k

Ci_ _.._m._

yy 3 nj ,I ( l7 decontamination opedations,;it has been assumed that all j .I .stcjannts of the EPZ sould be affected by a contaminating, j ~ part:iculate release. This:is a very broad, theoretical and l cerisarvative assumption. First, not all severe accidents 'l wouldsinvolve the release of particulate materials. NUREG-0654/ FEMA-REP-1 at p. 15 states: 1 [T]he potential for'releasco to the environment decreases dramatically in'this crder: (a) gaseous materials; (b) volatile solids, and (c) non-volatile solids. For this reason, guidance for source terms representing hypothetical fission 4 product' activity within a nuclear power plant { y containment structure emphasizes the development of i plans relating to the release of noble gases and/or ' volatiles such as iodine. Consideration of particulate materials, however, should not be completely neglected. For example, capability to determine the presence or absence of key particulate radionuclides will be needed to i M identifyrequirementsforadditionalresoyrces. -( /] yh-Second,-plume dispersion would limit the iffacred I segment of the population to areas in a downwind direction from the plant. The less concentrated the plume dispersion, the less the concentration of potential contaminants. The accident assessment model utilized by State of New Hampshire emergency response personnel, described in NHRERP, Volume 1, l Section 2.5.2, allows them to determine the concentration and 1 dispersion of an actual plume and, consequently, that segment of the EPZ population which potentially could be affected by a contaminating release. f i T. Anticipated Number of Evacuees \\ The FEMA Memorandum from Richard W. Krimm to FEMA 9 l V Regional Offices and Natural and Technological Hazards (NTH) -3 i i b'

y .c 3 ,y 1 _4 .e4 h 0 ._3 ' g c, ij f /'t il s -j Division Chiefs, dEted December 24y 19,85, Snt$1tled " Guidance i 1 ^ \\' ^ \\ l on NUREG-06U4/ FEMA-R2P-1 Evaluation Criteria J-12," ' ' ' hereto, provides guidance as to'the anticipated 4 I i i ' numbers of evacuees that may bs(estimated to perive at host 4 1 communities for radiological monitoring.,Thi,s guidancs .i / i

p suggests the use of 201/of the total-. evacuees as a planning

[ basis for estimating;tto nunber of persons' arriving at a s 3 reception centers. 1, f i I Based on FEMA guidance, the ntstbar of' arrivals for each 1 ( N' NHRERP host community was entimata,d W, first obtaining the ,I ) i.; sumofthesummerweehendpratg[caf(ddionforeachEPZ community to be routed to a qqrt4cular host reception area. '~ / With the exception-of Rye, Hampt'oh, Hampton Beach, North s Haqpton, and Seabrook, the sbhtner weekend peak population f s estimates are based on Table 1,'" Population of p Municipalities," which 1$ containda in Volumes 16 through 32 of tholNHRERP'. (The peak population estimates for Rye, 4 Hamp' ton, Hampton Beach, North Hampton, and Seabrook are based I on infortaation contained in Volume 6 and an;cnalysis of ? it ^f ,s aerial photographs taken on Saturday, Jefy'r18 1987 between M .e 7 I that h,ours of 12:00 noon and 1:20 p.m., as described in the s I 'i i testinony of the$ETE and Humad BehavlIr Panel). Next, the i resident and patient population o'f g special fhcilities and the number of those evacuees who areitransit-dependent for each EPZ community were subtractodbf3;oha the 9eak population i totals. The remainder populatiEhIwas then md1tiplied by 20% l 4' i i y< s i

in accordance with the FEMA memorandum. As a final step, n i 100% of the transit-dependent was added to the total since all transit-dependent individuals will be transported to reception centers. The mathematical model for determining each host community load is: ( Sum of Peak Special Facility Transit Dependent ) Numbers for )=P (20%) X ( Pop 11ations For Populations of (Assigned Communities Assigred Communities Assigned Communities) 100% Transit Dependent Assigned Evacuee Icad Per Host Community P + To 'Ihat Host Community = Performing the calculations, as described, equates to 9,667 evacuees arriving at the reception and decontamination Q,, centers at Manchester, 6,829 evacuees at Rochester, 9,621 at Dover, and 6,416 at Salem. The planned staffing level to fulfill the registration, monitoring, and decontamination function at each of the four host communities is based on the community (Manchester) which is anticipated to receive the largest number of evacuees (9,667). 2. Anticipated Numbers of Emergency Workers The current information from the New Hampshire personnel resource assessment program indicates there will be approximately 1,300 state and local emergency workers who may potentially require monitoring and decontamination services at host community facilities. [& Revision 2 of the NHRERP allows for emergency workers, 3 -s-l l -_A----_

j-) during the first twelve hours, to be sent to any of the four (/ host communities. 'Upon closure of the centers for the ) general public, monitoring and decontamination assistance j will be provided for emergency. workers at the secondary monitoring and decontamination center at the Hillside Junior High School in Manchester. In order to eliminate the need to assign emergency l workers to one of four facilities at the time of the emergency and to facilitate the tracking of emergency workers and their exposure records, the NHRERP will be amended to j establish the Manchester secondary monitoring and decontamination conter at the Hillside Junior High School as j the~ emergency worker monitoring and decontamination center l ( ), for all stages of an emergency. Therefore, the secondary cente-in Manchester will have the capability to provide monitoring and decontamination services to approximately 1,300 emergency workers. c 3. Anticipated Emergency Worker Equipment and Vehicle Decontamination Requirements In general, the philosophy 6f the"New Hampshire RERP is i to plan for sufficient. resources to implement the emergency response efforts without reentry of emergency workers or re-use of their equipment once outside of the Plume Exposure Pathway EPZ. This approach obviates the need to plan for extensive capability for decontamination of emergency worker equipment, vehicles, and supplies during the initial response phase of an emergency. ~ I 1

e f Contaminated emergency worker equipment, vehicles and ') i supplies would be identified and isolated until such time as the Division of Public Health Services (DPHS) can evaluate the safest and most efficient method to accomplish l decontamination. However, DPHS supervisors may direct the decontamination of selected items as deemed appropriate, based on the need for the item, time, staff available, and other conditions which are unique to a particular emergency. Appendix F9, Volume 4A, of the NERERP identifies the appropriate equipment to conduct decontamination of the selected items. 4. Anticipated Number of Vehicles j I Assuming 9,667 evacuees per host community and taking (_) information provided in Volume 6 of NHRERP which indicates that a reasonable assumption for vehicle occuprney is 2.6, i the planning basis for vehicle load at each host community was obtained by the following calculation: I 9,667 / 2.6 = 3,719 vehicles Rounding the number, 3,800 vehicles was established as the planning basis for all host community centers. 5. Analysis of Reception Center Processing a. Registration Operations i. Description of Operations l The New Hampshire Department of Health and Human l Services Emergency Services Units (DHHS/ESUs) are responsible i I f) for establishing and administering reception and registration l %J 1 1 _

7-) of evacuees at host community reception centers. Each center '~'/ s will be served by these Emergency Service Units (ESUs), which are made up of staff from DHHS Divisions of Human Services, Children and Youth Services and Elderly and Adult Services. These units will function as trained cadres of department personnel who will provide registration services as well as operational supervision to volunteers in the provision of 1 evacuee registration, message exchange and locating service, j i information/ recreation services, mass care referral and i student pick-up coordination. NHRERP, Volume 4B, Division of Human Services procedures provide a detailed description of what constitutes these various services. All persons entering a reception center will be (q registered, including persons seeking information only or j picking up relatives or friends. The principal purpose of this registration is to facilitate location of persons who l may have been separated from a family or other unit. j i Registration information will be recorded on Form 1050. Other services such as medical or mass care referral, message i exchange, family reunification, and provision of information to evacuees will be provided as needed. An analysis of registration processing has been I conducted by the Division of Human Services to determine the number of staff required to provide registration services under the most pressing circumstances. An assumption was fS) made that one registrar can process a " registration unit" v -8 1

every ten minutes, which translates into six units per hour

,-)

or 72 units per twelve hours. Based on the assumed vehicle occupancy rate a " registration unit" can be considered as 2.6 people. ii. Personnel Requirements and Availability Using the number of evacuees anticipated to arrive at reception centers, the calculation that follows determines the number of units requiring registration and the maximum number of registrars needed at each location. Reception Center Registration Resources and Needs Formula Projectai Arrivals / 2.6 = Number of Registration Units Since 1 registrar can register 72 units in 12 hours: tt.:mber of / 72 Units Nutrber of = Registration Units Registered in 12 hours Registrars Needed l Actual Planned Ighn Staffim Needed Staffim Recuired Rochester 6,829 / 2.6 = 2,627 Units 52 4 2,627 / 72 = 37 Registrars l l Dover 9,621 / 2.6 = 3,701 Units 52 3,701 / 72 = 52 Registrars Salem 6,416 / 2.6 = 2,468 shiits 52 2,468 / 72 = 35 Registrars l l Winchester 9,667 / 2.6 = 3,719 Units 52 3,719 / 72 = 52 Registrars Totals: 176 Registrars 208 l l l I

I-l' The NHRERP, Volume 4B, A-2. Division of Human Services r procedures, includes a staffing chart entitled " Staffing Availability for Reception Centers". The personnel on the chart in Volume 4B who are assigned to primary and support ESUs are'given training in reception center operations annually by the Division of Human Services.

b. Other operations In' addition to registration requirements there are an additional 220 persons needed as follows:

Message Exchange and Locating Service 4 x 16 = 64 Coordination of Volunteers 4x 3 = 12 Information and Recreation Workers 4 x 10 = 40 Sorters and Receivers 4x 6 = 24 Student Processors (if schools in session) 4 x 20 = 3_Q 320 Thus, the total personnel needed to carry out all functions would be 428. In addition t:, the 90 ESU personnel, i I there is estimated to be another 471 personnel from the three l DHHS Divisions who could be called upon to staff the four reception centers. Therefore, the total number of projected staff is'in excess of that required to serve the anticipated number of evacuees arriving at reception centers. In addition, volunteers from the host and adjacent communities Could be USed to augment DHHS staff. a 1 I .A. c. . Equipment: Requirements d.. A minimum.of 40,000 copies of Form 1050 will be acquired and stored at Division'of Human Services district and State offices. other equipment, such as office supplies and 300 1 directional signs,.'is. maintained at district and State offices, and is' ready for delivery to reception centers. Tables and chairs are 'eadily available at the reception r facilities. Crowd management material, such as rope and; crowd tape, will be available as needed for Reception. Centers --from the decontamination' center supplies which will be provided_to each Host Community. 6. Analysis-of Monitoring and Decontamination Operations. The monitoring and decontamination centers are intended to serve the general public and emergency workers who are -evacuated from-the EPZ and who might-have been exposed to a release of radioactive material. Each host community has two monitoring and decontamination facility centers. The primary l center of each host. community has sufficient capacity to meet the planning basis of 20% of total evacuees. The secondary center in Manchester is used for emergency workers. The secondary centers in the remaining three communities are available to be activated if they are required. The primary monitoring and decontamination center is co-located with the reception center in Manchester and Dover. In Salem and Rochester, the primary monitoring and decontamination center is in a separate building near the _u_ I J

t reception center.- The facilityflayouts and traffic flows for each monitorin'g'and decontamination, facility are presented in i the NHRERP, Volume 4A, Appendix F1. a. Monitoring and Decontamination Operations (i) Monitoring Operations t Initial monitoring.of evacuees arriving at reception centers will consist-of monitoring vehicles as they arrive at the reception centers. NHREP, Volume 4A, Appendix F1 shows the areas at which i vehicles will be monitored.as they arrive at each reception j i center.. Vehicle monitoring procedures in Appendix F5 have been reviewed and will be amended to show that veh c es will il be monitored with a COV-700 by one fire fighter performing a (). scan of the vehicle's grill and a wheel well. This procedure can be completed in approximately 50 seconds per vehicle and covers vehicle areas which would most likely be contaminated if a vehicle encountered a contaminating plume. If the initial vehicle monitoring reveals no contamination, the vehicles will be directed to a parking area designated for non-contaminated vehicles, and evacuees arriving in these vehicles will proceed to the registration area monitoring point, as shown in Appendix F1. If initial vehicle monitoring reveals contamination, the vehicles will be directed to a parking area set aside for contaminated vehicles. Evacuees arriving in these vehicles will be directed to the control point monitoring area within q) - 12 1 i ._________._.J

} the decontamination center where they will receive a more ,- 3 \\'") extensive, full-body, personal monitoring. This more f extensive monitoring, called " control point monitoring" is described in Appendix F5, Volume 4A of the NHRERP. Additionally, if an evacuee is found to be contaminated at the registration area monitoring point, the person is i immediately referred to the control point monitoring area for i more extensive monitoring. In this manner, evacuee monitoring provides for the immediate segregation of potentially contaminated persons from non-contaminated persons. j If the majority of evacuees arriving at the center are being referred to the control point, the registration area (] monitoring operations could be terminated by the DPHS Supervisor and all individuals would then be directed to the control point monitoring area. This would provide more effective use of available monitoring personnel. Once contamination is pinpointed and recorded at the control point, the evacuee is referred for decontamination. Each evacuee is " labeled" clean, contaminated or potentially contaminated through the use of a special tag which is given to all evacuees at the vehicle monitoring area. The tag has body diagrams and identifying numbers used for tracking evacuees and belongings through the monitoring and l decontamination process. Reception center staff will not allow an evacuee into registration until the tag shows the - 13 l l l l l

(- } l l l 1 evacuee has been declared " clean". i l 7s ( ) i (ii) Decontamination Operations As described in NHRERP, Volume 4A, Appendix F6, the i initial step in the personal decontamination process would be l l the identification and isolation of any contaminated clothing 1 or personal items. The contaminated items would be j I inventoried, (see Volume 4A, Appendix F5-Form 7), and placed in a personally identified plastic bag. Decontamination of a person may be provided by three methods: local, general, and a combination of local and l 1 general decontamination. Local decontamination could be i carried out in either a sink or shower when only isolated parts of the body are contaminated. Direct washing of the r~(m) area with a soft brush and soap is employed with care being exercised so as not to spread local areas of contamination to other parts of the body. General decontamination consists of l l a full-body shower and is used when an evacuee is l l contaminated over a large portion of the body. A combination of local and general decontamination is employed when an evacuee is contaminated over a large portion of the body with localized areas of higher contamination. In this case, those areas of the body with higher levels of contamination would l be washed using local decontamination procedures prior to the l full-body shower. Each of the two decontamination centers per host 1 (~/ community makes use of the gymnasium for waiting areas for I T \\_

l l

l l l 1

the control point monitoring _and locker rooms and showers for 1 ) . decontamination. Only middle and secondary schools are used [ for decontamination centers as they provide sinks and 'l' showers. 'l (iii) Emergency Worker Medical Referrals Emergency workers with wounds that require medical attention would be referred directly to a medical facility. 4 1 Volume.1, Section 2.7.5 and Volume 4A, Appendix F will be amended to clarify this policy. The medical facilities to 1 .which emergency workers may be referred, and their ] f capabilities are listed in Table 2.8-1, Volume 1 of the of the NHRERP. b. Personnel Requirements () The chart below shows the number of personnel required to staff the monitoring and decontamination center in each i host community. The staffing charts contained in Appendix j 1 F4, Volume 4A of the NHRERP will be amended to reflect these numbers. J l Functional Area Staffing Planned Primary Center Staffina I Decontamination Admin (DPHS) 3 Buffer Zone Advisor 2 Interior-Monitoring 6 Interior-Decontamination 6 Exterior-Control Point and 41 4 Reg. Area Monitoring Exterior-Vehicle Monitoring 11 69 4 [#l Planned Secondary Center Staffina Decontamination Admin (DPHS) 3 Buffer Zone Advisor 2 Interior-Monitoring 6 Interior Decontamination 6 I Exterior-Control Point _A 23 i TOTAL FOR BOTH CENTERS 92 The personnel staffing indicated for the primary center reflects the number of personnel that could provide monitoring services to 9840 evacuees within a 12-hour period, the staffing for the secondary center reflects the number of personnel which 1 l could provide monitoring services to an additional 1440 persons within a 12-hour period. [~D (i) Staffing Levels for Monitoring Positions l %-) The staffing levels for the positions of Decontamination i Administrator, 3, Buffer Zone Advisors, 2, and Interior Decontamination, 6, were derived from a careful review of procedures and experience gained through walk-though demonstrations, drill, and an exercise. (ii) Staffing Levels for Control Point and Registration Area Monitoring The positions of Control Point and Registration Area Monitoring are responsible for providing monitoring of individuals to detect contamination. The personnel who staff these positions can be moved between the two positions, as necessary, to optimize the center's operation. Assuming the j r^T l i (/ entire 9,667 expected individuals are potentially contaminated, ' i L___

all of the individuals would be referred directly to control /~' j \\ ') point monitoring. Given an average monitoring time of three minutes per individual, 20 individuals could be monitored in one hour; and 240 individuals could be monitored in 12 hours. The staffing level for these positions can be determined by the equation: 9,667 (Assumed Facility Load) / 240 = 40.28 Staff Required This number was rounded off to 41. The control point monitoring positions at the secondary decontamination center have an assigned planned staffing level of six. Using the same rationale as discussed for the control point monitoring for primary centers, it can be shown the secondary - /~'T centers have the ability to monitor 1,440 individuals.within a V 12-hour period. Therefore, the Manchester secondary center, which serves as the monitoring and decontamination center for the emergency workers, can provide monitoring services for the anticipated 1300 emergency workers. (iii) Staffing Level for Interior Monitoring Position l The personnel assigned to the position of interior monitoring are responsible for monitoring individuals after they shower. The staffing level of six would provide the capability to re-monitor approximately 1,440 individuals in a 12-hour period. (iv) Staffing Level For Vehicle Monitoring Considering one monitor is able to survey a vehicle every k_)g - 17

c minute (which equates to 720 vehicles in a 12 hour period) the staffing level of 11 monitors provides a capability of surveying ] + 7.,920. vehicles in a 12-hour period. This far exceeds the. anticipated number of expected vehicle arrivals at each center including' Manchester where an additional 1300 vehicles are anticipated due to emergency worker arrivals. c. Personnel Availability =DPHS will provide-personnel to staff the 24 decontamination Administrative positions in the four host communities. The 1 Revision 2 of the NHRERP does not reflect current DPHS decontamination administrative staffing. Currently 18 . individuals are identified to fill these positions.

