ML20244D606
| ML20244D606 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/14/1989 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| ASLBP, OL, NUDOCS 8906190163 | |
| Download: ML20244D606 (313) | |
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( UNITED STATES l NUCLEAR REGULATORY CORDESSION l
- IG' N A _
ATOMIC SAFETY AND LICENSING BOARD l
In the Matter of: )
) Docket Nos.
PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et al., ) 50-444-OL
) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING O
l Pages: 25527 through 25793 1
Place: Boston, Massachusetts l l . Date: June 14, 1989 W W W W W . M M W . W W W W W W E W W SBM W W W W W W W W e m M W W W W W W W W W W W W WD M S M . M W W W W W W I
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( o g HERITAGE REPORTING CORPORATION-yi opew neenes g#.,[uN[ $o 1220 L Strast, N.W., Sube 600 w u.si ,n.c.2sses f /0 (292) 628 4808
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25527:
' UNITED STATES' NUCLEAR REGULATORY COMMISSION Il
' ATOMIC: SAFETY AND' LICENSING BOARD -
t In the Matter of: ). .
_ :c l
) Docket Nos.- 4 PUBLIC SERVICE COMPANY OF ); 50-443-OL O' :]
NEW HAMPSHIRE, et al., )~ ' 50-444-OL .
.3
) - OFF.-SITE EMERGENCY-
-(SEABROOK STATION, UNITS l' AND 2) ) PLANNING EVIDENTIARY HEARING <
Wednesday, ,
June 14,H1989.
Auditorium Thomas.P. O'Neilli_'Jr.
- Federal Building 10 Causeway Street
. Boston,. Massachusetts The above-entitled matters came<onffor' hearing, pursuant to notice, at 9:00 a.m.
BEFORE: JUDGE IVAN.W... SMITH,' CHAIRMAN Atomic Safety and Licensing Board.
U.S. Nuclear. Regulatory.' Commission Washington, D.C. l20555-JUDGE KENNETH A.-McCOLLOM,: Member'-
Atomic Safety and Licensing Board-U.S. Nuclear: Regulatory / Commissions Washington,:D.C. '.20555' JUDGE RICHARD.F.HCOLE,'. MEMBER
' Atomic Safety [and" Licensing: Board ?
. U.S. Nuclear Regulatory < Commission Washington, D'.C. --20555 i
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, i Beritage Reporting. Corporation:
(202) 628-4888= -
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25528 APPEARANCES:
4 For the Apolicants:
THOMAS G. DIGNAN, JR., ESQ.
GEORGE H. LEWALD, ESO.
KATHRYN A. SELLECK, ESQ.
JAY BRADFORD SMITH, ESQ.
JEFFREY P. TROUT, ESQ.
GEOFFREY C. COOK, ESQ. ,
Ropes & Gray One International Place Boston, Massachusetts 02110-2624 ,
for the NRC Staff:
SHERWIN E. TURK, ESQ.
ELAINE I. CHAN, ESQ.
EDWIN J. REIS, ESQ.
RICHARD BACHMANN, ESQ.
Office of General Counsel U.S. Nuclear Regulatory Commission Washington, D.C. 20555 For the Federal Emergency Manacement Aaency:
H. JOSEPH FLYNN, ESQ.
LINDA HUBER McPHETERS, ESQ.
Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C. 20472 For the Commonwealth of Massachusetts:
JAMES M. SHANNON, ATTY. GEN.
JOHN C. TRAFICONTE, ASST. ATTY. GEN.
ALLAN R. FIERCE, ASST. ATTY. GEN.
PAMELA TALBOT, ASST. ATTY. GEN.
MATTHEW BROCK, ESQ.
- LESLIE B. GREER, ESQ.
Commonwealth of Massachusetts One Ashburton Place, 19th Floor .
Boston, Massachusetts 02108 l
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Heritage Reporting Corporation (202) 628-4888
25529
.- APPEARANCES: (Continued)
For the State of New Hampshire:
GEOFFREY M. HUNTINGTON, ASST. ATTY.LGEN.
State of New Hampshire 25 Capitol Street-
- Concord, New Hampshire .03301 For the Seacoast Anti-Pollution League:
ROBERT A. BACKUS, ESQ.
Backus, Meyer~& Solomon 116 Lowell Street
- P.O. Box 516 Manchester, New Hampshire 03105 JANE DOUGHTY, Director Seacoast Anti-Pollution-League 5 Market Street Portsmouth, New Hampshire 03801 For the Town of Amesburv:
BARBARA J. SAINT ANDRE, ESQ.
f' Kopelman and Paige, P.C.
77 Franklin Street' Boston, Massachusetts WILLIAM LGRD Town Hall Amesbury, Massachusetts 10913 For the City of Haverhill and Town of'Merrimac:
ASHOD N. AMIRIAN, ESQ.
P. O. Box 38 Bradford, Massachusetts 01835 For the City of Newburvoort:
. BARBARA J. SAINT ANDRE, ESQ.
JANE O'MALLEY, ESQ.
Kopelman and Paige,~P.C.
77 Franklin Street Boston, Massachusetts 02110 1
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Beritage Reporting Corporation
.N. s (202) 628-4888 s
25530 APPEARANCES: (Continued)'
For the Town of Newburv:
R. SCOTT HILL-WHILTON, ESQ.
Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street Newburyport, Massachusetts 01950 For the Town of Salisburv: ,
CHARLES P. GRAHAM, ESQ.
Murphy and Graham 33 Low Street Newburyport, Massachusetts 01950 Ep;t 3hp Town of West Newburv:
JUDITH H. MIZNER, ESQ.
Second Floor 79 State Street Newburyport, Massachusetts 01950 For the Atomic Safety and Liegnpina Board:
ROBERT R. PIERCE, ESQUIRE Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555
. Heritage Reporting Corporation (202) 628-4888
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25531' 1HREX i.
WJTNESSES: DIRECT CROSS REDIRECT RECPOSS EXAM
. Panel:
Captain ~ Daniel Breton.
John Van Gelder (prefiled) 25535
, by Ms. Doughty- 25533-by Mr. Cook 25536 by.Ms. Chan 25548 .
by Judge Cole .25563.
by Ms. Doughty. 25574' by.Mr Dignan 25577 by Mr. Fierce 25578-Panel No. 17:
Robert Cotter Joseph Bisson ;
Anthony M. Callendrello Peter Littlefield by Mr. Fierce 25585 y
( i EXHIBITS: IDENT. REC. REJ. DESCRIPTION:- -i i
(No exhibits)
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l l Heritage- Reporting. Corporation
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(202) 62S-4888
25532 1EDEE INSERTS: EAfaE Testimony of Captain Daniel Breton 25535 and John Van Gelder, Firefighters for the Town of Salem, New Hampshire, on Behalf of SAPL re: SAPL Cortention EX-12 (Reception / Decontamination Centers) , ,
Excerpts from Perrotti deposition 25614 Applicants' Plan for Cross- 25793 Exar ination of Testimony of Breton and Van Gelder NRC Staff Cross-Examination Plan 25793 for Captain Daniel Breton and John Van Gelder O
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Heritage Reporting Corporation (202) 628-4888
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l BRETON, VAN GELDER - DIRECT- 25533 1 E B Q Q E E D_ J__H Q R
(, 2 Whereupon, 3 CAPTAIN-DANIEL BP_ZTON 4 JOHN. VAN GELDER. 3 5 having been first duly sworn, were called as witnesses (
6 herein and were examined and testified as follows:.
- 1 7 DIRECT EXAMINATION l 8 BY MS. DOUGHTY:
1 9 O Good morning, gentlemen.
10 Would you please state your names and occupations 11 for the record?-
12 A (Breton) My name is Daniel Lewis Breton. I am-a-13 Captain in the Salem, New Hampshire' Fire Department.
, 14 A (Van Gelder) John William Van Gelder, firefigher,.
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\~- 15 Salem Fire Department, President of the Brotherhood of Salem 16 Firefighters.
17 Q Before you, you have a document entitled Testimony 18 of Captain Daniel Breton and John Van Gelder, Firefighters 19 for the Town of Salem, New Hampshire on Behalf of the
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20 Seacoast Anti-Pollution League, Regarding SAPL_ Contention
. 21 EX-12 (Reception / Decontamination Centers) ?
22 A (Breton) Correct..
23 A (Van Gelder) Yes.
24 Q Now, you have been informed that portions 1of that; 25 testiinony have been stricken to conform with prior rulings I
[-! Heritage Reporting Corporation (202)' 628-4888
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l BRETON, VAN GELDER - DIRECT 25534 1 of the Board? .
4 2 A (Breton) Correct.
3 A (van Gelder) Yes.
4 Q Are the remaining portions of the testimony true 5 and correct to the best of your knowledge and belief?
6 A (van Gelder) Yes. they are. ,
7 A (Breton) Yes.
8 Q And do you adopt that as your testimony in this 9 proceeding this morning?
10 A (Van Gelder) Repeat. I didn't hear. [
1 11 Q Do you adopt that as your testimony in this l J
12 proceeding? i 13 A (Van Gelder) Yes.
14 A (Breton) Yes.
15 MS. DOUGHTY: Your Honor, I request that the 16 testimony as conformed to the Board's ruling be bound into 17 the record and received as if read.
18 MR. COOK: No objections four Honor.
19 JUDGE SMITH: Have you provided a copy of it to 20 Mr. Trout for examination?
21 MS. DOUGHTY: I have not yet, but to Mr.. Cook, I * '
1 22 guess. I don't have the attachment which is the log. j
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23 JUDGE SMITH: The testimony as modified by the i 24 Board is received.
25 Heritage Reporting Corporation (202) 628-4888 4
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BRETON, VAN GELDER -' DIRECT 25535 1 (The Testimony of Captain 9 2 Daniel Breton and cohn Van 3 Gelder, Firefighters for the 4 Town of Salem, New Hampshire 5 On Behalf of the. Seacoast
, 6 Anti-Pcllution League, 7 Regarding SAPL Contention
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8 EX-12 (Reception /
9 Decontamination-Centers) 10 follows:)
11 12 13 15 16 17 18 19 20 7 21 22 ;
23 24 25 l 9 Heritage Reporting Corporation (202) 620-4888
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD '
'l Before the Administrative Judges:
.i Ivan W. Smith, Chairman
. Dr. Richard F. Cole Kenne th A. McCollom t ) -
In the Matter of )
)
PUBLIC SERVICE COMPANY OF NEW ) ' Docket No.
y 50-443-OL.
(Saabrook Station, Units 1 and 2) )
H (Of f-si te - EP)
)
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April 3, 1989' l
.t TESTIMONY OF CAPTAIN DANIEL BRETON AND JOHN VAN GELDER, FIREFIGHTERS FOR THE TOWN OF g SALEM, NEW HAMPSHIRE ON BEHALF OF THE SEACOAST ANTI-POLLUTION LEAGUE, REGARDING SAPL CONTENTION 1 1
EX-12 (RECEPTION / DECONTAMINATION CENTERS) i Seacoast Anti-Pollutien League By its attorney, BACKUS, MEYER AND SOLOMON-116 Lowell Stree t
- P.O. Box 516' Manches ter, N.H. 03105 1 i
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SUMMARY
OF TESTIMONY In their testimony, Captain Daniel Breton and Firefighter John Van ,
Gelder testify on issues raised by SAPL Contention EX-12 as to the lack of adequecy of the reception and decontamination center emergency response func tions in the host community of Salem, N.H. , as revealed by the June 1988 graded FEMA exercise. Captain Breton and Firefighter Van Gelder testify that due to inadequate manpower, infrequent training, lack of coordination, conflicting duties and overall confusion, the exercise in no way indicated the capability to respond to a real radiological emergency at Seabrook Station.
Captain Breton and Firefighter Van Gelder further state that because there was training immediately prior to the exercise, prior notice of the .
general timing of events, and only a few " evacuees" run through the facility etelative to the numbers that might need to be served, the exercise, confu nd inadequate as it was, did not provide a true picture of events e.e they would occur in a real emergency situation. They conclude that the exercise as it transpired on June 28, 1968 did not indicate an adequate emergency response capability in the host community of Salem in the event of a radiological emergency at Seabrook.
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TESTIMONY
- 1. Q. Would you each please state your full name and occupation?
A: John William Van Gelder, Firefighter, Salem Ngy Hampshire Fire Depa r tmen t.
A: Daniel Louis Breton, Captain, Salem New Hampshire Fire Department.
- 2. Q: How long have each of you been in your positions with the Salem Fire
- Department?
A: (Van Gelder) I started with the Salem Fire Departmert in January 1975, left in January 1982, and was rehired on July 5, 1983. I have served on the department from July 1983 to the present. ,
(Breton) I started in July 1972 and have almost 17 years with the department.
- 3. Q: Would you please describe your job responsibilities?
5 A: (Van Gelder) My job responsibilities are primarily EMS work and firefighting.
(Breton) I am responsible for supervising a shift of the Fire Department which consists of 15 men at 2 substations and the central station. I am the incident commander while I am on duty and would be in charge of the response to a fire or EMS type of incident.
- 4. Q: How many firemen are there in the Salem Fire Department?
A: (Van Gelder) 40 firefighters,16 lieutenants and 4 captains.
- 5. Q: Did both of you participate in the graded Federal Emergency Management .
Agency (FEMA) exercise of the emergency response plans for Seabrook 1
Station conducted in June 19887 A: (Breton) Yes. I was the shif t commander that day.
(Van Gelder) Yes. I was there as the union advisor to work along with Chief Donald Bliss. '
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. Q: What is your understanding of the functions that the Salem Firefighters' l 1
are supposed to perf orm during. a radiological emergency at Seabrook? i l
A: (Breton) My understanding is that the Salem Fire Department and the-1 firefighters on duty are supposed to be responsible _ for setting up and -
operating a reception and decontamination center for people possibly.
exposed to by products of a nuclear accident at Seabrook that would (
include the responsibility for decontaminating anybody who. was i contaminated. ;
- 7. Q: How many Salem firefighters actually participated in the June 1988 L
graded exercise? -
1 A: (Van Gelder) A total of 15 Salem firefighters. They were all on-duty-firefighters; no off-duty firefighters responded.
- 8. Q: W Id off-duty. firefighters respond to-a Seabrook emergency in your
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opinio:t
! A: (Van Gelder Currently no Salem on-duty.or off-duty firefight s are l
l l obligated to res nd. We have a Memorandum of Agreemen < ated June 21, i
1988, which states at aragraph 2 as follows:
The Town agrees th it will not re ire local 2892 members to particip(ate in radio ical/ decontamination'
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training, exercises an per ons .af ter June 28,.1988 until an agreement has b reached be ieen the parties.
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- Even bef ore the Memorandu Agreemen was in effect, no of f-duty.
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firefighters respo d to the two prior dri even though they Vould have been p time and a half. We will have t egotiate with- the town j and town in turn has to reach an agreement with t state. l
- 9. Q: Were any mutual aid firefighters present from other communities' at ;the l exercise?
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A: (Van Gelder) Yes, there were approximately 15 firefighters from out of town. Including Salem and the mutual aid personnel, there were a total of approximately 30 firefighters.
- 10. Q: our knowledge, have mutual aid firefighters r eived training to respond t radiological emergency at Se ook Station?
A: (Van Gelder) The we had the e- cise, June 28, 1988, I contacted .
the Deputy Chief from the W am Fire Department and as of that date they were not traine . I also talke cone in Pelham and Pelham firefighters a ,o were not trained as of tha ate. As far as the other m al aid towns are concerned, I am not sure o the answer to thj - question.
- 11. Q: Where is the Reception / Decontamination Center located in Salem?
A: (Breton and Van Gelder) At Salem High School on Geremonty Drive.
. 12. Q: lichqanyevacueeshaveyoubeentoldyoushoul a prepared to expect at the fh lity?
A: (Van Gelder) ave been told 3 .
(Breton) At meetings e e had I have heard anywhere from 3500 to 10,000. What fi re is urate I don't know. I have heard all different fi res at dif f erent sta s. I don't know today how many we ar suppoced to be able to receive.
- 13. Q: How ny firefighters would you expect would re there were an emergency a Jeaurook at any point in th u ture ?
A: (Breton) The reep se would cons of 15 on-duty firefighters.
(Van Gelder) The 15 on wt irefighters may be requested to respond l l
but would not be obl ted to spond at the present time. Fur the r , l those 15 firef ters could not all tied up at the reception center since t would be responsible for protec Nthe rest of the
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p community. Some of the irefi ters have told me that even if they were on duty, they would me sick and take care 'of their families. I J
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- 14. Q: We personnel given training just prior to the exer se?
A: (Van Gel r) On June 9,1988 we had a practic exercise, which we., l videotaped, an gs went roughly the me on June 28, 1988. The
, group that was on du for the Jun 8 exercise-had a class two days j
bef orehand and were traine what they were supposed to be doing. In
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a real situation it is t like y that there would have' been training just two days bef e and I do not thi that things would even go as :i well as the' id on June 28. The June 28 p ormance was totally
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inade te for a real evacuation.
- 15. Q. What portions of the exercise were you there for? -
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A. (Breton) I was there at the beginning to set things up but I was not' Ip) /
there for the monitoring and decontamination.
i (Van Gelder) I was there for the whole exercise.
- 16. Q: Was this an adequate exercise for what Salem firefighters are expected l
to handle?
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- (Breton) No. I just feel it was terribly inadequate, grossly 1
inadequate for what we are expteted to handle. In the first place, there is not enough manpower. There is also not enough coordination.
Our scope is extremely limited. I did the best I could with the 15 people that I had. We have to take our time because we don't do this every day. We have to unload the truck and everybody has to be refreshed as to where to go. There were a lot of people observing -
and looking around, but not a lot of people responsible for carrying out the exercise. In essence, we just don't have the manpower to pull it off the way it should be pulled off.
(Van Gelder) I agree totally.
- 47. Q: ere
. you abic to get all the equipment in place?
A: (Breton) When I lef t all the equipment was not in place. All the equipment was not off the truck. There was a lot of confusion about the materials coming off the truck with respect to the different kits.
Any particular sta tion might have 3 to 4 kits and some of the kits needed at the station might be in the front of the truck and others in the back of the truck. It takes an enormous amount of time to a coordinate the material. There was a lot of confusion.
- 18. Q: Did anybody seem to have a command of the central coordination of the f acility and how it was supposed to be set up?
A: (Breton) No. There seemed to be as much confusion among the people supposed to be "in charge" as with us. A lot of time I spent there dealt with just emptying the truck. It was just ridiculous, materials scattered all over the place, even though the truck was supposed to have been reloaded and better organized than it was at the non graded exercise that was supposed to prepare us for this graded one. What we had requested be done in loading the truck evidently was not done.
- 19. Q:\ ven the training that Salem firefighters hav had in monitoring and decont ination, and given the frequency that training, do you think the firefigh s will be able adequat y to recall and use that information in a Se rook Station mergency? l A: (Bre ton) The training va ad uste for me at the time, but we don't
- ge t the training of ten en gh t e efficient over a period of time.
In other werds, I can etain the infor tion from classes for a short ;
period of time, t after a week or two week or a few months, I can't remember the iner points or specifics about the m toring procedures.
Even th9 gh I have some background in this area I do have fficulties,
.( so I am concerned that y men a t able to' pick up this material as
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quickly due to lack of bac round training..
- 20. Q: Most the firefighters have not ha ny other training background in-this area?
A: (Breton) No, they ve " . Some of the people have come to me and
, expressed that t do n - understand and are not sure about what they aredoing
- 21. Q: What was your overall impression of the exercise?
a; (Breton) " Confusion" was the word of the day at the' exercise.
- 22. Q: It is being represented to you that the following quotation appears in the Final FEMA Exercise Report on the graded exercise that occurred in June 1988 in paragraph 5 on p.184:
The Salem f acility was activated in a timely and effective manner. The assigned personnel performed' as a team and demonstrated their knowledge of Emergency Plan Procedures for the necessary stations b to be established throughout the f acility. All necessary equipment and supplies were available and adequately demonstrated by the staf f. The staff was knowledgeab]e 1 in the proceedures to establish and operate each function of the facility.
q Do you think these statements accurately reflect what went on at the Salem High School on the day of the exercise?
.l A: (Van Gelder) 1 do not feel it accurately reflects what went on. l (Breton) 1 do not feel it's even close to an accurate description.
l of what went on. l l 23. Q: For what reasons do you think the statement is inaccurate? ;
A: (Breton) I'saw confusion and lack of coordination and people who did i not know what they were doing.
- 24. Q: Did you think the op of the exercise was reasonable?
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A: (Bre ton) The scope of e ex cise did not approach the number of people we're supposed to e apable of processit.g.
- 25. Q: Woul you report if there were an actual radiological mer.gency a t Seabrook St'b ion?
A: (Van Gelder) No. (wouldn't and if I e on duty I'd go home sick and
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get my family out of town (Bre ton) I would serve o 1 - were on duty at the time. I would ,
tell my family to 1 'e town and go t at the emerEency classification evel before the one at whic eople are told to evacua .
- 26. Q: Were you given prior notification of the time the Seabrook exercise was going to occur so you knew the general time frame to expect the l beginning of events?
A: (Bre ton) We were told the exercise was going to take place and we were informed of approximate times certain thinEs might happen. We had an idea of the time the EOC was going to be activated and we also knew l
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the approximate time when the reception / decontamination center would
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be activated. It was no secret.
- 37. Q: Did this prior notification help your response be more efficient than 1
it might otherwise have been? '
A: (Breton) Sure it did. But I wouldn't term the performance
- ' efficient". -
- 28. Q: How long did it take them to set up for evacuees to come through the facility?
A: (Van Gelder) A lot of the evacuees were standing outside the doorway
, for a couple of hours waiting to get inside. A lot of the buses that showed up later in the day were just turned around and sent back. '
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Q: During the exercise, were there any other impediments to pr,oceeding smoothly along?
A: (Breton) Yes. We still had to take care of the emergency calls for our own town. That's real life. There were a combination of various ambulance or EMS calls and fire calls. We responded to those as we normally would. Our department averages about 10 emergency calls per day.
- 30. Q: Of the 15 Salem fire personnel on duty on the day of the exercise, how many reported to the reception / decontamination center?
A: (Van Gelder) Twelve peopic.
- 31. Q: What was the time the reception / decontamination facility was supposed to be opened?
A: (Van Gelder) According to the Daily Communications Lt>g for June 28, 1988 (attached to our testimony), at 12:58 there was a telephone call to our dispatch center. It was the Assistant Chief requesting that the Fire Chief have the reception center ready for 1500 hours0.0174 days <br />0.417 hours <br />0.00248 weeks <br />5.7075e-4 months <br />, which is 3:00 PM.
- 32. Q: What time was the reception / decontamination operation open to admit evacuees?
A: (Van Gelder) According to the log, at 16:32, the Chief requested that the EOC be notified of the opening of the decontamination and reception areas, and at that time the EOC was advised of that. At 16:34, we had a report of a fire at 15 Henry Street.
- 33. Q: How many firefighters did the fire call at 16:34 call awey from the reception / decontamination center?
A: (Van Gelder) Nine of the twelve Salem firefighters that were at the Salem High School Icf t to r'eport to the fire call, leaving only three
Salem firefighters and the .rutual aid personnel there to carry on the operation. If it had been a call for the south end of the town, everyone at the high school from Salem Fire Department would have had
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to leave to report to the fire call. j
- 34. Q: Does this conclude your testimony? ]
A: (Van Gelder) Yes. ..
(Bre ton) Yes, it does. l l
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3 BRETON, VAN GELDER - CROSS 25536 )
x 1 MS. DOUGHTY: The witnesses are available for
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1 3 CROSS-EXAMINATION l 4 BY MR. COOK:
l 5 Q Good morning, gentlemen.
6 My name is Geoffrey Cook. I am one of the 7 attorneys for the Applicants in this proceeding.
J 8 I would like to begin by asking just a few brief 9 questions about your prior experience as firefighters.
10 Mr. Breton, you have worked with the Salem Fire )
1 11 Department for 17 years, is that right?.
J 12 A (Breton) That's correct.
13 0 When were you made captain? J
(. 14 A (Breton) I was made captain in -- I can't think 15 of the date. Approximately six years ago. I 16 O That would be about 1983?
17 A (Breton) Correct. I 18 Q Did you ever work as a firefighter for any other 19 town?
20 A (Breton) No, I didn't.
21 Q Who was the individual who first contacted you 22 about giving testimony in these proceedings?
23 A (Bretora) I was contacted by Mr. Van Gelder 24 relative to Jane Doughty asking questions concerning the 25 proceedings. And he asked me if I could answer some
[ ) Heritage Reporting Corporation K- / . (202) 628-4888
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l BRETON, VAN GELDER - CROSS' 25537 ')
i l r~s 1 ' questions, and I,came down, I went down to one of the fire 2 stations and answered questions.
3 O And the questions were put by Ms. Doughty? -
4 -A (Breton) Yes,.they were.
5 Q Mr. Van Gelder, did Ms. Doughty approach you 6 directly initially to give~ testimony?
7 A (Van Gelder) Yes.
8 Q She did.
9 Mr. Van Gelder, did Ms.-Doughty try to contact j 10 anyone else in the Salem Fire Department about presenting i
11 testimony? l i'
12 A (Van Gelder) Not that I'm aware of.
13 Q Did you yourself ask anyone other than Captain i 14 Breton to provide testimony, or whether he was willing to
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15 answer questions?
16 A (Van Gelder) No. The only person I discussed 17 this with was Captain Breton.
18 Q And, Mr. Van Gelder, at what time did you agree to 19 provide testimony in these proceedings?
20 Was that at the time that Ms. Doughty first 21 contacted you, or at a later time?
22 A (Jan Gelder) At the time she first contacted me. 1 23 Q Mr. Breton, when Mr. Van Geldor, in turn, spoke 24 with you, did you agree to provide testimony at that time, 25 or at a later time?
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( Heritage Reporting Corporation (202) 628-4888
BRETON, VAN GELDER - CROSS 25538 1 A (Breton) I didn't agree to provide any testimony 2 until I was questiened.
3 0 Until you were questioned.
4 A (Breton) Until I was questioned.
5 0 Okay.
6 Mr. Van Gelder, you've worked with the Salem Fire ,
7 Department for 13 years, approximately, is that right?
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l 8 A (Van Gelder) That's correct.
9 0 But you testified that you left the department for 10 approximately 18 months, from January 1982 to July 1983.
11 Is that also correct?
12 A (Van Gelder) That's correct.
13 Q For what reason did you leave the department at 14 that time?
15 A (Van Gelder) I had bought a business.
16 0 You operated your own business during the I
17 intervening months? l 18 A (Van Gelder) That's correct. J 19 Q What was the nature of that business?
20 A (van Gelder) It was a grocery store and a gas 21 station. -
22 O Why did you return to the Salem Fire Department in I 23 July of 19837 24 A (Van Gelder) There were a couple of reasons.
25 First of all, the long hours that I was putting in Heritage Reporting Corporation l
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BRETON, VAN' GELDER - CROSS 25539-l' at the grocery store.
2 And second of ell, I've.beenca'firefighter-in-3 Salem for seven years, and' previous to that I'was a-4 firefighter in Lynnfield, Mass,.for five years. And'after 5 getting out of the service for 18' months,.I realized that
. 6 this is the profession I want to~be in, that I really 7 enjoyed it and that I missed it.
8 Q Mr. Van Gelder, you say'that;there are 40 9 firefighters and 20 officers'in the Salem Fire Department.
10 1s that correct?
11 A (Van Gelder) That's correct.
12 Q Mr. Breton, would you know, does Salem have any 13 reserve firefighters?
14 A (Breton) No, they don't.
15 O They don't'.
16 A (Breton) However, the number you have has 17 increased recently, and there are now 43 firefighters.
18 Q And are the officers available in time.of 19 emergency to provide assistance for actual firefighting as 20 well?
21 A (Breton) Yes.
22 0 Yes. ;
23 Mr. Breton, you have the ability under state. ;
i 24 statute to conscript the services of persons during an J 25 emergency, .is that right? U I
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BRETON, VAN GELDER - CROSS 25540 1 A (Breton) In some --
2 MS. DOUGHTY: Your Honor. Objection, Your Honor.
3 That's a legal question and calls for a legal 4 conclusion.
5 JUDGE SMITH: Well, that certainly does, and we 6 will limit the question and answer to -- ,
7 MR. COOK: The witnesses' understanding.
l 8 JUDGE SMITH: -- the witnesses' understanding.
9 And not only his understanding, but his actual perception of 10 that requirement as it relates to his duties as a captain in 11 the department.
12 MR. COOK: Yes.
13 JUDGE SMITH: You may answer that.
14 THE WITNESS: (Breton) In certain types of 15 emergencies, I have the ability to use -- to obtain 16- personnel and equipment to mitigate the incident, the 17 particular incident, whether it be a mutual aid companies in 18 a situation of bad accident scene, vehicles to mitigate that 19 particular incident.
20 So I have the ability to put more manpower and 21 equipment into motion than we originally have, if that's -
22 what you are getting t.
23 MR. COOK: Yes, j 24 BY MR. COOK: l J
l 25 0 Mr. Breton, doesn't the Salem Fire Department have l l
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BRETON, VAN GELDER - CROSS 25541
,e w I mutual aid agreements with several towns?
f
's / 2 A (Breton) I don't know if there is a written 3 agreement. We do have -- historically, we have had 4 agreements with other towns, local communities and what not.
5 Q Would those towns include Auburn, Derry, East
. 6 Derry, Hampstead, Londonderry, Pelham and Windham?
7 A (Breton) To my knowledge, we've never, other than B Auburn. Yes, you are correct.
9 Q Okay, other than Auburn.
10 JUDGE SMITH: Is your answe; there you've never 11 called upon them for mutual assistance, or you understand 12 that they are available, or would you describe your answer 13 in terms of whether your experience or whether your 14 understanding as to their availability.
Ox 15 THE WITNESS: (Breton) Yes, Your Honor.
16 I don't know what their availability is, because I 17 am not familiar with Auburn And to my knowledge, we hrce 18 never called Auburn. And I don't know what the status is, ,
19 if they are a call-type fire department or a permanent fire l
20 department.
~
21 BY MR. COOK:
)
22 O But you have had a relation with the other six 1 23 towns, or some interactions? ;
24 A (Breton) Yes, we have. Yes.
25 Q Through the mutual aid agreements.
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BRETON, VAN GELDER - CROSS 25542 1 A (Breton) Yes.
2 Q Mr. Van Gelder, you say on the top of page 4 of 3 your testimony, don't you, that during the exercise 4 approximately 15 firefighters from out of town were present j
5 at the Salem High School reception center?
l l 6 A (Van Gelder) That's correct. .
l 7 O Mr. Breton, you say on page 5, do you not, that l
l -
8 you were present at the beginning of the exercise on June 9 28th, last year, but that you were not there for the 10 monitoring and decontamination.
11 Is that right?
12 A (Breton) That's correct.
13 Q Do you recall what time you arrived at the Salem 14 High School on the 28th?
15 A (Breton) I have it right here. I have the log of 16 that day if you permit me just to check it.
17 Q Sure.
18 (Witnesses review document.)
19 A (Breton) Sir, I can give you an approximate time.
20 Q That would be fine.
21 A (Breton) I was involved as early as -- I'm sorry. -
22 I was involved as early as probably 11:00, because j
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23 there were different levels of the emergency. j l
24 Q Eleven o' clock.
25 Were you there when personnel from the New Heritage Reporting Corporation (202) 628-4888 GI j 1
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BRETON, VAN GELDER - CROSS 25543 1 Hampshire Division of Public Health Services arrived?
2 A (Breton). Yes.
3 0 You were.
4 A (Breton) Yes.
5 As a matter of fact, they were there before'I got 6 there.
7 Q They were?
8 A (Breton) Yes.
9 Q Okay.
10 A (Breton) I didn't-reach the site of the - I was 11 involved like running around getting equipment. I'm in a 12 separate vehicle, okay?
13 So I have the ability to-go between stations and q 14 this type of thing. And so my vehicle happens to be Car 2, 15 that's the designation. I was running around getting i
16 equipment and this type of thing, and didn't reach the site ]
17 itself, the high school, until about 12:58.
18 Q 12:58.
19 A (Breton) Right.
20 0 Do you recall approximately what time you left
- 21 that afternoon as well?
22 A (Breton) I believe it was -- I believe I want to 23 say around 1400 or between 1400 and 1500, which is two and 24 three.
25 Q Mr. Van Gelder, you state ths,t you were there for-Heritage Reporting Corporation
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BRETON, VAN GELDER - CROSS 25544 1 the whole exercise.
2 Is that correct?
3 A (Van Gelder) That's correct.
4 Q What time did you arrive, approximately?
5 A (van Gelder) I was at the station from 8:00 on, C and the Chief and I were together probably at the high ,
1 7 school around 11:30.
8 11:30. - I Q
9 Were you with the Chief throughout the day?
i 10 A (Van Gelder) Most of the time.
11 Q Most of the time. i l
12 And you left at six or seven?
13 A (van Gelder) Yes, when the final -- when it was j 14 over, it was around seven. I'd say that's when I left.
15 O Mr. Breton, were you designated senior firefighter 16 for the day of the exercise?
17 A (Breton) Yes. I was in charge of the shift that I 18 day.
19 Q Do you understand the role of the senior 20 firefighter as defined in the New Hampshire Radiological 21 Emergency Response Plan?
22 A (Breton) Not totally, no.
23 Q Mr. Breton, before the exercise, the New Hampshire 24 Department of Public Health Services was assigned the 25 responsibility for managing the operation of the reception Heritage Reporting Corporation (202) 628-4888
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.j BRETON,. VAN'GELDERL- CROSS 25545 I center.. j 1
2 'Is that correct? ]
I' don't know who was assigned:
3 A (Breton). Sir, 4 responsibilities for management.
5 Q You don't know. Okay. . ]
)
6 Do you recall, perhaps from speaking.with-.
7 individuals,.how many DPHS supervisors were present.at~the 8 exercise? ')
9 A (Breton) No.
10 Q You wouldn't know, then, the precise l 11' responsibilities assigned'to the DPHS supervisors?
12 A (Breton) No, sir.
13 0 Mr. Breton, did you attend while.you were there a 14 DPHS monitoring supervisors briefing?
' 15 A (Breton) No.
16 To my recollection, what we did'when we arrived"we 17 had a --
18 Q Right. I just wanted to ask did you attend the 19 briefing.
20 A (Breton) No. No.
21 Q Okay.
22 Mr. Breton, if I can ask you for a moment to 23 assume that you and your men were performing monitoring and 24 decontamination operations in a real radiological emergency, 25 and that you receive notice of a house fire in Salem while l
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BRETON, VAN GELDER - CROSS 25546 1 you were at the Salem High School.
2 You would not send all of the firefighters that i 3 you had with you at the Salem High School to save the i
4 burning house, would you?
5 A (Breton) I would send whatever the response 6 recommendation was. And if my entire crew was at that . .
7 location and my entire crew was supposed to be on that 1 l
8 response recommendation, I would see to it that that 9 response recommendation was carried out.
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1 Q Now, if you were in charge of tbn entire ]
7 ~s
(
2 complement of personnel including. Mutual Aid Firefighters.
3 from other towns at the high school,,though', would it be 4 necessary to send the entire complement to answer a single 5 alarm fire? l
.i 6 A (Breton) It would. depend on where -- if our.
7 vehicles'and manpower are at the scene of the reception- {
'l 8 center, then whatever the response is'-- if that's where all; )
9 of our manpower and equipment is, and whatever the response ,
1 10 would call for, for this particular house fire, would be 11 what we would have to send. '1 12 And the response is, if it calls for two engines 13 and a truck company, then that would be.the response.we 14 send. And whatever the crews -- we set our people up as 15 part of a crew -- wherever they were assigned -- if they 16 were assigned to, let's say Engine 1, they would respond to 17 Engine 1 and go to the house fire.
18 We can't compromise the safety of the rest of our 19 town to this particular incident.
20 Q Right.
21 A (Breton) We still have to manage other incidents.
22 MR. COOK:- Your Honor, may I have just a moment to 23 consult, please.
24 JUDGE SMITH: Yes.
25 (Counsel conferring.)
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BRETON, VAN GELDER - CROSS 25548 1 MR. COOK: We have no further questions, Your i 2 Honor.
3 JUDGE SMITH: Does the Staff have questions?
4 MS. CHAN: Yes, Your Honor.
5 I believe you have the Staff's cross-examination 6 plan before you. ,
7 CROSS-EXAMINATION l
~
8 BY MS. CHAN:
9 Q Good morning.
10 My name is Elaine Chan, I'm counsel for the NRC 11 Staff.
12 Captain Breton, do you have any experience or 13 specialized training for the judging of the adequacy of the 4
14 radiological emergency response exerciPe7 15 A (Breton) Yes. I feel I P. ave enough training.
16 First of all, 17 years of experience on the fire 17 department. At least nine of those years in command 18 position.
19 I have a folder here with my schooling and that j I
20 type of stuff, if you would like that.
21 What I'm trained to do is, and what my schooling -
22 teaches me is, I'm trained to evaluate a situation, an
- b 23 emergency situation and try to determine the manning 24 requirement for it; the equipment; mitigate the incident, 25 hopefully, with as little property loss and little life loss i
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BRETON, VAN GELDER - CROSS 25549 i 1 as possible. Essentially, that is what my job is, i
f-~.s\ i h 2 Q I see.
l 3 Have you ever evaluated a FEMA graded radiological l 1
4 emergency exercise? )
5 A (Breton) Officially?
6 Q Yes?
7 A (Breton) No, I haven't. i 8 Q And you, Mr. Van Gelder, do you have any 9 9 specialized experience regarding -- judging the adequacy of 10 a FEMA graded exercise response?
11 A (Van Gelder) No, I don't.
12 Q Captain Breton, you said that you were the shift 13 commander the day of the exercise; is that correct?
'~ 14 A (Breton) That's correct.
15 Q And according to page 5 of your testimony the 16 response to question 15 which was: "What portions of the 17 exercise were you there for?"
18 You responded: "I was there at the beginning to 19 set things up, but I was not there for the monitoring and 20 decontamination." ;
21 A (Breton) Yes, that's right.
22 O Also on page 6 of your testimony, your response to 23 question 17 which was: "Were you able to get all the 24 equipment in place?"
l 25 You responded: "When I left all the equipment was 1
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BRETON, VAN GELDER - CROSS 25550 1 not in place."
4 2 Is that correct?
3 A (Breton) That's correct.
4 Q And during the time that you were at the center, 5 can you describe what activities took place?
6 A (Breton) Yes. . 4 7 We were trying to accomplish our goals, which were
~
8 to set up the area and parking lot for the buses and people 9 to come where they would be initially monitored. And set up 10 all the stations inside the high school.
11 In order to do that, naturally, we have to get the 12 equipment there, start removing the equipment. And while I 13 was there that's what I did, I just assigned people to 14 setting up the particular stations instead of taking the 15 equipment and material off the truck.
16 Q I see.
17 During the time you were there they were mostly 18 unloading the trucks?
19 A (Breton) That's correct. And setting up the 20 stations -- starting to set up the stations.
21 Q I see.
22 So the stations were not all set up and the trucks 23 were not completely unloaded at the time you left?
24 A (Breton) No, ma' am .
25 Q Your response to question 18 on page 6, you Heritage Reporting Corporation (202) 628-4888
BRETON, VAN GELDER - CROSS 25551 1 reiterated that: "A lot of time I spent there dealt with 2 just emptying the truck."
3 Is that where you witnessed most of the confusion 4 that you describe about some boxes being in the or some kits 5 being in the front and some being in the back and some
, 6 dissatisfaction about how the trucks were loaded?
7 A (Breton) There was dissatisfaction about how the 8 trucks were loaded and had been an ongoing problem, which we 9 had been trying to straighten out for some time, because we 10 had other nongraded exercises. We have a nongraded exercise 11 and we expressed to our chief what we felt some of the 12 problems were; and then he would let the Seabrook and 13 everything, whoever was responsible for taking care of the 14 truck and everything let them know.
15 And one of the problems was a serious ongoing 16 problem we thought was, to get this equipment off the truck 17 it had to be in specific places so it was easier for us to 18 locate it.
19 0 Oh, you mean in order of the setting up?
20 A (Breton) Yes. Whether it be in order of setting 21 up and have all the particular stations. There's a whole 22 bunch of different boxes with numbers on them. And there's 23 a few boxes with -- I don't know how many numbers, okay, 24 that's supposed to be in one specific station.
25 Well, we would start unloading the truck and try 9 Heritage Reporting Corporation (202) 628-4888
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BRETON, VAN GELDER - CROSS 25552 1 to get into that particular station and the next thing you 2 know in the back of the truck there would be something else 3 that would have to go to that station.
4 We tried to get that squared away because it is 5 very difficult to try and put all this stuff together in 6 specific locations. So we tried to get it so the truck was ,
7 packed properly.
8 Q In response to question 16 on page 5 where you l
9 were asked: "Was this an adequate exercise for what Salem 1
I 10 firefighters were expected to handle?"
11 Part of your response says: "Our scope is 12 extremely limited."
13 Could you please explain what you mean by that?
14 A (Breton) What question was that, please, again; 15 I'm sorry.
l 16' O Page 5, question 16.
1 17 A (Breton) Okay.
18 Q The fourth line of your response you say: "Our 1
19 scope is extremely limited."
20 What were you referring to? !
l 21 A (Breton) I guess I was referring to, none of us
- 1 22 had a full understanding of what we were actually supposed 1
23 to do. That all stems back into the training --
24 MR. COOK: Objection, Your Honor.
25 This covers an area that was stricken.
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- 1: MS.. DOUGHTY:. .Your Honor,.he is anewering a 5 2 question. The' answer was' elicited by Ms. Chan's, cross.
3 MS. CHAN: Well, I'm going to: move.to strikeithat 4 ' sentence from that testimony if it's based on theltra'ning, i
5 Your Honor.
6 MS. DOUGHTY: Your Honor, if the question' remains 7 .and the question is not withdrawn, he'has a right to answer 8 the question.
9 ' JUDGE' SMITH: I agree with Ms. Doughty. -
~
10 If you're going to ask the question and that's the 11 answer,-that's the answer; he is. sworn to tell the truth.
12 MS. CHAN: That's fine.
13 BY MS. CHAN:
14 0 Were you finished with your response?
\ 15 A (Breton) Yes.
'16 Q That was sufficient.
17 A (Breton) That was sufficient?
18 Q Yes.
19 You answer it, correct?
20 MS. DOUGHTY: Well, he hasn't finished his answer.
21 You haven't allowed him to do'it.
22 MS. CHAN: Oh , all right.
l 23 BY MS. CHAN:
24 Q I thought you had completed your answer.
25 Go ahead, I'm sorry.
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1 A (Breton) You had asked me about the scope of the 2 incident.
3 MR. DIGNAN: No , she asked you what the meaning 4 was of the words in the testimony; that's what she asked 5 you.
6 BY MS. CHAN: .
l 7 Q You said: "Our scope is extremely limited."
8 And I wanted to know what that meant? -
, 9 A (Breton) My understanding was, she was relating l
10 back to the scope -- my statement about the scope of the l 11 incident.
l l 12 JUDGE SMITH: No.
13 MS. CHAN: No.
14 JUDGE SMITH: Point to the actual question a7d 15 answer.
16 MS. CHAN: Okay.
l l 17 BY MS. CHAN:
1 18 Q On question 16 on page 5; do you see the question?
19 It says: "Was this an adequate exercise for what 20 Salem firefighters are expected to handle?"
21 On the fourth line down in your response you say: -
22 "Our scope is extremely limited."
23 Were you referring to manpower there?
24 MS. DOUGHTY: Your Honor, the first question she 25 asked was -- she asked him what he meant by the statement, Heritage Reporting Corporation -
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! l I which is a more general question. {
f-i 2 If she is withdrawing the earlier question.
3 JUDGE SMITH: It's a new question and she~can ask j 4 it the way she wants to. That was all right. She asked it-5 fine. 1 J
, 6 THE WITNESS: (Breton) I was referring to i I
7 manpower. I was referring to other things, also.
