ML20238F156

Testimony of Cj Earl Re Contentions NHLP-2,SAPL-8,SAPL-8A & Town of Hampton Revised Contentions IV & Vi.* Related Correspondence

ML20238F156
Person / Time
Site:	Seabrook
Issue date:	09/11/1987
From:	Earl C NEW ENGLAND COALITION ON NUCLEAR POLLUTION, RESOURCE MANAGEMENT SYSTEMS, INC.
To:
Shared Package
ML20238F154	List: ML20238F152 ML20238F156 ML20238F159 ML20238F165
References
OL, NUDOCS 8709160004
Download: ML20238F156 (8)

Text

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"%b September 11, 1987 UNITED STATES NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

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In the Matter of )

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Public Service Company of )

New Hampshire, et al. ) Docket Nos. 50-443 OL

) 50-444 OL (Seabrook Station, Units 1 & 2) ) OFFSITE EMERGENCY

) PLANNING

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TESTIMONY OF CLIFFORD J. EARL REGARDING CONTENTIONS NHLP-2, SAPL-8, SAPL-8A, AND TOWN OF HAMPTON REVISED CONTENTIONS IV AND VI i 1

QUESTION 1: Please state your name and qualifications.

ANSWER: My name is Clifford J. Earl. I am a resident of I the City of New York. I am the President of Resource Management l Systems, Inc. I am an expert in the area of public sector resource planning and management, including public sector staff resource needs planning. A resume detailing my qualifications is attached.

QUESTION 2: What is the purpose of your testimony?

ANSWER: My purpose is to offer my judgment concerning the validity and reliability of the conclusions reached in l Applicants' " Summary of Personnel Resource Assessment for the New  ;

Hampshire Radiological Emergency Response Plan," dated August,

! 1987, a) that the local governments in the Seabrook Emergency f

Planning Zone ("EPZ ") have sufficient personnel to adequately l respond to an emergency at Seabrook; and b) that the State of New Hampshire has adequate personnel to provide assistance to local i

governments, as discussed in Volume 2, Appendix G of the New 8709160004 870911 PDR ADOCK 05000443 T PDR

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h Hampshire Radiological Emergency Response Plan ("RERP"), Revision 2.

QUESTION 3: What materials did you review for your evalua-tion?

ANSWER: I reviewed Volume 2, Appendix G and referenced com-ponents of the New Hampshire RERP, Revision 2 and the Summary of Personnel Resource Assessment for the New Hampshire Radiological Emergency Response Plan, dated August 1987 (hereafter " Summary").

I also reviewed the Radiological Emergency Response Plan for the Town of Hampton. .

QUESTION 4: Please describe your evaluation of the Person-nel Resource Assessment Summary.

ANSWER: In reviewing the Summary, I found several serious weaknesses in the methodology.

First, and foremost, the Summary fails to explain or define one of the key terms it employs: " availability." The question I

of what constitutes " availability" is a key issue in this Sum-mary. The authors of the Summary claim to have employed

" availability analyses" (Summary at 2-2) in order to reach their k i

central conclusion that adequate personnel are "available" to j implement an emergency response at Seabrook. Summary at 4-1.

Yet, nowhere, does the Summary explain what the term means.

I The term "available" (" availability" or " availabilities") l I

l can have significantly different meanings for different people  ;

i under different circumstances. For example, 1) a senior decision-maker may conclude that it means specific personnel l l

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(i.e. people) has been assigned to perform specific tasks at

' specific locations within a predetermined timeframe; 2) a budget specialist may conclude that it means all funded positions, vacant or filled; 3) a personnel specialist may conclude that it means all funded positions, less personnel on terminal. leave; or

'4);a line-supervisor'may,. conclude that'it means the number of people.he or she has today to perform the necessary work. Other considerations in' defining the term "available" would include such issues as whether people are available only during their work shift or whether they can be relied on during off-shift hours; whether they can be reached during off-shift hours; and whether, if' reachable, they are capable of performing their assigned tasks (i.e. whether they have transportation, whether they have responsibilities at home that might prevent them from responding).

In this case, the concept of " availability" should include a clear understanding of which people will respond to a Seabrook accident, how they will become available, and how and when they will appear at their duty stations. However, the term

" availability" is not defined at all in the Summary. Given the wide range of. interpretations that may be given to this term, there is thus no means for evaluating whether the alleged staff-ing capability is actually adequate for a' response to a nuclear accident at Seabrook. Moreover, it is impossible to determine 1 whether survey personnel, or persons supplying data for surveys and interviews used a consistent definition for the term. If

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I they did not, the probability of unreliable data exists. I con-sidor the failure to define the term "available" or to

-demonstrate that it has been applied consistently throughout'the process of preparing the Personnel-Resource Assessment to be a critical defect in the Personnel Resource Assessment Summary.

Second, the Summary fails to quantify the work load involved for each-position to be filled. .The Summary's description of the assessment methodology used for all local. municipalities states that the determination of specific numbers of. personnel required to implement each local plan was made via a review of each plan and its associated procedures, and that " building upon the review and revision of each plan, a walk-through of each implementing ..

procedure was then conducted to identify,-by position and func-l tional responsibility, all of the tasks required to be performed  !

in fulfilling the contemplated emergency response functions."