However, there are only 15 Decontamination Administrative positions

() required within the four primary centers and the secondary center ( in Manchester. As operation of these centers provide sufficient capability to provide monitoring and decontamination services in excess of the anticipated demand, there is sufficient DPHS staff to support the planned host community response. DPHS will continue its efforts to identify individuals to staff the I remaining six positions. The New Hampshire Office of Emergency Management has established a working relationship with the fire departments of the four host communities for the purpose of providing monitoring and decontamination services.. Based on arrangements with fire officials of the four host community departments, a total of 328 j fire personnel will be available to respond to an emergency. The - 18 i i - a

) I Office of Energency Management has initiated a training program e ~' in monitoring and decontamination operations. Training has been provided to date to 162 personnel of host community fire departments. This training is ongoing and will continue to be provided regularly to ensure that sufficient personnel are trained to meet the requirements for maximum staffing of these operations. To provide additional support to host town resources, fire departments from nearby communities that could or do provide mutual aid fire services to host towns have indicated that they will provide personnel to support monitoring and decontamination j operations. These departments provide a pool of approximately 271 fire personnel who will be available to support host Il community fire departments. The numbers of personnel available from these departments were identified by fire officials of the individual departments. The training of these fire departments ) 1 in radiological monitoring and host community operations is an additional measure to assure that sufficient reserves of trained personnel will be available. L J Based on an analysis of the planning basis described in this testimony, the primary monitoring and decontamination center J alone has adequate staffing to monitor expected evacuees within an approximate 12-hour period. The secondary center at Manchester has the capability to provide the described monitoring and decontamination services to all emergency workers. Each k (') primary monitoring and decontamination center will require 66 l \\/ - -..

personnel plus three DPHS positions for a total of 69 personnel ? k required to provide the services described within this testimony, i The chart below lists the primary monitoring and decontamination center fire personnel needs and the fire personnel available for all four host communities. Planned ' Planned Host Fire Other Community Primary Secondary Department Fire Departments Total Center Center Available Available Available Staffina Staffina Dover 37 88 125 66 20 Salem 47 68 115 66 20 Roch. 68 32 100 66 20 Manch. 176 83 259 66 20 Totals 328 271 599 264 80 While operation of the secondary decontamination center in () conjunction with the primary center would require an additional 20 fire personnel plus three DPHS staff, it is not required to meet the planning basis and, except in the case of Manchester where it serves as an emergency worker decontamination facility, is for back-up use only. If the staffing for secondary operation is factored into the total need, the four host communities require an additional 80 personnel (exclusive of DPHS supervisors). The resulting total staffing need of 344 (86 per I host community) continues to be less than total available staff. d. Decontamination capabilities The decontamination procedure in Appendix F6, Volume 4A of the NHRERP indicates an average of approximately 10 minutes per 1 (^N decontamination shower. 1 i (_) ! ] 1 i i l i i l i

l The chart shown below reflects the number of showers ( \\ L# available at the primary and secondary decontamination center for each host community and the hourly shower capacity for each facility. Host Community Showers Primary Secondary Totals Center Capacity Center Capacity Capacity Host Community Showers Per Hour Showers Per Hour Showers Per Hour Rochester 28 168 24 144 52 312 ) Salem 29 174 25 150 54 324 Dover 40 240 34 204 74 444 i Manchester 25 150 31 186 56 336 e. Equipment Requirements and Availability Equipment required for monitoring and decontamination operations is listed in NHRERP, Volume 4A, Appendix F9. A } revision of Appendix F9, which reflects revisions in supply inventories, is Attachment 2 hereto. The necessary amount of l equipment is defined as that needed to monitor 9,840 evacuees I and the necessary equipment to monitor 1,440 emergency ] ] workers and decontaminate those workers and selected equipment, vehicles, and supplies. While the list of i suppliers in Appendix F9 is not amended, it may change as additional decontamination center equipment is purchased. It i can be observed from the Appendix that more than the required i q supplies are available. L/ { l

( Equipment will be stored at designated areas in each 73 r s l host community and will be maintained by the Fire Chief or i his designee. The principal item of equipment required for monitoring operations is the CDV-700 survey meter. This instrument is to be used by monitoring personnel to screen vehicles and persons for potential contaminants. A total of 70 of these instruments'is required to equip all of the described monitoring' positions in both the primary and secondary monitoring and decontamination center for each host community.. A total of 80 of these instruments will be acquired and maintained in each host community, specifically for these monitoring positions. This provides greater than (~') 10 percent surplus to allow for possible equipment failure. v These instruments will be subject to the same inventory and operational verification schedule prescribed for all radiological equipment by the NHRERP, Volume 1, Section 2.4.5. These will be added to the equipment list in j Appendix E. f. Summary cf Monitoring and Decontamination Center Capabilities As shown in the Monitoring and Decontamination chart, hereto, the four primary centers in conjunction with the secondary cen'ter in Manchester, based on the standards presented in this testimony, will be able to provide monitoring services to anticipated personnel and l es k_) vehicle arrivals at each center. Additionally, the chart j - 22 }

summarizes the staffing requirements defined in this ,- s 1 ) testimony and shows that personnel will be available in excess of the defined requirements. 7. Waste Water i The procedures and equipment list for the sampling of waste water from the washing of evacuees and their vehicles are contained in NHRERP Rev. 2, Volume 4A, Appendix F10. The purpose of Appendix F10, Environmental Monitoring in the Host 1 Community, is to verify that the discharge water from the ) decontamination centers does not exceed values for i permissible concentrations identified in the New Hampshire { Rules for Control of Radiation. The current procedures of the NHRERP establish that O seeee vere eme1 111 9r v1ee the ree "rce e ecc 911eu environmental sampling. f i The responsibility for environmental sampling will be under the control of the Division of Public Health Services. ] l The Water Supply and Pollution Control Division of the ] Department of Environmental Services will assist in collecting samples. The Field Monitoring Procedures ] contained in the NHRERP, Volume 4A, Appendix C, will refer to Volume 4A, Appendix F8, Section D to reflect monitoring and sampling of host community decontamination center discharge water as part of the Special Environmental Sampling Procedures. l Sampling of discharge water from host community l [ l l t

7 \\ i ? ). decontamination centers will be performed by the Water' Supply . V( and Pollution Control Division under the direction of the l 3- .DPHS. Special Environmental Sampling Procedures will be a'ded as an attachment to the Water Supply and Pollution d Control Division of the Department of Environmental Services Procedures in Volume 4B of the NHRERP. Water Supply and l Pollution Control maintains a roster of a minimum of 11 l. persons available to support special. environmental sampling. The' equipment required for each set of samples per community is listed in Attachment 4. The described equipment is in the process'of being acquired, and will be maintained by DPHS. l Contaminated water will be flushed into. ordinary drains. Faucets or shower heads will be left open to insure that' dilution occurs and that concentration limits are maintained i in accordance with the New Hampshire Rules for Control of LRadiation. Sampling will be performed at the discharge points of the host communities at those locations specified in the procedures and other points'that may be identified by DPHS. If deemed appropriate by DPHS, a New Hampshire monitoring team could be assigned to collect and screen water samples prior to the samples being sent to the laboratory. In any case, a laboratory analysis of these samples will take place in the DPHS Laboratory in Concord, New Hampshire. The laboratory equipment to be applied for this purpose is shown in NHRERP, Volume 1, Table 2.5.2. The type of analysis to be ~ conducted on water samples is shown in Table 2.5-3. - 24 I l 1 I

i .e p:V 8. Solid Waste Disposal ~# Decontamination center close down. procedures are contained in Appendix F. Volume ~4A.and Appendix B of Host ~ Community RERPs address shutdown and removal of contaminated material and contaminated waste. Contaminated waste-will.be disposed of by.the State through established contrac'tual. i . procedures with qualified radioactive waste. handlers, and~in l conformance with rules promulgated by the DPHS Radiological-Health Program for control of radiation. Contaminated materials will be handled by New Hampshire Yankee according to the provisions'of the letter from George S. Thomas, Vice- . President for Nuclear Production, dated May 1, 1986, included i in NHRERP, Volume 5. ] O _ _ _ _ _ _ _ - _ _ _ - _ - _ _ _ _ - - _ _ _.

.i ATTACmiENT 1. (1 of 2) U." gh.y Federal Ernergency Management Agency g E y washinston, o.c. 2on: [ DEC 24 75 l ) ME!OPANELN FOR: Nni Division Chiefs J rpm: Kr Assistant Associate Dinctor State and Incal Prograns and Support St2LTECI: Gaidance on NUREG-0654/f1NA-RIP-1 Evaluation Criterion J.12 ] l I Wis memorandum provides integretative guidance en NUR.TA654/FIMA-PIP-1 q protective a spense evaluation criterion J.12: { Each, organization shall describe the means for racistering and rrfonitoring of evacuees at relocation centers in host areas. 'Ihe personnel and equipnent available should be l capable of monitoring within about a 12-hour period all 'O r te "t >=* 'r = t "t= 1" ex 91== x9= "= trz arriving at relocation centers. The question arises as to the percentage of the evacuees that could reason-ably be expected to arrive at a relocation center (s). Previous experience gathered on evacuation responses to a variety of natural and technoic;ical ene mencies is not conclusive. Research into this matter, however, has i revealed that anywhere fran 3 to 20 percent of the evacuees arrived at relocation centers or shelters. For radiological ene gencies, it is rea-sonable to assume that additional evacuees, to allay their concerns and fear over radiation, will go to relocation centers whether or not they have been exposed to radiation. 'Ihus, the percentage of potential evacu-ees for radiological emegencies may be closer to the upper end of t.% 3 l to 20% range. De congregate care issue is reviewed as a part of all Atomic safety and Licensing Board hearings, although it has never been formally litigated at such a hearing. 'Ihe corgregate care facility capacity in the vicinity of nuclear ;cwor plants is usually cited as being between 5 and 15 percent of the estimated number of evacuees. With these percentages in mind, it is apparent t: t there is significant diversity in the frame of reference sur-rounding this issue. O 1 i i l i J

ATTACHMINT 1 (2 of 2) n yO l ~ 2 ) (1) Past { The guidance provided below is based on the fe11 ewing facters: experience with evacuations regardless of the nature of the emergency, (2) inclusicri of fear ard uncertainty f actors associated with ra:!iolcgical emergencies ard (3) percentage of potential evacuees for congregate care facili' ties cited in Asra hearings. Guidance. f The statsund decal eadj@g k.awss l@ans,. { e .sshould.did16derroE31cns 2t tr of_tra_ nedw:,and :aquigi$tht-tm =- --Ater a mini:ma et 20 - i 'pe,geg15..of dbg.Jastimatigd.Ji6pulation'sto be mtad. forh10My N1e JEfiiE16'#1_5I11ttEleasesMrns@@gfigh dgv We iaT1on:46=,==u.g; e zslatiyelyhe srea,, it i may be'necessary to nonitor a greaterjamber of evacueed l beyond 20 lpe'ecent 'of the population In such a mituatione, -l Jtats Jrd Amat envermertts -'id'bkew p see m ico g4

i. lamen hoccaspense imeasures,w-lamented,%f rned_eds.

urd 3:r ivatemoctor2*s:uzRims 22r.:2 g. e O Any questions or concems about this guidance should be directed to Mr. Bill i McNutt at 646-2957. t O I (

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ATTACHMENT 4. j l f'Y i Xj ATTACHMENT 4 l Environment",' Sampling Equipment i The equipment needed for each set of samples per community: 5 disposable funnels 5'- one liter bottles with the tops cut' off 1-1/2" below the ] neck t 2 5 - one gallon bottles disposable gloves disposable coveralls duct and masking tape 5 weights - reusable for all~ sets of samples reusable for all sets of 40 ft. of thin, strong rope -samples j 't^) ' scissors - reusable for all sets of samples s.J magic markers - reusable for all sets of samples l l O l 1 t f i

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W s 1 'I PANEL NO. 4 -DIRECT 474 L 3 1# (1. MR. LEWALD: I have other copies, if it would assist 2 .the Board. 3-JUDGE SMITH: I ended up with. October;1st, and so did i 4 Judge Linenberger, so that we could use two, if you will? -) Sr M R. LEWALD: Certainly.: .6 (The Board is proffered two copies of the above -

7

.. mentioned document.) .8: .MR.;OLESKEY: Could we have-a. copy, too, Mr. Lewald, -{ 9 please? J 10 MR. LEWALD: Surely. 11 (Counsel is proffered document.) 12 M R. LEWALD: Your Honor, if-you please, the panel' l rre .13 stands ready for cross-examination. {%s -14 JUDGE SMITH: -Mr. Backus?- -15 MR. BACKUS: Thank you, Your Honor. I 16. MR. LEWALD: Your Honor, if you please, prior to the 17 panel being examined, it has been the some time practice here, 18' to Dive a short opening resume of what the panel testimony-19 covers, and if the Board wishes, I can do that presently. 20 JUDGE SMITH: I think that it would be appreciated. 21 Would you please? 22 MR. LEWALD: The testimony of this panel addresses 23 the Seacoast Anti-Pollution League contentions 7 and 33. And i 24 these as noted in the testimony, challenge the adequacy of 25 personnel and equipment available to the four designated host ff I uJ 4 Heritage Reporting Corporation (202) 628-4888 i

m .i PANELuNO.'4 - CROSS 4742 '\\- 11 ' communities to meet the registration monitoring and ' contamination requirements, associated with the assistance l 2 d 3 provided.to_ emergency workers and general public: evacuees 4 arriving at reception centers, and to provide for adequate 5[ disposal of waste water. 6 The testimony of the panel. describes the planning- { 1 '7 basis utilized in setting up/the reception'and decontamination 1 -8. centers, to be used, if necessary,,after.a radiological-i 9 emergency; the personnel requirements, and availability of! l .10 personnel equipment requirements-and availability of the i 11-registration, monitoring and decontamination operations which 1 ] 3 12 are contemplated _and the methods which will be utilized [to + fl o - ' 13 handle' wastes resulting from the decontamination operations. i J 14 That'is essentially what the. testimony of the; panel-15 'is, and the: panel stands ready for cross-examination. 16 JUDGE SMITH: Mr.'Backus? g 17' M R. DACKUS: Thank you, Your Honor. 18 CROSS-EXAMINATION l 19 BY MR.'BACKUS: I l 20 0 Good afternoon, gentlemen. 21 I am going to turn first to page 7 of the direct l 22 testimony. ) l 23 Where you assume or some member of the panel, I i l 24 trust, assumes that at the decontamination centers, an average j I L 25 of 2.6 people a car will be arriving. l .LO Heritage Reporting Corporation (202) 628-4888 l

L 9 t J .I - l L s . PANEL NO. 4 - CROSS. 4743 0:17~ + 1~ - 1: Am ILcorrect,-that that is the statement contained on el pagen7'of;the testimony and carry throughout the calculations 1 3. that1are.done.that we are. dealing with-basically-an' average'of' 4 2.61 people.per' car, arri'vingfat the decontamination reception. 5 centers? 6.. A-(Ca11endre11o) As the! testimony states, that is.the' 7 assumption for.' vehicle occupancy, yes.. It'is not.'an;nverage. T. B .It is the assumption of 2.6 persons per vehicle. ,9 .O And this.is.an - assutapt ion, is'it not,fthat'none-of 10-the members of this panel hasLconducted any surveys to der.ive ] 11 thisinumber?" '12 A '(Callendrello) 'It.is an assumption consistent.with l f,v4 13 the' surveys, Land.the research involved in: developing the o 1'bs ' evacuation: time estimate. -The source of that~ number' is the 14- ~ ' 15 evacuation' time estimate. So that the surveys and anyL j 16 subsequent calculations'regarding that number were derived in l 17 that evacuation time estimate. I' don' t know if any of: the ... / 1.0 other members of the panel have any other experience related to .j 19 the vehicle. occupancy. rate? I 20 Q Is there any other taember of the panel that has any 1 I l 21 experience with vehicle occupancy rates, such as we are talking 'I 22-about on this test imony? l 1 23 ,No response.') l ( l 24 THE WITNESS (Callendrello): No other panel member 25 indicates that they have any other data. bt. Heritage Reporting Corporation (202) 628-4888