]
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8 BY MS. CHAN:
l So later in the question iua the last. sentence you 9 Q 10 stato: "In essence, we just' don't have the manpower.to pull 11 it off the way it should be pulled off."
I 12 You were referring again to: "Our scope is i 13 extremely limited." And it was a question of-lack of-14 manpower to do what you thought was necessary?
15 A (Breton) Lack-of manpower and lack of training.
16 Q Mr. Van Gelder, on page 8 of the testimony your 17 response to question 28.
18 The question was: "How long'did it:take them to 19 set up for evacuees to come through the facility?"
20 Do you recall how long it took you to set up?
21 A (Van Gelder) I can look back on'the log and tell j 22 you.
23 (Witness reviewing document.) ',
24 0 Would it assist you, I understand on page 9 of 25 your testimony the response to question 32: "According to Heritage Reporting Corporation (202) 628-4888
I BRETON, VAN GELDER - CROSS 25556 i i
i 1 the log at 1632 the chief requested that the EOC be notified q 2 of the opening of the decontamination and reception {
3 centers."
I 4 So I assume it must have been set up sometime I
5 prior te that time? I l
1 6 A (Van Gelder) That's correct. .
i 7 I was looking in the log for the estimated time of
~
8 the opening. I believe it was supposed to be around 1300 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />; it did not open up until 1632, 10 C I see.
11 But was it set up before you notified the EOC that 12 it was ready?
l 13 A (Van Gelder) In it's entirety? ]
l 14 O Yes?
15 A (Van Gelder) No. l 16 Q Was it set up some time before you notified the 17 EOC that it was ready?
18 A (Van Gelder) At approximately 1632 the equipment 19 was in place and that's when the notification was made.
20 0 On your response to that same question on page 8,
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21 question 28, you state: "That a lot of evacuees were 22 standing outside the doorway for a couple of hours waiting 23 to get inside."
24 Can you explain the reason for the line?
25 Was it because there were processing delays due to Heritage Reporting Corporation (202) 628-4 f t98
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- B R E T O N ,' -VAN GELDER -l CROSS 25557-1 the shortage of personnel-that were called-away to the fire?
2' A (Van Gelder) .The people.were' standing outside-3 waiting to be processed through, but:the evacuation center 4 wasn't set up.yet. .
1 5 -Q So this was prior to 1632?
6 A (van Gelder) Thisfis correct.
7 We didn't have the manpower to operate;this. LIn, I l
8 the meantime we received a' couple.of fire' calls that we had. .
1 9 to respond to, which we left: the'. center . empty. l i
10 Q Oh, I see, 11 This was prior to 1632,. also? ,
12 A- (Van Gelder) That's' correct.'
13 0 So that sometime prior to.the completion.of set up
- 14. all the firefighters had-to leave on various fire calls?.I -
15 A (Van Gelder) That's correct.
16 All the Salem firefighters; all except for three lj 17 that remained at the center because that'wasn't -- they 1 18 weren't on the running cards as a~ response to.the incident. ,
19 O Are you referring to the Henry Street fire when 20 you say, all but three firefighters had to; leave?
I 21 A (Van Gelder) Henry Street would be one of them; 22 yes. 'l
~ l 23 Q But there were other fires that called people away 24 before the setup of the center was complete?
25 A (Van Gelder) That's correct.
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BRETON, VAN GELDER - CROSS 25558 1 Would you like me to explain the way the system-2 works, then it will give you an idea why the firefighters 3 were called away?
4 Q That would be fine; yes.
i 5 Go ahead.
l 6 A (Van Gelder) In Salem we have three stations. ,
7 Main Street divides the town. Anything north of Main Street 8 would involved Station 2 and Central's apparatus.
9 Anything south of Main Street would involve i
10 Station 3, the South end Station and the main station.
l
! 11 Henry Street is in the north Salem part of town, 12 so we had the north Salem response plus central. The three 13 men left at the facility was the south Salem's crew.
14 If, in fact, this call was in south Salem there 15 wouldn't have been anybody left from the Salem Fire 16- Department at the scene.
17 Q I see.
18 So that was the reason for your response, if a 19 call for the south end of town --
20 A (Van Gelder) That's correct.
21 0 -- all the firefighters would have left? "
l 22 A (Van Gelder) If, in fact, it was a working fire, 23 that would have pulled the rest of the firefighters out of 24 the evacuation center and had them respond to the fire.
25 Q I see.
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BRETON, VAN GELDER'- CROSS 25559
,-~g 1 Going back to your response to question 28,.the' j s- 2 last sentence of your response 1you say: "A lot of buses 3 that showed up later in the day were just turned around and 4 sent back."
5 A- (Van Gelder) That's correct.-
6 Q What was your understanding of the reason why that- i 7 occurred?-
8 A (Van Gelder) . Why that occurred was, at 6:00 p.m.
9 at night we had change of. shifts. ,At 6 o' clock the night 10 crew came on and the. buses were waiting outside. By the 11 time we had the new shifts in' place and they were told what )
12 they were supposed to be doing, by the time that' process i 13 took place they felt that it would have been taking too 14 long, so they just-sent everybody home.
15 Q I see.
16 Were you aware that the exercise was terminated at 17 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />? )
i 18 A (Van Gelder) Yes, I am.
19 That decision was made when all firefighters had 20 to leave the scene at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> and swapping crews. j 21 I 22
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BRETON, VM3 GELDER - CROSS 25560 1 Q Can you tell us approximately how many 2 firefighters would be available from the other six towns 3 involved in their mutual aid agreements?
4 A (Van Gelder) I couldn't give you an exact count.
5 I did some research at the time to find out who would be 6 responding from the surrounding communities. And we're ,
l 7 right on the Mass border, and our normal mutual aid 8 companies would be coming from the southern part of New 9 Hampshire. And in Mass, it would be Methuen and Lawrence.
10 They will not respond to anything that has to do with the i
11 Seabrook incident.
=
12 The towns that are north of us are mostly call 13 departments.
14 Q Excuse me. J 15 They are mostly?
16 A (Van Gelder) Call department, volunteer.
17 Q Oh.
18 A (Van Gelder) And there is no way of telling how j 19 many you would get. )
1 20 JUDGE SMITH: Do the Mass departments respond in '
21 the event of a fire? -
22 THE WITNESS: (Van Gelder) Yes, they will.
23 After checking with the locals down in Mass, they 24 have been told they won't respond to any evacuation plans in 25 Seabrook. This came from the union officials in Meth'.en.
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1 BY MS. CHAN:
2 Q And in case of a fire, how many.could you count on 3 from Massachusetts if you needed additional help?
4 A (Van Gelder) Unlimited.
5 0 Unlimited?
, 6 A (Van Gelder) Yes, we can keep on calling all the 7 way to Boston.
8 To finish the statement about the towns north of 9 us, well, Windham has two permanent men on duty. We may 10 receive - you know, they would send a vehicle over.
f 11 Beyond that, you couldn't'have a guarantee on how 12 many people you are going to receive.
! 13 0 On page 7 of your testimony,' Answer 22, you were .)
t 14 presented with some information from the final FEMA exercise 15 report?
16 A (Van Gelder) That's correct..
17 O And your response was, "I do not feel it 18 accurately reflects what went on."
19 Was your opinion on the effectiveness of the 20 exercise related to the shortage of firefighting personnel 21 available to do the things that you understood were assigned 1
22 to be done?
l 23 A (Van Gelder) Well, as far as the firefighter l
24 personnel, there were only 15 of us that aren't going to be l 1
3 25 there during -- we have an agreement with the town that we i
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BRETON, VJde GELDER - CROSS 25562 1 don't have to respond until we receive further training and 2 make an agreement with Seabrook on this.
3 Right now the firefighters feel that the way they 4 came into town and started giving us our training, we asked 5 a bunch of questions to the people that were giving us our -
6 training, and asked where they were from. We asked is this .
7 directly related to Seabrook.
I B The general consensus is we were lied to by the l
l 9 trainers that came in and trained us during this process.
10 They were there under the pretence that it was going to be a 11 harardous material exercise not directly related to 12 Seabrook.
13 The training was inadequate for what they were g 14 expecting us to do at the scene. And as of right now, if '
l 15 there is an incident that takes place, we are under no 16 obligation as the Brotherhood of Salem Firefighters to i
17 respond to that high school and do any kind of
)
l 18 decontamination whatsoever. l 19 0 Is this based on --
l 20 A (Van Gelder) This is based on a memorandum of
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21 agreement that's between the Brotherhood of Salem 22 Firefighters and management.
23 MS. CHAN: I have no further questions at this 24 time. Thank you.
25 Heritage Reporting Corporation 4 (202) 628-4888
25563 f3 1 EXAMINATION BY JUDGE COLE j Ns- 2 JUDGE COLE: Gentlemen, on page 3 of your i
3 testimony, Question and Answer 7, you were asked, "How many !
4 Salem firefighters actually participated in the June 1988 5 graded exercise?"
l 6 And you stated, "A total of 15 Salem i 7 firefighters."
8 And you further state that they were all on-duty 9 firefighters and no off-duty firefighters responded.
x 10 Were the off-duty firefighters contacted?
11 THE WITNESS: (Van Gelder) Yes, Your Honor.
12 JUDGE COLE: Did they refuse to participate?
13 THE WITNESS: (Van Gelder) Your Honor, to my 14 knowledge, it was dispatch who called every on-duty 15 firefighter. Also, what we call a box was sent, which is a 26 tone that's put out over the radios. Most of the 17 firefighters have pagers, and a tone would go off, and the 18 announcement would be made.
19 I don't know -- I didn't speak to the dispatcher 20 about it. I don't know if there were actual refusals to 21 come in or if they were just, gee, I have other things to do 1
1 22 type thing. Nobody responded. 4 l -
23 (Witnesses confer. ) l i
24 THE WITNESS: (Breton) Did anybody show up? j i
25 THE WITNESS: (Van Gelder) Nobody responded. !
[
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25564 1 JUDGE COLE: Did they know what the nature of the 2 request was?
3 Did they know it was a Seabrook drill?
4 THE WITNESS: (Van Gelder) Yes, they did.
5 JUDGE COLE: All right, thank you.
6 THE WITNESS: (Van Gelder) They were also paying ,
7 firefighters time and half to come in off duty to respond, 8 and they still received absolutely nobody.
9 They knew this drill was coming down a few days 10 ahead of time, and the firefighters discussed it. And even 11 at time and a half, they wouldn't show up for these things.
12 JUDGE COLE: All right. Thank you.
13 Captain Breton, in answer to Question 16, 14 indicating that in your opinion there wasn't enough manpower 15 to do the task that was assigned to you, you said you did 16' the best with the 15 people you had.
17 Now, there were 30 firefighters,.is that correct?
18 Fifteen from your group and 15 from outside; is that 19 correct?
20 THE WITNESS: (Breton) No, Your Honor. We didn't 21 have -- -
22 (Witnesses confer.)
i 23 THE WITNESS: (Breton) Your Honor, when I was '
24 there, I didn't have the other 15 people yet. I left early 25 from the exercise. 1 Heritage Reporting Corporation (202) 628-4888
)
i 25565
- 7. 1 When I arrived for the first ' I'd say one hour, I'
( 2 was there with 15 people, just my own crew. ]
l 3 JUDGE COLE: They were all-your people? 'j 4 THE WITNESS: (Breton) They were all my' people, 5 yes.
6 JUDGE COLE: . You don't know when the other 15-7 arrived?
8 THE WITNESS: '(Breton) They started'to arrive ---
9 JUDGE COLE: The mutual aid firefighters.
10 THE WITNESS: (Breton) Yes, Your Honor.
11 JUDGE COLE: That's the bottom of page 3.
12 THE WITNESS: (Breton) We got an indication that I
13 they were on their way at about one. . For instance, there is j f- 14 a log report here from 1323. A telephone call to our q
'l 15 dispatch stated that the East Derry -- all right, East Derry )
l 16 advised men were on the way.
f 17 We could probably go through this log and 18 determine when they arrived at the scene. And'what some of 19 them did was respond to our fire department, fire station, 20 and then they were taken to the high school. ;
21 JUDGE COLE: All right.
l 22 So had they arrived in a more timely fashion, they l
l 23 would have been assigned to you?
24 THE WITNESS: (Breton) Yes, I believe so,. sir.
I 25 THE WITNESS: (Van Gelder) Yes. j
[ Heritage Reporting Corporation (202) 628-4888 u- _ _ _ _ _ _ _ _ _ _ _ _ _ _
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1 25566 i i
i 1 THE WITNESS: (Breton) May I say something, Your !
2 Honor? O l j
I 3 JUDGE COLE: Certainly. j l
4 THE WITNESS: (Breton) One ci che things is, with 1 5 15 people that we have on the normal response, our day shift 6 or night shift, whatever, our particular shift, there is ,
7 just not enough people to set these stations up and set 8 these people into the required locations. -
9 So until we get help, okay, it's very difficult to ,
10 set these stations up. It's also difficult to assign the 1
l 11 people to the monitoring stations. ]
1 12 The other thing is, if we're not involved with the l l l 13 out-of-town companies, mutual aid companies, in a situation 1 i
14 like this, it's the same thing at a fire scene. l 15 You can't expect the mutual aid companies 16 to -- they have to come and get the specific orders from 17 you, okay, at a fire scene or what have you, to be able to 18 know exactly what to do. Because, you know, you are all 19 part of a team.
20 Our 15 men day shift kind of works as a team. We 21 know what's expected of one another, that type of thing. .
22 And you get into these philosophy type things, all of a 23 sudden you have people from another community coming in, and 24 they might do things a little bit different. You don't know 25 their level of training or whatever as far as the particular Heritage Reporting Corporation (202) 628-4888 1
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J25567 f-s 1 incidant you are s:orking with. And you have to kind of take i
k 2 it from there. So you don't know what to expect.from these 3 people.
4 So as these out-of-town people are coming into the 5 reception center, we don't know what level they are, what 6 they understand they are supposed to do.
7 So now if I'm responsible for setting these things 8 up and I don't know what they are capable of, it's just 9 going to take that much longer because you.have to explain 10 it to them and, you know. It's difficult to explain because 11 I have to know where this person is at to'be able to assign 12 him to a particular function; you know, what'he knows.
13 JUDGE COLE: I think I understand you.
14 THE WITNESS: (Van Gelder) May I say something?
O( 15 JUDGE COLE: Sure.
16 THE WITNESS: (Van Gelder) After contacting'a 17 couple of the individuals in the Pelham and Windham Fire 18 Departments, they had received no training whatsoever in 19 radiological decontamination.
20 So these are individuals who were' responding to l -
21 our town that had no idea what was even going on. And for l
22 the Captain to have them perform a service or a duty, 23 basically he would have to train them at the time that they 24 are there.
25 JUDGE COLE: Okay.
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25568 1 Now on page 6 of the testimony again, Captain 2 Breton, you said there seemed to be confusion among the 3 people who were supposed to be in charge.
4 Do you know who was supposed to be in charge?
5 THE WITNESS: (Breton) Well, I was in charge of 6 my personnel, and I was confused. So that's one person. ,
7 The other people, no, I really didn't know who was
~
8 supposed to be in charge of the incident itself, or who was 9 supposed to be in charge at the high school.
10 JJDGE COLE: Well, I'm looking now back on page 3, 11 what your understanding of the functions that the Salem 12 firefighters are supposed to perform. And there you 13 indicate that you are responsible for setting up and i ,
14 operating a reception and decontamination center.
15 I assume that was your understanding of what your l 16 job was?
17 THE WITNESS: (Breton) Yes, but I guess -- see, I I
18 know that there are other people that I have to answer to. '
19 All we are is a small part of that operation. We have s
20 nothing to do with any of the paper work or anything that I i l 21 know of. !
22 It was more task oriented. Take the boxes out of
. i l 23 the truck, set the boxes up. And what we did this day was 24 set them up in the lobby of the library of the high school, l
l 25 and start setting up the stations where we had been l
Heritage Reporting Corporation (202) 628-4888
25569-1 previously taught to set.the stations up.
t 2 We have a drawing of the high school, .and,-you 3 know, this is where this particular station'is-going to be, 4 this is where this one is, and just started' distributing the 5 equipment to those stations. And then we have to assignLour
. 6 personnel-to those stations to be able to carry.out the" 7 monitoring.
~
8 I wasn't there for that part of it this particular 9 day. I had been there for a nongraded exercise where we did-10 it and went through all the procedures and stuff like that 11 and started distributing the personnel to,these particular-12 areas.
13 There are people who go around to the:different 14 areas and check to make sure things are going all right.' If 15 we need anything, we're supposed to be -- I guess one of the 16 problem in this chain of command thing, that's one of the ,
l 17 things that's bothering me and has bothered me through this 18 whole things. j 19 We don't have a bottom line, okay. I don't know 20 specifically where to go to get'my. answer when I have a !
t 21 question, because this is all too unfamiliar to me. I have j i
22 to have somebody to go to be able to get the information 23 that I need to carry out when I have a problem.
24 JUDGE COLE: Well, one problem you indicated 25 earlier was how the trucks were loaded, and you had l
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25570 1 indicated that in the past you had made a request that these 2 be loaded in a certain way just to make it more convenient 3 for unloading.
4 THE WITNESS: (Breton) Yes.
5 JUDGE COLE: Do you have any idea why that request 6 was not followed up on? -
7 THE WITNESS: (Breton) No, I don't, Your Honor.
8 JUDGE COLE: Do you know where the trucks came 9 from, where the equipment was initially?
10 THE WITNESS: (Breton) We had had most of the 11 equipment stored probably -- excuse me.
12 (Witnesses confer.)
13 THE WITNESS: (Breton) We had had a nongraded 14 drill and we had this truck stored in the back of our fire !
z 15 station.
16 After the nongraded drill, we had had a couple of 17 them, and the first time we had the truck -- I'm trying to l 1
18 think -- the truck was sent back, they repacked it, and we 19 had complained about how the truck was packed.
20 JUDGB COLE: Who repacked it?
21 THE WITNESS: (Breton) As far as I know, 22 personnel from Seabrook.
23 JUDGE COLE: Okay.
24 THE WITNESS: (Breton) You know, I don't if it's 25 Seabrook people. Whoever is responsible for taking care of Heritage Reporting Corporation (202) 628-4888
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'25571
/~' 1 the equipment and all the stuff that'we have'to distribute 2 at a reception center.
3 The truck was sent back.to'us and it was-parked'in-4 back of our station.
5 Then we had one other'nongraded' drill, and we had 6 more problems with the equipment. And there was a' lot of 7 complaints about the equipment and how it was stored and 8 everything else in the truck.
9 In other words, we still had the same problem.we-10 had prior.
11 The truck was then taken away, and --
12 (Witnesses confer.)
13 THE WITNESS: (Breton) And then it was brought to 14 the -- I can't remember if it was brought to the back of the 15 station or it was driven by somebody else or other people to 16' the site of the graded exercise.
17 Right now all that equipment is stored in Salem in 18 what we call Hose House 2, which'is a building, a town-owned 1
19 building. And right now that equipment is stored'in'that 20 building.
l 21 22 23 1 24 1
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l 1 JUDGE COLE: So in another exercise or emergency, 1 l
1 2 how would that equipment be transported? How would it be 1 3 loaded and transported? Would that be your responsibility, 4 'your group?
5 THE WITNESS: (Breton) No. Nobody had ever j 6 mentioned anything to us about transportation. .
7 The last I knew there was supposed to be a truck 8 parked in the back of the fire station, and this truck is a 9 vehicle that had all the equipment that we needed to open l 10 and maintain the reception center decontamination center.
1 11 But I haven't seen that truck or the equipment since the i
l 12 graded drill.
l l
13 JUDGE COLE: This concern you had or request you 14 made about how the truck was to be loaded for convenience 15 and unpacking, did you articulate your request in writing or 16 was it verbally?
1 17 THE WITNESS: (Breton) We verbally -- what we l 18 would do is critique the situation. After the nongraded 19 and everything, we critique these, bring our request and let 20 our fire chief know about the problems we had had. And he l .
21 had assured -- excuse me, please.
22 (Witnesses conferring.)
23 THE WITNESS: (Breton) Excuse me, Your Honor.
24 I lost my train. I forgot what you had asked me.
25 JUDGE COLE: Well, about the coordination of the l
l Heritage Reporting Corporation (202) 628-4888
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-1 l
25573 i
r~% 1 packing and unpacking of the truck, why it wasn't followed i V 2 through on?. .
1 3- THE WITNESS: (Breton) Okay.
4 Then what we did was, we brought our request to 5 the chief because he was present.at the critique. We let l
. 6 him know what problems we had. And then, to my knowledge, !
7 he assured us that he had transmitted this information~to 8 the proper people. I 9 Mr._' Van Gelder came up with something. fairly 1
10 interesting. )
11 THE WITNESS: (Van Gelder) On the nongraded 12 exercise, the one that happened a month before the graded 13 exercise, the people from Seabrook were unloading the truck-(j)
/ 14 15 and they made the statement that there is a certain way this truck is supposed to be packed. There are certain things' 16 that take longer to set up in other areas.
17 And when they had packed the truck originally they 18 had packed it totally opposite the way it was supposed to be 19 packed. So everything.was supposed-to be taken out of the J 20 truck for the graded exercise and repacked just totally
~
21 opposite of the way it was in the truck for the nongraded-22 exercise. '
23 And what they found when they were teVdng 24 everything off was certain things like boxes -- all box 25 number 6s are supposed to be in a certain area; all box l
g Heritage Reporting Corporation ,
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BRETON, VAN GELDER - REDIRECT 25574 1 number 5s are supposed to be in a certain area and they were 2 mixed up. They might have a box 5, box 1, box 3; so it was 3 total confusion trying to separate everything, where they 4 were supposed to be at that point.
5 JUDGE COLE: Okay.
6 I think that's all I have.
7 Thank you.
8 JUDGE SMITH: Do you have redirect?
9 MS. DOUGHTY: I have one little area, Your Honor.
10 REDIRECT EXAMINATION 11 BY MS. DOUGHTY:
12 O In response to a question from Ms. Chan you i
13 st ated., Captain Breton, that the training was inadequate. ,
i 14 How were you able to observe that at the exercise?
15 A (Breton) Observe the training --
16 MR. DIGNAN: Objection.
17 The Board has ruled training is not part of the i 18 contention.
19 MS. DOUGHTY: Okay.
20 I would just note that Ms. Chan opened the area.
~
21 MR. DIGNAN: Ms. Chan may have opened the area, 22 but probably we should have objected then, too.
23 MR. COOK: Well, Applicants did object at that 24 point. That objection -- Ms. Chan's question was related to 25 general experience and training; not training provided by Heritage Reporting Corporation (202) 628-4888 1
BRETON, VAN GELDER - REDIRECT 25575 r 's 1 New Hampshire Yankee specific to the exercise.
\> 2 JUDGE SMITH: What was the question?
3 MS. DOUGHTY: I believe it was about question 16 4 and what he meant by: "Our scope was extremely limited."
5 And it was a follow-on question.
. 6 She was asking about the bottom line in question 7 16: "In essence, we just don't have the manpower to pull'it 8 off."
9 And she said: "Was it just manpower that was the 10 problem?"
11 And he also mentioned --
12 JUDGE SMITH: Well, he seems bound and determined 13 to get this training aspect in. And we understand that is
(~'} 14 important in your mind, and indeed, may very well be 15 important. But as a matter of law in this case we cannot 16 take that into account because of different technical 17 aspects of the case. And so that is why we are excluding 18 testimony concerning training.
19 THE W1=TNESS: (Breton) I understand, Your Honor.
20 JUDGE SMITH: We certainly understand why you 21 believe it's relevant and important. And indeed, it could 22 very well be. But it just simply was not raised correctly 23 as an issue in a judicial proceeding such as this.
24 THE WITNESS: (Breton) Thank you.
25 JUDGE SMITH: We're not going to go into it
,/3 Heritage Reporting Corporation (N--) (202) 628-4888 l
BRETON, VAN GELDER - REDIRECT 25576 1 despite Ms. Chan's -- I mean, it's not in the contention, so ,
2 even if you get the answer it's not going to do you any ;
3 good. It simply is not in the contention.
4 BY MS. DOUGHTY:
5 Q Captain Breton, in response to a' question from 6 Judge Cole you mentioned that you were not Eble to ascertain -
7 who is in charge or how things were to be set up. And this 8 is even after you have looked at the plan, the plan has not 9 made that clear to you? l I
10 A (Breton) No, the plan isn't that clear and we j 11 don't go over it constantly.
12 I guess you have to know the players. When we're 13 working with procedures we know all the players, and to all 14 of a sudden be put into an unfamiliar area we don't know any 15 of the players. )
16 So if the plan says that so and so from or that l 17 this particular title is supposed to be in charge of the i
18 operation or certain portions of it, we don't know where to 19 find them or who they are, that type of thing. It's l 20 confusing.
I
~
21 And I'm not saying that the whole plan is terrible 22 and everything else. I'm just saying there are parto to
- \
23 that plan that are just very confusing for the people who 24 are trying to work with it.
25 O So improvements could be made?
i Heritage Reporting Corporation (202) 628-4888 1
-BRETON, VAN GELDER - RECROSS 25577
('~ -1 A (Breton)' Oh,-definitely. Definitely.
l 2 O Okay.
3 MS. DOUGHTY: That's.all, Your Honor.-
l
' JUDGE SMITH: Any further questions.-
4 5 RECROSS-EXAMINATION-
. 6 BY MR. DIGNAN:
7 Q The plan.you're talking about is the New' Hampshire 8 Radiological Emergency Response' Plan?
9 A (Breton) Yes, sir.
10 0 Thank_you.
11 MR. COOK: Could we consult?
12 (Counsel conferring.)
13 MR. COOK: Applicants rest, Your Honor.
14 JUDGE SMITH: All right.
15 MR. FIERCE: Your-Honor, I would have one follow-16- up question on behalf of the Commonwealth.
17 JUDGE SMITH: All right.
18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 l
PRETON, VAN GELDER - REDIRECT 25578 1 REDIRECT EXAMINATION 2 11 MR. FIERCE:
3 Q With respect to the towns in Massachusetts who 4 'might normally be a mutual aid response community for Salem, 5 which towns did you mention or did you mention the towns' 6 names? I thought I heard a couple. .
7 A (Breton) That I was in contact with?
~
8 Q Yes.
9 A (Breton) Methuen and Lawrence.
10 Q Do you know whether those towns also have Mutual 11 Aid Agreements with Massachusetts towns in the EPZ such as:
12 Salisbury; Newburyport; Amesbury, and might be responding in 13 a nuclear emergency to assist in those communities?
14 A (Breton) Can I answer that in a kind of 15 roundabout way.
16 In situations concerning -- I have to address, I 17 think people have the wrong idea about mutual aid. First of 18 all, yes, there are Mutual Aid Agreements that are written 19 agreements and that type of thing. To my knowledge, we have 20 no written Mutual Aid Agreements.
21 It's just like a short time ago Lowell, 22 Massachusetts had a very large fire and they enlisted 23 equipment and manpower from all over the place. I'm sure 24 those towns are in a written Mutual Aid Agreement.
25 However, when we get a telephone call for help to Heritage Reporting Corporation (202) 628-4888
BRETON, VAN. GELDER -' REDIRECT 25579 1 a fire scene, we respond. I mean, we've. responded to Lowell
~
2 before; wo have responded all.over the place. And it's the 3 same thing with other towns. You don't necessarily have to 4 be in'an agreement, but'if you. call'to enlist their help 5 they will send apparatus. We have never gotten turned down.
6 And this-type.of~a thing where this. equipment just 7 responds, our dispatch.has a list of towns and cities that 8 we normally use and it's kind.of a domino effect.
9 What everybody has to realize is that because of 10 this domino effect, when you call.and enlist a town for 11 help, okey, let's say we're having a large fire over.here.
12 It's kind of like the spokes of the wheel. If you enlist 13 town help out here, that affects their ability to take care 14 of their own situations. So they may have to enlist 15 somebody's help out here.
16 And depending on the size of the emergency and how 17 critical it is, how many people are involved, how.large the 18 fire is, if it's a. mass casualty incident or what not, 19 that's going to determine how far that mutual aid affects --
20 the call for that mutual aid affects -- the area that it 21 affects.
22 What's real important to know is that, somebody 23 had brought up the fact that we had left the scene of the t
l 24 reception center to go to a fire call, but there were mutual 25 aid people who were still there.
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BRETON, VAN GELDER - REDIRECT 25580 1 Had we had a larger fire or had they had to 2 respond to a fire in their own town, things may have been 3 different. If we had a larger fire, we would have had to 4 enlist their help and their equipment to come over to our 1
5 fire.
6 I was informed that they didn't bring equipment - I 7 with them. In fact, they didn't; they came in their own l l
8 cars from out-of-town, which may have affected -- if that's 1 9 the case it may have affected what equipment could be !
l 10 brought to us for our particular fire. l l
11 What everybody has to realize is, because if l
12 Seabrook has an incident and we're required to open up our 13 decontamination center, the Seabrook incident to us is not a j 14 major incident. We're not seeing what's happening in 15 Seabrook. We're getting the people out of Seabrook.
16 They're evacuating and they're brought into our town. We 17 still have to maintain and take care of our people, our 18 residents. We still have fire protection to maintain, EMS 19 rescue, all those things that we do every day.
20 JUDGE SMITH: Captain, I think you're going a 21 little bit beyond Mr. Fierce's question now.
22 His question: the domino effect I think did intend ,
23 to answer his question. I wish you would return to the 24 subject matter.
25 Heritage Reporting Corporation (202) 628-4888 3 I
BRETON, VAN. GELDER - REDIRECT L255el ]
< N 1 BY MR. FIERCE:
s 2 Q Well, the focus of my question would be, if you l 3 contacted a mutual aid. community in Massachusetts, say 4 Lawrence, and they had already been called by. Salisbury, you j j
5 wouldn't be expecting them to come across the state line and~ 1
. 6 help you in Salem first, would you?
7 A (Breton) No, not if Salisbury.had their manpower.
~
8 I mean, I can't' answer that because I don't know-9 how --
10 JUDGE SMITH: The idea'he is getting across, 11 Captain, is: assuming that the Massachusetts Fire 12 Departments would respond in a radiological emergency, a
13 although you said that they would not, but assuming that- J
/~N 14 they would, wouldn't it be the fact that if the other towns U 15 in the EPZ in Massachusetts had already requested mutual' aid 16 from these towns, it would not be available to you? .
l 17 I think that's the idea, isn't'it? l 18 THE WITNESS: (Breton) And that is correct. )
19 MR. FIERCE: .Thank you. I 20 JUDGE. SMITH: Anything further?
21 (No response) 22 JUDGE SMITH: All right.
23 Thank you very much for coming. You're excused. ;
i 24 (The witnesses were excused.)
25 i Heritage Reporting Corporation k (202) 628-4888
25582 1 JUDGE SMITH: Let's let the Panel go on. ,
1 2 Whereupon, 3 JOSEPH BISSON 4 ANTHONY M. CALLENDRELLO 5 ROBERT CO2TER 6 PETER LITTLE1TELD -
7 having been previously duly sworn, were recalled as B witnesses herein and were examined and testified further as 9 follows:
10 MR. DIGNAN: Your Honor, it's a matter of 11 scheduling. I had wanted to await the conclusion of that 12 cross-examination that just took place.
13 The Applicants will not be offering Applicants I 14 Rebuttal No. 25.
15 MR. FIERCE: At all?
16 MR. DIGNAN: At all.
17 Which, as I understand it, means that with the 18 conclusion of the cross-examination of the present Panel, 19 the next witness in order would be Dr. Cohn, Mr. Cohn.
20 MS. GREER: Just for clarification.
21 on the previous schedule as of last week anyway, i
1 22 there was still a bite in there after SAPL firefighters for
- l 23 telephone communications. I got a message that you are not 24 planning to put that on after SAPL firefighters.
25 Are you planning to put that on or are you going E
l Heritage Reporting Corporation (202) 628-4888
. 1 25583 i
i
-/'~N 1 to withdraw that? d i
2 MR. DIGNAN: Applicants' 25 was scheduled next, 3 and that's not being put on.
4 MS. GREER: Okay.
5 My. question really goes to the telephone
- 6 communication panel. Have you made.any decision on that?
- 7. MR. DIGNAN: .That.was a.long time ago.
8 Which number was that?.
9 (Counsel confer.)
10 Yes, that was pulled a long time ago.
11 MS. GREER: All right.
12 So you have pulled that?
13 MR. DIGNAN: Yes.
14 MS. GREER: Okay.
15 MR. DIGNAN: The present schedule that Mr.
16' Traficonte handed out yesterday has this panel's completion.
17 Then what was anticipated was our No. 25, and that's been 18 pulled. And then what's next-is Mr. Cohn.
19 MS. GREER: Okay.
20 Just for the record, Mr. Cohn -- we have booked 21 him to go off first thing on Friday morning. He is flying
- 22 up and will not essentially be available until Friday 1 23 morning. And so I thought I should apprise the Board of 24 that, and we did -- q i
25 MR. DIGNAN: Well, Mr. Fierce has already said l
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1 he's got a day and half with 17.
2 MS. GREER: Fine.
3 MR. DIGNAN: So you are not going to --
4 MS. GREER: I just wanted to confirm that l l
5 that's -- !
6 MR. FIERCE: I did say that I would finish some . ,
7 time during the day tomorrow would be my expectation. And 8 so we may have some free time there.
l 9 MR. TROUT: We still have two motions in limine we !
10 could argue tomorrow afternoon if we need to fill time:
11 Adler and Carter.
12 JUDGE SMITH: Well, it's never happened yet.
13 (laughter.)
14 MR. FIERCE: As long as we are on the scheduling 15 issues, I wonder if we could quickly follow it through to l
16 next week, because I'm still a little bit unclear how we 17 want to handle the various ETE returning commuter witnesses.
18 We have Dr. Adler, +here is the Lieberman Panel 19 and Dr. Urbanik. And I know there was some discussion about 20 Dr. Urbanik and his schedule.
~
21 We also have Dr. Harris, who will go off first l
22 thing Monday afternoon, but that Applicants' Panel No. 20 23 will be held in abeyance for some later date after the ETEs.
24 Is that the understanding?
25 MR. DIGNAN: What we said is that we will -- the
{ Heritage Reporting Corporation (202) 628-4888 4
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E il REBUTTAL PANEL NO. 17 - CROSS- 25585 m 1- difficulty, as.I understood it, of next week, and
( . . . ..
2 unfortunately Mr. Turk.is not here, was his' desire that 3 Urbanik get on'and off next. week.
4 And I said to accommodate everybody, if Harris 5 goes Mondsy, and I would be glad to push my Panel?No.L20
. 6 behind the balance of the ETE witnesses if that conveniences 7 people. We can go either way. There is no problem.
~
8 MR. FIERCE: Well, I think that would convenience 9 people.
10 And then the next question I have is the next --
11 JUDGE SMITH: This doesn't have to be on the 12 record.
13 MR. FIERCE: No, it doesn't. It doesn't.
14 (Discussion off the record.)
15 MR. FIERCE: May I proceed, Your Honor? '
16 JUDGE SMITH: Yes, please.
17 CROSS-EXAMINATION (Continued) 18 BY MR. FIERCE:
19 Q Good morning, Panel.
20 Panel, I wanted to go back and clarify a matter 21 that I had raised with you yesterday about, in response to I I
22 the adding of four more monitoring stations at'each 23 reception center, were there going to be any additional J
24 changes in personnel elsewhere. And we talked about that 25 some.
)
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REBUTTAL PANEL NO. 17 - CROSS 25586 1
1 I wanted to clarify in the reception center 2 building themselves. There may have been some confusion.
3 Inside that building will there be any increases 4 in the planned number of personnel as a result of that 5 increase or for any other reason?
6 MR. TROUT: Objection. .
7 MR. FIERCE: Basis?
8 MR. TROUT: The basis for the objection is that l
9 that has no relevance to any issue that's ever been raised, 10 even the late-filed issue that Mass AG raised and was J l
11 rejected by the Board.
12 MR. FIERCE: Well, it certainly has relevance to 13 that,,Your Honor.
14 In Supplemental Testimony No. 17, two members of 15 that Panel referred to a study that had been done of the ;
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16 facility's stay-time. And the facility's stay-time is the 17 time that it would take to process people through the entire !
18 facility, including the reception center.
19 And the staffing in the reception center would, in l 20 our view, be a relevant issue to facility stay-time l
questions, depending on whether they have added extra people l 21 l
22 or haven't in that reception center to process people 23 through the registration lines, the rendezvous coordinator, 24 the message center, the number of functiona that are 25 performed in there. And it's clearly a relevant question to Heritage Reporting Corporation (202) 628-4888
REBUTTAL' PANEL NO. 17.- CROSS' -25587 1 that issue of facility stay-time.
s_/ 2 MR. TROUT: Your Honor, I'm just wondering'whether 3 we are now -- I mean the contention was monitoring rate.
4- And now Mass AG seems to;be arguing that we are going to 5 litigate every activity of every nature in~every. detail that
. 6 occurs anywhere in the reception center process.
7 MR. FIERCE: Your Honor,' I'm . also - a little bit 8 puzzled --
9 JUDGE SMITH: We're conferring.
10 MR. FIERCE: Okay.
11 (The Board confers.)
12 JUDGE SMITH: The question would relate to the 13 turnover time in the parking lot.
' 14 MR. FIERCE: That's right.
15 JUDGE SMITH: And parking availability, which you 16 have decided to pursue.
17 For that reason, it's relevant and the objection 18 is overruled.
19 THE WITNESS: (Callendrello) No, we have not 20 added any personnel inside the reception center.
21 BY MR. FIERCE:
22 Q Has there been any. intention to redesign the
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i l 23 assignment of the people that you have assigned to the-24 reception center then?
25 A (Callendrello) Yes, there has. j
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REBUTTAL PANEL NO. 17 - CROSS 25588 1 Q And what is that?
2 A (Callendrello) One of the functions assigned, and 3 I'm referring to Attachment 2 of IP-3.5, the personnel that 4 are presently indicated as being clean tag issuants are 5 actually the individuals who will be doing the monitoring 6 trailer registration. We discussed that yesterday. -
7 And we have combined the functions of evacuee 8 registration and school and special population registration- .
9 So we, in essence, have five people performing 10 registration.
11 I'm sorry. It's the -- the combination was 12 congregate care referral and evacuee registration, to come 13 up with a total of five people who would be performing
, 14 registration functions for evacuees.
15 0 You are going to combine that function.
16 A (Callendrello) Congregate care referral and 17 evacuee registration.
18 Q Does that mean you will also be changing the 19 layout of the reception center so that those function tables 20 will be next to each other?
21 They may be next to each other in the Beverly 22 center already, or nearby. But I see that in the other .
23 center they were around the corner. ,
l 24 A . (Callendrello) I'm sorry. Which / 1agram are you 25 on?
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' REBUTTAL PANEL NO. CROSS 25589
(~'g 1 0 I believe it's'in Implementing Procedure 3.5, s- 2 Attachment 5, I believe, is the layout for the North Andover 3 center.
4 A (Callendrello) That's correct.
5 Q And I see three evacuation registration tables,
. 6 and then around the corner I see the congregate referral 7 table.
8 A (Callendrello) Correct.
9 0 Are you going to be. revising the layout as well?
10 A (Callendrello) I don't know.
11 I assume we will have to revise the layout.
12 A (Cotter) If I could maybe add to the answer.
13 The actual congregate care referral,,the reason 14 that we can just take the congregate care referral and add 15 it into the registration process is that is nothing more' 16' than getting the name of the congregate care centers that 17 will be available for referral.
18 That means the reception center coordinator up at '
19 the EOC will be in contact with the American Red Cross to 20 identify those available congregate care centers.
21 Once that information is passed to the reception ;
i 22 center leader, he gives it to the appropriate personnel who ')
l 23 asked the question or posed the question, do you need some !
1 24 place to stay, do you need congregate care referral. And !
25 it's nothing more than identifying that reception center.
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REBUTTAL PANEL NO. 17 - CROSS 25590 1 So the elimination of that congregate care table 2 could almost -- could be done if the process of congregate 3 care referral r, witched over to the reception center people.
4 O So when the people come to register and sit down 5 at one of these registration tables and they will be dealing 6 with one of the registration staff. And that staff will .
7 both register and offer the congregate care referral.
l 8 Is that correct?
l 9 A (Cotter) Yes, that's correct.
10 Q So there won't be a reference from one person to 11 another person?
12 A (Cotter) That's correct.
13 0 Okay.
14 How many registrees, whatever the word would be, 15 how many people can a single registration worker handle i l
16 simultaneously doing that process that you have just
]
17 described? )
18 (Witnesses review document.)
19 A (Bisson) One registrar would be assisting between 20 two to six registration units.
21 Q Simultaneously?
l 22 A (Bisson) Correct.
l 23 O Answering questions about congregate care and 24 making referrals for these people.
25 A (Callendrello) That's correct.
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l REBUTTAL PANEL NO. 17 - CROSS 25591' )
'l 1 Q Where does the plan say that?.
2 A (Callendrello) The plan does not.- .It's in an 3! analysis that was provided along-with-the parking analysis.
4 It's titled." Evaluation of' Reception Center Staffing", dated 5 .May 31, 1989.
. 6 0 Which was a study, as I understand it, of the time-7 to fill out the registration cards,. correct?
~
8 A (Callendrello) .No. This is an analysis of the 9 staffing needs at the reception center.
10 0 And that was basedfon a study of the registration 11 function which involved only filling out the registration 12 card, correct?
13 A (Callendrello) It did refer'to reception center 14 time tests which was a separate memo.
15 I have to refer to it to see specifically what 16 activities were included in the test.
17 (Witnesses confer.)
18 A (Bisson) The test that you were' referring to was 19 strictly the test of filling out_tho left side of the.
i l 20 registration form.
21 Q Parts 1, 2'and 37 I
22 A (Bisson) Correct. The name and address of the 23 evacuees.
24 Q. That doesn't require any interaction with the 25 registration worker for the evacuee to do that, correct?
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REBUTTAL PANEL NO. 17 - CROSS 25592 1 A (Bisson) That's correct. Other than the 2 registrar handing the form and requesting them to fill out 3 that particular portion of the form.
4 O But a congregate care referral discussion requires 5 interaction between the evacuee and the registration worker, 6 correct? -
7 A (Bisson) Some interaction, correct.
8 Q People might want to know what's the congregate ,
9 care center like, where is it, do you have options for me, 50 do you have one over here rather than one over there because 11 I work over here.
12 It could be a series of questions, correct?
13 A (Bisson) Possibly. However, I believe that they
, 14 would be provided directions and the congregate care centers 15 are opened as they are needed, so they wouldn't have a true 16 choice for people to pick and choose from.
17 As the congregate care facilities are needed, it 18 would be opened. And as it's filled, they would just move l
19 onto another one.
20 0 But the point is there would need to be some 21 discussion and interaction with people about congregate care 22 centers and filling out Part 4 of the form, correct?
23 A (Bisson) That part is filled out by the 24 registrar. And essentially all the registrar would have to 25 do is just put the name of the congregate care center on Heritage Reporting Corporation (202) 628-4888
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.l i
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' REBUTTAL PANEL NO. 17.- CROSS 25593- l that form for the'ORO's records.
'l v .. . .
l 2 ;Q They also have:to put the - if;the person.is not-
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3 using congregate care, where it is that the. person'is going-H 4' to go to stay, with a friend or a relative perhaps.'-
5 (Witnesses confer.)-
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.. 6 7
8 9
10 11 12 13 14
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15 16 17 18 19 20 21 22 23 ,
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24 25 Heritage Reporting Corporation (202) 628-4888 l
i REBUTTAL PANEL NO. 17 - CROSS 25594 1 THE WITNESS: (Callendrello) That's correct.
