ML20237C610
| ML20237C610 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 12/16/1987 |
| From: | NRC ATOMIC SAFETY & LICENSING APPEAL PANEL (ASLAP) |
| To: | |
| References | |
| CON-#188-5267 OL, NUDOCS 8712220028 | |
| Download: ML20237C610 (191) | |
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g ORIGINAL UNITED STATES '
NUCLEAR REGULATORY COMMISSION
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IN THE MATTER OF: DOCKET NO:
PUBLIC RERVICE COMPANY OF ) 50-443-OL
) BO-444-OL NEW HAMPSHIRE, et a1 ) OFF-SITE
) EMERGENCY (SEABROOK STATION, UNITS 1 AND 2 ) PLANNING EVIDENTIARY HEARING LOCATION: CONCORD, NEW HAMPSHIRE PAGES: 7921 through 8103 DATE: December 16, 1987 z===========u=========================================================r==========u==
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING APPEAL BOARD
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In the Matter of )
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PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL OF NEW . IIAMPSIIIRE, et al. ) 50-444-OL
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(Seabrook Station, Units 1 )- (Offsite Emergency and 2) ) Planning Issues)
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/~N k_) APPLICANTS' CROSS-EXAMINATION OUTLINE ON TESTIMONY OF DONALD J. ZEIGLER, JAMES II. JOIINSON, JR. AND STEPHEN COLE ON BEHALF OF THE ATTORNEY GENERAL OF MASSACHUSETTS Applicants' Cross-Examination intends to inquire into the following matters in challenge to the credibility of the witnesses and their testimony.
Panel Members:
Academic degrees - psychology? any branch?
Specializations -
Associations - .
Areas of interest technological and natural hazard distinction Nature of research conducted (geographer's surveys) field work and experience Cole's position as to the objectivity of sociological studies, value-free or value-involved sociology and the
() sociologist as a Technician or Reformer (p. 3).
"The Sociological Method") (p. 3).
(See
_ _ _ _ - _ _ _ - - - _ . __ _ _. __ - -- _ _ - _ - - - _ _ _ _ _ _ - _ - _ _ _ _ _ _ _ - _ _ -_ a
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(_) Basis for panel testimony that the Plan (NHRERP) assumes spontaneous evacuation of 25% of the EPZ population'(p.
j 4). Same theme (p. 26).
Identification of the radiological and non-radiological emergencies from which the panel's knowledge of human behavior is (p. 5) claimed to be derived.
Basis for distinguishing cases where the disaster agent is radiation (p.6).
-Effects of evacuation outside the EPZ on ETE's (p.6).
Where is geography defined in the manner of the panel definition (p.6).
Authority for conclusion "since behavior is linked to perception." Suggestion - that this relationship is one of cause and effect? (p.7)
Explanation of " intended human behavioral responses.
Correlation of intended and actual human behavioral responses (p.7).
Confirm panel's opinion regarding a Seabrook shadow r's evacuation is based on TMI investigation (p.8-9).
(_) Review Chapter 3 of TMI social survey, methodology, statistical data, sampling. Note panel's comment on mail surveys (p. 13) and Cole caveats on mail surveys and sampling, in The Sociological Method p. 62.
Implications of TMI evacuation distances (p.10).
Extent of TMI study corroboration by others (p.11).
Factors contributing to TMI evacuation. Confirm two factors noted on pp. 11-12 of Seabrook Survey Report Attachment 5, (pp. 11-12).
Assistance to be rendered the Mass. Attorney General.
Attorney General declared position (pp.12-13).
l What were panelists commissioned to do for the Mass.
Attorney General. Compare panel testimony with SDA's i report to Mass. Attorney General (p.12). Is this same matters discussed on page 20 of panel testimony and on page 49 et seg. in the techaical appendix to Attachment 5 Get details of meetings. Participants, objectives, plans. Question adequacy or demonstrate inadequacy in
() inadequacy of NHRERP?
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O Examine the three survey techniques. Pro's and Con's of each. Determine the most appropriate method for the survey undertaken (p.13).
'Where.in testimony or attachments is data.that more than 95% of residents of EPZ have home telephones (p.14)?
Basis for employing of Survey Sampling Inc. to select sample. What instructions were given by SDA. Purpose of choosing number 1400 to be interviewed. Correlation between zip code numbers and telephone exchanges. How were telephone exchange populations determined.
Determine method or procedures used to establish designated quotas for each town and each sex (pp.14, 16). Contrast with Cole's opinion (p.30)
Demonstrate non-randomness of sample. Compare design'of sample with interviewees in survey.
Determination of sampling error for survey. How calculated. Conclusion that can be drawn from sampling errors (p.16).
Significance in the size of the sample (p.17). j
() Where is the result of call back procedures utilized in survey (p.17-18).
Accuracy of completion rate calculations. What were factors considered. Why omissions. Compare with Cole's 70% figure in "The Sociological Method" (pp.61-62).
Limitations on the confidence that can be had from past surveys (p.18).
Methods used to validate survey (p.19). Question of what was validated other than the interviewing processes.
Identify MKTG Inc. What was its role. How was conclusion of few survey errors sustained (p.19).
Review details of meetings with Mass. Attorney General and consultants to draft questionnaires used in survey.
Explain nature of data required by consultants to conduct analysis (p.20). Compare with Shoreham survey
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even to same numbers.
How was questionnaire shortened. Questions abridged -
eliminated? (p.21).
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(_) Correct testimony -- aim of survey to " find out what i residents of EPZ would do" to what they think they would '
i do. Show testimony moves from behavioral intention to actual activity (p.21-22).
l Examine reasons for not using exact EDS messages in i
survey - (p. 24 ) . Are interviews with respect to Seabrook scenarios or SDA scenarios. Who is to say - all of Seabrook's EBS messages are not essential. . Repetition is one of foundations of EBS messages (p.24).
l Difficulty in repeating long EBS messages in a telephone survey - points up inappropriate method chosen for survey. Classic example of forcing a study to a method.
The topic of the study should determine the method.
Compare SDA's messages to Seabrook's EBS messages (p.23; Attachment 5, p.62).
On survey results of households requiring transportation. Can witnesses cite any study where public transportation was used to evacuate any one (p.25).
Compare variables on p.26 with witnesses TMI report
(~'} variables SDA Report Attachment 5 pp. 11-12.
.%)
Identify research conducted by Cole in Long island (p.27).
Review witnesses summary - of what survey data contains (p.27).
Examine reasons offered by witness why surveys are a reliable means to predict what people would do during a real radiological emergency (p.28).
Compare with witnesses assessment of what might happen in real accident vs. that depicted in survey. What was the accident depicted in the summary? (p.28). l Explore witnesses' statement that there is no reasonable basis for ignoring the expression of behavioral intention when attempting to predict what population will do in the event of an emergency (p.29).
Reference to last two sentences on page 30. What if every effort is made by the researcher and these efforts are unavailing?
What was the systematic procedure for selecting the
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( member of the household to be interviewed in the SDA Seabrook survey (p.31)?
Why do you term the failure of FMR to utilize a callback procedure to have probably resulted in over and underestimating certain people (p.31).
Describe the manner in which the findings from SDA's Seabrook survey have been corroborated by Long Island surveys (p.32, 33).
Are social geographers qualified to opine on sociological concepts such as role conflict (p.37)?
Examine the witnesses' position on the prudency of !
NHPERP drafters' reliance on emergency workers to report !
"promptly" (p.39).
In the articles witnesses rely on pp. 41-44 for view that emergency workers will not be available to perform their assigned tasks. Do any cite instances where ,
emergency worxers have clear understanding of role? !
1 Examine witnesses reference to recent studies in footnote 17 (p.45) recited by witnesses to indicate role conflict was a serious problem during crisis at TMI.
Do witnesses equate role conflict with role abandonment?
Compare witnesses representation that "at one local hospital, for example, only 6 of the 70 physicians who were scheduled for weekend emergency duties reportedly showed dp for work" (citing note 20) with the language !
of the cited reference. Also compare testimony with !
note 20.
Compare KASL article to testimony text (p.47).
Examine basis for the witnesses' statement that the strongest and most direct evidence of the extent to which role conflict is likely to be a problem in the i event of a Seabrook emergency comes from the Seabrook evacuation SDA study. Review survey results (pp.50-54). Have W compute Sampling error. Sampling error.
Size of sample. See Attachment 5.
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Thomas d'. Dignan, Jr.
George H. Lewald Kathryn A. Selleck Ropes & Gray 225 Franklin Street Boston, MA 02110 (617) 423-6100 1
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i UNITED STATES NUCLEAR REGULATORY COMMISSION' L 2 ATOMIC SAFETY AND/ LICENSING BOARD
. Sec50T&I-3 4 In the Matter of )
) Docket Nos.
15 PUBLIC SERVICE COMPANY OF- ') 50-443-OL l 1 NEW HAMPSHIRE, et al., ) 50-444-OL 6 ) OFF-GITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2)_ ) PLANNING l 7' d i
8 EVIDENTIARY HEARING ]
9 Wednesday, 10 December 16, 1987 11 Hall of Representatives New Hampshire Statehouse 12 Concord, NH
'p 13 The above-entitled matter came on for hearing, tv-14 pursuant to notice, at 9:03 a.m.
15
.BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN 1G ' Atomic Safety and Licensing Board
. U. S. Nuclear Regulatcry Commission g' 17- Washington, D. C. 20555 la JUDGE JERRY HARBOUR, MEMBER Atomic Safety and Licensing Board 19- U. S. Nuclear Regulatory Commission Washington, D. C. 20555 20 JUDGE GUSTAVE A. LINENBERGER, J R. , MEMDER 21 Atomic Safety and Licensing Board U. S. Nuclear Regulatcry Commission 22 Wanhington, D. C. 20555 23- ,
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0 792E 1- APPEARANCES:
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E 2 F,,or the A2p_1A ant:
J l 3 THOMAS G. DIGNAN, JR., ESO.
L GEORGE H. LEWALD,~ESQ.
L 4 =KATHRYN'A. SELLECK, ESQ. !
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51 Ropes &. Gray 225 Franklin Street
'I Boston, M3 02110
! G I For the NRC Staff:
l 7 l SHFRWIN E. TURK,. ESQ.
8 Office of General Counsel U. S. . Nuclear ~ Regulatory Commission 9- Washington, D. C. 20555
'10 For the Federal Emeroency Manaaement A_q3?IDCV 0 :
11 H. ~ JOSEPH FLYNN, ESQ.
Federal Emergency Management Agency 12 500 C Street, S. W.
Washington, D. C. 20472 13 O'
For the State of New Hampshire:
.14 GEORGE. DANA BISBEE, ASST. ATTY. GEN.
15' GEOFFREY M. HUNTINGTON, ESQ. -
State of New Hampshire 1G .25 Capitol Street !
Concord, NH 03301 17 _ _
Eptr the Commonwealth of Massachusetts:
18 _ 1 JOHN TRAFICONTE, ASST. ATTY. GEN. ;
19 STEPHCN~H. OLESKEY, ESQ. k ALAN FIERCE, ESQ. j 20 Commonwealth of Massachusetts One Ashburton Place, 19th Floor
'21 Boston, MA 02108 l 22 For the New Enaland Coalition Aq_ainst Nuclear Pollution: 4 i
23 (No appearance) I 24 j 1
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I 2 For the Seacoast Anti-Pollution Leanue:
3' ROBERT A. BACKUS, ESO.
Backus, Meyer, & Solornon 4 116 Lowell Street Manchester, NH 03105 5 1 JANE DOUGHTY
.J G Director l' Seacoast Anti-Poll'ution League 7 5 Market Street Port srnout h, NH 03801 8
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j 9 E.qr the Town of Harnot on s
- 10 MATTHEW T. BROCK, ESO.
- l. Shaines & McEachern j L 11 ES Maplewood Avenue '
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P. O. Box 360 j
. 12 Port stnout h , NH 03801 l 13 For the Towns of Harnoton Falls and North '
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. ROBERT'A. BACKUS,.ESQ. j 15 Backus, Meyer & Solornon ,
. 116 Lowell Street l 16 Manchester, NH 03105 l-17 For the Town of Arnesbury:
18 (No appearance) 19 Epr the Town of Kens i nqt on e
- 20 SANDR(-i F. MITCHELL
' 21 Civil Defense Director Kensington, NH 03827 i
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- 6. by Mr. Turk 8036 by.Mr. Traifonte ( resurned ) 8078-F : 7. 'by Mr. Lewald 8098 by.. Judge Harbour 8099 8 by Judge Linenberger 8100 by Mr. Bisbee 8101 9-10 11 12 13-14 15 .
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EXHIBITS: J_ DEN: RECD: REJD: DESCRIPTION:
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APPLICANTS' :
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No. 26 (Pre. . Marked) 8098 Excerpts f rorn The 6 Sociological Method by Stephen Cole, 8 pages 7
8 No. 27 (Pro. Mr.rked) 8098 Chapter'3, Report on Social Survey of TM1 9 Residents, 7 pages 10 No. 28 8026- Let ter 14' Dec ' 87 Stait h -
To Callendrello, 1 page.
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'13 INSERTS: PAGE c 14 Applicants' Cross-Ex arni nat ion Outline of Test irnony of Drs.
l 15 Johnson, Zeigler, & Cole 8031 16
' NRC Cross-Exarninat ion Plan of the Panel'of Zeigler, 17 Johnson,. & Cole ~6077 1
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() ZEIGLER, JOHNSON, COLE - CROSS 7920 T265 1 PROCEED I NGS .i l
b 2 JUDGE SMITH: Good' morning.
l 3 Is there any preliminary business?
- 4. .Al1 right, you may proceed, Mr. Lewald.
5 Whereupon, 6 DONi4LD ZEIGLER l 1
7 JAMES ' JOHNSON i
- 8. STEPHEN COLE 9 having been previously duly sworn, were recalled as witnesses 10 herein and were examined and testified further as follows: ;
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CROSS-EXAMINATION (Resumed) f 12 BY MR. LEWALD:
t 13 Q Gentlemen, when we concluded yesterday afternoon, 1 14 had inquired of you whether'the passage with respect to the 15 survey sample and also the questionnaire that was developed.for 16 the survey were discussed at the same meeting with the Attorney 17 General and the consultants. And my memory is that your answer 18 was that it was; is that correct, Dr. Cole?
19- A (Cole) Yes.
20 Q Could I ask you to turn to Page 49 of the technical 21' appendix that's attached to Attachment 5, which in turn is 22 attached to.your testimony?
23 At the bottom of Page 49, under the heading Design of 24 Questionnaire, recites that the research project was initiated 25' when the Assistant Attorney General, Alan Fierce, of the Heritage Reporting Corporation (202) 628-4888
t l:] ZEIGLER, JOHNSON, COLE - CROSS- 7927 1- Massachusetts Attorney General's Of fice, asked Social Data 2 Analysts to conduct a survey for use by the Attorney General's 3 Office'and its consultants in litigation currently underway l
L '4 before the ASLB in regard to the evacuation plan drawn up for l
L 5 the Seabrook Nuclear Power Station,
(: 6 Is this the beginning of the survey and the
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7 questionnaire, and how it developed at the behest of the 8 Attorney General, Dr. Cole?
l-9 A (Cole) Yes.
[ 10 Q Now you go on to say that the survey was also made 11 available for use by the other Interveners, correct? j l
12 A (Cole) Yes.
&~._ .. 13 Q And then after telephone' conversations between Alan-l 14 Fierce'and both Stephen Cole and Ann Harriet Cole, may I ask is 15 Ann Harriet Cole related to you, sir, in some fashion?
i 16 A (Cole) She's my ex-wi fe.
17 Q And after that conversation, she apparently arranDed 18 and did participate in a day-long meeting in New Hampshire 19 which wits attended by, as you point out, Alan Fierce, Mcs. Jane 20 Doughty of SAPL, and the number of consultants for the Attorney 21 General as you have listed here on Page 50, correct?
22 A (Cole) Yes.
l 23 Q Then you go on to describe that at this meeting each f.
l 24 consultant outlined the nature of the data that he or she would
, 25 require in order to conduct their analysis.
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( 7926 1' Islthere some -- was there'some log done at this j 2 meetings,' notes of what transpired?. j 3 A' (Cole) Do-I have notes?
4 Q Did you take notes?.
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5 'A (Cole) I wasn' t at the' meeting.
G. G ,You were not at the-meeting?
7 A .(Cole) ' No, I was not at the-meeting. It says Ann 8 Cole participated'in a day-long meeting. I was not at the 9 meet i nD-l 10 Q 'You wrote this testimony, though, correct?
11 A (Cole) I wrote the testimony.
12 Q- And so your writing is on the basis of what Ann Cole 13' told you?
14 A (Cole) Yes, and everything that I,know about what 15 happened.
16 Q Well, you say at this meeting each consultant 17 outlined the nature of the data that he or she would be 18 required in order to conduct their analyses, right?
19 A (Cole) That's correct. j 20 Q What r. An .the nat ure of the analysen that they were I
21 intending to conduct? '
22 A (Cole) You' d have to ask them. I mean, they told 23 Social Data Analysts and its representative, vire president, 24 what kinds of information they needed. We were serving their 25 needs. We were collecting data that they told un they needed.
Heritage Reporting Corporation (202) 628-4888
ZEIGLER, JOHNSON, COLE - CROSS 7929-1 If you want to find out what kinds of analysis.they intended to y 2- do.or actually did, you' d have to ask them.
3 Q Well, at this point in time the Interveners had 4 already. filed their contentions, true?'
l 5 A (Cole) Yes.
l 6 Q' And in which the Massachusetts Attorney' General is l~
i 7 going to join, at-least in part, that's true?
l, l 8 A (Cole) .Yes, as far is I understand.
I 9 O And are you saying here that despite the fact that l'
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u .10 the contentions had already been filed and the Mass. . A. G. ' s -
L 11 position, which'at that point was rather notorious for James l
12 Shannon-and his unequivocal opposition to the Seabrook plant, Lv. 13 that the consultants nevertheless were going on a clean slate 14 ard analyze the evacuation plan; is that what you' re saying?
15 A. (Cole)' We wanted to collect certain ir formation that 16 we felt we needed to answer certain questions. And we designed 17 a research design, in particular, this survey, that we felt 18 would give us an unbiased set of data that would be useful in 19 answering these questions. J 20 I had no idea how the survey was going to come out.
21 At the time that I designed this survey, I had not the 22 slightest idea whether you would have anybody saying they would .
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23 overreact. I could have guessed, but I didn' t know how it.was I
.24 going to come out, not the slightest idea.
y 25 O Well, you' re not suggesting that the analysis that
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1 was going to be done was value-free,-are you talkinD? 1
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! 2 'A (Cole) As far as I' m concerr$e:1, the analysis that:'
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4 A iZeigler) And I' d like to echo that po i n' i'. t 'I think
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5 the questions that I participated in'--
6 Q I beg your pardon? '
\f 7 A (Zeigler) I said, I believe the 49estions that' I.
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8 participated in designing were the sarne queuti7nu that would ,/
9 have been designed even bef ore the State of PtAusar huset s took /
10 a position in.this~ plant, ,
I rnean, there qd no bias;in.the.
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11 questions. There is no bias in analysis.
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13 I' rn getting an echo in it. I understand tht?se are line-of-f...
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15 A (Zeigler) Okay. I don' t believe there is any bias
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16: in the questions that I participated in designing, nor in the 17 analysis thet I ran afterwards. <
18 A (Cole) And, f urtherraore, 'let rne add that if I had ,
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19- been hired by the NRC to conduct the study of how people in the 20 Seabrook EPZ would have behaved under a certain kind of 21 scenario, and if they had Di ven rne the EDS messages, ubs/
22 questionnaire would have been identico1.
23 Q If you were hired? , I f )
24 A (Cole) If I had -- the NRC could havn ,c3rna to me and 25 they could have said, Dr. Cole, we would like ydur company to ^i
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6 New H arry ch .'. e , (*.c'NRC, or any other i1is.t would have bee, .
7 identi'M c.nudfar i as those questions wt, e concerned, V /
j 8 Ch Well, you would tf,ee used t h e 'f io e' iat.; questionnaire, t
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10 A (Colq) flurdon rne?
11 R You would have itse t!, , ,h ,1; ye t , e.t .. ' used it'l bhoreh ara,
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r 13 4 i (Cele) No, we d i d e', t ete wN, t we i-sed ' ot > 'inoreh ara.
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'5 !We used N/atain knowledne tha: we had gained froro Sh o r g O ro as l', far an how i.o do ;wrt ir lar V ndo of q u ent . t i , .5. F. .t , ne, we
, , 16 wouiJ have desitp A the (p .eu th .ana i re to answer ;he specific
, 17 q;. est icp i concerni ng this parttialar aree, this FiP Z and t +10 g 18 schnaviu that W ++ Were g i v e.n , the EDS rt' e s s a g e. , .
l19 ^Q We32, I're confuzad now. You nay that if t he NRf' *aine 20 to you, or if Pubin 3ervice came t"? you, you would have i
, designed e,m a c t l y the S F.me survey at d the carne questionnaires?
g 22 4 (Cs ' It > I'rn not saying the enti-e survey. I ' to saying 23 in t hef s .iest, ons regarding, let's say, evacuation. I ra : an, 2f l
2 '+ the N/,C had 'orn e to rn e , they rtight hcve had uvme d i f , ert, at
.- : - 2b questions. They eight have bi en 2nterec y.; e d in come th gn t hat e
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11 U. 16 would be inore corrdct to say that the survey was 12 what people. thought -- .how- they thought they would act rather
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F 44 A (Cole) How they said thUy wou;d react if.this --
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now they said they thought they would react is what-i l'G w' ihe .Nddit is.
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- a. 7, - A i (Cole) "t hought ". - I don' t i s IN think the word " thought" is in 'ths rauest ion. We asked t hern
- f. i9 what wduli you do, and this is,bhat they told us they would do.
20 Now if you want to i nt er.j ect the word " thought",
1 l 21 that's your priviiege.
22- Q ' Cut that didn' t[ change the rneaning, as f ar as you' re l
l-d3 concepned?- ,
! J 24 [ A ,
(Cole) , o, not as fur an I' rn concerned.
1 i C'$ ti 'Now, aftop the first rneeting, Stephen Cole, it says, l
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1 y[ .ZEIGLER, JOHNSON, COLE - CROSS 7933 l
1 and-Ann Cole drew up a: draft of the. quest 2onnaire which was 1 1
2 distributed to the Attorney General' u ' consultant and to Mr. -!
- 3 Fierce, ' correct ? ' On the bottom of that -- I guess it's the 4 continue --
5 A (Cole) Yes, that's correct.
l 6 Q -- at the end of the continuation of the paragraph.
'7 A (Cole) That's correct. {
8 Q And this is the kind of questiorinaire that you would- 'l 9 have Davon to Public Service of New Hampshire or to the NRC i f;
/
10 either of those entities had come to you and ask you.to do the-11' same work.
12 A (Cole) Let me reiterate what --
r- ,
4 13 Q, Is that true?
.14 A (Cole) I can' t answer that yes or no, because it's 15 an unclear question.
p 16 Q All ri Dht.
17 A (Cole) Let me reiterate what I said before.
18 If they had come to us with these same set of 19 questions, the same set of research questions, then the 20 questionnaire would have been identical.
l l 21 It's quite possible that if the client had been the l
l 22 NRC or Public Service, New Hampshire, they might have had some 23 other -interest. They might have had some other questions that L 24 they were interested i n. Then obviously the questionnaire l
25 would have had to have been different to cover their particular l_l l
1:
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- 1: research questions.
1 2 But if they had corne into rne with the sarne- set of l 3 questions, then the quest ionnaire would have !been the sarne. We 4 designed the.best, roost nonbiased questionnaire that we could 5 possibly design,.and this.is the best that we could do, and.it 6 would have been the sarne no rnatter who the client had been.
7 Q What was the set of questions'that was presented to 8 you?
9' A (Cole) 'I don' t. have that at rny fingertips. But 10 each --
11 Q Dordt.you have a. record of it sornewhere?
12, A '(Cole) No, I don' t , no, not now.
's
- 13. Q You don' t ?
14 A (Cole) No. Each person --
15 Q This is the whole basis for setting up the 16 questionnaires, and you' ve never preserved a copy of it? ;
1 17 A .(Cole) It was unnecessary to do that. We don' t la preserve all these notes and papers. We'd have rnassive files.
19 7 rnean, for exarnple, Don ZeiD ier was at the rneeting. Don 20 Zeigler said that he needed certain infortnat ion to do his f 21 analysis. We then drew up a draft of the questionnaire. '1
'22 Once Don Zeigler said that that quest ionnaire raet; his 23 needs, we didn't have to keep a record of what he said at a 24 ra e e t i n g . I rnea n, the questionnaire speaks for itsolf. This is 25 what he said he needed. !
O.
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pc r l }y . ZEIGLER, JOHNSON,. COLE - CROSS 793:r l- .
1 The people at.the Resource 'Systerns Group gave us a .!
2 wholo list of infortnation that they needed, a large list of I 3 infortnat ion that they needed. And we drew up the l
4 questionnaire. Then'they agreed that this questionnaire.wou'Id 5 provide thern with the . necessary infortnation that they needed to I
6 raake their analysis.
7 Once'all.these people concurred that the 8 questionnaire had in it the infortnation that they would need to 9 do their analysis, there was no need to keep notes at a 10 rneet i ng.
1;' Q And their analysis was intended to, support their 12' contentions.of the' Interveners, and as were, joined;in by the h 13 Attorney General; i un' t that correct?
14' .A (Cole)- I would not like to put it " intended to 15 support". My analysis was intended to find out what people 16 would'do if there was an accident at Seabrook. I don' t know 17 what their analysir, was intended to do, but presurnably their 18 analysis was. also airned at answering sorne quest ions relevant to 19 evacuation planning for the Seabrook plant.
20 A (Zeigler) Yes. I rni ght say that Dr. Johnson and I 21 have broader research interesta in inind than just Denerating 22 data to serve the State of Ma.ssachusetts.
23' I rnean, we were interested in finding out what people l
24 would do in the event of an accident at the Seabrook plant. l 25 Thib is a line of research that we' ve been f ollowinD over I Heritage Reporting Corporation (202) 628-4888 H
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l I) ZEIGLER, JOHNSON, COLE -CROSS 7936 1 several years, j 2 O Well, you already knew in your own mind'what that 13 answer would be, didn' t you?
4 'A -(Zeigler) Well, we had some hypotheses that we had j 5 been working on over the year. j 1
6 A ( Co'l e ) Like any good research --
7 Q And.you were just trying to confirm that hypothesis, 8 were.you.not? ,
a 9 A (Johnson) We were testing the hypothesis. I think 10 it borders on irresponsibility for a good social scientist to i I
11 ~ say that he's trying to confirm something. That's not I 12 objective research. We.were testing a series of hypotheses l
. =1
.)
v- 13 that we had been working on for the last seven or eightuyears. -)
1
-i 14 I might add that.those hypotheses were derived from l 1
15 what actually happened at TMI.
We were one of the first teams 16 to conduct research there. And for the laut seven or.eight j i
17 years, we have been building upon-that research. We have been l
18 establishing a serious research record of both theoretical and 19 empirical significance. And that's revealed in the survey that 1 l
20 Dr. Cole and his organization did on the behalf of the '
21 Massachusetts Attorney General's Of fice. i 22' O The TMI research i s, you say you were the first to do 23 a survey, is what we discussed yesterday as far as Chapter 37 24 A (Johnson) That 's -- we d id the first survey, and i.
25 we' ve also analyzed the surveys done by Flynn for the NRC. We 1
l'
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1 have published-work on that survey as well.
2 .Q All right, Dr. Cole, apparently there was a second 3 day-lonD meeting in Boston on April.ist to enew the initial 4 draft?
.1 5 A (Cole)' Yes.:
6 O And were Drs. Zeigler and~ Johnson attendants at that 7 meeting? j 8 A (Zei D1 er) No, I wasn' t ? l 9 A (Cole) No, they weren' t.
10 Q What was discussed at that second meeting?
l_ 11 A (Cole) By that. time we, as says in the appendix here l'
12 in Page 50,: we had a draft of the questionnaire. 'And at that IL . '
13 meeting'all of;the people present;went over the questionnaire l 14 and discussed whether or not the questionnaire, the way it.was
'15 set ~up and'the questions'that it contained, whether this l
l 16 questionnaire would provide them with the necessary information l
17 for them to conduct their analyses.
18 Q And what was the necessary information that they told
'i 19 they needed?
20 MR. TRAFICONTE: Asked and answered.
21 MR. LEWALD: I think we' re now in the second meeting. ,
22 JUDGE GMITH: Yes. Overruled.
23 THE WITNESS: (Cole) As far as I am concerned, the l l
24 information that was -- j i
25 '{
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I" l( '2EIGLER, JOHNSON, COLE'- CROSS 7936 1~ DY MR. LEWALD:
n 2~ Q .Do you know what they told you? Do you have any.--
3 MR. TRAFICONTE: Let ' s let the witness answer the 4 question'if you are going to put it to him, and you' re allowed 5 to put it to him, let's have . him answer it.
6 THE WITNESS: (Cole) The'y didn' t tell . me anythinD. 1 "7 wasn' t at the meeting. They told the representative.of my l 1
l 8 company. They'went over the questionnaire. The information l .. .