.j c ii; i o. l. PANEL NO. 4 - CROSS 474L i. g-s. '\\" 1. BY MR. BACKUS: L L 2 O So, is'anyone, I guess, it would be you, Mr. l 3 Callendrello, in this panel, able to defend the reasonableness 1 i 4 of that assumption? l J 5 A (Callendrello) It is an assumption that is 1 6 consistent with the evacuation time estimate and that number i 7-was. derived and the calculation for deriving that number is 8 contained there. '9 0 Well, I don' t necessarily mean to be getting into 10 Volume 6, of the New Hampshire Plan, which I understand to tua 11-the evacuation time estimate. la Do you know, Mr. Callendrello, where that number 2.6 13' persons per vehicle.came from? . =q. A ). q '14 A (Callendrello) There '>nas a calculation that KLD 15 Associates.did in determining the average vehicle occupancy 16 rate, and that calculation is contained in Section 2, of that 17 evacuation time estimate, and if I remember correctly, it is a 18 full page calculation. 19 I don' t recall the specifics. I know what the end 20 conclusion was, that 2.6 persons per vehicle is the occupancy 21 rate. 22 O And I am corr ect, Mr. Callendrello, that that figure 23 in the evacuation time estimate came from some sort of a survey 24 that was done? 25 A (Callendrello) I don' t know with certainty where O Heritage Reporting Corporation (202) 628-4888

p o, I" n; l-PANEL NO. 4 - CROSS. 474U i I La-1 all the data came from. I know that there was a calculation 2 that -- that'the-calculation involved the number of persons per 3 household; number.of calls per' household; and I believe that' 1 4 some of that data was acquired by a telephone survey. Where- ) 5 every piece of data that went-into that. calculation, I cannot 1 6 speak to that. 7 0 You were not involved in that survey, yourself,were B you, sir? i 9 A (Callendrello)' No, I was not. 10 Q And you were not involved in designing of that 11 survey, were you? l 1 12 A (Callendrello) No, I was not. i i yv 13 O And so for the purposes of this panel, we are to take 4 l r 1 Smd 14-that 2.6, as derived.by KLD, or the subcontractor, and you are. .l 15 using that on-the authority of those individuals, not on your ., j 16 own authority, is-that right, Mr. Callendrello? l 17 A (Callendrello) I am using that as a reasonable f 1 18 assumption for the vehicle occupancy rate, for persons arriving 19 at a reception center. l 20 Q And but as I understand it, you are not here to be i 21 able to personally tell us, how that 2.6 was derived on the I 22 basis of what survey documents, whether or not there was any l 23 bias in the survey, or any of those things? l 24 Is that true? 25 4 (Callendrello) That is correct. We asked Mr. l l l Heritage Reporting Corporation (202) 628-4888

a .V-t e PANEL NO. 4 - CROSS . '474E f R E I 1: Lieberman for,a reasonable' assumption for vehicle occupancy W 2, rate, Land that is the. number that we-were given.- 3 G 'Okay. 4 And_so, it would be true, would.it not, if:the number ~ 5 were really say, 2.3, as an accurate projection-of occupants s 6 per vehicle, rather than 2.6, that would mean that you would - c. 7 need to-process more registration' units, would-it not? 8 .R (Callendrello) I believe that the section of.th'e '9 testimony'that you are talking about, talks about the' number of ~ 10' vehicles. 11 As far as processing the number of registration - 12 units, if.the, number was, in fact, smaller 3 there would be more ~ t ? 7 13 registration units, that-would need to be addressed. 14 I;would just like to add something.though.. The. 15' number of 2.6'is below what Mr. Colburn has indicated is his 16 experience-in the average family unit size, and maybe he would 17 like to address what his experience has been?' 18 0 'I amisorry, I did not hear.that, is below what? ' 19 A (Callendrello) The number that Mr. Colburn has, 20 based on his experience of assembling family information. We ) 21 adopted.what was a lower number, therefore,. overestimating the f i 22 number of registration units. And as.a result, having a larger l 23 number of staff. ] t. L 24 0 Do you want to add some answer to that question, Mr. L l E 25 Colburn? ] 1 I Heritage Reporting Corporation (202) 628-4888 J L= __ - _. -. -

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-l .i 5 l . PANEL NO. 4.- CROSS. 4747 'i77: s e 31 1 1 .Mr.-Callendrello can' hand you a microphone.' 2. A (Colburn) 11 will try. 3 Origina11y when we were looking at.the number of { f 4 registrars that we felt would be.needed to process people,. i 5 coming'into'the reception' area, so. we used-a.. figure'which is' 6 an average, or was, at that time, considered an average of a 7 family grouping. 8 And in the Division, now the Division of Human 9 Services, is commonly used, some variation of.this, the. family 10 grouping being 3.2, and originully when we did our 11 computations, we used that figure, as an average registration le unit, as we call them. 13 Subsequently, for the purposes of consistency,. it was. -(iL 14 decided.to use 2.6 figure, which was fine with us, because i k 15 actually it gives us much more leeway in terms of the number ' of 16 people that we are planning for. It is a very. conservative 17 figure, I believe. 18 0 Well, you say that there was a number of 3.2, Mr. I 19 Colburn, that you had from some experience with your division? l 1 i 20 A (Colburn) That was a figure, that, which at the time J J l 21 ': b at we originally did the calculations, was considered to be, 1 1 1 22 so I was advised, an average family grouping,

3. 2, for various

] l 23 purposes that the agency might use, for determining some of its j 24 own objectives. l 25 0 Now, wait, what is the 3.2 used for, for purposes of I ?) l l-Heritage Reporting Corporation (202) 628-4888 l 1

( t k PANEL NO. 4 - CROSS 4748 1 "r' q 1 5 1 your agency?.'- .] 2 A (Colburn)- Simply as;an. average family. grouping.that: . !3 J He might be' dealing with. ]j 4 .O .Do'you mean that is an average-sized family',that you I 5: use when: projecting'the need? ( 3 .fi A' (Colburn) That was considered a typical or' average > } 1 7 size, inLthe area of working with, particularly, with' welfare-1 8 groupings,.AFDCLgroupings, and that sort of thing. j i 9. O And did you consider. that that : grouping forf typical 10 family size for welfare / purposes, had' some relationship to the l 4 11-number of occupants that you could expect in vehicles-f 12-evacuating from.a nuclear disaster? i 13L A l(Colburn) No, it'had nothing-to do with vehicles, as ) J 14 far=as I was concerned.- It was just.-- it seemed to me, as we 1 15L consider processing people coming in, as individuals or as . i 16 groups, it would be a reasonable basis, upon which to base our l 17-calculations. o l t L 18 Q-Now, Mr. Callendrello, i f, in fact, the number-of -- 19 the appropriate number of occupants for vehicle was 2.3, } 20 instead of 2.6, am I correct, that if that were the case, we 1 i L 21 would be looking at some 4,203 vehicles instead of the 3,719, i i 22 referenced on page 7, of your testimony? i 23 A (Callendrello) I have not done that calculation. - 24 0 4,203 registration units, I am sorry, a . 25 A (Callendrello) The numbers should be higher, whether i O Heritage Reporting Corporation 3 l (202) 628-4888 l. i r

.l .] PANEL NO. 4 CROSS. -4749 D 1 1. it.is 4,203, I cannot_say, I have not done the c:alculation.s j 1 2 0-Okay, let me suggest to you-that that is the way that 3 it works out, if we have done the calculation correctly,.and 4 offer you an opportunity to check that and if you would accept 5 that number, subject to check. -- 6 A (Callendrello) When you say, 4, 2O3, that is.,only<for 7 which community? i 8 I f. I look at Manchester, which is the community that i 9 has the largest number of evacuees, that is the one that works ~ 10 out to.3,719: units, f 11 The other communities have smaller populations.that 12 would-be arriving there, and obviously the number of-13 registration units, even divided by the 2.3, would'be,some 14 smaller-number. '15 And again, without havinD done the calculation, it l4 1 16 looks like some of them would be below the needed number of 17 registrars, because we had planned for the same registrar 18 staffing at each of the four reception centers, based on the 19 demand of the largest evacuee load. 20 Q And yes, it is in fact, true, that for each of the 21 reception centers, each of the four primary reception centers,- 22 you use the figures that you project for Manchester as a 1 23 planninD basis, in determining staffing requirements, have you 24 not? 25 A (Callendrello) That is correct. r 5 l Heritage Reporting Corporation { (202) 628-4888 l 1' l C. _______-__a

t: e;., : y. }. '.' ' ', x tl, j m l.: PANEL.NO 4. . CROSS. =4750 i k b li . G; .Well,~then with[that? assumption,. Land. going'back t'. ] o ? 2 where I.=a the.. question that'I.'had pending,'previously, .3-would you agree,, subject : to check, ; that. i f..it is,2. 3 occupant s : 1 t q 4' per car, we would be talking. at7ut. 4,203 vehicles arriving, ] l 5 instead of the 3,719 set'forth on page:7?s ci, ~6 A' (Callendrello) If that is the way thatathL '7 calculation works out,'I wil1~ accept--that. It.will work out,-to a ,) 8' 'some larger number than 3,719. 59 G. Okay. .j 1 )k i' 10' .And if that number is correct,' subject to check, then I. 11-the'. staffing requirements would be 59, would it not? 12-A (Callendrello) Without doing.the arithmetic, I-don' t i> a (_, l 13 know if thatfis the number orinot. ' '14 Q. Okay. ~ ' l l 15 Well, let me just make sure that I.have.donesthe-4 16 correct thing here. To chanDe the' assumption from 2.6 to 2.3, l we would simply divide 2.3 into the 9,667 individuals assumed, l 17 18 is that correct? 19 A (Callendrello) That is correct. 20 0 And then to determine the staffing, you would divide 21 the number of vehicles.by 72, is that correct? 22 A (Callendrello) That is correct. 23. Q Okay. EndT-6MB 24 Now, my understanding is that you assume that each 25 are, arriving at.these decontamination reception centers, CT I i Heritage Reporting Corporation (202) 628-4888 )y

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+ e PANEL NO. 4,-LCROSS L4751 s Sf )" .1 containsconly one. registration' unit,:is that. correct? e 2 JUDGE. SMITH:' Excuse me, before,you go:on, whatrdid-the number'70, how'did,that work;in'there? 3 ' 4' MR.-BACKUS: I am sorry?

.s 5

-Number-72? 6. JUDGE SMITH: Oh, I see, nevermind,.just~ disregard-' 7 i t '. ' o O MR.fBACKUS: Okay., .9 BY MR. BACKUS 10 Q Mr. Callendrello, do you have the pending question? 11 .A (Callendrello) Yes. 12 .A (Colburn) Could I spe'ak to this a-minute? I 13 0 Yes, sir. H i ~ 14 A (Colburn) I.have the. strong. feeling that we are 15 talking apples and oranges here. As far as IJam concerned, i 16 from'the point of view of registering people, it does not l 17 necessarily.have anything to do with how.many people.come in a 18 given vehicle, or we think how many will come in a given '19 vehicle. 20 We are talking about the average number of people .c 21 that we believe would be cominD through for registration at 1 22 that point in time. 23 We may wind up with people coming out of more than 24 one vehicle, for that matter. I don' t think that the two are I 25 related really as far as registration purposes are concerned. l l ll_)' I r?" Heritage Reporting Corporation (202) 628-4888 l L 1 lNN :_- _ _ -. - -. _

qvm a m 1 i 42-- a' t 1 -n PANEL NO. 4 - CROS'S -4752 ) w\\ , As :I' said, we had originaV1y projat:ted a J 1, 12 registration unit,. larger than 2.6. I don' t think that the two ( 3-should.be necessarily equated. 4 O Well, isn' t the - plan' staf fin,q required as: set ' forth' 5 on page 9, driven by these assumptions of'the. registration ~ 6 units, Mr. Colburn? I 7 A (Colburn) Yes, it is.. ~ ,8 But,.again, my point is that in'using the.2.6, it was 9 done as,a matter of consistency with the figure used for 10 vehicle occupancy. 11' But,.'as far as I am concerned, it.could well'have ~12 been.the. larger' figure, and usinD the 2.6, to my view, is being i n' 13 extremely generous. .V 14 I agreed to this,. but it was not the figure that I l .15 used originally. 16 JUDGE SMITH: What are you registering here, people I on page 97 17: or cars, 1 18 THE WITNESS (Colburn): We are registering people, we 19 are registering them if they come as a group. Naturally we are 20 going to have some who are individuals alone. We are going to 21 have family groupings that come through. 22 In some cases, we may have a part of a family group 23 come through. And we are registering whoever appears and says, 24 I am from this particular household, either I am alone and I 25 have some of my family with me or I have all of my family with I i Heritage Reporting Corporation l-(202) 628-4888 1 d I.

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PANEL NO.-

4.- CROSS .475:1 4 y: ':.y $ $.I.g 1, 'at%... ( ,j + ^ i

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0;9l) 2. -But the registration unit covers 7anything from a o f %:6 s k',,, [3-single. to : a' part ial.: f arpily): unit, to a complete family unit. p.g ; x a> p. /i it easier to~ register a=small'- ( 3m

4J JUDGE-SMITH:

Was -I 5: family;un'ity. thaniit ' is ~ a 6'igger faraily unit?- l '6' THE WITNESS'(Colburp)c' It is a litble easier, but ,.n ,7 actually, you can be registering several people with the form f .8: that:we-use,ais extremely fast. It-takes very.little time. c 1 '4-. 9. 1B Y.- M R.' ' B A C M U S : ?.#. .i ',G . Now, I think that I.;had a questien pending that was, j lLO-11-in'. it not.true~that:.you nonume that each ' car, ar-riving contains: 12. only one. registration unit, is that not.the planning assumption .p 13-on which the staffing figures.-are derived, from the policy: 14 . staffing; figures are derived? l 15 MR.-BISBEE: ' Objection. i i16 . JUDGE SMITH:- I don' t have the quest ion. 17 Could you read back the question, please? 18 (Reporter plays back the question.) 19 20 21 22 23 24 l' 25 p _( Heritage Reporting Corporation (202) 628-4888 J

1 j PANEL NO. 4 - CROSS 4754 l f 1 JUDGE SMITH: What's the basis of your objection? 2 MR. BISBEE: The form of the question. The question { 3 as do you assume that each car will contain one registration i I ( 4 unit. The testimony has already been that -- from Mr. Colburn 5 anyway, that the assumption is not necessarily that every car 6 will contain one registration unit. ) i 7 For purposes of planning, the number used is 2.6, and 8 that's been adequately test i fied to as well. I i 9 JUDGE SMITH: But I think I threw some confusion into { l 10 it by my questions, too. 11 Overruled. I 12 THE WITNESS: (Callendrello) The number of 2.6 1 i e, 13 persons per registration unit was the number used to determine { ( ) 1 14 the maximum number of registrarn needed at any location. 15 BY MR. BACKUS: j 16 Q And I think I heard Mr. Colburn just say, and I want 1 { 17 to make sure I got it correctly, by registration unit you are 18 really referring by and large to a single household; is that 19 right? 20 A (Colburn) It may be a single household. Yes, it 1 21 would be a single household unit. It may or may not be a l 22 complete household unit that comes through; maybe a partial. 23 O Now, Mr. CAllendrello, isn' t it in fact true that the l 1 d4 Applicants' testimony of evacuation time estimates assumes that dS tht?re will be an extensive amount of ride sharing in the event p';q_) i' Heritage Reporting Corporation (202) 62G-4808 l l

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v ?. i 1a 4 i } 3 l PANEL NO. 4 - CROSS 4753' ~ ' i 1*h ;, 1 of~an: evacuation?- i .2. ..A.. (Callendrello). I' m strying to recol1ett what* s in b. 3 that testimony.- <4 .O Well,-if you want me to direct your attention to a. 5' .particular portion offit, I can. I' m looking at page 98 of the 6' -Applicants' testimony on evacuation time-estimate, at least as; 7 filed before today's - edit ion. 8 ,MR. LEWALD: If Your Honor please, what Mr. Backus is s9 . rjoi ng., in. picking up..a portion of the proffered testimony in the 10 ele contention,,and using that as a -- I guesntas a' 4 111- . hypothetical to Mr. Callendrello. But if. he's. doing it, he . id ought to give him more than just a one-liner I think. I f he - 4 { 13- 'wants'to give him a hypothetical on the basis-of that ? - L ] 14-testimony, I see'no problem, but-I think he should identify it ' j 15 as:such, and not assume that it's. testimony that has been j 16' -accepted by the. Board,.or introduced into evidence. j! ~17 . JUDGE SMITH: Well, ' we knew that it wasn' t, but we d 18 also have established that some of this testimony is based upon 1 19 the ETE work. I see nothing wrong with it, i I 20 M R. LEWALD: Well, one number was taken from it, 21 sure. 1 <22 JUDGE SMITH: Certainly. And now he's challenging i l 23 that number from the same source. I i E 1 l 24 MR. LEWALD: My concern is not that it's wrong. I j 25 was just concerned that it be identified. And if it is a l L([) l Heritage Reporting Corporation (202) 628-4888 L L l'..