2 Looking at Procedure 3.5, if somebody does not i 3 need temporary shelter they would complete part 4 of that 4 form.
5 BY MR. FIERCE:
6 Q The registration worker does that? -
7 A (Callendrello) No.
8 Q The evacuee?
9 A (Callendrello) The evacuee would do that. I 10 0 Well, gentlemen, your estimate of two to six was ,
l 11 based on a system where people were just filling out parts j 12 1, 2, and 3. But when you are now moving to part 4 and I 13 getting involved with congregate referral, realistically, 14 the number of people that each registration worker can i 15 handle is going to be less than six; isn't it? l 16 A (Callendrello) Not necessarily.
17 The tests have shown that it takes an average of i
18 81 seconds to fill out the form. We have assumed for the j 19 staffing needs that it will take two minutes; that will l 20 allow sufficient time for the additional sections of the 21 form to be filled out as well.
1 i I
22 The registrar can fill that out while other !
23 individuals, other evacuees are filling out parts 1, 2, and 24 3.
25 Q For purposes of your calculation on flow-through Heritage Reporting Corporation (202) 628-4888
REBDTTAL PANEL NO. 17 - CROSS 25595
~' time through the reception center, do you'have six people 1
\' 2 per evacuation worker. calculated in?
3 Each registration worker is processing 4 simultaneously six evacuees through that registration ' table -
5 and now through the congregate care referral process; is
- 6 that how you have done that calculation?'
7 A (Callendrello) No. The assumption is that it 8 will take, I think, it's five minutes.
9 Let me just check that.
10 The assumption is, it takes five minutes-for 11 registration. That's the assumption that's'--
12 Q I'm quoting this congregate care referral, and I'm 13 just asking you how that assumption'is arrived at now that 14 you've got five registration workers, and I have an image of 15 a table, as.Mr. Cetter describes, something like you've got i
16' here with six chairs in front of it for each -- five tables, 17 five workers and six chairs in front of it, and you're doing l 18 this process for 30 people simultaneously. ;
19 Is that what you're telling me?'
20 MR. TROUT: Mr. Fierce, aren't you confusing the 21 two registration tables?
l 22 I believe Mr. Cotter testified earlier about.
23 registration before they go into the trailers, not- I 24 registration within the reception centers.
25 MR. FIERCE: Perhaps, I may be confused on this.
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REBUTTAL PANEL NO. l'7 - CROSS 25596 j 1 BY IG. FIERCE:
2 Q Is the table any different, Mr. Cotter, that's 3 used for registration inside?
4 A (Cs11endre11o) There's some confusion.
5 If you look at the memo that is dated May 31st, !
l l 6 1989 entitled, " Evaluation of Reception Center Staffing," we -
7 looked at the registration two ways.
8 First of all we said, let's ecsume it takes five 9 minutes to register an individual because that will increase 10 the amount of an evacuee's stay time five minutes to 11 register at a registration unit. That will increase the 12 evacuee stay time, and therefore increase the amount of 13 parking that's needed; and therefore, it would be the
, 14 conservative analysis for the parking needs.
15 We ran the time tests, however, and found that the 16 form could be filled out, parts 1, 2, and 3 in a minute and 17 21 seconds. So we said, let's assume that it will take two 1
18 minutes to register an individual.
19 Looking at those two bounds, if you assume it 20 takes five minutes then you need 30 registration stations or 21 each registrar will be handling five registration units.
22 If you look at the two minute registration time, , f 23 which is again the shorter time, the time that we have 24 verified in the tests, you would need to monitor - you
! 25 would need to register 12 registration units at a time or Heritage Reporting Corporation (202) 628-4888 i.
-REBUTTAL PANEL NO. 17 - CROSS 25597
.jr~ 1 each registrar would be handling two or slightly more_than
- 2- two, some would handle more than two registration units at a 3 -single time.
4 So there's going to be some difference depending 5 on how long it takes. We_think,, based on the test, 1t can'
. 6 be-as short as two minutes. .But for the parkingnanalysis we 7 have assumed five minutes, which would put 30. registration 8 units at the table at'a single time.
9 The reason we'did that is because that's the 10 higher limit on -- the higher range or the-higher end of the 11 range on the parking demand.
12 Q Except that your two minute time is based on a 13 study of just filling out parts 1, _ 2, and'3?'
14 A (Callendrello) . It's' based on that.
15 As I said, parts 1, 2, and 3.were. filled out in a 16 minute and 21 seconds.
17 Q So you are telling me that your calculations are' 18 based on five registration workers, each sitting at a table 19 which has six chairs in front of it in which you could 20 process, you believe, six people at each table, a-total of 21 30 registration units, as you call them, simultaneously?
22 A (Callendrello) I'm telling you, the conservative 23 parking analysis assumed that each registration unit would 24 take five minutes. As a result of that, that would place 25 six registration units at each registrar at a given time.
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REBUTTAL PANEL NO. 17 - CROSS 25598 1 Q Well, it either would do that or if you didn't 2 have six chairs in front of each table because that was too 3 many to process at once and you only had three, you would 4 have some lines formed, wouldn't you?
5 A (Callendrello) The difficulty -- no, I can't l 6 accept that, because our tests have shown that it takes two .
I 7 minutes; therefore, there would be two registration units at 8 three of the registrars and three at two of them.
9 So it's not a given that there would be six 10 registration units for each registrar. That is what we 11 assumed to increase the stay time, to increase the amount of 12 parking that we thought would be needed.
1 13 Q So you really haven't looked at the question of 14 how many evacuees a registration worker can process 15 simultaneously?
16 You're just working backwards from your parking 17 calculation; correct?
18 A (Callendrello) No. I don't understand the 19 question.
20 Q You haven't done any studies or run an:( drills to 21 see whether that, in fact, works, have you? To see whether 22 a single registration worker can process simultaneously six 23 registration units. A person, six people who are going to 24 be filling out, not just parts 1, 2, and 3, but part 4 ds i
l 25 well which is the congregate referral, where interaction is 1
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REBUTTAL! PANEL NO. 17 - CROSS 25599
=1 required about what the! congregate care is? .Where it'sL
.2- located? What services'are available there?~ -And 3 directions, and providing.directionsJto'the. center;; correct?
4 A (Callendrello). Well,-you've' asked a lot of-5 questions in that single question. ,'+
. 6 Q~ Well, the~ question 11s: you' haven't done any 7 studies-to see whether that'can beldone,-have-you?
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(Callendrello) - Let's take them or.e at a time.
~
8 A' 9 As far as drills go I'll-defer to Mr. Cotter on 10 what's actually happened in terms _of demonstration of1 11 registration at the' drills; and'then we'll take'the'others:a-12 piece at a time.
13 Q At the drills, as I understood, it was set up the.
L 14 way the plan now reads, not the way,you're describing-it" 15 here as to what it will' read; correct?
16 A (Cotter) That's correct.
17 Q The congregate care referral'was a different 18- table; correct?
19 A (Cotter) That's correct.
20 0 So are you aware of any studies, drills, tests of 21 any kind to show, in a realistic kind of setting with people 22 asking some questions and some interaction, how many people 23 each registration worker can process simultaneously?
24 A (Callendrello) I don't necessarily accept your 25 premise that there will be a lot of interaction between Beritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO. 17 - CROSS 25600 1 registration units or evacuees and the registrars.
2 It's a fairly straightforward process where the 3 registrar puts down the name of the congregate care center 4 that's currently at the top of the list, the address of it, i
5 and provides whatever directions are needed or a map.
6 Q But the answer to my question is, no, there really i f
7 aren't any studies or drills or tests that have shown, j I
8 realistically, how long that time is on average? ;
{
j 9 A (Callendrello) The only time tests we have done '
10 are the ones to fill out the forms. j i
11 JUDGE SMITH: Do you want to break? )
12 MR. FIERCE: Sure. l 1
l 13 JUDGE SMITH: All right, 15 minutes.
q 14 (Whereupon, a 15 minute recess was taken.)
15 j
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19 20 1 .
I 21 22 .
23 l 24 25 Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO.-17 -CROSS '25601-
/~N 1 MR.--TRAFICONTE: You will recall,.I'm-sure,.that-we discussed at great length' yesterday and we have a~ ruling
~
2 3 on the excerpts from'the Perrotti depositionithat areito be
'4 admitted.
5 Mr. Turk-supplied me with a setl of-pages...I^have 6 reviewed ~them=last night. 1There is.one four-page~section 7 which I have distributed to the parties and the' Board which' 8 I do not believe should be admitted because it' cannot be-9 confined to the limitations that1 attach to all'of the 10 Perrotti deposition.
~
11 .And those pages are'in the' excerpt that7 I-12 provided: pages 191 through-195. .'You can ignore'the first 13 three or four pages, but.the objectionable portion is on' 14 those pages.
~
15 I don't want to spend a lot of time on it. I will' 16' just state that the questions and answers on these pages are 17 Mr. Turk's own cross-examination:of Mr. Perrotti. For 18 example, on page 193 directly'at'line 12 Mr. Turk put the 19 question: "So in your mind, then, they had done'moreLthan 20 simply follow their procedures.- They had arrived at a 21 proper PAR."
22 Now, that simply cannot be limited to the'-- that 23 is not subject to the limitation that this testimony.goes in. .j 24 for the proposition that they just followed their procedure, !
25 since the purpose of the question, as Mr.-Turk well knew, ;
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1 REBUTTAL PANEL NO. 17 - CROSS 25602 1 was to get Mr. Perrotti to testify independently of l
2 following the procedures, that they still came out with the 3 right PARS.
l 4 These pages 191 through 195 are completely given l 5 over to Mr. Turk's efforts to have Mr. Perrotti opine as to 6 the appropriateness of these PARS independent of their .
7 relationship to the procedures.
8 In light of that, they can't fit into the ,
{
9 limitation. They're outside of the order, and I think they l 10 shouldn't be admitted.
1 11 JUDGE SMITH: The interesting thing about your I
12 argument is that you don't have to accept any of it. You 13 didn't have to accept any part of the Perrotti deposition if 14 you didn't choose to.
I 15 MR. TRAFICONTE: All right. l l
16 JUDGE SMITH: But I thought that parts of it you j 7 would agree to, for whatever reasons. l 18 MR. TRAFICONTE: Well, we have a dispute because 19 whatever the ruling -- ,
i' 20 JUDGE SMITH: You're really seeking arbitration l -
l 21 here more than ruling, actually, from the Board I think.
22 MR. TRAFICONTE: Well, I have communicated to Mr.
23 Turk that I do not -- I continue to object to these pages.
24 And Mr. Turk has communicated back that he would seek to 25 have the Board admit them.
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REBUTTAL PANEL NO.'17 - CROSS 25603
~
/~' 1 So perhaps-I'm.not the person who has instigated.
k 2 the dispute-as much as the Staff. He is seeking to have, 3 perhaps, in another offer these pages admitted; and I am 4 continuing to object on the grounds --
5 JUDGE SMITH: As we pointed out in the very
- 6 beginning, this depends very-heavily upon your. agreement as 7 to what goes in and what doesn't go in. You could object to 8 the whole deposition and say, it doesn't meet the standards 9 for receiving deposition testimony.
10 So, in effect, you are asking us-to. agree upon 11 relevance and it's not relevance. Boy, I thought this issue l
12 was all decided. I threw away all the papers, and hope I 13 never hear about it-again.
14 MR. TRAFICONTE: I did, too, Your Honor.
15 JUDGE SMITH: All right. ->
16 To review: what we had was three phases of the 17 Perrotti testimony. The one that you agreed to accept was a 18 follow-up procedure that is properly raised by Mr. Turk now 19 because the issue was first brought up on cross-examination.
tb MR. TRAFICONTE: Yes.
21 JUDGE SMITH: The issue of Perrotti's independent 22 conclusion as to the quality of the PARS, while relevant, 23 did not flow from the cross-examination of the panel and i
24 should stand in the place of any other direct written 25 testimony.
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REBUTTAL PANEL NO. 17 - CROSS 25604 1 So that part of it, if the objection were made 2 solely on that basis as compared to general interrogatory 3 deposition testimony in a whole, yes. In fact, I think we 4 did sustain objections along that line, because that's the <
5 only thing that was put to us.
6 MR. TRAFICONTE: That's exactly correct. - l I
7 JUDGE SMITH: The only thing that was put to us
~
8 was that. So it is properly before us. !
9 MR. TRAFICONTE: Yes.
10 And then Mr. Turk had -- we had all, I believe, 11 acceded to the ruling. He had proposed pages and I have an 12 objection or I continue an objection as to only these pages j 13 becaus.e they do precisely what Mr. Turk was trying to do i 14 yesterday.
l 15 JUDGE SMITH: Well, certainly, the question and 1
l l 16 answer you pointed out to us does. I don't know about the 17 rest of it. But it seems to be clearly as if it identifies 18 it. But I guess the thing for us to do is read them.
19 MR. BACHMANN: Your Honor, may I comment on that.
20 It is the Staff's position that while there are 21 objectionable questions and answers on these four or five 22 pages, there are also other "Q" and "A" that go to whether 23 they followed proceduras. And that is the limited purpose 24 to which the Etaff would like to introduce --
25 JUDGE SMITH: Well, can't you excise the material Heritage Reporting Corporation (202) 628-4888
i REBUTTAL PANEL NO.'17 - CROSS 25605 f 1 objected to? Did you' explore that?-
(
'2 MR. BACHMANN: Well,,Mr.'Traficonte and I'really.
I 3 had a ery brief time to chat about this.during the break,
'l 4 so.we Zea't'get that far in our. discussions. 1 5 I would say that, I suppose we could-just strike-
- 6 out the objectionable questions and answers. But ILthink. 'j 7 ~ Mr . Traficonte has a bases objection to the form of the' ;
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8 question rather than the answer. ;
I 9 MR. TRAFICONTE: I believe'the whole set'of pages- !
10 that Mr. Turk is seeking to have admitted has, as their 11 purpose, the effort by Mr. Turkfat that deposition to get~
]
12 Mr. Perrotti to opine independently of_the procedures as to 1
-?
13 the quality of the PARS. That's what the whole line'of ]!
14 questioning has to do with.
15 If we go "Q" and "A" we will strike, in my view, 16 every "Q" and every "A."
17 JUDGE SMITH: Now, lookingLat the first page, your 18 objection doesn't begin until line 16,:doec it?
19 MR. TRAFICONTE: That's right.
20 And the question on 13 and then.the answer. The 21 question on 13: "At any time during the. exercise did you-22 have in mind what a correct recommendation, an appropriate 23 protective action recommendation would be?"
'24 .And again, independent --
25 JUDGE SMITH: Where is that? Where are you -j
( Heritage Reporting Corporation (202) 628-4888 ll
1 REBUTTAL PANEL NO. 17 - CROSS 25606 1 reading from now?
2 MR. TRAFICONTE: I'm on page 191, line 13.
3 JUDGE COLE: You're talking only about pages 191 4 through 1957 5 MR. TRAFICONTE: 191 through 195. j 1
6 JUDGE COLE: Is that correct?
- 7 MR. TRAFICONTE: Yes.
8 MR. DIGNAN: Why were 191 through 195 were copied?
9 MR. TRAFICONTE: They were copied because I was l
10 going to object to those and Mr. Bachmann has convinced me j 11 that --
I l 12 JUDGE SMITH: Oh, okay. l l
l 13 MR. TRAFICONTE: -
you know, I basically have 14 agreed that Staff can have those pages.
15 JUDGE COLE: We can tear those off. 1 1
\
16 MR. TRAFICONTE: They can go off.
17 (Laughter) 1 18 MR. TRAFICONTE: Just on to the top of 192 Mr. I 19 Turk makes it very clear at line 8 of what he's talking 1
20 about.
21 MR. DIGNAN: For what it's worth, I agree with Mr. l 22 Traficonte, at least starting at page 192 and I don't know 23 that 191 has any independent thing. I think it is clearly 24 without the scope of the Board's ruling.
25 (Pause to review document. )
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.l REBUTTAL FANEL'NO. 17 - CROSS 25607-e' 1 MR. TRAFICONTE: ItSculminates on 194 at.line 12.
2 MR. DIGNAN: Doesn't.your objection really start' 3 at the top of'193?
4 ' JUDGE SMITH: Well, I think --
5 MR. DIGNAN: Isn't that where it starts?-
. 6 JUDGE SMITH: Starting at'line 22.on 192.we begin 7 to step into the complaint about material.
8 (Pause to review document. )
9 JUDGE SMITH: We don't get to theLpoint where:we-10 begin to share Mr. Traficonte's concern _about it until we 11 get to page 193. And'then the first question that comes up 12 is -- first question and answer on 193, which-I think is
~
13 saved by the answer. The answer being: " Comparing that' 14 with the guidance given by the NRC, yes, it was a proper one 15 I felt." And we interpreted that answer to be measured 16 against the guidance given by the NRC as comparing it in 17 contrast or comparing it and corroborating it.- But we read 18 that to mean, "as measured with the guidance given by the 19 NRC."
20 Was that a concern of yours, Mr. Traficonte?
21 MR. TRAFICONTE: .Well, it was to the extent that 22
- he is saying something more than -- that Mr..'Perrotti had 23 compared the PARS against the procedures in the plan. j 24 JUDGE SMITH: All over, in the following 25 sequences, yes. But up to that point, that sentence does l l
Heritage Reporting Corporation (202) 628-4888
4 REBUTTAL PANEL NO. 17 - CROSS 25608 1 not give us any trouble. It is simply we interpreted it as 2 being that the foregoing question was measured by him 3 against the guidance given by the NRC. I don't know if
^
4 that's correct or not.
5 MR. TRAFICONTE: Well, it may or may not be. I ;
6 still read the answer to be that he was making a judgment -- -
l 1
7 I took the answer to be the statement of what he considered 8 in making his independent judgment that these were the 9 appropriate PARS. And what he considered was that they were 10 in accordance with the guidance given by the NRC.
11 That's still something -- '
12 JUDGE SMITH: I don't understand that. That's 13 where I lose you. If he compared the procedures --
14 MR. TRAFICONTE: I don't think this is talking 15 about the procedures; I think this is talking about the PARS 16 that were issued.
17 JUDGE SMITH: No, he's talking about the guidance. I 18 MR. TRAFICONTE: The question was: "Did you ever i
19 reach a judgment in your own mind whether there was 20 appropriate and proper protective action respense? I should I 21 say, proper protective action recommendation?"
22 Comparing that --
23 JUDGE SMITH: Where is that?
24 MR. TRAFICONTE: That was on line 6 through 9 on 25 the same page, 193.
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REBUTTAL PANEL NO. 17 - CROSS 25609 7 N 1 JUDGE SMITH: Yes. I think what was happening 1 ,
2 there, and I wasn't present, of course, and we have to do 3 some speculation. It is not all that clear.
4 But if you begin at the bottom of page 192 the 5 answer is: "And if they were to follow that procedure they 6 would come to the same conclusion I would if I followed the 7 NRC standards.," That's harmless to you. I don't think 8 there's any problem with that. He's saying, it eqets it.
9 It equals "B" and "B" equals "C," therefore "A" 10 equals "C." It's measured against NRC standards, whatever 11 they may be.
12 Then I think that you, quite correctly,-
13 anticipated what Mr. Turk was doing. Mr. Turk was trying to
~s
,/ 14 get him to say, well, aside from NRC's procedures, it was 15 pretty good, wasn't it, pretty good PARS. And that could 16 very well have been the intent of the question beginning on j 17 top of 193.
18 MR. TRAFICONTE: I see.
19 JUDGE SMITH: But the witness didn't buy it.
20 MR. TRAFICONTE: I see. ;
21 So reading that answer on lines 10 and 11 it 22 simply restates what the witness said at the bottom of 192.
I 23 JUDGE SMITH: And it very much qualifies. See, he l
l 24 is not accepting the question; he's qualifying it. Yes.
l l 25 Sure.
l l
ltrm
, ( ')\ Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25610 1 To the extent that it is measured against the 2 guidance of the NRC; yes, it was a proper one. That's the 3 way I read it.
4 MR. TRAFICONTE: But Mr. Turk heard it differently 5 because the next question is: "So in your mind then." '
6 JUDGE SMITH: That's right. - i 7 Turk was trying to go faster than Perrotti was 8 going. l 9 MR. TRAFICONTE: All right. j i
10 JUDGE SMITH: I think, as I read it.
i 11 MR. FIERCE: He had a plane to catch, Your Honor. )
12 (Laughter) ;
13 JUDGE SMITH: Okay.
14 MR. TRAFICONTE: So line 12 -- the question that ;
15 begins on line 12 should not be --
16 JUDGE SMITH: No, that shouldn't be there.
17 MR. TRAFICONTE: And then the next question, 18 although it has a fact introduction, then just says the same 19 thing.
20 JUDGE SMITH: There is no doubt that the question 21 on line 12 and the answer on line 15 should be all out.
22 And then this is where we got into some confusion.
23 We didn't believe things were clear until we got to the 24 question beginning on line 12 on 194. And then the rest of 25 that should all be out. But it was hard for us to make a Heritage Reporting Corporation l
(202) 628-4888
l l
REBUTTAL PANEL NO. 17 - CROSS 25611 I 1
/N 1 determination as to the weather aspects.
I )
'- 2 I think we regard that as neutral. And we regard l 3 the whole exchange, with the parts that we have thrown out, 4 the whole exchange as being interpreted in the light of his 5 answers are in the context of NRC procedures.
. 6 Would that be satisfactory to you, Mr. Bachmann?
7 I think we have excised the parts that 8 legitimately can be confused. '
9 MR. BACHMANN: Could you just please repeat those 10 and I'll conform the testimony.
11 JUDGE SMITH: Let me restate our ruling.
12 We don't really have any problem until we get to 13 the top of 193. And interpreting 193 we also look at the f 14 answer beginning on line 23 at the bottom of 192.
15 Indeed, the question on top of 193 legitimately 16 causes Mr. Traficonte some concern. But the answer 17 qualifies it. The answer on line 10 and 11 qualifies it.
18 So there is no harm there.
19 The question and answer beginning on line 12 is 20 out. The question beginning on 26 and the answer all the 21 way through to line 11 is neutral. In context we don't know 22 what that means. Several questions and answers.
23 From line 16 all the way to line 11 on 194. That 24 doesn't hurt anybody. That doesn't really tell you much.
25 It doesn't really go to the issue that we think is before O
(' Heritage Reporting Corporation (202) 628-4888
l i
REBUTTAL PANEL NO. 17 - CROSS 25612 I 1 us.
2 Now, here is Mr. Turk, whom we know can be very 3 persistent --
i 4 (Laughter.)
I 5 JUDGE SMITH: -- and on line 12 of 194 he is I
l 6 saying, "Again, in other words." -
l 7 Those legitimately should be out.
B 1 1
9 10 11 i 12 1
13 1
14 15 l 16 l
l 17 18 19 20 21 22 23 24 25
( Heritage Reporting Corporation.
1 (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25613 1 ~MR. BACHMANN: So essentially we are excising on
\/ 2. line 194 starting on - page 1941 starting on line'12.
3 JUDGE SMITH: that's right. To the balance, to 4 the end. All the way through to the end of 195 should be 5 out.
. 6 MR. TRAFICONTE: I had no' objection to the other 7 pages that were proposed. And I take it we will bind it'in 8 'perhaps -- do we have the option of binding it'in at.the 9 beginning of --
10 JUDGE SMITH: Yes,.that was our --
11 MR. TRAFICONTE: At:the beginning of today's-12 session?
13 JUDGE SMITH: All right.
'\ 14 You want that bound in?
15 Are you satisfied now or --
16- MR. BACHMANN: Yes, sir.
17 I've made some conformed copies. I am just' going 18 to omit page 195 entirely. I've crossed out the offending 19 questions and answers on page 193 and 194. So that. leaves 20 us with 24 pages which I will'give to the reporter at this 21 point.
22 JUDGE SMITH: Okay, now, the reader of the 23 transcript, not having found the Perrotti deposition where 24 it was portended to be in yesterday's transcript, will now, 25 absent cther developments, find it in the following page O Heritage Reporting (202) 628-4888 Corporation
REBUTTAL PANEL NO. 17 - CROSS 25614 1 that follows our ruling. It should be right here. It 2 follows our ruling.
3 Is there a reason why you want it in the front?
4 MR. TRAFICONTE: No , it should follow the.- ruling.
5 That makes more sense.
6 JUDGE SMITH: Yea. So it follows the ruling. -
7 (Excerpts from the Perrotti q 8 deposition follow:)
9 10 1 11 12 13
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16 i l
17 18 .
1 19 20 21 I I
22 I 23 1
24 25 Heritage Reporting Corporation (202) 628-4888 l
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UNITED STATES OF AMERICA C; NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD In the Matter of, Docket Nos. 50-443-OL 50-444-OL KENNETH A. McCOLLOM (Offsite EP).
~
- and - Deposition of:
DONALD J. PERROTTI PUBLIC SERVICE COMPANY OF NEW HAMPSHIRE, et al. Deposition date:
May 9, 1989 (Seabrook Station, Units 1 and 2) Reported by: -
Maxine Jacoby COUNSEL PRESENT:
Allan Fierce, Esq.
DEPARTMENT OF THE ATTORNEY GENERAL One Ashburton Place Boston, MA 02109 e
} Sherwin E. Turk, Esq.
\d Office of the General Counsel U.S. NUCLEAR REGULATORY COMMISSION Washington, DC 20555 Geoffrey C. Cook, Esq.,
p William L. Parker, Esq., and 11 Kathryn A. Selleck, Esq. ,
ROPES & GRAY One International Place Boston, MA 02110-2624 Also Present:
Edwin F. Fox, Jr.
axine acoby $ scociales Professional Reponing Senin 500 Renshaw Building
( 9th & Liberty Patsburgh, Penruylvania 15222
< m >>.,.,,,, .
6 1 MR. FIERCE: Correct.
2 MR. TURK: Do you want to make the subpoena 3 a part of the record?
i 4 MR. FIEMCE: I don't think there is any 5 reason to do that now.
6 BY MR. FIERCE: -
7 0 Mr. Perrotti, you indicated you have not had a 8 deposit. ion taken or been deposed before. ..
9 A That's right. I have not been deposed before. _.
10 0 You understand that we are here today, and you are 11 under oath. I will be asking you a series of questions that 12 you will answer.
13 A I understand that.
+
14 0 To the best of your knowledge and belief.
15 A YeS-16 0 I want you to understand that if there are 17 questions that, for whatever reason, you just don't 18 understand, you can stop and ask me to rephrase it. I want 19 you to understand what I am asking you. I want you to give 20 a truthful answer, to the best of your knowledge and 21 recollection. .
22 If y u have any questions, just pose them to me at 23 the time, please. Do you undert+an6?
24 A Yes, I do.
,' 25 0 Why don't we begin, Mr. Perrotti, by having you MAXINE JACOBY & ASSOCIATES
7 1 give us, if you can, a thumbnail sketch of your background 2 and employment history within the Nuclear Regulatory <
3 . Commission.
.4 A 'Well, I have over 26 years of experience.in the 5 nuclear power industry, 12 of which were with the U.S. Army.
- 6 And my technical background is in health physics, 7 p-h-y-s-i-e-s, which I received through Army training.
8 After I retired from the Army, I went to work for the 9 Florida Power & Light Company, at the Turkey Foot Plant near
! 10 Miami, Florida, for approximately four years.
I 11 Following that employment, I was employed by the 12 NRC, the Region 2 Office at Atlanta, Georgia, Region 2.
- 13 That was in December of 1976, that I hired on with the NRC, 14 and I spent four years in the Regional Office. And then I 15 moved to Headquarters in 1980.
16 All of my experience with the NRC., from 1976, 17 until I retired this year was in emergency planning, either 18 as an Inspector or as a Team Leader or as a Plan Reviewer at 19 Headquarters. That was my job at the Headquarters Office.
- 20. So, that, very briefly, is my background.
21 O You left the NRC this --
l 22 A March 31st of this year.
23 0 March 31st?
24 A Yes, sir.
, 25 O What is your educational background, Mr. Perrotti?
\ .
MAXINE JACOBY & ASSOCIATES
13 1 0 All right, Mr. Perrotti. Moving ahead, you were a
,m
) 2 participant and an observer in the FEMA NRC graded exercise 3 for Seabrook Nuclear Power Plant last June?
4 MR. TURK: Did you say " participant"? I 5 object to the form. As an " observer." I think
. 6 the two terms are terms of art.
7 BY MR. FIERCE:
6 0 What was your role at that exercise?
9 A I was a team member of the Region 1 Inspection 10 Team, who were there to evaluate the onsite portion of the 11 Seabrook Exercise.
12 0 And, do you remember that exercise?
13 A Yes, I do,
) 14 0 You were there for a number of days?
15 A Two days, as I recall.
16 Q Can you tell me what kind of preparation you 17 engaged in prior to the actual observations you made during 18 the exercise?
i 19 A Yes. As the Plan Reviewer for the Seabrook l
l 20 Station, I was familiar with the emergency plan, number one.
21 So, I knew the organization, the training that they had gone 22 through, and things like that.
23 O All right.
24 A And then, when I received my assignment as the 25 Inspector for the eor, which is the Emergency Operations
/')
MAXINE JACOBY 6 ASSOCIATES 1 ___- _ ___ - _
14 j 1 Facility, then I started to focus in on the procedures that 2 would be used at that facility d.2 ring the exercise.
3 O All right. When you say you were the Plan 4 Reviewer, --
5 A Yes, I was the assigned Headquarters Plan Reviewer 6 - '
l for the Seabrook Station on emergency plan.
7 O Do you recall the title of that plan? '
l B A Yes. The Seabrook Station Radiological' Emergency
~
9, Response Plan.
10 0 Or the RERP? Is that how you refer to it, RERP?
l 31 A No, because the offsite also had a RERP. So, in 32 all of my evaluations and any reports, I tried to keep the 13 two terms separate, so that everybody would know exactly. ,
t 14 So, we keep it separate, the two terms. That's the easiest 15 way I know of.
i 16 O And, the Seabrook Station response organization, 1
1 17 how did you refer to them?
16 A As the onsite organization.
19 O As opposed to the various offsite operations? ,
j l 20 A Yes.
21' O We will try to use those terms here today.
- 22 A All right.
23 O So, you were familiar with the plans themselves 24 before heading into the exercise.
25 A Yes.
j MAXINE JACOBY & ASSOCIATES
1
'l u
~
27.
1 assume that you would' continue to'do the' standard kind of n
(, 2 evaluation that you were familiar with in the past.
3 A I believe that is correct. It was assumed 4 that --
' you know,.that I would perform like a team member,.
5 like I had been doing. .Decause, I had made several trips to
+ 6 Seabrook.with Region 1, and I'was familiar with the team;.
7 they were familiar with me and how I operated'. ,
8 O Let me put'the question slightly differently.
9 Did they ask you this-time to do anything 10 different than you'had done in the'past?
11 A No.
12 O So, in terms of your preparation, you did what you g- 13 have just described,.in terms of selecting'the pages from t
14 the evaluation criteria which would be applicable to your' 15 assignment to the EOF. You were already familiar with the 16 plan.
17 Did you do anything else in preparation for the 18 exercise?
19 A I reviewed those procedures that pertained to the 20 EOF.
21 O And, this would be from the onsite plans for the .
22 Seabrook Station Radiological Emergency Response Plan?
23 A Yes-24 0 Did you review the procedure for protective action 1 .r
( 25 decision making?
m MAXINE JACOBY & ASSOCIATES !
28 l
1 A Yes, I did.
2 Q The copy of the inspection procedure that I just 3 showed you has two columns next to each of the standards:
4 the first column for inspected licensee response, and the 5 second column for actual licensee response at.4 comments.
6 I have been provided by the NRC with a copy of
- 7 what purports to be some pages from the evaluation criteria 8 forms which purport to be from you. I see they don't have 9 these two columns listed on them. '
10 Do you have any explanation for that?
11 MR. PARKER: That is just the first page.
12 MR. FIERCE: I don't have the columns.
13 MR. TURK: Page 2. j 14 MR. FIERCE: Generally, they just don't have 15 those columns.
16 BY MR. FIERCE:
l i
17 0 It doesn't have the line drawn down. {
18 A May I see that?
19 0 Yes.
20 MR. COOK: This is one other page.
21 BY MR. FIERCE:
- 22 O This is not a major point, but I am curious.
23 A Yes. This is guidance. And what I usually did on 24 my effort was to tailor our guidance inspection procedure to 25 suit my needs, the way I wanted to conduct my evaluation.
MAXINE JACOBY & ASSOCIATES
31 1 utility would come from a memo that you would write after-2 the exercise,-describing, as you indicated, the good points.
3 and the bad points?
4 A' Yes.
5 0 But, there was also a team meeting that would
~
6 occur after the exercise, where you would.have an d
7 opportunity to present your'commtents and your input?
8 A Yes.
9 MR. TURK: Are you asking him if he 'also 10 understood that at that meeting, at that time,_his-11 account at that meeting would be used as input?
12 Is that the witness's answer?
13 THE WITNESS: You asked me if there was a-14 team meeting where'we provided comments to the 15 Team Leader, and I answered yes to that.
16 BY MR. FIERCE:
17 O All right.
\
18 A If your question is, did I expect my comments to j i
19 be entered into'the final inspection report, I would have to 20 say I didn't know whether they were-going to be or not.
21 That's up to the Team Leader and the Region 1 management.
22 0 You did understand that, essentially, you would 23 have two shots --
24 A Right.
g 25 0 --
in offering input?
0 O
MAXINE JACOBY & ASSOCIATES
34-1 period of time, from June 29th to July lith, that caused the 2 delay in this input being sent up to the. Regional Office.
3 0 Do you have any reason to believe that your input l 4 as stated in this memo was-not received in time'before the 5 exercise report was issued?
. 6 MR. TURK: The contDnt of his memo versus 7 this 7-14?
l 8 MR. FIERCE: He said at least'a draft or- !
9 something might have been sent up sooner,'at ,
10 least to his regional people.
11 A Well, I had provided the essence of this report at i
12 the team debriefing.
13 BY MR. FIERCE: l
\ 14 0 Did you?-
15 A Yes, I did.
16 O All right.
17 A And the only thing I did after I got back to j 18 Headquarters was to have it typed so it was more legible, I 19 and have it concurred by my imrediate supervisor. But, as 20 far as the actual content of the comments, they had already 21 been provided to the Regional Office, 22 MR. TURK: May I note that Mr. Perrotti was 23 referring to the essence of this report, and he is 24 looking at the July 14th memo.
25 MR. FIERCE: All right.
(_ .,
MAXINE JACOBY & ASSOCIATES
36 I them.
() 2 O Prior to the 7th?
3 A Prior to the 7th.
4 O All.right. Can you tell me how'you actually.
5 physically discarded your notes? Did you throw them'in the
. 6 wastebasket?' -
7 A That is what I recall. Yes, just simply threw 8 them in the wastebasket.
9 Q How many pages of notes do you recall taking?
10 A Approximately four pages.
11 Like I mentioned before, most of- it was in a time -
{
.[
12 line frame, so I could capture when the event actually i f-- 13 occurred. What we did at the team debriefing was to compare l
14 notes on when this facility heard the declaration of a l 15 certain class of emergency and when the other facilities or l
16 the other oersonnel also got that same message.
17 0 Well, let me take you back to the date of the !
l 18 exercise.
5 19 Can you tell me what you did when you got there? 4 I
20 A Yes. I took a look at the' facility to make sure 21 there was no repositioning. I walked through the entire 22 building to make sure of that. I checked.the emergency plan. !
23 I checked the procedures that were on file there, to make 24 sure they were current and up to date. And that is pretty 25 much it.
MAXINE JACOBY & ASSOCIATES c__________ _ _ _ . - . _ __ _ l'
1 39 l 1
question, to be relayed to a player if needed.
i 2 O Well, let me just ask you, generally. Did you 3 take up a fixed position'at some point, a' chair,.and sit 4 there and observe?
5 A Absolutely not.
6 0 How were you performing your duty?
7 A No, I never sat in a' chair for any length of time.
8 There are certain periods of time during the day'when you 9 would get tired, so you would want to sit down to t'ake a lot 10 of notes. But, for the most part, you have a clipboard in 11 hand; you have one or two procedures that you are looking 12 at, and you observe and take notes while you're moving I 13 about.
\
14 0 What were the one or two procedures that you had 15 in hand?
16 A The one --
one was the activation of the EOF, 17 0 Yes, j
. I 18 A The other was the PAR decision-making procedure.
19 0 All right. Did you feel like you were able to see 20 all of the critical activity that was going on, see and hear
)
21 all of that activity?
22 MR. TURK: All the activity in the EOF?
23 MR. FIERCE: Where he was. ;
24 A Yes, I think I did. You are not going to see 100 25 Percent of anything, but you attempt to position yourself at MAXINE JACOBY & ASSOCIATES u_________________ _ _ _ _ _ _ _ _ _ _i
40 1 a certain position when you know a certain event is going to 2 take place, that you will be there to see the response of 3 the key players. And that is how I operated throughout the 4 day.
5 BY MR. FIERCE:
6 0 Were you focusing on specific exercise objectives
- 7 in doing this exercise evaluation?
l 8 A Yes. Pretty much all of the objectives' that were 9 to be demonstrated at the EOF.
10 0 Okay. With respect to observing the dose 11 assessment activity and the recommendations that were 12 ultimately made to the EOF Coordinator, is that the person 13 who ultimately makes the decisions about PAR e
14 recommendations?
l 15 A Well, "makes the decisions" is not the way we 1
1 16 phrase it. He is the one who formulates what the protective 17 recommendations should be.
18 Q Right.
19 A Then he coordinates with the Response Manager. ,
20 The Response Manager then authorizes --
approves and 21 authorizes that the EOF Coordinator notify the offsite "
22 authorities at that point.
23 0 Was the Response Manager there in the EOF as well?
24 A Absolutely. He is one of the key players.
I 25 0 He is the superior of the EOF Coordinator?
l MAXINE JACOBY & ASSOCIATES
3 59 Il 1 recommendations," could you tell me what you mean by1 that?
(g- s) 2 A Well, in certain cases there is no protective f
3 action recommendation. Depending on the severity of the 4 situation, they could request that the offsite organization 5 just simply stay on standby, or they might recommend that
.. 6 certain sectors or areas be sheltered or evacuated. It all 7 depends on the' actual conditions.at the time.
8 0 When you indicated what you would be looking for 9 would be the development and the making of some typ6 of 10 protective action recommendation, --
11 A Yes.
12 0 --
and I believe your language was that?
13 A Yes.
14 0 I am curious whether that could be any protective 15 action, as long as he made one. Were you looking for any 16 type of protective action?. What would be some type you 17 would be looking for?
~
18 A I was looking to insure that-they follow their j i
19 procedures which had already been evaluated.
f 20 0 All right.
21 A And their procedures would give them particular l 22 PAR for that particular scenario.
'23 O Mell, procedures that I have seen don't list a set i
24 of complete, predetermined PAR's for any and every I
( 25 conceivable situation. They would still have to put their MAXINE JACOBY & ASSOCIATES I
, l 60 1 heads together and make a recommendation for many situations.
1 2 Isn't that true?
3 A That is true.
4 O And with respect to --
5 A I'm sorry.
6 0 With respect to those kinds of PAR's they would -
7 have to make, what is it that you would be looking for?
)
. \
8 Would any PAR that wasn't specifically designated in the 9 plans have been an appropriate one, in your view?
10 A Well, you have to look at the PAR process and the q I
I 11 procedures that they used. You have accommodated, I think, 12 four different types of releases: stack,' steam line, 13 monitored vent --
containment, I mean, or unmonitored 1
t 14 release. l 15 0 Yes. j 16 A The procedure also accommodated plant conditions; 17 for example, what was the status of the core at the time :
18 they are developing this protective action recommendation.
19 0 Yes.
20 A It also took into account any offsite dose 21 measurements that were made by the field monitoring teams. -
22 When all this information gets plugged into the 23 PAR decision-making process, and ultimately what you come l
l 24 down to is whether the protective act!.on guides that are 25 delineated by the EPA are going to be exceeded or not.
MAXINE JACOBY & ASSOCIATES
61 1 If they are exceeded, then you take some i ( 2 protective action,-or you recommend some' protective, action,
\
3 so that the public is not going to be exposed to doses in.
5 0 All'right.
, 6 A So, when I say that I was looking for-some.
.7 protective action recommendation, I did not mean~I was 8 looking for just any protective action recommendation, but 9 the one that leads them through a logical series, okay,
.10 working through that PAR procedure, to come ultimately to 11 what they are going to recommend to the state with regard to 12 shelter or evacuation, or both.
-s s 13 0 Were you' aware there was any preference for either k 14 shelter or evacuation in the onsite' plans?.
15 MR. TURK: Was he aware of that?
16 MR. FIERCE: Yes.
17 MR. TURK: He is saying he is.
18 A I'm not sure what your question is.
19 BY MR. FIERCE:
20 0 You weren't looking for any particular kind of
. 21 protective action, then, shelter versus evacuation? Either 22 one would have been appropriate PAR, as long as the 1
1 23 circumstances warranted it?
24 A No, I would not say that, because they are two 25 completely different types of actions.
\
MAXINE JACOBY & ASSOCIATES
62 1 Because of the proximity of the beaches, the 2 protective action recommendation would be to close the 3 beaches and evacuate the public from those areas.
4 O sure. Sure. But, for the rest of the population?
5 A For the rest of the EPZ, it'would depend on many 6 factors: weather predictions, wind speed, how long it would 7 take a release to reach a certain distance from the plant,
~
8 the evacuation time estimates, for example.
9 0 Wind direction?
10 A Well, certainly. That would give you the downwind 11 sectors. All of these things are considered in that PAR 1
12 process.
13 Q And ultimately making the decision, a choice l 14 between shelter versus evacuation, is it fair to say that l
15 the overall goal would be to pick the one which would 16 minimize the dose?
17 A That is true. That is the way the procedure is 18 set up.
l 39 0 If either one of those actions would provide ,
(
l 20 sufficient protection to reduce the dose below PAG k 21 guidelines, would the appropriate PAR still be the one which '
j 22 minimized the dose?
l 23 MR. TURK: I don't understand the question.
A Is this a hypothetical?
24 25 ;
MAXINE JACOBY & ASSOCIATES
91 l ,p rotective action?
fN--
2 A I believe so. i I3 ]
0 How do you know whether they were able to 1 4 correctly assess and evaluate criteria'that call 1for all 5 this information? How do-you know?
6 A How do I know?. - -
7 0 Were they able to correctly assess it? How do you
~
6 know?.-
9 A From listening to conversations between the key 10 players regarding plant status, from taking a look at the l
11 key players as they were completing these forms, and the 12 fact that actual message form was sent out'by the EOF.
13 Coordinator.
f~%
k, m 14 0 They followed the procedures?
15 A Yes, that is correct.
16 0 But, did you do more than assess whether they were 17 following their procedures in order to determine that they 16 had correctly assessed and integrated the information?
19 Do you understand what I am saying?- It seems to 20' me it's possible for them to actually assemble the
. 21 information and put it together, and in the process of 22 assessing and integrating it, come up with a wrong 23 conclusion.
24 Did you assess whether they came up with a right
/
25 conclusion with that information? Did they correctly assess k .
MAXINE JACOBY & ASSOCIATES
92 1 the information?
2 A At that time, I evaluated, yes, whether it was a 3 correct bottom line, so to speak.
4 Q How do you do that? How do you evaluate it? How 5 do you know that they had correctly assessed and integrated 6 all that information? - .
7 A Well, I guess, besides my observing approximately l
- l 8 100 exercises in my career, and --
9 0 It's based on evaluation of different utilities, 10 and different facilities, and different people; so, based on 11 your background --
12 A Basically, yes.
13 MR. TURK: Let the witness answer.
c 14 A (Continuing) It was basically a subjective 15 evaluation; an emergency planning is that to some extent.
16 BY MR. FIERCE:
17 0 You did not have objective criteria, then, that 18 you were using to determine how to correct an assessment; 19 and when an integration occurred, it was subjective --
20 MR. PARKER: Objection. Off the record.
21 (Whereupon, a discussion was held off the -
22 record.)