'9 that they needed essentially was the same set of information ,
l- l 10 that they had laid out at the beDinninu, at the first meetinD-( 11 And then the purpose of the second meeting.was to go over, .and t
l' 12' now we had a draft of the questionnaire. . We just weren' t
,Q' v' 13 talking about abstract, we need information on this, we need 14 'i nformation'on-thac. We had a draft of the questionnaire whiclS 15 was designed to obtain this information.
16 They then went over specifically the draft of this L
11 7 questionnaire to discuss whether or not it would be adequate to o
18 give them that information. 'This is a procedure which is 19 always followed in design of the questionnaire. You always 20 desiDn a draft of the questionnaire, and then you have to Do 21 over it with people who are going to use this information to 22 find out if the questionnaire is adequate.
23 Then there are other procedures that you have-to-24 followed, like pretests which we did and are reported in the 25 technical appendix.
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1 BY MR. LEWALD: '
2 Q And do these people with whom you are consulting have f 3 an expertise'as.to whether or not a questionnaire is adequate?
4 A- (Cole) -Some of them do,. and they have - they 5 certainly~know what information they need, what questions-have 6 to be answered. We were --
. 7 Q They know what informat ion they' re looking'for, isn' t I:
8 that what you' re saying?
9 A (Cole) .They know the questions that have to be ,
10 asked. They, don' t necessarily know the. answers.
11 JUDGE LINENBERGER: Excuse me, Mr. Cole, but I would 12 just like to'quickly inquire, what year are we talking about ~
? - 13 for these happenings we' re discussing ri Dht now?
14 THE-WITNESS: (Cole) It's April of 1987.
L 15 JUDGE LINENBERGER: Thank you. Sorry, f,
f 16 BY MR. LEWALD: 1 1
l I 17. O Well, the upshot of that second meeting was that a 1
l 18- second draft of the questionnaire was prepared and mailed to 1
19 all the consultants, correct?
20 A (Cole) That's correct, yes.
21 Q And at this point you say a small pretest of
[
.22 questionnaire was conducted on April 3rd?
L 23 A (Cole) Yes.
l I
24 0 .Just what was done in that pretest?
1 li - ,- - 25 A (Cole) We took the questionnaire, we used some
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l 1 rsndom' numbers from the people livinD in the Seabrook EPZ,:we i
a dialed them, and we interviewed them just as we would in-the i l I j- 3' regular survey. We went through the interview to see whether l l
L 4 the questionnaire could be administered; whether it was smooth, 5; whether there were quest ions that ~ people didn' t understand, how 6- long it took to administer on the telephono,. normal kinds of.
7 things that you always do in a pretest before you do a major _
l 8 survey.
9 G Now, by we, do you mean SDA?
10 A (Cole)' And that most competent, or that I know, all' 11 competent researchers and survey research, they_all follow !
12 essentia11y'similar procedures. They all do drafts of M k/ ' ..13 questionnaires, then they do pretests,- and then.they come up 14 with their final instrument.
15 Q Did you miss my question?
16 A (Cole) perhaps.
17 G l' asked you who did the calling.
18- A (Cole) Who did the calling?
4 l
19 Q Yes. 1 1
20 A (Cole) Employees of Social Data Analysts. I 1
21 Q Now after this, another conference was-held, this i
22 time by telephone, according to your -- !
I 23 A (Cole) Yes.
24 D -- chronology?
i 25 A (Cole) That's correct.
.D.
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ZEIGLER, JOHNSON, COLE - CROSS 794; 1 Q And you say each consultant participating in this 2 call reviewed the questionnaire and then relayed suggestions 3 and comments back to Social Data Analysis.
4 Were you a party to any of this?
5 A (Cole) Excuse me, 1 don' t understand the question.
6 Q Were you a party to any of the conference call 7 callers?
8 A (Cole) I was not in that particular conference call, 9 but I was a party as far as the final design of; the 10 questionnaire Does-11 Q Well, based on the suggestions, you say another 12 questionnaire set of questions was dessloped?
v 13 A (Cole) Another draft of the questionnaire, it says.
14 Q And this time you decided that you should conduct a 15 pretest with 100 random cases?
16 A (Cole) Yes.
17 Q And you say this was done by MKTG.
18 A (Cole) Correct.
19 Q Who are they?
20 A (Cole) They' re very --
P1 Q Or who was it?
22 A (Cole) Sorry.
23 Q I correct my question to who is it.
l 24 A (Cole) Oh, Marketing is a large corporation located 25 on Long Island that does nationwide telephone interviewing for
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ZEIGLER, JOHNSON, COLE - CROSS 794F 1 most of the major survey research companies in the United !
2 States.
3 Q You or Ann Cole have had some affiliation with 4 Marketing?' i
-5 A (Cole) No. $
'1 6 Q None whatsoever? /
E265 7 A (Cole) No. I 1
T266 8 Q Now, following this, you say an extensive telephone .i 9 contact with the Massachusetts Attorney General's Office, the l 10 final, nomewhat sho'rter version of the. questionnaire was 11 prepared, is that --
12 A (Cole) Correct.
' 13 ' ' Q' Now, by shorter version, do you u.ean that' some of the L
14 questions were abridged, or eliminated, or just.how was it
[ 15 shortened?
16 A (Cole) Some of the questions were deleted.
l 17 Q Did you save any of the drafts of the early l 18 questionnaires that --
l 19 A (Cole) No.
20 Q You threw them away as soon as you proceeded to the 21 next level, is that what I understand?
22 A (Cole) Correct.
23 O Pld anybody instruct you to do that?
24 A (Cole) Instruct us?
25 No. We normally do that. We just can' t keep --
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1 L ZEIGLER, JOHNSON, COLE - CROSS '7943 1 Q. That's your normal procedure?
L 2 A (Cole). Yes.
3 O So that.each time you start developing a new 4- questionnaire you start from a complete new: slate? .You don' t
- 5. have any of the old. material?
6 A (Cole) I don' t understand the question.
'7 O You don' t understand-the question. Well, I won' t 8 pursue it.
9 Could we -- let's turn over to Page 40 of the 10 technical appendix.
11 A- (Cole) Yes.
12l Q Now, ' I' m assuming that following your development of y%:
$2 13 the questionnaire and the kind of data that,was going to be 14 compiled by Social Data Analysis, that you next turned to some
- 15. method to go out and get that data; is that your statement?'
16- A (Cole) Yes.
17 O And so you looked to some sampling procedures.
18 A (Cole) We were working on the sampling all along.
19 Once we decided that we wanted to do a random sample of EPZ 20 residents, we started our sample. design procedure. And then p 21 after we did that, we contracted with a company to act ually l~
22 draw the sample.
(
l
! 23 Q And have you worked with the company, Survey 1.
l 24 Sampling, Inc., of Fairfield, Connecticut; in that true?
L ,
25 A (Cole) Have 1 usad it before as a subcontractor?
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() ZEIGLER, JOHNSON, COLE - CROSS 794L 1 Q Did-I ask you that? {
2 A (Cole). Did I'-- your question is unclear. .Did I' 1
1 3 work for it? Have'I worked with . it"? -What does "with" mean?
4 l' m sorr' y.
5 JUDGE' SMITH: If you don' t understand the question, I 6 you arefjust free to say you don' t understand it. !l
'7 MR. LEWALD: All ri Uht,..letJme rephrase it. ]
8 JUDGE SMITH:. You' re ent it led to understand any 9 question that is put to you.
l-L 10 BY MR. LEWALD:
l l 11= Q On PaDe 40, you say, the sample was selected by L i l-12 Survey SamplinD,. Inc., of Fairfield, Connecticut, under'the
( .
D. 13 direction of Social Data Analysis. .
/ 14 How did you choor,e Survey Sampling, Inc., or why did-
-1 15 you choose it to do this?
l o 16 A' .(Cole) Well, Survey Sampling in one of the most,.the 17 11 Nest and best known, and one of the companieu with the best 18- reputation for drawing telephone samples. We have used them q
-j 19 before on many surveys, and they have always'done a very good j 20 job, and they are very efficient. They are an excellent i 21 company.
- l 22 Q And do you have any affiliation with them?
d3 A (Cole) No.
24 Q Does Ann Cole have?
25 A (Cole) No. l L
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~ZEIGLER, JOHNSON, COLE - CROSS 794S 1 Q- Now, you say the survey was baned upon a stratified 2 random sarnple of households with residential telephone,
[ 3 correct?
t 4 A (Cole) That's right.
E266 '
5 (Continued on next page.) I 7 .)
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ZEIGLER, < JOHNSON,. COLE - CROSS 7946 T267MB 1 Q. Now, you say data obtained frorn local telephone a cornpanies - indicates that ' approxirnately 95 percent of the 3- residents of the EPZ have telephones in their hornes.
4 Where in. your test irnony of the survey data here 5 presented, does that kind of data appear?
G A (Cole) What' data?
.7~ Q That 95 percent of the residents of the EPZ have 8- telephonen in their horne.
9 MR. TRAFICONTE: Other.than at the location'that you 10 just read?
11 I arn a little puzzled by the question.
ll . 12 MR. LEWALD: If the witness has sorne probleras with . it,
- 13: I will rephrase it.
1 THE WITNESS (Cole): It appears right here, on Page
-14 L
15 40 of the technical appendix. .j j' 16~ ' BY. MR. LEWALD: 1 l :l I. 17 -Q That is what it says, but where is the data, itself?
i: 18 A (Cole) What data?
I' l-19 Q That 95 percent of the residents of the EPZ have-I l 20 telephones in their horne? i 21 A (Cole) This is what was told to us by =
22 representatives of the local telephone cornpanies, i
23 0 You picked up the phone and said-how rnany residents j 24 in tha EPZ?
25 JUDGE SMITH: Do you really quarrel with that fi Dure?
I 1
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'( ) ZEIGLER,-JOHNSON, COLE - CROSS 7947 1
- 1. MR. LEWALD: Pardon?
2 ' JUDGE SMITH:~ Do you really quarrel'with that 3 statement?
4 Do you quarrel with the statement?
]
5 MR. LEWALD: I am looking for the backup for_the-6- statement. If there . isn' t any backup --
7 JUDGE SMITH: Do you'believe or not believe as you 8 are cross-examininD, that approximately 95 percent of the 9 residents of the EPZ have telephones-in their homes?-
10 MR. LEWALD: I - don' t know, I don' t know.
11 -And I was just looking for the data that would backup 12 that statement.
13 JUDGE SMITH: You don' t know.
14 Did you have discovery?
15 MR. LEWALD: I am sorry.
16 JUDGE SMITH: Did you have discovery on this' issue?- j 17 MR. LEWALD: I don' t understana you.
I 18 JUDGE SMITH: All right,.never mind, proceed, y 19 You don' t know what discovery is?
20' MR. .LEWALD: I know what discovery is.
21 THE WITNESS (Cole): The way we_obtained this
- 22 information --
23 MR. LEWALD: I am satisfied if he, i f that is the f- 24 source of his information, he picked up the phone and he' asked l- 25 somebody at the Phone Company and this is what he got, then all L O-I Heritage ReportinD Corporation l (202) 628-4888 1
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i ZEIGLER,oJOHNSON, COLE - CROSS 7940 l' right. l
.2 JUDGE SMITH: Just proceed with your cross-3 examination. 3 4 BY MR. LEWALD:
]
5 Q Dr. Cole, do you know how many households in the EPZ 6 do not have telephones?
L 7 A. (Cole) Somewhat less than 5 percent.
8- Q In terms of' numbers? l l
l 9 A (Cole) I would.have to take a calculator and do 5 l
l' i 10 percent of the total households. As fat an I remember, there L
( 11 are something like, what 30,000 households in the EPZ. And you l
l 12 have to take 5 percent of that.
l 1
t ' 13 Q And this would be how you would-determine that?-
14- A (Cole) This would be an approximate estimate,'yes.
15 Q 'Now, you say that you want to interview a total of l
1" L
16 1,400 residents of tho IPZ?
17 A (Cole) That is correct.
18 Q Why 1,400?
19 A (Cole) We decided that was the larDent sample that 20 we could afford to interview for this survey. I 1
21 Q And this was the governing factor, money, as to how j 22 many you would -- l 23 A (Cole) No, there is two factors.
24 One factor is how many interviews do you need to have 25 an accurate sample, the n: ore interviews, the better, but up to )
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1 a -- at a certain point, you get a point of dircinishing 2 returns.
3 You can interview rnore people but it d oesn'. t 4 substantially increase the accuracy of your survey. Wu felt 5 that this sarnple of 1,400 would be a very accurate 6 representative sarnple of the EPZ and it was . sornet h ing that --
7 it was the -- it was to go above that we felt that the added '
l
- 8. cost would not be beneficial in terras of the very, very slight 9 additions, a reduction in your uarnplinD error that you rnight 10 obtain.
11 Q Now, you said earlier, this was a stratified sarn p l e.
12 A (Cole) Correct.
13 Q So, and what does that rnean in this case?
14 A (Cole) It rneans that. we are really doing randorn
'l 15' sarnpler within each of the 23 towns; 17 in New Harnpshire and 16 six in Massachusetts.
17 Q So, even though you had nurnbers for individual towns, 18' you considered the sample, itself, to be 1,400 and not the 19 nurnbers for each of the towns? {
20 A (Cole) Depends upon what you are doing with the 21 data. If you are usinD the data to generalize about the EPZ, i
22 then the sarnple size is 1,400 and practically all the results 1 23 that I rnad e use of, in roy testirnony, dealt with the entire l
l- 24 sarn pl e, 1,404, and were Generalized to the EPZ.
l-l 25 If somebody were goinD to raake a generalization about l
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<7950 l 1 a specific town,- then, of course, the sample would be those 2 people interviewed-living in that town, r
'l 3 Q Suppose that someone were trying to test the 4 reliability, then_would'you use 1,400 or would you.use the j i
5 town,.the numbers'in the various towns? I 6 A (Cole) .The accuracy of the sample, in so far as it' 7 is' generalizable to the EPZ population?
8 Is.that what you are asking?
9 O In each'of the towns.
10 A (Cole) In so far as the sample is generalizable to 11 the population of the EPZ, you would use the number 1,404.
.12 Q Now, atlthe bottom of.that page, you say that since. 3
.1
[L -13 telephone exchanges do not correspond exactly with Geographical .l 14 boundaries in thestowns'in the EPZ, you had to.use-a more 15 complex procedure to draw the sample of telephone numbers'.used~ ,
16 in the survey.
1 17 And then from this you say, from local telephone 18 directories, we have obtained the list of zip codes for every 19 town in the EPZ.
20 Is it significant that you were looking at telephone 21 directories for the zip codes of every town in the EPZ, or Were 22 you just looking for the zip codes? )
23- A (Cole) We were just looking for the zip codes, and
)
1 24 this was a convenient way to obtain them. 1 l
~25 0 And in the Yellow Pages you find a listing of these j
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i 2 4 (Cole) To my knowledge, they are in the' front part 1 i
'3 of~the White pages.
4 Q Is that so?
l 5 A To my knowledDe. I was not the one who (Cole)
G collected the zip code data.
7 Q Now, then you say that in order to check that this i
8 list of zip coden was complete, we had Survey Sampling utilize 9 a computer program, which listed all rip codes within 15 miles 10 of Seabrook?
11 A (Cole) Correct.
12 O What was the purpose of drawing a 15-mile radius 1 ('
l '
13 around Seabrook, if I might ask?
l l !
14 A- (Cole) Well, it was my understanding that there were 1 l
15 nome towns in the EPZ, that a portion of the town was within 10 l-l 16- milen of the plant, but the rest of the town was outside of 1
l 17 that 10-mile zone.
18 That the EPZ, as I underutand it, was not just cut i
19 off at a lo-mile radiue. It includes towns that have portions f
20 of the towns in the lO-mile zone, and portions outside.
l 21 Q So the EPZ border would be an irregular border r l 22 following the geographical or political lines of the towns, any 1
23 part of which were in the EPZ? i 24 A (Cole) Ae I understand it, yen.
25 0 Ncw, do I understand your procedure was to use the i HeritaDe Reporting Corporation ;
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- s, ZEIGLER, JOHNSON, COLE - CROSC -79S 1' - zip codes as surrogates for the towns themselves,-in conducting i
2 your, or for setting up the sample?-
3 A (Cole) Yes.
4 We are using the zip codes to help generate the 5 sample.
F 3; 6 Q But you were using a' rip code only to idertity a-7 particular town, i 's that correct?
8 A (Cole) Yes.
9 Q And you could have used the name of the town, rather s
10 than a zip code?
11 A (Cole) No.
12 -Decause names of the towns are not in the Survey 13 Sampling data base. The alp codes are.
I 14 Q There,is already_in the --
15 A (Cole) The zip codes, all.the rip codes are in the i h
16 Survey Sampling data base. The data base that they used to
'17 generate the sample. The names of towns aren' t.
1 la O So this is the reason why 2ip codes were used as 19 surrogates?
20 A (Cole) Yes.
21 Q All right.
.22 Now, going on down on 41, I don' t know if you can ~~
23 you say for most, for each zip code within the EpZ Survey 24 Sampling Denerated a list of telephone exchanges.
25 And then for most of the exchanges that appeared on Heritage Reporting Corporation (202) 628-4888
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) ZEIGLER, JOHNSON, COLE e CROSS 795: ,
1 the list, all of the nutobers were i t, the EPZ. !
2 Gorne exchanges, however,- contained nurnbers of people
~3 . living inside the EPZ and nurnbers_of people living outside.
4 This is as your explanation reads,- correct? j i
S A (Cole) Yes.
-6 O Now, in order to aetermine whether or not to include 7 a particular exchange in the saraple, you say you looked atthe f' S total propovtion of the phone ' nurnbers in that exchange, which-9 are inside the EPZ as deterrained by the zip code.
l- .
- l. 10 And then if 15, or more of the numbers, or 15 !
11 percent, excuse me, or more of the numbers in a particular 12 exchange were inside the EP't. that exchange was included in the
!-O .
13' sample.of generated telephone numbers, correct? j 14 A (Cole) Yes.
15 R Now,' what happened to the remainder of that?
16 A (Cole) What do you mean, an exchange that.had less I-17 than 15 percent of the numbers --
18 Q - yes.
19 A (Cole) -- in the EPZ, they were excluded. !
l 20 Q Is the, does the, anywhere is - let ue - .does the i 21 survey, anywhere within it, discusc the magnitude of the 4 2P exclusion of these towns that had less than 15 percer.t?
23 A (Cole! No, but they were a very, very small number 24 o f -- no t towns, there-were not towns that were excluded, all i
)
25 the towns were included. l l t O i J
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-1 Q The exchange.
2 .A (Cole) But the number' of ' resident s that were 3 excluded were a very, very tiny number.
4 G Do you have that number?
1 $I A (Cole) .I don' t have it here, with me,-and'it is hard l
l
[ 6 to estimate whet it i s, but it is based upon my experience in 7 analyzing-these kindt of data. I would outimate that it isLa 8 very, very small number.
a l l; 9 If anything, we over-included. We included a zip -- !
v 10- exchanges in our. sample, in which 80' percent of everybody in l 11 that exchange were outside the EPZ.
l-h la Q But these towns, these areas that you' excluded were
{) 13 on the very peripheral or the boundary of the EPZ?
14' A ' (' Col e ) Right.
15 Q And you attach no significance or bias to that, that 16 fact?
17 A (Cole) I am absolutely sure that if we had come 18 method of getting every single residential telephone number 19 into the samplinD base, the results would have been virtually 20- identical.
21 Q All right, at the very bottom of Page 41, you say, I 22 Survey Sampling then calculated the total number of residentic.i ;
1 23 phones in all the exchanges included in the sample? !
24 A (Cole) Yes.
I 25 Q How was this sone?
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b ZEIGLER, JOHNSON, COLE - CROSS' 7955 1 'A' (Cole)' They have'a list. It is on a computer. They 2' have every single number in that exchange. They,have data 1on 3 the number of: residential exchanges in-every single exchange.
4 Q' Have.you got, do'you have any information as to how
'5 that information was' derived, in so far as arriving at a number 6 of residential phones concerned?
7 A (Cole). I don' t know exactly how they do it, but I 1
know.how 1 have done it for samples that I have drawn myself,
'8 1
J 9 without their assistance. R l
10 There are, for example, on Long Island, there is 11 something called Cole's Directory which liste all the telephone
.l '
12 numbers and they tell you exactly in that directory how many 13' residential numbers there are in each exchanDe*
14 Presumably they obtained it . frors the Telephone i
15 Company and I am not exactly sure how they get it.
'16 Q It is.your understanding that this is another 17 telephone call to the Telephone Company?
18 A (Cole) I was told by one of my colleagues that the 19 Telephone Companies sell it to them.
20 Q Oh, they sell it?
21 A (Cole) They sell this information.
22 A (Johnson) You can buy the information from the l 23 Telephone Company.
24 Now, there is also something called, address-first
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l 25 telephone directories. )
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1 ZEIGLER, JOHNSON, COLE - CROSS 795b i There are address-first telephone directories.that 2 list every telephone number on a block and indicate whether 3 they are residential phones or business phones.
4 And a lot of survey companies une those address-first 5 telephone' directories.
6 JUDGE SMITH: They.certainly co.
7 BY MR. LEWALD:
8 Q Now, in the -- you then go on to say that nu'obers W were selected in such a way so that the proportion of numbers 10 inJthe sample, in a particular exchange would be the same.as l 11 the proportion of numbers in the population in that exchange?
12 A (Cole) Yes.
13 Q Do you understand how that procedure _was or-what that l
! 14 procedure was?
1 I
l 15 A . (Cole) I understand it, yes, l
[ 16 Q And is.this, can you tell us how this is done?
)'
L 17 A (Cole) Very simple. If they find out,_for example, l-(:
18 that one percent of the entire population that we are dealing 19 with lives in a particular exchange, then they pick, they make 20 up the sample so that one percent of the sarnple has that l
21 exchanDO.
! 22 They draw one percent of the entire body of numbers, 23 over 6,000, in this case, from that exchange so that the number 24 of numbers, the proportion of numbers in each exchange o 25 corresponds with the proportion of population living in that O '
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4 h ZEIGLER, JOHNSON, CULE - CROSS 7957 1 exchange.
2 'O Now,. you go on to say the sample utilized is a random
.3 digit sample,'in which the last two digits in the telephone 4 number are selected at random'by a computer,' from among all 1 5 those working blocks in a particular exchanDe-1, 6- Now, I understand that you are taking discrete i
l 7 exchangen and taking blocks of numbers that have been issued by L 8 the phone company and takinD this entire block and then running'
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9 a.two-digit number, the last two digits of all of the telephone l
1 10 numbers in that block, to determine the sample,- in that l
11 correct?
12 A (Cole) More or less, yes.
v 13 Q That is the D ist of what --
14 A (Cole) Yes.
15 Q Now, you go on to say that even though utilizinD this 16 relatively complex procedure, it was still impossible to know 17 whether a particular phone number was for a household included 18 in the EPZ.
19 So, you had a double check on this and when the 20 interviewer called the number, it, he or she auked the person i 21 in what town he or she lived?
l-22- A (Cole) Yes, l.
I l- 23 Q And you say that as interviews were coupleted with
(
l 24 respondents in each town, you kept track of the number of l 25 completed interviews until you reached the designated quota for i.. O-Heritage Reporting Corporation (202) 628-4888
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2 And what happened then?
3 Was.that town-just crossed off?
A (Cole) Yes.
5 Q How would-the interviewer know that a quota had been 6 reached?
7 A (Cole) The supervisors.would tell them. 'They woeld 8 be givinD out the samples.for the various towns.- 'As I said, it 3 was a stratified random sample. lhat means that there were 10 sections of the nample.for each totn. j t
11 So we would hand out te ephone numbersb c!, let's
./-
12 say, Seabrook and'once we had corepleted the number vf J y .f
. . 13 interviews that.we had priorly der 3 Dnated to t;e e4[r4 eted in / ( 'y 1 t 14 Seabrook, we stopped. C I i
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.. 15 We collected back1 the. sample chentu~from the u l
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L 16 interviewu, _and we would hand o'ut sample sheets for another l '17 town.
l 18 Q Now, on PaDe 43 of the Appe ndix, you say that the 19 samp;e you utilized in this'seqvey is'a random sample of 20 households with residential te3ephones, not a random sample of I 21' individuals.
lL ,
22 And then within.the household, you Do on to say, we 23 utilized either the male <or female adult-head of h( e household ,.
24 as an informant on what ihe hoasehold evuld do in case of; an 25 accident at the Seabrook Nuclear Powder Station, correct?
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1 4 ts.asehold.
i 5 And t h er, following thisp it c ay s., a sex quota w.rn r j used to ensure what the final santple wo a d represent, e x c uar- 1 i )
7 me, a sex quota rah o med to ensure that the final namplo aould
. G represent 4.10 po",ulation in terms of sex.
9 , Now, how 4 ;u i .: the interviewer know t tr at a sex quota I s 1 1
g 10' ghad been reached for 4 p a r t i,*: .1ar town? j 11 4 (Cole) The A deri iewerG are given particolar in p 12 instructions. The way that it in normal 1y done in you tel1 an
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p 13 interviewer i..at;they have to '.Tep tracN of 't ne nurnbee of men l
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// 14 and women t ', a t they have interviewed.
..1Ba ..# 15 Onf if an interviewer han interv:eeed two or more 16 tomen, than si:e hau men -- let'r.nay slie han interviewed three i7 women and one nan, the next person that interv2 ewer i nt erv i ews e -.
18 t' a s to be A man.
s -
19 7.'i a t is how a rot' ma l 1 :, r o the e e c quota.
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20 f) %' when the quota in reached on either side of the 21 sux m t:. . e -Ai i o n, thno rou jubt a s ti r.uryst i cnn of the other Le x,
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22 urtil s cle quota i .; filled up?
- a. 23 -. [j
', C o l e ) Thad would only happen at t, h e very end of the a
24 survey. fs ut sincu we are keeping the quot a thcoughout the RF interview.ng, we rver, we always have it roughly b a .l e n t e d .
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[*y 2 the ,Sdrhey damhliNg rnethods 7t,h at were used?-
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(Cole) Yes.
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we r.'ould go back, you say the survey is-a L
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randon Whinplelof hpuseholds with residential telephonnu.
w 9' Not a randorn 3 ample of individuals. But' isn' t the
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- i 3 . U AnQin households that contained more-than.one head, 14 there was no random samplict)' procedure done with respect to i b .. which head would be. iniervir
- Wed, is that correct?
1 <>
16 ' A (Cola) .No isr, dom,uample, because as you know there 17- was this~queta raystem that : was ut ilized, that,is correct.
N
'e 18 Q You dropped the randoni- sample and went over to quota 19 , system, is.that correct? ,
.j A !
'14o A- (Cole) For as far'as thb selection of the individual j 3
10' , 21 within a household, yes.
22 O And you would . agree that within the houseriold so far
, . .i 1 23 as there were two heads, that the be l i e i', knowledge, and
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1 A (Cole) Generally we find. correspondence on'a lot of 2 the information that we wanted to obtain in this survey, but it 3 is possible that it could. vary, yes 4 Q- .You say that in test imony , den' s t you, that it.is well
'5 known from prior surveys that the attitudes of men and women 6 toward , issues-like nuclear power, generally differ?
7 A' (Cole) That-is correct, yes.
8 That is why we~used the quota to make sure that we 9 didn' t have.an overly large number of women in the_ sample.
10 0 Well, isn' t the result of this procedure that in 11' those households containing more than'one heed, the sample 12 over-represents those who are at home and willing to' answer the
.p
?v 13 phone?
'14 A (Cole) Yes.
15 But there is no evidence that those people have any 16 different attitudes on any of these questions.
17 Q Well, haven' t you, in your testimony, indicated that 18 it in known from prior surveys, that the attitude of men and l:
E 19 women toward issues like nuclear power Denerally differ?
I:
1 20 A (Cole) But we had a representative sample of men and l-21 women. We have S4 percent women and 46 percent men.
l 22 Q You had a qucta did you not?
l 23 A (Cole) The sample, au far au sex poes, in 1
l l 24 representative of the population.
L 25 O Well, don' t you say on Page 30 of your testimony that 1.
1 1
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1 you should not rely on quotas and you cannot project ' .t o the 2 total populat ion frora quotas?
.e 3 A (Cole) We, our --
"4' Q Don' t you say this'on.Page 3O?
5 A (Cole) If you want rne to' look at Page 30 --
6- D' If you need t o, sure.
7 .A (Cole) I don' t . know what -- PaDe 30 of rny direct-
'8 testirnony or roy at tachrnent, could you refer roe, please? ,
i 9 .Q Your direct t est i rnony.
-10 A~ (Cole) Pardon roe?
11- Q Why don' t we look at the panel's test imony.
12 And I am referring you to the last two sentences, 13' procedure utilized by . the FMR raakes their survey more of a 14 quota sarnple than a randorn sample. In ray opinion, it is 15 dangerous to Deneralize from this type of sample to the 16 population.
17 A . (Cole) Dur sample utilized --
18 Q That is your test iroony?
19' A (Cole) That is rny test irnony.
20 Q Do you want to add something?
- 21. A (Cole) Yes, I would.
22 O Okay.
23 A (Cole) Dur sample that we did it for the Seabrook
- j. 24. survey was des.igned to be a representative, random sarnple of l
L -- 25 households.
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ZEIGLER, JOHNSON, COLE - CROSS 7963 3
1 .We have data on households. 'Within each household'--
2 we have randomly selected a set of households, within each l 3 household we are utilizing either the male or female head of t-4 household ~as an informant as to what that household would do.