. {A #. .- PANEL NO. = 4 -- CROSS. 4755 ( -l-hypothetical, that it be identified as a hypothetical. i 2 JUDGE SMITH: We got it from the -- he alluded'to the 3-testimony, didn' t you? ~4 . MR. BACKUSz-Yes,.I did. Let me..backfand-just -.let f 5 me withdraw the pending question..

6 BY MR. BACKUS:

i E 7 Q. Mr. Callendrello, you are going to. testify as,a b 1 8 member of the. Applicants' panel on evacuation time estimates f L9 and human' behavior, are you.not? f L '{ L 10 A (Callendrello) Yes, I am. g f 11 ,GI .And I presume that-you are familiar with that direct f f 12 testimony that will be filed or offered for admission here at a 4 13 subsequent time, are you not? ja-L 14 A (Callendrello) Yes, I am. l 15 Q And are you aware that on page 98 of that testimony _ !U /- 16 there is the statement, and I quote, "In summary, an extensive ] 17 . history of human behavior in an emergency leads one to be 18 confident that -- in the event of an evacuation due to an 4 { 19 emergency at the Seabrook plant -- the vast majority of q l 20 evacuees without their own transportation would receive ] 21 transportation from other evacuees." I I 22 Is that correct? ) 23 A (Callendrello) I don' t recall tite statement 24 verbatim. I recall that there are statements in there on ride 25 sharing, cecause there is testimony from the panel members. I Heritage Reporting Corporation (202) 628-4888 i

f. wo_t m 2:n- [ N[' w- [: :N -PANEL NO. 4.- CROSS. 4757 E ,,.o I. M -11 agreeiwith,that statement, but sI don' t recall it word for word. '2 Q-In fact, do you recall.that there is an entire-3 section in the ETE testimony on ride sharing?. i 4 A (Callendrello)- Yes. 5 Q. And. isn' t it the testimony there, and I ascume you-6'

support'~it, that there will be extensive ride sharing'in the 7.

event.of an evacuation from Seabrook-resulting.from.those i 8 without ' transportation joining t43 to ride with those'that:do 9'. have vehicles?- t 10 .A~ (Callendrello) As I. recall that. testimony, it 11 described Mr. Lieberman's assumption of 50 percent ride I 12. sharing, and the assessment that based.on actual emergency-experience, that number of 50 percent was in fact conservative, 13 14 and that in likelihood it'may be higher than 50 percent. { 15 O Okay. And by ride sharing, we understand we are 16 taking about members of one household picking up members of 17 other households, or people without transportation to share a 18-ride to a reception center, correct? 19 A (Callendrello) That's correct. 20 JUDGE SMITH: Or transients, would that be -- 21 MR. BACKUS: Or transients. Yes, thank you. 22 BY MR. BACKUS: 23 O And you are certainly not assuming, are you, Mr. 24 Callendrello, that all the drivers who pick up or ride 25 share -- provide ride sharing -- will head to destinations O { Heritage Reporting Corporation 4 { (202) 628-4888 l I i

'f 1 4 -P~T. ~ 4758 'J PANEL NO. 4 - CROSS , -.b-[ 1 other-than the reception centers? 2 A (Callendrello) Just to make.sure I understand it: 3 correctly. .If you are asking me whether all drivers that 4 report '-- t hat pick up people for riding sharing will not l 5 report to a reception center,- I agree. 6. O In other words, to state it affirmly, some of them I' 7 will report to the -- .8 A .(Callendrello) Yes. I 9 0 -- reception decontamination centers. 1

10-A (Callendrello)

Yes. 1.1 G So isn' t it fair to say that to be conservative you l 12 ought to. expect.at least some percentage of the cars returning, 1 f-v 13. or arriving at. decontamination centers should have more than ) + t%A h .14 : .one registration unit? E15 MR. LEWALD: I'm going to object to this line of l 16 questioning. It's uncertain now whether it's conservative with -17 respect to vehicles, or' conservative with respect to people, j 18 JUDGE SMITH: Or units. 19 MR. LEWALD: It's assumed that the ride sharers are 20 going to be people with no transportation I think in the ETE f I o 21 -testimony. And he isn' t distinguishing in the question whether l 22 or not it's conservat ive in the number of vehicles arriving, or 23 the number cf registrants arriving. And these figures have L ? 24 been used sort of interchangeably in that -- or the concepts 25 have been used interchangeably in that we' re considering 2. 6 as j Heritage Reporting Corporation ) (202) 628-4888 i

{ j.. p

?

PANEL NO. 4 - CROSS-4759 ( and also the

1

.the appropriate' number of people:per car, 2 appropriate. number to. consider a registration unit. '3 But this weaving'back-and forth is causing. general 4 confusion as to which -- what is being talked about at any one v5. point in time. 6; JUDGE SMITH: Indeed. In fact, I' m really confused 7' .from the very beginning as what the real significance of a B registration unit is, and how it -- what-relationship it has to 9 the need for registrars. I don' t understand it, and I was l I 10 hoping that'this might throw some light on it, too. -11 MR..BACKUS: Well, let's ask about that if it's 12 confusing. 13 BY MR. BACKUS: 1-4 O It's the registration units that -- the determination i 15 of the. number of registration units that's the primary ] '16 determinant of the staffinD requirement for -registration at the 17 reception and decontamination centers; isn' t it, Mr. 18 Callendrello? 1 19 A (Callendrello) No, there's two pieces. One is the 20 number of evacuees that will be arriving at a recept ion center. 21 That is divided by the number of persons assumed to comprise a 22 registration unit for the purposes of this testimony. 23. As I indicated, the number of 2.6 persons per 24 vehicle, which then corresponds to 2.6 persons per registration 25 unit, was used for the proposed staffing. Heritage Reporting Corporation (202) 628-4888 l __-_-__---__a

PANEL NO. 4 - CROSS ~4763 ? MA l ' -1

As>Mr. Colburn indicated, that'is somewhat less than 2.

hisLexperience has.iridicated. Therefore, we over-estimated:the 3- -number of staffing that would be needed to act as registrars.. l 4. JUDGE SMITH: The missing link, however, is how -- ) 1 5; what is the-relationship of'the size of the registration unit i 6; to the-work required to. register it. I mean, when it all bolls l '7 down to' it, you are registering people,~ aren' t you, not units? ) 8 THE WITNESS: (Colburn) I' ll try to answer this. I 9 As far as the registration is concerned, we'have -. l '10 understand, we have a very simple. registration form. .And as -] 11. -people come through, we may' register. If it's a single person 12 alone, we register them. If it's a family - group, we register I 13 them and so forth. L 14: .All this figure is to us is simply an average that we 15 use to try'to figure out how many of these forms we' re going to 16, have to fi11 out. 17 JUDGE SMITH: That's all that means? 18 THE WITNESS: (Colburn) That's all that means, yes. 19 JUDGE. SMITH: That's not what it says. 20 BY MR. BACKUS: 21 Q Well, Mr. Colburn, you' re saying that's all that 22 means. If 1 look at page 9 of the testimony that's been 23 entered for this panel, I see a formula that indicates to me 24 that you are determining whether or not you have got adequate 25 staff to man these four principal decontamination reception I Heritage Reporting Corporation (202) 628-4888 l

PANEL NO. 4 - CROSS 4761 c., 1 (./ I centers on the basis of these~ registration units;; isn' t that 2' true?' 3 A' .(Colburn) Yes, it is true, and I'm not' denying that.. 4 I'm just saying. that this -- this is the -- we have to-l '5 determine what the average number of people may be that we'have 6 to enter on this. form.- And it can range-from one to eight or 7 10, presumably.- But we have to use.an average in terms of .) s 8 trying to arrive at an estimate of how many people we need, or 9 how many of these units, how many of these forms we may have.to -l 1 10 complete. l 4 11 And therefore,. knowing that, then we can go frpm 12 there to determine how many registrars we will need, because we J 13 use a time' estimate in terms of how~1ong it will take them to O 14 fill out one of these forms. 15 JUDGE SMITH: It will take longer for a single --~it 16 will be somewhat faster for you to hand out a registration - form 17 to one person arriving in a car, having her fill it'out'and 18 return it, than it would say for five people arriving in a car, 49 but not five times as long. o l 20 THE WITNESS: (Colburn) I would just clarify that to f 21 say that we are not going to have the people fill these out. l { 22 We are going to fill them out. I 23 JUDGE SMITH: Al1 right. With that clarification, 1 24 would that be about right? l 25 THE WITNESS: (Colburn) Yes. ) i o ( Heritage Reporting Corporation (202) 628-4888 i

i a (. PANEL NO. 4 - CROSS .476E -c l 7~1 l b..) 1 JUDGE SMITH: And so what you have done-by'the l l l 2 registration' unit is you have sort of averaged out the time. 3 THE WITNESS: (Colburn) That's right, yes. 4 JUDGE SMITH: And it's a little bit like, counting-5 cows by counting their legs and dividing by four, then. 3 6 multiplying and getting back to get the: legs again, you know. 7 And;as Judge Harbour points out, if all you can'see is the 8 legs, there's nothing wrong with 'that. 9 All right, I' m ' sorry, I did interrupt, however, the 10 point that was being made in that the people without 11' transportation-has some.effect upon the registration units is 12 your point. 13 But I think that you had a non sequitur.in your 14 question. I think that you made an assumption that there were ~ 15 X number of persons without transportation, and that number had 16 not been established in the context of your question, as I .I 17 recall. 18. MR. BACKUS: I did not offer a number on that. I was 19 simply referring to the anticipation that Mr. Callendrello 20 makes as part of another panel that there will be ride sharing, 21 and I believe he said something about 50 percent, but he may f 22 want to -- 23 JUDGE SMITH: Fifty percent. 24 MR. BACKUS: He may want to explain that. That 's r,ot 25 a number that was in the testimony I recall. Heritage Reporting Corporation (202) 628-4888 1 i I

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[1-f l' q, pil b4 PANEL NO., 4 - CROSS <4762 1 . JUDGE SMITH: Well, that,would be the,banis for g A '2 overruling the objection now to invite the explanation of what- [- ] 3 ef fect. persons without transportation ceuld have ' upon the '4 average number of people in your registration units. 5 THE WITNESS. (Callendrello) I would anticipate that 6 that effect would be fairly small if recalling the results of . i 7 these KLD surveys developed to support the evacuation time 8 estimate. They identified about 4500 individuals in New '9 Hampshire who indicated they needed transportation assistance. ) 10 If you assume that 50 percent'of those' people will 11 ride share, which is what Mr. Lieberman assumed, then you wind ) 1 12 up with about 2500. If you assume that 20 percent of those 13 then show up at the reception center, you' re talking about 500 A~ ~ 14 individuals spread -- and if you assume they are spread among 15 the four recept ion centers, you' re talking about 125 16 individuals who even if they are single units doesn' t appear to I k 17 add very much to the registration load. 4 18 BY MR. BACKUS; 19 Q Well, Mr. CAllendrello, i f, for example all that adds 20 up instead of one registration unit.per car it works out to 1.1 21 registration unit per car, then you are going to need 10 I 22 percent more staf f to process all the expected registration j l 23 units in the 12-hour period, aren't you? 24 A (Callendrello) Only for the Manchester facility, and 25 it looks like possibly the Dover facility. The Salem and ILO l I Heritage Reporting Corporation (202)628-4888 l l l J

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2_ capacity, and.there would beino effect on that,,1ct af fing.- [ :-liy 3' Q .All"right,'but you did. agree that for the purposes of ~' ' d., .4 the staffing all these facilitles-you were using the figures

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,3 for Manchester; is thathcorrect?,: 2 L 5 + E. A, (Callendrellot That's-right. That provided a O5 <;7 1consa rvat 3 ve est htate of.';he staffing required. O' O-Lana y\\ou did' agree, I think, that Q the registration L j i 9(< units were~notil.%, but 1., 1, at least for Manchester, t hat ' i;4 a-j l

10. ! 1Qcpercent increase: in M affing requirement ; is trid./ correr7t? '

.ik ' A= (Callendrello? That would be trum I'w not saying y. 12 e that it. is L,1.- .Itu.saying that the Lwe're assuming'.one" 13. registration and 2.6 pew.ons por registration unit., j 1 i [d'#' L 1 _v a 14 l 0 Okay. And - d'o kyou.- well, it is'true then in coming g 15 upLwith the 2.6 occupants por vehicle makinD one registration 1 N. 4 3 les unit you were mt taking Anto account the ride. sharing .i. .e 1 . 17 phenomenon, isn* t.<that true? j - 18 .4 (Callendrello) I don' t know i-f that. number i'ncludes i i 19 the ride sharing phenomenon. As In indicated, that number was 1 20 caicQlated in the evacuation time surtimate. Exactly what went i 21 int o that number, I am not certain, i do not know if it ) 22 incit. den ride sharing or nob 23 JUDGE SMfTH: It seems to me this whole exorcise 24 here, the numbers that ycu are taking about can get lost very 25; easily i'n the variables. I mean, these do not -seem to be

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G i* 3 p 3 c o t ' / s i ,syt, i 4 . ;1L a - 1 _,: 1 j / t / v \\'t_ j \\ / I s 1 r .t N hANEL NO. 4.(,/6RO';)$ g 4765 ( i /, .f we' re tall 5 ng ' A}nout, ,q 4 y V' i significant ' nuraders that t the' ride sharers + 'n l .t ) (, \\ 's 2 and even the dif ferences that y ou w t/,71 l.petween the family ,.V f gi [ s 3 group from your experiephe and Health &,luman Resources and tho, [{! el 4 4 ride,nharers. No Q$ter how you.\\ook: at 'it, arv th/ej pally ' f' / ( [ 9 r'. \\, .t numb'rt// / 5 significant g e 4 J/ ) L. t hey get( -- wo'. ' br.( t 'a y get ' lost in 6. I mean, can' t ( 4 r J7 other assumptions? f'! ' \\ {f 8 MR. BilvlOL) 7, cer% inly \\ agree with,qt 'lat, x/our Honor. w s y .9 It seems to me that if you recall back to the 'i anel we had (l ,y .) o '3' \\ M, " '/ previously}%stYied, I thinkjthere was some 10 where Dr. Wallace f \\ / 11

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) .? j 12,- reception centers /decontamina', don cente ts f red' his department. ,/ .A 4 13 4 - These art # people to come / rom hjs departfkenii d I knderstand 4 \\ 1 s. 3. N (_) a {e,' 34 g g '} \\ f,q }. r 15 ' JUDGE SMITH: 1 unde stand the evcern.. ut at I -- ) s' ? -> h i q \\ I i 6 54 16 MR. BACKUS: ' 'And ~ 1 ' t hink chang ing t' 4--) c h a n g i n g *l/..t spi i a .i i [ 17 assumptir:nx2')out trh number of occupants per ry,' cle, faila' ] s

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befofv,rp have pptten $hrough, ell of the testimony on ' 20 record 97 41 21 this whether these numbers are rpi.1 or they are not. ,N I'sg he grr'/ Mr. k Callendrellt,(oNer an op nion / 22 Now ( t .o, (; 23 about that, but I certa hly don' t think that' e cargassume that l t 24 that's correct. And.5'<think that all I can io at this time is I g re,drh (' M i s th'y have used. I 25 take the assumptions that i rA e i,c 9 l Heritage Nep ting, Corporation l q UM) 6284889 / t '/ i l /, i

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m 1 1 i f ', - I 1 i y4 4l PANEL NO. 4 -l CROSS 476E 1 mi ~,'I ' ' 1 their methodology to det' ermine staff resources and explore:it. W ;p g/9 f4 ~ s 2L I can' t be' asked.to agree with the. Chair as to the correctness j 3 l g .of.the significance of the' varying assumptions. l 4; JUDGE SMITH: I am not asking you to. agree, and-I S i also recognize that:if'there11s a problem as I have perceived l 6 it,.they have invited the criticism by their very fine numbers 1 0 17' that they have used themselves, very' fine numbers. 4 l>~ .c h '81 . M R. BISBEE: May I interject a comment here,LYour j y 9 Honor, just a very brief one? 4 10. There has been mention of these numbers applying to w ,t .6+ fQy(p, .f, 11' reception centers as well as decontamination centers. I think 12 the' testimony which uses the 2.6 assumptionLfor registration .f i ( n l 3 13-units is applicable only to the reception center process, and y3 -- I'(j/ l i l L14 - the.numberLof units to be processed, and the numbers of Ys i' L t J/ 5 i h/- 15 registrars needed to register that number. It does not pertain '6[ 16 to decontamination. l t 17-JUDGE SMITH: Well,'is the significance there that [ 'f ja the number of automobiles is not important? It's the number of ~19 people. 3 'a9 MR. BISBEE: I don' t mean to say that automobiles are l' J! 21 not important to decontamination, but the 2.6 assumption does ),, ild i 24 not apply directly to the decontamination process. It is the s._;, [ [2 23 number of individuals. There is a question also of number of dl N 24 automobiles, but that's separate. T EndTe.' 25 (Continued on next page.) . ' f, t Heritage Reporting Corporation (.i. i (202) 628-4888 { l b_ _ _ _

t l I PANEL NO. 4 - CROSS 4767 1 JUDGE SMITH: You may proceed. 2 MR. BACKUS: All right. 3 BY MR. BACKUS: 4 G Now, at page 4 of the testimony you adopt an 5 estimated planning figure of 20 percent of the estimated 6 population to be evacuated is going to show up at the reception 7 and decontamination centers; is that correct? j 8 A (Callendrello) That's correct. 9 Page 4 says, "This guidance suggests the use of 20 10 percent of the total evacuees as planning basis for estimating 11 the number of persons arriving at reception centers." 12 Q And I take it that that 20 percent is based upon what 1 (~N 13 has been marked as Attached 1 to this testimony, which is a i \\-] 14 FEMA memorandum, the date on which is illegible here, but 15 December 24, from Mr. Richard Krimm; is that correct? j i 16 A (Callendrello) That's correct. l 1 17 G And the reference in question would be on page 2 of f ( l 18 that attachment under " Guidance" which states, "For highly j 19 improbable radiological releases involving high levels of I 20 radiation encompassing a relatively large area, it may be l 21 necessary to monitor a greater number of evacuees" -- I' m j 22

sorry, I' m sorry, strike that out.