23 A If I might, --
and I really hesitate, you know, 24 to go into the details on a total emergency plan evaluation
- 25 and emergency plan implementation evaluation; but I guess MAXINE JACOBY & ASSOCIATES
93 1 I'm goingto have to explain how this process works.
g 2
~
i 0 All right. Okay.
3 A About two years prior to the licensing of any 4 plant we get their onsite emergency plan, and we'will 5 evaluate it against criteria that are in our regulations.. .
6 0 Probably somewhat more than'two years in.this 7 case?
. 1 8 MR. TURK: Objection.
9 A Af ter that process is done, and we- find' ttie plan 10 meets those standards, then we go to the site; and we will 11 evaluate whether they have. implemented those portions of the 12 plan that can be implemented at that point. For example, 13 has the training been done; are the facilities described in 14 the plan; are the procedures written as the plan intended; l
15 and, moreover, do the procedures actually fit the plan; will 16 they ultimately implement.that plan.
17 0 All right. j 18 A And, so, when we get to the exercise point, then 19 we are looking at a plan and procedure that has been gone 20 over by many Inspectors; it has been revised by the utility
. 21 based on their training and their exercise history. And, 22 so, basically, what we insure is that they follow those 23 procedures. Because, they adequately assess and they 4 24 adequately integrate information; they adequately do m
25 radiological monitoring; they cover source term MAXINE JACOBY & ASSOCIATES
94 1 assumptions.
2 Every item in this Section 3.2.1, if the proper 3
work is done up front, then it's really a matter of insuring 4
that they follow their procedures. Basically, that is what 5
it is, because of all the work that was done up front.
6 0 What did you do during the exercise to determine .
7 that they had correctly assessed and integrated 8 meteorological information?
9 A Well, you have the scenario in your left hand --
10 0 Yes.
11 A --
and your clipboard in your right hand, noting 12 what they are doing. You're looking, at 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br /> there 13 was a wind shift of 25 degrees, then you look around and see i
14 if they have spotted that wind shift of 25 degrees.
15 It's that simple, how you do it, because you know 16 ahead of time what is supposed to happen.
17 0 What if, in addition to the wind shift of 25 18 degrees, the forecast in hand is for further shifting to 19 occur in the short term? Wasn't that the case during the 20 exercise --
21 MR. TURK: Are you asking hypothetically, or -
22 are you asking about the exercise scenario again?
23 MR. FIERCE: I'm asking about this scenario, 24 this event.
/ 25 MR. COOK: What is the question?
MAXINE JACOBY & ASSOCIATES l
J 122 j
. . I 1 they had their dose projections. And I don't remember ]
f-~s 1
! I 2 exactly what it was that triggered the General, Emergency. I J
\~-l l 3 think it was the fact that they had'a safety injection 4 ' signal, and they had a release ongoing at the same time, H
5 which put them in a General Emergency status.
6 So, what.they did within-15 minutes, as I 7 explained, they did the assessment, the dose projection, and 8 they made the notification with those protective ~ action 9 recommendations. And those details I don't remember, but it 10 was essentially the evacuation after a certain point and 11 sheltering out beyond that. s l
12 0 When you wrote, "Done," was it j'stu that those !
13 things happened within 15 minutes?
14 A That is correct, that they performed those things 15 within 15 minutes.
)
16 0 Focusing on the word " appropriate," before 17 " protective actions," did you do anything to determine that 18 that protective action was appropriate?
i 19 A Well, if they followed their procedures, which had 20 already been reviewed and approved by the staff, then they j
- 21 took appropriate actions; and they did in fact follow their i 22 procedures.
23 0 You also have written under the word, "Done,"
24 " discretionary PARS given."
25 What does the word " discretionary" mean, in your MAXINE JACOBY & ASSOCIATES
1
'191-1 concerns?
+
r 2 A None.
3 0 Also, there is a question about your.Section 4 Number 3.7. Your notes in Section 3.7, you indicated that-5 you filled'in those notes after the exercise as you recalled 6 things. Do you remember approximately when'you did that?
7 A Well, it was immediately after the exercise. It-8 probably was within a couple of hours following the.end of.
I 9 the first day's exercise.
10 0 It would have been done on the first day of the 11 exercise?
12 A Yes.
13 0 At any time during the exercise did you have in
,) 14 mind what a correct recommendation, i.e., an appropriate 15 protective action recommendation would be with respect to 16 the accident scenario that had been in progress?
17 A Yes, I did. In going through the scenario, and 18 then looking at their procedure, I had in my mind what they 19 should do, you know, if they were to follow the scenario and 20 take the data as given to them by Controllers and all of
. 21 that. And it was simply a matter, really, of their 22 following that procedure to the ultimate conclusion as to 23 what PAR should be given.
24 0 Let me focus on that for a second.
O 25 When you say that you did have in mind what they m
MAXINE JACOBY & ASSOCIATES
192 1 should do, if they follow that procedure and taking the data 2 into account, are you saying that you had in mind what 3 appropriate protective action would be to issue an order to 4 protect the public?
5 A I'm not sure what you are driving at.
6 0 Let me ask it again. ~
1 7 A Okay.
1 8 0 I am left with an impression, following.
9 Mr. Fierce's examination, that you determined that l'f they 10 follow their procedure, they will arrive at a proper 11 protective action recommendation.
12 My question to you is: During the exercise did 13 you have in mind what a proper protective action t
14 recommendation would be at various parts of the exercise 15 scenario?
16 A Well, they were consistent, that the two elements 17 you just mentioned were consistent.
18 0 What do you mean?
19 A Their procedure allows for decision-making process 20 to occur. That procedure was found to be acceptable to NRC 21 standards. .
22 O All right.
l 23 A And if they are to fo31ow that procedure, they i
24 would come to the same conclusion I would if I followed NRC l
25 standards.
MAXINE JACOBY & ASSOCIATES
193 1 O Now, with respect, for instance, to what they_did i 1
2 when the General Emergency was declared, that they evacuate f (a) 3 up to five miles, within a 360-degree circle around the {
l 4 plant, and they sheltered the population five to ten miles 5 from the plant in a 360-degree circle.
6 Did you ever reach a judgment in your own mind 7 whether that was appropriate and a proper protective action 8 response --
I should say a' proper protective adtion recommendation?
9 .;
10 A Comparing that with the guidance given by the NRC, 11 yes, it was a proper one, I felt.
12 0 9e, in your rind, then, they 5:d donc ;;rc than
, 13 ' simply folicued their prac darc;; they had asi-ived -L o l'
14 proper PAP?-- ')
l 15
. Ycc. .
l 16 0 Also, later in the day, while they were still at i
17 the General Emergency, if you recall, they decided to I 18 evacuate areas which lie within "E" and "F." They are 19 indicated that they were Southwest of the plant.
20 Did you ever reach determination whether that was !
. 21 an appropriate and proper PAR?
22 A I understand your question. I'm trying to think ,
1 23 of what was going on at the time. It seems to me that there 24 was a point where they gave a little more weight to the 25 projected weather change, and they decided to go ahead and
( -.
MAXINE JACOBY & ASSOCIATES
194 1 conservatively extend the evacuation out in those particular 2 areas based on the potential for a weather change, wind 3 direction primarily.
4 0 So, they considered the predicted weather change?
5 A Yes.
6 0 And did you ever reach a- determination in your .
7 mind as to whether it was proper and appropriate for them to 8 issue that PAR's '
9 A I felt it was appropriate in discussing it with 10 the other team members. I think the conclusion was that it 11 was an appropriate PAR.
l l
l 12 .
O ngain, ir Othcr wvium, uvL just cnat tney were l
13 junt f n11 mi nn procedurec, bat they had reacned good i
14 vasultc?
15
- Yes.
16 0= It var a veed 2nd proper pan?
17 A Ycs.
18 -0 !c that your-general fealin0 uith respect to the 19 V-three Pt"'s, to " ^# *ha*a "h"'*'
9 20 MF- FEERCE- ObjevLivu Lv Lhe ivsm vi che 21 _queetien. It'r bad enough te epinc on whot to .
/
22 ._ nonA in A uhat 1E nOt good .-?i t h e s i O c i i n i n g " good.' '
23 Meu Scu'rc asking what his general feeling was 24 bbcut-all three pan's, and whether they sre good
- End not gcod, withvut Jefluing some terms.
', 25 1 MAXINE JACOBY & ASSOCIATES
REBUTTAL PANEL NO. 17 - CROSS 25615 1 MR. DIGNAN: Your Honor, I'm not sure if you have 9 2 formally stated that these pages are received in evidence.
3 JUDGE SMITH: Yes, they are received in evidence 4 as if Mr. Perrotti had testified here. Yes, that would be 5 identified as an inlay as Perrotti Deposition in the index.
. 6 All right, anything further before we go back to 7 the Panel?
8 Oh, Cohn, yes.
9 MS. CHAN: Cohn motion.
\
10 JUDGE SMITH: Ms. Greer.
11 MS. GREER: The Applicants have made three 12 separate objections to the testimony of Mr. Cohn. And I 13 will handle the objections in any way that pleases the 14 Board.
15 My suggestion is that I would do the first one, 16 make my rebuttal to the first objection. If the Applicants 17 want to then respond to that, and then we can go on from 18 there.
19 The first objection that the Applicants raise is 20 to a part of a sentence on page 2. And as I read the part 21 that's being objected to, it reads, "
... deficiencies in the ,
l 22 SPMC's provisions for rapid response by New Hampshire Yankee l 23 offsite response organization (NHY ORO) to information 24 received and transmitted by field workers."
25 I would submit to the Board that that is not in G Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. CROSS 25616 1 any way irrelevant or immaterial. It does not, ac has been 2 argued in the motion, go to any particular procedures, but 3 is really only part of the introduction describing the 4 general sum that the testimony will address later on in the 5 later pages.
6 And I believe that the provisions that are being .
7 addressed in that summary there are the provisions that deal
~
8 with the inability or perceived inability of New Hampshire 9 Yankee to make rapid response because they will in some 10 instances not be able to receive certain information, 11 because of range issues, or will not be able to receive and 12 transmit information because of channel overload issues.
13 And I don't see anything in there dea).'.ng with i , 14 procedures as is posed in the motion in limine. I believe i
15 that is simply a summary of what is later addressed in the i 16 testimony, and I don't see it in any way being objectionable 17 on that ground.
18 JUDGE SMITH: So in fact there may not be a 19 dispute between you and Mr. Trout if you can agree upon what 20 that is.
21 MR. TROUT: Mr. Smith's, Your Honor.
22 JUDGE SMITH: I beg your pardon?
23 MR. TROUT: This is Mr. Smith's motion, Your 24 Honor.
25 JUDGE SMITH: Oh, Mr. Smith. Excuse me.
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REBUTTAL PANEL NO. 17 - CROSS 25617 ,
g 1 MR. SMITH: No, Your Honor. With that I )
'/_- 2 representation, we will accept the testimony and that 3 limitation. We read it --
4 JUDGE SMITH: It should be developed that's not 5 what the witness meant. Well, then, that's another matter.
. 6 MR. SMITH: Correct.
7 MS. GREER: But that is essentially -- you will 8 notice that that paragraph is found in the portion of the 9 testimony that's headed " Introduction". And I believe 10 that's simply meant to be a brief summary of what later 11 follows in the testimony.
12 JUDGE SMITH: Well, that wouldn't save you were it 13 not for -- but the thing that saves the statement is that
/'~N 14 you are speaking of the rapid response being delayed by
('-J 15 inadequacies in the communication network.
16 MS. GREER: Right.
l 17 JUDGE SMITH: And not by information once l
18 received.
19 MS. GREER: That's right.
20 JUDGE SMITH: If you agree that that's what that 21 says, there is no dispute.
l 22 MS. GREER: Moving on to page 7 of the testimony, l 23 the Applicants have objected to the paragraph, and tell me 24 if I'm wrong here. I believe the paragraph they are 25 objecting to reads, "There appears to be a similar range Heritage Reporting Corporation
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REBUTTAL PANEL NO. 17 - CROSS 25618 1 problem with respect to coverage for the Emergency Medical 2 Systems service."
3 Is that --
4 MR. SMITH: That's correct.
5 MS. GREER: Okay. And you are talking about the 6 entire paragraph there, I'm assuming. .
7 MR. SMITH: Correct.
8 MS. GREER: The Applicants have objected to that 9 on the grounds that it's outside the scope of the 10 contention.
11 We would submit that it is in fact found in 22 Contention MAG EX-8, Basis B. Reading from MAG EX-8,.the 13 contention itself, the first sentence reads as follows.
7 14 JUDGE SMITH: Wait a minute.
15 (Pause.)
16 JUDGE SMITH: All right.
17 MS. GREER: The contention starts with the 18 sentence, "The results of the graded exercise revealed that 19 there exists fundamental flaws in the Seabrook offsite 20 emergency plans submitted by the State of New Hampshire and 21 the Applicants with respect to Planning Standards 10 CFR
- 22 5047 (B) (6) , " et cetera.
l .
l 23 Going down to the next paragraph, it continues on, l 24 "The exercise results which individually and/or collectively 25 provide basis for this contention include the following."
/
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REBUTTAL PANEL NO. 17 - CROSS 25619 l I
<x 1 Then going down to the first sentence of the
( b \
\- / 2 basis, Basis B. "The communication net linking the ORO 3 field personnel with the EOC and with each other was 4 demonstrated to be completely inadequate. Information flows I
5 were delayed and accuracy was compromised by the vertical
. 6 communication chain required by the SPMC. ORO field I 7 personnel, including vans drivers, traffic guides, transfer 8 point dispatchers, route guides, radiological field teams 9 and others, were using hand-held battery-powered 8-channel 10 radios. Radio communications were demonstrated to be i
11 deficient." l 12 And then a series of instances are provided. The i i
13 first instance that is posed there is that the EMS itself j
("N 14 was nonoperable, and that is raised in paragraph -- and that 15 happened during the course of the course of the exercise.
I 16 The EMS was not in fact used in the exercise.
17 However, if you look at the paragraph that's being 18 objected to, the paragraph that is objected to says, "There 19 appears to be a similar range problem with respect'to 20 coverage for the Emergency Medical System as exists for ERN
~
21 coverage."
22 Obviously, because the ERN was not used, there 23 could not be actual -- during the exercise, there could not 24 be any actual demonstration. Instead, what we found in the I
25 course of discovery was that in fact there was a limited --
,/ m
( ) Heritage Reporting Corporation
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REBUTTAL PANEL NO. 17 - CROSS 25620 1 there was a range limitation.
2 And that is in fact found down below in paragraph 3 four under Basis B which reads, "Other ORO field personnel 4 had only sporadic communications with the staging area 5 because of channel overloading and intermittent reception."
6 Obviously, there could be no demonstrate. But .
7 certainly the issue of the sporadic reception was raised.
~
8 Sporadic reception is posed as distinct from merely channel 9 overloading, and that is a range issue.
10 What happened was that during the course of 11 discovery it came to our attention through a memorandum 12 that --
13 JUDGE SMITH: Wait a minute.
14 You could have got there a lot faster.
15 MS. GREER: Sorry.
16' (The Board confers.)
17 JUDGE SMITH: The Board agrees that that does 18 allege a range problem.
19 MS. GREER: Okay.
20 JUDGE SMITH: Now let's see. Having found that, 21 does your objection still survive?
- 22 MR. SMITH: Yes, Your Honor.
23 Ms. Greer has defeated her own argument here. She 24 stated that this was a problem that was not exercised, and 25 therefore it could not have been part of the initial
~
Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO..17' ' CROSS. 25621- j 1
1 contention to begin with'as~it applies to the EMS radio. 1 2 It is also not.--
'3 ' JUDGE SMITH: 'Just-wait'a minute. ' Wait.
4 JUDGE' COLE: Iou say it.was not' exercised. It was. I 5- planned toibe exercised. It didn't function.
l
. ~6 - Is that correct? 'l l
7 MR. SMITH:: The' EMS radio,'right, did not 8 ' function.
9' JUDGE COLE: Well','that's --
10 JUDGE SMITH: It was. broke. It was broke or 11 inadequate?
i 12 MR. SMITH: It did not function. . I'm not sure'if 13 - it actually --
/" 14 JUDGE SMITH: Was it " supposed" to-function?
( )
q 15 MR. SMITH: Yes, it was. j 16 And there was a compensating measure that was.used 17 using hand-held radios.
18 (The Board confers.)
1 19 MR. SMITH: 'Your Honor, I think it was a battery-20 problem as to the reason why the radio' failed. 1 21 JUDGE SMITH: All right. {
22 MR. SMITH: So what I -- j l
23 JUDGE SMITH: Give us a chance to! catch'up here. l l
24 (The Board confers.) d 25 JUDGE SMITH: What's the ERN? ,
j O
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REBUTTAL PANEL NO. 17 - CROSS 25622 !
1 MS. GREER: It's the Emergency -- !
2 MR. SMITH: Radio Network. ]
{
3 MS. GREER: -- Radio Network. l 1
i 4 (Pause . ) <
5 JUDGE SMITH: We have held that intermittent i
6 reception can reasonably be attributable to a range problem. . )
7 Given that, what is the relationship between !
1 8 Exercise Contention 8 (B) (4) and the paragraph that is being l I 9 attacked?
10 I still don't understand batteries and battery !
11 failure and how that fits into the debate. We will have to 12 come back to that pretty soon.
1 13 MR. SMITH: It was my understanding that Basis ,
i 14 B (4) was specifically going to range problems, whereas this 15 sporadic reception did not necessarily go to range problems, 16 but it could. It could be a number of --
17 JUDGE SMITH: But is B(4) talking about the same 18 thing that the subject paragraph is talking about?
19 I don't know.
20 MR. SMITH: No. I believe B(4) -- I'm sorry.
l 21 B(4), I believe, is overloading, too many people 22 on a channel, so therefore you cannot break into the 23 reception and not be able to get your communication through.
24 JUDGE SMITH: But are the same people using the 25 same communication network as alleged?
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_ _ _ - _ - _ . _ _ _ _ _ _ ._ _ _ = _ . - -.
I I
-1 h
. REBUTTAL PANEL NO....17 - CROSS' '25623 -
.1 ' MS. GREER: 'It'says channel overloading and- j T' .
2' intermittent' reception. '
)j
. . . - 1 3 JUDGE SMITH: Already you.got intermittent 4 reception as a range problem.
]
5 Now what I want to know, are you we talking about; f
. 6 the same range problem'in the contention as he's. discussing 7 inLthe paragraph.
8 Is that the same network that is'b'ing e discussed?'
9 MS. GREER: .That paragraph 4Esimply;says, 10 " Generally, ORO field personnel" which would include i 11 everything from route. guides to' traffic guides to bus 12 drivers to ambulance drivers. I.mean essentially ORO-field l 13 personnel would be all ORO personnel responding.
.{ '
14 JUDGE COLE: Well, we've got two communication 15 systems, the ERS system and the ERN system.-
16 Are you saying that Item B(4) pertains.to both the l
17 ERS and the ERN system?
18 MS. GREER: That first sentence of it certainly 19 appears to cover both.
20 (The Board confers.)
21 22 23 24 25 t Heritage Reporting Corporation
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REBUTTAL PANEL NO. 17 - CROSS 25624 1 JUDGE McCOLLOM: Let ue ask another question about 2 the ERN and the EMS.
3 MR. SMITH: Yes, sir.
4 JUDGE McCOLLOM: Does the EMS have any kind of a 5 channel into the ERN, or is it strictly between the 6 ambulances and their host hospitals? .
7 MR. SMITH: My understanding is that there is no 8 connection between the two. They will go to the host l
9 hospital. The two channels do not overlap, the ERN and --
10 JUDGE McCOLLOM: No connect.
l 11 MR. SMITH: No, that's correct, Your Honor.
12 That's my understanding.
I 13 MS. GREER: If I may, my understanding is slightly I 14 different. At least, it may not be different, but I think 15 there is a plus there. 1 l
16 It is not solely between the ambulances and the 17 host hospital. It also is between -- there is also an EMS-18 designated radio that is linked -- that transmits on the EMS 19 frequencies located --
20 MR. TROUT: Right, and that's the radio that 21 wasn't used during the exercise because the batteries 22 didn't --
23 JUDGE SMITH: Wait a minute.
l 24 MS. GREER: I believe it's at the staging area.
25 JUDGE McCOLLOM: But it still is not connected Heritage Reporting Corporation (202) 628-4888
.a
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i REBUTTAL PANEL NO. 17 -' CROSS. 25625' l
-s 1 into the frequency that the ERN uses.
L.
2 MS. GREER: It transmits on different frequencies.
3 JUDGE McCOLLOM: 'And-therefore is not connected.to.
4 the ERN.
5 MS. GREER: That's correct.
, '6 MR. SMITH:. Exactly, Your Honor.
7 (The Board confers.)
8 JUDGE COLE: You would have no way of determining 9 whether the EMS system had a range problem, because it just 10 didn't work.
11 MS. GREER: Actually, it also'-- no, because in 12 fact during the course of the exercise, Applicant observers 13 said the EMS has never transmitted this far. At one point,
(s 14 at one point during the course of the exercise when a FEMA
-- 15 observer was in the one ambulance that was used, and.the one 16 ambulance was down here theoretically dropping off or making ,
17 a delivery to a Boston area hospital, the FEMA observer j 1 18 said, pull over and do a transmittal. #
19 The FEMA observer then -- the ambulance then 20 pulled over and did a transmittal on the ERN. However, the j 21 Applicant observer, who was in the vehicle, said that the 1
22 EMS had never been able to transmit that far which indicates ,
23 an EMS problem as well as an ERN problem. l 24 MR. SMITH: If that were the. case, I don't see-25 that anywhere in these contentions. That is something that j r
f Heritage Reporting Corporation (202) 628-4888
l l
REBUTTAL PANEL NO. 17 - CROSS 25626 1 could have been spelled out as a separate basis.
2 MS. GREER: I would point out'certainly --
3 MR. SMITH: I do not think that that was the basis I
4 for this argument, q 5 MS. GREER: I think it's certainly within the j 6 plain language of the contention and basis. And the .
I 7 Applicants never did --
8 JUDGE SMITH: Contention and Basis B(4) ? ;
l l 9 MS. GREER: Contention and Basis B, and also found
]
1 10 down in the first sentence of B(4) . And the Applicants j 11 never did any discovery as to all grounds and every fact 12 that was relied upon.
i 13 MR. SMITH: If I could just --
y 14 MR. TROUT: There was no formal discovery allowed.
15 MR. SMITH: If I could just address --
16' MS. GREER: You never did any informal discovery. j 17 JUDGE SMITH: All right, never mind.
18 MR. SMITH: If I could just address B(4) for a ,
1 19 minute, too. I think there is a misconception there as 20 well.
~
21 This contention, if you read the plain language, 22 it says, Other ORO field personnel had only sporadic 23 communications with the staging area because of channel i 24 overloading and intermittent reception."
25 I think it's just an amazing stretch to say that Heritage Reporting Corporation (202) 628-4888
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?
REBUTTAL PANEL NO. 17 - CROSS '25627 l 1 this is something that was included within that language. i O 2 That there was a conversation between an evaluator and --
j 3 was it an evaluator or someone'from the Applicants?
4 I'm not sure, but however it was, and that that-R 5 became the basis of that contention, given how all these
, 6 contentions are spelled out in excruciating detail, that 7 they didn't-include that'as'part of the basis of their --
8 JUDGE COLE: So your interpretation of the words 9 " intermittent reception" there would be thatLintermittent 10 reception associated with channel overload?
11 MR. SMITH: Yes. Yes, Your Honor.
12 (The Lcard confers.)
13 JUDGE SMITH: The Board believes that, after 14 further consideration, the essence of Basis B(4) was 1 O 15 overloading and that intermittent reception was intended to 16 be attributable to that. It's alleging here a very narrow 17 problem.
18 The testimony in dispute is an allegation 19 concerning the basic range of the EMS radio, EMS syst'em 20 itself. We don't believe that it is fairly covered by the 21 basis.
22 So the motion with respect to the paragraph on 23 page 7 is granted.
24 MS. GREER: Okay. The third area that the 25 Applicants seek to exclude is over on page 11,-the first Heritage Reporting Corporation
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_- -_-_-__-_____a
REBUTTAL PANEL NO. 17 - CROSS 25628 1 paragraph under the heading " Procedures".
2 And the objection here is that it's outside the 3 scope of an admitted contention or basis. In fact, what 4 this really here is in the nature of anticipated rebuttal to 5 a defense that Mr. Cohn foresaw the Applicants posing to his 6 channel overload critique. .
7 During the course of a deposition of Mr. Catapano, 8 who was self-described as the primary designer of the 9 Emergency Radio Network System that is used by New Hampshire 10 Yankee, the issue of channel overload came up, and the 11 question was posed to him, well, how are you going to deal )
i 12 with this if in fact you have this many people on the j 13 channel and you do have an overload situation. <
1 i
l ,
14 And Mr. Catapano came back and said, well, we do l 15 have in fact a way to deal with that, because have a 16 priority system that we can come in.
17 And Mr. Cohn in this one paragraph here is simply 10 saying that that priority system, which you are going to use 19 if there is a channel overload, is not going to work, or may 20 not work because in order to exercise that priority system, 21 you are going to have this problem. And that's all that is.
22 While it's essentially anticipated rebuttal, which 23 my understanding is we have an obligation to put in once we 24 are put on notice. And during the course of the deposition 25 of Mr. Catapano, notice was provided. That dep0sition was Heritage Reporting Corporation (202) 628-4888
REDUTTAL PANEL NO. 17 - CROSS !25629 !
1 taken in' March of 1989. .
(f Mr. Cohn, in drafting this testimony,: reviewed 2
3 that deposition:and had this critique of that essential ~
4 response to the channel overload issue.
5 JUDGE SMITH: Is:it actually in the testimony?
, 6 MS. GREER: What?
7 Is the priority system in the rebuttal'that's l
8 provided to Mr-. Cohn?
9 Yes, it is.
10 7UDGE SMITH: All right, what do you say'to that?
11 MR. SMITH: Given that limitation that it was in' 12 anticipation of the rebuttal, I think we are going to- l 13 concede the point.
/' 14 JUDGE SMITH: All right.
15 That's the end of it.
16 MS. GREER: That's it.
17 JUDGE SMITH: Yes.
l 18 Do you want to proceed or do you want to break for l
19 lunch?
20 MR. FIERCE: Again', I'll do either, Your Honor.
21 JUDGE SMITH: Let's break for lunch.
22 (Whereupon, at 11:53 a.m., the hearing was !
23 recessed, to resume at 12:53 p.m., this same day, Wednesday, !
24 June 14, 1989.)
25 t Heritage Reporting Corporation
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REBUTTAL PANEL NO. 17 - CROSS 25630 1 AEIEBH22H EEEEI2H 2 (12:52 p.m.)
3 Whereupon, 4 JOSEPH BISSON 5 ANTHONY M. CALLENDRELLO 6 ROBERT COTTER ,
7 PETER LITTLEFIELD 8 having been previously duly sworn, resumed the witness stand
- 9 herein, and were examined and further testified as follows:
10 JUDGE SMITH: Anytime you're ready, Mr. Fierce.
11 MR. FIERCE: I'm afraid, Your Honor, that Mr.
12 Dignan's prediction of three days for Mr. Fierce's cross-13 examination of this panel may come true, but not for the 14 reasons he anticipated.
15 I'm going to press ahead and see how far we can 16 get today, but we may end up going over tomorrow some with 17 this panel.
18 CROSS-EXAMINATION (Continued) 19 BY MR. FIERCE:
20 Q Panel, I want to pick up where we were last 21 evening in terms of the process of taking an individual '
22 through the monitoring trailer.
23 And I have an individual that I've got now in a 24 monitoring station who is wearing a coat, has some 25 belongings with him. For purposes of this question the coat Heritage Reporting Corporation (202) 628-4888
REBUTTAL' PANEL'NO. 17 - CROSS 25631 y- 1. is my focus. ,
( !
2 Is a person to be monitored with a coat on, 1
'i 3 perhaps with a. hat on, with gloves on,'or will the person be' {
4 asked to remove those objects or the third option would be, 5 are they to be monitored with the clothing on first'and
, 6 looking,. secondly, at the street' clothes underneath?
7' A (Cotter) They would be~ monitored'with their' J 8 clothes on.
9 JUDGE COLE: Their clothes on?
l 10 THE WITNESS: (Cotter) Yes.
11 BY MR. FIERCE: ,
12 O With the coats on, the hat on,-et cetera?
13 A (Cotter) Yes, that's correct.
14 Q What if the monitor does not know what the person 15 was wearing when they left the EPZ? In other words, doesn't 16 know whether they might have put the coat'on, the raincoat 17 on as they got out of their car; would that be.an issue?.
18 A (Cotter) No, it wouldn't.
19 Q So at no point would the person then be asked to 20 take off their coat so that an additional probe of their ;
21 street clothes could be conducted; is that correct? i 22 A (Cotter) The only time that would happen is if we l 23 identified contamination on the other clothing. )
24 Q But the other clothing could well have been put on 25 after the person left the EPZ in their car? For example, i [\ Beritage Reporting Corporation ,
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REBUTTAL PANEL NO. 17'- CROSS 25632 1 before they decided to walk to your monitoring trailer; 2 correct?
3 MR. TROUT: The hypothetical is: the person has 4 gotten contaminated and has then, in their car, put an 5 overcoat on over themselves and the contamination, and then 6 goes to be monitored; is that t.he hypothetical? .
7 MR. FIERCE: Well, the hypothetical doesn't rely 8 on them being contaminated. Obviously, neither one of them l
9 know. But what we do know is that.the person put the coat 10 on after they left the EPZ.
I 11 THE WITNESS: (Cotter) Could you repeat the .
l b l 12 question, I kind of got lost. l 13 BY MR. FIERCE:
14 Q I guess the question is: does that make a 15 difference for proper monitoring technique?
16' Maybe Mr. Littlefield would know the answer to 17 this question?
18 MR. TROUT: Objection. The witness asked for 19 clarification and all you said was, does that make a
)
20 difference. And I think it's the "that" that needs to be l l
21 clarified.
22 BY MR. FIERCE:
23 0 would that situation, if it arose, a person who i 24 had put on a coat, perhaps, gloves and hat as well, it's not 25 terribly relevant 1 but at least put on a coat after they had !
l l
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REBUTTAL PANEL NO. 17 - CROSS 25633
~
, ~g 1 left the EPZ, perhaps, as'they were. leaving their car in the' m- 2 parking lot of the reception center; would that make a 3 ' difference in terms.of proper monitoring technique when, 4 obviously,.it would be the clothing that's underneath the 5 coat that would be -- if there's any contamination that's
.. 6 where it would be?
7' A (Littlefield) The clothing on' top of the 8 contamination would certainly be less. easily detected.by the L 9 frisking technique than would contamination'on the'outside-10 of the clothing.
11 However, in that. situation I.would expect that if 12 there were any contamination on the individual the feet
{
13 would be the most~likely location'for that contamination, .
1
[g 14 and the feet would be frisked,.of course, as'part of that ,
N- 15 frisking process.
i 16 JUDGE McCOLLOM: Mr. Littlefield, what kind of i
17 radiation does the monitoring device measure?
1 1 18 THE WITNESS: (Littlefield) It measures both beca 19 and gamma radiation, but it's most sensitive to beta 20 radiation.
21 BY MR. FIERCE:
22 O Isn't it true that it's not just the noticing of e
23 radiation that is the purpose of the monitoring, but the 24 monitor is looking for a particular count per minute, 200 25 counts per minute in this case; isn't that true?
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REBUTTAL PANEL NO. 17 - CROSS 25634 1 A (Littlefield) .That's correct.
2 Q And it's also true that proper monitoring 3 technique for your probe is such that the probe should be 4 held quite close to the body, approximately half an inch; 5 isn't that correct?
6 A (Littleft. eld) That's correct. ,
7 Q Now, if a person is wearing a winter coat, when j 8 you monitor over the winter coat you could well be more than I 9 half an inch away from the underlying clothing; correct?
i l
10 A (Littlefield) That's correct.
l 11 Q That might affect the count per minute reading 12 that the monitor and the meter would be reading; correct?
I 13 A (Littlefield) That could affect the efficiency of l l ,
14 the detector: the distance it was held away from the 15 contaminated surface.
i 16 Q Proper monitoring techniqye to assess whether a 17 population group of people may be contaminated would be to 18 frisk the outer clothing; and then have the people take l I
19 their coats off and then frisk them in their street clothes; I l
20 correct?
21 A (Littlefield) I don't know what your talking
- 22 about, proper monitoring technique. The technique we use in 23 the trailers is to frisk the outer garments.
24 To carry your scenario further, then you would 25 have the person strip down to possibly their underwear and Heritage Reporting Corporation (202) 628-4888
25635 REBUTTAL PANEL NO. 17 - CROSS.
l 1 monitor the skin as well.
k 2 The chances of a person being contaminated at that j 3 level and n'ot having contamination'on their outer clothing 4 would'be very. rare. I can't conceive.of'how they could do 5 that. q
. 6 Q You can't conceive of them gathering up 7 belongings, taking them with them in their car, putting on a 8 coat, for example, as they leave.their car?
1 9 A (Littlefield) I don't-know why:they wouldn't have 10 that coat on when they entered their car. In any case, I'm 11 assuming that the coat came with them; from wherever the 12 contamination was available, the coat was there, also.:
13 Q Now, there is nothing in the SPMC plans or 14 procedures which instruct your. monitors on what to do with 15 this situation, is there?
16 MR. TROUT: Objection. What situation?.
17 JUDGE SMITH: I think the question has already 18 been asked and answered. There is no particular procedure 19 to take into account the phenomenon he's talking about.
20 JUDGE McCOLLOM: Well, Mr. Littlefield, let me ask 21 one question here.
22 If a person has some contamination on their 23 clothing and then he takes a coat and puts it on, what is 24 the probability of him not having any' kind of radiation 25 somewhere on the outside of the coat, whether it's his own
-I l r i ( Heritage Reporting Corporation l \ (202) 628-4888 ;
REBUTTAL PANEL NO. 17 - CROSS 25636 1 extremities or on the surface of the coat? Can he do that 2 without --
3 THE WITNESS: (Littlefield) That's the situation 4 I would find to be -- I can't conceive of how that could 5 happen, providing that the coat that he is wearing came from 6 wherever he came from. If he's going to be contaminated, ,
7 then so is the coat that he brought with him.
8 JUDGE McCOLLOM: Even if it weren't on him or near 9 him when the got the contamination?
10 THE WITNESS: (Littlefield) That's correct.
11 BY MR. FIERCE:
12 Q Because they would be handling the coat, is that 13 your rationale?
7 14 A (Littlefield) Because the contaminating event 15 would be affecting his coat as well as his body.
16 Q A person at the beach, leaves the beach where the 17 contamination exists, drives to their guest house or motel 18 in the area, grabs their belongings. It's raining when they 19 get to the reception center and they put on a raincoat.
20 The contaminating source was at a different 21 location than where the raincoat was, in that scenario?
22 MR. TROUT: They were at the beach and now it's 23 raining.
24 BY MR. FIERCE:
25 O Ten hours later when they arrive at the reception l
l l Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 CROSS 25637 I
-~ 1 center -- eight hours later when they arrive at the l s- 2 reception center it's raining and they put on a raincoat, 3 which was not in the contaminated area.
4 A .(Littlefield) In that. situation I'would have.to 5 rely on the head' frisk -- the frisk of the. head area as s .6 potentially being the only exposed area, under those 7 circumstances, that may.have contamination.
8 JUDGE SMITH: Are these floor-length. raincoats?
9 MR. FIERCE: Most raincoats are not' floor-length, 10 they're knee-length.
11 BY MR. FIERCE:
12 O While, I understand what you're saying,' Panel, I 13 would like to get this clear for the record. The procedure i
r'% 14 is not to have people remove clothing: coats, hats, gloves, 15 boots; you will monitor them as they come.
16 And I want to just nail down that there is nothing 17 in the plans or procedures that say that directly or l 18 indirectly, is there?
19 A (Cotter) Could you restate.the question.
20 Q Is there anything in the SPMC, the plan or the 21 ' procedures which direct monitors to monitor people as they 22 arrive with the clothing they are wearing and not ask them 23 to remove articles of clothing so they can monitor them in 24 their street clothes?
25 JUDGE SMITH: Is this different from a.similar 1
)
I f
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REBUTTAL PANEL NO. 17 - CROSS 25638 1 question I recall that was --
2 MR. FIERCE: I don't think I got from this panel 3 the statement, I believe it's not in the plans and 4 procedures. They're telling me that's what they do.
5 JUDGE SMITH: Plans and procedures now.
6 MR. FIERCE: But the plans and procedures, I just ,
7 want to make it clear, do not cay this.
8 JUDGE SMITH: I thought it was. answered.
1 ~
9 MR. FIERCE: And part of this contention has to do 10 with plans and procedures, Your Honor.
11 MR. TROUT: And the plans and the procedures are 12 documents that are already admitted into evidence. The SPMC 13 plan volume, the SPMC procedure volume.
l 14 MR. FIERCE: I'm fully aware of that.
15 I just'want to make clear, I don't see anywhere in l
16 those plans or procedures. But if the panel knows. )
17 THE WITNESS: (Cotter) I understand the question l 18 to be: is there any place in the procedures that instructs 19 the monitoring personnel to monitor them as they arrive.
20 BY MR. FIERCE:
21 Q And with respect to coats -- they don't need to 22 ask people to take their coats off? ,
23 A (Cotter) The procedures do not instruct 24 monitoring decon personnel to ask evacuees to remove their 25 coats.
^
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REBUTTAL PANEL NO. 17 - CROSS 25639. ,
g 1 Q I know that. ;
2 But do they affirmatively instruct people in any 3 way, shape or form -- 4 4- JUDGE SMITH: Not to.
5 BY MR. FIERCE:
6- Q -- to monitor as they arrive with the clothing 7- they have on including coats?
8 I know the procedures just say, when a person-9 arrives begin the process, do the head,-the shoulders, the 10 arms and the face?
11 A (Cotter) That's correct.
12 Q But it really doesn't address the outer clothing 13 issue, if I can call it that, does it'?
14 A (Cotter) There is no place in the procedures that O.v 15 tells the monitoring personnel to.ask an evacuee to remove i 16 clothing other than in the decon area after contamination is 17 determined to be on the clothing, and the attempt to decon 18 is made.
19 0 Your procedures are in agreement with the standard
! 20 monitoring procedures, that the probe should be held 21 approximately half an inch away from items being monitored; ,
22 is that correct?
23 A (Cotter) Which standard?
24 You said the question was: your procedures are in !
25 accordance with the standard.
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REBUTTAL PANEL NO. 17 - CROSS 25640 1 Q Well, I happen to be aware of the INPO standard ,
2 and the INPO guideline, which I believe is no more than a !
3 half an inch away, so that's really irrelevant.
4 But what is your procedure with respect to the 5 distance away from clothing or the item being monitored, the l l
6 face if it happens to be skin? .
7 A (Bisson) The procedures states to hold the probe ;
a 8 as close as possible to the individual and not to let the i
9 probe touch the individual skin, hair or clothing. l I
10 Q Is there anything in the training that you're j l }
l 11 aware of that identifies that anymore specifically than you I 12 have just indicated, as close as possible? I 13 A (Cotter) The training is consistent with the 1 14 procedures. i 15 Q As close as possible. )i 16 And when people actually do it, at. ,
p2 have seen l 17 it done in drills and exercises, can you c, Ave me a distance 18 of how far away people are holding the probe when they do 19 this monitoring?
20 A (Cotter) As close as possible, maybe half an inch 21 or maybe closer than half an inch, all depending on the 22 individual doing the monitoring and the area being 23 monitored.
24 1
1 25 Heritage Reporting Corporation 1 (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25641. I 1 Q Are you aware of the'INPO standard which does say.
f d
\ ~
2 that the probe should.be no more than.one-half inch from the 1
source of contamination?
3 4 Is that a . standard that any member of the panel is~
j 5 familiar with?
. 6 A (Littlefield) 'Yes, I have seen that, !tc. Fierce.
7 Q And it's no more than one-half inch? j
~
8 A (Littlefield) That's correct.
9 Q Now the frisk itself,-the-frisk itself, the moving j i
10 of the probe over the various parts of the body. I 11 understand the Panel, according to the Panel's. testimony,.
12 the ORO standard that you believe you can achieve is a 60 13 second frisk.
J
('"' 14 Is that-correct?
15 Forget about the in and out time.
! 16 A (Callendrello) That's correct.
l l 17 Q Am I correct that this is just the frisking 18 process itself?
l l 19 We're not talking about other steps in the l
20 procedure?
21 A (Callendrello) We assume that the monitoring time 22 is 70 seconds for an individual,.or a rate of 70 seconds per 23 individual. Sixty seconds of which is considered to be 24 monitoring time and 10 seconds for an individual to walk up 25 and then walk away.
Heritage Reporting Corporation (202) 628-4888 1
REBUTTAL PANEL NO. 17 - CROSS 25642 1 Q I'm just trying to, for my purposes of taking a 2 person through this, trying to figure out where it is in 3 that process that what you are calling the frisk actually 4 stops.
5 A (Callendrello) That would be the 60 second time.
6 0 In the 60 second time. .
7 But is that at the very end of the procedure when
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8 you get down to -- I think the last step is to monitor the 9 feet. And when that's complete, that's where the 60 seconds 10 ends?
l 11 Or is there some additional time for the monitor 1
12 to lift the probe back up and get it read for the next one 13 in that 60 second period?
14 A (Cotter) The completion of the 60 second frisk is l
l 15 when they bring that individual across the line, which is 16 the final process of monitoring the feet. The last thing 17 that happens is each foot is raised, and the sole of that 18 foot is monitored. And they put that monitored foot, the 19 foot that's verified to be clean, the noncontrolled side, 20 the clean side of the line. And they monitor the second ;
21 foot and bring that across. Once that is done the person is j
22 now clean.
~
23 0 Okay. j 24 Now you told me earlier yesterday, Mr. Cotter, l
25 that at that point the monitor hands a clean tag; is that I
Beritage Reporting Corporation (202) 628-4888 Oi
REBUTTAL PANEL NO. 17 - CROSS 25643 1 correct?
2 A (Cotter) Yes, that's correct.
l 3 Q I'm trying to demarcate here.
4 The 60 seconds is ended and then the clean tag-5 gets handed in another second or two, correct?
. 6 A (Bisson) It's -- I mean there is no sequence of 7 events here. Obviously, the green tag is handed out after 8 the person steps across the line. It could be within one or l
l 9 two seconds as the person starts to walk away.
10 Q Okay.
11 Isn't it reasonable to expect that many of the 12 evacuees at that point might want to ask a question that 13 would at least result in some minor conversation with the l 14 monitoring workers?
15 A question like, what's this you' re just handing l 16 me. Or , am I completely clean, or something about the 17 frisking process.
18 A (Callendrello) I don't know.
19 Q Don't know.
20 Your timing for the 70 second rate overall does 21 not allow for any dialogue at all to occur, correct?
22 A (Callendrello) No, I didn't say that.
23
I don't know whether people will ask questions or 24 not. We have allocated five seconds, or allotted five 25 seconds as the time from when people cross the threshold to Heritage Reporting Corporation (202) 628-4888
REDUTTAL PANEL NO. 17 - CROSS 25644 1 the time they leave the trailer. That's the time we 2 verified in our tests, or actually, the overall time is what 3 we verified in our tests.
4 Q During those test exercises and drills at that 5 stage, at the completion of the monitoring process, the 6 frisking process and in handing out the clean tag card, were .
7 the simulated evacuees engaging any questions of their
~
8 monitoring workers?
9 MR. TROUT: Is the question limited just to that 10 last five seconds?
11 MR. FIERCE: Yes. Yes.
12 MR. TROUT: Not the other 65 seconds.
13 MR. FIERCE: Well, we've been through that stage j 14 of it. There may well have been some interaction at that 15 point as well. But at this point, at the end of the 16 process.