~
5 The irnport ant unit,.as far as we were concerned, were j 6 not individuals, 'since families or households tend to'either 7 respond as a family unit in emergencies.
8 The itnportant unit was the household.and we did a 9 random sample of households.
L 10 Q But you don' t have a random sample of heads o.f.
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L .. 11 households, do you?
12 A (Cole) No.
13 I say that clearly in the direct testimony. We'do 14 not have a random sample of individuals.. We are generalizing l
L 15 to households, not individuals.
i 16 ~O And you cannot represent that even the head of the l
I 17 household you. interviewed, represented.the household because l
18 the other head,, assuming there were two heads in the household, 19 most likely was, and indeed, you thought had different views, 20 isn' t that correct?
21 A (Cole) Could you repeat the question, please?
22 (Contirued on the'next page.)
23 24
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ZEIGLER,. JOHNSON,. COLE - CROSS 796L t269 1 .MR. LEWALD: Can you read it' back?
2 JUDGE SMITH Please.
.3 MR.'LEWALD: I think it would be easier if I --
'let i
4 me restate i t' .
.5 JUDGE SMITH: Never rni nd, ; t hen. j 6' BY MR. LEWALD:
7 Q It's t rue, is-it not, that the person interviewed an 8 the head of the household, particular household, 'cannot be.
I 9 considered to be representative even of the household that l 10 participated in the survey.because the responding head.for the 11: particular household differed from the other. head of-that 12 household?
{} 13 A (Cole) I haveL no evidence that-they differed.
14 Q You have no evidence that they are the same, do you?
15 And'indeed it's your position,_and well known that-
.16 the attitudes of snen and wornen toward issues like nuclear power 17 are considerably different; isn' t that correct?
18 I' d like to comment on that, A (Johnson) -I f I might, 19 because it --
20 Q- You can comment after Dr. Cole answers my question. ]
L 21 A (Cole) Our sample is completely representative of l
22 the EPZ population as far as the portion of rnen and wornen )
)
23: living'in that population. So our results are accurate, and l- 24 they are not d i st ort ed by sex differences in the respondents.
25 We have 54 percent of our sample being wornen, and 46 being men. 1 I
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1 According to the census data, that's approximately what exists
'2 in the EPZ.
3 I have absolutely no doubt that if you were to do a
'A random sample of i nd i v i d u a l.s, which I don't think would-be 5 proper in'this' case because we.are interested in the household 6 as.the unit, but I have absolutely no doubt when you do a i
7 random sample of individuals, which I have done in other 8 studies of attitudes towards nuclear power, you would find they 9 are virtually identical results that we found in this survey.
10' MR. LEWALD: I move to strike that as'not being 11 responsive'to anything.
12 JUDGE SMITH: Read the question back. Yes, read that
. 13 last question back.
14 (According, the record was read back by the
- E269, 15 court reporter) iT270 16 JUDGE SMITH: Is that --
17 MR. TRAFICONTE: As heard the question, it asks for 18 his position. He commented on his position as to men and women 19 in the sample.
20 JUDGE SMITH: I think the problem is he went on to 21 challenge the inference and implication of the question that --
22 MR. TRAFICONTE: Households versus individuals.
23 JUDGE SMITH: Yeah, and that there was distortion.
24 In any event, you have asked a series of argumentative 26 questiors, and you' re getting argumentative replies, and it's Heritage Reporting Corporation (202) 628-4888
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() ZEIGLER, JOHNSON, COLE - CROSS .7966 .
1 just exactly what you' ve established.
2 The answer did overreach the question. There is no 3 question about it, but it will remain. You can' t pick and 4 choose in this type of examination.unless it's clearly of f on 5- another subject. If you want narrow answers to your questions, 6 you are entitled to them, but let's make 'it clear as.you l
L '7 progress that that's what you want.
l 8 BY MR. LEWALD:
l l 9 Q We' ll go back to PaDe 22 of the panel. testimony. And 1
10 on the bottom of.that page, in answer to the question, "What L
11 were the results of the survey relative to the evacuation 1 12 shadow phenomenon," you -- the panel says that one of the 13 primary aims of the survey was to find out what residents of 14 the EPZ would do the case of an accident at Seabrook Station.
15 And you say, "Therefore, the survey contained several 16 scenarios-which we read to the respondent, and which we asked 17 them what they would do under such circumstances."
18 Now, you say the scenarios were based as closely as 19 possible on the actual emergency broadcasting system, EBS, 20 messages contained in the plan.
21 And I assume the reason for using emergency broadcast 22 system messages was because these were the messages that the 23 Seabrook EPZ people would hear in the event of an emergency at 24 Seabrook; is that correct?
25 A (Cole) Yes. l l
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1 Q Now the first scenario that the testirnony referu to 2 nays that.it asks residents to assurne that they.and their 3 families were home on a hot Sunday afternoon in July at 2:00' l!
4 p.m., and-then going on skipping the next sentence, and-the EBS 5 message announces that the beaches have been closed and. advises 6 a'11. people on the beaches and'in the state park areau of
.7 Seabrook, Harnpton and Salisbury to.. leave the area immed f ately.,
8 but it does not advise any. residents of the EPZ to take any 9 protective action.
- l. 10 And then you say'to the exact wordinD of the I
11 quention, "See Attachment 5 at Pageu 60-1."
12 Now, I' assume that'the question that you refer in the l-13 questionnaire at Attachment 5 at 60-1 in patterned on the EDS 14 messages in Revision 2 of the' plan; am I correct in that?
15 A (Cole) Yes, I believe so.
16 Q I put before you what is entitled Arpendix G, 17 Ernergency Broadcast System Activation, and then on the left-18' hand corner of that, it says Volume 4. On the riDht-hand 19 co l urnn,, it sayu Revision 2, 8-86.
20 And I ask you i f you' re Denerally f arniliar with that 21 Appendix G7 22 MR. TRAFICONTE: Does counne) have an extra copy of 23 what wan handed out, or give un a --
24 MR. LEWALD: Beg your pardon?
25 MS. SELLECK: He wants an extra copy.
y 5
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--n. l Ej ) ZEIGLER, JOHNSON, COLE'- CROSS 7960 1 (Pause.)
q 2 MR. LEWALD: Your Honor, may I ask that the excerpt 3 from. Volume'4, Appendix G, EmerDency Broadcast System- i 4
.4- Activation, I' ve shown the witness, be marked for l 5 ident ificat ion, as Applicants' Exhibit 28?
6- JUDGE SMITH: What is this at Appendix 2.
7 MR. .LEWALD: Appendix G is an appendix to Volume 4.
'8' I' m ' simply pulling it out of -- actually, it's an exhibit in 9 this case,EExhibit 5, but I was keeping it as a separate j 10 exhibit for thefpoint of convenience in examining the witness 11- on.
,12 It's, as I say, physically a part of what we have ivm 13 already marked as Exhibit 5 in this case.
14 JUDGE SMITH: This will be Applicants' Exhibit 28 for
-15 identification.
16 Do you intend to offer it?
~17 MR. LEWALD: I was just marking it as -- it's already 18 in evidence, Your Honor.
19 JUDGE SMITH: I know. That's what is confusinD me.
20 MR. LEWALD: I was just marking it for identification 21 so we could -- I could proceed and examine the panel on the-22 basis of the scenarios that they present, and the matters that l
23 are contained in this.
24 JUDGE SMITH: So you don' t intend to offer it as a i-25 separate --
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- -1 MR. LEWALD: I don' t intend-to offer it at any time O 2 as'a separate exhibit.
3; JUDGE SMITH: It's not -necessary to D i ve it'an 4 identification number. So all we have now is just a' void in the
~
5- list of exhib'it. numbers. But, nevertheless, proceed with'it.
6 Is that also the casa with Exhibit 27 and 26 for' 7' identification?-
8 MR. LEWALD: I' ll just refer tv it as Exhibit G of
- 9. Volume 4.
10 JUDGE SMITH: Well, refer to whatever you want t o. j 11 I' m 'J ust asking, have you. identified other exhibits that you 12 don' t intend to offer?
^
13 M R. LEWALD: Twenty-six and 27, I would intend to.
14 offer at'some point in time before -- well, I' ll offer.them now' 15 if it's a problem.
16 ' JUDGE SMITH: 'I don' t care what.you do. I just want
- 17. to know, you know, when you give an exhibit a number,'it really 18 should be one that you intend to offer inf.o evidence.
19 Otherwise, --
well, just proceed any way you wish.
l' 20 MR. LEWALD: All right.
21 BY MR. LEWALD:
l 22 Q Dr. Cole, could I ask you if you would turn to Page 23 G-13 of that -- of Appendix G7 24- A (Cole) Yes.
25 Q And could I ask you if you could -- are you familiar 10 Heritage Reporting Corporation (202) 628-4888
] ZEIELER, JOHNSON, COLE - CROSS 7970 1 with that, that EBS message on Page G-137 -l 2 A (Cole) I can' t say for absolute sure. We were given 3 . some EBS' messages to look at, and in order for me to say 1
4 l]definitelythat this is the same as the ones that we were 5 given, I would have to just go over this and compare'it with 6 the copies of the EBS messages that we were given. But it 7 looks very similar. I cert ai nly . -- it ' s probably the same.
8 O And would you have a moment to compare it with what -
i l
.9 you put in the wording of the question in the New Hampshire j l
10 version that you refer to on Attachment 5 at Pages 60-1'?
11 A (Cole) Yes.
12 Q And can you tell us what you left out of the EBS akJ 13 message in your question?
l 14 JUDGE SMITH: We are now looking at Attachment 5, l 15 Page 60 to the technical attachments? What are we looking at?
16 What do you hope that the witness is looking at?
17 MR. LEWALD: The question was asking of -- in 18 essence, asking the witness to compare the wording of.the 19 question in the New Hampshire version of the questionnaire 20 which he refers to on Attachment 5 at Pages 60 - 61, and 21 compare it to the message -- 1 1
22 JUDGE SMITH: What page on Attachment 5?
23 MR. LEUALD: Attachment 5 at -- I' m reading from Page 24 22 of the testimony, Your Honor. 1 25 JUDGE SMITH: Yeah?
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L 1 MR.. LEWALD: And I' m taking the --
2- JUDGE SMITH: Just tell me what page on Attachment 5 3 you are working with.
4 MR. LEWALD: I' m following the reference . Di ven in the 5 't est i mony, Your Honor, and I' m assuming that i t's correct.
6 Maybe I' m incorrect in --
7 JUDGE SMITH: Well, .just tell me what.it i s. 60-1, 8 all right.
9' .A11:right, I have it.. Thank you.
10 , BY MR. LEWALD:
11 Q And'I ask you if you could compare.the messaDe th'at 12' is on Appendix G'with the question that you asked the
~13 respondents that were interviewed?
l 14 A (Cole) Yes.
l-
-15 Q And are they the same?
16 A (Cole) No, not precisely, rx). They are almost the p 17 same, but not precisely.
[18 Q You have deleted certain things, have you not?
f 19 A (Cole) As I can see from -- well, first, let me say, 20 let me repeat what I said before.
21 I am not 100 percent sure that this is the same copy 22 of the EBS message that I was given. But on that assumption, 23 it appears that we have deleted the last paragraph.
24 Q And the last paragraph repeats, does it not, that no 25 action is necessary at this time for persons located in several f
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'ZEIGLER, JOHNSON, COLE.- CROSS 797s f) 1 towns, does it?.
2- A (Cole) Yes, that's what . it says.
3- 0 And you did not think that significant.in~your 4 question?
5 A (Cole) No,. we had already.said that.
6 Q And where did you.say that?
l 7 A (Cole) "At this time there is no need to taide.any '
l 8 action."
9 Q So ou didn' t see any need to say it,apain?
10^ A (Cole). 'That's right, because.'we had to reduce the 11 length of these scenarios. They were too long.
12 0 ~The scenarios were too long?
13 14 (Cole) The EBS messaDes were too long to include the 14 full text of all the~EBS messages ter all the scenarios that we 15' wanted to cover in this survey.
16 Q Well, do I understand that you were putting your 17 scenarios.to witnesses and not the scenarios that were set' 18 forth in'the EDS messages?
19 MR. TRAFICONTE: Objection. I . think that's 20 argumentative, Your Honor.
21 JUDGE SMITH: No. Overruled.
22 THE WITNESS: (Cole) Our scenarion were based upon, 23 based upon the EBS messaDen that were included in the plan.
l l 24' BY MR. LEWALD:
l' 25 Well, do I understand that you redrafted them on (D
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- 1. the --:rTdrafted the rnessages that you thouDht' suitable _to
-l 2 present'in questions to witnesses -- to respondents? ;
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'3 A .(Cole) No, ws did'not redraft t h ern. What we.did was 4 we deleted.what.we' felt'was.either confusing or unnecessary .!
5 i nfortnat i on, but we did not redraft t h ein. - We inade every --
6 possiblu atterr.pt to use the exact wording .Jf the EBS rnessages 7 that we'were.given.
t 8 Q Well, let's inove to the serond scenario ' included in i l
.9 the questionnaire.
,10 And you say the second scenario - this is on Page 23 I G 11' --- t h at the second scenario included in the questionnaire 12 atternpted to find out what EPZ residents would do if the first
'13 scenario were to involve a situation in which.a general i 14 ernerDency was declared. Residents of Harnpton Falls and J
15 Seabrook were advised to evacuate, and other EPZ residents were ]
16 advised to shelter in place.
17 And yvu say for the exact wording of this question, 18 see Question.31 in Attachrnent 5, paDe 62, correct?
19 A (Cole) Yes.
1 20 0 Could you turn to that question on that page? i l
21 A (Cole) Yan.
f I
22 Q And could I direct you to -- in the Appendix G - .to !
23 Pages 30 to 35, and I ask you if that is the EB - rnessaue that 4 l
24 you say you are presenting in Scenario 27 f 25 MR. TRAFICONTE: Could I have a page in the doeurnent LO ;
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, 1. you just distsibutedr Mr. Lewald?
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.2- MR. LEWALD:- Page G-30 to 34.
3 JUDGE SMITH: It cont inues on to Page 35, does it. )
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i 4 not? .I l
I' 5- MR. LEWALDr Excuse rne, 35, too. l
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6 . JUDGE SMITH: That's a rather long one. Do you want.
7 hirn to take sorne tirne to cornpare?-
8 MR. LEWALD: I just asked hirn to look at -
I wasn' t 9 asking hirn to testify to anything. I.was just asking hirn 10 to --
l 11 JUDGE SMITH: To cornpare. I 12 MR. LEWALD: cornpare thern and then I --
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[ .. 13 JUDGE SMITH: It's a four and a half-page raessage. I ;
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14 suDgest that rnaybe we abould take a rnorning break and let l 15 h i rn -~ )
i 16 MR. LEWALD: Fine.
- l. 17 JUDGE' SMITH: -- cornpare it. l l
l 18 Return at 10:30, pleane.
l l 19 MR. BROCK: Your Honor, Matt Brock.
l l 20 JUDGE SMITH: Yes.
l-1:
21 MR. BROCK: In response to the Board's request, I-22 called Sal Guadagua's of fice this rnorning. I was i nf orrned by 23 his secretary that he is at a roset ing in Maine and will be 24 unavailable all day.
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3 'I did check with those two witnesses, though, Vour
.4 Honor. :
5- (Whernupon, a recess wan'taken.)
[E270 6 (Continued on next page.)
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t271mb 11 JUDGE' SMITH: Proceed, Mr. Lewald.
2 BY'MR. LEW'LD: A
,3 3 Q Dr. Cole, I hould ask you if you would compare the l
l' -4 ' language c of'the Question 31, in your questionnaire with the.
- 5. message F, which is on G-pages, the G-30-to-35 of. Appendix G, 6 and ask if you have now had an opportunity to'do so?
7- A- (Cole) Yes, I have.
i 8 Q And.now, if you could turn.to Page 30, if you would, 9 excuse me, G-3O?
10 A (Cole) Yes?
I 11 Q- And'as IEunderstand it, and correct me if'I misstate 12 it,'that your' Question 31 says a general' emergency condition 13 was declared at 3:30 today, at Seabrook Station.
.14 'Is that --
15 A (Cole) That is correct.
16 O Now, this is in relation to --
17 JUDGE SMITH: Excuse me, go ahead.
18 I wanted just to interrupt here, a moment to let the 19 record reflect that SAPL's representat ive has returned, and-the 20 Town of Hampton.
21 BY MR. LEWALD:
22 Q And that a General emergency condition indicates that 23 there has been a failure in the plant safety systems.
24 And then going on, the Question 31 says, a release of 25 radiation into the air occurred at -- and what is the time, is Heritage Reporting Corporation (202) 628-4888 1
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i ZEIGLER, JOHNSON, COLE - CROSS 797'7 1 there a t'ime -- does Question 31 give a time for-the blank that' 2 is on Page G-3O?
3 A- (Cole)- No, it does not.
.i 4 Q 'So'that the time is skipped'in the' quest' ion'and also 5- the following words,.New Hampshire, is that correct? i 6- 'A (Cole) Yes. q 7 O And then the question.goes on to reed, civil defense ,
8- and public! health officials are currently reviewing the 9 consequences of-the release, local weather conditions and1other 10 factors.
11 And then the next block is not chosen,: correct?
12 A (Cole)- The next block of what?
13 Q Of PaDe G-'30.
( 14 A (Cole) .The one, the_ alternative for no release?
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15 Q Yes.
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L 16 A (Cole) No, that in correct.
l- 17 Q And the last paragraph is,in the question, correct?
l 18 A (Cole) Yes.
19 Q And all right, now, on Page G-31, you have deleted '
20 the first paragraph, of the EBS message in your question?
21 A (Cole) That is correct.
22 O And you have paraphrased the second paragraph?
23 A (Cole) Well, we selected two of those towns, yes.
24 O And the same is the case for the nent town, you have 25 deleted the -- these are not any of the towns in the, in your l
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2 A (Cole) The next paragraph deals with reception 3 centers for towns that ~ weren' t selected'for evacuation in our 4 questionnaire.
't -Q Now, is there anything on the remainder of-Page 31 6 that appears in.your Question 317 7 A- (Cole) No.
8 Q And you'have deleted G-32, in its entirety except for q 9 the. fourth paragraph and the.first three and a half lines of l 10 that paragraph, and in the next line, the phrase, remaining, or 11 the sentence, remaining indoors will provide you with
[ 12- protection for any radiatior:-being released from the plant,
! 'l D i j 13 correct?
o l
14 That is in your Question 317 i We included-that entire paragraph-except the i 15 A (Cole) 16 last sentence. ,
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17 Q And you have not included anything else on Page G-32?
18 n (Cole) No.
- i l 19 Q Rnd nothing on Page G-33 that appears in your "
l 20 Question 31?
That is correct, 'l
- 21 A (Cole) 22 Q And nothinD on Page 34. i 1
1 23 A (Cole) That is right. j l
24 Q- And nothing on Page 35.
25 A (Cole? Yes.
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f- ZEIGLER, JOHNSON, COLE - CROSS '7979 1- G .Now, the next scenario, if you will, appears as 2 Question 312, does it not, in your questionnaire?
3 A (Cole)- Yes.
4 0 .And'this was taken from message G, .in Appendix G,
- j. 5 appearing at Pages G-36 to -39, was 'it not?
l 1 6 A '(Cole) I really cannot answer that, without, you 1.
H 7~ know, reviewing this message and actually having access to the .
l-8 draf t' of the -EBS message that' I was given.
-9 G Well,'maybe.I can' cut it.short.
I' 10; Isn' t it true that - insofar G-312 is concerned, as far 11 as that scenario, that you took but one single paragraph from
.12 Message G, which appears on Pages G-37, through G-39, of_
13' Appendix G.
(n 14 And that paragraph appears on the first page and the:
15 next paragraph from the bottom, it says, all schools within the ;
16 town advised to evacuate, are being evacuated to the pre-17 designated reception centern, for the towns in which they are -
l 18 located. Parents should not drive to school to meet their 19- children since children are being bussed directly to reception 20 centers.
21 A (Cole) That is correct. <
1 22 O And you have used nothing else in Message G of the P3 EBS messages as appear in Volume 4, of the Plan, Rev. 2 of the 24 Plan? ]
i 25 A (Cole) Except that, at the beginning --
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1 Q Pardon?-
p 2. A (Cole) -- except that at the bed i nninD of question,
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3 we.tell them to -- that they had heard the last messaDe j 4 ordering a~ general evacuation.
15 So that.information was included then.
l.
6 -Q' You just made a reference to it.
-7 .A- (Cole) Th at' is correct,'yes.
8 'O You did not repeat it?
9 A .(Cole)' No, we did not.
10 0 <And insofar the EBS message, it is fair to say that
-l 11 you took a single paragraph of'an EBS message of. rome 12 two-ared-a-hal f pages?
13 A- (Cole) Well, they had just heard the --
<l 14 Q Is that true?
15 A (Cole)' As far as what we took from this EBS message, 16 or as far as what the respondents ---
17 O As.far as what you took from the EBS message.
18 A (Cole) As far as what we took from the EBG messages, f 19 that is true. .
.)
20- Q And now, on PaDe 24 of your testimony, you say that 21 you did not utilize the exact Nording of the FBS messages 22 contained in the plan.
23 And that is a true statement?
24 A (Cole) Yes.
25 O And you say the reason you did not is because you
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, 1 regard the messages as either repetitious or not essential? i l
l 2 A (Cole) For the purposes of the survey.
1 I 3 0 For the purposes of the survey. !
l 4 A (Cole) Right.
L i L 5 Q But you are not saying that these were not essential I
I 6 for the purposes of giving an einergency broadcasting, emergency i
)
7 broadcast message in a real emergency, are you?
I" 8 A (Cole) No.
l l 9 We were not making any attempt to evaluate the l
l L 10 adequacy of these messages in a real emergency. We were just 11 utilizing the messages to aid us to construct plausible 12 scenarios to find out how people would behave, under a i 77 f Swd .13 plausible scenaric at Snabrook. 1 14 Q And you were not trying then to relate.the possible 15 scenarios that, in your questionnaire to what might be an
.16 actual scenario at Seabrook?
17 A ( Co l,e ) We believe that --
la Q Can you answer that yea,.or no, and then elaborate?
I 19 A (Cole) I don' t think that I can, but if you will 1 20 repeat the question, I will see if I can. I i
21 Q Well, in the scenarios that you incorporate into your i
22 questionnaire, in doing so, yvu did not intend to siiaulate what !
l.
23 you miDht consider to be an actual scenario at an incident, or ,
24 following an incident occurring at Seabrook?
I
, 25 A (Cole) We attempted to give these people an idea, an i
{
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.( )h 1 essential: idea of what would happen at Seabrook, what they 2 would be told to do,'and then find out what they would do.-
l 3 That du what we. asked them.
l 4 We did not attempt to simulate the actual EBS 5 messages.
l
's D You were~just trying to Dive them'a' gist.of it, is 7 that what.1 understand?
8 A (Cole) . We wanted to know how people in the EPZ.would 9 behave if there were an accident at Seabrook.
10' Now,'there are a million possible accidents that-11 could occur, and.to help us-to construct reasonable and 12 relatively. realistic scenarios, and to. limit as far as 13 possible, any unintentional bias that can come into a 14 questionnaire, we utilized as far an possible, the actual EBS 15 messages contained in'the plan.
16 Q But as far as possible, in some of these instances, 17 did not take you very far, did it?
18 A (Cole) We did as much as was possible to do in doing 19 this research.
20 We conducted pre-tests as I said before, in which we 21 had'four versions of these EBS messages and we found that you 22 just cannot read a five-page EBS messaDe to somebody in a
- 23. telephone survey.
24 Q Well, would.it be fair to say that you found out that 25 the survey metheds that you had adopted, was not suitable for Heritage Reporting Corporation (202) 628-4888
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) ZEIGLER, JOHNSON, COLE . CROSS '7983 h 1 the purpose intended, so that instead of changing the model of l
2 your survey, you changed the facts of what you were studying?
i l 3 A (Cole) That is not true. That is not true.
4 The technique that we -- they uti'lized, I think, is a 1 S very good method, to collect information on what we were 6' intererted in studying. j 7- We were interested in knowing what people would do ie 8 there were a radiological emergency at Seabrook and we found 9 that out. We were not interested in usinU.a telephone survey 10 to do some sort of evaluation of the actual EBS messages in l
11 this plan.
12 'We only utilized these messages to help us construct
?
tbg 13 reasonable probable scenarios, that could occur if there were l i
14 an accident at Seabrook.
15 Q Well, doesn' t this point up the classic case of 16 forcing a study to a method?
l 17 A (Cole) I don't understand what you mean by forcing a .
18 study to a method.
19 Q Well, you could not read the EBS messages as they 20 were drafted, which were intended to cover a particular 21 situation at Seabrook, so you improvised and created your own.
22 And you also in the method chosen to study, you could 23 not examine households and you had to go to individuals. Had 24 you chosen a methodology to go out and interview the various l 25 people that the sample would, households that the sample Heritage Reporting Corporation l (202) 628-4888 i
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- :C- u' i l 1 indicated you should, then you would not have had these ,
2 prob l eras.
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!': 3 You would not have had to readapt the EBS rnessages, 4 you could have interviewed households instead of. individuals, G- isn' t that . so?
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6- MR. TRAFICONTEr. I arn going.to object to the l 7 raischaracterization of the testirnony up to this point.
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8 I don' t believe that question was a fair l
9 characterizat ion of the testirnony.
10 JUDGE SMITH . It is a very lengthy question and it'is l
1 . .
11 going to be hard to go back and see if'every element of it, 12 every link of it is a correct characterization.'
13 Can you break it down and --
14 MR. LEWALD: I arn not going ~to pursue it.
15 It is just a follow-up of asking 'hirn whether he is 16 forcinD the study to the rnethod.
17 JUDGE SMITH: I think that he has explained his 18 objectives.
19 The Board feels the question as originally put is 20 were you forcing the study to the rnethod, was clear, and we 21- think that it should be answered.
22 But i f you don' t understand it, let's try again, and 23- see if we cannot satisfy Mr. Lewald$s needs.
24 THE WITNESS (Cole): We were not forcing a study to a 25 roet h od. We used the best possible rnethod to conduct thin study. ,
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) ZEIGLER, JOHNSON,. COLE - CROSS 798b L; 1 We wanted to find out what people would.do in a 1
2 radiological emerDency. We briefly described a hypothetical-l 3. radiological emergency at Seabrook and then we asked people 4 what they would do?
5 And we obtained their responses. And in my opinion, 6 th'ose responses are reliable. We utilized the EBS messages in 7 order toz help us construct these plausible accident. scenarios.
8 MR. LEWALD: I will move to another subject.
9 SY MR. LEWALD:
10' O- On PaDe 25, of your testimony, I guess this in yours, 11 Dr. Cole, you refer to Question 341 of the survey, which asks 12 respondents how many individuals in your household would need 13L public transportation in order to evacuate?
14 And then you then proceed to analyze the results of 15 that question or the results of answers to that ouestion on the l
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- 16. remaining portion of that page.
17 And then in the last paragraph, you say, thus, there 1 !
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'18 are about 4,000 separate households requiring public 'f 19- transportation.in the event of an emergency and a total of 1
20 approximately 67,000 or 7.3 percent of the population requiring 21 public transportation. I i
22 Now, and then you go on to say this about three 23 times, the estimates made by KLD.
L 24 Now, have you, in the course of your scrutiny of the )
l l 25 respor.ses to the questions in your survey, considered the i
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ZEIGLER, JOHNSDn!, COLE - CROSS- 798f4 1 responses to questions that were asked of people in the E?Z as 2 to how raany cars they would uce to evacuote, g one car, no cars, 3 or whatever? 'I \
I 4 A (Cole) Yes, I believe that i c ts question in the 5 survey, yes.
n 6 Q- And would you accept that' the answers to 'those .
-l h
'7 questions with respect -- that with respect.to no. cars, fell in ,.
. t-8 a range of zero to 3 percent of the phr.ulation, does that seern i\; j 9 in order?
10 A (Cole) . I don' t have the data'-31 f ront - of rne.
11 Q You have the answers to thcOpmstions in front'ofL 12 you, don' t . you?
13 Do you want to take a rainute and Jc st.. look at a .
14 couple of those? .
i 11 ,
l 15 A (Cole) If you tell rne the quest ion nurnber, that 1
i 16 would help. ,a l
l 17 Q You are perhaps enore f arniliar with che questionnaire d (q
18 than I a rn.
19 MR. TRAF1 CONTE: If Mr. Lewald knows the nurnber, it 20 would certainly exped ite inat ters.
21 MR. LEWALD: I appreciate that, but I don' t have the 22 nurnber at rny .f ingert i ps. j 23 (Pause.) f 24 MR. LEWALD: Can we start at -- i; ,
25 THE WITNESS (Cole): Can you repeat i.hu question, I 0 !
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\ l 1 .f t fri nk I have the relevant' infore at ion now. !
2 ,
i[ MR. LEWALD: Yes. ,
I 3 DY MR. LEWALD: - I t
4 Q Ig was a :t<ing you to ecvnpare the survey responses of t- t >
lJ 5 psople 'wM'c/have antimfre!d that they have no carn to use in an I- 6 evacuation, with Fe s pec*; t o, and cornpare it with your figure of i
7 67,06v individualtt, or 7.3 percent.
i 't y' O bdDGE WITH: That is 6,700.