I got the wrong thing. I 23 It's crossed out here. It's number one I wanted to read. I I 24 "The state and local radiological emergency ( 25 preparedness plan should include provisions at relocation () %) l l Heritage Reporting Corporation 1 (202) 628-4888 l l 1

c. ( ,; } ~ -e PANEL NO. 4 - CROSS 4760 .? h I'l_J 1 centers in.the form of drained personnel and equipment.to 1 8 : 2; monitor a minimum of 20 percent of the estimated population to j 3-be evacuated." 4 Is that correct? 5 A -(Callendrello) That's correct. 6 Q Now the reference there is to a minimum of 20 7 percent, and yet.the New Hampshire appears to use that' figure 8 without ever. allowing.for some greater number. 9 Was there some reason -- well,'was there some reason 10-why a more conservative number than 20 percent was not'used? ) 11-Perhaps'I could ask Dr. Wallace that question, i 12 A (Callendrello) Maybe if I can just take one cut at .(' 13 the answer'first. j 'sm 1 14 The guidance memo was used as it was written. The 15-minimum of 20 percent was used as a planning basis. If you 16 read further i the testimony, the process for determining the 17 evacuee load at each reception center was done by calculating,- 18 in fact, it's on page 5, determining the peak population, l 19 subtracting out the special facility population, subtracting 20 out the transient-dependent population, multiplying that by 20 l 21 percent, and then adding back in the transient-dependent l l 22 population, because they would be arriving at the reception L L 23 centers. l 24 Those numbers vary for a reception center. The 25 larDest number of evacuee would be arriving at the Manchester ~7 /%J l Heritage Reporting Corporation (202) 628-4888 C

i i i ' (~'\\- ?ANEL NO. 4 - CROSS 4765 V 1' reception center. Therefore, that number was used as the -4 2 planninD basis to determining the staffinU and~ equipment needs 3 for all four of the reception centers. 4 While that equates to 20 percent for the Manchester 5 reception center, it equates to some larger percentages for the 6 other reception centers. And in fact, the percentages worked' a ~7 out to about 25 percent of the total evacuee population can be. 8 monitored. So the intent of that guidance memo was followed. 9 The planning basis was a minimum of 20 percent. In actuality, i 10 that worked out to.somewhat more, and it's about 25 percent.. 11 -Q I would like to get an' answer to that.from Dr. 12

Wallace, I understand your claim that it's conservatism for r~g 13 the non-Mancherster reception centers, Mr. Callendrello.

V 14 A (Wallace) What was your question again on that? 15 Q The testimony says that you ere assuming that 20 16 percent of the evacuees will be going to the reception centers, 17 and for that 20 percent refers to Attachment 1, which is the 18 FEMA memorandum for Mr. Krimm, which refers to using a minimum 19 20 percent figure. a l 20 And I guess I' m asking you, Dr. Wallace, as the 21 professional in charge of the Division of Public Health. 22 Services, are you comfortable with going with a 20 percent 23 figure and not a more conservative figure, a higher figure? 24 A (Wallace) I think as Mr. Callendrello was 25 indicating, we actually have -- on the basis of the ) I u l Heeitage ReportinD Corporation l (202) 628-4888 4 I

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.c-i p E PANEL NO. 4 - CROSS 4770 - -1 ,y l; ,"[' '1' calculation, we actually have a higher percentage of evacuees I b 2 that are being taken care of in these centers. 3 'In addition, where. we' re basing our calculations on - j m 4 4 the peak summer population,-and in fact in wintertimes-you 5 would handling 50 percent or evenLureater of the population. l 6' 'O Isn' t it true,.Dr. Wallace, that in regard to the 7-Manchester, reception center'where you.have expected that -- 8' where you have the most communities I guess assigned, or the b t 9 most' people assigned, including Hampton Beach, you don' t have l 1 f 10 that; conservatism. 1 11 A (Wallace) Let me confer just a moment, please. 12 O Sure. Y'N .13 JUDGE SMITH: As'I understand your. question, it's an ) 'd 14 arithmetical question and not a -- I mean, it's a mathematical 1 15' question, i sn' t it? 16 MR. BACKUS: If I' ve got everything correct'in my l l 17 assumption, which I would like him to confirm, that's true. I 18 (Witnesses confer. ) 19 THE WITNESS: (W.al l ace) I guess the additional load, l 20 possible load could be handled by opening the secondary center j 21 as well which is an additional number of peoples that could be i 1 22 handled. So I think we have an adequate, an adequate number. ) i J 23 BY MR. BACKUS: 24 O So you are referring to the secondary centers as j l 25 providing a degree of conservatism here; is that what you are i p. d Heritage Reporting Corporation ] (202) 628-4888 i l

n-lK' L i s l. PANEL NO. 4 - CROSS 4771 f. L 1 saying? I [< 2 A (Wallace) Yes, that adds-an additional load that can 3 be' handled. l' 4 O The. secondary center in Manchester as I understand 5 it, Dr.'Wallace, is to be Hillside Junior High' School which is 6 also to. act as.the -- if this is the correct word --~ primary 7 center for the local emergency workers that will be goinD'to-a. j B decontamination center; is that right? 1 9 A. (Wallace). That's correct. f 10 MR. BISDEE: -Your Honor, at this interlude could I 11 ask if counsel could refer specifically to whether he's' 12 questioning on reception centers or decontamination centers? I I 13 think there may be some confusion here in the record as to 14 which one is being responded to or referred to. I 15 MR. DACKUS: I understand they are both to be 16 colocated in the same facilities, j l 17 THE WITNESS: (Bonds) The primary reception center, I 18 or the primary decontamination center and the reception center i 19 in the host community are colocated. j 1 20 The secondary decontamination center does not carry ) 21 with it a separate registration reception area. There is still 22 just one registration area per host community. l 23 BY MR. BACKUS: 24 O So there is no secondary reception center. There is I 25 only a secondary decontamination center; is that right, Mr. O Heritage Reporting Corporation (202) G28-4888

s, ' s l. t e' PANEL NO. 4 . CROSS. '477E 19, Bonds? .1 ' - 1-2 'A' (Bonds). That's correct. 3 0 ~All right. In any' event, I take it on page 4 that 4 after you used this 20 percent figure from the FEMA memorandum 5-as-you'have outlined, you then go,to determine the po'pulations 6 of.the communities involved, and there.in a reference on page 4 '7 to the peak population estimates are Rye,.Hampton,. North f i 8 Hampton, Hampton. Beach and Seabrook.' ,j 9 1.take it as it states there that this peak 10 population is based on information contained in Volume.6 which-i 11 is the evacuation time estimate; ~is that correct,'Mr. l (: 12 Callendrello?

13-A (Callendrello)

That. is one piece of it, and the l h-14 analysis of tho' aerial photographs taken on July 18,'1987. ) -15 Q Do you know whether or not those estimates of i 16 population exceed those to be-found in Tables 1 of the local 17. community plans, Volume 16 thvough 327- ) 18 A (Callendrello) I believe for all the communities l 19 they.do exceed them for the summer weekend condition. There 1 20 are three columns of numbers there. One is resident, one: is 21 summer weekend, the other is summer weekday. So my answer l 22 addresses only the summer weekend. ) l 23 Q Okay, on page 6 there is a discussion of the use of I 24 Hillside Junior High School in Manchester for decontamination 4 l l 25 of the emergency workers. I take it this is local emergency O l Heritage Reporting Corporation J l (202) 628-4888 l eE M ___

77, i ,4 PANEL'NO. 4 - CROSS 4772 .i k) 1 workers estimated to 1300. t 2 How was that figure arrived at? 3 A: '(Callendrello) It's not -- the question is not 4 correct. That's not only local workers. It's state and local' S workers. 6 .The number was arrived'at by examining the 7 information contained in the personnel resources assessment, 8 and totalinD all those numbers, and that comes -- for local, as 9 well.as state,..as well as transportation providers, and that 3 1O' number is roughly 1300. 1.1 - Q Okay, so that's based on the personnel resource 12 summary,-plus the needs of local workers, all combined (^T 13 together; is that.right? -%) 14 A (Callendrello) The local workers were treated by the i 15 Yesource assessment summary. 16 0 Okay. And at what dose levels are these workers 17 ' supposed to report, or to be advised to report? 18' A (Callendrello) I' ll let Mr. Bonds handle that 19 question. - 20 A (Bonds) There is within the plan in Volume 1 21 indications of how a radiological screening program is set up 22-for emergency workers. i 23 Local emergency workers are removed from the EPZ at, 24 I believe i t ' s t h e 5-R level. We would anticipate though that { f 25 'if the community has been evacuated that these individuals are { f L ([) i l' i Heritage Reporting Corporation l (202) 628-4888 l L J

g 4r 1 d e { t ~ ' PANEL.NO.'4 - CROSS 4770 c .f 1 going.to come out there at doses considerably less than that. 2 They' re.not going to wait 'till they hit 5-R. Thuy are going 3 to come out when the community comes out. For state. emergency 4. workers it could be at a level higher than 5-R. l s '5 O In fact, i f' ' I recall the' plan, it couldLbe at 20-R;- 6 is'that right? .7 A (Bonds) That could be; yes, sir. I B Q And then I think Dr. Wallace has authority under the l 9 plan, 'if I' m not mistaken, to allow certain workers to receive 10 levels in excess of that. 11 A (Bonds) To'25-R,.yes. I 12 O Now you indicated, Mr. Bonds, that the reception work 13 was to be,done at the four primary reception centers. Is there '] 14 going to be ' then no reception work done at the Hillside Junior 4 15 High School for emergency workers? 16 A (Bonds) The reception work that's done that Mr. l I 17. Colburn and his units does is primarily for the general ] l{ 18 population. The Hillside Junior High School activity for 19 emergency workers doesn' t have a reception or registrat ion 20-function with it; no sir. But what it does do, and the ) i 21 rational behind doing it in the first place, was to collect 22 information on the emerDency workers, that they are in fact out 23 of the zone, to collect their dosimetry, to complete their 24 dosimetry logs, to capture any information that may ber there 25 with regard to any intake of potassium iodide. That { i. l Heritage Reporting Corporation (202) 628-4888 1 L_--__.

.3, .m j q I b PANEL NO. 4 - CROSS 4775 1-information is collected and maintained. j j; '2' At.some. point I would. imagine /that these' individuals l '3 are released bac'k into the general population once their i l '} 4 special. needs ara c taken' care ' of. i 1-5' (Pause.) l .E ' JUDGE'SMITHat Do you need some times-Mr.-Backus? 1' l I? m looking for. MR.'BACKUS: I think I' ve found what L 7 l 8 I was1 turning to.the issue of-vehicles discussed.on paDe 17 and: L 9 18 of the testimony. l 10 .BY~MR.'BACKUS: 11 G- 'And.I was trying to get a-figure for'the' total number h a la of vehicles that are expected in a 12-hour period:that may need l i L 13 decontamination at these facilities.. p 14 Can you tell me that? j o 15 A (Callendrello) to the testimony has a l-i 1 '16 column labeled " Vehicle planning basis" which indicates the t-l ? i ' 17' number in parenthesis which is the' actual number.of vehicles L L. t 18 that are expected to arrive. The assumed planning basis is l d 19 directly above that. And then two columns over is the actual ] i i 20 -vehicle monitoring capacity in a 12-hour period. I 21 You can see in all cases the vehicle planning basis 'j 22 is higher than the actual number of vehicles that should l 23 arrive, and the vehicle monitoring capacity is more than twice 1 24 as much as the vehicle planning basis. So we have greater than 25 twice the capacity versus the actual expected need. O Heritage Reporting Corporation (202) 628-4888 l

c q \\ i s' c -i' ~ 1 PANEL NO. 4 - CROSS 4?7E 1 1. O 'Han there'been any survey done to determine the l <- - ^ a 2 availability of parking.for this number of vehicles at'these I I I' 3 facilities? 1 4 A (Bonds) ~ Yes, sir, there has. 5 lUsing the high schools per se, which are not great on li a' lot of parking,:there is a limited spacc available. But ,l t p 7 there'is sufficient space in surrounding areas using, for 8 example, in Rochester there is a small mall across'the street. 9 In good weather there are playing field, other areas that,are 10 available, but we are comfortable that &ne could accommodate the. 11 3,000 and some vehicles that would arrive at the primary 12-centers. J 13 O Mr. Colburn, we were furnished some time ago at the -t L 14 start of these hearings with what appeared to be a survey form 15 of some sort that had been done for the_ emergency services 16 unit. 17 Are you familiar with that? 18 A (Colburn) Yes, I believe I know the one you are 19 referring to. 20 Q I have a memorandum dated February 6th from William 21 N. Colburn, Coordinator, Emergency Services, to all staff. ( 22 Are you familiar with that? l 23 A (Colburn) If you read a bit of it, I can respond to l 24 that. ( 25 0 Well, perhaps it would be best just to furnish it to l-l Heritage Reporting Corporation (202) 628-4888 1 l l I-t

. \\c .,t. PANEL NO. 4 - CROSS '.4777 , p). /s 1 you. 2 JUDGE SMITH: While you are doing that, let's take a '3 five-minute break. EndT9 4 (Continued on next paue.)' 5 6 7 8 9 'j 1O l 11 l t l 12 3 l 1 A. 13 3 ,V - { 14 i l l 15 16 17 18 19 i ao -l ] ' 21 22 l i 23 l 24 l 1 25 1 I J. A-l,_ Heritage Reporting Corporation { (202) 620-4888 l 1 l 1

r 4 477E f 10-BMAR 1 BY MR. BACKUS: s 2 G Mr. Colburn, I have been asking you about your role i 3 in the questionnaire, and survey, but let me back up for a 1 4 minute. 5 You describe your title, in your resume, which was 6 marked here earlier, as coordinator of emergency services, for 7 New Hampshire Division of Human Services, Department of Health ) 8 and Human Services. 9 And what is the task of the coordinator of emergency j k 10 services, generally? { 1 11 A (Colburn) The functions that I am involved with in l la that capacity has to do with the role that the Department has (~; 13 in actually five different emergency response plans. It f V ] l 14 requires actually developing the plans for our role in theue 15 various programs, and preparing a core Droup of people to i 16 recpond to these needs, whenever they may arise. 17 Very briefly, in a nutshell, I guess that is what it { l .18 is. I l 19 Q Well, what are the emergencies that the emergency 20 services unit would normally be created for? 21 A (Colburn) Okay, the plans in which we have a part, i 22 are the first one that we ever became involved with is the ] 1 23 individual family grant program, which is a program, as the j 24 name implies, of providing grants to people who may be victims l l \\ ( 25 of various types of disasters; where there is a Presidential l i f 1 G l l .ieritage Reporting Corporation i (202) 628-4888 l l I L____ l

l l L i h 1 PANEL NO. 4 - CROSS 4779 y- ! i ' 1_1 i .1' declaration of disaster, such as we had this past sprang.- { l 2 That was actually the original impetus of this whole I 3 program, several years ago. !.l 4 Subsequent to that, we have had the addition of i 5 the -- of course the radiological emergency response plan, l l 6 first for Vermont Yankee and.tvow for Seabrook, t 7 We also have a role to play in emergency l l 8 repatriation. And we play a role in terms of relocating 4 .l 9 families in' instances of EPA cleanups in the State, of.which we 10 have had several. 11. And we have a plan for emergency food stamp 12 ' provisions which usually goes along particularly with the 7~N 13 individual and family grant pr ogram. So that these are five k 14 plans of which we play a part, and my job is to try to make 15 sure that we are ready to play that part. 16 Q Okay, now, the emergency se rvices unit, in the 17 division, is that a voluntary organization? 18 'A (Colburn) Yes, it is. 19 Q So that all of the people that are members of the 20 emergency services unit have other line responsibilities within '21 the agency and then they volunteer to do these emergency tasks, 22 is that ri Dht? 23 A (Colburn) That is correct, this is additional 24 responsibility. 25 Q Okay. Heritage Reporting Corporation (202) 628-4888 b