17 THE WITNESS: (Cotter) I don't recall any 18 conversations going on at that point, because the monitoring 19 decon perscanel would issue the clean tag. And as stated in 20 procedure, would direct the evacuee to the door, to the exit
~
21 door leading to the reception center.
22 BY MR. FIERCE:
23 O And the simulated evacuees would not ask, what am 24 I to do next, or anything like that?
25 A (Cotter) As I said, I don't recall any of that Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO. 17' CROSS 25645 l 1 type of discussion going on. The direction was given as.to l
-i ?
\
2 what to'do next. This is a clean tag, and there's the exit l 3 door to the reception center, leading to_the reception .!
I 4 center. )
i 5 0 All right. )
)
. 6 l[ want to ask'you some questions about the 7 frisking process itself. But before I do that, I wanted to l
~
8 get a little more information about'the equipment itself.
9 And-I'm not sure, maybe Mr. Littlefield is the one.
10 I understand that the plan is to use the 11 Bircon(sic) frisk tech meter with an APTEC, I think it's .j
,)
12 often called an FT-126 (b) probe.
13 Is that correct?
14 A (Littlefield) I'm not sure about all those 15 designations, but it's called the APTEC probe.
]
16 Q- Okay, 17 l I'm sometimes seen it describe as a Geiger-Mueller _j 18 tube.
19 A (Littlefield) Yes.
20 0 What is a Geiger-Mueller tube? I
~
21 A (Littlefield) It's just a particular radiation I 22 detection device, one of thu means of detecting radiation. ,
23 Q Now I understand the APTEC probe works together 24 with.the Bircon meter. ,
25 Can you describe the difference between these two'
("
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REBUTTAL PANEL NO. 17 - CROSS 25646 1 pieces of equipment?
2 A (Littlefield) Well it's the Bicron meter. The 3 probe itself --
4 Q Bicron, is that right?
5 A (Littlefield) Bicron, yes.
6 The probe is actually the radiation-sensitive .
7 device. And it contains the Geiger-Mueller counting portion
~
8 of the instrument.
9 The meter is simply there to count the number of 10 pulses that the probe detects. So the meter is nothing more 11 than just a count device, if you will, whereas the 12 radiation-sensitive instrument is in the probe.
13 Q Can you briefly describe for us the size, the 14 shape of first the probe and then the meter?
15 A (Littlefield) Well, the probe is roughly a little 16 over four inches, I guess. Pretty much a square probe, 17 containing something in the order of 126 square centimeters 18 of surface area. '.'.t has a GM, Geiger-Mueller detection 19 system covered by a thin window.
20 The meter itscif is pretty much a standard count 21 rate meter with a scale indicating the counting rate. It 22 has an alarming device, an adjustable alarming device that 23 you can set to alarm. It has several scales, up to zero to 24 500,000 counts per minute that you can set the meter on. ,
25 Is that the kind of information you want? j I
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1
.f REBUTTAL PANEL NO. 17 -' CROSS 25647~
1 O Yes. 'I'm still a little bit unclear on the probe. l j
(
\ 2 JUDGE McCOLLOM: What about the -- is there a- 1 3 cable that connects the probe to the meter?- 1 4 THE WITNESS: (Littlefield)' 'Yes, there is. ;
5 JUDGE McCOLLOM: LHow'long is that cable,
- \
. 6 approximately? ,,
7 THE WITNESS: (Littlefield) Oh ,' 'I'd say I l
8 approximately -- i 9 .THE WITNESS: '(Cotter) To answer that, I thinkf d
4 10 it's about three and a half feet. We had some longer cables' 11 made up. Early,on in that drill _ process, we identified the _
12 existing cables were too short.
'l 13 BY MR. FIERCE:
/" 14 Q You' described the probe as.being about four and'a- a 15 half inches square?
I 16 A (Littlefield) Yes.
17 Q That's one dimension for me.
18 In three dimensions, what does this thing look 19 like?
i 20' Sometimes we think of a probe as having a baseball !
21 bat type shape, or I'm not sure what this looks like and how 22 it's held.
23 A (Cotter)- Maybe I could describe it for you. 1 24 Again, the size of the probe is about four and a-25 half inches square. In height,.it's maybe an inch tall, and-i Heritage Reporting Corporation '
l (202) 628-4888 l . _ _ _ - _ _ _ _ _ - _ _ _ - - _ - _ _ _ -
REBUTTAL PANEL NO. 17 - CROSS 25649 1 Is that correct?
2 A (Bisson) Well, the rate in IP-2.9, Step 5.4.3, 3 which is the general description of this frisk, the rate 4 isn't given there.
5 However, on the next page at Step 5.4.4 where it
, 6 talks about frisking of special populations, that the rate 7 is listed two to three inches per second there. And also 8 the half-inch away from the surface is also indicated.
9 Q And by the way, it's an identical procedure for 10 monitoring whether you are in the trailer or whether you are l 11 out in the special facility buses. It's the same equipment, 12 same distance away, same inches per second, although the 13 people are out on the buses, I understand that.
l 14 A (Bisson) The same equipment, the same rate and
! 15 the same distance is used for both populations.
I 16 However, the frisk for the special populations is 1
17 limited primarily to the head, shoulders, hands and feet, 18 whereas inside the trailer the torso and back and legs are t
l 19 also included.
I 20 0 Okay.
21 Now is the Panel aware of the document that was 22 attached to the testimony of Ms. Sneider at the back, a FEMA 23 memorandum which indicated that FEMA had a standard for 24 monitoring individuals that was based on, I believe, I think 25 it was either 33 or 40 individuals per station per hour?
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REBUTTAL PANEL NO. 17 - CROSS 25650 1 Is the Panel aware of that FEMA standard? ,
2 A (Callendrello) Your question was were we aware of l 3 the document.
4 I am aware af the document. I have seen the 5 document.
6 Q And you are also aware that from Mr. Donovan, I ,
7 believe, that that standard was based on 180 inches to t
8 monitor assuming a standard size adult and moving a problem {
d 9 approximately two inches per second? )
10 It was a 90 second assumed frisk rate. l 11 A (Callendrello) There is more that goes into that 12 than just the size of somebody. It was the type of 13 instrument that was assumed.
14 Q Right.
4 15 A (Callendrello) That was a civil defense type of 16- instrument.
17 Q And that their standard was based on a different 18 instrumentation than you use?
19 A (Callendrello) Correct.
20 0 And I understand that, there has been discussions 21 between New Hampshire Yankee and FEMA, perhaps directly with 22 Mr. Donovan, over the use of the instruments you have just 23 described and obtaining from FEMA its approval of the use'of 24 that instrumentation to produce monitoring rates per hour 25 which were higher than their standard, because you are using Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25647
.l 1 Q Yes. I'm still.a-little bit' unclear on the probe. '
(
\m/
x) 2 JUDGE'McCOLLOM: What about-the.-- is there.a 3 cable that: connects the probe to the meter?-
4 THE WITNESS: (Littlefield). .Yes, there is. j
.. i 5 JUDGE McCOLLOM: How long is that cable,' j j
.. 6 approximately?
)
7 THE WITNESS: - (Littlefield) Oh, : I' d say l i
8 .approximately -- I
! 9 THE WITNESS: . (Cotter) . To answer that, I think- ,
l 10 it's about three and a half feet. We had some longer cables 11 ~made'up. Early on in that drill process, we identified'the- i l
12 existing cables were too short. >j 1
13 , BY MR. FIERCE: .
~'
/""' 14 Q You described the probe as being about four and a k
\ 15 half inches square? 4 16 A (Littlefield) Yes. >
17 Q That's one dimension for me.
18 In three dimensions, what does this thing look 19 like?
h 20 Sometimes we think of a probe as having a baseball 21 bat type shape, or I'm not sure what this looks like and how 22 it's held.
. l 23 A (Cotter) Maybe I could describe it for you. j 1
24 Again, the size of the probe is about four and a (,
25 half inches square. In height, it's maybe an-inch tall, and i l Beritage Reporting Corporation N- (202) 628-4888 l
REBUTTAL PANEL NO. 17 - CROSS 25648 1 attached to the top of that is a handle much like you might 2 see a handle on the top of a suitcase or a briefcase, a 3 small handle which the probe is held by.
4 Q New can you briefly describe for me how then this 5 hand-held probe is used in the monitoring process?
6 It's a one-handed device that is brought within, .
7 as you've described it earlier, as close as possible to the 8 body, and then moved over the body at that same distance 9 away, correct?
10 A (Cotter) That's correct.
l l 11 Q And contouring the body as you go with your --
l 12 A (Cotter) That's correct.
13 Q Okay.
14 How many inches per second are you moving the 15 probe?
16 (Witnesses review document.)
17 A (Cotter) It's moved about two to three inches per 18 second.
19 Q Is that the instruction that is given to the l
20 workers, about two to three inches per second?
21 A (Bisson) When you say " instructions", do you mean 22 from the procedure or the verbal instructions?
23 Q Well, I, frankly, didn't see it in the procedures.
24 But I believe, if my memory servec me right, might have seen 25 it in a trsining manual.
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REBUTTAL ~ PANEL NO.'17 --CROSS 25649 .o f-s 1 Is:that correct?
.i
\ 2 A (Bisson) Well,,the rate in:IP-2.9,. Step 5.'4.3,1 j 3- which is~the general description of this frisk,-the rate 4 isn't.given there.
5 However, on the next.page at Stepi5.4.4 where-it'
. 6 talks about frisking of'special populations,;that the rate 7 is listed two to three. inches per second there. Land alsos 8 the half-inch away from the surface is also' indicated.
9 Q And byzthe way, it's an identical procedure for 10 monitoring whethwc you are in'the' trailer or whether youlare 11 out in the special facility buses. It's-the same equipment, 12 same distance away, same inches.per second, although'the 13 people are out on the buses, I understand that.
f 14 A (Bisson). The same equipment,:the same rate and 15 the same distance is used for both populations.
l 16 However,.the frisk for the special populations is l
l 17 limited primarily to the head, shoulders, hands and feet, 18 whereas inside the trailer the torsofand back and legs ~are 19 also included.
20 Q Okay.
21 Now is the Panel aware of the' document that was 1 1
22 attached to the testimony of Ms. Sneider at the back, a FEMA h
23 memorandum which indicated that FEMA had a standard for 24 monitoring individuals that was based on, I believe, I think >
25 it was either 33 or 40 individuals per station per hour?
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_ _ _ _ . _ _ _ __ _ . _ . _ _ __ _ __ .___=_____ _______________j
t REBUTTAL PANEL NO. 17 - CROSS 25650 j
1 Is the Panel aware of that FEMA standard?
2 A (Callendrello) Your question was were we aware of 3 the document.
4 I am aware of the document. I have seen the I I
5 document.
6 O And you are also aware that from Mr. Donovan, I , ;
7 believe, that that standard was based on 180 inches to 8 monitor assuming a standard size adult and moving a problem 9 approximately two inches per second? !
I 10 It was a 90 second assumed frisk rate. l I
11 A (Callendrello) There is more that goes into that 12 than just the size of somebody. It was the type of 13 instrument that was assumed.
14 Q Right. i 15 A (Callendrello) That was a civil defense type of 16- instrument.
i i 17 Q And that their standard was based on a different <
18 instrumentation than you use?
19 A (Callendrello) Correct.
20 0 And I understand that, there has been discussions 1 l
l 21 between New Hampshire Yankee and FEMA, perhaps directly with '
22 Mr. Donovan, over the use of the instruments you have just
~
23 described and obtaining from FEMA its approval of the use of 24 that instrumentation to produce monitoring rates per hour 25 which were higher than their standard, because you are using
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REBUTTAL PANEL NO. 17 CROSS 25651
.- f
~
s 1 that instrumentation, correct?.
s 2 A (Callendrello). Yes. FEMA' accepted our monitoring 3 rate because of the combination of equipment'that we use,
- 4. although Mr. Donovan, I think, testified more. completely-as 5 to exactly what the_ process was.for evaluating that.
6 Q Now as I understand-it, the SPMC's, monitoring 7 procedure for individuals:in the trailer is in IP-2.9 at-8 Section 5.4.3.
9 Is that correct, Panel?
1 10 A (Bisson) That's correct. j J
11 Q Has anyone, to your knowledge, at New Hampshire 12 Yankee or elsewhere totaled up the number.of inches that'the j 1
13 monitor needs to pass over in order to complete this i 14 monitoring procedure on an average-sized adult?
( :
15 A (Callendrello). If you just give us a moment, l l
16 we'll check that. !
l 17 At first thought nobody can recall any, but we' )
18 would just like to check and make sure.of the complete- s 19 answer.
20 (Witnesses review document. )
21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25652 1 MR. TROUT: Mr. Fierce, could you repeat the 2 procedure that you are citing?
3 MR. FIERCE: 5.4.3 in Implementing Procedure 2.9.
4 (Witnesses confer.)
5 THE WITNESS: (Bisson) The 180 linear inches is 6 referred to in the technical justification that you just .
'7 cited as attachment to Ms. Sneider's testimony.
~
8 BY MR. FIERCE:
9 Q Where FEMA got its basis for the calculation of a 10 90 second frisk came from a 180 inch circumference of an 11 average size adult?
12 A (Callendrello) No.
13 What Mr. Bisson is referring to is a document 14 entitled " Technical Justification" that I think Ms. Sneider 15 referred to in her testimony, which is a document that New 16 Hampshire Yankee produced.
17 And in it we refer to, the statement says, "For 18 monitoring /decon purposes, the standard frisk entails 19 movement of the probe approximately 180 linear inches 20 encompassing the face, head, shoulders, hands, elbows, knees 21 and feet in a circular pattern about the body."
22 O That's a standard frisk that is used -- those 23 numbers are used in the FEMA analysis and just standard 24 calculations.
25 My question to you is different than that, l Heritage Reporting Corporation l (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25653
-% 1 however. My question is, has anybody ever taken your 2 procedure for frisking and totaled up the number of inches j.
3 it entails?
4 MR. TROUT: Mr. Fierce, are you asking the Panel 5 whether someone has gone out with a tape measure and l
. 6 measured people's elbovs?'
7 MR. FIERCE: Yes. W 8 THE WITNESS: (Callendrello) No.
i 9 JUDGE SMITH: May we have the question before the i
10 last question, please? i 11 (Accordingly, the record was played back by l
12 the court reporter.) i i
13 BY MR. FIERCE:
14 Q Panel, --
Ei t
15 MR. TROUT: I'm going to object to the question, 16 Your Honor, having had that read back. )
i 17 It seems implicit in Mr. Fierce's question is the 18 assumption that the route that Applicants take to frisk 19 people is different from standard procedure, and I'm not 20 sure that he's established that assumption at all.
21 MR. FIERCE: Well, they haven't done the 22 assessment to determine whether they have a standard number 23 of inches. I think that's what I want to get into right 24 now, Your Honor. Let's see if they do.
25 JUDGE SMITH: All right.
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REBUTTAL PANEL NO. 17 - CROSS 25654 1 So you withdraw that question for the time being?
2 MR. FIERCE: No, the question stands. They say 3 they haven't --
4 JUDGE SMITH: All right.
5 HR. FIERCE: -- gone through the process of 6 totaling up the inches in their procedure. .
7 THE WITNESS: (Callendrello) No. But I think 8 where the confusion -- I started to answer that question.
9 The confusion is you say we do something than the standard 10 frisk. At least in my experience what we do is the standard l 11 frisk.
12 BY MR. FIERCE:
I 13 0 I'm not assuming you do anything different. I 14 just wanted to know if you had done any assessment to see if 15 you had a standard number of inches in your procedure.
16 You said you hadn't, and let's explore that.
17 A (Callendrello) The standard is not the number of 18 inches. The standard is the technique: the areas of the 19 body and the flow of the frisk. It's not - you don't try 20 to achieve a standard of measuring 180 inches. You try to 21
- cover the body in some standard frisk way.
22 And I'll defer to the experts on health physics.
23 I'm just relating from my experience working in nuclear 24 power plants.
25 Q I note on your procedure a note below Item B in Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL.NObl70- CROSS: 25655 l
. /~ 1 5.4.3. We've:already talked aboutcItems:A and:B, I.believe, ,
2 and that you are not letting;the probe _ touch the 1 3- ' individual's skin'or hair;or clothing..
4 And the note'readsi "During initialisurveyffori
'5 gross contamination, the< frisking should focus on the areas s
. 6' s of .the body 1that are mosty likely to . be:. contaminated, 'i.e. , .
7 head, face,' shoulder,. buttock, hands and; feet."
~*
l 8 I understand thatito be just alnote,:that those.
9 are the areas to. focus on.- But that the procedure'isaset'-
10 forth below that in Items 15through 5.
11 Is that correct?
12 (Witnesses confer.)
13 A (Cotter) I believe the note.is justiidentifying 3 1
14 to a person reading the procedure those areas that,are more= J 15 likely to become. contaminated on an evacues.
16 O When you get out to the buses with'the special 17 facility evacuees, you reallyrare doing a procedure that' 18 looks much like that note, focusing.on those.
19 But for the trailer, you are-doing this procedure 20 1 through 5 below, correct? ,
21 A (Callendrello) No..
22 I think what Mr. Cotter said is that-the procedure 23 is outlined in 1 through 5. What the note identifies are ;
I 24 those areas that a monitor should be aware'of are the'likely-l 25 areas, or the most likely areas to be contaminated. !
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l REBUTTAL PANEL NO. 17 - CROSS 25656 I 1 Q Fine.
2 Now'the first step is frisk the individual's head, 3 face and shoulders. l 4 Can you tell me how that is done by your people if 5 it's done in any particular standard way?
l 6 A (Cotter) Yes, the probe would be placed as the , !
l 7 individual approached the monitoring station. The probe !
8 would be placed typically from one shoulder, and it's a 9 large enough surface area that that probe would then be 10 moved from the shoulder across the top of their head and 11 down to the other shoulder.
12 Q Okay.
13 A (Cotter) And then brought back across the front
. 14 of the face.
15 Q Now does that cover the back of the head or not?
16- A (Cotter) The back of the head would be covered 17 when the individual turns around, and is asked to turn 18 around.
19 0 I see. Okay.
20 Well, let me just see if I've got you right.
21 It's one shoulder, around the top of the head, the
- 22 other shoulder and then back across the face.
23 Is that what you just said?
24 A (Cotter) That's what I just said, yes.
25 Q Okay.
l f Heritage Reporting Corporation (202) 628-4888
H REBUTTAL PANEL NO. 17 - CROSS 25657' l 1 Are you about a standard-sized individual, Mr. 1
[
2 Ootter?
'3- I don't'know how tall you are,-but what's'a-
~
4 standard-sized individual? 5'8"? 5'9"?
5 A . (Cotter) - I; don't know what that is.
._ -6 Q Well, a shoulder would.be;-- can we say,six, inches 7 for a shoulder?
8 Does that sound reasonable?
9 A (Cotter) Sure, it sounds reasonable.
10 0 I have a measuring tape if you want to check.
1 11 JUDGE SMITH: No.
12 BY MR. FIERCE:
13 Q Six inches for a shoulder? 'l 1
14 JUDGE SMITH: No, we're not going to measure.
i
15 MR. FIERCE: Okay.
i 16 BY MR. FIERCE:
17 Q Around from the point where the shoulder meets the 18 neck, around the top and back to the next's shoulder, 24 19 inches?
20 JUDGE SMITH: Okay. Twenty-four.
21 MR. FIERCE: Twenty-four inches sounds reasonable. '
22 BY MR. FIERCE 23 O And another shoulder is another six inches, 24 correct?
25 Assume we have the same size, both sides.
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i REBUTTAL PANEL NO. 17 - CROSS 25658 1 A (Cotter) Sounds correct. f 2 Q Okay. -
3 A face, how many inches is that going to be now?
4 A (Callendrello) Mr. Fierce, are we assuming 5 adults?
Ij l
6 Q Normal size adults. - j l'
7 JUDGE SMITH: This is a reference.
8 THE WITNESS: (Callendrello) Adults. So we have 1
9 eliminated the children, okay.
10 BY MR. FIERCE:
11 Q For this calculation, we're talking a normal size 12 adult.
13 A face, six inches?
l 14 A (Cotter) If you're talking about travel of the --
15 what are you talking? The size of the face? I don't know.
16 About six inches.
17 Q Yes, the number of inches you are going to cover.
18 I guess you are sweeping from one side to the other.
19 A (Cotter) Oh, that's a different question.
20 A sweep of a face area would travel about zero l 21 inches, because the surface area of the probe would cover l 22 approximately the whole face. If you put the probe up to my 23 face, for instance, there would have to be no movement at 24 that point.
25 Q The probe is only four and a half inches square.
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REBUTTAL PANEL NO. 17 - CROSS 25659- l
-i
, 1 The face is a little bigger'than'that,-can'we assume?. 1
('
2 Maybe a face'is six inches by 10l inches or
'I 3 something like that.
I 4 Okay, but it's one movement. .You're-not covering' l 1
5 the top and the bottom of,the face?- ,
l 6 A (Cotter) No,.there 'is nothingjin the. procedure ;
7 that directs them to go from the top to the bottom of-the 8 face.
9 O The procedure then says, " Scan the remainingJfront
-'I 10 of the body, including the legs from top.to bottom using a 11 single sweep."
12 Can you show me how that would be done,'Mr.
13 Cotter, or tell me where that begins and where that ends?
1 14 A (Cotter) From the head:and shoulders, it would i 15 move down one arm, down to the hand area.
1
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16 0 Well, it says, . . . individual's head, face and 17 shoulders. Scan the remaining front of the body,' including 18 the legs from top to bottom using a single sweep."
19 So you are saying from the face I now go to an 20 arm?
21 A (Cotter) Well, as the procedure states, the.
I 22 individual would be standing with his palms facing forward. i l 23 0 Yes.
I 24 A (Cotter) Not out to the side like you see, but 25 ~ closer into the body.
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REBUTTAL PANEL NO. 17 - CROSS 25660 1 Q Okay.
2 A (Cotter) The arms are still part of the body.
3 Q Right.
4 A (Cotter) We would try to monitor the front 5 portion of that arm by moving the instrument down that arm. ;
6 Q So from the face, I go down the arm. ,
7 All the way to the hands?
8 A (Cotter) To the hands, yes. ;
9 0 And include the hands?
10 A (Cotter) The hands are included, yes.
11 Q Okay,,
12 On the front side of the arm.
13 A (Cotter) Yes. j 14 Q Can you give me a rough estimate of how many !
i 1
15 inches you would cover that from - you've already done the 16 shoulder so don't include that. Just the arm down to the '
17 hands, including the hands.
18 Would that be 24 inches? I don't even know on i
19 this one. l 20 (Pause . )
21 BY MR. FIERCE:
- 22 O Mr. Cotter, we just figured out that this is 23 probably an average-sized shirt sleeve. I happen to be 24 about a 30 or a 31 on a shirt sleeve.
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25 JUDGE McCOLLOM: Yes, but are you a standard man?
E l Heritage Reporting Corporation (202) 628-4888 I
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j-REBUTTAL PANEL NO. 17 - CROSS 25661 f- 1 (Laughter)
.i
\~. 2' MR. FIERCE: I may be oversized, Your Honor.
3 BY MR. FIERCE:
4 Q You want to use a smaller number.than that?
5~ . Thirty inches?
. 6 JUDGE SMITH: He'doesn't want to.use'any number.
7 You are the one that wants to use them.
8 MR. FIERCE: Well, I'm not going to quibble with-9 the' panel over.these.- I.just want some reasonable length 10 for an arm.
11 JUDGE SMITH: Not including the hand.:
i 12 MR. FIERCE: I think he said including the hand.
13 BY MR. FIERCE:
( 14 Q You go down the arm, including the open palm of' 15 the hand, correct?
16 A (Cotter) That's correct.-
17 Q And so that's what I just measured on my -- it was 18 30 inches. I think the normal shirt sleeve must measure it 19 some other way, because I seem to buy shirts.that are 30/31.
20 JUDGE SMITH: It goes from the middle of the back 21 down to the wrist.
22 BY MR. FIERCE:
l 23 Q Well, can we say 30 inches?
24 A (Cotter) If you want to say 30, sure, that's 25 fine, l'
-( Heritage Reporting Corporation (202) 628-4888:
i REBUTTAL PANEL NO. 17 - CRO3S 25662 1 Q Is that a reasonable number for a standard size 2 arm, Panel?
3 A (Callendrello) I think said we don't know what 4 the standard dimensions are for an adult.
5 Q Where do you go from there then with the probe?
6 You've done the -- we've been pointing to'the left .
- / arm. l 8 What's the next movement?
l 9 A (Cotter) The next movement would be the other i 10 arm.
11 Q Same procedure?
12 Start at the top. Move down to the hand in one 13 movement; is that correct? j l
14 A (Cotter) Yes, that would be correct. i 15 Q Okay.
16 Then what next?
17 A (Cotter) Now is the scan of the remaining front 18 portion of the body in a single sweep, which brings it from 19 the chest area, which is below the head and shoulder. We've 20 already done the head and shoulders. And then a movement 21 straight down, straight down the body to the feet.
22 Q Standard size adult let's assume if 5'8". Five 23 feet would be 60 inches.
24 Something less than 60 inches from the chest, 25 would you say? Maybe 55 inches?
l Heritage Reporting Corporation (202) 628-4888 1
REBUTTAL PANEL NO. 17 - CROSS 25663 1 A (Callendrello) I'm sorry.
2 Where are we now?
3 Q I think we're trying to measure - .we'll just get 4 a number of what a reasonable figure would be for the 5 distance from the top of the chest area down to the -- where
. 6 is the end point on this one, Mr. Cotter?
7 A (Cotter) This goes straight down to the feet.
8 O Covers the feet as well?
9 A (Cotter) That's correct.
10 Q So it gets down to the bottom. Then would go out 11 across the feet.
12 Well, if we get down to the ankle, we may have 13 gone, let's say, 55 inches. And then the foot would be 14 another what?
15 Eight inches?
16 A (Cotter) I'm not aware of a standard man's foot 17 dimensions.
18 Q Subject to check on all of this.
19 Now does that cover both feet in that one 20 movement, or just one of the feet?
21 A (Cotter) Feet as described in the procedure.
22 0 I thought the feet didn't get scanned until the 23 fifth step in the procedure, after having done the back 24 side.
25 Are you telling me the procedure that's actually Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25664 !
1 used is somewhat different than is described here?
2 A (Cotter) No, that's not what I'm telling you.
3 0 Okay. This says, " Scan the remaining front of the 4 body, including the legs, from the top to bottom using a 5 single sweep."
6 But I see an Item 5, that the frisk of the feet is -
7 left for last.
8 A (Cotter) Typically, when the frisk of the foot is 9 done as in Step 5, the individual is facing away from the 10 monitor.
11 Q So you are really focusing on the bottom of the 12 feet at that point.
l 13 A (Cotter) That's correct.
14 Q Okay. '
15 So this scan from top to bottom would cover the 16 top of the feet as well.
17 Is that what you are telling me?
18 A (Cotter) Yes.
19 20
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21 22 23 2-4 25 Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO. 17 - CROSS 25665 'j
, 1 Q Then, and I ask you the question, does that cover
(
l- ( 2 both -- you do two movements to' cover each -- top of each-l 3 foot or is that just all done in one?
4 A (Cotter) The procedure indicates to' instruct the 5- individual with the' legs -- to stand with palma' facing out
. 6 and legs close together, and with legs close together the j 7 ' feet can be done'in a single sweep. . i 8 0' Legs close together, but not touching? ] 3 9 A (Cotter) That's correct.
10 Q And this four and a half' inch probe can do both
.i 11 feet at once. Doesn't.that seem a little impossible;'Mr. ]
12 Cotter? To be no more than a half inch from each foot 13 simultaneously with a four and a half inch probe covering 14 both feet?
15 (Witnesses conferring.)
16 THE WITNESS: (Cotter) There may be slight .
l 17 movement from one shoe to the other if the individual's feet {
18 are not close enough together to monitor both of them.
19 BY MR. FIERCE:
- 20 Q So if the top of the foot is roughly eight inches 21 we might get that in there twice? Covering that distance l 22 twice, one for each foot? That's seem logical.
23 I'm trying to get you to agree with that.
24 A (Cotter) Well, actually, the logic of the 25 individual having to drag the probe all the way across one
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REBUTTAL PANEL NO. 17 - CROSS 25666 1 foot and then come bach and start on the other, that I 2 disagree with. They would bring it down and actually could 3 really just move the probe from side to side as they pass 4 over the couple of inches of foot surface.
5 Q A back and forth kind of movement?
6 A (Cotter) And "S" type of movement. .
7 Q "S" type of movement?
~
8 A (Cotter) From side to side.
9 Q According to the procedure the next step is s'ept 10 number 3 which is to frisk the elbows and buttocks; does 11 that require turning the person around?
12 A (Cctter) Yes, it does.
13 Q So the person is asked to turn around, and they l
14 turn around, and the probe is then moved to each elbow or !
15 does it go from the elbow to the buttocks to an elbow?
l 16 A (Cotter) Typical 3y, the individual when turned 17 around the monitor would start at the top of the head -- not j 18 at the top, but the direct back portion of the head, which l
19 he has already done the top surface of the head. l l
20 Q Right. l l .
f 21 A (Cotter) Starts from the back, moves down across j 22 one shoulder, straight down to the elbow and hand. Brings 23 it back to the center of the shoulder blade and brings it 24 back down to the other elbow and hand.
25 Q All right.
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REBUTTAL PANEL NO. 17 - CROSS 25667
<w '1 So you do the whole backJof the arm just like i
2 you've done the front of the arms; correct?- I 3 A (Cotter) Yes.
4 LQ ~ All right.
l 5 And then what?
. 6 A (Cotter): And'then we drop from the back straight 7 down to the feet again.
8 Q Okay.
9 So that's how.you pick up the buttocks' . It's not 10 a separate step, it's just part of-the movement-from the top; 11 to the bottom? g 1
12 A (Cotter) None of the highlighted areas are 1 l
13 separate steps. It's just an indication to the monitor'to
(T 14 pay close Atter. tion to these areas that are more likely to !
N ,) 15 become contaminated.
I 16 0 As I read your steps 3 and 4 it sounds to me like 17 those are essentially merged,'the procedure for the back 18 that you just told me?
1 19 A (Cotter) Would yon repeat the question.
20 Q As it's set forth in the procedures it makes it-
~
21 look like the elbows and the buttocks are a separate step.
22 I'm just noting that it sounds to me like the 23 procedure you just described includes the elbows and the 24 buttocks in the scan of the back that you just described, 25 the arms -- scanning the arms would include the elbows,
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REBUTTAL PANEL NO. 17 - CROSS 25668 1 scanning from top to bottom along the back side would a
2 include the buttocks.
3 So you have essentially compressed steps 3 and 4 4 in that fashion?
5 A (Cotter) That's correct.
6 As I already stated, it's identifying the areas to ,
7 pay particular attention to.
8 Q Now, the person is, at that point, facing away 9 from the monitor. What's the next step?
10 You've gone down, I guess, all the way to the 11 floor at the heel of the individual, essentially?
12 A (Cotter) That's right.
13 The individual is asked to raise his right or left
, 14 foot depending on the monitor's desire at that point. That 1 <
15 foot is raised and the probe is put to the sole of that foot 16 to identify contamination on the foot. If it's identified 17 as clean the foot is then placed on the clean side, so he is 18 asked to put the foot on the clean side and raise the other 19 foot. He would raise the other foot, put the probe on the 20 second foot, and then asked to put that on the clean side, 21 also. So that's the movement across. ~
22 Q This is the movement along the sole of the shoe or 23 boot or whatever we have here?
24 A (Cotter) That's correct.
25 0 Okay.
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REBUTTAL PANEL NO. 17 - CROSS 25669
, 1 Whatever a standard size boot or shoe would be, 1
2 they cover that distance twice. It's not one movement, it's 3 two because they do it one at a time?
4 A (Cotter) They monitor the soles -- the sole on 5- the right foot and on the left foot.
, 6 Q By the way, is this a point at which many of the 7 evacuees grab the rail for support while they're standing on 8 one leg?
9 A (Cotter) That's correct.
10 Q Now, as they step across the line then are they --
l 11 with one foot, are they still facing backwards, so to speak, 1
) 12 or ic it now kind of a sideways?
l 33 A (Cotter) That's really not specified in the 14 procedure.
l 15 Q They manage it somehow or another.
16 And at that point, however, whatever their 17 position, the evacuee is facing away from the monitor; 18 correct?
( 19 A (Cotter) Yes, that's correct.
20 Q And at this point the frisk ends and the monitor says, here is our clean tag or what, what is the procedure?
21 22 You're clean?
23 A (Cotter) Typically it will be, you're clean.
24 This clean tag will get you into the reception center.
25 Q Now, is that procedure modified in any significant Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25670 1 way for children? I know the distances differ, but is that 2 the procedure?
3 A (Bisson) The monitoring?
4 Q Yes.
5 A (Bisson) It would be the same for the children-l 6 Q Now -- .
3 7 A (Callendrello) Mr. Fierce, again, with the l
8 exception of that children that are carried on, as we 9 discussed yesterday.
i 10 Q Right, j 11 Now, assuming we did have an individual who did I
l 12 come to the frisking station with some hand carried !
13 articles. Let's talk about purses first; and then let me 14 talk about handbags or overnight bags.
15 But a purse, would the monitor ask the individual 16 to take the purse out of their hand or off their shoulder or 17 wherever it was and set it down as the frisk occurred or l 18 would it be monitored as part of the frisking process?
I 19 A (Cotter) As part of the frisking process the 20 articles would have to be hand carried as identified earlier 21 in the procedure, and they would be monitored in hand.
22 Q If a woman was carrying a purse in hand, she would 23 have it and when the monitor went down the arm he would 24 continue the probing movement around the purse; is that how 25 it would be handled?
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REBUTTAL PANEL NO. 17 - CROSS- .25671
-w 1 (Witnesses conferring.)
k/ % 2 THE WITNESS: (Cotter) Yes.
~
As the monitor would-3 continue to go down the? arm he would continue right.down the 4 surface.
5 BY MR. FIERCE:
. 6 Q So it's not two steps: it's not monitor the person 7 and monitor the purse, it's'all included in the' process in 8 one monitoring process?-
9 A (Cotter) That's correct.
10 Q How about a handbag, excuse me, an overnight bag 11 that'would be in the form of a small suitcase or, perhaps, a 12 daffel bag kind.of bag; would that be handled in the same j 13 way, the person would be holding it or would they' set it li 14 down for subsequent monitoring?
15 A (Cotter) Again, as the procedure indicates ]
16 earlier on the articles would be hand carried, and there-17 would be just that hand carried.
18 Q So even though I see it as Procedure C here as 19 5.4.3 which comes after the monitoring procedure forithe i
20 individual, you' re telling me again it's merged? The
~
21 articles are frisked along with the body in the process of I 22 monitoring the individual; is that correct? j i . ;
23 A (Cotter) That's correct.
24 Q If it is a small overnight bag in the shape of a l
25 small suitcase, would both sides of the suitcase be g Heritage Reporting Corporation
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REBUTTAL PANEL NO. 17 - CROSS 25672 1 monitored?
2 A (Cotter) Yes.
3 Q And the bottom would be monitored?
4 A (Cotter) Yes, they would monitored, both sides.
5 And if there was a bottom where it was likely put down it 6 would be monitored. .
7 Q How about a piece of clothing that an individual
- I 6 may be carrying over an arm such as a sweater, a jacket; how 9 would that be handled?
10 A (Cotter) That would be our hand carried article 11 which would be held in the hand and monitored in the same 12 process as we have just described.
13 Q The same thing true for an umbrella? i I
14 A (Cotter) Yes, if an umbrella was carried in that l 1
15 would also be a hand carried article.
16 0 Could an umbrella be monitored in one sweep of the 17 probe and determined whether the umbrella had any 18 contamination?
19 Maybe Mr. Littlefield knows.
20 (Pause)
\
21 MR. FIERCE: Let me withdraw that question.
I 22 BY MR. FIERCE:
23 Q An umbrella, if it had been opened in the EPZ to a 24 rain which was a contaminating rain and then were folded and 25 carried into a monitoring trailer, you could detect the i
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REBUTTAL PANEL NO. 17 - CROSS 25673 f-~s 1 radiation on~the umbrella fabric'while.it was folded up, my 2 could you not?
3 A (Littlefield) Yes,- you'could.-
4 Q And the next question is: can you then monitor 5 that umbrella in one' sweep from one end to.the other?
6 A (Littlefield) .Yes.
7 0 In addition to moving the probe over each of'the' 8 parts of the body that we have just. described, the process-9 will entail some mevements, nonmonitoring movements, if we 10 could call them that, just to reposition'the_ monitor-to.get 11 another swipe in; isn't that correct?
12 And I can give you an example: when you go down 13 the body in the front'to the feet and do the feet with.your 14 little S-movement and you tell the person to turn around, t
15 you move the probe back up and you start again back up at 16 the back of the arms; correct?
17 I mean, it's only logic. My question-really is:
18 can that movement be accomplished as fast or faster than the 19 person can turn around?
20 A (Cotter) Can the monitor stand up as fast as the 21 evacuee can turn around?
22 Q Yes.
~
23 A (Cotter) I eould assume.
24- Q Do you know how long it takes the evacuees on 25 average to turn around? !
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REBUTTAL PANEL NO. 17 - CROSS 25674 1 A (Cotter) I've never done studies, personally, to 2 verify that, no.
3 0 Two seconds?
4 A (Cotter) Again, I haven't done studies. Two 5 seconds would seem a little bit high to me.
6 Q When you move down one arm to the hand and then ,
7 move the probe back up to move it down the other arm, does 8 that recovery stroke take a second?
9 A (Cotter) Again, I never took independent 10 measurements of these individual sequence of strokes.
11 Q New Hampshire Yankee hasn't done any studies or 12 estimates of how many people or what percentage, really, of 13 the population who would be arriving at monitoring trailers 14 would be carrying purses or overnight bags, have they?
15 A (Callendrello) No, we have done no studies.
16 Q Okay.
17 Let's assume in the process of monitoring an 18 individual the monitor goes off, what does it sound like?
19 A (Cotter) To the monitor? It sounds like a high 20 pitched tone.
21 Q And how loud is it? '
22 A (Cotter) I have never taken a decibel reading.
' ~
23 24 25 l
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REBUTTAL PANEL NO. 17 CROSS 25675 !
1 A (Callendrello) The confusion, Mr.' Fierce,'maybe l 1 i 2 you're not aware. -The monitor is wearing headphones. So j l
3' it's not audible to the individual being monitored. -
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'l 4 0 Oh, I'm not-aware of this. l 1
5 A (Ca11endre11o) It is only audible in the
. 6 headphones.
7 Q Okay.
8 So the individual being monitored.would'not hear- '!
9 .anything. j 10 A (Ca11endre11o) That's right. )
11 Q If the individual were found to be contaminated 12 and the tone went off, what does the monitor do or'say?.
1 13 A (Cotter) The monitor would then stop the
('
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14 monitoring process at that point, and say, I've identified 15 some contamination. If you could step to the decon area, 16 which is in the back of the trailer, and indicates that to 17 the lead person.
18 For instance, he would say, whatever that 19 individual's name was, A1, we've got a. contamination here.
20 A thousand counts to the head. And at that point the 21 evacuee is directed to the back of-the decon area, and 22 another person is brought into position.
23 O All right.
24 JUDGE McCOLLOM: Excuse me.
25 MR. FIERCE: Yes.
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REBUTTAL PANEL NO. 1*/ - CROSS 25676 1 JUDGE McCOLLOM: What can he hear in the 2 headphones?
3 What can the monitor person hear?
4 THE WITNESS: (Cotter) The instruments have what 5 we call pulse alarm setting. And maybe if I could - pulse 6 alarm setting. It will pulse during his normal monitoring ,
7 process. The pulse rate will increase, a noticeable 8 increase to the monitor as the probe passes over the 9 contamination and up to the alarm set point.
10 When it hits the alarm set point, the pulse will 11 shove down and an audible alarm.
12 JUDGE McC(%LOM: So it's the each individual 13 radiation pulse that comes in. If more of them come in in a 14 second, than the rate of the popping in the earphones goes 15 up?
16 THE WITNESS: (Cotter) I don't think it's exactly 17 the number of pulses coming into the instrument that 18 correlate back to one pulse in he ear. But it's that 19 concept, yes.
20 JUDGE McCOLLOM: And the alarm is initiated to the 21 headphones or to somewhere else?
- 22 THE WITNESS: (Cotter) When the headphones are 23 plugged in, the alarm only goes through the headphones.
24 JUDGE McCOLLOM: Okay.
25 E
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J REBUTTAL PANEL NO..17'- CROSS 25677' l
'l f~s 1 RBY MR. FIERCE: j
~
2 Q Can the individual wearing the headphones hear 3 standard' conversation'from.the person:he~is monitoring?
- 4 .A. (Cotter) It's been demonstrated to me in drills 5 that the. persons with'the headphonesLon have heard very
,_ 6 easily things that are going on.;
7 MR. FIERCE: It's at-this point,. Your Honor, where 8 "I would have asked some questions ab'out;the anxiety factor.
9 But'we covered.that yesterday. LI:just wanted t'o point that 10- out.
11 BY MR.' FIERCE:
12 Q The individual- then is directed to walk to the:
13 decontamination area down the -- according to the flow 14 path -- down the dirty side of the trailer, the controlled !
15 side, correct?
16- Or maybe I'm using that term wrong. Which side is i
17 the controlled side? 1 18 A (Cotter) The controlled side is the potentially 19 contaminated side.
20 And that's correct.
21 Q Okay.
22 So using that side of'the trailer,'would-walk down.
. 1 23 toward the decontamination area, correct?
24 A (Cotter) That's correct. j 25 Q Now I believe in your testimony you indicated.that ;
I !
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REBUTTAL PANEL NO. 17 - CROSS 25678 :
1 1 the lead person at the door would hold an individual until 2 that person has passed the doorway before sending them in.
3 Is that correct?
4 A (Cotter) If the identified contaminated i 1
5 individual was on the side of the trailer that had to -- 1 l
l 6 Q Right, .
)
1 7 A (Cotter) -
pass by the doorway.
~
8 Q Right.
9 A (Cotter) He certainly wouldn't send another I 1 l
10 person on, on going into the individual. }
l 11 Q Okay, now, what happens when this contaminated )
i 12 individual gets to tb.e decontamination area? l 13 l There is a portion of the trailer --
14 MR. TROUT: Objection.
i 15 BY FR. FIERCE: )
16 I Q -- that doesn't have a closed doorway. It's just
]
l 17 open, is that correct?
18 MR. TROUT: Objection.
19 The Board specifically excluded litigation of the 20 decontamination process. We're litigating the monitoring 21 process.
22 MR. FIERCE: I'm certainly doing that, Your Honor.
23 And I promise you I'm not going to get into the 24 decontamination process. I'm interested in flow path here, 25 and I want to ask some questions about flow path for the l
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REBUTTAL PANEL NO. 17 - CROSSJ 25679 t f-w '11 contaminated people and inquire whether.that may impact.on lj s~s/ 2 flow path for'the people who.are'being; monitored,-
3 ' JUDGE SMITH: Allright.'
i 4 MR. TROUT: With thatLunderstanding, Your' Honor, I, ]
.5 withdraw the objection.
... 6 :BY MR. FIERCE:
7 .Q So Indon't want-to'get'into the contamination.
8~ But when they get to~the entrance-way',can-they walk right' 9 into the decontamination area? <
10- A (Cotter). The decontamination' area'is in the same.
11 trailer, and there really is:no entrance-way that they have-l 12 to get to, if you look at the diagram.
J 13 Q. The-Implementing Procedure 3.4.has.an Attachment '
. 14 No. 4 labeled " Monitoring Trailer Flow Path".
l w. 15 Does that diagram accurately. depict'the layout of I
16 the contamination area in relationshipfto the monitoring 17 area? <
~
18 It shows a counter top with cabinets coming out l l
19 from the left wall there about, oh, what, two-thirds of the j 20 way across the trailer.