/y i< >
9 M R .' LEWALD: That.is 6,700. '
~
p 11 Q Arid I 4'bn asking you to accapt : sit at ercept that the, p
12 insofar the people in ~4ew Hmap" hire in the EPZ, that hav e 13 answered the question, how roany eF your vehic)es Jesuld you and 14 your fatnily use to evacuate, that those responding with no 15 vehicles to the quest ion, no vehicles or responding with the 16 answer no vehicles were f rorn zero to 3 percent.
17 A (Cole) That scans reasona;;i e.
18 (Contipued on the next p a g e . .)
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And thak? If you +d, ok three percent of the EPZ T272 1 ,d
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populat ion, . what digd {)'e uo41d - you arriveWell, at ? let' y i:
y ,, ./ , j ,t f ,j ,
T me 7, -? nt ri ke ; t, hat.' ,
- v. 5. , 1
.n (4- 11 # 't9R. TRAFICONTE: If this would help, I think.the-data .I b r j 1 nl :
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, S b i ;n crytainmJ at Page 25 of the technical a ppenc'i x , if I? m
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'g f-' % wing the line of. questioning. .
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7 BY MR. LEWALDs I p, ,8 0 'Is tbree pen:* cent - is three percent that far-away =;
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9 9 from the ~ 2. ti percent that the plan assumed as those residents l
,- 10 of New Hampshire whipt wou)d require public-transportation y j k 11 during a mdiological. esoergency?
h 513; l, ' 12 A' (Cole) I don' t = really. understand the logic of'
'13 your 0 -- ,
I '!
14 Q Would it be fair to assume'that those people who i l
w 15 answered the survey and said thqt they had no caru with which 5 .
16 to evacuate would need pubfic transportation to evacuate? l s '
17 A (Cole) Not necessarily, h
b 18 Q Not necesarily. All right.
19 Dr. Co W, edn you cite ' any nbody anywhere where 20 public transportation is used to evacuate anyone, let alone 7.3 21 percent of the total population?
D- 22 A (Cole) Could you repeat the question, pleasey I l i-23 Q Sure,
[.
i 24 Can you cite any st udy anywhere were publ.ic 25 transportation is used to evacuate anyone, let alone 7.3 D
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'1' percent of the population?
2J A (Cole) I' m not familiar with those studies.
l 3 Q Turn back to Page 16 of your testimony.
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(' 4 .And do -- in the middle of that paDe is a question, l
! 5 "Can the result of such a random sample survey be used'to G generalize to all of the households'in the EPZ?"
7 Do you see that question?
8 A (Cole) Yes.
-9 Q First of all, can we agree that the survey that was 10 undertaken was not a randora sample survey?
11 A (Cole) No.
I 1 A oe No 14 Q Even thouDh the heads of households were not changed, 15 were not selected randomly?
16 A (Cole) It was a random sample of households.
17 Q But you didn' t interview. households, did you?
18 A (Cole) We interviewed individuals as informants 19 about what househol d s; would do.
20 Q All riDht, we' ve been over that.
21 You then go on to say, "With the exception of a few 22 households who do not have residential telephones.. that this 23 sarapie is an accurate way to generalize to all the households 24 living in the EPZ."
l 25 And you say that because you consider the sample tn Heritage Reporting Corporation (202) 628-4888 i l
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() ZCIGLER, JOHNSON, COLE - CROSU 7990
'1 have been a random sample.
2' A (Cole) 1. consider it to be.a random and accurate 3 sample of households in the EPZ, correct.
4' Q Now, you Do on to say, "For'this' survey, the sampling 5 error is plus or minus three percentage points."
6 Then you'further say that, "This.means, in theory, 7 that if.the survey would be repeated 100 times'using-the same-8 techniques, in 95 out of 100 times the result obtained for a 9 particular question would be within three percentage points of 10 the t'esults which would have been obtained by interviewing 11 every member of every household'with telephonen living in the 12 EPZ."
13 Now, how did you compute the sampling error?
14 A (Cole) There is a standard statistical formula 15 that's ut ilized.
16 Q Well, would it be fair to say that you took twice the 17 standard error, and called it the sampling error?
18 A (Cole) Yes. 1.96 times the standard error.
19 O 1.96?
20 A (Cole) Yes.
- 21 Q Could you tell us what the standard formula is?
22 Could you write that on the board? Have you --
23 (Pause while witness writes on blackboard.)
24 DY MR. LEWALD:
l 25 Q And by doubling the 1.96, you -- this is standard g 10 1
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1 error that you have Diven us the formula for, correct? !
I 2 ~A (Cole) The' sampling error. .I D i ve the sampling 3 error'of the survey.
4 Q Now, on - thank you, Doctor.
5 Now, on Page 53 of the technical appendix you say 6- with respect to this error that, Th is means, in theory," and-7 goinD on is a repetition of what you have on Page 16 of your 8 testimony,. correct?
9 JUDGE SMITH: What are you going to do with that l' 10 sampling error formula? Anything? Do-you want to put it in
' 11 the record? It hangs there unproductive.
12 MR. LEWALD: Why don' t . we put it in the record?
13 JUDGE SMITH: All right.
14 Could you duplicate that?
15 JUDGE SMITH: All right, why don' t you read it into 16 the record, l-L 17 THE WITNESS: (Cole) All riDht, it's -
?
l 18 BY MR. LEWALD:
4 Could you tell us what it i s, Doctor, verbally? !
19 Q 1
20 A (Cole) Yes. It's P times P minus O.
21 Q P is percentaDe?
22 A (Cole) P is the percentage on a particular question.
23 P times P minus 0 - O is not P - divided by the square root 24 of N-times 1.96.
25 Q And N is the number of interviews?
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'l .A (Cole) Correct.
2 D Or responses of --
3' A (Cole) Correct.
4' O Now, on Page 53, Dr. Cole,- you-say.that, "The 5 calculations," and these are the calculations that determine 6 the sampling error, " assume that the survey was conducted;under 7 ideal circumstances."
8 And then you say, "Since there are a large number of 9 practical problems in conducting surveys of this type, it is 10 possible there could be other sources of error in the survey."
11 A (Cole) Correct.
- 12. Q And is it fair to say that'this caveat is in'the i 13. technical appendix ~ because the formula . by which you have uced-14 to dotermine for a standard error, and then sampling error, is 15 for situations which present simple random samples?
16 A '(Col e ) The caveat is in there because it's 17 essentially boilerplate. It's in every report I do. .There 1 18 are all sorts of other types of possible errors that could be 19 in surveys besides sampling error.
l 20 Q Is the formula you have used to determine sampling 21 error adaptable to a stratified random sample?
22 4 (Cole) I' m not an expert on --
23 0 Is it appropriate to use that formula where you have 24 a stratified sample?
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L 25' A (Colo) I' m not an expert on statistics. I don' t LD l Heritage Reporting Corporation (202) 628-4888 o
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) ZEIGLER, JOHNSON, COLE - CROSS' I993 1 claim to-be'an expert on statistics. -But as far as I can 1
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2 understand,-this way of computing the sampling error on a
- 3. survey of this type is an adequate way. Where there in some 4- more complex way to do it, I really don' t know. You would have 5 to ask a statistician'that.
r-G But from my experience in dealing with all sorts of 7 surveys, this is an adequate way of computing the samplinD 8 error for a survey.
9 Q For any survey, irrespective of whether or not it's ]
10 stratified, or multistage; is that so?
11 A (Cole) I am not a samplinD expert. I am not Doing 12 to give testimony on the different -- there are many -- this is I
13 a whole field in statistics. It's a specialty in statistics, 14 and there are literally hundreds of various tests; to compute' 15 the sampling errors under all sorts of different circumstances.
1G Q Well, you have unrd r a statistic in your testimony, 17 have you not?
18 A (Cole) That's right. I believe that the statistic 19 is more or less accurate.
'l 20 0 But you are not certain as to its limitations in more 21 complex samp)ing procedures, are you?
22 A (Cole) No.
l 23 Q Does your lack of knowledge in this field concern you 24 that your determination of the sampling error may give a 25 misleading interpretation of the reliability to be obtained by Heritage Reporting Corporation (202) 628-4888 i
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2 .A. (Cole) 1 am absolutely sure, since 1 have worked 3 with--statisticians, that if.you use any other method of
,. 14, computing the sampling error, it is not Doing to be 5 significantly different from what I have indicated. .Given the 6 purposes of this! survey, the method that I have used of 7 computing the sampling error is very accurate.
8 We aren' t interested in figuring out whether.52 9 percent, or 54 percent, or 50 percent of the Seabrook 10 population would evacuate. We were interested in looking at a 11 general idea of what's going to happen here.
12 .You can' t Det another method of computing the 13 sampling error that's going to show a sampling error that 's 14 very different from what I have done, because I have worked
~
15 with statisticians on more complex surveys such as election-16 surveys where they have used more complex methods of computing 17 sampling error, and using the least complex method does not 18 give you sampling error estimates which are significantly 19 different from the most complex methods.
20 Q But it does give you -- the most simple form does 21 give you a lower sampling error, does it not, lower sampling 22 error fiDure?
l 23 A (Cole) It's possible that if you were to use some 24 more complex method, you might get a sampling error of four l 25 percent instead of three percent.
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.1 0 'Butyou think'it would be in that range, dolyou?:
2 A' .(Cole) Yes. From_~my experience, that's the maximum 3 that'it would change. You might get four percent.
4 Q- Now,. on.the-bottom of Page 17, .y ou describe what your 5 interviewers did by way of a -- well, by way of following a set j 6 of. callback procedures.
L 7 Do you-see that?'
- 8 A- (Cole) Yes.
L 9 Q Where are the results of the callback procedures I 10- located'in the study?
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11 A (Cole)' The only.information that is presented in the 12 study is included in the technical appendix in Table A-3 on l.:
l '- Page 57.
'13 l
l 14 Q And what does that tell us? Does that tell un how 15 many successen'the interviewers had by calling back 11 6 individuals?
' 1 '7 A (Cole) Yes. It tells us what happened to every 18 single phone number in that sample, 19 What we.do is we D i ve an end result for every phone 20 number. There were a total of 6611 phone numbers. In 1404 of 21 these numbers, we completed interviews, et cetera.
22 Q But it doesn't tell us on what callback were managed 23 to complete the interview.
24 A (Cole) No.
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.1 interviews were made~on callbacks, doer, it?
2- A (Cole)- This table does not, no.
3 Q Does any table? J 4 A (Cole) No.
> I 5 Q Do you personally know whether any callbacks resulted 6 in completed interviews?
7 A (Cole) Yes, I do.
8 Q But you didn' t choose to put this information.in the h 9 study?
10 A (Cole) This type of information is never included in
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11 any of the 150 reports I' ve written. It's detailed information 12 that "doesn' t haveLany relevance to this study. We never 13 include that information in our reports.
14 Q That's in your reports?
15 A (Cole) I haven' t seen it in other reports either.
16 Now, on Page 18, you were asked the question, "What- '
Q l
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17 was the response rate in this survey?"
18 And~your answer to that is, "Normally in surveys, i 19 such as this one, response rates are computed by dividing the i
20 number of completed interviews by the number of eligible people t 21 contacted (the complete plus the refusals)." j 22 Then you go on to say when you did this, you found a J
23 completion rate of 64 percent. And then you are discussing the 24 reciprocal of that and say, "This means that we were unable to
. 25 complete interviews with 36 percent of the households we 1 Heritage Reporting Corporation (202) 628-4888 1
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_(f-1' contacted," correct?
l 2' A (Cole) Correct, yes.
ll 3 0 'Now the 64 percent cornplet ion rate ignores, 'does -it. )
4- not, the 1055 no answers that you received after three 5 callbacks? l l
6 A (Cole) Correct. !
7 Q. And it also ignores the 457 busy signals, inability 8 to reach household heads?
9 A- (Cole) Correct. i 10 Q And'it also ignores the 2270 nonworking numbers that ,
11 you found?-
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-12 A (Cole) Well, those would be totally' irrelevant. 1 13 mean, those aren' t real phone nurnbers.
14 Q They were not real phone numbers?
13 A (Cole) No. The randora digit dialing practice 16 generates a whole list of numbers, some of which don' t really 17 exist. That's the only way you can be sure of including 18 unlisted numbera.
19 So sorne of those numbers don' t exist in the sense 20 that they' re not assigned to anybody. They are not real 21 nurnbers. They are not existing numbers.
22 Every survey that uses randorn digit dialing has a l
23 substantial portion of these, 24 Q But sorne of them do exist, but were not working at f
25 the time you attempted ta call these numbers.
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) ZEIGLER, JOHNSON, COLE - CROSS. ~799W 1 A (Cole) No, . I m ' sorry t hat the t'erm'"not a working 'l
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2 nunber", it's a technical term; .it's not clear in this report.
3 Not a : working nurnber rneans it is no phone number. When.you 4 dial that nurnber, you get a recorded message saying, this.is
-5 not a working phone nurnber. But nobody has that number. No 6 individual, no business, nobody has that nutnber. There are-7- gaps'in the blocks.
8 Let's say we' re dealing with ' 751-6000 as-a block.
9 That's what my home ' phone is. There might be 751-6234, which 10 is assigned to nobody. It's an empty number. And the computer 11 could Denerate that, and if you dialed that number, you' d get 12 this recording.
'/ ^
$ .. 13 Q 'All right, you began in your sample.by-taking 14 ' discrete telephone codes, correct?
15 A (Cole) We started with exchanges.
L 16 Q Would you -- these are -- do you accept that these-
-17 are discrete telephone codes, exchanDes, 823 or 5237 18 A (Cole) Yes. We started with those exchanges.
19 Q And would you accept that there are rouDhly 10,000 20 nurnbers in each of these discrete exchanges?
21 A (Cole) Oh, no. Some of them have very rauch less 22 than that. Some of them only have less than a thousand.
23 Q I' m tr' kind about -- not talking about issuech 24 numbers. I' m talking about total possible numbers in an 25 exchange.
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1 A (Cole) Of possible numbers?
1
'2- Yes.
3' Q Now, in the discrete exchange,-there are subdivisions 4 called blocks; is that what . He' re saying?
5 A (Cole) -Yes. .
6 Q And it5s the blocks that you' re concerned with, .not f 7 the numbers in the exchange?
- 8. A '(Cole) The computer has information on which of the-9 blocks'are working; that is, have numbers that you' re assigned.
10 And they only draw the random numbers from the working blocks..
11' O So you' re taking random numbers of the total' possible j 12 telephone numbers in an exchange, is that true?
13 A (Cole) No, we' re taking random numbers from the i
-14 working blotks.
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T273 .1 Q Froni a block in which any number may be working, is 2 that what I understand? 1 3 A (Cole) Right.
4 Q And it could be one or 5,0007 5 A (Cole) In a block?
6 Q No, that is working.
7 A (Cole) The blocks are smaller. There couldn' t be 8 5,000 in a block. A blocks are smaller units. They are 9 defined generally by the first --
10 0 What category do you have of the numbers called that 11 you were unable to complete because the line was out of order, 12 if that's a better term? It had a household on the other end 13 of it, but for some reason the line was malfunctioning.
14 A (Cole) That would have either come in in a no 15 answer, or busy. If the line is out of order, it could ring, 16 or it could ring as a busy.
17 Q And the 2270 is just a plain nonissued number in what 18 you' re telling me.
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19 A (Cole) Yes.
20 Q Now, you also say the 64 percent complete rate l
21 ignores 93 cases where the communication was too difficult to l
f 22 complete the interview.
I j 23 A (Cole) Correct.
f 24 Q And it also ignores 439 cases, where the sex or town l
25 quota was filled, correct?
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.1 A (Cole) 249, yes.
2 Q lsn' t that 4397 3 A (Cole) It's 249 on my page.
4- Q Now earlier in your testimony with respect to the 5 response rate, you say the lower the response rate, the less 6 confidence you could have in the survey of result; is that --
7 that's true?
8 A (Cole) In Deneral, yes.
9 Q And then you go on to say, "It is also important in 10 assessing the adequacy of the result of the survey results how 11 the numbers of no answers, busy signals, or.no eligible 12 respondents at home, because there can be no way.of knowinD
'13 whether these people would have answered differently than those 14 interviewed."
15 A (Cole) Correct.
16 Q And is what a)1 this comes down to that you have no l
17 way of knowing as to how -- knowing that 155 no answers, to 457 1 18 busy signals, and 93 communication difficult cases, and the l 19 cases in which sex or town quota was filled would answer the 20 question?
21 A (Cole) Correct.
22 G Now proceeding on Page 19, you talk about methods 23 used to validate the surveys.
24 Wouldn' t it be more accurate to say that you weren' t 25 validating the survey, but validating the interviewing process?
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. 1 1 A (Cole) Yes, I' ll accept that.
2 JUDGE LINENBERGER: . Excuse me, Mr. Lewald, but with .
.l 3 respect.to the last question inquiring about validation, I l
l' 4 thought I heard you say, Dr. Cole, in answer to the question, 5 "Yes, that also."
6 'Did I-hear correctly? i 7 THE WITNESS: (Cole) No, I said, yes, I' ll accept 8 that.
9 JUDGE LINENBERGER: Oh, excuse me.
i 10 .THE WITNEGS: (Cole) His change of my wording.
.11 JUDGE LINENBERGERt- Thank you.
12 =THE WITNESS: (Cole) He said that we utilized two 1 .
13 methods to validate the interviewing process. I-think that 14 is ~~ that's . more accurate than --
15 JUDGE LINENBERGER: T hat ' s fine. Thank you.
f 1
16- MR. LEWALD: May I have a moment?
17 (Pause.) i 18' BY MR. LEWALD: .j l
19 Q Like to ask the panel to turn to Page 28 of the 20 testimony, and to the question that's put on that paDe, I n ,
.I 21 other proceedings," which I' ll read. "In other proceedings 22- concerning emergency planning for nuclear power plants, 23 witnesses for the owners have argued that curveys are not a 24 reliable tneans to predict what people would do in a real 1.
25 emerDency."
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) ZEIGLER,'. JOHNSON,. COLE - CROSS 8003 1 And then you ask yourself, "Why should the Bocrd
-2 accept as valid the survey results you have described?"
3' Ar.d 1 want to ask the panel if isn' t it the almost 4 unanimous position with panel acceptance, that no credit can be !
.5 D i ven to responses as to a belief of individual in their own G behavior in an emergency that they have never experienced?
7 1sn' t their. great weight of authority in profession i 8 to this extent? ,
9 A (Cole) That 's not true, in my opinion. And -- j 10 Q But isn' t that the weight of authority is?
11' A (Cole) . No, i t ' s not . .And if you can -- I can D i ve 12- you an example. A witness for LILCO during the recent 13 proceedings"down there, Michael K. Lindell has published 14 extensive research in which he has used the same kind of j 1
15 surveys ar,we use, and Di ves them tremendous credence in
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16 analyzing what people will do in a radioloD ical emergency. q l
17 Dr. Dennis Mileti and Dr. John Sorenson of Oak' Ridge j 18 National Laboratories have published many papers in which they l l
19 use surveys, for example, the Cynthia Flynn survey, in j 1
20 analyzing what people do in emergencies. I mean this is --
l 21 Q These are not studies simply to determine people's )1 1
i 22 perception of a risk? l i
l 23 A (Cole) The Lindell and Barnes study --
24 Q No, the Mileti studies.
l 25 A (Cole) Do you want to answer -- 1 l
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1 9 Well, finish the Lindell study. i l
2 R (Cole) The Lindell and Barnes study dealt totally )
3 with hypothetical accidents. One caused by a radiological l l
4 accident at a nuclear power station, and the other by some 5 chemical accident. And then they asked samples of people what 6 they would do in this condition. And they published an 7 extremely good and interesting article analyzinD why so many 8 people would overreact, if yvu ve i l l , in the case of a 5 radioloD ical emergency. It's a fine piece of research.
10 Q In that study cited in the testimony?
11 A (Cole) Yes, it is.
12 Q And that's at what page?
13 A (Cole) Page 34.
14 Q And the Mileti study that you were talking about, is 15 that cited in the testimony?
16 A (Cole) It's cited in the -- I think in the report, 17 the Social Data Analysts repo:c't. It's on Page 12 of the Social 18 Data Analysts report. I do not have an exact reference to the 19 paper there, but it was a paper that -- it was written DO initially by Sorenson, who was a witness for LILCO in 21 proceedings on LonD luland.
22 Q Now, in your answer to the question that you have 23 asked yourself on Page 28, you say that, "No one suggent'.s that 24 the survey is a precise instrument which accurately predicts 25 exactly how many, or which people would actually attempt to Heritage Reporting Corporation (202) 628-4888
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1 evacuate were a real accident to occur. But the survey-in-the 2 best tool we have."
L 3 1s it.the only tool that you have to determine how i
4 people are going to behave in an accident?
5 A (Cole) No.
6 Q Isn' t the empirical evidence of some value to teach a
-7 determination as to what people may act -- how people may act 8' in an accident?
9 A (Cole) What empirical evidence? 'j 10 Q Empirical evidence of how people have acted in !
1 11 accidents?
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- 12. A. (Cole) In a radioloD i cal emergency such as TMI?
- b. '13 It's extremely important, very important what people 14 did at TMI, 15 Q TMI would be one example, would it not?
16 A (Cole) TIM, to my knowledge, we don' t have Good 17 data, unfortunately, on Chernobyl. But TM1 in the only example 18 of a significant radiological emergency in the United States, f i
19 and certainly the only example upon which we have any data.
1 20 A (Zeigler) And I think most researchers today would ;
21 aDree that it's better to generalize from Three Mile Island to j 22 future nuclear emergencies than it is to generalize from the 23 many st udies of floods and hurricanes to nuclear emergencies.
24 Q Now, going on still on that page, the last sentence .
-- 25 in that paDe you say, "In a real accident, dependinD on the
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i seriousness of the accidents and the variables, the evacuation 2 .. shadow might be somewhat larger or smaller than that found in 3 the survey."
4 Are_you suggesting that in a real accident we 5 shouldn' t count on the survey?
6 A (Cole) The statement speaks for itself, We' re 7 saying that in a real' accident you could have either a larger, l .!
8 perhaps a si Dnificantly larger or a somewhat smaller evacuation 9 shadow than that indicated.by the survey. There are all. sorts 1
l l - 10 of variables that could inf'luence that in a real accident.
11 Q Turn to Page 39 of your testimony, and the question 12 in the middle of the page. 'It says, "Was it prudent for the (q/. '13 New Hampshire Radiological Emergency Response Plan drafters to 1
14 have assumed that these emergency workers can be relied upon t'o 15 report to duty promptly."
'16 And your answer is no.
17 Could I ask the panel how it is using the word !
18 "promptly" here in this question? Is there a time frame that I 19 the "promptly" suggests?
20 A (Johnson) I think the time frame would be dictated ;
J 21 by the nature of the accident, the speed of onset of the )
l 22 accident. Promptly is used in the sense of protecting public 23 health and safety.
l 24 Q Then if the accident was one of slow development, j 25 then the promptly would be -- could be slow response also; is Heritage Reporting Corporation (202) 628-4888 1
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3 A (Zeigler)- No, I think promptly means, in most 4 people's minds, as_ fast.
1
! 5 Q. Think it'means what? J 6 A (Johnson) In rnost people's minds, prompt ly . tneans -- '
i 7 Q What does it mean in your mind?
8 A (Zeigler) Well, I think I' m representative of most 9 people. .In most people's minds, promptly means as fast.as you 10 can. And there is no way to assess a slow rnoving accident 11 except in retrospect.
12 Retrospectively, you could say . it's . a slow-movinD o_m 13 accident. But if you' re looking to the future of a developing
.14 accident, you'have to assume that an accident could break
- 15 ' a ltnost instantly and require ernergency personnel to pay
.16 attention to their duties almost instantly. ,
1 17 Promptly means as fast as possible, as fast as you 18 can.
1 19 Q Well, goinD on with your answer, you say, "In makinD 20 this," - af t er "no" . "In making this assuroption, the State of 21 New Hampshire has failed to consider the impact of ro?e 22 conflict on the behavior of emergency workers in crisis 23 situations."
{
24 The fact that people may have role conflicts, you 25 would agree, dces not rnean that they will actually abandon i
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[ 1. their roles, does it?
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l 2 A (ZeiDier) No, there's a ranDe of. behavior. Role li 3 abandonment 'is'one possible behavior.
I 4 Q .And in that role abandonment'has never been -- has' l
b 5: never happened where the ' nature of the emergency worker's role.
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- 6. was defined,.would it not be imprudent for the New Hampshire 7: drafters to assume that the emerDency workers aren' t going to R l
8 show up?
9 A (Johnson) I' m not sure of -- I' m unclear on your ;
10 question.
11 Q You are unclear as to.that?
12 A (Johnson) Yes.
13 MR. SELLECK - He doesn' t understand the' question.
14 M R .~ -LEWALD: No, I know he doesn' t understand-the j 4
15 question. j 16 BY MR. LEWALD: J i
17 Q The question that you. posed is, was it-prudent'for. <
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18 the New Hampshire drafters to have assumed that these emergency l
19 workers can be relied upon to report to duty prompt ly. j j
20 And from that question, we have in our discussion has i 21 led us to the fact that failure to report in nome instances may ,
1 22 be for reason of role abandonment; in that true?
23 A (Zeigler) In some instances, role abandonment may 24 result from role conflict.
25 Q And you would consider in --
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1 JUDGE SMITH: Well,.you ---I didn' t ' think that' was a 2 response -- responsive.
- 3 If you are happy with it, proceed.
4 MR. LEWALD: Well.
t 5 THE WITNESS: (Zeigler) I' m unclear to the quest ion.
- 6 .BY MR. LEWALD
7~ Q Would it tvot be imprudent for the New Hampshire 8 drafters to assume that emergency workers with defined roles 9 will not report to duty promptly or when needed?
10 MR. T RAF T. CONTE : I' m going to object. I' m sorry, but 11 I think the question was, would.it not be imprudent to assume 12 they would not." I think it's a triple negative, and I sure
'13 ' don' t understand it, if that's what the panel is struDgling l 14 with, 1
15 MR. LEWALD: Well, it may be, and let me rephrase it.
1G BY MR. LEWALD:
17 Q Would you aDece that it would be imprudent for the 18 New Hampshire drafters, or New Hampshire umergency response i
19 drafters, to have assumed, or to assume that emergency workers !
20 under the plan cannot be relied upon to report to duty where i
21 emergency workers with defined roles have never refused to 22 report to duty?
23 A (Zeigler) At Three Mile Island, while there was not 24 a plan to take care of an accident at Three Mile Island, there 25 were Uroups of people in the population that had generally 7-b Heritage Reporting Corporation (202) 628-4888 l
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1- assigned: emergency duties. They knew that they would be called )
'I 2 upon to'take care of emergency situations in general.
3 These people.at Three Mile Island did not universally 4 respond. They experienced role conflict. Some of them existed 5 role abandonment behavior.
'G. And.I'think we ought to generalize once again from 7 the experience at Three Mile Island to future nuclear 8 emergencies. l 9 Q Well, what you' re saying is, Doctor, that in an
.10 emergency, even though it's not part of a-upecific emergency 11 response plan, people look.to the fire department, the local 12 fire department, the local police department, to respond to 1
.a 1
-L .13 emergency _ functions? l 14 A' (Zeigler) I think'that --
15; Q And that these people in Three Mile Island, they had 16 not stayed on the premises. Is that what you' re talking about ?
i 17 A (Johnson) I- t hink we' re t al king -- i 18 Q That people with general emergency duties?
l- 19 A (Johnson) I think we' re talking --
PO Q Is there anybody in Three Mile Island that had an l 21 emergency role as defined in the plan, that abandoned his role?
22 A (Johnson) First of all, it is important to establish l-l 23 that there wasn' t a plan at TMI. And I think we can be more L
l L 24 specific with the groups that we' re telking about.
l 25 To my way of thinkinu, medical doctors have emergency l
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1 roles irrespective of the kind of incident, especially 2 emergency room doctors. Moreover, I think the National Guard 3- has emerDency roles ir.espective of the kind of incident.
4 And the research record shows that in both instances 5 we had people who failed to report for duty, who were unable to j 6 be contacted by telephone and so forth and so on. And that led 7 to role abandonment. They.just weren' t available. The 8 evidence shows that they had evacuated with their families.
E273 9 (Continued on next page.)
10 11 12 13 14 15 l 16 17 18 19 20 21 22 l
23 24 D
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i n j' p- ZEIGLER, JOHNSON, COLE - CROSS Bo2 a l- T274rnb 1- (Q Is one of the sites for this proposition that you l= 2 have just g iven sne, , Dr. Johnson, in that of Maxwell's Hospital l' 3 organization's response to the nuclear accident at Three Mile 4 Island, which appears in your footnote 17. to your test irnony?
5' A (Johnson) What paDe . are you referrir.g to?
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, 6 Q Page 45.
7_ A (Johnson) I think that all of the sites in footnote t
8 17 refer to the basic proposition that role conflict was a l
9 p* oblern at TMI.
i 10 Q Well, I thought in your testirnony you were il specifically referring to Maxwell, and then, indeed, on Page 12 46, of your test irnony, you say at one local hospital, for 13 e x arnp l e, only six of the 70 physicians who were scheduled for.
14 weekend ernerDency duty reportedly showed up for work?
15 A (Johnson) Yes.
16 (Pause.)
17 BY MR. LEWALD:
18 Q On Page 46 of your testirnony, that we just rnade l 19 reference to, in Note 20, you cite Maxwell and then footnote l
l 20 17, and at Page 278, for the sentence, at one local hospital, l
'21 for exaraple, only six of the 70 physicians who were scheduled
( 22 for weekend ernergency duty, reportedly showed up for work, do 23 you not?