4 l r 1 i l PANEL NO. 4 - CROSS 478C j ~ (2) .1 . Now, your memorandum of February 6th, that I was l I. 2 getting to just before the break, indicates that you needed 1 3 assistance in determining the reason why more staff are j 4 volunteering Lto part icipate in emergency service units, is that 1 I 5 right?' l 6 A (Colburn) The purpose of the survey was simply to 1 7 try and determine why more people were not volunteering for 8 these particular units. 9 Q Do.I take it, that as of the time that you sent out 10 this memorandum that your staffing rosters for these volunteers 11 were low? 12 A (Colburn) It is not that they were low, it is just 13 as people come and go, it was a little more difficult to obtain 14 replacements, or find replacements, although we did, in fact, 15 maintain our numbers, and there were some units in some of the 16 district offices, that I would have preferred to have a larger 17 unit, than, in fact, was present. 18 O Now, the memorandum makes reference to the fact that 19 you were sending out to all taff, a survey questionnaire, is 20 that correct? 21 A (Colburn) The questionnaire was made available to 22 all staff, who are part of three divisions -- the Division of 23 Human Services, the Division of Children and Youth Services, 24 and the Division of Elderly and Adult Services. L 25 It did not include all staff in the Department. l l l Heritage Reporting Corporation l (202) 628-4888 1 l

6 e i PANEL NO. 4 - CROSS 4781 u_--.). 1 l 1 Q Okay.. j I 2 How'many. people would.that be, in those three j 3 divisions?' 4 A (Colburn) Well, at the time that it was sent out, it s 5 was sent out utilizing a number of 645 and this-was just j i 6' district offices. It was not distributed in the state offices.~ 7 '(Witness is proffered document.) 8. Q We have placed in front of you, and have also served 9 to the Board and the parties, a copy of the February 6th 10. memorandum that[I have been talking about, to which is.also 11 attached, another memorandum dated January 20th, and a two page 12 emergency services questionnaire. 13 Is that emergency questionnaire that is attached, the ~ 14 one that is referred to in your memorandum of February 6th?- y.. 15 A -(Colburn) Yes, it is. 16 Q And did you, in fact, get responses to that 17 questionnaire and tally them? 18 A (Colburn) Yes, I did. 19 Q And let me now furnish to you a document, which we 20 were also provided, it 'looks like a computer printout, and . 21 saying survey WK-1-on the upper left-hand part of the page. 22 (Witness is proffered document and examines it.) i 23 BY MR. BACKUS: 24 Q Now, Mr. Colburn, is that computer printout a tally 25 of the responses that you obtained to this questionnaire? f( ) Heritage Reporting Corporation (202) 628-4888 y L

1 PANEL NO. 4 - CROSS 4782 &g - ' l 1 A-(Colburn) It is a tally.of. some of' the. responses, 2' not all of them. 3 G And is there a:more complete tally that'would.tell us l 4 what personnel.you have in these emerDency scervices unit, or 5 have agreed.to perform? 6- .A (Colburn) Maybe I should clarify that what.I meant 7 to say is that it ~ is a tally of some of the:., questions that were 8-asked and the responses to those questions. ) 9 It is not a. tally, obviously, of every question that { 10' was asked. I 11 D-Okay. d I 12 Now, over on the left-hand column on this sheet,Lif I 1 13-am correct in interpreting this, is a column saying, how many d 14-people are members or not members of the emergency services 15 units, is that correct? j ] 16 A -(Colburn) In the left-hand column? l 17 Q I am sorry, the right-hand column. ~ l 18 A (Colburn) Yes, on the far right, it identifies of , ] 19 the respondents, 'how many were members, were currently members ] dO of the unit, as opposed to those who were not. 21 Q And is it correct, that as of the time that'the { l i 22 survey was returned, that 33 of the employees were members and l l 23 119 were not? 24 A (Colburn) Of the respondents to the questionnaire, j, 25 33 of the respondents, at that time, indicated that they were l. l I l 1 Heritage Reporting Corporation h (202) 628-4888 l l

i a s .g. PANEL NO. 4 - CROSS '4780 ~ ' 1 members. 2' Q-Okay. .3 And then there is another column that says, should 4 train /not: train, what does that mean? 5 A (Colburn) T h a+- is in response to the question'on the 6 survey which is on page 2, where the statement was'made, I 7 'believe~that the Department etc., should: train staff.for the 8 tasks that they are assigned to ful#ill during. declared 9 emergencies, and disasters, yes, or no. 10 0 And'then the next column, moving to the right, is 4 11-willing/not willing. 12 I take it'that that is willing or not willing to 13 volunteer for the emergency service units? 14 A (Colburn) Again, that is'in response'to a statement-15 on page 1, which ways, I am willing to volunteer my services to ] 16 assist victims of any disasters, yes, or no. 17 Q Referring to page'1 of the emerpancy services 18 questionnaire, you did offer your the people being surveyed, 19 the choice of responding to particular types of disastues? 20 A (Colburn) As f ar - which statement are you l 21 referring to there, because there are a couple that you might f 22 be referring to, I am not sure?- I 23 Are you talking to the very outset? { 24 0 Yes, I am. f . 25 A (Colburn) That list of disasters? U-l l l Heritage Reporting Corporation (202) 628 4888 ia--.

e 'i i i I l PANEL NO. 4 - CROSS 4784 l /3 J (m/ 1 1 Q Yes, sir. .l I 2 sA (Colburn) Yes, that isfri ht. D l 3 Q1 And down below that, there is a question, I.am. A willing to volunteer my nervices to assist victims of any 5 disasters? 6 A (Colburn) Yes. 7 Q And is thatstallied on this> computer printout sheet, '8 somewhere? 9 A (Colburn) 'Yes, as a. matter of fact, the willinD/not. 10 willing is in response to that ' question. If I indicated 11 otherwise, I stand corrected. That is the quest' ion to which 12 that tally responds. 13-Q And what is the figure? O> / 14 A (Colburn) The figure on the respondents, the actual' 15 number was 97, and percentagewise, it was 57.2% of the 16 respondents, which indicated that they were willing to do'so. 17 Q And in terms of raw numbers, what is the fiDure? 18 A (Colourn) In terms of raw numbers, if I can read 19. this correctly, I believe that'it is 97. It looks like 97 20 here. 21 Q I think that it may be 87. ~22 A (Colburn) Well, could be the figure is not that 23 clear here. 24 Q Now, you also prepared I take it, or had prepared a 25 pie chart, showing reasons for not participating in emergency l () l Heritage Reporting Corporation l (202)-628-4888 l l m___________.____________i

1 5 PANEL.NO. 4 - CROSS 4780 1 service units based on the response to these questionnaires is 2 that correct?. 3 A (Colburn) That is correct. 4 0 And that pie chart showed one piece of the pie being l ~ 5 removed, labeled Seabrook 28.1%, is that correct? 6 A. -(Colburn) That is correct. 7 G And does that mean that people were not choosing to. 8 participate in an emergency' response to an accident at 9 Seabrook? 10 A (Colburn) These were respondents who indicated that 11 they would not respond to -- sometimes they specified-Seabrook 12-and sometimes theylspecified nuclear, but I interpreted these u 13 ,all to be respondents $ n terms of Seabrook, o 14 Q Okay.. 15 And in your questionnaire, you did start off by 16 noting that there were a large variety of natural and manmade 17 disasters, to which persons could be required to respond -- 18 hurricanes, tornadoes, earthquakes, and so forth. 19 Am I correct that the largest number of persons 20 indicating that they chose not to respond because of the type 21 of disaster, would list Seabrook as the reason? ] 22 A (Colburn) No. 23 Actually, if I understand youe question correctly, if 24 you look at the pie chart, the largest number of people -- i 25 well, the largest number of people not wishing to participate l L Q~, l Heritage Reperting Corporation (202) 628-4880 L i I L__11_ I

q { PANEL NO. 4 - CROSS 478E { 1 in the ESUSs, said that it was because of the~1ack of-1 I 2 information about the program. D 3 Q. Yes, but was there any other type of disaster.that 4 people specified that they would not choose.to respond,,other I 5 than a radiological disaster? j 1 6 A (Colburn) There were a few - toxic chemical spills, 't 7 and in some cases, of course, in a few cases, they included-1 l 8 accidents at Pease' Air Force Base, and Portumouth Navy Yard. ~j 9 O' In fact, I take it, Mr. Colburn, that the only actual ] 10' type of emergency that you specifically directed a question to, I it where you got a significant negative response, was-a. 12 radiological emergency, is that a fair statement? 13 MR. BISBEE: Objection, Your Honor. 14 Are we referring-to the pie chart? 15 I f so, I think that the pie chart relates to why 16 people are not participating in the emergency services unit. 1 17 There is a difference from that question and the question, 18 generally about responding to emergencies. 19 It is unclear to me, which question the question that 20 Mr. Backus has just posed, refers to. 4 21 MR. BACKUS: Well, actually, Mr. Bisbee, I was 22 referring not to the pie chart, but to the questionnaire -23 compilation, dated as of March 6, 1987, where there is a ] 24 heading, reasons for not volunteering to serve in ESU's, and as l 25 I read it, there are non-Seabrook reasons and Seabrcok reasons, i l ,C, ) Heritage Reporting Corporation (- (202) 628-4888

l ls. E PANEL NO. 4 - CROSS. 4787 gm

t. a 1

but no.other disaster related reasons, such as hurricanes, or a tornadoes,.or fires or floods. L ^ .3 MR.. BISBEE: No, but just to clear -- l 4-MR. DACHUS: I was just.asking the witness if-I am 5 ' understanding this cor'rectly? 6 THE WITNESS (Colburn): I'am sorry, when'you spoke of 7 compilations,.I.was looking at the printouts, and apparently 8 you are looking at this other compilation here. g 9 So I don't think that we'are looking at the same 10 documents. 11 Okay, if you will give me the. question again, I will 12 try to respond.to it. f 'f^ ^. '13 BY MR. BACKUS: b:

{

14 0 I asked you, am I correct that the only reasons for { 15 not volunteering to serve in the emergency services unit, that f 16 were disaster related, was because of Seabrook? 17 A (Colburn) Well, what this compilation does is to try 18 to identify what the various reasons were for not volunteering ] 19 to serve the ESU'u, and Seabrook was, obviously, one of those 20 factors. i 21 O Okay. i 1 22 And if we turn again to the computer printout, marked 23 survey WK-1, and does this tell us anywhere how many people 24 were actually added to the emergency survices unit, as a result 25 of this questionnaire, and any fol' low-up? {0 1 Heritage Reporting Corporation l (202) 628-4888 4

i ) l 1 PANEL NO. 4 - CROSS 4780 ' i 3,, 1 A (Colburn). No, it does not, and was not intended to. ) 1 ) 2 O Okay. 3 Well, I take it that as of the time that this survey ] ) 4 result was compiled, there were some'33' employees in these i .q 5 three divisions that were members of these emergency services l 6 unit? ] 7 A (Colburn) N o,' that is not correct. l 8 O That is not correct. 9 A (Colburn) There were 90. 10 All that this says, is that of the respondents to the 11 survey 33 of those respondents were members. I wanted to know 12 that so that naturally I expected c.ertain types of responses { f A 13 from members that might well be different from non-members. u 14 But we had, at that time, approximately 90 people who-15 were in the units. 16 O What is the figure at the present time? 17 A (Colburn) Actually the figure at the present time, 18 is 95. 19 This is not including a variety of backup people for 20 at the -- my backup in the various programs and so on and so 21 on, but these are currently 95 people who are available for all j 22 programs, including radiological emergency response programs. 1 23 O Okay. I 24 Of those 95, do you know, Mr. Colburn, how many of t l 25 those indicated a desire not to participate in responding to a i j tlO l l Heritage Reporting Corporation (202) 628-488.8 1 t

}. l; I 1 l-L' ( PANEL NO. 4 - CROSS 4789 l ( 1 Seabrook emergency? k 2 A-(Colburn) None of them. 3. Q So all of those people who ended up being 4 28%-some-odd, said that they did not care to volunteer.for z. 5 emergency services work because of Seabrook, none of.them are ~ 6 in the' roster as being in those units today? / 7 .A (Colburn) That is right. I 8' I would make just one modification of that. I do,-in 9 addition to these people who have committed to all programs, I 10 have accepted recently people who specified certain programs. 11 But I have 95 people at the present time, who have t 12 committed to serve in all programs without exclusion. '{ p-13 G And have you made it known to those 95 people that l%d 14 that. service does include participation and perhaps, responding 15 to radiological emergencies, at Seabrock? 16 A (Colburn) Absolutely. 17 MR. BACKUS: I would like, at this time, to offer and 18 have: marked, if I could, these documents I have been using. 19 The first one would be the memorandum of February 20 6th, and the attached memorandum of January 20th, and the 21 two page questionnaire, which we have together. 22 (Pause.) 23 JUDGE SMITH: I don' t have my Exhibit Book here, do 24 you know what number you are on? 25 MR. BACKUS: Unfortunately I don' t either, but i Heritage Reporting Corporation f (202) 628-4888 4 I

PANEL NO. 4 - CROSS 479C .O 1 perhaps somebody else -- 2 MR. BISBEE: Your Honor, according to my list, this 3 would be SAPL Exhibit Number 3, but maybe if we could get two 4 or three others to confirm that? 5 MR. BACKUS: That is right, SAPL Exhibit Number 3. 6 JUDGE SMITH: That is Exhibit Number 3? 7 (Pause.) 8 JUDGE. SMITH: All right, SAPL Exhibit Number 3 is j 9 marked for identification. 10 (The document previously 11 referred to, was marked 12 for identification as 13 SAPL Exhibit Number 3.) 14 MR. LEWALD: We do not know what purpose this is 15 being offered for, and it does not appear, on the face of it, 16 at least, to offer anything probative, in relation to the 17 testimony that has been presented by the panel. 18 We have no objection to it being marked for 19 identification because it was obviously a document examined on 20 and the witnesses were questioned on it. 21 But as far as what a poll in the late winter and 22 early spring of 1986 showed, -- 23 JUDGE SMITH: That is 1987. 24 MR. LEWALD: -- 1987, we would submit has little 25 pertinency to any of the issues in the case. O Heritage Reporting Corporation (202) 628-4888

q l i i PANEL NO. 42-CROSS-4791 l 7-, 11 ~ 1 At least it does not go to add up and show a 4 4 '~ 2 deficiency in numbers of the personnel of the Division of Human 3 Services.'..It simply indicates some of the feelinus in some'of 4 the people who chose'not to join some of the services that were 5' being provided on a voluntary basis. 6 Where.does it go? It is just another-piece of paper, '7 and I don' t even know what you can even argue from it. And,it a 9 JUDGE SMITH: Mr. Backus? End'T10MD 10-(Cont inued on the next 'page. ) ' 11 12 771 ~ 13 {%A 14 15 16 17 18 19 20 21 22 23 24 25 i Heritage Reporting Corporation (202) 628-4888

f .F r- }6{/ '\\' 9 i s h: ( J { l' PANEL NC. 4 - CROSS / 479,2 ) i 1 1 1 1 MR. BACKUS: Well, I think it follows on the 1 i i s 2 testimony we had from the survey Mr Wallace took from the j s l s s 3 Department of Public Healthi?nevices, and I think it is { 4 4 probative. I don' t say it 's conclusive, and I think the Doard h 5 will give it -- choose what weight to give it, but I think it 6 is probative on the claim that we have not only numbers on a 3 7 roster, bucfpeople who are actually going to be willing.and 1 1 8 able to perform. l ? In fact, there was a survey conducted. More thanta 't 10 quarter of the respondents said that t h e'y.,d id' not l care to t s N, volunteer for emeA;gerey work because of Sea \\d r. ook. I thinN that f 11 f 'y i[ ) 12 that certainly is prouq.tive. 13 JUDGE SMITH: Wnat part of the direct testimonyjdoen 7"J .14 it pertain to 15 MR. B ACKLE : Well, it would pertaintoparticularpys s 16 the testimony on availability at page 9, and the personnel ib l 17 referenced on page 8 of the Applicants *s testimony, I suppose. t 18 JUDGE SKI 1H: Page-3 and 9, ar khat.other paja? \\ VI >J%re I see --

1. 6W t c a any claim except --

1; Sb MR. BACMUS:, Wait a minute, I addr.e t,o make sure -- l ' 21 the testimony has been' renumbered, I think,3 'h\\ the last -- I' m 22 not sure I' ve got the correct -- L i l 23 JUDGE SMITH: Yeah, I don',t see any claim eecept one l l 24 that might be inferred that -- V \\ l 25 MR. BACKUS: Yeah, page 8, it talks abobt the D U Heritage Reporting, Corporation (202) 528-4388 E l s. I

hAf y l ~t . b;]f l j U+ 4 'I u l p 'j tl s A 1 l ,. i - ,..c pS?4ELNO. 4 - CROSS