21 Is that correct?
l 22 A (Cotter) Yes, there are counter tops.
23 Q Is that essentially a' wall.there, or is that open? l 24 Is there a counter top and then a through space !
l 25 and cabinets above? !
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REBUTTAL PANEL NO. 17 - CROSS 25680 '
i 1 Or is it just a counter top with cabinets below l 2 and open all the way above?
3 A (Bisson) It's a counter top with cabinets below. ;
4 A (Cotter) And above, as you can see right where 1
5 the decon sink is on that diagram, above that there are 6 cabinets. ,
7 O So the decontaminated person walks into this area.
8 What happens then?
I 9 (The Board confers.) j 10 JUDGE SMITH: Is fl.are an objection?
l 11 MR. FIERCE: No, we are just waiting for you, Your 12 Honor.
1 13 JUDGE McCOLLOM: We were just looking at the 14 diagram to see what you were talking about.
l ,
l 15 MR. FIERCE: All right.
16 Okay, I thought you were taking a pause.
17 JUDGE COLE: We were just trying to keep up with !
18 you.
19 (Laughter) 20 BY MR. FIERCE:
21 Q Panel, if the person arrives in this section,
- 22 steps into that area and finds that the two decontamination 23 workers are busy working on other individuals, what will 24 that person be told?
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- REBUTTAL PANEL NO. 17 - CROSS 25681 l
f ~x 1 would back up in the decon area, before it would be allowed i I ) i l \_,/ 2 to affect the monitoring areas, they would be backed out the ;
l b l 3 decon area doorway, which is the doorway just opposite the
' i 4 sinks in the trailer.
5 And what would be established would be a holding i
. 6 area as you would with stanchions and ropes to have an area j i
7 where they -- much like a doctor's office seating, or a j
- l 8 holding area to come in when the deconers were available to i 9 deal with the next person. {
a 10 So this holding e.rea would be down those steps and I Q
l 11 off to the side somewhere?
f I 12 A (Cotter) Yes. Towards the front part of the -- j l
13 Q There would not be a line right on the steps? I i
rN 14 A (Cotter) We don't -- we have never demonstrated I k'-
15 in any of the drills a line on the steps. They are 16 typically backed out. And as I said, an area almost like a 17 corralled area put together with stanchions and ropes that 18 would segregate that group from any other groups.
19 And they would be brought back in one by one as 20 the availability.
21 Q You say if more than a couple of people would back 22 up, then this procedure would be utilized.?
23 A (Cotter) That's correct. You could still get two 24 or three people in that decon area before you really impact 25 at all the monitoring areas.
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REBUTTAL PANEL NO. 17 - CROSS 25682 1 Q What happens -- strike that. ]
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2 Does anything different happen if the monitoring 3 process finds an article, a hand-carried article to be
{
4 contaminated, but the person is not contaminated? ]
5 The person would still be directed back to the j I
6 decon area with their item, their handbag, their purse, ,
7 their umbrella perhaps?-
8 A (Cotter) Which question are we answering now? I l
9 0 I said -- {
i 10 A (Cotter) Is anything different done now?
?
11 Q Yes. Would the procedure for directing people {
12 back to the decon area who are contaminated, would that 13 procedure be any different for people who themselves were )
l 14 found clean but an article they were carrying like a 1'
15 handbag, an overnight bag or an umbrella were found 16 contaminated?
37 A (Cotter) No. As I previously stated, once 18 contamination is found, the individual is directed back to 19 the decon area. That's where that initial monitoring 20 process stops.
21 So if the hand-carried article was identified as 22 contaminated, the individual would not have been verified 23 clean. That monitoring process would stop at that point, 24 and the individual would be sent back to the decon area.
25 The deconers would then verify to what extent l
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-REBUTTAL, PANEL:NO.;17-- CROSS- 25683:-
fs -1 contamination. covered the material and. body and whatnot'. ,
L\ 2 Q WithLrespect to' articles, Dis an effort made thenL 3 to decontaminate any articles-using. duct or' masking tape?
~
4 , 'A (Callendrello). .That's what'the. procedure --
5 'MR. TROUT: I'm going.to' object.:
, 6 LJUDGE SMITH: That seems.to be within'the:
7: . category.
B- How'does this affect monitoring rate?
'9 MR. FIER'CE: (Well, if they are' telling me thati 10 they do do some article ~ decontamination right'then while 11 people wait, I'm going'to be asking them where the people 12 are waiting who are clean.
13 ,
This again is a. flow path issue..
14 If they tell me they don't do it} then I don't.
O 15 have any people' waiting around.
16 JUDGE SMITH: So the idea is that they are going 17 to impact upon the flow path back at'.the monitoring.
18 stations, is that it?
19 MR. FIERCE: Well, I'm not sure it's:"back at"._
20 They are at the monitoring station.:
21 JUDGE COLE: Well, I. thought they answered that 22 question.
23 They said.if they're found to have a contaminated 24 article with them, they are assumed to be contaminated and '
25 they are sent to'decon with the article.
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REBUTTAL PANEL NO. 17 - CROSS 25684 1 Is that correct?
2 THE WITNESS: (Callendrello) That's correct.
3 MR. FIERCE: That's right.
4 And then decon would determine that it's just an 5 article that needs to be decontaminated. And I'm wondering 6 if they have essentially clean people waiting for articles .
7 to be deconed who are somehow in this area waiting around.
8 JUDGE COLE: But by that time they are out of the 9 monitoring stream, aren't they?
10 MR. FIERCE: Depending on where they put them.
11 JUDGE SMITH: So this is a particular group of 12 people who are back at the decontamination area.
13 And what difference does it make whether they are 14 there to hrve carry-on items or bodies or whatever 15 decontaminated?
16 What's the difference?
17 MR. FIERCE: Well, these people are going to be 18 clean.
19 JUDGE SMITH: But still, as far as impacting upon 20 the flow through the monitoring stations, what's going on
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21 there?
22 MR. FIERCE: Well, I'm not sure this even happens, 23 Your Honor. In fact, I think it probably doesn't. But if 24 they have gone some clean people, my guess is they're not 25 going to stick them out in the holding area with the dirty Heritage Reporting Corporation (202) 628-4888 j l
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REBUTTAL PANEL NO. 17 - CROSS: 25685 i
,- 1 people. ;
k- s 2 JUDGE SMITH: 'All'right. f 1
3 THE WITNESS: (Cotter) . Could you repeat the 4 question?
5 BY MR. FIERCE:
l 6 O The quertion is: Are you deconing any articles 7 really while people are waiting for-them?.
8 A (Cotter) And they would only be deconed if it was, 9 convenient to do so at thati point in time, and articles 10 would not take precedence over personnel to.decon, for 11 instance.
12 Q So essentially if the decon area people were not 13 busy and they had time to do it, they might attempt it.
g 14 Is that what you are saying?
-/ 15 A (Cotter) That's correct.
( 16 Q And if there isn't time, would this individual !
I 17 then be directed out to the holding area if it'were-that 1 l
18 kind of a busy situation?
19 A (Bisson) If there wasn't time, most likely-what 1 20 would happen is the individual would be asked to leave the ,
i 21 article. This is on the assumption that it's just the i 22 article and the individual, him or herself are clean. The 23 article would be left and would be picked up later when time 24 permitted for it to be deconed.
25 0 When time permitting being after the evacuation l
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REBUTTAL PANEL NO. 17 - CROSS 25686 1 and the monitoring decon activities had concluded?
s 2 A (Bisson) After the monitoring of evacuees or 3 deconing of individuals who contaminated.
I 4 Q Well, let me pose a situation. I am a particular 5 evacuce. I have a contaminated article. Maybe a better 6 situation would be a woman who has a purse. A purse is ,
7 contaminated. In the purse is her wallet, her car keys.
8 What is this woman told about her purse?
9 It's now too busy to decontaminate the purse at 10 this point. What is she told?
11 Should she wait around for her purse? Can you 12 reach into the purse now and pull out her keys and her 13 wallet and give them to her and let her take those in the 14 clean area and perhaps leave the reception center?
15 A (Callendrello) I think we addressed that in the 16 procedure, Mr. Fierce. This is procedure IP-2.9, Step 17 5. 5. 3 (b) , where we place the contaminated article or 18 clothing in a bag for later decontamination.
i~v 19 If a person refuses to leave the articles, ensure 20 the bag is clean on the outside and allow the individual to 21 keep the bag. So we don't confiscate any individual's 22 property.
23 Q Well, within that limitation that you are not l
24 confiscating, you've got a item, a purse that's l 25 contaminated. She perhaps is looking for some guidance.
1
..y.,
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REBUTTAL PANEL NO. 17 - CROSS 25687 7-~g 1 Should she stick around-and.let.yet decontaminateLit?-Should
_s 2 she not wait,,and proceed and leave the reception center and 3 come back later?
4 MR. TROUT: I want to make sure that this 5 hypothetical is clear.
. 6 We've got an individual with a contaminated' purse.
7 MR. FIERCE: Yes. .You've got a-contaminated' 8 purse.
~
9 MR. TROUT: And the purse has the person's car 10 keys and their' wallet in it.
11 MR. FIERCE: Yes.
12 MR. TROUT: And it's already clear that the ORO is 13 not going to take-thel purse and the wallet and the car keys 14 against the individual's will.
15 And now your question is what happens if the 16 person does what exactly?
17 MR. FIERCE: Well, what if the person merely says, 4 18 I'm sent here. It's my purse. What should I do?
l 19 MR. TROUT: And it's also part of our hypothetical l 20 that there is a backlog at the --
21 MR. FIERCE: It's a busy time in the i
22 decontamination room. 2 23 MR.. TROUT: At the decontamination trailer. i 24 MR. FIERCE: And they say, we don't have time to 25 decontaminate your purse right now.
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REBUTTAL PANEL NO. 17 - CROSS 25688 i 1 And she says, well, what should I do? i I
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25689' 1 THE WITNESS: (Bisson) When the contamination is.
km 2~ first found at the station, .given the case it's'a woman'with-3 a contaminated purse, she would be directed to the decon
- 4. area where she would be? frisked by1one of the decon-people u 5- there just to identify the extent. And if it's limited
, 6 strictly to the purse'-- I'm assuming that would be' limited 7 to the'outside of the purse, and certainly her keys;or 8 wallet inside would be contamination free.
9 BY MR. FIERCE:
10 Q Is that correct, Mr. Littlefield, can that 11 assumption be --
12 A (Cotter) I think that's.the assumption - is, in 13 fact, the assumption you aere making based on his.
N 14 A (Bisson) The. assumption I'made is that.the i
g '
15 contamination from your hypothesis-is that the contamination 16 was limited to the outside of the purse.
17 Q Well, I'm not making that. In fact, I'm not even 18 making the assumption that the. person was clean.here. It-19 could have been the person was also found' contaminated.
20 They were then decontaminated and the only problem is an 21 article is still here, it's contaminated, it's the purse, 22 they can't do it right now and she says, what should I do.
23 What, Mr. Bisson, you're going to let her reach in 24 and pull out the wallet and keys?
25 A' (Bisson) No , sir, I didn't say that.
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REBUTTAL PANEL NO. 17 - CROSS 25690 1 The monitoring person in the decon arec is there 2 with an HB-210 and RM-14, which would allow this person to G ,,
3 do a frisking of the inside, going on the case that you 4 described, she wanted her keys and wallet and didn't want to stick around because she was clean herself; then logically i 5
6 it would take a few seconds to just frisk the keys and .
7 wallet and give them to the woman and issue a contaminated 8 -- if she wanted to leave the purse -- issue a tag for that ;
)
9 receipt that she can come back at a later time to pick up i
10 the purse.
11 Q Might she want to hang around the reception center )
l 12 and wait for that? 1 1
13 A (Bisson) That certainly would be --
14 JUDGE SMITH: That's just too much. ,
i 15 She's clean, right. You just go on and on to l
l 16 these improbable things. There's an infinite number of 17 scenarios you can think of. Where is she going to wait, ;
18 outside or what? j 19 How does that impact upon the monitoring rate?
20 MR. FIERCE: It impacts on the parking rate, Your l 21 Honor.
i 22 JUDGE SMITH: Oh, parking rate. Okay. We're l
23 talking about parking rate. !
24 MR. FIERCE: You've got some people who are 25 waiting around now --
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REBUTTAL PANEL NO. 17 - CROSS 25691 1 JUDGE SMITH: Okay, go to it.
0 2 MR. FIERCE: -- who are not turning over in the 3 parking lot.
4 JUDGE SMITH: All right.
5 I missed that.
. 6 JUDGE McCOLLOM: I would like to ask one question 7 while you're at this point.
8 What is the probability of a woman carrying a 9 purse that's contaminated on the outside of not being 10 contaminated herself on the body?
11 THE WITNESS: (Littlefield) I would think that we 12 would expect that she would also have contamination on her 13 if her purse were contaminated.
14 MR. FIERCE: For this particular hypothetical I 15 didn't assume that this person was clean. She could have 16 either been clean or dirty. She is ultimately, either 17 because she's clean or because they have now decontaminated 18 her if she's clean, waiting for her purse.
19 BY MR. FIERCE:
20 Q And you did admit that one option would be for her
~
21 to wait in the reception center then for the purse to be 22 decontaminated?
23 A (Bisson) I don't believe I said that.
24 Q It's not an option? ,
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REBUTTAL PANEL NO. 17 - CROSS 25692 1 possible that she might want to do that.
2 O Yes. And you said it's possible.
3 And you would allow that to happen?
4 A (Cotter) That would not be the direction that 5 would La given to her in this situation that you have 6 described. A contaminated article tag would be filled out .
7 for that particular article.
8 A copy of that tag would be issued to the person 9 as a receipt for that article and instructions that that 10 article will be decontaminated at the first earliest 11 convenience and returned to that individual. And the 12 individual will be sent on their way.
13 At no point would directions be given for that 14 individual to stick around and wait for that article, 15 because articles would certainly not take procedence over 16- the decontamination of personnel or evacuees.
17 Q So then you would put the person in a position of 18 simply demanding their car keys from you and then you would 19 not resist?
20 A (Cotter) I'm sorry, repeat the question?
21 Q So you would put the person in a position of then 22 demanding to take their car keys and then you would not 23 resist, as you indicated before?
24 A (Cotter) Right. I didn't say that we would hold 25 them back until they would be demanded. If the individual i
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y-"N 1 refused, and.this'is in the procedure,-if an-individual j
- i 2 refused to leave an article the procedure states clearly how 1
3 to handle that situation, also. j 4 Q Just so I'm clear: if she says, what should,I do?
5 The procedure then is, we're going to take the item',.we'll
. 6 stick it-in a bag, we will issue you a receipt:and we will 7 decontaminate it later and you canLpick it up later on. At
.8 that point they say, but I need my' car keys.
9 And then your person ~says,- well, that's our 10 procedure. And she says, well, I'm taking my car keys. ;You .l 11 don't resist. That's how it plays out.
12 A (Cotter) Given that situation, again, I think Mr.
l 13 Bisson went through that. If she needed her car keys._from 14 the purse, the purse could be opened, the decon person could 15 pull those keys out and monitor those keys and turn them 16 over to the --
17 Q If they're clean. And if not?
18 A (Cotter) And'if they're not clean, they're a 19 contaminated article just like the pocketbook itself. And 20 if there is no time to decon the article -- for instance, if ,1
- l 21 there's a backlog of people, then all efforts would be made j i
22 to get the person the keys.
l 23 But if not, again, a receipt would be issued to i j
24 the individual and if they refused to leave it, that's again.
25 their prerogative and there is no reason for us to hold that r
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REBUTTAL PANEL NO. 17 - CROSS 25695-s 1 JUDGE SMITH: What happened to'the. lady that was
\_ 2 out in the parking lot refusing to leave until.her purse was j
3 decontaminated? j 1
4 MR. FIERCE: Well, it sounds likefit played out <
l !
5 differently here,.Your Honor.
. 6 JUDGE SMITH: Oh. So we didn't get to her, 7 .MR. FIERCE: It sounds _like it doesn't happen.
8 JUDGE SMITH: 'All right.
9 MR. FIERCE: She either has -- she insists on her 10 car keys or she doesn't in which case I'm not sure what.she l 11 does.
12 BY MR. FIERCE:
13 Q It is the case, is it not, Panel, that' during the j 14 emergency when people are being monitored and decontaminated
\
15 no one is engaged in the article decontamination process 16 unless there is some downtime with people not. coming through 17 the trailer at some point; correct?
18 There is no specific assignment of article 19 decontamination during the exercise or during the emergency 20 because the people assigned to article decontamination are
~
21 also assigned to do monitoring or decontamination work of 22 people or vehicles; correct?
23 (Witnesses conferring.)
24 A (Cotter) Could-I get a repeat of that question.
25 0 Well, maybe I can put it in a different way.
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REBUTTAL PANEL NO. 17 - CROSS 25696 1 As I look at the staffing for the monitoring and 2 decon function I see in the procedures assignments for )
i 3 deconing vehicles and articles. It's on Implementing 4 Procedure 2.9, Section 5.2.9 where the assignments are set 5 forth for inside and outside the monitoring trailer. I i
6 The only assignment I see here for decontaminating .
I 7 articles is in B-3. There are four people who are outside )
1 8 the monitoring trailer who are monitorzng -- excuse me, who-9 are decontaminating vehicles and articles, j l
10 Now, are those the people who would be i 11 decontaminating these articles that we're talking about?
12 A (Bisson) Articles? Are you talking about inside 13 the trailer?
14 Q That came from inside the trailer, they may be
]
15 placed outside the trailer, I understand.
16 A (Bisson) The two monitoring persons who are 17 assigned to the decon area inside the trailer will attempt 18 to decon a personal article. And that's in step 5.5.3. >
19 0 Okay.
I 20 A (Bisson) And if the article is not usually 21 deconed, that's when the person owning the article will be 22 asked to leave it, to be picked up at a later time after it 23 is deconed.
24 O So it would be, if the people in the decon area 25 have time, if there isn't a flow of people into the decon {
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REBUTTAL PANEL NO. 17 - CROSS 25697 1 area, they would then move to monitor articles -- decon 2 articlest is that how it would work?
3 It's, essentially, their second priority: people 4 first; articles second?
5 A (Bisson) The procedure right now has an evacuee
. 6- found to be contaminated going to the decon area where the 7 evacuee is remonitored. If the contamination is on a 8 personal article or clothing, an attempt is made at that 9 time to decon either the clothing and the article or either.
10 If the article is not easily deconed, the person 11 would be requested to leave it.
12 Q We understand all that.
13 We're talking now about articles that were left.
14 Who is responsible for ultimately deconing them, and I 15 thought you just told me it is these two people who are in 16 the decon trailer and they would do it when they had time, 17 when there are not people coming into their section that 18 would be their first priority?
19 A (Bisson) Correct. I misunderstood your question.
20 For articles that are left it could be the four 21 people who are designated as vehicle and article deconers or 22 it could be the two people inside the trailer, if time 23 permitted them to do that. And --
24 JUDGE SMITH: What's the relevance -- excuse me, 25 finish.
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I G Heritage Reporting (202) 628-4888 Corporation l
4 REBUTTAL PANEL NO. 17 - CROSS 25698 1 THE WITNESS: (Bisson) And also, it's not limited 2 to just those four people. If after the whole evacuation O1 I
3 process is through, they will freeze up the people at the 4 station who then could assist in deconing articles that were .
1 5 left, if that were the case. i j
6 JUDGE SMITH: What's the relevance of this line? . j l
7 MR. FIERCE: Well, to the extent that they've got j 8 manpower available to do deconing they might be indicating l 9 to people, you know, that they could stick around, we may be 10 able to get to it in a little while kind of thing.
11 JUDGE SMITH: All right. i 12 Then what's the relevance of that? l J
13 MR. FIERCE: People then staying around the 14 reception center waiting. l 15 JUDGE SMITH: But by the very nature of the l 16 scenario the load is down; right?
17 MR. FIERCE: It's only -- it's at the point where i l
18 the flow is not down that the people might be told this. 1 i '
19 JUDGE SMITH: Yes.
20 MR. FIERCE: The flow may never come down, Your 21 Honor. And over the 12-hour period that we are looking at 22 here for the purposes of the calculation at issue, they're 23 assuming steady flow of people at least through the i
24 monitoring trailers.
25 I'm moving on at this point.
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REBUTTAL PANEL NO. 17' . CROSS 25699-f- 1 (The Board confers. )
(
\ 2 May I proceed.
3 JUDGE SMITH: Sure.
4 JUDGE SMITH: Well, if this is another point, 5 let's take an afternoon break.
l . 6 MR. FIERCE: Fine.
'7
. (Whereupon, a recess was taken.)
^
8 JUDGE SMITH: All right.
9 MR. FIERCE: Okay, Your Honor.
10 BY MR. FIERCE:
11 Q Panel, can you tell me.what.the flow path is for 12 -those people who leave the decon area clean?
13 A (Cotter) Upon completion of the-frisking process
(
14 the clean -- I'm sorry, the:decon. process, the frisking ,
\ 15 after the decon process, so that frisk would then result in j 16 a clean evacuee. The monitor would then wait for that 17 nearest station, nearest station to the decon area to be 18 open and the flow of that clean evacuee would be through 19 that station.
20 0 So they're actually going to exit through that-
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21 last monitoring station while it's open for a few seconds in 22 between evacuees? i 23 A (Cotter) That's correct.
24 Q Those people who are unable to be decontaminated 25 in the decontamination area will what, travel down the Beritage Reporting Corporation
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REBUTTAL PANEL NO. 17 - CROSS 25700 1 stairs that are adjacent to the decontamination area?
2 (Witnesses conferring.)
3 THE WITNESS: (Cotter) An individual that was 4 unsuccessfully deconed c.fter three attempts would be going 5 out the exit door to the reception center. He would be l
l 6 issued a clean tag with the stipulation of whatever levels ,
7 of fixed contamination. For instance, we don't send him l
8 back out the exit door back towards where he came from. We 9 bring him out the same direction as the clean evacuee.
10 BY MR. FIERCE:
11 Q This is news to me. You've got an individual, 12 you've tried the three methods, you say after three I
13 a'.t empt s , but really there are three methods that progress 14 f:om using the waterless cleansers to water wash with soap 15 t o a Lava soap and then, perhaps, showering or the shower 16 could be in either of the second or third steps, correct, 17 bicause those ese both water-based systems?
18 (Pa ase) 19 B'J MR. FIERCE:
20 Q I really don't want to get into this, but you had 21 said after three attempts, but we're talking about -- they 22 can't be decontaminated - you've monitored -- you've 23 frisked them again, you still see they have some 24 contamination. They are then advised of their contamination 25 and then directed in the same flow path that a clean person 1
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REBUTTAL PANEL NO. 17 - CROSS -25701-
'I would take who was leaving the1decon area?
'\s_/ 2 A (Cotter) I should probably_ clarify.
3 There are a couple of situations or.a couple of 4 options thet may happen'at that point.in time. .One' option-5 may be to direct.that-individual to.an MS-1 hospital where
. .6 further decontamination may happen. That individual then 7- would be brought out the -- as you described it.
8 -Q Would that be in serious cases? You say, one-9 option?
10 A (Cotter) No , I wouldn't describe it as a serious-11 case. I think more the -- it would be more based on the 12 level or the number of personnel who are at the MS-1 13 hospital at that' point in time.
14 (Witnesses conferring.)
\- 15 BY MR. FIERCE:
16 Q Mr. Cotter, were you in the middle of answering?
17 A (Cotter) I'm sorry, I'm getting clarification on 18 the answer. I think I need to --
19 0 Okay. I'll pause then and wait for you.
20 (Witnesses conferring.)
21 MR. TROUT: Mr. Fierce, is your question about the 22 flow path or about the decontamination process or when
~
23 people are referred to MS-1 hospitals? What's^the pending 24 question?
25 MR. FIERCE: Well, my question is: where do people <
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REBUTTAL PANEL NO. 17 - CROSS 25702 1 go who are unable to be decontaminated? And he was about to .
2 give me a one option -- other option kind of answer, and 3 he's in the middle of that, I think.
4 THE WITNESS: (Cotter) Let me back up a second.
5 The MS-1 hospital, I want to back away from that, j 6 that was a contaminated injured person. .
l l 7 What would happen for the individual is they would l
8 be entered into what we call the radiological screening 9 program as identified again in Procedure Steps 5.7 in that 10 area.
11 At that point, at the three attempts at j i
12 contamination, the contamination would not be loose surface l
13 contamination, which means it would not be spread to another 14 individual surface or article by rubbing. And the reason we 1
i 15 can say that is because we have already attempted !
j 16 decontamination several times, several different methods.
17 If it was loose contamination it was easily spread, it would 18 be gone at that point.
19 If it's not gone it may be an indication that the 20 contamination is either internal or embedded in the skin.
21 We enter them into this radiological screening program, 22 issue clothing if needed, and direct the person out the same 23 direction as I have just identified for a clean evacuee, but 24 their clean tag would just identify that they have certain 25 levels of fixed contamination identified on them and that Beritage Reporting Corporation (202) 628-4888
1 REBUTTAL PANEL NO._17 - CROSS 25703 .l 1 radiological screening program would then address that at a
( 2 later time. 1 3 BY MR. FIERCE:
~
4 0 You just said something that jogged my memory.
5 about a question I forgot to ask back when we were going
. 6 through the steps in the monitoring process, and so I.just 7 want to jump back for one question.
~
8 You just mentioned internal contamination. In the l monitoring process do the monitors stop the probe at the 9
10 nose, at the mouth,. wait for the person-to exhale, and 11 attempt to gauge whether the person may have: internal 12 contamination?
13' A (Cotter) Okay.
f-% 14 There was a couple of questions in that one s 15 question. Do we attempt to gauge internal, contamination?
16 The answer is, yes. And the use of -- or in the way'that we 17 pay particular attention to the face and the other portions 18 of the body.
19 If there was internal contamination it would-20 become internal by inhaling through the nose and mouth area. 1 21 As contamination is drawn across the face the face would 22 also have a very high probability of being contaminated at 23 the same time, and that would be a means of identifying that q l
24 type of contamination.
25 Q Are you aware that the INPO guideline instructs j i
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REBUTTAL PANEL NO. 17 - CROSS 25704 1 that, in the case of personal monitoring, the monitor should 2 stop and hold the probe for five seconds at the nose and 3 five seconds at the mouth; are you aware of that INPO 4 guideline, Panel?
5 A (Littlefield) I don't remember those specific 6 instructions. .
7 O If I showed you the INPO guideline would it l 8 refresh your recollection on that point?
l 9 A (Littlefield) I have no reason to question you.
10 Q Your procedure doesn't follow the INPO standard 11 procedure then, does it?
12 A (Bisson) This procedure is designed to detect 13 gross external contamination. I believe the INPO document 14 or guidelines that you may be referring to apply to routine 15 situations in the industry.
16 Q And in routine situations in the industry monitors 17 would stop at the nose for five seconds and at the mouth for 18 five seconds in the monitoring process; is that correct?
19 A (Bisson) I'm not sure. I just made an assumption 20 about the document you referred to.
21 Q Are you familiar with that document, Mr. Bisson?
22 A (Bisson) No, sir, I made an assumption just then.
23 Q I think Mr. Littlefield is familiar with the 24 document; correct?
25 A (Littlefield) Yes.
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f REBUTTAL PANEL NO. 17'- CROSS- 25705' j
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f That ckocument applies to the industry; correct? -
1 O' -
s/ 2 A (Littlefield) . 'It's'an industry guideline. ~I 3 Q And is there any reason why the industry guideline
)
4 for inhalation, checking for' internal contamination by 5 inhalation, shouldn)t also apply-to offsiteLradiological i 1
. 6 monitoring process? )
! 7 JUDGE SMITH: We're going very far here when he l
8 doesn't even testify as to~his own, knowledge that there is a 9 five second standard, and I don't think he has testified yet 10 the application of it.
11 I mean, is it industry guidance for-power' plant 12 workers or for monitoring evacuees or what? We don't know. )
]
13 It hasn't been sufficiently established to be meaningful.
, 14 Is it_ directed toward quarterly. accumulated doses
( 15 for plant workers or what?
16 It's not going any place. d 17 MR. FIERCE: Well,.why don't I do it this way, 18 Your Honor, q j
19 BY MR. FIERCE:
l 20 Q Mr. Littlefield, I'm going to show you a document l 21 which is labeled, " Guidelines For Radiological Protection at !
1 22 Nuclear Power Plants," with in large letters.at-the bottom 23 "INPO" on it and ask if you recognize it?
l.
l l
24 (Document proffered to all parties.) l l 25 l
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i REBUTTAL PANEL NO. 17 - CROSS 25706 I 1 BY MR. FIERCE: j 1
2 O Do you recognize that document, Mr. Littlefield? i 3 A (Littlefield) Yes. ;
4 Q Is that the INPO guideline regarding. radiological ;
)
5 monitoring? !
6 A (Callendrello) Well, the full title is, .
7 " Guidelines For Radiological Protection at Nuclear Power j 8 Station." I 9 O And that is what you would describe as.the l 10 standard industry guidance?
11 A (Littlefield) I would describe it as a guideline 12 put out by INPO for industry consideration.
13 0 Well, INPO is the organization which issues j 14 guidelines that the industry does look to; correct?
15 A (Littlefield) It is one source of guidelines that 16 the industry looks to.
17 Q 1sn't it the key source besides the NRC7 18 (Pause) 19 THE WITNESS: (Littlefield) I don't know whether-20 it's a key source.
21 JUDGE COLE: Well, how many sources are there?
22 THE WITNESS: (Littlefield) We have NRC;'we have 23 EPA. In emergency planning areas we have FEMA; we have Food-24 and Drug; we have INPO; we have all kinds of standards 25 activities, standards organizations, health physics society. l l
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REBUTTAL PANEL NO. 17 - CROSS 25707 q I
-- 1 There are a; number of areas -- number of groups of l
\v 2 people that produce guidelines for the industry. q l
3 THE WITNESS: (Callendrello); Your Honorsh they typically are involved more with the.onsite emergency
~
4 L '5 planning or-emergency response or operations. They
. 6 typically, with a few exceptions, do not get involved.very 7 much in offsite emergency planning, a few-exceptions being 8 they have put out some guidance on protective action 9 recommendations, but again,Jt hat's more of an onsite 10 function, as well as public information.
11 But typically, they. provide guidance related 12 to --
13 JUDGE COLE: Who is "they" now?
- 14 THE WITNESS: (Callendrello) INPO.
15 JUDGE COLE: Okay.
16 BY MR. FIERCE:
17 0 On page 53 of that document, Mr. Littlefield, does 18 that refresh your recollection regarding what the INPO' 19 guideline is with respect to monitoring and checking for 20 internal contamination?
21 (Witness reviewing document.)
22 TliE WITNESS: (Littlefield) Yes, I see the 23 paragraph that you're referring to.
24 BY MR. FIERCE:
25 Q Well, does that refresh your recollection or not? j l
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i REBUTTAL PANEL NO. 17 - CROSS 25708 i
i 1 A (Littlefield) It does not. J 2 My experience in the industry is that there is no 3 five second pause at the nose and mouth, f l
4 JUDGE SMITH: That's onsite for plant workers? q l
5 THE WITNESS: (Littlefield) Onsite for plant )
6 workers. .
i 7 MR. FIERCE: Your Honor, I wasn't anticipating 8 doing this, but I think at this point I've got to offer that 9 document into evidence and I would so make that offer. j 1
10 MR. TROUT: I would like the entire document.
{
1 11 MR. FIERCE: I'm sorry.
]
12 JUDGE SMITH: You want the entire document before 13 you make your onjection or you want the entire document in 14 evidence?
1 15 MR. TROUT: I would like to see the entire 16 document, Your Honor, to see whether this is -- whether it's i
17 possible to tell the context. 1 18 JUDGE SMITH: And it's not possible from --
19 MR. TROUT: Not from the excerpt, no.
20 MR. FIERCE: Well, I'm not sure it's an excerpt, j
- l 21 Your Honor, if I can explain. This is a document I got from 1 22 the Applicants in discovery and this is what I got.
23 I have no objection to postponing a ruling on this 24 offer until tomorrow morning so that the Applicants can 25 produce the full document. I thought that's what was being
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REBUTTAL PANEL NO.'17 - CROSS 1 produced to us in discovery.
If it's not, I'm'more than i '
2 'willing to allow them to substitute the entire document 3 unless they want to just'go with these excerpts. I'm 4 flexible,.I'll go either way. =I have nothing to hide here.
5 The witness cannot -- it's not serving to refresh.
., 6 his recollection,~and I would like to get'into the record 7 what this guideline states.-
~
8- (The Board - confers . ) '
9 MR. TROUT: Your Honor, since we'are going.to be' 10 coming back tomorrow morning, very likely, to this panel on 11 this subject, the-Applicants:would ask that we defer - ,
1 l 12 JUDGE SMITH: All rioht.
13 MR. TROUT: -- until then and we will try to 14 obtain a copy of the entire document between-now and then.
15 JUDGE SMITH: All right.
16 It will be your responsibility, Mr. Fierce, to 17 renew your offer. As it stands right now it would have to
, 18 be -- any objection will have'to be sustained, so it will be_ .l l
19 your responsibility to renew the offer.
20 MR. FIERCE: I will'do that, Your Honor, and I
- i 21 will cease further questions along this'line until tomorrow I 22 morning when I anticipate the Applicants will come in with 23 the entire document. .
I 24 JUDGE SMITH: All right. .
25 i
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REBUTTAL PANEL NO. 17 - CROSS 25710 1 BY MR. FIERCE:
2 Q Panel, picking up again with the area that we were 3 discussing just prior to that.
4 There is nothing in the plans and procedures for 5 the SPMC which explain the system you just described for 6 sending a person who has been unsuccessfully decontaminated .
7 into the reception center with a clean tag, is there?
8 A (Cotter) No, there is not.
9 0 Would.that system that you described essentially 10 apply as well to a -- strike that.
11 I want to pick up a couple of questions about what 12 happens after the monitoring person in the monitoring 13 station has identified someone who has been contaminated and 14 have sent them on their way - person or articles.
15 In Implementing Procedure 2.9, Section 5.4.3, down 16' in subsection (d) there is a procedure which reads, quote:
17 " Evaluate the potential for monitoring area to have been 18 contaminated by the individual and take appropriate action 19 in accordance with Section 5.2.14."
20 And that section referred to then is a section 21 which describes steps for decontaminating the monitoring 22 area, monitoring trailer.
23 My question to you is: how is the person in the l
l 24 monitoring station to evaluate this, quote: " potential" for 25 the individual -- for the monitoring area to have been l
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REBUTTAL PANEL NO. 17 - CROSS 25711 1 contaminated?
2 A (Callendrello) If you look at the sentence that 3 precedes that portion of that step it says: " Instruct 4 contaminated individuals to proceed to the decontamination 5 area."
l . 6 So the initiating event is that there is a l
7 contaminated individual who has been detected at the B monitoring station.
l 9 Q So in each instance when there is a contaminated i 10 individual they evaluate the potential for the area to have 11 been contaminated itself.
12 My question to you is: how do they go about that 13 evaluation?
14 A (Cotter) The evaluation would entail that person 15 knowing what areas he had just identified as being 16 contaminated.
17 For instance, if it were the soles of the person's 18 foot, that evaluation would indicate to the monitoring 19 person that there's probably a higher probability of there 20 being contamination remaining or has been transferred to the 21 floor possibly versus contamination in some other area of 22 the body or levels of contamination that were -- that would 23 necessarily lead him to believe that there may be 24 contamination in the area where the person was just 25 standing.
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REBUTTAL PANEL NO. 17 - CROSS 25712 1 Q Other than contamination of the feet, is there 2 anything else that would suggest a potential to a monitor to 3 engage in this check?
4 A (Cotter) Certainly, very unusually high levels of 5 contamination may prompt -- in that situation it would 6 probably prompt the lead person in the trailer to bring- ,
7 someone in for a gross contamination swipe of the aisles of 8 the monitoring area.
- 9 Q Mr. Littlefield, is it true that the feet are --
10 of all the areas of the body that may well be contaminated 11 the feet are among the likeliest?
12 A (Littlefield) Yes.
13 Q Now, 5.2.14 is an instruction for the monitoring 14 and decon leader to assign monitoring personnel to 15 periodically perform contamination swipes of the monitoring 16 trailer including aisles. That process occurs periodically 17 regardless of what is happening in the individual stations; 16 cc rect?
19 A (Cotter) No.
20 The monitoring trailer lead person would be aware 21 of every time there was a contamination event detected or '
22 contamination detected on one of the evacuees.
23 And it is his responsibility or he is the person 24 who decides that if there is a more frequent determination 25 of contamination on evscuees that he may -- he should then
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REBUTTAL PANEL NO. 17 - CROSS 25713 1 maybe take a gross contamination swipe and see whether there O 2 is a problem in the trailer or not.
3 4
5
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8 9
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l REBUTTAL PANEL NO. 17 - CROSS 25714 1 Q He may initiate that apart from what an individual i 2 monitor does in evaluating whether this particular evacuee j i
3 he's just had might have contaminated the area. ]
4 A (Cotter) I'm sorry. I 5 Repeat that one. j l
l 6 0 Well, I see two people making this judgment. I J
4 1 7 see the individual monitor may having evaluated, it's the l 8 feet.
(
9 At that point he would what, signal for somebody 10 to come over and do, as you call it, the gross swipe? i 11 A (Cotter) The individual monitor. That may be as 12 simple as kneeling down while he's waiting for someone else 13 to approach him and put his instrument across the floor in 14 front of him, which he's got a monitoring instrument in 15 hand. He doesn't necessarily need a separate individual to 16 come over end make that detexv.ination.
17 Q Except that the procedure refers me to 5.2.14 l
18 which says, "If greater than 100 counts per minute (cpm), f 1
19 above background is detected on the gross swipe, using an )
20 HP-210 probe do the following."
21 So let me see if I understand this.
22 The APTEC probe would.be used first? q 23 And if greater than 100 counts per minute are 24 found, someone is called in with an HP-210 probe?
25 A (Cotter) No. You've confused the two situations Beritage Reporting Corporation (202) 628-4888
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.l REBUTTAL: PANEL NO. 17 -LCROSS .25715
-1 thatl'I.just describedLnow.
t'
' 2- 'O= Okay ..;
3 A. - (Cotter): .Again, I.said'it'may be'as simple aslthe 4_ monitor. kneeling.down as he's waiting during that five-5 seconds while someone.else isLapproaching the station. .He
. 6 may.just wantato kneel down and reach his. instrument.across 7- that line.
8 If.there.was contamination,'cro~ss-contamination
~
9 caused by that contaminated individual,-he.would;get an 10 alarm on his instrument.
11 Referring back to 5.2.14,.5.2.14 indicates the.
12 results of a gross contamination' survey which is different-
~
13 than what I just explained. What I explained was a direct l
'14 frisk.
15 A gross contamination survey, the monitoring 16 trai3er lead wculd call semobody in on a regulaz. basis and 17 say, grab a cross-contamination' swipe. That individual will 18 take a rag, typically a-maslin cloth,'as we describe it in 19 the trailers, and just drag it across the floors and walls j 20 from one end to the other.
21 When he got to the decon end of the trailer, there 22 is an HP-210 probe. That instrument has-a limit of 100 23 counts per minute. He would.just put that instrument on the ,
-1 24 rag and identify if there had been any contamination in the .
I 25 area where he had-just dragged that rag across. )
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REBUTTAL PANEL NO. 17 - CROSS 25716 1 Q All right, I may be confused. This is not an area ,
2 I am familiar with, so please bear with me. I 3 The procedure for the monitoring individual is to 4 evaluate the potential for the monitoring area to have been 5 contaminated. And you've explained how that is done.
6 I'm assuming now we've got someone who has just .
7 been found to have contamination greater than 200 counts per 8 minute on their feet. J 9 The APTEC probe is set ior that rate, correct, 200 i
10 counts per minute? j i
11 A (Cotter) The contamination limit. We're using l 12 that instrument set up as 200 counts per minute above )
i' 13 background, yes.
14 Q Above background. 1 15 A (Cotter) Right.
16 C The procedure here says, " Evaluate the potential 17 and take appropriate action in accordance with 5.2.14."
18 Now you've just described a procedure by which the 19 monitor himself, using his own APTEC probe, reaches across 20 the line and checks the area.
21 That's not here in 5.2.14, correct?
22 A (Cotter) That's correct.
23 O So if he follows the procedure in 5.2.14, he or 24 she follows the procedure, can you explain this procedure to 25 me in that situation?
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REBUTTAL PANEL NO.717'- CROSS '25717'
.f~ 1 .A ~-(Cotter) 'IfLyou1 refer back;t'o:wherelyou1just came
- (
\
2 from, 5. 4. 3 (d)', . " . . . and take appropriate ; action in :
3 accordance with 5.2.14".
~
.4: 5.2.14 then would identify 3ifzmore than?just that 5- localized area had become' contaminated.. So he may.wellE
. 6 identify.that there is.some contamination;where'that-7 person's feet were.-
8 What he now needs.to do isLidentify the' extent'of .
~9- that contamination or how:far back thencontamination, and 10 appropriate actions would be 5.2.14, getting contamination 11 swipes of the trailer areau 12 O Okay.
13 My problem is this is that,'as ILlook'at 5.2.14,-.
14 it looks like it sets a background tolerance level of having
{O} 15 100 counts per minute'above backgroundIaslthe' tolerable 16 lilait . And if it's above.100 counts per minute, tnenraction 17 is taken to decontaminate-the' area.-
18 Is that correct?
19 In other words, what_theLSPMC'is striving:for here-20 is to 'aave the monitoring.traileri particular1yLthose 1 .
21 portions of it where people are being monitored, have a 22- contamination level which is no greater than'100 counts _per 23 minute above background, is_that right?
24 A (Cotter) Understanding'that that'100 counts per.
25 minute is referring back to the different instrument, the Heritage Reporting Corporation (202) 628-4888-
REBUTTAL PANEL NO. 17 - CROSS 25718 1 HP-210 probe which has a different limit. Has the same 2 limit, different count rate. ;
3 0 Right.
4 But your monitor using his own APTEC probe set at .
5 200 counts per minute for the individuals he is monitoring, !
6 in reaching a ross that line and checking, isn't going to be .
7 able to tell, is he, whether that area is something over 100 j 8 counts per minute but not yet 200 counts per minute?
9 A (Cotter) Yes, maybe Pete might want to clarify.
I 10 The levels are identical, 100 on one instrument, 200 on the l
11 other.
l 12 JUDGE COLE: Are you referring to the count rate 13 efficiency difference between the two probes?
14 THE WITNESS: (Cotter) Right. The surface area 15 of one is much smaller than the other. So 200 counts per 16 minute is, I believe, actually more conservative than the ;
17 100 counts.
l 18 THE WITNESS: (Littlefield) Yes, that's correct.
19 THE WITNESS: (Cotter) So, in relationship, it 20 would be less than -- we would be detecting even less than I 21 that 100 counts with the large area probe. Because of the l i 22 size of the probe, it's a more efficient instrument.
23 BY MR. FIERCE:
24 Q Okay, let's assume, even though it's not in the 25 procedures, that happens; that is, this monitoring worker 1[ Beritage Reporting Corporation (202) 628-4888 l
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' REBUTTAL PANEL'NO. 17 - CROSS 257191 1
using.his own probe reaches;across_the line.and'h'e.' checks -'
/}
( i.
1-
\- ' 2 and the sound'in his ears;is going-off. Heifinds:
3 contamination.
4 "What then.happens?
5 A (Callendrello) First of.all, Mr. Fierce,1I;think 6 -Mr. Cotter' indicated that there'is'a procedural' step that
~
7 says evaluate theLpotential for the monitoring' area thatLhad-a 8 been contaminated. .And he indicated there isLsevera11 ways 9 to do it.
10 One is by'the location.of the contamination. 'The 11 other is by evaluating with the instrument that'the monitor 12 has.
I 13 So that to argue that'it's not.in accordance with 14 the procedure, I can't agree with.that premise.