! 24 Do you find that on Page 278?
l f 25 A (Johnson) On Page 2'78?
lD 1
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() ZEIGLER, JOHNSON, COLE - CROSS 8010 1 Q Isn' t that what you cite as a reference to that 2 statement in your test iraony? !
l 3 A (7ei D1 er) No, in fact, -1 would have to clarify that j 1
4 and say that the quote is from Page 276, the reference --
5 Q The quote is on Page 226? ,
1 i
6 A (Zeigler) The quote'in on Page 276, that is an j i
'j 7 error.- j l
8 Q And where is the quote on Page 2?67 !
9 A (Zeigler) There is a section called staffinD at,the )
I 10 end of that first paragraph, under the section called staffing.
I 11 Q Can you find a quote that at one local hospital, for j 1
12 example, only n'ix of the 70 physicians who were scheduled.for j
\ 13 emergency duty reportedly showed up for work? .
1 14 Where is that quote appearing in that? -l s
15 A (Johnson) It is'not a quote in our testimony. It is !
f' l
l l 16 a reference to the statement at the bottom of the first 1 i:
l 17 paraDraph on staffinD, which reads, physician staffinD reached .
l 18 critical levels at at least one institution, with one emergency L
L 19 department phyuician noting.that only six of more than 70 l 1
20 doctors remained available. ;
21 Q This is not quite the same thing as saying that in ;
22 one local hospital, for example, only six of the 70 physicians 23 who were scheduled for the weekend emergency duty reportedly 24 showed up for work, is it? ;
i 25 A (Johnson) Well, it is not the precise wording. I ll Heritage Reporting Corporation !
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t ZEIGLER, JOHNSON, COLE - CROS3 801 o l 1 think the critical thing here is the notion that physician 2 staffing reached critical levels, at least, at at least one l
3 institution, 4 That suggests to me that they vere not available for .
5 work. I think that we are splitting hairs if we are talking 6 about the wording, but the idea is that there were not
- 7. physicians available to do needed work.
8 Q You are not suGDesting that 70 physicians who were 9 lined up for emergency duty, defaulted, and only six appeared, !
10 or are you?
11 A (Johnson) The statement states that only six of more 12 than 70 doctors remained availabli to work. Now, whether they iv. 13 were lined up or whether they had evacuated, I don' t know. -l .;
14 Q You don' t even know whether they were emerger cy l
i
.15 workers.
16 A (Johnson) Well, it said that they were th ergAncy 17 department workers.
I 1B Q The department head was emergency.
19 A (Johnson) Well, in most studies of organizational ({
p.
l 20 behavior, you have to interview someone, karely do they ever l 21 interview every emergency worker. They interview the .s.
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22 organization heads. 1 23 Q Do you know of any hospital that would have an i
24 emergency staff of 70 people on duty, during a weekend?
25 A (Johnson) I am sure that a lot of hospitass O-Heritage Reporting Corporation (202) 628-4888 r U
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t i i 6 appear on' i:.w t er t irnony, tha{ -- 3 L
7 Q .1 R . LtiWALD : That st t ternent i n 's est i rnc-' iy ?
O .
,, Jt.'JGE GMITH: Yeu.
9 MR. LEWA D: l'n Page 46, Your Honc) i, . m t hea seccind
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- is 4 a% it 10 sentem:e on that page, _vaginning on the ninth '
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s' g il beginn with, "At one 160s' houpit ajO -- "
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Gm you stpli happy with that st at ernent ?
13 t 14 ., Are you sti'.11 pleased with that st at ertant ? >
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15 .. THE WITNESS (Zeigler): 1 av sorry, I
{. i d not hear' 16 a ,
7,. :.eo u. i s
Are you sblil cont ent or[ coinfx.1 t able 17 ~' JUDGE SMITH: i
. c 18 with that st at ernent ?
\
s '9 THE WITNESS 5:eigler): ' Eiased on this article 8 1 c ; .,
20 rn i gh t rnod i f y it to be ' ' acre in l i.t m with the phrd i t 1; tW 'l I
21 appears in the article, n 1
22 But I think thet the essential po A M tt t w are i '
[ 23 raak i ng is rne ce, either way.
s I
24 Ani Dr. Jc;hnson says that h rt has talked to Dr.
t 25 Maxwell on toe phone and I don' t <now wheether that is where the 9 (
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- 2. THE WITNESS'(Johnson): I spoke with him a couple of .,
t,a, 3' years ago with reference to the Shorehara' proceedings, and it )
4 was baned on our conver,sation that the way thst it was
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D 5 striset ured 'here.
i 6 I think it ir real splitting hairs, personally, so --
7 MR. LEWALD: I see.
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f' 8 . JUDGE' SMITH: Unll, let's pursue that.
ti 9 Don' t you apor, eciate the 'dif ference that is being ,
10 inade here,h as ,cornpared. to those act ually scheduled to work, 11' compo ed to'thoselavailable to work? ]
1 12 Is that a difference, do you think, is a hair-split? I f
- t. . 13 THE WITNESS (Jonnson): No.
a ,
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14 1 thir.x what is crucial i s, that irnpl ici t in these ]
15 st$ dies is thrat there ira a staffing crisis, if they are 16' pai'lable to worB, it seerns to rne that there wed1d-not be a ,
l 17 s t a f f i n g ce,f,n i s. ,
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,1,8 JUDGE E!MITH: Well, just talk about the word,
- 2 p# . . .
IL Neheduled", in your instiraony, is that; an irnport ant word?
El'
! THE WITNESS (Zeigler): Yes, I would change that to 20 ]
21' (bring it rnore into line with the article.
ii 22 BY MR,;LEWALD: -
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- 23. Q Actually, the portion of Maxwell article that is I
' 24 referencNd, is footnoted to another soi..*ne, itself, is it not? l l
- 25' A (Zeigler) Yes, it i s. ;
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) 'ZEIGLER, JOHNSON, COLE - CROSS 8017 1 Q. And what source ~is it footnoted to?
l 2 A. (Zeigler) The.Harrisburg Patriot Evening News.
3 Q Has anybody ever read that?
4 A (Zeigler) Oh,.yes.
5 Q Does anybody have it?.
6 A (Zeigler) No.
7 G. I would like to go over your' testimony on Page 50.
8 And-we are still on-role conflict and your testimony 9 says the strongest and most direct evidence of the extent to 10' which role conflict'is likely to'be a problem in the event of c 11 Seabrook emergency comes from the Seabrook Evacuation Survey 12 already discussed.
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13 And then you go on to say, amonD the other questions, 14' the Seabrook Survey respondents in the New Hampshire portion of 15: the Seabrook EPZ, were asked whether or not they had an l l
16 assigned role in the plan?
17 And-if so, what specific role were they expected to 18' perform and then what they would do first if a Deneral i 1
19 emergency requiring-full-scale evacuation of ihe 10-mile plume 20 exposure was declared at Seabrook?
l 21 And the precise wording of the question, you suggest' -
J26 is in Attachment 5, at Pages 68 and 69.
l 23 Now, the result of that question was that of the 959 24- households surveyed, 2 percent contained individuals who 25 reported that they had an assigned eme.gency role in the plan.
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! And then you go on to say, as Table 2 shows, the 2 range'of services these individuals are expected to perforta is 1 3 t'airly extensive; including police and fire protection and
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'4 traffic cobbobl, einergency and t ransportat ion -- school bus and 5 ambulance drivers, emergency medicine, nurses and doctors and
.6, emergency communication and official radio or'TV position.
7 Now,.on Page 51, which is' inserted in the middle of 8 that response, there is a Table 2, and the Table sayu, AssiDned 9 Emergency Work Roles of Seabrook Evacuation Survey Respondents, 10 and then in parens,. (N equals 31).
11 And, can you tell me what N-31 means in reference to 12 this Table?
13 A (Zei Ul er) 1f you add up the absolute frequency 14 column lin the Table, you will get 31. There were 31 people who 15 responded to this question.
16 Q So there were, your 31 people responding and six of 17 those respondinD said, police, and.two of them, four of them 18 were associated with fire, and so on? ~4 19 Is this -- l 20 A (Zeigler) Yes.
21 Q Dn the column.
22 And then if we could go back to Table 1, which is on 23 Page 49,.and this Table shows the initial reaction of i
24 designated emergency personnel to an evacuation uummary.
25- And then in regard, unde > the column, Behavioral O
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(f ZEIGLER, JOHNSON, COLE - CROSS 8019 1 Intentions, The Gelected Personnel, Seabrook, N-31.
2 Is this the same reference that appears in Table 2, -
3 this.N-317 (
4' And then on that, we have percentages for the 31 5 Seabrook personnel, wherein, 52 percent say i nat they will l G perform'the emergency work; 39 say that they will check on-7 family; and'three will leave the area; three do something else; i
8 and. three don' t' know. j 9 Can the panel help me by applying some numbers to 10 these percentages?
11 What'is 52 percent in terms of numbers?
12 A (Johnson) About 16.
13 Q. Pardon?
14 A (Johnson) About 16.
15 0 And 397 16 A (Johnson). About 12.
17 Q And the three is --
18 A (Johnson) One each.
19 Q Pardon?
20 A (Johnson) One each.
21 Q One each.
22 Now, Dr. Cole, if we were to compute sampling errors 23 in the methodology that you have done for the survey, for these j lL 24 statistics, what figures would we get?
25 A (Cole) I am sorry, I don' t have a calculator with
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l l 2 (Counsel proffers witness calculator.)-
3 JUDGE SMITH: While he is calculating that, are 4 you -- it seems like you are almost completed with your cross-5 examination.
6 MR. LEWALD: I have, I think,. less.than five minutes, 7 but we can stop here. I -- we will be coming back -anyway so --
8 (The Board confers. )
9 JUDGE SMITH: All right, let's break and return at-L L .10 1:00 p.m., please?
I-11 (Whereupon, at 1 1 : 5 7 - a . m .~ , a lunch recess was taken, l
12 the hearing to reconvene at 1:00 p.m., the same day.)
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3 ' JUDGE' SMITH: You may proceed, Mr. Lewald.
4 MR. TRAFICONTE: Your Honor, Dr. Cole would like to 5 being with a correction, if we might.
6 THE WITNESS: (Cole) Yes, excuse me.
7 When I gave you the formula for computing the 8 sampling error, it should have been the following. It's P l 9- times P minus Q, divided by N minus.1, square root, t irnes 1.96.
10 Yes, it's the square root of P times P minus Q, divided by N 11 minus 1, times 1.56.
12 Thank you.
7'3 i Ts2 13- CROSS-EXAMINATION (Continued) 14 BY MR. LEWALD:
15 Q And the values of the letters are the same? P is 16 percentage, Q is what?
17 A (Cole) It's the inverse. If P is 50, then Q is 504 18 P-Q is not P.
19 Q So you could substitute 50 percent above the line 20 within the square root symbol, or 50 percent over N minus 1?
21 A (Cole) It would be . 5 t irnes .5 if you assume a 22 dichotomy.
23 Q Okay, thank you.
24 Now when we had ed.journed for lunch, I think I had 25 asked you if you had -- if you would compute the sampling error f
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ZEIGLER, JOHNSON, COLE - CROSS 802a i_e ' using the'same formula for that portion of Table.1 involving, 1
2 Seabrook-selected personnel for thefeategories. I think'the 3 first two would be sufficient. I' m not ' asking you to do the 4 leaveLthe area, do.something, and don' t know categories. .
5 Have you_done that?
6- A (Cole). Yes. Assuming'that'you have a dichotomy,; and 7 it's 52 as opposed to all others, it would be a sampling error 8' of pl.us.or minus 18 percentage points.
-9 O For the 52, perform emergency' work?
10- A (Cole)- Correct.
11 Q And how about check on family?
12 -A (Cole) I didn' t compute it for the others.
'13 Q Would you accept 17, percent?
14 A -(Cole) I mean, if you' ve computed it, it sounds 15 reasonable, yes.
16' O Thank you.
17 Now, before lunch I had referred to that part of your u '18 answer, well, to a question, I guess, beginning on Page 50, 1
L 19 which appears on 51 and the top of 52, and resuming l" . .
I 20 interrogation with respect to that answer and directing.your l
21 attent ion to Page 52.
22 You say that "When asked what they would do, first, 1 23 if a general emergency were declared at Seabrook," and this is 1
L 24 the emergency plan workers at Seabrook, "only half," which is L 25 52 percent, " indicated that they would report immediately to l-l Heritage Reporting Corporation (202) 628-4888 r
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ZEIGLER, JOHNSON, COLE - CROSS '8023 1 their assigned emergency postc."
l 2 That's the way the testimony reads, correct?
l-I l 3 "The other half gave responses suggesting that they !
4 would either not report, or would not-report promptly to 5 perforrn their assigned emergency roles."
- i 6 And then you say, "Among this latter group, a small 7 percentage indicated they would either leave irnmed i at ely, do 8 something else, or unsure what they would do."
9 And then you go on to say, "It's not surprising the 10 majority indicated."
11 Now, majority here, I assume, rneans the rernaining 39 12 percent and not majority of 52 percent who r, aid that they P
5 13 would, they would report immediately; is that correct?
14 A (Johnson) That's correct.
15 Q And than "not surprising the majority," which I take 16 it'is the 39 percent, which is what the panel agreed with, 17 " indicates that they would first raake sure their families were 18 safely out of the evacuation zone."
19 "Now, in response to the question, 'How would you 20 make sure your family was safely out of the evacuation zone,'
21 eight percent of 39," which I take it is some two people or sio,
- 22 " indicated that they would go home and drive their familios to 23 a safe place out of the evacuation zone, but a rnajority, 67 24 percent," which I calculate to be 17 percent, " indicated they 25 would call horne and tell the family to leave without them."
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1 Is that correct as I have added the numbers'to the j l l R percentages? j l 3 A (Johnson) You said 17 percent.
! 1 1
4 Q Yes. 4 5 A (Johnson) I assume you meant 17 individuals.
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.6t Q Seventeen wnat?
7 A (Johnson) I assumed you' meant 17 individuals. You 8 said 17 percent. l 9- Q Oh, 17. I' m sorry, I do mean -- I did mean 17.
10 Thank you for correct ing rie.
11 With that correction, have I correctly stated your 12 testimony?
13 A (Johnson) I think so, yes.
14 Q- Now you go on to say, " Implicit in.the latter 15 testimony'rcsponses, the notion the individual would then 16 report to his or her assigned emergency post."
17 Then the testimony goes on to say, "It is highly 18 unlikely, however, that these designated emergency workers 19 would be able to contact family members by telephone during an 20 accident at Seabrook plant."
21 And for this statement, I read your testimony to rely 22 on some study that was done in 1979, to the effect that the
- 23. telephone system would not be able to handle the emergency work 24 numbers; is that true?
25 A (Johnson) That's one source, yes.
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ZEIGLER, JOHNSON, COLE - CROSS' 8025 1 Q Is there another cited?
2 .A .(Johnson) There is.no'other cited here, but-there I
3 are other studies that show that telephone overload is a i 4 problem in many disasters.
5 (Pause.)
6- BY MR. LEWALD:
'7 Q Dr. Johnson, in reference to your prior answer and 8 your sources in add'ition to the source cited in your; testimony
.9 and in. Note 27 as to telephone overload, are these other 10 sources that you' re referring to from the New England, or in il particular,-the Seabrook area?
12 A (Johnson) No.
7 f .
t . 13- -Q And I have placed before you a one page letter, a 14 copy of a one page letter on the stationery of the New England 1S Telephone Company, under the date of December 14, 1987, 16 addressed to Mr. Anthony Callendrello, signed by Berton Smith, 17 Operation Manager.
18 c1R. LEWALD: And I would ask that this be marked 19 Applicants' Exhibit 28 for identification.
20- JUDGE SMITH: Twenty-nine.
21 MR. LEWALD: Excuse me, 29.
22 I think Appendix G had been -- I had asked that be l!
23 28. f 1
24 JUDGE SMITH: That's ri ght.
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U 7i 25 MR. LEWALD: And I think with the discourse with the !
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1 1 Board, I had asked that that'not be marked as an exhibit for 2 identification-because I didn' t intend to offer it as a l 3 separate' exhibit.
4 JUDGE' SMITH: All riDht, so we will' mark the letter 5 of December 14, 1987,- as Applicants' Exhibit 28 for 6 identification.
L 7 (The docurnent referred to was l
l 8' marked for identification as l
9 Appl icant s' Exhibit No.- 28.) I 10 MR. TURK: For clarification, Your Honor, do I L
11 understand thet Appendix G, Emergency Broadcast System
-12 Activation, should not bear --
13_ JUDGE SMITH: Doesn' t have any numLer.
14 BY MR. LEWALD:
15 Q In light of the information contained in Applicants' ;
16 Exhibit 28 for identification, should your -- well, should you j 17 not alter your testimony as to the opportunities for emergency.
i' 18 workers to reach their homes in the EPZ area in Seabrook?
i 19 M R. TRAFICONTE: I' m going to object, Your Honor. I j 20 don' t think it's appropriate to use information gathered j 21 apparently yesterday or the day before from officials who are i 22 not here, and then put this kind of information directly before 23 the witness and ask, in light of this information.
24 We don' t know what the questions were that were put -
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I 1 the information is to be interpreted.: Clearly, we don' t know j 1
2 whether it's true or not, but that would go to the hearsay l 1
1 3 aspect of it. .'
4 But beyond that, the recent vintage of this letter i i
5 gives me some pause as to whether it's appropriate to use in l
6 this-fashion. It may be rebutt.al, but I' don' t see it as 7 appropriate. technique for' cross.
8 . MR. LEWALD Well, the witness obviously was relying 9 on. hearsay for the statement that he has in his testimony as to 10_ the sources that he has in his testimony, and that which he 11 cited today. I don' t see that this is any different than the 12 other sources, and the question was --
b.
VN)- 13 l JUDGE SMITH: Well, you' re --
14 MR. LEWALD: And I don' t know whether he will say yes 15 or-no,'he would or would not.
l L 16 JUDGE SMITH: So in effect right now you are askinD 1
17 the Board and the' panel to accept as established the statements l
l 18 contained in this letter for the truth of it?
19 MR. LEWALD: Well, I' m asking if they would accept it 20 as the truth of the matters stated, whe',per this would change 21 their testimony, yes.
l' I
! 22 MR. TRAFICONTE: As a hypothetical then. In which 23 case, I don' t think we need this letter at all. If it's put as 24 a hypothetical, then I have no problem.
25 JUDGE SMITH: Do you intend to support this letter O
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1 other 'than just a nake'd offer of it?
2 MR. .LEWALD: We can bring in a witness who will 3 testify to this, as to the contents of the letter. I assure 4 you ' I' d idn' t make up the letter.
5- JUDGE SMITH: Oh, no, Mr. Lewald, you know --
6 MR. LEWALD: I -- we do have a --
7 JUDGE SMITH: -- this is a very fundan, ental --
8 MR. LEWALD: We would call this witness to have him 9 present the testimony, if necessary.
10 _ JUDGE SMITH: All right, if you are representing that 11- that's what you will do if it is required to do, I' ll allow you
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12 to cross-examine on it. But you' re not going t o, over the 13 objection of counsel, you' re not going to offer the letter 14 unsponsored.
15 MR. LEWALD: Is the question still to the witness?
16 ~ JUDGE SMITH: Yeah, you can examine him about this_as 17 a hypothetical, and the hypothetical will be, presumably, 18 redeemed when you call your witness.
19 BY MR. LEWALD:
20 0 Assuming,' Dr. Johnson, that the contents of the 21 letter are true as stated in the letter, would that cause you 22 to' change the conditions that you relate in your testimony on 23 Page 53 with respect to the hypothetical emergency worker being 24 able to contact his family?
25 A (Johnson) No, sir.
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P-~j's '- .ZEIGLER, JOHNSON, COLE - CROSS 8029 1- Q And could .I ask you what more you would need in this l
2 respect?
3L -A (Johnson) Sir, Is m relying on my knowledge of the 4 social science literature, and I think one of the general L
5' findings in that literature is that telephone systems 6 traditionally have been overloaded in disasters.
7 If that were not the case, I' m remiss to understand 8 why, in one of'your own EBS. messages, you advise people not to ,
9 use their telephone systems. 'It's stated clear on one of the i 10 messages that you handed out.
11 And I quote: "You use of telephones for unnecessary- I J
12 calls may tie up circuits needed by.others'for emergency 1
l 1 . 13 calls." ,
14 You are advising people not to use'the. telephone )
i 15 system.
16 I'can also give you a recent example of a natural l'7 emerDency in which the telephone system was tied up. And that a 18' example is the October 1st earthquake in California. My mother 19 tried to rail me all day and was unable to re.ach me. I.tried j i
20 to call one of my colleague's spouse, my colleague happened to l 21 be in Boston at the time, and I was unable to reach her all day 22' lonD. I fira11y reached her at 7:00 p.m. at night.
23 Now if ' that's not evidence that, you know, telephone 24 systems are problematic in emergencies, then I don' t know what 25 evidence you want to bear.
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- 1. I cannot' comment on.a specific telephone system. I' m H 1
2' not an. expert in' emergency communications, and I would: I 3 certainly not sit here and even attempt.to be one.- But the 4 general emergency 1-iterature.shows that problems with telephone 5 communications are'real in terms of emergencies. And.that is 6 whet our testimony is based on.
7 Q Would it be a fair summation of what you have told me O that you are not a communication expert, or an expert.in )
9' telephone connections, but you just know the circuits arefDoinD 10 to be. overloaded?
11 A (Johnson)- It would be fair'to summarize what I said,
- 12. and I' ll restate it again, that the social science evidence 13 shows that telephone tie upr. are a potential' problem.in 14 emergencies, and that it is' unrealistic to rely, or to expect' 15 that that may not be a problem. ,
i 16 Q Thank you, Doctor.
17' Now, you didn' t -- in this context.you say, the 18 survey data supported your contention that if'a major accident 19- were to occur at Seabrock, problems of conflict group loyalties 20 among the designated emergency personnel who reside within the l
-21 10-mile plume would significantly hinder efforts to implement i
i 22 the^ emergency response plan promptly, correct?
1 23 A (Johnson) That's correct.
24 Q' Now viewed in the context that you have viewed it, it I
25 is necessary, is it not, because of the result that you found q L !
l l --
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1 from your own survey?
2 A (Johnson) It's necessary because of the social 3- science evidence that exist, including some of.the results that 4 we fourd in our survey. ;
5 Q And where you have social science evidence that 6 indicates a matter that is contrary to the findings of the I -
7 sarvey, you would accept the social science evidence rather 8 than the results of the survey; is that correct?
I 1
l 9 A (Cole) That's a hypothetical that I am not in a I
10 position to comment on.
11 Q You don' t want to answer that? l 1e A (Cone > No. l 7 )
f )
L . 13 M R. LEWALD: I have no further questions.
14 ( Applicant s' Cross-Examination 15 Outline on Testimony of Drs.
16 Zeigler, Johnson and Cole 17 follows:)
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1 JUDGE SMITH: Okay. Do you have --
2 MR. TURK: Yes, I do. ,
3 MR. BROCK - Your Honor, excuse me, I did want to
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4 follow up'on the questions about the telephone system overload 5 just now. j 6 JUDGE SMITH: I' m sorry, I didn' t hear you.
7 MR. BROCK: I did.wish to examine the panel very 8 briefly on the issue that Mr. Lewald was just addressing.
9 JUDGE SMITH: All right, let's take your examination
- 10. next, right now. -
11 MR. BROCK: Thank you. l L E275 12 (Continued on next page.)
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LT276mb. 1 MR. BISDEE: Good afternoon, gentlemen, I am Dana !
3 Bisbee from the New Hampshire At torney General's of fice. l l
3- I just have a very;few questions for you. .
l 4 And as I said, it is about this question of i 5- telephone-overload.
6 CROSS-EXAMINATION 7 BY MR. DISBEE: H 8 Q Could you tell me'what the actual impact'was at Three 9 Mile Island when there were two million calls made on a system 10 made to: handle only one million?
-11 A (Johnson) It is my understanding that the system was 12 rundered useless.
O' . '13 Q No calls were'able to be made at all, is that your 1-4 understanding?
15 A (Johnson) Overload.means, to my way of thinking, 16 that you just cannot use.the. system, it is overloaded.
17 .Q And it is your understanding that it remained 18 overloaded for an extended period of time?
19 A (Johnson) I don' t remember the specific details.
20 Q Something like what, you, yourself, experienced, Dr.
21 Johnson, during the earthquake where you could not --
22 A (Johnson) That is pretty frustrating, yes.
- 23 Q So, is your testimony based on the assumption Yhen 24 that in a Seabrook emergency the-system would be overloaded so 25 that no calls at all would be made for a certain period of Heritage Reporting Corporation (202) 628-4888 f i
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) ZEIGLER, JOHNSON, COLE - CROSS ,8039 l l' t'ime?
l' j 2 A (Johnson) Yes.
3 Q 'So the statement that you make on Page 53 of your 4- t est'i mony, that the only reasonable assumption thatlyou could' 5 make is that people would leave immediately to check.on their j l
6 loved ones, is based on the assumption that they would not.be_ ,
'7 able to reach their family by telephone at-all?
8 A (Johnson) That is correct.
,9 (Pause) 10 Q What if there were a slight delay in their ability to
.11 cell their families?
12 A (Johnson) It would --
13 Q Would that change your position?
14 l A (Johnson) .That is a hypothetical that I cannot 15 speculate-on.
-16 Q You cannot --
17 JUDGE SMITH: You can -- you may -- you don' t have to 18 agree with a hypothetical before you give your best answer.
19 You can accept, you know, you can make it clear that you don' t 20 agree with a hypothetical.but you can accept the hypothetical 21 for the purpose of the question and answer it to the best of 22 your ability assuming the hypothetical is true.
23 BY MR. BISBEE:
2 4' Q Do you understand what I am asking?
25 A (Johnson) Yes.
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f)' ZEIGLER, JOHNSON, COLE - CROSS 803b i It did not have any time frame on it, and I guess 2 that is why I characterized it as a hypothetical. How long are 3 you expecting people to wait to be able to contact their 4 families?
5 Q Okay, let me ask you this.
6 If an emergency worker were to make one call and be 7 unable to reach the person he was trying to, would that l
j 8 inability to reach that person', by itself, cause, in your view, t
l 9 the person to leave immediately?
V i 10 A- (Johnson) I think it varies dependinD on the person.
1 I
11 Some' people it may be enouDh to force them to go immediately.
12 For others, they may wait and try two, three maybe even four
- t. -
T L- / 13 times, maybe even five t unes to reach their families.
f-14 I think it depends on the person.
l 15 Q In your view, is it reasonable to expect that people 16 would try a second time and reach their families so that if 17 they were unable to reach someone the first time that'they 18 would try again and perhaps be successful in doing so the 19 second time?
20 A (Johnson) I don' t know whether they would be ;
21 successful but I don' t think it is unreasonable to expect that 22 a person would try a second time.
23 MR. BISBEE: That is all that I have.
24 Thank you very much.
25 JUDGE SMITH: Mr. Turk?
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ljl ZEIGLER, JOHNSON, COLE - CROSS 8036 1 MR. TURK: Thank you, Your Honor.
2 CROSS-EXAMINATION 3 BY MR. TURK:
4 Q Gentlemen, my name is Sherwin Turk and I am an 5 attorney with the NRC Staff.
6 I have a series of questions, which to some extent 7 are going to tread over the same ground that were raised in Mr.
8 Lewald's examinat ion earlier today.
9 I ask you to bear with me. I won' t prolong this and 10 I hope that I will be able to finish with you before 1.im i t ed 11 appearances start.
12 I can' t promise that that will happen, but I am noir.g h 13 to try. j 14 Dr. Johnson, your testimony addresses to some extent' l
15 the survey work.you did in the area of the Three Mile Island I 16 nuclear plant.
17 And I am, wondering if you know what the population 18 size is of the area which was the subject of your survey?
l 19 A (Johnson) I don' t recall.
20 Q Do you have a general idea of that population size? l 21 A (Johnson) No. I
)
l 22 0 .Well, let me see if I can focus for a moment. {
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23 MR. TURK: Excuse me, one minute s Dentlemen, I would -
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24: appreciate it if you would not confer while the question is i l 25 . being asked. If a person to whom a question is asked, needs to
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() ZEIGLER,' JOHNSON, COLE - CROSS- 8037 i confer, he can identify that on the record, and then we can'see a' if th'at will be permitted.
3 But absent an indication that the conference is 4 needed, I would-appreciate it if you would, hold back on'your 5 '. coriferring at~.the table-for the momente
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i 6 BY MR. TURK:
L7 Q Dr. Johnson, in your survey-of the Three Mile Island-O' area, you' sought to send'in questionnaires to people who lived 9 within five miles of the plant, is that correct?
10 A (Johnson) That is one'of the distance spans that was 11- included in our_ survey design.
12 O And in addition to that area, you looked to send out 13 questionnaires to people who lived within 'five-to-15-miles of 14' the plant, is that correct?
15 A (Johnson) Yes.
16 O And in addition to those two areas, you also sought 17 to send questionnaires to people who lived in other communities 18 outside the 15-mile radius, is that correct?
19 A (Johnson) That is correct.
20 Q And do you have any idea at all of what the 21 population size is in those areas?
22 A (Johnson) No, I don' t .
23 Q You indicated in your testimony that approximately 24 144,000 people evacuated from the Three Mile Island Area, is 25 that correct?