4792 p.f i

p Q ,i, t / i 1 emergency servire..,vr,3 44 "Eich center diil be seried by these 4*, j Y f \\ emergency servic'e ur[tta. ESUs, which are que,up of staff of s (, j 2 4 s

f. i s

s. 3 r .M DHHS, Divisions Human Servides, Children and youth Sd vices l i I t j and. Ef d erly and. Adult ServitTinc.^.These ') n ar t. ~ units will function ac29/ .l + i, s, 5 tra'inoi cadres of departtoent personnel}howi.1.1,,grovide" j i t-6 registration services as wd[Mj)s operational supervision to y .i. ,./ - y g s o f 7 volunteers in the provisiqriof evacuee registration, messages l 1 I / p j .,8 'enchanged and locating service," et cetera, et cetera. f s i t, t 9 f.( JUDGE'Sl%iNr And how doefj,hhis ex*11 pit; challenge y A , t.. r f A' ' 10 t h.t.t statement? ,4 ; .I .l \\ 11) MR. SACKUS: iWell,'7(t'hink it's some indication that f 5 4 12 +there'is a large degree of reluctance to serve 4A plaimed in 'y ~ < ' /k 4 ('T 13 this testimonyl O a( 14 JUDGE SMITH: Yes, but it d6esn't, add up. We don't /:.. ) Idonthseeanyclaimednumber<,. ands,tjjn' - lf 15 have any -- at least 1 ( .r 4~ 16 that number being chcIlengeJ by'the numbers in your AAPL i 4 { 3fer4ffdnbificMi'cA./ a 71t may be there. It's just that 17~ Exhibit ( 1 r 1 );, 9 1,.t-9 f AG I can' t - f dd ;[t/ ri yY j { 6. now. 4 a,- r ') 13 Mk lDACKUCT4 'Well. f >t 1-E s \\ < <20 JUDOi! SMITH: See, I still don' t thinh.that -- 1 1 i 21 think you hAe an :: pen' I ycsu have an open formde, here, and ! / 22 equation, and it's not'-- it doesn' t mean anytnj[ig) BACHfS: 11. i 23 MR, ,t ;

1. a

'24 JUDGE Sb'ITH: .s I underst ar>d it, you are asserting 25 that a certain percentage of' people in t h at : department say that R \\. i 'O ',i ,'i Heritage Re p,rting Corporation (2024 628-4888 66 d 1.

x k! + l l l l PANEL NO. 4 - CROSS 479L t p'^ 1 ~ .1 - they are not interested in helping. Therefore, the inference j l 2 is that they can' t do this staf fir g. But I don' t see the 3. numbers ad'd up either way. 4 i i ' 4 MR. BACKUS: Well,- it's not only that, Your Honor. I i 5 think it is a question that casts some doubt on those that they q y j (#) 6. claim are available to meet the staffing, l 7 JUDGE SMITH: Where do they claim them though? '8 That's what - I' m looking for. I' m not familiar enough with this ).' 4 V"! 9 testimony to see where they claim them, and where the shortfall l 10 i s. I see 72 and ended up with 87 is what -- r, .3 11 MR.'BACKUS: There)s a reference to the number on 12 page 10, and there is a statement, "In addition to the 90 'ESU y 13 personnel, there is estimated to be another 471 personnel from ) ?m/ }. ', N Q c-l 14 the three DHHS divisions who could be called upon to staff the 15 four reception centers." j. 16 Now I have heard Mr. Colburn say that he's gest 90 or i. \\ 17 95 people that are not among those that said they wouldn' t care 18 to respond to a Seabrook-related emergency. But another 471 19 may well include those. So I think it has some bearing on the g, 20 issue of the numbers. 21 JUDGE SMITH: The numbers don' t mean anything if they 22 are just floating around without some relationship to claim f-23 totals, and,just to say that a certain number would not respond i( A 24 doesn' t tell us anything. I mean this is the other side of the 25 same coin of the question you were asking. ' IM t l \\%1 l l4 Heritage Reporting Corporation l I (202) 628-4888 l L. s W -_ _ __ _

[.. U [: I PANEL NO. 4 - CROSS 4795 (( : '1- -Give'me an arithmetical reason why the numbers-in 2 this' exhibit are probative. 3 MR. BACKUS: Maybe I should.do a'little bit more 4. examination on this then, because there-is - -there is the 5-claim,'and-I heard Mr. Colburn make it, that he has 90 people G that are not among the 28 point something percent that said 7 they wouldn' t respond. to Seabrook. 8 He has also claimed that he's got additional people-9 adding up to 471. Now whether that includes the people that 10 have signed this survey, I quite agree I haven' t asked him, and i 11 I would just as soon ask him. 12 JUDGE SMITH: Well, until.you tie up these numbers to 13 something that is before us, they really don' t prove anything. 14 M R. BACKUS: Well, I think it goes beyond'a. numbers 15 issue here, too, Mr. Chairman. That's the other point I' d like l 16 to make. l 17. I think there's an issue of whether or not these 18 numbers actually represent people that are going to be trained, 19 capable and actually respond. And I think the fact that 20 they' ve had in two divisions of this department, Dr. Wallace's 21 division, and these other divisions that Mr. Colburn surveyed, 22 such a high degree of refusal on the grounds that people did 23 not care to participate in addressing a Seabrook emergency is l 24 probative on the whole issue of whether these other numbers 25 they claim are really going to be there. () Heritage Reporting Corporation { (202) 628-4888 j 1 ) i

L l 1 ~1 PANEL NO. 4 - CROSS' 47901 1 JUDGE SMITH: Well, don' t tell me a high degree in a l 2 vacu'um. Tell me a high degree in arithmetic.- j i 3 MR. BACKUS$ 28.1 percent is what this' survey said. j J4 JUDGE SMITH: Let me consult. 5 (Boar-d-confers.) 6 JUDGE SMITH: There is no numbers that the Board .7-unanimously agrees that are '--- there are no numbers th.st are 'l 8 tied to the testimony you are challenging. 9-Now we are not foreclosing further questioning if you 10 think that that's appropriate. But 28 percent standing out 11 there by itself doesn' t -- this -is not a useful number to us. 12 MR. BACKUS: Well, let me just finish marking the a 13 rest of them for-identification. 14 JUDGE SMITH: All right. -15 MR. BACKUS: So we will be able to refer to theu as 1 16 we debate this. 17 I understand that the one we have just been talking 18 about has been marked as SAPL 3 for identification. I would 19 like to mark as No. 4 the computer printout designated Survey, 20 WK-1, two pages. 21 (The document referred to was 22 marked for identification as 23 SAPL Exhibit No. 4.) 24 MR. BACKUS: And as SARL 5 the pie chart labeled 25 Reasons For Not Participating in ESUs, and attached ESU ~j~t .d Heritage Reporting Corporation (202) 628-4888

+ L s I L , c 4

5 '

' 11 1 PANEL NO. 4 - CROSS-4797 .z .1 questionnaire compi1attons as of March:6,.1986.. 2 '(The document referred.to was 2i marked for. identification,as 4: SAPL Exhibit'No. 5.) ,\\ JU'GE SMITH: Let 's 1.j ust - see if.the panel itself, 5 D 6' they have heard our discussion, our probing to,see what these 7' fiDures mean. 'Do you' mind if I just-ask'them if these - what 4 0 these figures do to their. testirnony, how do.they fit in? I. 9 don' h know how thay ! fit in? .MR. BACKUS:

Sure,

~10 f '.1 1 JUDGE SMITH: All rAght, gentlemen, would you care to l .12 - help us.out? i - 13 THE WITNESS: (Colburn) Since it's my survey, .14 .probably 1'ohould respond to it. H, l - 1 l. 35 I.would like to point out, first of all, that this l 16 survey was not put out there for the purpose of developing any i 17 figures as far as our capacity to respond to Seabrook'is 18 concerned. Okay, that was not its purpose. 19 It was an in-house survey simply to try to get some 20 feel as to why there were not more people interested and 21 responding to participating in these voluntary units. 22 JUDGE SMITH: And in some areas you had hoped that 23 there would have been more; that you thought the ideal would j 24 have been more. 25 THE WITNESS: (Colburn) Yes, I expected that there i

r. -O i

l Heritage Reporting Corporation l (202) 628-4888 1 1

H j L H p n 4 1 l PANEL NO. 4 - CROSS 4790

h*

1. should be more, and I didn' t know what the reasons were. l

• )

p-(- s l 2 Obviously I assumed that in the climate in which we operate-3 these days that Seabrook was a factor, but I didn' t know how I A big a factor. And that's why that. is prominent in the survey. 5 But the survey was not, as I say,' designed to develop any ~ 6 figures having to do with Seabrook or the plan for Seabrook. ) 7 JUDGE SMITH: So notwithstanding the fact that it 8 wasn' t designed for that purpose, do the results, do you see 9 that the results have an effect upon your testimony, and your 10 assurance that the personne1'would be'available that you claim 11 would be available in your testimony?' 12 THE WITNESS: (Colburn) In terms of the results as fj'] 13 far ao I' m concerned, it's supportive of my contention that the L4 14 numbers are there. And I wish to emphasize that other than for 15 these people who are in the units, we have not asked for a 16 commitment from these other people, and they have not made any, 17 but we believe they will respond in sufficient numbers. 18 JUDGE SMITH: Well, how about the number that you 19 alluded to you, the 400 and 70 some figure, 471; they are 20 clearly not in your units, your ESUs. 21 THE WITNESS: (Colburn) That's right. Th a t ' s 22 correct; yes, sir. 23 JUDGE SMITH: Where do they come from? 24 THE WITNESS: (Colburn) Deg your pardon? 25 JUDGE SMITH: On what basis do you believe that those D Heritage Reporting Corporation (202) 628-4888 l = -. _ _ _ _ _ _ _ _ _ _ _.. _ _. _ _ _ _ _ _ _

} ;. e J' ~ ~ } ~ o- _p ) ? r PANEL NO. 4 - CROSS 4795 7 l. ~ 1' po'sonnel would be available?~ r i l Lt. .2 .THE WITNESS: .(Colburn) My basis, Your Honor, is 3~ havinD worked.with human' services staff for most of my working j 4 life, which is a< good many years, and with this particular U 5' department over 20 years in various' capacities, I find that the J .1 Es. averages person who comes to work.in this type of field isfa y, 7 very selfless, not selfish. person. When the need.is there, m .i 8 they. respond. p i a _9 JUDGE SMITH: About like the people who responded to l '10 your survey? Would you extend by analogue the same results as t x if the survey had:been sent'to_them? -j p ' 11' (. 12 THE WITNESS: (Colburn) I believe, as I.say, I I 13 believe that. in terms of. the responses to the survey, I.was

l. 1"%%)'

l 14 frankly encouraged by it in terms of my belief that the numbers j l 15 are.there when t' hey are called for.. 16 JUDGE SMITH: Well, for example, was this_ number 471, 17 was that reduced by -- was that a product reduced by 28 percent ~, ! 18 or any other number based upon -- whether encouraging or.not ~~ ] 19 was it based upon the results of your survey? 20-THE WITNESS: (Colburn) That number was arrived at i a 22 by looking at that point in time, by looking at the numbers of j i 22 staff in each of the district offices and the three divisions I 1 i l 23 have alluded to, and looking at the numbers of those people ] 24 that I felt could reasonably be called upon to respond. And j i 25 again, that's in addition to the people who are in the units LO 1 o l Heritage Reporting Corporation (. (202) 628-4888 L

7 v ~ g H' )q 'N, j .p o!g i L.J. PANEL NO. 4'- C,ROSS-4800 i-who~for the core that, we' re concerned with.being knowledgeable i 2. and trained-to-respond. I 3 JUDGE SMITH:.But in'the -- the'471, is that a simple 4 accumulative number adding'the-different people in the'various- { < '5 divisions?-- -6 THE. WITNESS: -(Colburn) ,Yes, it.. i s. 7- ' JUDGE SMITH: 'But ~ you don' t reduce it in based upon-I -8 and extending the logic,of the survey which did. develop a-' f 9 certain amount-of negative attitude, negative responses based 10' upon the Seabrook'. problem. 11 THE WITNESS: (Colburn) Actually, what I do with 12-this .'I look.at the total number of people who are ~ in those ' 13 three divisions, both state office and. district office. 14-Remember, I did not survey state office at:all,.,just district 15 offices. But.there are upwards of a thousand people at any. 1 ~ 16 given-time in these three divisions, state and fit 1d. l l 17 And if you.take 57.2 percent of that^ total, you come { 18 up with sufficient figures, sufficient numbers. 19 JUDGE SMITH: Okay. So you have a pool of some i l, 20 thousand or so people from which you identified 471 you thought 21 could be counted on. 22 THE WITNESS: (Colburn) As a minimum. Yes, we have 23 that many. 24 JUDGE SMITH: Mr. Backus. 25 BY MR..BACKUS: O j Heritage Reporting Corporation (202) 628-4888

r1~ 1 6; l o h L ((")q.. . PANEL NO. 4 . CROSS -4801 l m 1% 1-G .And 'what I want to know, Mr. Colburn, is can you. L R 2, anuure us that none.of.these 471 are people that responded to 4 3 that survey indicating'that they did not-care to respond.to a 4 'l 4 Seabrook'emerDency? 1 i It's 5 A (Colburn) .No, I can' t assure you of that. l 1 l 6 entirely possible and very likely that in the 471 figure there' 17_ are people'who were respondents to the survey. But I have no; o 8' way of knowing how many.- s l 9' Q-All right. And of the 471, I thought I heard you say 10. to Judge Smith that the.471 was the staffing roster as of the '11 time this was prepared of three divisions; is that right? IE! A (Colburn) At the time this was prepared' that ~ was my - I M7% 13 estimate of-the potential-pool -- potential number of people , U. 14 that we could' expect to draw from' the districts to do the job. 15 JUDGE SMITH: Now at that point, I think i t ' s' 16 wortliwhile you clarifying-it, because I understood him to say 17 that there was a, or as I paraphrased it, a pool, but you would 18 call it a staffing roster of 100 or so peccle. 3 19 MR. BACHUS: Right, I'm trying to find out what the l 20 difference-is. 21 BY MR. BACKUS: l 22 Q When you mentioned the people of a thousand, was that j l l 23 including other divisions, or what? i 24 A (Colburn) The figure of up into the thousand, I 25 believe in fact at this carticular time, in August, there was j 1 1 Heritage Reporting Corporation (202) 628-4888 { } l l l

j i i e i 1 r-. PANEL NO. 4 - CROSS '4808 1 1' 979 people -in these three divisions between state office and 2 the district offices. -Therefore, getting 471 people;out'of 3 that total number would not, in my opinion, be that difficult. 4 I can' t prove'that, but that is my belief that.we can do that. 5 O Well, when you say'there were some 979 in state and' 6 district offices,. you are talking about workers within these 7 three divisions here in Concord, in field offices in Berlin, 8 and Keene, and Clairmont, Laconia, Littleton, all over the 9 State of New Hampshire; is that right? 10 A (Colbur,) That's right. 11 O Does the 471 include people in field offices, or-in l l 12 that people here in Concord? l 13 A (Colburn) The 471 includes only people in the field. w}, {~ l 14 offices. It.does not include any people in the state office at 15 all. l 16 O And is the difference made up by the office staff t l 17' here in Concord? I' 18 A (Colburn) In terms of a total pool to draw from, I 19 would visualize the difference being made up, any difference 20 that might come about as a result of some people in the 21 districts not responding, I would expect could be made up at 22 the state offico very likely. 23 JUDGE SMITH: Now was that responsive, Mr. Backus? 24 MR. BACKUS: I would like to have the answer repeated 25 if I could. I didn' t quite get it. (/ Heritage Reporting Corporation (202) 628-4888 t 1 E______________

[e .(, i i {, 1 t h ~ l. PANEL NO. 4.'- CROSS 4802 p; i j 1 THE WITNESS: . (Colburn) lI' m sorry, maybe -I. don'.t .. p< w 1 Would you'try'it again? '2' understand your question. 3 BY MR. BACKUS: 4 O' l' m just trying to understand, and'you can explain it 5 anyway you want, Mr. Colburn. You put;down here for some j 6 reasons - on some basis that there would be another 471 7 personnel from.three divisions who could be called upon to. 8 staf f the: four reception centers.. -9 You subsequently.said in questioning from the Bench a 10 some: thing about the total availability possibly of a thousand. 11 And I'm.Just trying' to understand where the 471 has diffored f -{ 12 from the thousand. l 31 1 13 .A (Colburn) First of all, the 471 figure was arrived j '14 at by looking at what was then the current staffing in the 12 15 district offices, looking at the current staffing, subtracting 16 out those who were already members of the emergency services 17 units, and looking at that number and saying that I felt that ] f 18 there were that many' people who could reasonably be requested, j l 19 could be called upon to respond to do the job. l 20 I didn' t say that it was a guaranteed figure. It is l 21 not. But those people were there, and that was not counting 1 22 administrators and so forth who would need to remain in the I l 23 offices probably in some circumstances to keep things going. j i 24 But that was the figure that I arrived at at that time. l 25 As far as its relationship to the total staffing in j Q I Heritage Reporting Corporation ) (202) 628-4888 j 1