15 0 Okay.
l l 16 Except that there is a difference between-17 evaluating the potential and actually evaluating whether 18 there is contamination by using your probe, correct?
i 19 A (Ca11endre11o) I guess I don't see the 20 distinction.
.)
21 Q Well, the distinction is that with respect to each' 22 and every evacuee who comes through the monitoring station, 23 the monitoring worker isn't going to be, after each one 24 passes through who is contaminated, reaching across the'line- )
25 and doing the measurement. j i
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REBUTTAL PANEL NO. 17 - CROSS 25720 1 He's going to be evaluating the potential based 2 on, as Mr. Cotter indicated, the location of the 3 contamination fcund.
4 Saving himself some time, correct?
5 A (Callendrello) Correct.
6 Q So there is a step of evaluating the potential. -
7 You know, it's just he thinks about it. It's the feet. I'm 8 going to have to check with my probe.
9 If it were the hands, would you want to check the 10 rail?
11 A (Cotter) That would be part of the evaluation 12 process, I would assume.
13 Q The hands and the feet might trigger at least a 14 check with the probe.
15 A (Callendrello) I think he also indicated it would 16 depend also on the amount of contamination that an 17 individual had on him or her.
18 Q Sure. That would be a third, perhaps, indicator, 19 if we can use that term.
20 If contamination were on other parts of the body 21 but seemed to be -- I'm not sure how he determines that.
22 How does he determine whether it's a significant 23 amount or a small amount when he stops the minute he hears 24 the sound in his ears?
25 JUDGE McCOLLOM: Where are you now on your plan?
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-REBUTTAL PANEL NO. 17 - CROSS 25721-rx 1 MR. FIERCE: This is No. 8.
I\ i
/
v 2 (Pause . ) i l
3 THE WITNESS: (Cotter) I'm sorry. l l
4 Is there a question? Could you repeat it? ;
i 5 MR. FIERCE: Yes, I'll repeat it, j l
. 6 BY MR. FIERCE: 1 1
7 Q How does any given monitor know whether he's got a 8 case of significant amount as' opposed to a small amount of 9 contamination when the procedure as you described it is for ,
l 10 the person to stop immediately upon hearing the 200 count 11 per minute sound go off in his headphones, and then 12 immediately send the person off?
13 He doesn't complete the survey to see if there is
,/ 14 contamination on other parts of the body, correct?
\~' 15 A (Cotter) By just the response of the instrument.
16 These are sensitive instruments.
17 If there were any appreciable amounts of 18 contamination, the instrument getting close to that 19 contaminated person would alarm.
20 Q Okay, it would sound differently?
21 A (Cotter) It wouldn't sound differently. The 1
22 sound is the same.
23 It would, however, alarm before he got very close 24 to the individual. Again, these are sensitive instruments 25 and the appreciable levels that I'm talking about would i
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1 alarm that -- ;
I 2 Q Okay, so there are perhaps -- well, there are ]
3 three indicators you have given me now. The hands, the feet i
4 and the level of contamination that would be the evaluation j i
5 and that would trigger a reaching across with the probe and !
6 checking either the floor area or perhaps the handrail area -
a 7 if that were the case.
8 And in doing that, again, if it appeared that the -
l 9 individual found contamination, what happens then?
1 10 A (Cotter) The first thing they would do is j 11 identify it to the lead person in that trailer.
1 12 They would at that point, on 5.2.14 again. We'll l 1
13 go back to 5.2.14. We're talking about performing j 14 contamination swipes of the monitoring trailer. So now we 15 are trying to identify specifically the areas of '
16 contamination.
17 We know that, first, that there is contamination 18 in the trailer because that one individual may have reached 19 across and identified there is contamination.
20 Now we want to identify to what extent the trailer 21 has been contaminated following that path of travel of that 22 contaminated individual back to the trailer entrance.
23 Q And that is done using the gross swipe technique 24 with the cloth?
25 A (Cotter) They could either do a gross swipe, or
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] I REBUTTAL, PANEL NO..17 - CROSS 25723' j'~s 1 several gross contamination swipeA which would be smaller
- 2 areas, trying to identify smaller: areas. And that could 3 also be done in the same method,=only not doing such a large-4: area.
5 They could just drag smaller 1 areas and then 6 monitor that with their instrument. Do'another area, 1 7 monitor that with an instrument. And move up until they 8 identified the areas that need attention.
9 Q Now during that process, the monitoring trailer 10 lead person at the doorway would not allow other evacuees 11 come in to walk over that same pathway,1 correct, until the 12 check had been made?
13 A (Cotter) Over the areas that are being affected,
/ 14 that's correct.
l l 15 Q And who is it that'comes with the swipes then to l
16' do this check? q l
1 17 A (Cotter) Okay, there is a couple different !
18 situations here now.-
19 If it's just a routine gross. contamination survey. l 20 Q Yes.
21 A (Cotter) Someone from outside the trailer can be 22 brought in. We have spare people. We have people that'can 23 just walk up the stairs with a maalin cloth and'just do the- i 24 gross contamination survey as we have identified.
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4 REBUTTAL PANEL NO. 17 - CROSS 25724 1 where maybe we have stopped the flow so that we can deal 2 with this particular contamination, all of those monitors 3 that are not freed up are also available to either reach 4 across and do monitoring in their specific areas, or one of 5 them could come across and deal with that contamination.
6 0 You all have these swipes available to you right -
7 there?
8 A (Cotter) In the decon area with the cabinets up 9 above, down below the -- they have all of the --
10 Q So someone would quick go to the cabinets, get one 11 or more swipes and they would quick check the path that that 12 particular individual had traveled 13 A (Cotter) Yes.
14 Q Okay.
15 Now you had already identified, or your worker has 16 already identified a spot where the person was standing when 17 they got monitored, which is contaminated. So you don't 18 need to swipe there, correct?
19 A (Cotter) It has been identified. It wouldn't 20 take a whole lot to do a direct frisk on that area to 21 reidentify it.
22 Q Okay.
23 Well, then, having located the places, is it 24 likely that if you've got somebody who has contaminated the 25 area right in the monitoring station, there may be what,
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I ' ll REBUTTAL PANEL NO. 17 - CROSS 25725 9 2 1
footprints that follow back to where they came in that would be contaminated?
, points 3
4 5
6 7
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Heritage R rting rporation
REBUTTAL PANEL NO. 17 - CROSS 25726 3 (Witnesses confer.)
2 A (Cotter) There's a possibility that there would 3 be footprints. But it's much like a tire that may have 4 picked up contamination in a contaminated area. By the time 5 it reaches a reception center there would most likely.not be 6 much contamination. If he had been walking for any amount .
7 of time, I wouldn't expect that there would be a lot of 8 contamination, for instance, falling off of the individual 9 at the time.
10 0 Well, it makes sense that it would get 11 progressively weaker the more the person walked, the more 12 steps they took.
13 A (Cotter) That's correct.
14 0 Is that correct, Mr. Littlefield?
15 A (Littlefield) That would be correct.
16 O And does that lead then to a logical assumption 17 that if they were standing in line on the steps before 18 getting into the trailer and you located contamination on 19 the floor where they stood when they were monitored, that 20 you might have actually more contamination out on the steps? .
21 Is that a logical inference from this, Mr.
22 Littlefield? .
23 A (Littlefield)
It's possible to have contamination 24 out of the steps if somebody has contaminated shoes.
25 Q All right.
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1 We're at the point where we have identified some
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'~ ' 2 places. I'm including in the monitoring stations.
3 What happens next?
4 MR. TROUT: I'm sorry.
5 What happens next?
6 MR. FIERCE: In this process of decontaminating 7 the trailer. That's what we're talking about here.
8 MR. TROUT: No, I know that.
9 But what happens next after what?
10 MR. FIERCE: After.the people in the trailer have 11 identified, using their techniques, the locations of these 12 places where they have some contamination greater than 100 13 counts per minute above background on the gross swipes, and
[~'T 14 apparently may in fact be using the HP-210 probe as well at
'~
15 this point?
l 16 THE WITNESS: (Cotter) I'm sorry. Could you 17 repeat?
18 BY MR. FIERCE:
19 Q Well, I see in the procedure it has "If greater 20 than 100 counts per minute above background is detected on 1 -
21 the gross swipe, using an HP-210 probe do the following:
22 (a) perform a follow-up smear survey to locate the l
23 contaminated area." i i
24 Is that the next step?
l l
fl 25 You've used the swipes. You've located --
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REBUTTAL PANEL NO. 17 - CROSS 25728 1 A (Cotter) No. We've already identified the areas.
2 You proceeded your question with "we've identified the 3 areas". The next --
4 Q Using the swipes.
5 Is this sentence to be read some way differently 6 than I'm reading it here? -
7 When it says, "If greater than 100 counts per ]
8 minute above background is detected on the gross swipe," I 9 read a "then" in there.
10 A (Cotter) Okay.
l 11 Q A "then" in there. Then, using the HP-210 probe, 12 do the following.
13 A (Cotter) Okay, we've already gone through that ]
l 14 step. The gross swipe was how we identified the areas of 15 contamination, if you recall. j 16 -Q Okay.
l 17 A (Cotter) And then we further broke down the areas l
18 using these gross swipes. We had already arrived at that i l
19 point where we had identified the areas of contamination. I 20 Q All right. ;
21 Are you using the HP-210 probe to do that?
22 A (Cotter) A monitoring instrument is required in l
. 1 23 order to determine the levels, So certainly the HP-210 is 24 available right there in the decon area, and it would be 25 used in the determination, yes.
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REBUTTAL PANEL'NO. 17 - CROSS .25729 1 Q 'All right'.- And then the next step is, 2 " Decontaminate contaminated area using maalin cloth or l
- jl l
3 contain the contamination'with herculite duct. tape."
1' 4 Is that the procedure that would be followed?:
1 5 A (Cotter) Yes.
. 6 Q It would be rubbed with maslin cloth first to'see ;
- 7. if you could remove it?
8 A . (Cotter) ' Yes. The maslin cloth.is an oily type 9 rag. It's a very commonlyLused decontamination tool in 10 nuclear industry throughout the country, and is fairly 11 effective in picking up contamination because of.its. oily 12 nature. It picks up dust and dirt which'is essentially.how 13 contamination is also picked up.
/ 14 So the maslin' cloth would'be used-for j 15 decontamination, unless the time --.we didn't want to spend
~
16 the time and we could contain it, and that's what it's l 17 talking about, contain it,with paper or herculite.
~
18 JUDGE COLE: It's covered up.with paper?
- l 19 THE WITNESS: (Cotter). Merculite is'a. covering, )
l 20 right. "
21 BY MR. . FIERCE. .,
'l 22 O Who is doing this then?' !
. 1 23 The same workers at the stations that have been~ l 24 held up in this process?
25 A (Cotter) Again, there aren't.a whole lot of
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REBUTTAL PANEL NO. 17 - CROSS 25730 1 persons that it takes to do this function. It could be an 2 individual from the decon area who has come over to do it.
3 It could be someone from outside who has come'in to do it.
4 Q Again, there is nothing in the plans and 5 procedures which direct -- other than this procedure --
6 which direct how this is to be done, correct? .
7 A (Cotter) That's correct.
8 Q Would it be fair to say that the person in the l 9 monitoring station, the monitor in the monitoring station 10 who first found the first spot would be doing the maslin 11 cloth or the taping, if necessary, for that location?
12 A (Cotter) No, they would deal with the 13 contamination as a whole. Ideally, they would have someone 14 who was already on the controlled side doing that, whether l 15 it be a decon person.
16 0 I see.
17 You would rather not have your monitoring workers 18 step across the line, correct? l 19 A (Cotter) We would rather not have that, yes.
1 20 0 Has New Hampshire Yankee done any drills or tests 21 to determine how long this whole process takes?
a 22 A (Cotter) We have demonstrated decontamination 23 just the way we have described many times during the 24 operation of the monitoring trailers in drills and walk-25 throughs and whatnot. Yes.
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'- 1 Q Were any such decontamination efforts made during
'- 2 the exercise, the graded exercise when the monitoring drills 3 were underway?
4 A (Cotter) Not during the 20 minute span of each of 5 the monitoring tests, no.
- 6 Q Has anybody timed average time that it takes from 7 start to finish to determine -- having made an evaluation
~
8 that you want to check. Somebody then checks with their 9 probe, they find contamination, they signal to the leader,.
10 people get swipes, they check the foot path, and then they 11 take the maslin cloth and they make their efforts. And if 12 unsuccessful, do a little taping, how long that process 13 tapes?
14 A (Cotter) I don't have specific data --
15 Q Nobody has done any tests.
16 A (Cotter) -- with me to do that.
17 0 Okay.
18 If an individual is'found to have contaminated 19 feet, and the normal procedure is direct them to the decon. ,
1 1
20 area. j
. 1 21 Are they asked to perhaps wait and not walk to the 22 decon area until they remove their shoes, or is any kind of 23 instruction te that given?- l l
24 A (Cotter) Typically, what's been demonstrated in !
l 25 the exercise is you really would never have an individual .l I
l
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REBUTTAL PANEL NO. 17 - CROSS 25732 1 walking to the trailer with contaminated feet, because the 2 monitoring decon leaders take it upon themselves to set up a 3 monitoring, a hand and foot monitoring station prior to 4 someone approaching the stairs to the trailer.
5 So before someone even steps on the stairs, they 6 would do a quick hand and foot frisk. If.they identify .
7 contamination, they have plastic boots and gloves that they 8 would issue right at that location and say, just put these 9 boots on.
10 When they get to the top of the stairs, when their 11 turn in line comes up, they go straight to the decon area 12 and they bypass monitoring altogether.
s 13 0 I'm aware that that was dono during the exercise 14 for a time. But that is not part of the plans and 15 procedures in the SPMC, is it?
16 A (Cotter) That's correct. '
'17 Q And in fact during the monitoring drills during 18 the exercise, that was not done, correct?
19 A (Cotter) That's correct.
20 JUDGE COLE: Why did they do it before then?
21 THE WITNESS: (Cotter) Well, the monitoring decon 22 leaders at each of these facilities, they typically have a 23 pretty good handle on contamination control. Most of them 24 have come through Navy nuclear programs and whatnot.
25 And for their own purposes, they said, hey, I'm !
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.1 not-going to let the most Lobvious type of contamination,, i 2- . cross-contamination happen'in'myffacilities. I'm going to 3 put someone out front;and do's hand and frisk monitor to-4 . identify that contamination, ahead of time'and avoid:any kind-5- of contamination events or contamination 1 situations from
.. '6 happening onzthe floor..
7 Soiif ;they' identify those right up front, they put, 8 . boots and gloves'on~them, send them right to the decon area.:
9~ JUDGE COLE: That sounds like a' pretty good idea.
10 THE WITNESS: '(Cotter) Yes.
11 JUDGE COLE: Okay.
12 I
13 I
(' 14 15 6
17 18 19 1
20 1 21 22 23 ,
24 !
1 25 l
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REBUTTAL PANEL NO. 17 - CROSS 25734 1 BY MR. FIERCE:
2 Q Looking at the flow path diagram, Attachment.4 to 3 IP-3.4, if the person whose feet were contaminated -- we're 4 at the bottom end of this diagram, toward the bottom -- in l 5 that monitoring station and then were told to go to the j 6 decontamination area, they would walk the entire length of -
7 the controlled area pathway, would they not, and could !
^
B perhaps' contaminate that entire floor area as they walked?
9 A (Cotter) Well, given the premise of the question ,
l 10 that someone would actually make it down to that area with ;
11 contaminated feet.
I 12 Q Yes. j 13 A (Cotter) They, again, would be issued booties, 14 plastic booties to contain that contamination at that point 15 before they would be asked to walk down to the.end of the t
i 16 trailer. !
17 Q Where is that in the plans and procedures?
18 It's not there, is it, Mr. Cotter? j I
19 A (Cotter) No, I don't believe that step is in the 1
20 procedure. l l . l 21 0 That would be a good idea, too, to have booties I 22 issued right there at the monitoring station to people whose 23 feet were found contaminated?
l 24 A (Cotter) It's a very good idea.
25 JUDGE McCOLLCM: But are you saying that it is 1
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l l
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REBUTTAL PANEL NO.>17,-' CROSS 25735~
1 done at all of the monitoring; stations?
3_ % 2 THE WITNESS:- ,( Cotter)l That has been 3 demonstrated.
4- JUDGE McCOLLOM: LThat meanszthat'the foot covers 5 are provided.there automatically?.
. 6 THE WITNESS: (Cotter) Yes,:.we have footi 7 coverings in the trailer. And in every.one of the. drills i 8 and exercises that has been done-as part,of'a good 9 contamination control effort.- ,
10 : JUDGE McCOLLOM: I know they're'in the 11 decontamination part,.but are they distributed along all the'
^~:
12 monitors? s 1 .
l 13 THE WITNESS: (Cotter) They' typically pick them 14 up. Just like their clean tags, they would pick-them'up and 15 put them in a back pocket or have-them available. And.if 16- they're not available -- for instance, if they have run out 17 of them in their pocket they-will ask that person to stay 18 there and get them. But they typically have.them with them.
l l 19 BY MR. FIERCE:
20 Q During the monitoring drills, during the exercise, 21 the bootie issuance procedure did not occuri correct?
l 22 A (Cotter). Excuse.me?
l
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l 23 Q During the monitoring drills, during the exercise?
l l 24 A (Cotter) Are you talking specifically about the 25 tests or during the course of the exercise?
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REBUTTAL PANEL NO. 17 - CROSS 25736 1 Q During the tests?
2 A (Cotter) During the tests? No, there were no 3 plastic booties issued.
4 Q And during the other parts of the exercise it was 5 outside the trailer that the hand and feet frisking was a 6 occurring; correct? .
7 A (Cotter) That's correct.
8 Also I might add, that the reason that during the 9 test they were not issued is because we had the actual 10 contamination that was being identified and there were no 11 sources taped to the bottom of shoes or the soles of feet l
12 which would have been very obvious to a monitor when he l
13 lifted the foot that there was contamination there. So 14 there would have really been no situation where it would 15 warranted issuance and that's why no booties were issued.
16 Q Now, I want to turn to those exercises and drills 17 -- the exercise drills, excuse me, the tests as you call 18 them of the monitoring procedure at North Andover and 19 Beverly.
20 As I understand it there were two tests at each
~
l 21 facility; is that correct?
22 A (Cotter) That's correct.
23 Q And if I'm understanding your testimony correctly, 24 attached as Attachment C to your testimony are some data 25 sheets, it's labeled "ORO reception center monitoring record l
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REBUTTAL PANEL NO. 17 - CROSS 25737
(N 1 sheets, exercise test results for Beverly and North
\'
) )
2 Andover." These are copies of the data sheets that were j 1
3 made during those drills, those four drills? j 4 A (Cotter)- Yes, that's correct. f 5 Q Can you turn to those sheets, Panel? .i i
6 The first sheet which is labeled 1 of 6; do you 7 see that?
8 A (Cotter) Yes.
9 0 I believe I have gathered from deduction that that 10 is a Beverly sheet, although it doesn't tell me that on the 11 sheet as I read it. Is that a Beverly sheet?
12 A (Cotter) Yes, it is.
l l 13 Q And is that the first shift or the first test in
[\ 14 Beverly?
\
) \
15 A (Cotter) It's labeled as test number one. Yes, i
16 that's the first shift, yes.
I 17 Q All right. )
I 18 And if I read this form correctly I see up at the i
19 top a series of hatch marks under " evacuees processed," and 2 20 I believe the number is 62 for the hatch marks; is that 21 correct? It's kind of obliterated on mine, that's why I'm i
l 22 asking?
l 23 A (Cotter) That's correct.
24 Q And I also see below it says: "15 people found 25 contaminated, and a total of 77 people processed," is that p
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REBUTTAL PANEL NO. 17 - CROSS 25738 1 correct?
2 A (Cotter) That's correct.
3 0 Now, the next sheet is circled "Beverly test j 4 number 2." Is this actually the second_ shift that did this 5 test?
6 A (Cotter) Yes, that's correct. . ;
l I 7 Q And I see now 65 people processed as noted by the !
8 hatch marks, and is it 18 people contaminated? Again, mine j 9 is kind of obliterated here: is it 18?
l l
l 10 A (Cotter) Yes, I see 18. l l 11 Q And a total of 83 people processed; correct?
12 A (Cotter) Yes, that's correct.
13 Q And the nexL sheet is for North Andover test 14 number 1. And also, the following sheet, pages 3 and pages 15 4 of 6 are for test number 1 for North Andover; correct?
16 A (Cotter) Yes, that's correct.
17 Q And in that test we processed 89 clean people and IB 26 contaminated people; correct?
19 A (Cotter) Yes, that's correct.
20 Q And that's a total of 115 people; is that correct?
21 A (Cotter) That's correct.
22 Q And then the final sheet, page 5 of 6, North 23 Andover test number 2 tested 66 clean evacuees. And I see j i
24 on page 6 of 6 what looks like 19 contaminated evacuees were l 25 processed; is that correct?
l 1
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REBUTTAL FANEL NO. 17 - CROSS 25739 1 A (Cotter) That's correct.
9 2 0 I also see on page 5 of 6 under the column 3 " contaminated evacuee not ID'ed," one listed. Does that 4 mean there was one person who had a Coleman Mantle that 5 wasn't located?
- 6 A (Cotter) Yes, that's correct.
7 Q Now, is that person included in the 66 then or 8 not?
9 A (Cotter) No, I don't believe he's included in 10 that 66.
11 Q So the total number of people processed in that 12 test would have been 66 plus 1 plus 19; in other words, 86, 13 is that correct?
14 A (Cotter) Yes, that's correct.
15 16 17 18 19 20 21 22 23 24 l 25 I
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REBUTTAL PANEL HO. 17 - CROSS 25740 1 JUDGE McCOLLOM: Did you find out why that one 2 person was missed?
3 THE WITNESS: (Cotter) The note indicated here.is 4 that it was in the back pocket. And other than that, he had 5 gone through.
t 6 JUDGE McCOLLOM: You don't know which monitor 4 7 missed him?
8 THE WITNESS: (Cotter) I couldn't trace it back.
9 BY MR. FIERCE:
10 Q Now, I did note in your testimony the statement 11 that during these drills you were able to process on average 12 54 individuals per hour per station. You were processing 13 people at that rate?
14 Is that correct?
15 A (Callendrello) That's correct.
16 Q And is that average obtained by --
17 A (Callendrello) The testimony actually says, I 18 think, 54.7, yes.
19 Q 54.7?
20 I am just querying now how that average was ,
- i 21 obtained. '
22 Was it obtained by totaling up the total for these !
1 23 four tests? The 115 -- the two from North Andover which is ,
i 24 115 and 86 and the two from Beverly, 83 and 77. Obtaining a (
25 total number of evacuees processed. Those drills were 20 f Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS ' 25741 1 minutes long, and you'say five stations were used atleach:
I
\ 2 trailer. 'So 20 stations were;used. Twenty stations in 20 3 minutes processed, what is it, 361 evacuees? _]
i
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4 A (Callendrello) We haven't calculated it that way..
5 If you would like, we can take a minute and add it up'.
I
. 6 Q Subject to check?
7 A. (Cotter). Yes.
B Q' Three hundred sixty-one,. and'then with that obtain 9 a rate of, I believe, 1,083 evacuees.in one hour'at 20,
. 10 stations. And dividing by 20 would get the -- is that how I 11 you get the number you got, 54.7?
12 Or if not, tell me how you got the number you got?.
13 (Witnesses confer.) -
14 Q I just did that math. I get 54.15, not 54.7.
l 15 A (Ca11endre11o) Yes. We'just verified doing it 16- that way.
17 What we are discussing is whether we averaged it.
18 Did a rate for each test and then averaged those results.
19 We didn't do it, obviously, your way because we came out 20 with a different number.
21 Q Doing it that way, you get 54.15, correct?
22 A (Cotter) That's. correct.
23 (Pause . )
24 A (Callendrello) Are you waiting for us to --
25 Q Yes. I thought you were going to tell me how you 5 Heritage Reporting Corporation
\s (202) 628-4888 1
- .- . _ _ _ _ ______.____m______m _ __ _ .-_____.m, _ ,
REBUTTAL PANEL NO. 17 - CROSS 25742 1 came up with the number you did.
2 (Witnesses confer.)
3 A (Callendrello) I just added it a different way, 4 Mr. Fierce, and I came up with 54.2.
5 Q Can we --
6 A (Callendrello) It may be that that was a typo. I .
7 don't know.
~
8 0 I'm willing to round 54.15 up to 54.2, if you are.
9 Can we agree that that's a mistake in your 10 testimony?
11 A (Callendrello) I can't reproduce 54.7 right now.
12 So 54.2, I can get. So it may have been just typed 13 incorrectly and we missed it.
14 Q Can you confirm for me that these drills were 15 conducted in the same fashion that -- that monitoring 16 proceeded in the same fashion that you have described for me 17 in the testimony here today?
18 A (Cotter) Yes, it did.
19
~
Q People weren't cutting steps out in the process?
20 A (Cotter) No, they were not.
~
21 Q They were following the entire procedure, as far 22 as you know?
23 A (Cotter) Yes, there was one step that was 24 simulated, and that was the issuance of the clean tags.
25 0 There were no clean tags handed out for these Heritage Reporting Corporation (202) 628-4888 l l
REBUTTAL PANEL NO. 17 - CROSS 25743 1 drills, correct?
2 A (Cotter) During the drills, that's correct. That 3 was a simulated step whereas the hand motion was made and an 4 acceptance was also made. So that was a simulated step.
5 O When monitoring workers, in doing the monitoring, 6 the frisking, went over an area of clothing which had a 7 Coleman mantle and the signal sounded in the monitoring 8 worker's earphones, the procedure was followed and the frisk 9 was terminated at that point and the person was sent to the 10 decontamination room?
11 A (Cotter) Decontamination area.
12 Yes, that's correct.
13 Q There were no hand-carried articles that were 14 monitored during those drills, correct?
15 (Witnesses confer.)
- 16 A (Cotter) Hold one second. Let me refer to my 17 notes.
18 (Witnesses review documents.)
19 A (Cotter) That's correct.
20 The articles were used in times other than the 21 monitoring tests.
22 Q Mr. Cotter, I notice that you seem to be answering 23 all these questions.
24 Where were you during these drills?
25 A (Cotter) I was inside the monitoring trciler at Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25744 1 North Andover.
2 Q You were not observing the Beverly drills?
3 A (Cotter) That's correct.
4 They happened at the same time that the North 5 Andover drills occurred.
6 Q Who were these simulated evacuees for these .
7 drills?
8 JUDGE McCOLLOM: Didn't we cover that yesterday?
9 (Pause.)
j 10 MR. FIERCE: I'm not certain. We may have, Your 11 Honor. I have no memory of this specific question.
12 JUDGE McCOLLOM: Massachusetts Electric, was that? i 13 THE WITNESS: (Cotter) Yes. We tried to utilize
]
14 everybody that we had available to obtain the largest pool 15 of people we could put together, because a drill of this 16 nature obviously was going to us up so many people going 1
17 through the trailer. So Mass Electric people were involved, 18 also.
19 BY MR. FIERCE:
20 Q Yankee Atomic people, mutual aid?
21 A (Cotter) I don't believe -- there were no mutual 22 aid people brought in for that purpose. The only mutual aid 23 people were brought in were specifically for shift turnover.
24 Are you sure of that?
25 A (Cotter) Sure that there were no people brought l
Heritage Reporting Corporation (202) 628-4888
l-REBUTTAIr PANEL NO. .17 CROSS ~ 257451 f-~x 1 in' spec.lfically for evacuees'from the Yankee: mutual aid?:
1 2 O The. Yankee mutual aid people were broughtLin,:were 3 they~not, for the exercise specifically to.belsome' simulated 4 evacuees for.these drills,Ecorrect?
5- .A (Cotter) Give'me'a second. ..Let:meirefer to the
- 6 exercise.
7 (Witnesses review document.)
8 JUDGE. SMITH: What's the - relevance ofi this
.9 direction?.
10 MR. FIERCE: I'll have to approach the' Board to; l
11 discuss it with yea - I: would rather not publicly, -Your:
12 Honor.
13 JUDGE SMITH: Well, it should be on your cross-L / 14 examination plan if that's important.- If it's thati .
\s 15 important to your case, you shouldn't -have' to approach- the 16 Board.
17 MR. FIERCE: It's in. Item 9.
.. ~)
18 JUDGE SMITH: -Well, you can come and tell us if 19 you want.
20 We don't favor this approach at.all. It is ;
21 rarely, if ever, necessary. l
)
22 (Counsel approacdes Bench.)
23 (The Board confers.) ,
- 24 THE WITNESS
- (Cotter) To the best. of my 25 recollection, I think the evacuees were coming from more' i
HO Beritage Reporting (202) 628-4888 Corporation
REBUTTAL PANEL NO. 17 - CROSS 25746 1 than one area. And the one that I have already recognized, ;
2 which was the Mass Electric people that we could gather up l 1
3 from the offices.
4 There may have been some other ORO members that j l 5 were sent down to the facilities. But I don't recall mutual 6 assistance, or mutual aid, Yankee mutual aid people being .
7 brought in for that purpose.
8 BY MR. FIERCE: j l
9 Q The mutual aid people were not participating in l l
10 your drills as the --
i
, 11 MR. TROUT: Asked and -- I'm sorry, go ahead.
I 12 BY MR. FIERCE:
13 Q In North Andover, correct? i 14 A (Cotter) No, they did participate in drill No. 2 15 as monitoring personnel. The second shift Yankee mutual 16 assistance personnel who replaced shift No. I were 17 monitoring, were doing the monitoring for shift No. 2.
18 Q All of the people, all of the five people that you 19 claim were in that test No. 2 were from Yankee mutual aid?
20 A (Cotter) Yes. Those five persons filling the ;
I 21 second shift monitoring test No. 2 in both Beverly and North 22 Andover were brought in through the Yankee mutual aid 23 program, or Yankee mutual assistance agreement, whichever 24 you prefer.
25 MR. TROUT: Your Honor, I'm sorry. I thought Mr.
Ileritage Reporting Corporation (202) 628-4888 l
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-REBUTTAL PANEL-NO. 17 - CROSS 25747 1 Fierce's' question was whether. Yankee mutual aid people were' f
t
- j 2 run through the monitoring stations as mock evacuees.
1 3 LMR. FIERCE: That's what I first asked.
4 MR. TROUT- Oh. And now it's'a different' l~
5' question.
6 MR. FIERCE: . He'said he didn't-think so, and now L.
7 he says they were used as they monitors in the drills, the 8 second drill at each facility.
9 -BY MR. FIERCE:
10 0 Is that correct?
11 A (Cotter) As identified in the Extent of Play-
~
12 which is part of our attachment.
i 13 Q Is that your source for.that information?
14 A (Cotter) No, I know that.they were. people, 15 because I met with them and talked with them afterwards, and 16 I know that they came from'that agreement.
17 My source was just to identify that it's already l 18 here in front of me.
19 Q Now looking at the numbers again from.the 20 exercise, each of those~four drills. If my math is correct 21 and I add up the number of contaminated individuals who are 1
22 identified,-there were 78 altogether, correct?
23- Twenty-six in the first drill at North'Andover.
24 There were 19 identified in the second drill in North 25 Andover. Fifteen in the first. drill in Beverly, and 18'in
, Heritage Reporting Corporation i
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REBUTTAL PANEL NO. 17 - CROSS 25748 1 the second drill in Beverly, correct?
2 A (Cotter) That's correct.
3 0 Seventy-eight of-them altogether.
4 A (Cotter) Seventy-eight were identified.
5 Q And subject to check, would you agree, gentlemen, 6 that that 78 out of a total of 361 individuals is roughly 22 +
7 percent?
8 A (Callendrello) That's roughly correct.
9 The objective was to place a contamination source 10 on one out of -- on every fifth individual. So that should 11 work out to about 20 some.
12 Q So this average monitoring rate that you are 13 referencing in your testimony was derived from four 14 monitoring drills in which 22 percent of the evacuees were 15 contaminated, correct?
16 A (Callendrello) Correct.
17 0 And in 22 percent of the monitoring frisks that 18 you did in those drills, those frisks were cut short when 19 the contamination source was found, correct?
20 A (Cotter) That is correct, as we have already 21 discussed.
22 Q Now, before the graded exercise, there was a 23 practice exercise in which a monitoring drill was held of a 24 similar nature, correct?
25 A (Cotter) Yes.
l l
9 Heritage Reporting Corporation (202) 628-4888 l
g- -
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y
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. REBUTTAL.' PANEL'NO. 17L-~ CROSS: =25749' 1; O And in that exercise, was that.the. dress rehearsal-
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- 2. right before the graded exercise?-
3- I should say shortly before.the: graded-exercise
~
4L where this additional monitoring drill wasfconducted.
5 A' :(Cotter) Yes, I believe we-did-tests of:this?
l ' '- 6 nature in the 7dress. rehearsal..
\
7 Q' Okay. _
8 And during!thatl practice exerciseithe:nverage 9- monitoring rate wasionly 35 individuals perLhour;per.
10 station,-correct?
11 A (Cotter) 'I don't have that information.available 12 with me. J 13 w Does anybody on..the Panel wantito confirm:that?. - .
_s 14 A (Callendrello) I have no knowledge'of'what the 15 rate was.
16 MR. FIERCE: 'Your' Honor, at this time I would like 17 to offer into evidence the. Applicants' Answer to 18 Interrogatory No. 63.
19 MR. TROUT: Would you like'to'distributeilt first?
20 MR. FIERCE: I don't have copies to distribute.
21 I'll show it to you, Mr. Trout, so that you'.can confirm that.
22 I'm reading it accurately. l'm just going to read'the.
23 answer quickly into'the record.
24 MR. TROUT: I would like toisee it first, Mr.
25 Fierce, before you read it into the record.
. Heritage Reporting Corporation (202) 628-4888 l
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REBUTTAL PANEL NO. 17 - CROSS 25750 !
1 JUDGE SMITH: Short break. Five minutes. I l
2 (Whereupon, a recess was teken.)
3 4 1 5
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8 9
10 11 I I
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13 i
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18 19 20 21 22 23 24 25 l
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Heritage Reporting Corporation (202) 628-4888
REBUTTAL' PANEL'NO. 17 ' CROSS 25751 1 JUDGE SMITH: We're all ready.
fi ~s
'N 2 MR. FIERCE: Your Honor, I would like'to offer.
3 into evidence at this time, it's answer to' interrogatory 4 number 63 of the~ Mass AG's second setLof interrogatories to 5 the Applicants. And this is'the Applicants' response..
- 6 The question is: " Describe'in detail how'New 7 Hampshire Yankee's ORO proposes.to monitor'8300' evacuees 8 within 12-hours at each of these trailers?
l 9 What is the-assumed monitoring time per-10 individual?
11 How does this compare to the actual. time 12 experienced during drills and exercises?"
13 Applicants' response reads, quote: "The SPMC at 14 Section 3.5.3 and IP-2.9 provides the details for monitoring
('"
\
15 evacuees.
16 The. assumed monitoring time is 70-seconds which 17 includes 60 second frisk plus 10 seconds for the individuals l
18 to step up to and away from the monitoring station.
19 Therefore, 51 people per hour per station times 12-hours l
20 times 14 stations equals 8,568 people.
21 The actual monitoring experienced during drills 22 and exercises was compared to the assumed monitoring time on 23 two occasions: during a practice exercise the average 24 monitoring rate was 35' individuals per hour per station 25 which indicated that the actual time was longer than the Beritage Reporting Corporation l
(202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25752 1 assumed time."
2 The last sentence reads: "During the FEMA graded 3 exercise the average monitoring rate was 54.7 evacuees'per 4 hour4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> per station which indicates that the actual time was 5 slightly shorter than the assumed time."
6 JUDGE SMITH: Do you object? -
7 MR. TROUT: No, Your Honor.
8 JUDGE SMITH: Are you going to offer it as an 9 exhibit?
10 MR. FIERCE: No, I'm just reading that portion of 11 the interrogatory into avidence.
12 JUDGE SMITH: And that's stipulated?
13 MR. TROUT: That's Applicants' answer, Your Honor,
, 14 yes.
15 JUDGE SMITH: Then it's received.
16 BY MR. FIERCE:
17 Q During that practice exercise, that again 18 consisted of a number of tests, not just one test; correct?
19 A (Cotter) I don't understand, the number of tests?
20 Q Well, as you did during the graded exercise, there 21 were tests at both reception centers, two tests at each 22 reception center, four tests; correct?
l 23 A (Cotter) I'm trying to recall again back to the ;
1 24 practice exercise. And not having that in front of me -- l 25 maybe you have that information, you can refresh my memory.
I f Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25753
/-'x 1 JUDGE COLE: By test you mean the 20 minute k
v 2 drills?
3 MR. FIERCE: Each of those drills is -- four 4 drills.
5 JUDGE COLE: Two drills at each center?
- 6 THE WITNESS: (Cotter) Yes, I'm trying to recall 7 back to the practice exercise. There have been so many 8 drills that I have been involved in, specifically that 9 exercise I can't recall if there were one or two or three.
10 It sounds reasonable, though, that if we were 11 planning two for the graded exercise that we would have run 12 two for the practice, also.
13 BY MR. FIERCE:
jN 14 0 In one of those drills, specifically the second
'\ /
15 shift drill in Andover mutual aid responders averaged 16- approximately three minutes to process each evacuee, didn't 17 that?
18 MR. TROUT: Are we -- we're still on the dress 19 rehearsal?
20 MR. FIERCE: Yes.
21 THE WITNESS: (Cotter) Again, I don't have that 22 information in front of me and I can't recall.
j 23 BY MR. FIERCE:
24 Q During the practice drills, both for the graded 25 exercise and the dress rehearsal -- strike that for the l( ) Heritage Reporting Corporation K. / (202) 628-4888 l
REBUTTAL PANEL NO. 17 - CROSS 25754 1 dress rehearsal, you're not sure the mutual aid people were 2 there for the dress rehearsal?
3 A (Cotter) Again, I didn't bring any information or 4 material with me other than for the graded exercise.
5 I could find that out for you.
6 Q But in the graded exercise did the Yankee Atomic -
7 people receive instruction beforehand from the first shift 8 monitors they replaced?
9 A (Cotter) Yes, they did just as identified in the.
10 procedure, they receive instructions on the specific 11 operations of that facility and instrumentation.
12 Q Now, during the graded exercise there was also a 13 monitoring rate drill at the emergency worker facility 14 trailer; correct?
15 (Witnesses conferring.)
16 THE WITNESS: (Bisson) We don't know of a similar 17 test that was conducted at the EWF.
l 18 BY MR. FIERCE:
19 Q Does the panel have available the FEMA exercise 20 report?
21 A (Callendrello) I think I may have a copy.
22 Q I wonder if you would take a look at page 232 of 23 that report and see if it refreshes your recollection 1
24 regarding whether there was a monitoring drill at the 25 emergency worker facility during the exercise?
Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS: 25755 je- 1- A (Callendrello). WhatLpage was that again?
\ 2 'O I believe it's 232,'that's of the original.
3 (Witnesses reviewing document.)
l 4 BY MR. FIERCE:
l 5 Q The middle paragraph specifically?
l . 6 A (Callendrello) I'm reading that middle paragraph 7- and it appears that FEMA did count the time it:took to 8 monitor some people, but it.was not'one:of.the. pulse tests' 9 as we are recalling'it.'
The FEMA exercise report'says: ' "The average time-
~
10 Q 11 required to monitor emergency workers was 79 seconds (based 12 on FEMA observations of the times required to monitor 17 13 persons)."
1 14 Do you have any reason to disagree with that 15 statement?
16 A (Callendrello) I don't disagree that the 17 statement is there. I don't know anything about the test, 18 when they started their clock, when they stopped their l
l 19 clock. I don't know. I don't know anything about the 20 statement.
21 A (Cotter) I think it was more just an observation 22 of the normal monitoring-process rather than;the specific
~
J 23 structured test that we ran in each of the reception y 24 centers. And the reason that they wouldn't have'a test at 25 the monitoring trailer is that we had no need to demonstrate Heritage . Reporting Corporation (202).628-4888'
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REBUTTAL PANEL NO. 17 - CROSS 25756 1 rate of monitoring of emergency workers specifically, only ;
1 2 evacuees.
3 Q The equipment used.at the emergency worker 4 facility to monitor emergency workers is the same equipment 5 you're using at the North Andover and Beverly monitoring 6 trailers; correct? The APTEC/Bicron system? .
7 A (Cotter) Yes, that's correct.
8 Q The monitoring procedure is the same, is it not? )t 9 A (Cotter) Yes, that's correct.
10 0 In Attachment A of your testimony, Panel, on page 11 4 -- I guess it's really beginning on page 3 of.24,.I find a l 12 document which is labeled " Performance testing of G-M probes 1
I 13 at var.ious frisking rates, originator, R.M. Thurlow."
14 Who is Mr. Thurlow?
15 (Witnesses reviewing document.) j
\
16 THE WITNESS: (Callendrello) I believe he's an l
17 employee of New Hampshire Yankee. I don't recall his exact i 18 title though. He's in Health Physics Department, as I 19 recall.
20 Q Is the Panel prepared to discuss this study'i 21 A (Callendrello) Yes, Mr. Littlefield is here to 22 discuss that study.
23 Q On the next page, page 4 of 24, down in what's 24 labeled " Item 3 discussion," the first sentence says, quote:
25 " Guidance found in Reference 2.4 indicates that a standard Heritage Reporting Corporation (202) 628-4888
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' REBUTTAL-PANEL NO. 17 - CROSS 25757-I 1 frisk for-personnel. contamination should be performed using 2 a pancake G-M detector and a count rate me'ter at a. frisk 3 rate of less than two' inches per second or'an equivalently 4 sensitive technique."'
5 Do you see that sentence, Panel?L i
6 A (Littlefield) Yes.
7 Q Guidance -- excuse me, Reference 2.4 is -- the 8 , references are. listed directly above and 2.4 is:-
9 '" Guidelines for radiological protection at nuclear power 10 stations, INPO guidelines85-004., February 1988."
11 Do you see that reference?
12 A (Littlefield) Yes.
13 Q Is this the same' INFO guideline we were discussing 14 earlier?
15 MR. TROUT: Mr. Fierce,-do you want to put the' 16 document in front of the witness when he answers that or- do 17 you just want to stipulate that the' document that you l 18 circulated earlier is 1985, a preliminary draft?-
l 19 MR. FIERCE: Oh, I'm going to ask.him about that, 20 Mr. Trout.
21 BY MR. FIERCE:
22 Q Is it the same guidance, though, the INPO guidance 23 85-004?
24 A (Littlefield) I don't recall the number of the L
25 document that you showed me earlier, Mr. Fierce.
Beritage Reporting Corporation (202) 628-4888
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i REBUTTAL PANEL NO. 17 - CROSS 25758 j 1 (Document proffered to witness.)
i 2 THE WITNESS: (Littlefield) Yes, that's the same f i
3 INFO document number, j 4 BY HR. FIERCE:
5 Q All right.
6 The document I handed you is labeled 1985; -
7 correct?
l 8 A (Littlefield) That's correct.
9 Q This document indicates that there is a February 10 '88 version; is that correct?
11 A (Littlefield) That's correct.
12 Q But it's the same INPO guideline document 1
13 referenced to a new version; correct?
14 A (Littlefield) That's what it appears to be, yes.
15 Q New Hampshire Yankee's reference in this study to 16 a standard frisk rate comes from the INPO guidance document; i
17 correct?
18 A (Littlefield) That's what that states, yes.
19 MR. FIERCE: Your Honor, just a point I would like 20 to make is if the Applicants are bringing in the entire 21 document I would hope they would bring in the 1988 document. )
22 I'm not asking them to bring in the 1985 document. We do 23 want to have the most up-to-date current reference that we 24 can ask the panel about.