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) .7EIGLER, JOHNSON, COLE - CROSS 8030 1 A (Johnson) Ye%
2 Q- Do you know what. percentage of the population 3' evacuated?
4~ A. (Johnson) That is 39 percent of the population n 5 within a 15-mile radius of the plant.
6 .Q 'Does the figure,- 144,000 represent'only those persons 7 who live within 15 milesEof the plant?
8 A (Johnson)' Yes.
9 Q So if I do.a simple calculation, I'come up with 10 something on the order of 369,000 people, who would be presumed k if to live'within 15 miles of the plant, is that approx iniat el y '
1'2 your understanding of what the population rize would'be, within b_.- 13 the 15 miles of the plant?
14 A (Johnson) As I indicated earlier, I don' t know what 15 the population'is, and if your calculation is correct, then I 16 accept your figure.
17 Q Do you have a calculator at the table with you?
18 A (Johnson) No, I don' t .
' 19 .Q And let:me explain what I have done.
I 20 I have taken 144,000 and I have divided it by 39, 21 would that be an appropriate measure to determine what the
. 22 percentage, what the 100 percentage figure would be?
23 A (Johnson) I guess so.
24 Q Excuse me, I should say I divided it by . 39.
25 A (Johnson) .39, yes.
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() ZEIGLER,. JOHNSON, COLE'- CROSS 8039 1 Q And when I did that I came up with 369,230 people.
2 Now, in addition to that population size, you 3- surveyed several communities outside the EPZ.
4 And'you identified in your testimony-that one of'them 5 was a small community; one of them a medium-sized comtnunity; 6 and one of. thern was 'a large comrnunity.
7 ~I believe the large one was Lancaster.
8 -Do you know what the population sizes'are in those 9 tbree comtnunities?
10 A (Johnson) No, I don' t.
11- Q. Can you give toe an order of rnagnitude?
12 'A (Johnson) I have.no idea.
13 Q Does anyone at the table have an order of magnitude 14 idea for that?
.15 A (Zeigler) Lancaster is a rnetropolitan st at ist ical -
16 area. There are.at least 50,000 people living in Lancaster.
17 Carlisle perhaps has maybe 30,000 people.' Duncannon 18 perhaps has -- gosh, I don' t know -- 12 or 10,000? No, that is 19 too many.
20 Duncannon is a smaller town. I would hate to even 21 offer an --
-22 MR. TURK: Excuse rne, I would like to ask that there 23 be no conferences at the table while the questions are pending.
l 24- THE WITNESS (Johnson): I am sorry, sir.
L 25 MR. TRAFICONTE: Now, wait a minute, while the LO
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ZEIGLER, JOHNSON, COLE'- CROSS 8040 1 questions are pending or while the questions are.being 2 formulated. Because we have had conferences at the table 3 certainly after the question has been put, as I understood your 4 earlier comment.
5 Now, it is conferences while they are pending. So
, 6 that would be a change, in my understanding of the ground 7 rules.
b 8 The panels'have conferred while there have been 9 questions pending.
l 10 JUDGE SMITH: If he doesn' t want collaboration in the I
l 11 formulation of' answers to his questions, that is his 12 prerogative.
t t .- 13 MR. TRAFICONTE: I understand that, Your Honor, but 14' this is a new instruction is my point, to the panel. They are l 15 not to confer at any time, either before a question is put, or 1:
16 even when-it is'pending.
17 I just want clarification. They have to understand 18 what they are supposed to do and not do.
19 JUDGE SMITH: I guess I don' t appreciate it, but the 20' distinction you are' drawing, but it would be better. gentlemen, 21 if you did not confer unless you are invited to by the, by Mr.
22 Turk.
23 MR. TURK: And also i f, at some point, you feel the 24 need to confer, you may identify that on the record, and we can J
25 see if that is necessary. 4 Heritage Reporting Corporation (202) 628-4888
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()' ZEIGLER, JOHNSON, COLE - CROGG 804]
L 1 I want to explain my reasons. I don' t want you to I
- 2. feel that I am being unfair. In cross-exarnination of a panel 3- it is important that the person to whom.a question is directed 4 provide an answer.
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! 5' 'And if sorneone else has something to supplernent, or t
6 if they differ, they are free to rnake that expression. We are 7 not seeking a collegial opinion in the first instance, or l 8 seeking independent thought to the best extent p'ossible.
9 BY MR. TURK:
i 10 Q Dr. Zeigler, you indicated that Lancaster had a 11 population of 50,000-plus, what would be the upper-end of that l 12 potential population sire?
l.
.: 13 A (Zeigler) I will only say . ttunt it has'been so long 14 since I looked at these population figures, that they are not 15 fresh in my mind, and I would prefer not to respond to that.
16 Q Well, if I sirnply add the 369,000 figure to the l
17 50,000, 30,000 and 12,000 figures, I come up with a population 18: in the range of 461,000 plus.
19 Would that be a fair characterization of the 20 population size of the area surveyed?
.21 Yes, or no.
22 A (Zeigler) -- I --
23 MR. TRAFICONTE: -- well, I think that question has 24 been put to thern in parts. And you have gotten the answer that 25 they are not sure.
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l 1 And so if you add.it;.up and'put the question again, I j 2 think that it is a little bit' unclear as td what; they can 3 possibly. respond.
.4 ,
They have l'nd i cat ed to you that they don' t ' know the
{
5 population in those areas.
6 JUDGE. SMITH: Now, you are asking -- there,was a s
i 7 question and answer that I missed, but I thought we had' fairly-8' well established the mathematics of. arriving at t'he greater 9 Harrisburg, or 15-mile. :
10 And then it would seem to be a reasoned estimate for the 11 'other three cities, but therewasaninterveningquestionand;( :p
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12 answer that I missed, but it seams to me, absunt that-beipp c
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contradictory, this question right now, is-appropriate.
a.
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- l 14 MR. TRAFICONTE: I thought there was another ty ' l I
15 popu1Ltion input there, besides the 15-mile band and the threei s
16 towns. Maybe I missed that intervening question, too.
17 MR. TURK: Your Honor, at this point, I would'like to 18 note that Dr. Cole has passed a note t o Dr. . Johnson.
19 And I don' t understand what is going on at the table R 20 and I would like to ask the witnesses what i s happening there?
21 JUDGE SMITH: Well, what is happening?
wq 22 THE WITNESS (Cole): Yes, I did pass a note.
23 It was our understanding that as we wrote this 24 testimony that it was a collaborative work.
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! 25 JUDGE SMITH: Well, that may very W911 be. I did say 30 N l Heritage Reporting Corporation l (202) 628-4888 LJ z_____ _ _ -
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3 2 I' guess.I should habe gone all the yfy and told you, t' O - v :n N ., 1 k .p( ' [' s
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6' MR. TURK: I would like to make a note, also, around gl
- x. ; c A O
( ;. 7 this D roint. The testimony in huestion, in the direct testimony
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. n 8 as identified 'au the testirnony of Dr. I2eigler an.. gD, r . Johnson. -(l
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- a. E 9 And'this is-(the quest 4cn and answer beginning WL t-he' l -
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;g 30 bottom of Page 6, and continuing on to Page 7. I don'p-,t ses Dr.
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1 l b' (Cole's narne bp that piece of test irnony._' i.
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proceed. 5 12 61UDGF/ SMITH: g 4ta'g g I *
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(. 13 1bH. TRAFICOhik 'Well, I don' t - s f j 14 3 L t JUDGE SNiTN: 'po ceed , proceed. n % i(' y' , yb May I air 47
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( . , 15 THE WITNESS (Zeigler): jr t
.4 s.
(q - r 16 BY MR. TURK: 1 . .
<b ,- '( r- pd kred(ad you like to co,rf9 back to the oriD nal nuestion?
- f. -17 Q ,
i 't j4 2 _ p),i%f y )t <w c I f t s.
) '( la !
f< ,.Zeigler) To jhe br iginal questimp?s( 4
, \ g 19 y U Yes. A'nd that in in terms of tp pbpu l at i on s i z e -~
- 20 A (Zeigler) Yes, I Imwilling,to.acdept your addition- ]
s, 21 that is, your mathematical addition, witp the proviso that I arn + 22 not sure at this point in time what th population of these 23 communities was at t he d i rne o f t h,e acc ident,., 5' ', l l 24 (continead on ne t pageo x i
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.,' Butil'would also Jike to say.that the 144,000 figure r y 2 was a figuretthat we contpdtied using the NRC's own data. So that 3 J'was Mot a 1igure that we generated nor]was the.pg.4centage, . as I d1 4 cAcall, 39 percent, a figure that we generated. 1
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f f . . . . ..
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5 i }; f *8 ,, The NRC had a icmger dh'.:a baar and they computed l i ,l j i' j' 6 o their estimate of the curnber o. f evacupes i and we have reported
-)
7 that, 2 O.
.. Q ' And When you refer to the NRC, are you referring to l ,1 , l
< 9 t h e ' re t. ort done by Mounto.in Wsst Research? j 1 ;<, - y 10, 4.' 12eigler) Yes, U av. ;
i 11 0 You don' t quarrel wiI:h their statistics or with their ;
>. . a' 12 populatzon..by estimate, do you?/ i.
3 P' > ; , i N2 13 A= (Zeigler) No. 14 Q Gentlemen, how did ~ vyd this is to Dr. Johnson, in
'15 the first instanae, 'now did you make a determination to send 9,.
) Y 16 out 300 surveys'? i. p,? 17 P/' tuohnson) Co s t, .
- 18 Q Could you explain,that?
}{ <
I' 19 A Uchnson) Yes. r; 20 We funded the st udy ciurselves, but Dr. Zeigler and I 21 were graduate undeents at th'e time and we did it in I, C 22 collaboration with our dissertation advisor. d -j p' 23 We felt it important to get data w. noon after the ii,s ' 24 accident as humanly possible, therefore, we did not have time E'f 1 ll), 25 to: write a grant, so we funded it ourselves. io
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~1 And we funded what we could afford to fund.
2 '- 0 I would like to focus on several aspects of the 3 evacuation at Three Mile Island. 4 At Page 9, of'your testimony, there is a discussion' ' 5 near the bottom oflthe page, that "During the eruergency, . the 6 State of Pennsylvania advised evacuation of all pregnant' women. 7 and pre-school age children within a five-mile radius of the a 8 plant." 9 Gentlemen, do you know when that advice was issued? 10- A (Zeigler). Ves'. 11 As I recall, that-was issued by the Governor of
~12 Pennsylvania, around 10:00 a.m.,on Friday morning, of that s.
~
E 13 week.- 14 Q And to the best of your recollection, when did the
~15 accident occur at Three Mile Island?
16 A (Zeigler) The accident occurred the previous 17 Wednesday, I believe around 4:00 a.m., in the morning, with 18 notification being delayed until about 7:00 a.m. 19 Q And do you have any knowledDe as to when the first 20 reports of that accident began to appear in the rnedia? 'l 21 A (Zeigler) It was Wednesday morning. 22 O So that approxirnately two days time passed before the 23 Governor'of Pennsylvania issued the advice to pregnant women 24 and younD children.to evacuate? 25 A (Zeigler) Oh, yes. l Heritage Reporting Corporation (202) 628-4888 l t.
l 1~ l l. l 1-L () ZEIGLER, JOHNSON, COLE -' CROSS 804b L 1 Q' After the initial reports:were out to the' media? ji L 2 A (Zeigler) Yes. l- 2F G And do you know, general'ly speaking, what, sort-of . 4: information had been provided to the public. prior to the 5' Governor's recommendation on Friday morning?
~
.'6 A (Zeigler) Well, there was just every~ conceivable 7 type.of information that'you could imagine.
8 Q Do I assume from that, that there were. conflicting
.9 reports?
10 A (Zeigler) Oh, yes. Li l ' Q: Confusing reports?
.12 . A (Zeigler)' Yes,'sure.
A; .., 13 -Q Do you recall whether the Mountain West research
- 14. study iridicated.that the existence of confusinD information
- 15. within the public or within the public realm was a contributor
'16 to the public's- reasons for evacuating?
1~7 A (Zeigler) Oh, yes, it was. 18 ~ It was also, according to our survey, a contribut ing 19 f actor . in the . people's decision to evacuate. And it was also 20 one of the factors that people, who did not evacuate, cited for 21 their decision. 22 So, people were using confusing information, to make 23- a decision both to evacuate and not to evacuate. And I believe-24 both' the Mountain West study and I know our study reached that 25 same' conclusion. Heritage Reporting Corporation (202) 628-4888
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..1- So confusing'information cut across both
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2 categories -- the evacuees'and the non-evacuees. It was a - 1 l 3- constant. -l { 4 0. Gentlemen, are you aware, as to whether at the-time, 5 of the Three Mile accident, the Nuclear Regulatory, Commission - y
'6 had any regulations or guidance in place, as to;the type of
-7. public information that.should.be made available to the public 8 in the event of.a radic'ogical emergency?
9 A (Zeigler)I I cannot say that I know if they had any 10' regulations in place. If.they had it in place, they were'not 11' employed. f12 A (Johnson) Not at TMI. 13 .A '(Zeigler) Not at.TMI. 14 O Are you familiar at all with the regulations that had 15 been adopted'inJ 1980, and the regulahory guidance contained ire 16 NUREG-06547 17 A (Johnson) Yes. 18 A- (2eigler) Yes. 19 Q And you are aware that those regulations and those 20 statements of guidance, were issued after the accident at Three 21 Mile Island, weren' t they? i 22 A (Johnson) That is correct. j 23 A (Zeigler)~ Yes. j i 24- Q And you do recognize, don' t you, that the Emergency l . 25 Broadcast System Messages which were discussed in part, in Mr. Heritage Reporting Corporation (202) 628-4886 i
i 3-,)
- ZEIGLER, JOHNSON, COLE - CROSS '8040 1 Lewald's examination, were drafted in response to NRC 2: regulations'and guidance, you recognize that, don' t you?
3 A (Johnson) Yes. l 4- A (Zeigler) Oh, yes. l
- 5 'O. And at Page 12,-of your testimony, this is addressed
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6 to anyone on the panel who cares to respond. 7- I see all three of your-names appear at the answer. 8 You indicate.that, "In connection with this 9 litigat ion .the Massachusetts Attorney l General's. of fice retained 10 as' consultants a group of social and behavioral scientists with t il expertise in technological hazards, and planning, to analyze. 12 the: adequacy of NHRERP Revision 2."
..13 Do you see that statement?
l 14 A (Zeigler) Yes, I.see it. 15 O Can you identify the members of this Droup-of' [ l-l 16 scientists referred to, in your testimony? ( 17 A '(Zeigler) Well, there was Doctor Johnson and there 18 was me. And there was -~ ! 19 A (Johnson) There was Dr. Al Luloff. I 20 A (Zeigler) -- Dr. Al Luloff. Dr. Ortman Renn. 21 Q Pardon me? [ Dr. Ortman Ronn, I believe. l_ 22 A (Zeigler) l 23 Q I don' t catch the name. I 24 A (Zeigler) Ortman Renn. l 25 0 How does he spell that' lO l - i Heritage Reporting Corporation ; (202) 628-4888 l t <
- 1. .
I- _ ._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
. (f 'ZEIGLER, JOHNSON, COLE - CROSS L3049 1- A. (Zeigler) R-E-N-N, perhaps?
2 A (Johnson) W-R- -- I . don' t know. 3 A (Zeigler) I don' t , know. 4 And Dr. Cole, and Dr. Adic , Tom Adler, Dr. Colin 5 High.'. 6 I believe they are all mentioned at one-point or 7 another in this testimony. 8 O Apart from persons mentioned in your testimony, .or 9' sponsors.of other testimony in this proceeding,. afforded by the 10 Interveners or by the Massachusetts ' Attorney General's of fice, 11 are you aware of any other persons who were consulted? 12 A (Zeigler) 1 am not,- no. k -
- 13. O Anyone else on the' panel?
14 Dr. Cole? 15 A (Cole) No. 16 (Pause.) 17 Q We have had some discussion today already about the 18 survey you did in the Seabrook area. 19 And Dr. Cole indicated that the questions that he put 20 forward in the questionnaire would have been the same, even if 21 the NRC had asked him to do a questionnaire. 22 Is that a fair paraphrasing of your testimony? 23 (Pause.) 24 A (Cole) The questions on given topics, I tried to 25 make clear that if the NRC had wanted to cover other topics, l l. L Heritage Reporting Corporation (202) 628-4888 l' l . .
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ZEIGLER, JOHNSON,-COLE - CROSS 18050
'l 1 then we would have included questions dealing with'those 1 l
topics.
~2' 3 To the extent that the NRC had asked us to do a 1
- 4- survey on, the sarne topics, as we were. asked to by the .
h 5. Cornrnonwealth of Massachusetts, then the' questionnaire would I
. . I
- 6' have '. been the sarne, yes.
l 7 (Pause.). l 8 Q- In the developraent of the questionnaire, I believe 9 that you indicated that there were a series of rneetings, with 10 Massachusetts Attorney General, Interveners and other persons, 11 is that correct? 12 In the course of developing the questionnaire? ! , l l'3 - .Is that correct?
'14 A (Cole) There were a series of rneetings with the 15 representatives of the Massachusetts Attorney General on the
'16 other consultants.
.17 Q Arad in the course of those rneetings, were suggestions l 18 roade'to you, as to how questions should be phrased?
19 A (Cole) Yes. 20 0 And were suggestions also rnade to you as to whether 21 or not certain questions were appropriate?
'22 A (Zeigler) It was a general atrnosphere of discussion 23 that reigned at these rneet ings.
(- 24 So, yes, there was quite a cornrnon interchange
.25 concerning what questions we needed to achieve the objectives Heritage Reporting Corporation (202) 628-4888
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. 'ZEIGLER, JOHNGON, COLE - CROSS 805]
t 1 we.had set out for ourselves, and so forth. -
._2 l (Continued on the next page.)
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' Z!i I G L E R , '. J O H N S O N , COLE - CROSS 8050 T277' 1 0 That's your underst anding . as well, Dr. Cole?
2 A (Cole) Yes. You should remember that I wac not 3- actually present at these meetings. 4 0 Yes, I believe you referred.to your ex-wife as one 5 peeson, and perhaps someone else from your firm who actually I
-)
'6 attended the meeting.
7 A (Cole) That's correct.
-8 Q Now you don' t know, do you, if you had met with NRC o 9 Staff or other persons apart from the groups who did meet-with 10 your firm, what sort of questions or comments they might have 11 had with respect te your questionnaire, do you?
12 A (Cole) No. ( 13 Q At Page 16 of~the testimony, and.this is addressed to 14 Dr. Cole, in the upper half of the-page, you indicate that, 15 "The survey ended up with 54 percent female respondents and 46-16 percent male respondents, which closely corresponds to the sex 17 distribution of the population." 18 De. Cole, can you tell me what the sex distribution 19 is of the population within the Seabrook EPZ? 20 A (Cole) I don' t recall precisely, but it was either 21 53 or 54 percent female, as I recall. 22 Q And where did you obtain that number? 23 A (Cole) From census data. ; i' 24 Q And I presume that was the most recent census 25 available? . Heritage Reporting Corporation , (202) 628-4888 J
k I ()) .ZEIGLER, JOHNSON, COLE - CROSS 8053 l1 A (Cole) Yes. 1
.o . 1 2 Q Census data available to you?
3 A -(Cole) Yes. l
'4 Q Do.you know what the distribution is for heads of 5 households by sex within the Seabrook EPZ7 6 A Would the census data indicate that?-
-(Cole) 7 A (Cole) It might.
8 Q And your survey was with heads of households, wasn' t 9' it? i p 10' A ~(Cole)- Yes. 1 11 Q Did you know at the time you conducted the survey 12 what the sex distribution was for heads of household within the 13- Seabrook EPZ?
= 14 .A- (Cole) No.
15 Q Do.you have'an experience in'the survey work you have 16 done prior.to the Seabrook survey which would lead-you.to have 17 an opinion as to whether males or females generally predominate 18 as heads of households? 19 A (Cole) Well, generally there are more female heads 20 of households than male heads of households. 21 Q That's true on a national basis? 1 l: 22 A (Cole) Yes. I' m not a demographer, but that's my 23 understanding, yes. 24 Q In the event there is a family situation where
.- 25 father, mother and childrwn reside within the same household,
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.( ZEIGLER, JOHNSON, COLE - CROSS .805L
'1 ' is there a standard, or a general tendency for either male or i
L 2 female to be considered the head of the household? 3 A. (Cole) No, we would refer to the female or male' head 4 of household. In the case of a married, couple living together L !' in a home,.they.would both be heads of household. 5 i 6 -O So you would have two heads of household in that I l 7' situation? 8 A (Cole) Yes. 9 Q And that's regardless of what .the psychological 10 makeup was of the family and of the relationship between a 11 husband and wife? 12 A (Cole) Yes, we have no idea about that. (Dl/- 13 Q There.would simply be a standard assumption that '
- 14 there are two heads of household. ]
15 A (Cole) Yes.
- 16. Q ' And that's the assumption you made in your survey?
17 A (Cole) Yes. l 18 At Page 20 of the testimony, at the top of the page, ' Q 19 Dr. Cole, you indicate that, "An occasional error by an 20 interviewer was detected and corrected." 21 Do you recall at this time approximately how many ; i 22 such errors were detected and corrected? : 1
.23 A (Cole) Oh, very few; a handful, four, five, six, I 24 something like that.
I 25 Q And what was the nature of the error that was l l Heritage Reporting Corporation (202) 628-4888
() ZEIGLER, JOHNSON,. COLE - CROSS- .8055 1 detected? 2 A '(Cole) Oh, sometimes you would find'an' interviewer 3' would put down what we call a stray punch. That is, they.would
'A. write down"a number ' for 'which 'there was rio designated code.
.5 ' For example, if you have.three. categories in a question, one, 6 two, three, you would see a five there. That's' an error, ,
7 obviously. There1is no category for that. 8 _Sometimes a skip instruct ion wasn' t followed 1 I 9' precisely. 10 But as I said, there were very few such errors. 11 Q In the course of the verification effort, you-12 indicate on Page 19 that.there was to some extent some 13 listening'in on the telephone calls. Do you see that at the. 14' top. 15 A .(Cole) Yes. 16 Q The answer-there in the middle of Page 19. 17 How many telephone' calls were listened in to by a 18 verifying person 19 A (Cole) Well, there were'two' sets of verifiers.' 20 There were employees of Marketing and there were employees of 21 Social Data Analysts. This is just a rouDh estimate. I would 22 say that the Social Data Analysts employees must have listened j i 23 in on several hundred calls, and I' m sure that the market ing l- ! 24 supervisors listened in on more. 25' Q And in those instances, did they listen into the D i Heritage Reporting . Corporation l (202) 628-4888 V l^
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) 2EIGLER, JOHNSON, - COLE ~ CROSS 805( ,
1 whole conversation? L '2 A (Cole). Sometimes, but generally not. 3- Q- 'Was the' person conducting the interview'by telephone.
- 4. given some, directive as to how long-his interview should take?
5- A' . (Cole)- No. i 6 Q. How long did the interviews actually take? 7 A' (Cole) As I recall, they were between 15 and 20-8 minutes. 9 Q Did_any extend beyond 20 minutes? 10 A- (Cole) Yes. There's always a tremendous variation
. 11 in'the length of. time that'it takes to complete interviews.
I' m 12 sure that some extended beyond 20 minutes, and there were
, \
' 13 probably:some that were completed in 10 minutes, or maybe even 14 leus. There's a huge variation in this. L l
15 -Q And how many persons actually conducted the telephone 16 calls?- 17' A (Cole) I can' t answer that precisely, but I can take 18 a guess, and I would say that there probably would have been 19 maybe 30, 30 to 40 people that were doing it. 20 Q Was each of-those persons expected to achieve some ! 21 sort of-quota in terms of number of telephone interviews , 22 conducted? 23 A (Cole) No. f 24 Q Were they expected to complete their work within any 25 particular time frame? , Heritage Reporting Corporation (202) 628-4888 I
() ZEIP ER, JOHNSON,-COLE - CROSS
. 8059 l- A. . (Cole) N.
2 Q. Do you t>t vve.that there may have'been any perceived 3 pressure by the telephone callers to complete the interview 4 within a certain time?
- 5. A (Cole) No, 6 Q In the occasions in which telephone calls were- ,
7 listened into for verification, and where -- also where 8 occasional. errors were detected, were there any errors detected 'j
.l 9 where the questioner omitted;a question,'one or another l I
10 question? 11 A (Cole)' 'Not that I' m aware of. i l i 12 O Were there any. instances detected where an t i ah - 13 interviewer. neglected to read all of the wordsLin the 14 questionnaire? 15 A (Cole)- I personally did not' listen in on several 16 hundred calls, and I coul'dn' t . answer that. It's. quite possible in all those calls that one 1 '7 Q l 18 interviewer,.or whatever, may have left out a word.. You' re . I 19 reading a questionnaire. It's . possible that anybody could leave 20 out a word. But, in general, the interviewers were following 21 the survey instrument as it was written. 22 O Did you make any attempt to compare the results 23 obtained by each of the callers to see if they were consistent 24 with the results achieved by other callers? I No, there were too many interviewers doing l 25 A (Cole) D Herit age Reporting Corporation L (202) 628-4888 i l
! l i l [ ). ZEIGLER, JOHNSON, COLE - CROSS 8050 l 1 this. _' The ends wouldn' t have been sufficient to do any j 2 reliable comparisons. That's only relevant if you have a .- 3' ' relatively small number of interviewers'doing a'relatively 4' l'arge number of interviews. 5 When you have 30 or 40 interviewers, it's not 6 generally done. 7 Q Earlier you made reference to some census data for 8 percentage of persons within the EPZ who may be male or female. I 9- Are you aware of any census data tor' number of 10 persons who do not own their own automobile? 11 A_ (Cole) No, I haven' t seen those. 12- Q I may have missed this in going through your 13 questionnaire, and I ask you to forgive.me if I have. 14 Some of the questions were directed toward the issue 15 of whether persons within the household would require public 16 transportation. I don' t recall see'ing any question _as to 17 whether or not the persons surveyed'had ava21able space in i 18 their vehicles to offer to others who might need ride 19 assistance. 20 Was that type of question asked? 21 A (Cole) We did not ask that, no. 22 O And did you ask whether any of the respondents would 23 in fact offer rides to persons who needed assistance in 24 transportation? 25 A (Cole) No. 4 I l Heritage Reporting Corporation j ! (202) 628-4888 ) i l l b
) ZEIGLER, JOHNSON, COLE - CROSS 805')
1- Q I' d like to 'turnito the specifics of the survey for a 2 little bit. And I have to adriit I' m a little bit confused.in 3 the numbers. 1 4 If I' m correct, you . completed interviews with 915 5 persons who reside within the-New Hampshire port ion of the 6 Seabrook EPZ; is that correct? 7 A (Cole) Yes. 8; Q And of those 915 persons with whom you completed 9 interviews, you indicate that,-and this is at Page 60, two 10 percent of those households represented by those telephone 1 11 calls contained individuals who reported that they had an 12 assigned emergency work role in the plan. L 13' How many of those 915 households had individuals who
- 14. reported an emergency worker role in absolute numbers rather-15 than percentages? i 16 A (Cole) You' re addressing this to the people who I
17 wrote the testimony, Drs. Zeigler and Johnupn? 18 Q Forgive me. Yes. 19- A (Zeigler) Could you tell me where you are again? 20 0 Yes. 21 A (Zeigler) Page 50 of the direct testimony? . L 22 Q That's correct. 23 MR. TRAFICONTE: Your Honor -- l l 24 THE WITNESS: Two percent of 915, so it would be , l L . 25 about 20, 19, 20 people. L-- I' l' Heritage Reporting Corporation l (202) 628-4888
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BOGO ( ')- ZEIGLER, JOHNSON, COLE - CROSS 1 BY MR. TURK: j l 2 O If 1 multiply 915-by two percent, I get 18.3 1 3 households. 4 A' (Zeigler) Okay, fine. , a 5 Q Wel'1 -- i 6 A' (Cole) Yes. 7 Q You ' obviously ' don' t have a fraction of a household. ; 8 A (Zeigler) Right. 9 Q So was it probably'about 18 households, Dr. Johnson? 10 A (Johnson) Yes. 11 Q .I see Dr. Cole wants to add something. 12 A (Cole)' When you get a veryfsmall number like this,
'()
v- 13_ you have rounding error. When we report two percent, it.could- l 14- have been, let's say, 2.46 or something. So i t ' u : -- without
- 15. Doing back to the raw data, it's impossible for us to compute 16 the exact number of cases.
17 Q Dr. Cole, do you agree that it was approximately 18 18~ households which reported emergency worker members? 19 A (Cole) More or less, yes. 20 Q Within what range of approximation? 21 A (Cole) Well, you have the calculator. What would b 22 2.49 times 915 be? l l t 23 Q I get 22.78. l -. p 24 A (Cole) Yes, so it's more or less within about 3.18. 25 Q And that's the upper end. I suppose the lower end EO p l: Heritage Reporting Corporation (202) 628-4888
h oi N' .ZEIGLER,. JOHNSON, COLE - CROSS {j 806 , 1- could be 1.5 -- 2 A (Cole) One. 3 .Q Which leads me to 13.8 households.
- 4. So, Dr.' Cole, is the range somewhere between 13.8-and 5 22 and a fraction?
6 A (Cole) Yes, assuming your_. calculations are correct. 7 O An'd can we agree that it's approximate 1y18
-8 households?