\\<- 3 t PANEL NO. 4 - CROSS 480L =,, 1 the three divisions is concerned, both state office and-12 y s _ 1 2 district offices, it is only related in my mind inasmuch.as I 3 did not consider the total staffing when I did the 471 figure. 4' But considering the total staffing, which as of I 5 August'was I'believe 479 people, I still believe tha*c between 6 state office.and the district offices I could get those 471 7 people, or the number that were needed. You know,. we don' t l 8-even -- we may not even need that many, but I believe those 9 figures are there. It's reasonable out of that total pool to ( 10 get that number of people. I 11 Q All right. Now my understanding is that the people, { l 1 l; 12 the 90, or I think you said now 95 people that have signed up f l - -M 13 for the emergency services units.are being provided with u \\ l 14 training; is that correct? 15 A (Colburn) That 's correct. We endeavor to keep this f 16 core of. people oriented to the proDrams, all'the programs, and a 17 trained to respond to their particular roles, yes. 18 0 Have they been receiving training with regard to the f 19 New Hampshire Radiological Emergency Response Plan? 20 A (Colburn) Yes, they have. In fact, most of them an 21 recently as of August of this year. 22 Q Now the 471 that you referenced in your testimony, 23 are they receiving training in carrying out their tasks under { 24 the radioloD cal emergency response plan? f i i I l 25 A (Colburn) They are not receiving t raining I i i l l-Heritage Reporting Corporation ) I (202) 628-4888 )

\\' ya s s ,+.. c.r :,j I -! l-' < ; ' ' ' ' PANEL' NO. 4' - ' CROSS 4805 {-)-; :g).~ 1-specifica11ytfor that purpose, no. But I.believe.that'the OQ? l-- !! <V ~ # .i 'fL training : and background ~ of most of j them in terms Lof the jobs ' i ~3-theyL do is -very appropriate 'to the work they would1be calle' ~ d 4 upon=to do'in this case. ,i g 5. G 'What-in the work most of them do, Mr. Colburn?' 6 'A' '(Col burn) A large number of them are people who deal .s 7 directly with people under stress, identifying needs,; referring 8 them for services', and processing' lots of paper. 9 O This would be for example typically a' social. case' ) 10 worker administering the :various aid and welfare programs? 11 A (Colbu'n) Social. workers, case technicians, much of' e 12 the clerical staff. .13 - JUDGE SMITH: .If somebody's house burns down. and i { )'; i '14 comes in for' help, that type of thing, could be? 15 THE WITNESS: (Colburn) Well, it's not. quito that. f 1 16 related. cTheseLfolks -- these folks are responding within the l J J '17 definition of very specific programs, federal / state programs. 1 18 That specific type of thing, a house burning down is not l 19 something we would respond to, or they would respond to as l 20 such. 1 'EndT11 21 (Continued on next page.) ) l e2 23 .1 1 24 ) i 25 l C) l Heritage Reporting Corporation l (202) 628-4888 { I l I 1

, e L. ? ? l. 5 4 r ,a. D l 480E R I (I'$ ,ti2BMAR -1. THE' WITNESS (Colburn):- These are responses to 1 .2 categorical programs as defined in Federal and state -- l 3 JUDGE SMITH: Just basically-poverty cases? .4 THE WITNESS (Colburn): Yes, needy people of various 5 kindu,,yes. 6 BY MR. BACKUS: 7~ G So we are talking-about food stamps, aid to families ~8 with dependent children, that. sort of program, riDht? 9 A (Colburn) Right, and disabled people.and so forth. 10 Q Okay. I 11 And if we go up to the thousand figure that.you have l 12 mentioned, I presume that that is a general personnel figure 13 given us, which includes,the clerks, and typists, and. people 14 who do that sort of work, is that rignt? 15 A (Colburn) Yes, it includes the whole personnel 16 grouping, that is true. f-17 Q Okay. l l 18 MH.-BACKUS: I think, at this point, I would like to !l-l 19 offer the exhibits that have been marked for identification, 'm testimony that the 20 into evidence, on the basis of Mr. Co 21 figures that he has testified to may in A., at least the 471 22 figure may include people who have made responses to those 23 surveys. 24 JUDGE SMllH: Mr. Colburn, i f, in your view, knowing l 25 the total roster, the pool of people from which you derw the O ~ Heritage Reporting Corporation l (202) 628-4888 l t I

7_ c. t.y. PANEL NO. 4-- CROSS ?4807 37-k'J 1 471, if you had surveyed the total pool -- notwithstanding-he: 2-fhet,'that.some may'have been surveyed, but if you ha, surveyed l 3 the t tal pool -- would you expect ~results somewhat as i in-SAPL'Exh' bits three, four'and five? l-4 indicated r> 5 THE WITNESS-(Colburn): Okay, you.are' referring'to: i '6-the compilations? 7-JUDGE. SMITH: Yes, the pie' chart, .t h e letters and 8 all.. 9 THE WITNESS (Colburn): I think that would.be a 10 reasonable assumption. 11 JUDGE SMITH: Now, are there any objections to 12 receiving them? l i 7N 13 MR. BISDEE: No objections from the State of New $A 14. Hampshire. f 15 MR. LEWALD: I think that we still object to the -16 introduction, Your Honor. 17 It appears to be a scheme here of double counting 18 that is going to' follow and I -- f i 19 JUDGE SMITH: I don' t nee that and if that is a j 20 concern, I think that we had better clarify all of these l 21 numbers to fall in. But that is a good point, that you know, L l l l 22 that we had better make sure that we don' t have double counting l 12 3 or omissions. i I l 24 I am sorry, I interrupted you, please finish. j ) f 25 MR. LEWALD: Well, the witness has already testified ! [:) I ] Heritage Reporting Corporation (202) 628-4888 1 1 1 -m_______________

g s . (a). PANEL NO. 4 - CROSS '480E f. L 1 that he took into account, from arriving at the'other number, j l j 2 and now, to introduce these exhibits, that have been marked for 3 identification -- his only effort is to try to cast ~ doubt on 4 the validity of any.of the numbers. 5 JUDGE SMITH: Right, exactly. l M R. LEWALD: But'it on'1'y does it by a distorted 6 7 association. There is no nexus between the two numbers., 8 JUDGE SMITH: I think there 'is now. l 9 MR. LEWALD: Well, it is in a negative sence, it is i 10 not in a positive sense. I mean if you a.e trying to j l ) l 11 introduce, say the number three, to show'the validity of five,- j 1 ( 12 and you are starting with 10, I fail to grasp the nexus of it. 13 (Pause.) l 14 (The Board confers.) f 15 JUDGE SMITH: Well, the Board believes, that if these 16. Exhibits, Numbers 3, 4, and 5, provide a profile of a i 17 statistically significant group of employees, who are 18 presumably homogeneous with the group that were not surveyed, j 19 and based upon Mr. Colburn's testimony that he would expect 3 20 similar results, the objection is overruled, and the Exhibits f 21 are received. 22 MR. LEWALD: Well, it was my understanding of his 23 testimony that that is what gave him some confidence in the 24 471-or-5 number because he had already discounted that because 25 of the kind of information that he was getting in the survey. O Heritage Reporting Corporation I (202) 628-4888 ( } l

yc7 r e-L -PANEL NO. 4 - CROSS 4809 a [..k" #); 1 . JUDGE. SMITH: .Yes, my-)very' feeble-arithmetic would 2 think'that he might come.out to that pretty close, anyway. ;But '3 Is don' t know. i-4~ But Mr. Backus'has made his. point. S-M R. BACKUS: Your Honor, i f the order was that 'these. !6 Exhibits were in, I was prepared to move on.to another' field'in 7 the exa'mination'and this would be a convenient time for me to 8 break.' 9 (The documents previously 10 marked'for. identification 11 as SAPL Exhibits Numbers la 3, 4, and 5, were received 13-into evidence.) ,. m 14 JUDGE SMITH: All right, we will adjourn until 9:00 '15 a.m.-tomorrow, and for the convenience of the parties, we will 16 have some arguments. 17 And I don' t ' think that we have to have extensive j l 18 arguments. We have all read the papers and the three issues l 19 have been well briefed, but we will have the arguments on the l l 20 motions to the objections to testimony. q 21 And then at 11:15, we are going to adjourn because l I l l 22 there is going to be a ceremony down in the Hall of Flags, and I' 23 that will be our luncheon recess. j I 24 So we will have a rather short morning, but then we l 25 will return early from lunch at 12:30 and continue. i i y, d I Heritage Reporting Corporation I (202) 628-4888 l l I I l eb________.___ ..1_

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'I PANEL NO. 4 - CROSS 481C I) i 1 So, if some of these gentlemen want to come in '2 later, we can assure them that 'we won' t get to them'unti1 S:30 ^ 3 or closer to 10:00 a.m. 4 Is.there anything else?- 'S ' MR. BACKUS Your Honor, just one point that I would g i G like to make on tomorrow's schedule. 7 We do have Dr. Herzberg here, tomorrow afternoon, and. 8' we hope that he can be heard at that time. 4 9 And the other thing is'that I think that 1.have an ~ 10 unavoidable thing, I'have to do during the lunch which your l 11 break. schedule may assist, but I may not be back first thing in 12 the afternoon. 13 If Dr. Herzberg'is here, I would like to ask that he ) 14 could be, his testimony could be sponsored by Jane Doughty or 15 perhaps by Attorney Brock, if it needs to be an attorney just 16 to make sure that he gets on and is available for examination? 17 JUDGE SMITH: Well, I am.looking at Mr. Backus' 18 cross-examination plan, he has a substantial amount of cross- ) I 19 examination left, or do you? 20 MR. BACKUS: I don' t know, another hour maybe. I 21 don' t think that it is as substantial as you would gather from 22 looking at that. 23 JUDGE SMITH: Okay, if you are about a third through, 24 I am pleased. i 25 All right, so that it looks like we would have a good l 4 l-ll Heritage Reporting Corporation I f (202) 628-4888 f - i 1

,.~- ox. ,s: _, ~ q i _ I s L c I l PANEL.NO. 4'- CROSS 4011 fj

pr.4 M 6'-). i 1

L[' 1 chance of winding up at 11:15. l; i ^ 2 MR. OLESKEY: Judge, this is Stephen Oleskey? 3 JUDGE SMITH: Yes? J 4 MR. OLESKEY: Since we discussed earlier-in the 1 E 5 afternoon the schedule for the arguments for tomorrow, two 6 matters came up which le&d me to broach with you putting off 7 the arguments for a couple of days. i 8 First of all, one of my colleagues, Assistant J 9 Attorney' General Sneider arrived with some materials-that she l 10 had received on Friday,.which I.had not seen and which'she and il l'had not had'a chance to discuss, which deal with the NRC's s 12 dose consideration and perspective, which is obviously very 13 Dermane to the Sholley-Deyea testimony. 14 And also would.it appear, from what I saw this 15 afternoon in reviewing it with her, as'we sat here, to bear on-16 the discussion at page 27, from the text of the rules 17 consideration which Attorney Turk referred to, the reference to 18 the extent to which the NRC deals with dose considerations at 19 all. 20 And we could not, in all candor, sit here and write 21 anything additional this afternoon, based on this material. 22 And I think that since we only appear to have received from the C3 NRC partial material, which does not fully identify the i 24 documents, to the extent that I would like, if we handed them 25 in, we may have to do something tomorrow from our office to try l-l Heritage Reporting Corporation (202) 628-4888

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{ l b 481E , ?,-s. PANELfpO. 4 - CROSS L ~'\\,h 1 to get additional materials. 1 L i .l l E So, for that reason only, and beingzvery candid with 1 3 you,. I would like to put it off for a day or two. If we cannot- , l i i-4 flush'out'the argument that I think is there, we won' t file j I 5 anything additional, and if we can, we would file it no later j 6 than Thursday and argue it Friday. j .j 7. JUDGE SMITH: Well, that certainly is pretty much up ] . ) 8 to'you because we scheduled this as early as we can, -- 1 l 9 MR. OLESMEY: Yes. ] k 10 JUDGE SMITH: -- for the convenience of your panel. k 11 MR. OLESKEY: I understand. I am willing to go by' j f 12 that advantage in order to see whether there is some further 13 argument that I think that we can, in good' faith, put together 14 in'the next couple of days. . { 15 JUDGE SMITH: Let me state this, it is your panel and 1 16 you can have it any way that you want t o, but right now, as we 17 sit here, having read the papers, we really believe, except 18 that we have not heard from the staff, we really believe that 19 on all of these motions, we can rule based on the papers before 20 us, it is the usual amount of argument. 21 And were we to rule, we would rule that you could not f 22 present the Sholley testimony; that you could not present the 23 section two of Luloff, of the population projections, except as 24 they might be in the very, very short term. And we would j 23 overrule the objection on FEMA testimony; we would not strike O> \\ Heritage Reporting Corporation f (202) 628-4888

lN . PANEL NO. CROSS '481;; ~ 1 that~ test imony1-- the' Applicant's object ion to the FEMA 2 testimony. That would be how we would rule on the ' papers. 3 People want to be heard further on these issues, 4 particularly the.Sholley -- 5 MR. OLESKEY: Yes. is a critical. issue, and we'wish to 6 JUDGE SMITH: 7 be as fully informed as you want us to be on that issue, so 8 that it is up to you. 9 MR. OLESKEY: I would like to see if there is 10 something else which we could file in the course of the week, 11 based'on the material that we received on Friday. 12 JUDGE. SMITH': Okay. 13 MR. OLESKEY: Thank you. 14 JUDGE-SMITH: It might even be helpful to you, if you j 15 prefer it, is that we would.make our ruling -- no, let 's" have ' d 16 all the facts before us. o J 4 '17 MR. CLESKEY - I would just as soon wait. 18 JUDGE SMITH: Yes. l 19 MR. OLESKEY: Thank you. -] 1 20. M R. TURK: Your Honor, this is.Sherwin Turk? 1 21 JUDGE SMITH: Yes, proceed. 22 MR. TURK: For the record, I just want to note that I ) 23 am not aware of what materials it is that Attorney Oleskey has ] 24 received? l 25 He states that he received them from the NRC, but { l Heritage Reporting Corporation J (202) 628-4888 ) L i a- .1

) f y ,. s l, d p ' 1, ef-y '.. '( r i 'a j (. PANEL NO.: 4-- CROSS 4814 it they did.not come through me, and I am not sure what he is. = ~ 2 referring to. ) 3

MR.'DLESKEY:

That is correct.- J 4 . JUDGE SMITH: All right,'we will meet tomorrow-I l 5 morning at 9:00 a.m., and can we dispose of Luloff and FEMA j 6 motionn tornorrow morning, if you want to? 7 MR. OLESKEY:. Well, it is obvious from our O perspective and-I assume from FEMA's, we-would be' happy to have j 9 you dispose'of FEMA based on your indication of-tentative- '1C ruling. .it I don' t know how Mr.'Dignan feels about that. { 12' . MR. DIGNAN: I wish that he would get rid of the 13 other two, Judge, too. 14 -JUDGE GMITH: ~All right, let's' finish this panel '15 tomorrow. 16 MR. OLESKEY: Fine. 17 M R. DIGNAN: Your Honor, could we go off the record, .i q 18 and have the attention of the Board for a few minutes? j l 19 JUDGE SMITH: Yes. I i 20 MR. DIGNAN: Because Mr. Fierce brought up something i G1 that I think he and I can reach an accommodation, and we l 2a probably would like to advise the Board of that so the Board l 23 could be prepared. l 24 JUDGE SMITH: The hearing will adjourn now, until j l 25 9:OO.a.m. Parties will remain for a conference. 1 J O' ) i Heritage Reporting Corporation ] (202) 628-4888 l J i l l

w a PANEL NO. 4 CROSS 4816 l , j7q '

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~ 1 (Whereupon, the hearing was adjourned at 5:09 a.m., 3 1q l 2 the hearing to be reconvened at 9:00 a.m., the following day.) i End T-12BMA8 4 1 5 6 7 l-g 9 I 10 I -- 11 l l l 12 l LQ 2 14 15-16 17 18 19 20 21 22 23 24 i i 25 ( Heritage Reporting Corporation j (202) 628-4888 I l. A ...a _ _:- _

r 1 CERTIFICATE ,s ) xs 2 l 3 This is to certify that the attached proceedings before the q 4 United States Nuclear Regulatory Commission in the matter of: { Name: PUBLIC SERVICE COMPANY OF 1 l l 6 NEW HAMPSHIRE, et al. i 7 Docket Number: 5-443-OL, 5-444-OL j 8 Place: CONCORD, NEW HAMPSHIRE l d Datet November 2, 1987 10 were held an 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 I l /'N 14 of the court repor t ing company, and that the tranneript is a l'. \\..) l 15 true and accurate reobrd of th fo sing proceedings. b4% 16 ./ S./ _. _. j 17 (Signature typed): KENT ANDREWS I l 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 /'T V Heritage Reporting Corporation. (202) 628-4883 l t _____1_ _. _. _. _ __}}