25 So I would just make that request.
Beritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25759' l 1 MR. TROUT: Mr. Fierce,.is'this'a document' 2 production request?-
3 MR .1 FIERCE: I'm not trying to be. cagey here, Mr.
4 -Trout. We have a' document --
5 MR.' TROUT:. No, you're:trying to get~me to get.an
. 6 exhibit for you.
7 MR. FIERCE: -- that you provided to me during 8 discovery. You provided to me during' discovery, INPO 9 guideline document. I have taken that document and~I have ,
10 used it-today, and you said you would like to bring in.the 11 full document. I'm not objecting to that.
12 JUDGE SMITH: He.said he's going to' reserve 13 whether he objects or not depending upon what he sees in the 14 full document, as I understand it.
\
15 MR. TROUT: That's exactly right, Your Honor.
16 MR. FIERCE: Well, I'm just recognizing that I am 17 aware that there is a newer document that I haven't been 18 provided by the Applicants.
19 And I'm making the request that if the document is 20 going to be brought in tomorrow that the Applicants do bring i i i 21 in the newer document instead of using the older document i
22 which may have been superseded.
]
1 23 I've got the only document that I hav3 been q 24 provided by the Applicants in discovery. These are not 25 documents that are generally available to the'public.
1 <-~
l(
Heritage Reporting (202) 628-4888 Corporation l
REBUTTAL PANEL NO. 17 - CROSS 25760 l' BY MR. FIERCE:
2 Q Now, referring to this document in this study the 3 reference is made in order to establish a baseline, so to
- 4. speak, for the study; isn't that correct, to a standard 5 frisk in the industry?
6 A (Littlefield) Yes. .
7 O And according to that INPO document, that standard 8 frisk using a standard device is one in which the probe or 9 the detector is moved at less than two inches per second; 30 correct?
11 A (Littlefield) That's correct.
12 Q And this is also the document, at least the '85 13 version that I showed you, indicates the detector is to be 14 stopped for about five seconds at the nose and at the mouth 15 to check for any indications of inhalation or ingestion of 4 16 radioactivity; correct?
17 A (Callendrello) It's the same document, but it's a I 18 different purpose for the document.
19 As I indicated, that's a standard that applies to 20 nuclear power plants. The stated purpose of monitoring in 21 the SPMC, and it's stated on page 3.5-9 of the plan is that 22 we are trying to determine and we are monitoring for l -
l 23 external cor.tamination, not internal contamination.
24 Q Now as I understand this study, what the 25 Applicants are using it here for is to determine what the E
l Heritage Reporting Corporation I (202) 628-4888 1
if , u. l LREBUTTAL. PANEL'NO. 17'- CROSS 25761'
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1= frisk rate in inches per:second, the APTEC probe can'be l 0
\ l l 2 moved at..and still:have the same or'betterscounting; 3- efficiency as the standard. industry equipment with a' smaller-l 4 ' face to it; correct?
5 A (Littlefield) That's correct.
6 Q . Ultimately you're11ooking at what is the" rate'that 7 the APTEC probe can be moved at'and still-have the<same orf 8 better efficiency of that standard probe.when that standard 9 probe is moved at a rate of two inches'per'second; correct?.
10 A- (Littlefield) . Correct.
11 12 13 1
) 15 16 j 1
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23 24 .!
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I ' Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25762 1 Q Now for purposes of this test, the so-called 4 2 standard equipment was an Eberline HP-210 probe.
3 How did the Panel, or-the people doing the study
-4 know that the Eberline HP-210 was in fact a kind of probe 5 that the INPO standards were referring to?
6 A (Littlefield) I'm not sure I can answer that -
i 7 except to say that the Eberline, the 210 probe is the l 8 industry standard for frisking.
I 9 Q On page 10 of 24, this is the summary data sheet. l 10 Am I correct in noting from this data that the 11 test shows that the Eberline equipment gets less efficient 12
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l the faster it's moved?
13 A (Littlefield) That's correct.
l 14 Q And more efficient the slower its moved? l 15 A (Littlefield) Yes.
16 Q And at two inches per section, it's counting ;
I l
17 efficiency is .02817 i 18 A (Littlefield) That's correct.
19 (The Board confers.) l 1
20 MR. FIERCE: .I heard the Board inquiring among 21 themselves, and I have the same question. ,
l 22 BY MR. FIERCE: I 23 O Can you explain for me what counting efficiency is 24 here?
25 A (Littlefield) In this case, it's simply a measure Heritage Reporting Corporation !
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REBUTTAL PANEL NO. 17 - CROSS 25763 f' 1 of the effectiveness of the probe for detecting a source.
?
2 And what they have done is simply taken the counting rate of 3 the instrument and divided it by the disintegration rate of 4 the source. And the resulting units of that are counts per 5 disintegration.
6 So for every disintegration of a radioactive atom, 7 you would get .0281 counts on the instrument.
8 0 When it is moved at a frisk rate of two inches per 9 second?
10 A (Littlefield) That's correct.
11 Q If it were moved at less than two inches per 12 second, that counting efficiency would be somewhat higher, 13 would it not?
14 A (Littlefield) It probably would, although you
[
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15 would reach a limit at some point where the efficiency would 16 not longer continue to increase.
17 Q And the study used the two inch rate, two inches 18 per second rate despite the fact that the INFO guideline 19 says the industry standard is for a probe moved at less than 1
20 two inches per second, correct?
21 A (Littlefield) The INPO guideline states that the 22 INPO recommendation is less than two inches per second.
23 Q This study didn't test the Eberline equipment at 24 less than two inches per second, did it?
25 A (Littlefield) Apparently, it did not, h Beritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25764 1 Q This study doesn't tell us what the frisk rate.in 2 inches per second of the APTEC probe would be to have an 3 equivalent or greater efficiency as the Eberline equipment 4 wnen the Eberline is used at less than two inches per 5 second, does it?
6 A (Littlefield) Would you state that again, please? -
7 Q This study doesn't tell us what the frisk rate in
~
I 6 inches per second of the APTEC probe would be to have a 9 greater or equivalent -- I guess the way I should put it is 10 this way. Strike what I just said, i
11 It doesn't tell us what the maximum frisk rate in !
i' 12 inches per second of the APTEC probe can be and still have a l
13 greater or equivalent efficiency as the Eberline when the I 14 Eberline is used at a rate of less than two inches per .
15 second, does it?
16 The study simply doesn't tell us what that aaximum 17 rate would be.
18 A (Littlefield) Well, it depends on your definition 19 of "less than two inches per second".
20 Is that 1.99 inches per second?
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21 You certainly can tell from the data on the table 22 that at a frisk rate of six inches per second, the !
23 efficiency of the APTEC probe is greater than the efficiency i 24 of the HP-210 at two inches per second.
25 Q This study doesn't tell us what the maximum rate i i
/
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REBUTTAL PANEL NO. 17 - CROSS 25765 1 for the APTEC probe would be that's equivalent or greater 2 than the Eberline efficiency when the Eberline is moved at 3 less than two inches per second.
4 JUDGE COLE: I don't understand your question.
5 Could you read that question back, please?
\
. 6 (Accordingly, the pending question was played 7 back by the court reporter.)-
8 MR. FIERCE: I'm going to withdraw that question.
1 9 BY MR. FIERCE:
10 Q It doesn't tell us what the maximum frisk rate 11 could be and still have greater or equivalent sensitivity to 12 the Eberline probe when it's moved at less than two inches 13 per second, because this study doesn't do any tests of the 14 Eberline probe at less than two inches per second, correct?
15 A (Littlefield) This study --
16- MR. TROUT: Your Honor, I think there are still 17 two questions lurking in there.
18 MR. FIERCE: Is that an objection?
19 MR. TROUT: Yes.
20 MR. FIERCE: I don't think there were two 21 questions in there, Your Honor.
22 I would like the witness to answer.
23 JUDGE McCOLLOM: I wonder, Mr. Fierce, if you are 24 not willing to accept two inches per second as the rate that 25 the Eberline was moved at to try to get a comparison.
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REBUTTAL PANEL NO. 17 - CROSS 25766 1 MR. FIERCE: It was moved at two inches per second 2 and three and four and five and six for this study.
3 JUDGE McCOLLOM: All right.
4 But in order to get a number from what you are 5 talking about, say less than two inches per second, I agree (
6 that that is not something that is easily arrived at unless -
7 you.say is it 1.95 inches per second or what.
8 If you say that it's less than 2 inches per second 9 and it was really 1.999, then it's negligibly less. It's 10 just something that's hard to answer, I think.
11 MR. FIERCE: Well, I would agree with that. And 12 perhaps one way -- it sounds like a dialogue we might have 13 in proposed findings.
., 14 But the question is efficiency and what you could i
15 do in examining other real live drills where people are 16 using the Eberline at less than two inches per second and 17 see, in fact, what the rate was on average and use that as 1
18 the standard.
l 19 THE WITNESS: (Callendrello) We did something 20 slightly different. We asked Mr. Donovan what was the rate 21 and what was the instrument that we should consider as a 22 standard. And we got the answer, the 1.75 inch diameter 23 pancake GM detector and a rate of two inches per second.
24 BY MR. FIERCE:
25 Q Except the reference you give us here in the study Heritage Reporting Corporation (202) 628-4888
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REBUTTAL ~ PANEL NO. 17.'- CROSS _ 25767 ;
'1 is: to the INPO document which says: "less than two: inches per,
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2 second".
3 JUDGE McCOLLOM: Which he has stressed as a 4 guidance document.
5 MR. FIERCE: And the one they relied on in this
- 6 . study.
7 THE WITNESS: (Callendrello) We gave both 8 references.
9-10 11 12 13 14 15 16 l 17 18 19 20 21 22 23 24 25 I
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REBUTTAL PANEL NO. 17 - CROSS 25768 1 JUDGE SMITH: Mr. Fierce, I want to remind you 2 that when the Board asks a question or makes an observation 3 about the quality of the evidence, it is not a satisfactory 4 response to explain that the matter will be addressed in 5 proposed findings.
6 I have explained that to you before and I just -
7 want to remind you that that is the case. l
. 1 8 MR. FIERCE: I appreciate that, Your Honor, i I
9 May I proceed.
1 10 JUDGE SMITH: Yes, please.
j 11 BY MR. FIERCE:
l l l 12 Q I want to ask some questions, Panel, about 13 monitoring special needs individuals and vehicles.
14 Now, the same equipment is going to be used out in i 15 the parking lots for monitoring the people in the buses who 16 come in in the special needs vehicles. I also presume for 17 the bed buses; is that correct?
18 A (Bisson) That's correct.
19 A (Callendrello) There's one correction. People 20 that come in on buses would not be monitored on the 21 vehicles.
22 The buses from special facilities, yes. But there l 23 are also buses --
24 Q Special facilities?
25 A (Callendrello) Okay.
l 0
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, , o-3 REBUTTAL; PANEL'NO.u17 / CROSS- 25769 f i1' Th'ere arel buses?that will have[ transit-dependents t
2 individuals.
3 Q 1 Transit-dependent people,7I unde,rstand, will be 4- Iflowinglthrough:the' trailers.-
~5 'But.the procedureffor, monitoring; people in their!
6 vehicles'--' excuse me, inLthe~ buses.oribedLbuses'_or, :I -
^
7 assume,--itLalso would occur for whatever the1 vehicle-istthat 8 .the?special:needs-individual arrives in,~itfmight1even>be-an 9 ambulance;41s that correct?.
10 A (Bisson) That's correct.
1 11 -A. (Call'endrello) ~ It's not likely to.be an 12 ambulance, but it could be.
.13 JUDGE McCOLLOM: Mr. Fierce?
.i 14- MR. FIERCE: Yes.
15 JUDGE McCOLLOM: I.would-like to see this 16 document, this INPO document, and,I'm going to'ask'for it.
i 17 from him right now. ,
18 MR. FIERCE: Sure.-
]
1 19 (Document proffered to Judge McCollom by witness.) !
-i 20 BY MR. FIERCE: 'l
.- l 21 Q But the procedure I believe:isLImplementing 22 Procedure-2.9, 5.4.4. .I 23 Let's assume we do have a. bus, not a bed bus but'a- -i 24 bus, and we have a' population which is.from a nursing home, 25 and in the bus we have people sitting on both sidesfof the Beritage Reporting Corporation (202) ~628-4888
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REBUTTAL PANEL NO. 17 - CROSS 25770 l 1 aisle, typically two seats on either side of the aisle and 2 they are filled.
3 Can you tell me how the monitoring process will l 4 actually occur in that situation?
5 Will the people, for example, stand up? Will they 6 remain seated? -
7 (Witnesses conferring. )
8 THE WITNESS: (Bisson) Could I have the question i 9 again.
i 10 BY MR. FIERCE: '
l 11 Q Well, in that situation with a bus from a nursing 12 home is filled with the nursing home residents, they are in )
i 13 the bus, the bus has typically an aisle in the middle with 14 two seats on either side of the aisle and these seats are, l
15 in fact, filled with the nursing home residents. That's the )
i 16 setting; that's the bus.
17 Can you tell me how the monitoring process will 18 proceed? And to get the ball rosling 2 just asked, first o 19 Eall, will the evacuee be asked to stand up from their seat 20 or will they remain seating? How will the process work? ,
. l 21 A (Bisson) The process is outlined in the Procedure '
22 step 5.4.4. The emphasis of the monitoring would be placed 23 on the head, shoulder, hands and feet. If this can be done 24 without an individual standing up, then that individual most 25 likely wouldn't be asked to stand.
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-l REBUTTAL. PANEL NO. 17.- CROSS 25771 1 Q In looking at Procedure 5.4.4 (b) (2) which you just
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! 2 referred to, I see the procedure noting to place emphasis _on 3 the scan of the head, the shoulders, theihands and~the, feet.
4 Are you saying the way the procedurefis actually implemented 5 is by reading the word " emphasis" out and, in fact, that is
. 6 what's done, they monitor the head, the shoulder, the hands 7 and the feet, and that's it?
8 A (Bisson) It depends on the individual' involved.
9 If someone is in a wheelchair they would probably just limit 10 it to the head and shoulders and maybe the hands and feet..
11 Only because those would be the most likely spots.to'be.
12 contaminated. While that individual is in a wheelchair is ,
1 13 transported from his facility into the special' vehicle.
/~' 14 Q I've got you in a bus that-is a normal bus, center
\' 15 aisle, two seats on either side, nursing home' residents and 16- they are seated. The monitor, person with the monitor 17 enters the bus. A roster is obtained as it says in step i 18 (b) (1) , and the next step is to monitor each person. . .d 19 I'm wondering how you proceed in that setting?
20 (Witnesses conferring.)
^
21 THE WITNESS: (Bisson) I believe for special 22 vehicles, buses coming from nursing homes where it may be 23 difficult for people t6 stand during a monitoring process, 24 the process may be just limited to the time that.a' person is 25 seated and actually just focus on those areas described in l
l l
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1 the procedure. .
2 BY MR. FIERCE:
3 0 I heard the word "may" in there, and what does
)
4 that mean in practical terms for the person who steps in the 5 bus to do the monitoring? Does he ask if the person can 6 stand up? .
7 (Witnesses conferring.)
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I 14 15 16 17 18 19 20 21 l 22 I .
23 24 25 Heritage Reporting Corporation (202) 628-4888
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~I REBUTTAL PANEL NO. 17 -CROSS 25773- )
j 1 A (Bisson)' As I read that, the-monitoring. person j
( would monitor the individual while he'or'she was sitting'.
2 i 3 0 Well, that's how you understand this, Mr. Bisson. II 4 What does the training, theLORO training say'about l- 5 this point?
. 6- (Witnesses confer.) !
7 A (Cotter) I believe the training follows the 8 procedure, indicating that special populations are monitored 9 on the special vehicles, placing emphasis on the. head.
10 Q So no'further clarify.is offered in the training 11 than is provided to us here in the procedure.
12 Is that correct?
13 A (Cotter) Well, we typically discuss the situation
/'~N i
14 that you have already discounted, which would be if someone 15 arrives in a wheelchair van or an ambulance or that type of 16 situation. We don't have provisions to get that person l 17 through the monitoring' trailer. We monitor them in place, 18 do the best we can given their particular circumstance.
19 0 So if the people remain seated on the bus, the ,
20 monitor will reach over the person on the aisle to monitor q
~
l 21 the person next to the window.
22 Is that how it will work?
23 A (Cotter) Yes. They could certainly from the l
24 center aisle perform the monitor of an' individual by the j 25 window without any problem.
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i REBUTTAL PANEL NO. 17 - CROSS 25774 1 1 Q How about their feet? 1 2 A (Cotter) Certainly they would have to lean over, 3 but, sure, their feet. q 4 Q They could reach to the feet of the person sitting l 1
5 next to the window by leaning over the person sitting next 6 to the aisle? -
7 A (Cotter) It may require asking-the individual to
\
8 pull their feet in a little bit if their feet are extended 9 under the seat in front of them.
10 Q Are articles carried by the nursing home residents )
I 11 all monitored? i 12 A (Cotter) Yes. If they had articles with them 13 much like we would monitor hand-carried articles in the j 14 trailer. We would again attempt to monitor articles if they '
15 had them with them.
16 For instance, if they were clutching their 17 pocketbook or something. !
18 Q There is no mention of article monitoring in the 19 procedure we are looking at here, is there?
20 (Witnesses confer.)
21 A (Bisson) I don't see it listed at all.
22 JUDGE SMITH: Mr. Fierce, we are wondering about 23 the amount of time that you are spending on bus loads of 24 nursing home people.
25 MR. FIERCE: Oh, I didn't want to spend more than Heritage Reporting Corporation (202) 628-4888
l REBUTTAL PANEL NO. 17 - CROSS 25775 i
[ 1 about five minutes on.it, Your Honor. I'm ready to-move on-k' 2 the bed buses ~for a few short questionE. -
3' JUDGE SMITH: Yes. Well, how do they get' 4 contaminated?. )
5 MR. FIERCE: How do people in --
6 JUDGE SMITH: Yes.
-7 MR. FIERCE: Well, I'm not an expert in this area 8 but I could ask Mr. Littlefield. I believe that patients in 9 nursing homes and other special facilities can be 10 contaminated and that's why they are brought to the 11 reception center for monitoring.
i 12 JUDGE SMITH: All right.
13 MR. FIERCE: Is that --
/ 14 JUDGE SMITH: I guess it's theoretically possible, I
\
l 15 but we're trying to envision what they were doing to get 16 contamination on them.
17 MR. FIERCE: Well, I'm assuming that the nursing 18 home could have been in a plume in the summertime with 19 windows that either were open or didn't get shut in time, or 20 perhaps just the sheltering factor -- )
. J 21 JUDGE SMITH: Well, I guess the point;is that the 22 probabilities are such that the time that you spend on it j i
23 just doesn't seem to be commensurate. )
i 24 MR. FIERCE: I promise not to spend more than five j l
25 minutes on bed buses, Your Honor. '
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REBUTTAL PANEL NO. 17 - CROSS 25776 1 BY MR. FIERCE: 1 2 Q There are no procedures currently for monitoring.
3 people in bed buses, are there, or is it the same procedure 1 4 that we're looking at here?
5 A (Bisson) It would be the same procedure we are l 6 looking at. .
)
l 7 Q And the people in the bed buses are laying down l
~
8 when they would be monitored, correct?
9 A (Bisson) Correct.
i 10 0 The procedure recommending that emphasia be placed i
l 11 on the head, the hands, the feet, and I forget what the l 12 other item was.
13 A (Callendrello) Shoulder.
14 Q Shoulders.
4 15 Would in fact be not just the emphasis, but the j 16 limit of the monitoring at that point, wculd it not? I 17 A (Bisson) I wouldn't say it would be the limit.
]
18 Q They would in fact monitor additional portions of 19 the body?
20 A (Bisson) If someone is laying on their back, then l
- 1 21 certainly it would be easy to pass the probe on the areas of J 22 the body between his chin and feet.
23 Q I agree, it would be easy to do.
24 Will they do it in following this procedure?
25 (Witnesses confer.)
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REBUTTAL PANEL NO. 17 - CROSS 25777 1 MR. TROUT: Do you understand the question?
2 THE WITNESS: (Cotter) Well, first, give us a 3 repeat of the question. I think that would help.
4 BY MR. FIERCE:
5 Q Well, I agreed with Mr. Bisson that it certainly 6 appears to be easy to do, to pass the probe over the entire 7 body while scmeone is laying prone in a bed bus.
8 I'm just wondering, given the procedure that we 9 have, whether your people, the ORO monitors in these buses 30 will do that given that the language says emphasize the 11 head, the shoulders, the hands and the feet.
12 What have they been trained to do, if anything, 13 Panel?
] 14 A (Cotter) To monitor the best they can given a 15 particular situation.
16' And the situation that we are talking about where 17 an individual would be laying on their back, there would be 18 that person's back that would end up not being monitored 19 because of the extremely low probability that he was at some 20 time prior to that out roaming around, and now he's 21 bedridden.
22 So the individual would be monitored, again, to 23 the best that the monitor could do that.
24 Q There are no specific plans or procedures for 25 dealing with the evacuees in the bed buses yet, are there?
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REBUTTAL PANEL NO. 17 - CROSS 25778 1 A (Callendrello) I think, as we testified, they are -
f i
2 contained in that paragraph. That paragraph is as 3 applicable to somebody in an evacuation bed' bus as it would j 4 be in any of the other special vehicles.
5 Q How will the decontamination of a nursing home i
6 resident occur?
7 I don't want to go into the whole process, but 8 will it occur in the bus or in the decontamination area of 9 the trailer? i 10 A (Bisson) It would occur in the vehicle. If it 11 was possible to decon in the vehicle that they arrived in, 12 it would occur in the vehicle in which they arrived.
13 0 The same is true for bed buses?
14 A (Bisson) Yes, sir.
15 Q There is nothing in the plans and procedures 16 directing how this should be done or even where it should be 17 done, is there?
18 A (Bisson) Step C of this procedure paragraph 19 reads: "If contamination is found, decontaminate under the 20 direction of the monitoring decon leader."
21 Q And if you are the monitoring decontamination 22 leader, is there a procedure anywhere that tells you how to 23 proceed?
24 A (Bisson) The basic procedure for the decon 25 process as it -- of course, it would have to be modified or Heritage Reporting Corporation (202) 628-4888
1-1 REBUTTAL PANEL NO. 17 - CROSS 25779
("' 1 limited to individuals in'special1 vehicles. That is, if:it x 2 was possible just'to wipe down.the loca1' contamination, if-
~ ~
3 it was just an area'of the. person's; face, that could be done 4- in the vehicle.
5 If the contamination involves moving' people who 6 may be-stretched out.in a bed' bus,-that.probably wouldn't-7 occur.
8 Let me correct that last statement.
9 It wouldn't occur at that facility. The 10 individual would be referred to an MS-1 hospital for l
11 decontamination.
12 Q How do they get to the MS-1 hospital?.
13 MR. TROUT: I'm going to object. 1 1
14 I think we went into that at some length with two 15 prior panels.
16 BY MR. FIERCE:
17 Q Well, another vehicle, correct?' ;
18 An ambulance takes them?-
19 A (Callendrello) Not necessarily.
20 If somebody in a vehicle, in the bed buses is !
21 contaminated, I would think that we would just take them in-I 22 the vehicle they are in.
23 Q Take the entire busload?
24 A (Callendrello) That's correct. j 25 O Even though perhaps most or even all of the rest 1
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REBUTTAL PANEL NO. 17 - CROSS 25780 1 of them may not be contaminated.
2 A (Callendrello) Well, I don't think it's likely 3 that they would be contaminated anyway. But if you have one 4 person who came from one location and is contaminated, 5 chances are better that the other people on that vehicle 6 would be contaminated if they came from exactly that same -
7 location.
8 O There is nothing in the plans and procedures that 9 says that either, is there, Mr. Callendrello? Is there, 10 Panel?
11 A (Callendrello) I don't know what the "that" 12 refers to.
13 Q That if someone is on the special needs bus or the 14 bed bus who cannot be decontaminated using the wiping 15 method, take the whole bus to an MS-1 hospital.
16 MR. BACHMANN: I'm going to object to this line of 17 questioning, Your Honor. He has not tied it into 18 monitoring. Decontamination is just not part of this issue, 19 and this just seems to be a pure decontamination line of 20 questioning.
21 MR. FIERCE: I can tell you it's not " pure",
22 because I am concerned about what happens to this bus in the 23 parking lot.
24 JUDGE SMITH: Oh, this is a parking lot problem?
25 MR. FIERCE: It has both aspects to it here, Your Beritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL:NO.'17 - CROSS 25781 l' Honor.
) .
\s 2 JUDGE SMITH: What's the other aspect?
3 .MR. FIERCE:- Well, there is the. monitoring rate 4 issue, and --
5 JUDGE SMITH: But isn't he correct?'
.- 6 You've got these people off: on. the bus: headed! for.
7 decontamination,.and the problem has:beenstaken out'of the.
8 issue. It's somebody else's problem'now.-
9 MR. FIERCE: Well, .perhaps.. I haven't explored it' 10 enough to know yet.-
11 JUDGE SMITH: Well, that's'not a good enough 12 reason.
13 Sustained.
14 BY MR. FIERCE:
('~
15 0 Panel, in a bed bus or in a regular special-16 facilities bus, if you get to the first row'and you do your 17 monitoring and you find someone contaminated, do'you begin 18 the decontamination process immediately?
19 Is there someone-following behind who'does that?'
20 Or do you monitor the entire bus and then go back
~
21 and do the decontamination steps?
22 (Witnesses confer.)
23 MR. TROUT: May I request a clarification?
24 Is the question whether there is a procedure, a 25 reference in the procedures as to whether you go through the -
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REBUTTAL PANEL NO. 17 - CROSS 25782 1 entire bus monitoring, and then go back and decon, or you 2 stop along the way and decon before you go on to monitoring?
3 Is that the question?
4 MR. FIERCE: Yes, 5 (Witnesses confer.) ;
i 6 , ,
7
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9 ;
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15 l 16 17 18 19 20 21 22 23 24 25 l
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- / ' 1 THE WITNESS
- . (Callendrello)- That's not specified 2 in the procedure.
3 I would have to check with'Mr.' Cotter to see'if' 4 that subject is touched in the training'.
5' THE WITNESS: (Cotter)l No,Jwe' don't specifically a
6 address the sequence of monitoring ~an individual.first, then 7 decontaminating one;' moving to.the.next. monitoring and 8 decontamination; . or' monitoring the whole' bus, that's .not-9 addressed.
10 They're instructed to monitor the personnel.
11 Decontaminate as instructed by the monitor decon leader, i
12 BY MR. FIERCE: i 13 Q There have been no drills or tests.to determine
[
\
14 how fast the ORO can monitor special'needs' evacuees in j 15 buses, have there?
16' A (Callendrello) No.
17 Q And in monitoring the person,. if the clothes are 18 found to be contaminated and the' monitoring decon leader is 19 called, do you know what the procedure is for dealing with' 20 contaminated clothing on the bus?.
21 A (Bisson) The procedure is outlined in step 5.5.3.
22 Again, it would be applied, probably, in somewhat of an 23 abbreviated fashion given the situation we're talking about.
24 Q Abbreviated in the sense that they're not going to 25 be asking people to remove their clothing in the bus in T 1
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REBUTTAL PANEL NO. 17 - CROSS 25784 i
1 front of all the other people; correct? j 2 A (Bisson) Correct.
3 Q So they won't be removing the contaminated {
4 clothing, they will be making whatever efforts they can? l I
5 A' (Bisson) If it's just an outer clothing -- for j i
6 instance, if a person is covered by a blanket or something -
j 1
7 like that, and certainly that can be removed.
- i 8 Q But the clothing itself would not be? {
9 A (Bisson) If it meant that that person -- for 10 instance, if it's just an outer sweater and it could be i
11 removed without disrupting that person, then it could be j i
12 removed. {
13 0 Discretion would be utilized in this process?
14 A (Callendrello) Common' sense, yes.
I 15 Q The decontamination process would not use any of q l
16 the water-based methods in the buses; correct? )
17 A (Bisson) That's correct.
1 18 Q Now, according to Procedure 5.2.9 of Implementing 19 Procedure 2.9 there are to be four monitoring decon 20 personnel assigned to standby and monitor special vehicles 21 and school buses; correct?
22 A (Callendrello) As I indicated yesterday, we 23 considered those four individuals plus the four individuals 24 to monitor other incoming vehicles, to be a pool of 25 personnel available to monitor either private vehicles or Heritage Reporting Corporation (202) 628-4888
i REBUTTAL PANEL NO. 17'- CROSS 25785-1 special vehicles.
2 O Are the four individuals typically going to.be 3 monitoring the special vehicle itself and then the:peop39 1 4- inside it or the same group of people, some will be 5 monitoring the - bus while others will be inside of it; 'is
. 6 there a procedure on that, that you're aware of?'
7 A (Bisson) I think.this pool of people would take' 8 the situation according to need. Forfinstance, if a special-9 vehicle came in and there was a free, person who was 10 designated for vehicle monitoring' d there was no other 11 vehicle, then certainly, I could see that person helping out 12 in the situation.
13 O Let me pose a situation where the facility is
'" 14 busy, the people monitoring the personal vehicles are busy, l \
l 15 there's at least four lanes. _And people who are assigned to 16 be decontaminating the vehicles and articles are, in fact, 17 busy. And there are, in fact, four, people available to 18 monitor the special vehicles and the buses and the people 19 inside them. And there are four buses who pull in all at 20 once from a nursing home or two or three nursing homes.
21 Will the four buses be placed in a line such that-22 the four individuals can, together, work and complete the 23 first bus and then move to_the second, third, and fourth or 24 will, in fact, the four workers each take a bus; how does 25 that work?
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9 REBUTTAL PANEL NO. 17 - CROSS 25786 1 (Witnesses conferring.)
2 JUDGE SMITH: Is that in your cross-examination 3 plan? On your personal one; it's certainly not on mine?
4 But is it on your personal cross-examination plan or are you 5 just making up these as you go along?
6 MR. FIERCE: Well, I'm in number 11. . l 7 No, it's in my plan as well, in number 11. ,
8 JUDGE SMITH: The four' buses and people going 9 along, that's all planned cross-examination? !
I 10 MR. FIERCE: Yes, it is.
11 JUDGE SMITH: Let me see. I want to see that.
12 (Pause) 1 13 JUDGE SMITH: I think, Mr. Fierce, we're going to 14 have to think about a time limit now, which we don't like to i
15 do , because of the quality of your questions. !
16 MR. FIERCE: Perhaps I can -- if you can be 17 specific in giving me some guidance I'll try to shape. I 18 understand that I'm going into a series of areas where I 19 believe there are no plans and procedures or inadequate 20 plans and procedures which is just what this contention 1 e 21 says.
l .
22 JUDGE SMITH: And including those, whether you go 23 one at a time and four buses or four times in one bus in 24 sequence, that is all part of your thoroughly tnought out 25 cross-examination plan or did it just pop up as something i
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REBUTTAL PANEL NO. 17 - CROSS 25787 1 that came to mind?
9 2 I keep having difficulty on relevance anyway, but
- 3 I have sort of given up on that.
4 MR. FIERCE: There are two issues I'm dealing 5 with, with this issue, Your Honor. And there are just the
- 6 two issues I have been focusing on all day.
7 JUDGE SMITH: Time in the parking lot.
8 MR. FIERCE: There's the monitoring rate time.
9 JUDGE SMITH: Monitoring rate time.
10 MR. FIERCE: For individuals in special vehicles, 11 and they have some calculations on that.
12 And there's also the bus stay time, they have 13 calculations on how many buses they can handle and how many 14 parking spaces for buses they need.
15 JUDGE SMITH: Of course, the more buses you have 16 in there the fewer cars.
17 MR. FIERCE: I think they're parking the buses in 18 a different place, so I'm not sure that's true.
19 JUDGE SMITH: All right, never mind. .
20 MR. FIERCE: I would like to wrap this up very 21 quickly, if I can, 22 JUDGE SMITH: Yes.
23 Well, we're getting impatient with the level of l
24 the detail. j 25 9 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25788 1 BY MR. FIERCE:
2 Q Is it fair to say, Panel, that there just is not a 3 procedure or plan for how these four individuals will deal 4 with a small convoy of buses who arrive -- to arrive 5 simultaneously when other people are busy, and it's just 6 these four individuals who will have to deal with these -
7 buses? I 8 JUDGE SMITH: That's divided up one at a time and q l
1 9 four buses or four one bus at a time.
10 MR. FIERCE: All I want to know is, if there's a 11 procedure and they can tel1~me there is, I'll move on. ,I f ,
12 there isn't and they can tell me that, I'll move on.
13 JUDGE SMITH: That may be the solution.
14 (The Board confers.) l l 15 JUDGE SMITH: Of course, Judge McCollom has l
16 propounded the better question of them all and that is, is 17 the procedure needed?
18 Mr. Callendrello's answer of " common sense" a 19 little while ago seemed to throw a monkey wrench into the 20 scheme.
P 21 Is there a procedure?
22 THE WITNESS: (Callendrello) No , there isn't.
23 JUDGE SMITH: Do you think you need one?
24 THE WITNESS: (Callendrello) No, sir.
25
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'*%g 1 BY MR. FIERCE:
N- 2 -Q You don't have any intention to change the plans 3 with respect to the monitoring and decontamination of!these :
4 special vehicles or the people on.the special vehicles;.
5 correct?
- 6 MR. TROUT: Change the plans in any regard;-is 7 .that the question? 1 8 BY MR. FIERCE:
9 Q You don't have any present-intention to change the 10 plans and procedures for staffing or'forlthe procedures 11 themselves to deal with the monitoring'and decontamination 12 of the special vehicles and the people in those vehicles; is 13 that correct?
14 A (Callendrello) No, that's not correct.
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15 We indicate on page 10 of the testimony that the 16' eight personnel that are available to monitor private 17 vehicles, buses, school buses and vehicles from special-18 facilities will, in essence, be considered a pool and the 19 monitoring decon leader can reassign those personnel as 20 needed to assure adequate coverage. So that is a change in "
, 1 21 the procedure from where those -- there were four 22 individuals for one specific function, four for another.
9 23 We're now treating them es a pool of eight individuals. !
24 Q On Procedure 5.4.4 is a procedure'for' monitoring U 25 special populations and I'm wondering whether it also refers 0; Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 17 - CROSS 25790 1 to people in the monitoring trailers; does it or does it 2 not?
3 A (Bisson) This specific paragraph here?
4 Q Yes.
5 A (Bisson) I think right in front it's identified 6 for special populations and special vehicles. .
7 Q Does this apply to people who are in -- this 8 procedure: "When directed by monitoring decontamination 9 leader to perform monitoring special population and special l
10 vehicles do the following."
11 Does that apply to the people who are in the 12 trailers doing monitoring as well as the people out in the 13 parking lots?
14 A (Bisson) No, sir. That applies to the pool of 15 people that are available for vehicle monitoring and special
! 16 population monitoring.
l 17 Q When I go back to Implementing Procedure 2.9, !
18 Section 5.2.9 which is the assignments of personnel for 19 outside the trailer I see, in addition to the lead, four 20 monitoring decon persons to monitor incoming vehicles; four 21 to decontaminate vehicles and articles; four monitoring l 22 decontamination persons to standby to monitor special 23 vehicles and school buses.
24 Now, is it Item 4, is that directing those people 25 to monitor both the vehicles themselves and the people in 1
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REBUTTAL PANEL NO. 17'- CROSS 25791 j
/ 1 them; is that the understanding? l
-/ 2 A (Bisson) That this paragraph applies to those i
3 individuals. ;
4 Q In Item 4?
5 A (Bisson) In Item 4,-for monitoring a 6 decontamination persons to standby to monit; ' special-7 vehicles and school buses, would be' implementing step 5.4.4.
8 Q. Okay.
9 Now,.again,'it's the APTEC/Bicron system?
10 A (Bisson) That's. correct.
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11 MR. FIERCE: I am going to pursue another item 12 here, Your Honor. Do you want to break now, I'm moving to-13 Item 11.
14 JUDGE SMITH: All right, let's break.
15 But I do want to caution you that you're going to 16 have to raise the level of your questioning, otherwise we 17 will be required to put a time limit on.
18 MR. FIERCE: I understand the Board's concern and 19 will do whatever I can.
i i 20 JUDGE SMITH: It's just the level of 'the ,
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I' 21 questions, the productivity of the questions that.is coming 22 to our attention here, my attention in any event. l 23 I notice on your cross-examination plan of the i j
24 parking, Item No. 3, that much of that was covered today, I )
25 trust. ,
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25792 1 MR. FIERCE: I think some of,it was covered today, 2 Your Honor.
3 JUDGE SMITH: I hope that will be relatively 4 short, too. Go to the important aspects.
5 MR. FIERCE: Well, we did discuss the combination 6 of the functions, the panel brought out this morning.
7 JUDGE SMITH: Well, I understand your theory that 8 it will all become clear on proposed findings. But 9 nevertheless, we are charged with the responsibility of 10 moving the hearing along and making sure that the cross-11 examination is understandable, is cogent, is relatively 12 efficient, is no longer than is necessary. And I think we 13 are failing in that responsibility with respect to your l 14 cross-examination.
15 MR. FIERCE: Your Honor, I will do whatever I can 16 in my power to obey that command and will try to sharpen 17 this for tomorrow.
18 At the same time I did want to caution the Board 19 that I am not going to be taking up all day tomorrow.
20 JUDGE SMITH: Well, you certainly are not. That's 21 exactly the point.
22 MR. FIERCE: And that we have no other witnesses 23 who will be testifying tomorrow, and I do expect we will 24 have some down-time tomorrow.
25 JUDGE SMITH: That's fine. Neither is that the Heritage Reporting Corporation (202) 628-4888 4
25793 1 point. We just don't cross-examine because we have nothing 9 2 else to do.
3 MR. FIERCE: I'm clearly not going to be doing 4 that.
5 JUDGE SMITH: All right.
< 6 MR. TROUT: Your Honor.
7 JUDGE SMITH: Must this be on the record?
6 MR. TROUT: No, Your Honor.
9 JUDGE SMITH: We'll adjourn until tomorrow.
10 (Whereupon, at 5:28 p.m. the hearing was adjourned 11 to reconvene tomorrow morning at 9:00 a.m., Thursday, 12 June 15, 1989.)
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June.14,.1989 1
UNITED STATES ~OF AMERICA !
NUCLEAR REGULATORY. COMMISSION ]
BEFORE THE 4 ' ATOMIC SAFETY AND LICENSING BOARD l
)
In the Matter of- -)
)
PUBLIC SERVICE COMPANY )' Docket Nos. 50-443-OL OF NEW HAMPSHIRE, et al. ) 50-444-OL
.. ) . .
(Seabrook Station, ) '(Offsite Emergency Units 1 and 2). )- Planning Issues)
)
APPLICANTS PLAN FOR THE CROSS-EXAMINATION OF THE TESTIMONY ;
O OF CAPTAIN DANIEL BRETON AND JOHN VAN GELDER, FIREFIGHTERS' i ( FOR THE TOWN OF SALEM, NEW HAMPSHIRE ON BEHALF OF THE SEACOAST ANTI-POLLUTION LEAGUE, REGARDING-SAPL CONTENTION EX-12 (RECEPTION / DECONTAMINATION CENTERS) 1 I. Backaround.
Applicants will inquire about the lengen.of time Mr. -.
l Breton and Mr. Van Gelder have held positions as firefighters with the town of Salem, any'other firefighting experience they have, who contacted them about presenting testimony, and when-they agreed to testify.
II. Number of Firefichtina Personnel Available.
The witnesses will be asked z. bout the number of firefighters in the Salen department, the existence of any reserve firefighting personnel, the power they 'have under.
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state law to conscript the services of persons present during an eme.gency, and their knowledge about Salem's Mutual Aid Agreenents with other towns.
III. The Witnesses' Opportunity to View the Exercise at the Salem Hich School ReceDtion Center.
Applicants will ask Mr. Breton about his leaving the Salem High School before the monitoring and decontamination began, when he arrived, whether he saw persons from the state .
Department of Public Health Services arrive, and when he
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departed.
Witness Van Gelder will be asked when he was present at Salem High School and whether he accompanied Salem Fire Chief 1
Donald Bliss throughout the exercise.
IV. Whether Captain Breton Was Desicnated " Senior Firefichter" Durina the Exercise.
i l Applicants will inquire of Mr. Breton whether he was l
designated " Senior Firefighter" on the day of the Exercise and whether he knows what the role of the " Senior .
l Firefighter" is under the New Hampshire Plan.
V. The Witnesses' Familiarity With the Supervisors Role of Personnel From the Department of Public Health Services.
l Applicants will inquire about the witnesses' ,
understanding of the managerial role of the New Hampshire Department of Public Health Services, their knowledge of who -
the Department's supervisors were during the Exercise and what their precise responsibilities were, and their opportunity, if any, to hear Department supervisors give
, instructions.
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i VI. The Limited Personnel Resources-Recuired to Resoond
( to Ordinary Fire Alarms Durina an Actual Radiological
\, Emeroency. )
The witnesses will be asked'whether,lduring an' actual ~
radiological. emergency,-responding to a single' alarm = fire irt !
Salem would take precedence over assisting evacuees'and1would
. require sending all firefighting personnel:present at-the-
.High School to answer that alarm.
Respectfully submitted, l
(d f* .
aG
' Thomas C{ Dg% nan,,Jr.
George H..Lewald:
Kathryn A. Selleck Jeffrey P. Trout Jay Bradford Smith:
Geoffrey C. Cook-William L. Parker Ropes & Gray O. One International-Place Boston, MA102110-2624 (617) 951-7000 1
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/~ N j I ) NFC STAFF CnOSS EXAMINATION PLAH FOR CAPTAIN DANIEL BRETON AND JOHN VAN G" , DER, V FIREFIGHTERS FOR THE TOWN Or SALEM, NEW HAMPSHIRE
- 1. Determine the witness' experience, training and general qualification to judge the adequacy of a radiological emergency response exercise.
- 2. Determine the extent of Capt&'n Breton's observation of the exercise.
-If he was only present "at the beginning to set things up" (p. 5) and "left
. bef ore the equipment was in place," (p. 6) his basis for opining on the adequacy of the exercise (p.5, A16) is limited to the initiation of the set up and ^ut its completion. His opinion on efficiency is similarly limited.
-Eis obt.rvations of confusion would be limited to. unloading materials from the truck. See p. 6, A17, A 18,'A 21, A 23 and A 27. A 18 "A lot of time I spent there dealt with just emptying the truck."
l l 3. Determine what is meant by "Our scope is extremely limited." (p. 5, A 16)
- 4. Determine what Breten meant and Van Gelder agreed with- "we just don't .have the manpower to pull it off the way it should be pulled off." (p. 5, A 16)
Is this cenclusien limited to the unloading of the truck since that is all that Breton claims to have witnessed? i.e. kits in the front of the truck and others in the back. (p.6) l
- 5. Determine from Van Gelder how long it took to set up, the reason for the line r of evacuees outside a doorway and his understanding of why the buses were
( ')/
turned around and sent back. (p.8, A 28) Was the line due to processing delays due the shortage cf personnel or because the center was not set up?
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- 6. Determine from van Gelder how many mutual aid personnel were available to aid !
the remaining three firefighters afler the report of the Henry Street fire.
Is this shortage of firefighting personnel at the reception center the basis of his opinicns concerning the effectiveness of the exercise on p. 7, A22 7 i
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- 7. Determine from Van Gelder the s. significance of "a call for the south end of town." Would the mutual aid personnel still remain at the high school?
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I CERTIFICATE This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter of:
Name: Public Service Company of New Hampshire, et al. .
(Seabrook Station, Units 1 and 2) l Docket No: 50-443-OL 50-444-OL ;
(Off-site Emergency Planning) i I
Place: Boston, Massachusetts l l
Date: June 14, 1989 i
were held as hereia appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission taken stenographically by.me and, thereafter reduced to typewriting by me or under the i direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing proceedings. 1
/S/ l (Signature typed) : Donna L. Cook Official Reporter Heritage Reporting Corporation HERITAGE REPORTING CORPORATION (202)628-4888
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