-9. _A (Cole) Yes.
i 10 MR. TURK: Your Honor, I' m on Item 8 of my cross-l l '11 - examination plan.. Au you can tell, I have 11 items. I would 12: project another 20 minutes of questioning. I realize we have l; p L - ;bJ 13 members of the public here who are waiting to speak. l 14 JUDGE SMITH: Yes, we' re running over, but we had l 1 E 15 pretty much planned on having this panel completed today, 'and i L. 16 if you can -- 17 MR. TURK: I' ll try to speed through it. l
'18 JUDGE SMITH: Yes. How much redirect, Mr. ]1 19 Traficonte? Will that be very long?
20' MR. TRAFICONTE: I will be as concise, and I was 21 hoping to get in 20 minutes at the most. I 22 JUDGE SMITH: Okay.
'23 MR. TRAF1 CONTE: We would very much like to get this l 24 panel --
25 JUDGE SMITH: Yes. Well, that was a rather tirm Heritage Reporting Corporation (202) 628-4888 4
) ZEIGLER, JOHNSON, COLE -. CROSS ~ 8060 1 planning objective'we had.
- 2. MR. TURK: Thank you. I' ll try to speed.
.3- DY MR. TURK:
.4 'O' I would address this to either Dr. Johnson or Dr.
~
.5 Zeigler. I.gurqs alphabetically, let's start with Dr. Johnson.
6 Of these 18 households which identified that they had 7 emergency workers within the house, do,you_ recall whether any 8 of. those households had rnore than one emergency worker? 9 A (Johnson) I think they did. 10 Q So that the person who responded to the telephone
.11 call-would be identifying his anticipated conduct as an- !
12 ernergency worker, as well as what he anticipated the other'
.[
't
. . -13 family.roember -- the other.-- utrike that.
14 The respondent to the telephone call would be 15 predicting in part'his own response in an ernergency; is that 16 correct? 17 A (Johnson) I think the question, if I' rn not wrong 18 here, asked if they had assigned emergency work roles in the-19 event of an emergency at Seabrook. 20 So what the person would be doing is indicating 21 whether or not someone else in the household had an assigned
'22 emergency work role.
23 Q All right. Now to return to my question then. l 24 When the telephone call carne in to whoever it was who l: i ; 25 received it, and let's call that person the respondent, the 1 l' L Heritage Reporting Corporation (202) 628-4888
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) ZEIGLER, JOHNSON, COLE.- CROSS- 8063-l' respondent then would~be providing infortnation as to what he 2 predic'ed t his own role would be if in fact he had an assigned-3 emergency worker role; is that correct?
I 4: A ( Joh nson) - I don' t know what you'mean by predicted.
- 5. A person either knows whether he or she has an assigned role or
- 6. not. I.think you have to look at it within the context of
,7 which the. c;uestion- was posed.
8 Q Forgive me. It's the problem of trying to rush 9 through. < 10 Part of your survey souDht to identify the intended 11 behavior of emergency workers; is that correct? i 12 A (Johnson) That's correct. l'3 Q Anci the respondent to your survey, in describing 14 his intended -- in describinD the intended behavior of an 15 ernergency worker, mi Dht be describing his own conduct if he was
' 16. the person with an assigned emergency role; is that correct?
17 A. (Jonnson) That's correct.
.18 Q And he rnight also be describing the intended conduct
- 19. of some other fatnily mornber who may have been assigned an
( 20 emergency role; is.that correct? l L ' 21 A (Johnson) I don' t like the use of your word 22 " intended" here. The question reads, "Do you play any assi Dned 23 role in the evacuation plan?" 24 Now, it seerns to me that a person would know whether
- 25 or not he or she is to play an assigned role. I think the key
- i Heritage Reporting Corporation (202) 628-4888 1
L 1: I p 'j l l I; i 1 [: ZEIGLER,' JOHNSON, COLE - CROSS BOGA 1
-h 1 question here is ' assigned".
And'your use'of " intended", 1 2 con' t think is appropriate here, and, thus, I don' t want to 3 answer.yes here. I t ' s no, I don' t agree : with the .way you' ve 4 stated it. ,1 5 MR. TRAFICONTE: If I rni ght interrupt in the service 6 of t irne here.
.l
- 7. I have a strong hunch that the two percent raay be in .
l 8~ error, because if you look at Page 26 -- 9 MR. . TURK: Your Honor, I object. 10 M R .' TRAFICONTE:- Well, I know, I -
.11 ' MR. TURK: I .t h ink we' re gett ing test irnony frorn i
12 counsel. 13 JUDGE' SMITH: All right, let's see if he can be 14 helpful. I don't see that he's trying to shape. the test irnony, . 15 MR. TRAFICONTE: Your Honor, I rnay have raisspoke 16 raysel f. . Typo instead of orror.
-17 On PaDe 26 of the technical appendix, which I believe 18 Dr. Johnson was just referring t o, the statistics are set forth 19 on that page as to the nurnber of respondents who said that j 20 sorneope in the household had an assigned role. And that nurnber 21 is three. It's at the bottorn of the paDe, Mr. Turk. And that 22 nurnber seerns to be tbree.
23 In the testirnony that you are reviewing, the nurnber 24 is two percent. You then roult iplied the two percent and corne l 25 up with your 18. But you rni ght want to do the sarne thing with Heritage Reporting Corporation , (202) 628-4888 1 i
ZEIGLER,. JOHNSON,-COLE - CROSS 606S 1~ the three. [ l 2 MR. TURK: Well, Your. Honor, I think the problem that
;3 .I was, objecting to has just materialized. We have counsel.
.I 4' providing informat ion t o' the witnesses for their evaluation.in i
5 response to the line..of questioning. ! 6 ' MR. TRAFICONTE: Well, it was a fruitful.line of 7 questioning, and'I think it had some merit as long an'the 8 numbers were right. But if counseluwould want'to ask whether. 9 there should be a correction from two percent.to three percent, 10' we could save ourselves some t ircc. 11 JUDGE SMITH: Proceed. We are trying to be efficient (- 12 here. Proceed. ! 73 3%J .13 BY'MR. TURK: ; 14 Q Dr. Johnson, in your testimony incorrect when it t. ! 15 states two' percent of the households contain individuals? l l 16 A . ( Joh nson ) It could have been u. typo there. It 17 doesn' t appear that -- 18- Q It could have been? 19 A (Johnson) Yes. :) 20 Q Was it? 21' A (Johnson) I don' t know. I don' t remember what 1 22 cent in on the original draft, but it appears to be a typo. 23 Q Now your testimony says that two percent of those l 24 households "contain individuals who reported that they had an 1 25 assigned emergency work role in the plan." Heritage Reporting Corporation (202) 628-4888
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, - 4 p ) ZEIGLER, JOHNSON, COLE - CROSS 806C ,
'1- >Does.that mean that two percent of the respondents 2~ themselves personally had an assigned emergency. work role?
3" .A (Johnson) I~think it says'two percent of the 4 households, doesn' t it?
'S A- (Zeigler) The'way the question reads, do you have an i
-6 assigned emergency work role." And I would presume when the
.7 questionnaire was administered, that only the person Who was B. speaking on the telephone as the informant would have qualified
~
9 to say, yes, I have one. 10 Q So should I then -- should we foodify your testimony
- 11 then to say -that -it's not that the households contained 12' individuals necessarily, but the respondents?
'13 ,A (Zeigler) Well, the households did contain 14 individuals. The individual was the informant.
15' Q All right. Gentlemen, if you look at Page 26 of the ; l 1G' attachment to your testimony, Attachment 5,-Question 342.does 17 ask in fact,."Do you play any assigned role in the uvacuation 18 plan?" 19 Now, is it that question and the series of answers 20 which are tabulated after it to which you then refer in your 21 testimony that we have been discussing? 22 A (Zeigler) I believe it is, yes. 23 Q And, I' m sorry, who made that response? 24 A (Zeigler) I did.
. 25 '
Q Dr. Zeigler. Do you believe your testirnony then Heritage Reporting Corporation (202) 628-4888
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- .1 ZEIGLER, JOHNSON, COLE - CROSS 806'7
'1 - should be amended to change'the two percent indicated on'Page-2 50 of the testimony to read three percent?
3' A (Zeigler) Well, ifL I accept-the nuraber on PaDe 26'as
'4 being. correct, and I believe that it is, then,_yes, I would say
' ~5 go ahead and change'that' number from- two to tbree percent.
E2771 6 (Continued.on next page.) 7 8' 9 10
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J ZEIGLER, JOHNSON, COLE - CROSO 806B f )f I t278mB, 1 Q Dofyou.know wha't three percent of.915.is? l l
- 2. A (Zeigler) Twenty-seven, 31, 27 people, 28 people.
]
'3 0 .Approximately 277 1
4 A (Zeigler) Yes. ! 5: D And you agree with that number? j
'6 A' (Zeigler) I. beg your pardon?
7 Q. Did you just agree with me, that it is approximately 8 27? 9 A (Zeigler) Yes. 10 MR. TURK: Your Honor, may Counsel approach the-11 bench, please?
.i 12 JUDGE SMITH: Certainly.
. .p .
. .i . . ; 13 (Bench conference.)
.14 BY MR. TURK:
15 Q I would like to turn to Page 52 of the testimony, and 16 this is a continuation of the same answer provided by Dr. 17 Zeigler and Dr. Johnson. 18 In'the first full paragraph on the page, you indicate l 1 19 that "among this latter group, a small percentaDe indicated ! 20 that they would either leave immediately (1 percent); do 21 something else (1 percent); or were unsure what they would do, 22 (1 percent)." 23 Do you see that statement? 24 A (Zeigler) Yes,
- 25 A (Johnson) Yes. 1 l.
1 1 Heritage Reporting Corporation (202) 628-4886 l l
h ZEIGLER, JOHNSON, COLE'- CROSS. 8069
- 1. Q Is this an error also in the' test irnony?
2= A (Zeigler) The providing of these. figures of'one , 3 percent? 4- .Q Maybe I can tell you what rny concern in. 5 If you have a survey- group of- approxirnately 31 6; people, and I arn puzzled as.to how one percent of 31 gives you 7 anything less than a fraction of a person, or anythinD rnore . 8 than a fraction of a person. I' 9 A (Johnson) It should have been three percent. 10 Q Three percent for each category? 11- A (Johnson) Yes. 12 A (Zeigler) One person or three percent.. ; 13 A (Johnson) Yes, it appears in the Table. It is a typo
. . i 14 there. If you look at the.. Table 1, you will see that it is 'i 15 three percent. ;
16 Q Do any of you gent lernen know how raany persons in the; ! 17- New Harnpuhire portion of the Seabrook EPZ have been assi Dned-l 18 ernergency worker roles? 19 A (Zeigler) I don' t. 20 A (Johnson) I don' t . ( 21 A -( Co l e ) No. I 22 Q Do you have, would you know an order of rnagnit ude 23 that we can put on it? i' 24 A (Cole) No. l I l' 25 A (Johnson) No. l lO l l l Heritage Reporting Corporation
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): ZEIGLER,-JOHNSON, COLE - CROSS 8070.
1 A .(Zeigler) No. l . - . .
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2 0 -And your survey, I take it, as described in Table 2, } H 3- of your testimony,'found that some of your respondents were on
- .4 the policeLforce, and the fire department force, they.had j 4
i 5 traffic control' functions, they may have bee =n s'chool bus 1 6 drivers, special-emergency' bus drivers. 7' They may have had a role as an amb ;lence . person or _ as i 8 an assigned d'octor'or nurse, and they may have been media- -I 5
-9 personnel, and there are some people who could not specify'
- 10. their roles.
L 11 Do you know whether the total number'of persons.could
~ 12 fit all'of these different categories, including roles.which
.t '13 were not specified by your-respondents,-exceeds 1,000 persons?
14- A (Johnson) I have no idea. 1 Y I l 15 A (Zeigler) I don' t know. ., { l 16 Q None of you have'any idea, is that correct? l; [ 17. A '(Cole) I could take an educated Duess. 18 Three percent of the 915 said that they were' involved l. l - L 1V and you can project it as three percent of the population, , l
'20 which would give you several thousand, l l
l' 21. Q Do you know what the current population i s within the j l 22 New Hampshire portion of the EPZ? . 1 23 A (Cole) It is about 90,000. I may be wrong. I would l 24 have to check. 25 Q I think that we have that established in the record, 1 i Heritage Reporting Corporation (202) 628-4888 1 4 i
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l\v) ZEIGLER, JOHNSON, COLG - CROSS 807:
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( 1 already through the ernergency plans, so wo ',g an' t need you to e ' s pj 2 guess as to the n urnber. ) \ f 5 3 A (Cole) Pardon tae?' i a
<t I i 4 0 You w n ' '; need tr[ guess. We' cio have that in the hl
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5 reed t~d , already
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l \ f 6 Also, in yoya t est i roo ny, at Page 54, at the top of ,
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7 the page you discuss the local telephone c orn pany in the ) l i p
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- j 8 vicinity of the T hree: Mile Islano nuc Nar plant. ,
9 kn;j you indicate that the company there had 10 difficulty f inding telephone personnel who were wdp[ging'to i 11 "expotje t hernuelves to the hazards of venturi {a rorr t,h e plant, p
-[r 12 in or$2r to install additional phone eq ui prnent . "
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(/) x._ 13 , Ncw, does that t est irnony re fs,- to,s t el ephoop ernployees I , l 14 kn the ihree Mile Island area? -
,r 15 A (Zeigler) It is rny understanding that it does, yes.
16 Q know if those personu had previously been
\'bcp do' you 17 assigned v.cl% as ernergency workern in the event of a nuclear
\18 ernergency, at \rhree Mile Island?
'19 A \ T E.11:er ) '
I don' t know, but I would uespect that
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20 they had not been annigned speci fic einergency tk l es in the
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;. 21 event of an ernergency at Three Mile Island .. i nc e we were not 22 planning for an ernergency t here. ,
23 0 You suspect that they had not been? , I s f l 24 ) l ,4 (Zelgler) I suspect thetc ;ey were not a ss i t;ned 23 emep;ency roles that i n, to go to fD,^ee Mi lts / .;1 and, should an l l (c) v - l / {
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L k)EIGLER,. JOHNSON,' COLE - CROSS 807u
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1 :ovent'happere ;' l 2 Q8 .1;would like to turn to Attachtnent 50 of your- l
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t est i rnony, and in,w, p articular Table'A-3, - at Page 57. 4 And.this provides a surnrnary of what is characterized. { as '"r a i l ure . t o . cornpla t e"
'S 3 and then "nurnber of ' telephone; nurnbers
-6 , diale#V and outcorne by state. - , -?
l .r os.. 7. a> And.is it fair for .sm t.6/ characterize this eas a . 7: . l , 4 8.' il sun 1rnary of the tot al nurnber ofl calls placed byl category and the L #, 3 . -
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l 9 oukeme of the ' telephone t!.3117 . 4 g% t ;. .
. . ~) r> ' Ti 10 .A 1 Cole) Yes.
i' Q >
'11 Q And what - tirne of day . wpe these .di f ferent . calls rnade?
{ , 12 A- (Cole) ' The uurvey wis conducted rnostly- during the 13 evenaWgs between f900 and 10 00' p. rn. , but call-pquks were rnade l 14 on' Saturday, during the day, for people who could!not be ,. e
,f 15 rwached by phone #t several different-days and several i r
l ti i i,,
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16 di f ferv.ht ' t irnes duri ng the itvenings.
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MD (.i- '; ' 17 , Most of thero t hough were wide and cornpleked in the v.
,, ' 18' .4a'venings. '-
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'[ 19 Q And in'this Table,;you. indicate,.nell, the bottorn ]
,, [O 20 line indicates. refusals, 542 persoon kithin ' the New Harnpshire f
r, 9 21 EPZ ~ refused to respond to tin' questionnaire, is that correct? , n ;: 1
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y A (Cole) i. 4 f<i cl3 .j . Q At uhat point L in the questioning ; did t 6at _ ref. usal' ' y)/ ;
^24 ]take place?
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, .25 j h A (Cole) Varioun points, rnost of thern at the 7 ,
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ZEIGLERh JOHNSON, COLE - CROSS 607L 1 beginning, but if somebody stopped the interview, stopped 2 participating, at any point in time, including up to the end,. 3 we counted that as'a refusal.
'4- But most of the refusals take place at the beginning 5 where-the pot ent ial respondent refusen.to beDin the interview. '. 6 Q And would the same thing be true for the 251 refusals 7- in Massachusetts?
8 A (Cole) Yes. 9 Q So that che total of 793 refusals reflects people, ,
.l 10 who at one point in the interview or another, either in the 11 beginning or,some time in the course of it, refused to 12 participate?
O
\~/ 13 A (Cole). Yes, with the overwhelming majority of those 14 people being people who refused at the very-beginning.
15 O In your experience, Dr. Cole, as a surveyor, do you 16 have an opinion as to what sorts of people are likely to refuse l 17 to complete an interview, and what sorts are likely to aDree to 18 complete it? 19 A (Cole) I don' t have any general information on that. 20 And-in my experience of doing over 150 telephone surveys, I 21 would say that it depends a lot upon the topic of the survey. 22 I mean some people are more or less interested in 23 various topics. 24 Q And the ones who respond to an interview, are those 25 who are laterested in the topic? Heritage Reporting Corporation (202) 628-4888
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) ZEIGLER, JOHNSON, COLE - CROSS 807o 1 A . ( Col e ) ' There is a. correlation between people's
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2 interests and their agreeing to respond, yes. 3 Q So that you may expect that a' number of people who 4 refused the call,.or.who refused to participate further, are . 5 simply not interested in the topic? 6 A -(Cole) Some of them, yes. 7- Q But statistienlly, can you correlate the people -- in 8 there any. statistical significance that we can establish as to ] 1 9 whether a. person may be interested in the interview topic, , i 10 which we can correlate whether or not he refuses to participate 11 in the interview? 12 A (Cole) I don' t know of any such studies. 13 There may exist but I am not aw.are of them. 14 Q Do you have an opinion as to whether that kind of a 15 correlation exists? 16 I believe that you said -- 17 A (Cole) I would imagine that it is relatively low, if 18 it exists. 19 Q Are people who have strong opinions about a subject 20 more likely than not to be willing to discuss their opinions? 21 A (Cole) Not necessarily, no. 1 l' 22 Q Do you think that people who have strong opinions 1 i-( 23 keep them to themselves? L 24 A (Cole) They may not want to share their opinions 25 with other people. They may feel that it is not somebody
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A fi) ZEIGLER, JOHNSON, COLE - CROSS 8075 1 else's business.
.2 I think that just my personal intuitive feeling from
- 3. doing.a. tremendous amount of survey research, is that'the 4< personality characteristics.of the. respondent are the primary 5 determinant.
6' 'There are some people who just don' t / want l to t alk .to 7 any strangers on the telephone and-there are-other people.who 8 are much more friendly and.willing to talk to people. 9 Q In the course of your interviews,Lin this survey, did 10 you ask the respondents whether or not.they have an opinion.as 11 to whether the Seabrook Nuclear Plant should be licensed? 12 A (Cole) . Yes, we did. 13 Not licensed. We -- I think the wording of the 14 question was whether it should be allowed to operate, but I 15- could check that if you want me to. 16- . Yea, we asked, do you think that-the Seabrook Nuclear 17 Power Plant should be allowed to operate to generate 18 electricity? 19 Q Where are you looking? 20 A (Cole) On Page 60 of the Technical Appendix, of the 21 Attachment 5,. Question 1G. 2R Q And I am looking to see if you have the-numbers 23 tabulated as to how many answered, yes or no? t-
.24 A (Cole) Yes, we have that in the Table in the report.
25 It is on Page 15 of the Attachment 5, and it shown mO-l Heritage Reporting Corporation (202) 628-4888
il ZEIGLER, JOHNSON, COLE - CROSS CO76 1 that 'are you concerned _only with New Hampshire residents or 2 the total EPZ population? 3 O I think they are both shown there, aren' t they? 4 A (Cole) -They are both. 5 Twenty-nine percent of the entire EPZ. population said 6 that it should'be allowed to operate; 65' percent said it'should 7 not be; and six percent had no opinion. 8 Q Did you make any attempt'to correlate the responses 9 to Question '16, as-.to whether or not.'th'e respondents' thought 10 that the plant should be allowed to operate with the other-11 results of the survey? 12 A (Cole) Yes, we did. fu .- -13 Q Is that' presented somewhere in your study? 14' A (Cole) Yes, it is. 15 Q Where would I find that? 16 A (Cole)- I think it is Table 3, but let me just check 17 for a second.
'18 (Pause.)
19 THE WITNESS (Cole): Yes, it is on Page 33. 20' At the bottom. 21 BY MR. TURK: 22 O And is this the only instance where you correlate 23 that, the response to Question 16, with other questions posed? 24 Actually no, I see that it is not. I une another L p 25 instance on Page 38, where you correlate it, with the question i Ll I Heritage Reporting Corporation (202) 628-4888
O ze s'en. 30""so" co's - caoss co77 1 of whether they would not evacuate at all? 2 A (Cole) Yes, that in correct. 3 Q All right, thank you, 1 appreciate your held on that. 4 MR. TURK: I have no further quentions. 5 JUDGE SMITH: Okay. 6 We wi11 take a l o--m i nut e break and we wi11 come back 7 to your redirect examination. 8 (A brief recess was taken.) 9 (The NRC Cross-examinat ion 10 Plan of the Panel of Zeigler, 11 Johnson, and Cole follows:) 12 i O 13 { j 14 l 15 16 l 17 l l 18 19 l 20 21 22 23 24 O Heritage Reporting Corporation i_____. _ ____ _ _ _ _ _ _ _ _ _ _ _ _ _
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NRC Staff Cross-Examination Plan: Ziegler, Johnson and Cole (Human Behavior)
- 1. Identify the population size of the area surveyed by the witnesses at Three Mile Island (p. 7).
- 2. Identify certain aspects of the evacuation at Three Mile Island: (a) when the advice was issued for pregnant women and young children to evacuate (P. 9); (b) what information had been provided to the populace at that point in time;-(c) whether the Mountain West Research syudy (Flynn, et al) identified as a factor in the reasons why people evacuated, the problem of their having received-confusing information (p. 11).
- 3. Determine whether the witnesses are familiar with post-TMI developments in regulations and guidance concerning emergency information.
- 4. Determine whether other social and behavioral scientists have been identified (p. 12).
- 5. Determine the sex distribution of the Seabrook EPZ, as a whole and in'NH and Mass (p. 16). Determine witnesses' basis O. for this estimate. Determine the sex distribution for heads of households within the same areas (p. 16).
- 6. Describe nature of errors identified upon verification (p. 20). Determine whether any callers skipped over some portion of the simulated EBS messages in order to complete the survey within the available time.
- 7. Determine whether they are aware of census data as to the number of households without cars in the NH section of the EPZ-(p. 25). Determine whether their survey requested information as to how many respondents would offer rides to persons without vehicles of their own.
- 8. Determine the number of respondents in the NH portion of the EPZ who were, themselves, emergency workers (p. 50).
Determine the reliability of the survey to predict the behavior of other members of the same household. Identify the respective numbers of persons represented on Table 2 (p. 51).
- 9. Determine whether the witnesses know the number of persons who are assigned roles as emergency workers in NH.
Determine the reliability of the survey as a sampling of this ' group. Determine whether the percentages reported on p. 52 are related to the numbers reported in Table 1 (p. 49).
- 10. Determine whether telephone company personnel near 3 TMI were previously assigned roles as emergency workers (p. 54). l l
- 11. Determine whether potential biases affect the survey (Attachment 5, Table A3, p. 57).
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) ZEIGLER,' JOHNSON, COLE - REDIRECT 8073
.T279 1 JUDGE SMITH: Proceed, Mr. Traficonte.
.2 REDIRECT EXAMINATION 3 BY MR. TRAFICONTE:
4 Q Dr.' Cole, I' d like to ask you, do you have a view as 5 to the accuracy and reliability of the survey conducted fby Drs.
- 6. Zeigler, Johnson and 'Brunn that's. discussed in the.diract
- 7. testimony?
8 A. (Cole) Yes, I do. 9 Q And could you tell us what your view is? 10 A (Cole) I think that the evidence suggests that the 11 basic conclusions of that survey, for example,. the fact'that 12 approximately 40 percent of EPZ. residents engaged in a
& , 13 voluntary evacuation are very valid.
14 And the reason I would not be concerned about the 15 response rate or-the size of the sample in this particular 16 survey, which are potential problems in survey, and I would 17 like to underline that potential, is that because in this. case 18 the results of this survey were independent ly corrobc rat e by 19 two other investigators, including one funded by the NRC, and 20 all three surveys came up with essentially nimilar results, i 21-And to my knowledge, the results of the ZeiUler, 22 Johnson, Brunn study are almost universally, or virtually 23 universally accepted in the literature on response to TMI. 24 In fact, they are cited by Dr. Mileti in his work and
- 25 in his testimony.
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(. ~1 Q ZEIGLER, JOHNSON, COLE - REDIRECT Now, Dr. Cole, you will_ recall that you were cross-8079
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examinedLat'uome. length concerning a text that you-have 3 written, Sociological Method. Portions of that t e x't were read
- 4. to:you concerning value freedom inenociology.
5 Do you recall that testimony? 6 R- (Cole) Yes. 7 'Q . And,you were asked to place yourself in one of.two 8' camps: 'the value-free technician camp as opposed to those in 9 sociology who would want, for ti.e' sake of a term we' ll call it 10 committed sociology, sociology that is pursued for identified 11 reasons and ' values.
,12. Do you recall that discussion?
O; V -~ 13 .A- (Cole). Yes, I do. 14 O And-it was.your testimony that you place yourself in . i 15 the technician camp. That's correct, isn' t it? 16 A (Cole) Yes. 17 Q Is there any evidence that you could provide us for 18 your self-evaluation that you should be considered, or that you 19 consider yourself in the technician camp? 20 A (Cole) Yes. I have done a substantial amount of 21' research on energy and public response to energy and to nuclear
- 22. energy in particular. And I' d like to point out that I have 23 worked for Brookhaven National Laboratories on surveys funded 24 by the NRC; that I have worked for Columbia University, School i.
25 of Engineering, on a survey funded by Consolidated Edison. l !L O L H \ I Heritage Reporting Corporation (202) 628-4888 h L _ __. _ _
V ZEIGLER, JOHNSON, COLE - REDIRECf 8080 F i' 1 And, f urt herrnore, I have worked for the Long Island Lighting 2 Coropany, and I have done surveys for t h ern on the attitudes of 3 Long Island residents towards the cornpany and towards the 4 Shoreh arn Nuclear Power Plant. 5 In fact, in one report that I wrote for LILCD in fs 1981, I rnade a set of recornraendat ions to LILCO on what they can 7 do to increase their credibility. And I believe if they had 8 listened to those recorntnendat ions, the situations on Long 9 Island rni ght have been different. 10 0 Dr. Cole, there was sorne exarninat ion that dealt with 11 the randorn sarnplinD of households perforrned for the survey that 12 you have provided in this case. Specifically, there were sorne 13 questions directed to the 50-SO division between rnale and 14 fernale heads of household. 15 Do you recall that t est i rnony? 16 A (Cole) Yes. 17 Q Would you explain why there was a conscious choice 18 rnade of ensuring that rnale and fernales heads responded in a 19 roughly equal proportion? 20 A (Cole) Yes, I' ll repeat what I said in rny t est i rnony. 21 If we had s i rn p l y interviewed any head of household, rnale or 22 f erna l e who we were able to obtain on the telephone, we probably 23 would have ended up with a larger proportion c# I'erna l e 24 respondents. 25 In fact, I think that the first rnarket research D Heritage Reporting Corporation (202) 628-4888
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i . ZE1GLER, JOHNSON,. COLE - RED 1 RECT 808] 1 l O' - . 1. survey used by KLD in' preparing work for the Applicant ended up l
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l -- 2 with'something"like 58 percent of women. l 3 It has been my general experience that if you do not l , 4' use a sex quota-system, you obtain higher proportions of women 5 than you'would find in the' population, .because women'are more
- f. 6 likely to answer the phone, and probably more likely, or .
l' . 1 l 7 slightly more likely to be willinD to talk on the phone. -j i 8- '.Now, i t 's wel l known from my research and the. 9- research of other people that wornen have more negat ive . 10 attitudes towards nuclear power than men. And if the survey 1-. 11 overrepresents women, if it has more women in the camplelthan 12 exists in the population, it could be. biased against' nuclear : . 13 power. And.therefore we. made a specific offort to make sure
- 14. that the proportion of women in the sample was not more than 15 the proportion'in the general population.
- 15. O Dr. Cole, the question was put to you earlier-by Mr.
17 Lewald concerning callbacks that were actually perf~.med in j i 18 your surv0y. 19 Do you recall that~ question? 20 A (Cole) Yes, I do. 21 O Let me ask you, do you have a rough estimate for the 1
^22 number of cal 1 backs that were actually performed for your l:
L 23 survey? \: \ 1- 24 A (Cole) Our contract - it wasn' t a written contract, i L. L 25 but our informal agreement with Marketing called upon them to { O: t l Heritage Reporting Corporation L. (202) 628-4888 l: K
y f)' T ZEIGLER,' JOHNSON, COLE - REDIRECT- , 800a 1 make one initial call, and at.least -- I' d like to' emphasize 2 the "at least" -- at.least three additional callbacks. 3- So that before we decided that a nurnber could l not be 4 reached, at least four . calls were rnade. I would uay that
-5 generally ' more calls were rnade.