Summary at 2-1. O The Summary asserts the completion of a " a walk-through.of each implementing procedure...to identify, by position i l

and functional responsibility, all of the tasks required to be j performed in fulfilling the contemplated emergency response func-tions." Summary at 2-1. However, the authors of the Summary have not defined the term " walk-through" clearly enough to 1 1

determine if they actually calculated the amount of work involved i

! in each task and position, or merely matched up tasks to i

responsibilities and responsibilities to positions. In this par-l l

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p1 ticular case,~atia minimum, a walk-through should include cal-3 ,;

culation~of' work load for:each position'. / i c

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I 1A: sound staff redource methodology wouldinvolve.predictioft q of'the number.of staff'needed for eachtposition based on a cal- @:, j x

culation of the' amount of work requireditol fulfill the responsibilities associated with each position, otherwise, it cannot be reliably concluded that perscn\s filling specified: posi-tions can perform all of their required tasksseffectively. ;The P y .ky g methodology. described in'the Summary,'however, doe.s not indidate s

that'the determination of the-: number of staff.needed.to implement

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'each plan-is based on a.. calculation of:the amount offwork to be

, performed:by-a' person in'each position in. order to: fulfill his or.

her. responsibilities..

If work load was not quantified and used in the calculation of needed staff resources, then there is a serious flaw in the methodology used to determine the.-number of staff required. If work load data were used in the calculation, then the work load calculations should be specifically. cited.in the Summary.

Unless work load i's incorporated'intoIthe staff needs cal-culation, the Summary does not support the assertionLi'n Section 4 that-"the Summary identified the specific needs for... personnel."

Further, if work load estimates were not developed and used in calculating staff requirements, then the estimates of staff needs SN

are unreliable.

. Finally, the methodology employed in the Summary fails to-i show consideration of potentially critical variables. ;For exam-o

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pin, one might' expect that in any emergency situation,' time would s of

' w! g'IgF b, a 4 critical' factor -- for instance, the.. time needed to contact-

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$ t-}QY)<y ccEntpensatory ' . state . personnel, . the time required. for. su

'^ne'Into travel 1from their routine work location to their emergency

. responce location, the tiine such personnel would take to famil-ep iarize themsels;es'with, and implement,' specific emergency response proedddres.

Considering the3 foregoing, - it'is my opinion.that due to qu jf'cri,t.ical flaws in the methodology employed in1the Summary,.the r,

Summary's conclusions that a) that the. local governments in the 4 Seabrook' Emergency' Planning Zone ("EPZ ")'have sufficient person-

.nel to adequately respond to an emergency at Seabrook; and b) a that the State of New Hampshire has adequate personnel to provide f assistance to local governments, as discussed in Volume 2, Appen-dix G of the New Hampshire Radiological Emergency Response Plan, Revision 2, are not reliable conclusions.

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s RESUME Clifford J. Earl, President Resource Management System 30 Fifth Avenue,.4th Fl.

New York, NY 10011 (212) 674-1350 1985- .

Resource Management Systems, Inc., President Present The firm's primary line of business and' expertise is providing training and technical assistance to local-and state agencies. The services provided are,-

. generally, in three areas: human and budget rosource planning; operations planning and evaluation;-and man-agement/ operations planning and reporting systems.

I.have designed and presented 12 of our training courses for public managers and executives. The train-ing. program titles include: Writing Effective Budget Justifications; Designing Management Planning and

' Reporting System Performance Indicators; The Operations Review / Audit; Project Management; and Work Force Plan-ning and Budgeting. These reflect my personal areas of expertise.

1984 Independent Consultant Developed and presented training programs for executive and managerial personnel from New York State and' City.

The training programs were designed to enhance critical resource, operations planning, management and evalua-tion skills and abilities.

1981- National Center for Public Productivity, Consultant 1983-Provided technical and/or training assistance to New York, New Jersey, and Connecticut state and county agencies in the following areas: program evaluation and implementation; operations auditing; budget and management planning systems; cost-benefit analysis; management by objectives; and project planning and man-agement.

1979- NYC, Office of the Mayor, Office of Operations:

1981-Director, ODerations Audit Coordination add Review Responsible for: a) review, evaluation and, if appropriate, approval of agency operations improvement plans, and b) monitoring implementation status of approved plans.

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'g!c t-An agencyioperations improvement'p1A, was..normally.

developed id response'to ah audit or operations review report which. identified actual, or potential, per-formance problems. .

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The review / audit repccts wcre usually issued.by: -the Office of the State Coup, troller (New1 York),, the Office $

l- L d 4 -of the Special Deputy Comptroller-(State of New York),

or thb Cffice of the Comptroller (City of New York) . . '

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Manaaer, Finance, Economitf; Deve19J2mgnt : 1 Jntrastructure ,

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Responsible-for review a>d evaluation ~of annual aga.ncy l operations. plans (and rilated performance objectives),

in conjunction with annuni agancy expense budgot requests.- Also monitored and evaluated implementation e x status of critical Inter-agency program initiatives.

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1978- NYC, Department of Consumer Affairs:

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The Department's primary areas of responsibility were: l a) businegs Jicensing, standards ~and control, and b)-

consumcr protection. -

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1. EugLoe. ten.t And Budaet (1978)

, Dan {d . Commissioner A I

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Responsible for agency management, operations and financial / planning; internal audit; coordination of ~

certain onterragency projects and programs.

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period 1974-1977, fulfilled operations and.

dinopcial planning responsibilities under tne following titles: "

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s. p a a Assistint pommissionqr - Budog_t (1977) #

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,e y Executive Assistant 19 Alle Decuty .pommjssiongr (1976)

Assistant ,t_q llLQ Dept , CommissioILqr ' (197 4-1975) 1972- Union Paciff ' c Corporation, Assistant to the Secretary 1974 Provided information and' data to the Chairman of the Board, and Board of Directors, to be used when consid-ering matters requiring their assent or approval.

h g; 1969- NYC, department of Cmisumer Affairs, Various Titles P'

1.972 Academic Background

'j 1984 John Jay Collega of Criminal Justice (Adjunct Lecturer) 1983 Ilofstra University (Adjunct Lecturer) 1981 '82 New York University, p4 1969 Morehead State Univne,GPA Technology Policy sity,;B.B.J. Program s

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