6 Now, I can' t tell you exactly how many cal-1 backs were 7' made. Sometimes we were able.to reach a number of'the first'
-8 call, sometimes on the second' call, third call, fourth call, in 9' some cases, .five, six and seven calls were rnade to these 10' people. But in every case, at least a total ~of four calls were 11 made.
12 Q. Well, do you have some sense for how _large number of, 13 the absolute number of callbacks was? Was it_a significant
'14 nutnber?
15 A (Cole) Oh, yes. 16 Q .Now, Dr. Cole, 'there was some examinationidirected to 17 the nature of the survey questionnaire with regard to EBS
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18 messages or' portions ofLEBS messaDes that were used in the 19 questionnaire. 20' Do you recall that testimony? 21 A (Cole) Yes. 22 Q And there was also testiroony as to a pretest 23 conducted'by you, I believe, of an initial questionnaire. 24- Do you recall that testimony? 25 A (Cole) Yes. I Heritage Reporting Corporation (202) 628-4888 [-
'I s l l f! ZEIGLER, JOHNSON, COLE - REDIRECT 808h i ' 1 G The EBS messages or portions of EBS messages that 2' were.used in the pretest, were they the'same, were.they i' 3 identical.t'o the ones that ended up in the final questionnaire? 4 A- (Cole) No. In the protest, we included more, a
-- 5 larger portion of the EDS mesuaDe. But what we'found when we 6' actually administered this questionnaire on~the telephone to 7 real people-living in the EPZ was that.the respondents foundi l 8' the question to be too long,'to be confusing, and difficult to 9 answer.
10 Hand so we decided that in' order to get reliable 11 informat. ion, we would try to delete some sections of the EBS I 12 messages which1we-felt were not crucial in order to. identify 13 the scenario that we wanted the respondents to reply to. 14 Q New I' d like to direct the panel's attention to PaDe 15 6 in the technical appendix. Specifically, Question No. 31 as 16 well as in a document that was distributed but unmarked, headed 17 Appendix G, Emergency Broadcast System Activation. I would 18 like to direct your attention to PaDes G-30 and the following 19 pages. 20 Have you located those two pieces, two documents?
-21 A (Cole) Yes.
22 Q Now, first, Dr. Cole, let me put this question to l-1 23 you. 24 Was the intent of this survey instrument to simulate 25 for the respondents the actual EBS messages that they would be Heritage ReportinD Corporation (202) 628-4888
l i I l l ZEIGLER, JOHNSON, COLE - REDIRECT 6089 h 1 1 hearing during an emergency at Seabrook? ) 1 2 A (Cole) No. The intent was to ask the respondents l 3 what they would do in a scenario which was based au closely as l l 4 we could base it upon the EBS messages. But the intent was l' 5 certainly not to read the EDS messages, or do any kind of test l 6 of the clarity of the EDS messages. i 7 Q Were you attempting to test the effectiveness of the G EBS messages? 9 A (Cole) No. 10 Q Would it, in your opinion, be possible to empirically 11 validate or test the effectiveness of the EBS messages? 12 A (Cole) If by the effectiveness you mean the extent
, 13 to which the typical kinds of people living in the EPZ would 14 understand those messages and would feel that they would listen 15 to the advice given in those messages, then the answer is yes.
16 Q Well, let me be more precise in my question. 17 Would it be possible to test empirically the clarity la of the EDS messages? 19 A (Cole) Yes. 20 Q And would it be possible to test empirically the 21 believability of those messages for the people to whom they are 22 going to be addressed? 23 A (Cole) Yes. 24 Q How would such an empirical validation be done? 25 A (Cole) We conduc',ed a study of EDS message in our 4-Heritage Reporting Corporation (202) 628-4888
1 7a ZEIGLER, JOHNSON. COLE - REDIRECT 808S
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1 research<on~ involving lit igat ion concerning L} LCO's exercise in 2 February.of 1986. In tnat exercise, LILCO sirt.ulated the 3' . broadcast of a set of' EaB messeges; messages which were either 4 written by.or partially by Dr. Dennis Mileti. 5 And in order to find out how clear t here messages: 6 were and how believable they would be. we recruited' a random 7 group of approximately 50 Long leicnd residents.living in i;he 8 EPZ and right outside the EPZ.
.9 We had, prior to the actual research, made A tcpe L
11 0 recording of somebody reading the EBS reassages. So we'then had' i $ 11 these people come i nto a t-core. We had them sit down. There l .- L 12 were three different groups. We didn' t do all 50 at once. .We 4 o l 4
~13 had three different groups. And rse told them to ira,a g i ne t h ey l l ' [&_]_. '
I 14 were at home on a given day, and a certain time, and that they l 15 heard the following message on the radio. i 1 16 And we then played the EBS message exactly as it was i - 17 simulated in the LOCO exercise. We then had the people discuss
' 18 - these messages, and we found that the great majority of the 19 people who listened to them found them to be confusing, j 20 frightening. People said they didn' t believe that they were .
i 21 real EBS messages; that these couldn' t -- these were so bad 22 that they could not possibly be real EBS messages. And a great l l 23 majority of'the. people who listened to those messages said that I 1 24 they would not do what they were advised to do in those EBS ] 1 25 messages. Heritage Reporting Corporation j (202) 628-4888 I 1 1 J
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1 A similar type cf research could be done'here.at 2 Seabrook in which real people living in the Seabrook EPZ were
'3 asked to licten to the EDS messages, and then asked to respond
.it to them to.see how they felt about t'h a m , whether they felt that
.3 they,were clear, understandable, and what.they would do under-6' those circuristances.
7 Q -But I take your testimony to be'that the survey.that 8 you conducted did.not-have that as one of its purposes. 9 A- (Cole) No. 10 _Q Now I would like tocask the panel to turn to, and I 11 1' won' t spend a lot of time on this, but to turn to Page G-30, 12 and . f'you.wi]l, compar e what appears on G-30 with what appears 3a, 13 on Page 62. G-30 of the' document already identified as
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14 Appendix.G. Compare what' appears on that page with Page 62 in 15 the technical appendix. 16 And I would like to ask in the first instance, there-17 is a blocked piece of text that is headed "No Release of 18 Radiation". That blocked piece of text does not appear on Page 19 62, does it? l 20 A (Zeigler) No. l l 21 A (Cole) No. I-
- i. 22 O And why is that?
I 23 A (Zeigler) We were trying to structure a scenario I l 24 here to put people in the context of an emergency at the IE r 25 Seabrook plant. L
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I t T. 4 i j ZEIGLER, JOHNSON,.' COLE - REDIRECT. 8087 1- And so we chose the first blocked section on PaDe ! 2~ G-30 where there had been a release of radiation.
.l 3 -- Q Did you understand the two blocked portionn.of text 4 to be alternatives?
5 .A (Zeigler) . Yes, they were taken'to be-alternatives. 6 Q- So that a 'hoice c of on would. preclude the choice of .1 7 the second? 1 8 4 (Zeigler) .Right. 9 O If you would turn to Page G-31, the following page in l l h - 10 the Appendix G. Does the very first paragraph on:thet page, l~
- 11 does it appear on Page 62 of the technical appendix? J 12 A (Zeigler) N o', it doesn' t.
O 13 Q Does the following paragraph appear? Well, let me-1' 14 summarize it for the sake of time. 15 Does any cf the text on Page G-31 appear on Page 62 16 of the technical appendix? 17 A (Zeigler) No, I don' t believe it -- 18 Q And do you have a view as to why that's the case? 19 A (Cole) No, it does. Excuse me. l-s 20 A (Zeigler) The second paragraph there, Evacuation -- 21 no, I' m sorry, on Page 62, we' re simply advisinD the -- on Page 'i
-1 22 62, the scenario on Page 62 simply advises people in the beach l 23 areas and the state parks to evacuate.
I 24 So I don' t believe anything on Page G-31 appears in j i 25 that scenario. I Heritage Reporting Corporation 1 (202) 628-4888 l 4 _--___-__-__2_- _ _ . _ - - -.
ZEIGLER, JOHNSON, COLE - REriRECT 8080 , 1 A (Cole) No, it's evacuat ion of retornmendud people in 2 Seabrook -- 3 .Q Well, If I could direct Dr. Zeigler to the'last 4 sentence, or the next to the last sentence that appears in the 5 first quoted paragraph on 62, if you would like to modify -- 6 A (Zeigler). Okay, evacuation is also recommended for 7 people in Seabrook and Hampton Falls. 8 So the second paragraph on'Page G-31, we selected the 9 communities here, Seabrook-and Hampton Falls, and thus did 10 include,part of the paragraph, the second paragraph:on Page 11 G-31. 12- Q Se essentially you were directing -- on Page 62 you
- 13 were directing two towns to evacuate.
14 A (Zeigler) Yes, we were directing two towns to 15 evacuate. 16 Q And what are the directions being given to the other-17 towns? 18 A (Zeigler) The directions being given to the other 19 towns are specified in the paragraph following, people living 20 in the towns, and then they are specified, are advised to 21 shelter in place. So it was a sheltering advisory for the 22 remaining portion of.the zone. 23 Q So all the towns were either told to evacuate or 24 shelter. There was no town given no. protection? 25 A (Zeigler) There were only two groups, right, either G V Heritage Reporting Corporation l (202) 628-4888 l 1
-- --___--_---_-___-______-___-__--___-____-.__-1
. 'ZEIGLER, JOHNSON, COLE '-- RtIDI RECT 8089 l' evacuate or shelter.
2 Q Now, rather than take the tirne here going through the 3 ent ire ernergency broadcast raessage that's set forth at.G-30 4 through G-35, do you have a general' view as to why the portions l 5 that were deleted frorn - the rnessage read an is set forth-on Page l
~l 6 62.were deleted?
7 A' (Zeigler) yes, we could go through. thern one by one, 8 but there were several reasons why we did not use seine of the 9 rnat ori a l that appears in Message F. 10- One of the reasons was that we really wanted to'get a 11 handle on evacuation, the evacuation shadow, spontaneous 12 evacuation. 'So we were interested.in what the people that were 13 advised to shelter in place would do. -) 14 We therefore elirninated - sorne of the inforrnation about
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1 15 where to seek shelters for those people living in Seabrook and 16 Harnpton Falls.
-17 In addition to that - and that was our singular,,
18 basically our singular focus here. We wanted to get an idea of 19 the evacuation shadow.
. l 20 But, in addition, we also elirainated uorne portions 21 that were n>t fit into the context of the scenario given that 22 it was a weekend. People who were advised not to pick up their 2E children at school, that-was eliroinated. And, in addition, 24 sorne ' of the repet it ion, rauch of the repetition was elirninated 25~ .frorn Message F. f UIE79 i s
Heritage Reporting Corporation (202) 628-4888
h ZEIGLER, JOHNSON, COLE - REDIRECT 8090 T280MB 1 So we believe that we did a good job o f~ retaining a the spirit of Message F, without parroting it verbatim, 3 Q ! would like to ask, as a final question, I would 4 like to ask the panel a question very similar to one put by 5 Judge Linenberger. 6 And we have heard testimony both on direct and cross 7 with regard to TMI. And what happened from a behavioral point 8 of view at T M 1, and its relevance, if any, to predictions 9 concerning what might happen in the event of an emergency at 10 Seabrook. 11 And I would like to put to the panel, this question, 12 we have heard from you that it was quite clear that there was 13 no emergency plan in place, at the time of the TMI i nc i rie nt . l 14 And it is quite clear, or you could at least assume f 15 as a hypothetical, that if the Seabrook plant is licensed, it l 16 will only be licensed as a consequence of the NRC determining l 17 that there is, in accordance with the regulations, an adequate 1 l 18 emergency response plan in place. l l 1 19 And based on your own knowledge of NRC regulations as l l E to the contents of that plan as wel1 as your knowledge as l 21 behavioral scientists, do you have a view on what difference of l 1 l 22 differences the existonce of an approved p1an wi11 make t'o r l l 23 human response to an emergency or potential emergency at 24 Seabrook? 25 MR. TURK: Your Honor, objection to the form of the 1 Heritage Reporting Corporation (202) 628-4888
ZEIGLER, JOHNSON, COLE - REDIRECT 809.. 1 question. j 2 I arn not sure where the pretnise ended and the , 3 question began. 4 MR. TRAFICONTE: . Well, I will restate it, if you want
- 5. rne t o, I thought that it was clear but --
6 JUDGE SMITH: If you wish, if you want to accornodate 7 counsel, do it. 8 I thought that it was clear, but whatever you wish. 1 I 9 . MR. TRAFICONTE: Well, 'I will -try to sirnplify it.- 10 BY MR. T RAFICONTE: 11 Q You have all studied what happened at TMI, and you. ; 12 have testifying as to what rniDht happen at Seabrook in light of 4 6.,2 13 TMI. And.it is clear to everyone here that there was no l 14 ernergency plan in p} ace at TMI, but Seabrook will not be
'15 licensed at all, without an approved ernergency plan in place.
16 Now, based on those statements which you can assurne 1 17 is.a hypothetical if you are not otherwise cornfortable with 18 them, what is your view on the irnpact of an approved plan, in 19 11 ace, on the hurnan response to an emergency in the event of an 1 l 20 incident at Seabrook? 21 A (Zeigler) We do not believe that the planning that h 22 has gone on in this case, or any other case, or the planning 23 that is required by the NRC and FEMA takes into consideration 24 the realities-of human behavior in the context of a nuclear 25 emergency. Heritage Reporting Corporation (202) 628-4888
i )' ZEIGLER, JOHNSON, COLE - REDIRECT 809E:
.V 1 In this country, we have one general emergency on 2' which to draw out for experience in planning and that in the 3 emergency at Three Mile luland.
4 And at Three Mile Island, in an area that was not 5- anti-nuclear to begin with, we had an extremely large response-i- 6- to a very 1imited evacuation advisory. 1 [ 7 7 believe that that response would materialize.nDain, l . i- 8' should an accident occur at the.Seabrook or any other nuclear. ' l V 9 power plant. f- 10 -And the reality of that behevior is not factored into L l- 11 planning as it currently exists. Instead, what seems to be l L 12 facto.*ed in here, is a dependence on the emerDency broadcast ,
- 4 13 massages to completely control human behavior in a disaster-14 situution.
15 And I do not believe there is a. shred of' evidence 16 that supports that contention. I do not believe that by 17 adjusting emergency broadcast messages you can cope with, you 18 can overcome the complex set of confusing and conflicting 19 information that wi11 natura1ly occur at any nuclear power 20 plant accident in the future. 21 People are going to look after their own welfare, 22 during a nuclear accident. Given the fact that there has been 23 a lot of thought on the part of the public, given to nuclear 24 l power in the aftermath of Three Mile Island, in the aftermath 25 'of Chernobyl, I think people now, are even more likely to 1 l' Heritage Reporting Corporation (202) 628-4888 l l . . . _ _ . = . _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ . _ _
I I i f.~ e ., , 1 f ZEIGLER, JOHNSON, COLE . REDIRECT 8093 1: respond - to evacuation - l 2- JUDGE SMITH: Just.a moment. Did you intend for such 3 an. extended response to your question? 1. 4 MR. 'TRAFICONTE: Well,- I wanted a summary if 1'could 5- get one, o f t h e -- 61 JUDGE SMITH: Very well, okay. 7' THE. WITNESS (Zeigler): I will try to be brief. i 8 'I think that Daven the context-of events.as they have _ 9 followed Three Mile Island that you may, in fact, expect _just
'10 as stronD, if not a stronger evacuation response at Seabrook or 11 any other plant. ,
1 12 Maybe I will give my colleagues a chance to respond, 7 .. . 3 , 13 too. 14 THE WITNESS'(Johnson): . I' w i'1 1 be brief. 15 With respect to the whole role of EBS messages, I j 16 think it.is important to point'out that in the long list of 17 disaster ntudies that'have been cited, by Dr. Mileti and other. 18 people in this proceeding, I think that it is important to-19 point out that what the research shows is that EDS. messages 20' have been important.in under-response, that is, Detting people 21 who refuse to respond to take protective actions initiative.
'22 It has been important in getting those people to take 23 protective actions.
24 There is no evidence to suggest that those EDS 2S messages will deal with the issue that we are confronted with Heritage Reporting Corporation (202) 628-4888
l
) ZEIGLER, JOHNSON, COLE'- REDIRECT 809L 1 in terms of a nuclear power plant accident,.and that issue is 2 over-response.
3 There is no evidence that an EBS message'will keep 4 people in place, will stop them from spontaneously evacuating. 5 I think when you' add that fact to the whole notion L G that.the revised regulations do nothing to deal with the.large 7 amount'of other conflicting information that is likely to i 8 present.itself, in the event of another. nuclear emergency in 9 this country, I ~think that when you factor that i n, I.have to l 10 concur with Dr._Zeigler, that spontaneous evacuation is a real 11' problem that is likely to'present.itself, in the event of a 12 nuclear emergency at Seabrook or any other nuclear power plant. (' . 1
-13 THE WITNESS (Cole): Just very briefly, it seems to 14 me that one of the primary if not the basic difference between
~
15 the. witnesses for the Applicant and the witnesses for the 16: Interveners on the. behavioral issues, is that we all agree.that l l 17 the residents of the Seabrook EPZ have a strong fear of L 18 radiation, that mi Dht be released in a radiological arcergency l-f, 19 at Seabrook. L.. 20 The witnesses for the Applicant argue that the 21 clarity of the EBS messages, will overcome all of t.biu fear, 22' and we believe that the EBS mesnages, no matter what they say 23 in them, cannot possibly overcome this fear, in the light of R24 - the atmosphere that is going to exist in a real radiological t 25 emergency, with all the media, all the different people Heritage Reporting Corporation (202) 628-4888
r, i' I l' l-1 ZEIGLER, JOHNSON, COLE - REDIRECT 8090 0 1 commenting on it, and the lack of. credibility that the people 2 issuing the EBS messages will have under that situation. 3 And that was very strongly supported by our research 4 on.Long' Island, in which we found that the people living around 1
.5- Shoreham just-did not believe the EBS. messages and found them 6 confusing and frightening and anxiety-producing and this was 7 only in a room at the University, it was not during'a real 8 radiological' emergency.
9 So,'essent'ially we'believe that on all the trasis,- all i- .10 - the evidence that we have that these EBS messages, in l 11' 'themselves, can' t overcome the strong fear of radiation.
' 12 ' And that if there is a radiological emergency there
^
- h. 13' wi:1 be a very subst'antial over-responne.
l l 14' MR. TRAFICCNTE: I have nothing further, Your Honor. 1 L 15 JUDGE 9MITH: Are you' going to have recross? l 16 MP. lEWALD: I have two matters. 17 'One I would like to move to introduce the Applicants' 18 Exhibits Number 26, tnd 27 for identification, which I do not 19 believe I have formally done earlier. It has been alluded to 20 but -- and I would like to do it at this time. 21 JUDGE SMITH: Are there objections? 22 (No response.) I i 23 JUDGE SMITH: The Applicants $ -- l l 24 MR. TRAFICONTE: - can we j ust , we are just trying 25 to locate which ones they were. There were other papers that
- 1) i i
1 1 Heritage Reporting Corporation j (202) 628-4888 !
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I gg. . ZEIGLER,. JOHNSON, COLE - REDIRECT. .8096 , Q) . I we had.. 2 MR. LEWALD: These'are the Sociological Method 3 excerpts, and the Chapter 3'Section from the.Three. Mile 5 Island-
.4 study that was conducted by Drs. Zeigler?and Johnson. I 5 MR. TRAFICONTE: But not the Maxwell pieco?
6 MR. LEWALD: No. 7 That'in already part offExhibit Number 5, as I 8 understand that is already in-evidence. 9' MR. TRAFICONTEi Well, just on that last.part, I 10 don' t believe that is correct. 11 I don' t believe the Maxwell study is part of.-- 12 MR. LEWALD: No, the Maxwell: study i's not, I am 13 sorry. The Maxwell study was not offered in evidence.
.{
I-
'14 thought that you were referring to' Appendix.G of. Volume 4.
15 The Maxwell study was neither marked nor am I 16 offering it. 17 JUDGE SMITH: Two Exhibits, Numbers 26 and 27;.'26 in 18 the Sociological Method, excerpts by Dr. Cole, and 27 is the 19 Chapter 3 of the Social Survey of TMI Area Residents. 20 M R. TRAFICONTE: I have no ob.jection to those. 1 21 I would just, if I might, add our root ion to have the 22 next document which was the Maxwell article also entered into l 23 evidence, that Mr. Lewald used during the cross-examination of 1 24 Drs. Johnson and Zeigler.
.25 MR. LEWALD: I don' t know on what basis this is being =
0 Heritage Reporting Corporation f (202) 628-4888
y, . jb i ZEIGLER, JOHNSON, COLE - REDIRECT 8099-1- offered.- It is an article that uornebody wrote and the person I
.2 who wrote it, is apparently, at least.in the portion we were ;
concerned with was quotinD to a newspaper --' 3 j
-4 ' JUDGE SMITH:. Go you ob. ject' S b ,,.
5- MR. LELJALD : I object. k y i 6- JUDGE SMITH: Okay. l 7 - MR. TRAFICONTE: Well, .if.we are. going to have,e
- I l .-
8 rnot ion heard, I arn sure that we don' t want to, I would just 9 point out t hat - Mr. Lewald dio. cross-exarnine on the basis of( thja 10 inforrnation contained.in that - - - t 11 JUDGE SMITH: That does not get it intb evidence-(( L
- 12. though.'
- m 13 You cannot get it into evidence on that basis; l-L- 14 objection sustained. .,
t . 15 You are not at this tirne of fering the. telephone 16 cornpany letter, Exhibit Number 28? 17 MR. LEWALD: No.
-18 I think that I already had'a ruling-on that, that in <
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19 the face of the objection raised, that it wouldn' t be adJnitted, -l
,i h' 20 so I won' t press it s adraission. [ ,
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21- JUDGE SMITH: Yes. I l' 22 At least'it was a portender of what an offer might 23 bring. , 24 MR. LEWALD: That is correct, Your Honor. # ')
- 25 And I just have one question on redirect. s
!' Heritage Reporting Corporation I (202) 628-4888 l t l \- \. _ .._ - - - -
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- 8. Exhibits Numbers 2G and 2'7, lthenk you, e,g , received.
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V 13 , RECROSS EXAMINATION' , I
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.14 BY MR.t LEWALD: 4,
[ 15 Q .I would ask the panel if it would direct itn Il
= 16 attention to Page 11, of At t achrnent 5, . to your . test imony. and .
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-x hi . II theglast, paragraph on that paDe, which" reads, "most ebeial 17 l q -1 9 18 scii niihts studying the respcnse *;o the public to thy n ,. >
f 19 rad iolcig ical emergencies agree that whether or not Jhti pub 1(c 20 complies with protect ive act ion recornmerNe hp nrp, depends C , I t i, , 4 21 prirnarily on two f actors: pre-exist i ng- f ear . 0f. exposure t o e< 1 ..!' 22 y;adilalion and the informat ion the public rd:eiven during the 3 .( ct'h 23, ,, t ,W:c @ nt , (including the official CBS messdt.es)."
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24 ]t_ i And there is a cito forwarv to footnotes, including
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* , i 1 19 pro-nuclear or' anti-nuclear sent irnent s oW&ehalf of the I
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( Is that correct [ d.id.you infer that or state that?
;l 22 t THE WITNESS (Zeigler?: I would say that if I stated r
(23 jit.in a pro-nuclevr or ant i-nuclear cont e xt, I wou l ti rnodify
'24 that to,say, a f9arful context. It is correlated, I think, with l t l
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i I lZEIGLER, JOHNGON, COLE - EXAMINATION 8100 - 1- JUDGE HARBOUR Ai1 right. !
-l
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2, -THE WITNESS (Zeigler): People.who are fearful of d 3 radiation. 4 And I think, what I-think,- in that context what I w a s 5 saying at the .t irne of the Three -Mile Island accident, people 6 were.not exceptionally conscious ~.of the hazards of nuclear _ 7 energy in this: particular sett ing.. 8 Whereas, now, I think that the people are very 9: conscious and hence, very fearful of the reality of a nuclear 10 accident taking place. 11 : JUDGE -HARBOUR So you were not ' rnaking such a 12' correlation'then? 1 i THE WITNESS , (Zeigler): 4 '
. 13 I was not' intentionally.
14 JUDGE' HARBOUR Thank you. L15 . JUDGE LINENBERGER: Very quickly, Dr. Cole, the' l i L ~16 respondents to your, I will say your survey questionnaires, l' l'-
. 17- lived in a'quite a few towns, within the EPZ er bordern the l:
l 18' sarne. I 1 19 And I arn wonderinD if - I should like to inquire, l-20 was any effort rnade to deterrnine whether the responses, total 21- responses, frorn any given town, represented a significant i' 22 departure frora the overall response of the total aggregate of 23 respondents? 24 Was that looked at? 25 THE WITNESS (Cole): Many people analyzed the data. Heritage Reporting Corporation (202) 628-4888
'y.
~ZEIGLER, JOHNSON, COLE - RECROSS 8101
.D3 1. My. primary role was in' collecting it. .And in my analysis 1 2 did not do that. My analysis was ainmd at generalizing to the 3 entire EPZ. Some of the other consultants mayi have looked 'at 4 some of.tha separate tewns. But-I personally did not. 5 JUDGE LINENBERGER: 'Do any of the other panel members
'.G have a comment that would' help here?
7 THE_ WITNESS (Johnson): We did not look by town, 8 either. 9 THE WITNESS _(Zeigler): No.
.10 JUDGE LINENBERGER: All right, thank you.
11 That is all. 12 JODGE' SMITH: Any further questions? 13' MR. BISBEE: Just one raat ter to . follow-up, Your 14 Honor. 15 RECROSS EXAMINATION 16 BY MR. BISBEE;
- 1 '7 Q And I would like to. address this to Dr. Cole, in the 18 first instance.
19 1 thought that I heard you say in response to Mr. 20 Traficonte's quest ion earlier, about the impact of the EBS 21 messaDes that these EBS rnessaDes would not overcome the fear 22- that the publit has to a large extent to diminish the 23 spontaneous evacuation that would occur. 24 Were you referring to the messages that are contained 25 in the plan as it now stands? 1 HeritaDe Reporting Corporation (202) G28-4888 1 i
' i l ..
f l :. 1 ZEIGLER,. JOHNSON,LCO.LE - RECROSS 8102
. 1 1 A. (Cole). My statement would certainly include those l
2- messages, yes. 3 Q But -it would also include any EBS rnessage. 4- 'A (Cole) It would include all..the ones that I have 5 seen. 6 Q Are.there EBS messaDes.that you would prepare so that 7 the impact would be greater on dirninishing spontaneous L 8 evacuation? 1 9 A (Cole) I think I could do a better job, but I don' t 10 think I could overcome the tremendous fear of radiation that [ 11 people have. L l 12 I agree with roy ' colleagues, that the rnessages are one
'13 factor and they, by themselves, cannot overcorne this tremendous
}
L .14 fear, no matter how clear the messages are, no matter who 15' writes them or what is in them, they are not; going to 16: completely overcome the fear. l 17 And there will be a significant spontaneous 18 evacuation which should be considered in making up the plan. 19 However, I think that there is room for good and bad
- 20. in the messages and they can have some effect. How much, is 21 hard to say.
.22 Q And can I ask the last question to Drs. Johnson and 23 Zeigler.
24 Do you agree that really, in escence, no EBS message, 25 regardless of how clear it rn i gh t be, would overcorne to any Heritage Reporting Corporation (202) 628-4888 l 1 l
- r. _. - - - _ _ _ _ _ _ _ __ _
ZEIGLER, JOHNSON, COLE RECHOSS 8103 1 appreciable extent, the. irnpact on the 'public in terrns of 2 spontaneous evacuations? 3 'A (Zeigler) Well, .in general, Iwould agree'with that.
.4 I rnean I agree with Dr. Cole's assessrnent of the situation.
5 ~A (Johnson) I concur. 6 MR. BISBEE: Thank you.. 7 JUDGE SMITH: You roay step down, gent lernen. 8 Do you have any further questions? 9_ (No response.) 10 JUDGE SMITH: Thank you very touch for corning. 11 You are excused. 12 (Whereupon, the witnesses were excused.)- 13 (Whereupon, at 3:00 p.rn., the evidentiary hearing was 14 recessed, to be reconvened irnrnediately to the public l irnit ed 15 appearance staternents. ) 16 17 18 19 20 21 22 i i
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_______b m _ _ . - _ . . - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
1 i 1 CERTIFICATE e l l l 3 This is to esert i f y that the attached proceedings before the l l 4 United States Nuclear Regulatory Commission in the matter of: 5 Names PUBLIC SERVICE COMPANY OF G NEW HAMPSHIRE, et al. 7 Docket Number S-443-OL, 5-444-OL 8 Place CONCORD, NEW HAMPSHIRE 9 Date December 16, 1987 10 were held as herein appears, and that this is the oriD inal 11 transcript thereof for the file of the United States Nuclear 12 ReDulatory Commission taken electronically by me and, 13 thereafter reduced to typewriting by me or under the direction 14 of the court reportinD company, and that the recording is a 15 true and accurate re:e of h forer(0ing pro.tedings. 16 /5/ i IMM LA%_ 17 (Signature typed): KENT ANDREWS 18 Official Reporter 19 Heritage Reporting Corporation 20 21 22 23 24 25 D Heritage Reporting Corporation (202) 628-4888
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