ML20245A466
| ML20245A466 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/16/1989 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#389-8814 ASLBP, OL, NUDOCS 8906220032 | |
| Download: ML20245A466 (132) | |
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/ ATOMIC SAFETY AND LICENSING BOARD 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 Pages: 26033 through 26136 Place: Boston, Massachusetts
( . l Date: June 16, 1989 1 5
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#/ HERITAGE REPORTING CORPORATION omew s.p.mrr lO.
l 1220 L Street, N.W., Suke 600 Washington, D.C. 20005 8906-2 20032 890616 g;g2) 628-4888 PDR ADOCK0500tgj3
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; ," -26033 y , ' UNITED.' STATES NUCLEAR REGULATORY COMMISSION
. l ATOMIC SAFETY.AND LICENSING BOARD In the Matter of:. )
..,,. -) . Docket Nos.
PUBLICESERVICE COMPANY OF ) 50-443-OL f -NEW HAMPSHIRE, et al., 50-444-OL l-
.) ,
) OFF-SITE EMERGENCY
.f.
(SEABROOK STATION, UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING Friday, June 16, 1989 Auditorium Thomas P. .O'Neill, Jr.
-Federal Building 10 Causeway Street Boston, Massachusetts
- The above-entitled matter came on for hearing, pursuant.to notice, at 8:38.a.m.
BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN Atomic Safety and Licensing Board U.S.. Nuclear Regulatory Commission Washington,' D.C. 20555 JUDGE KENNETH A. McCOLLOM, Member Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
' Washington, D.C. 20555 JUDGE RICHARD F. COLE, MEMBER Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Beritage Reporting Corporation
(- -
' - (202) 628-4888 1
l 26034 APPEARANCES: For the Applicant: THOMAS G. DIGNAN, JR., ESQ. GEORGE H. LEWALD, ESQ. KATHRYN A. SELLECK, ESQ. JAY BRADFORD SMITH, ESQ. - I 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 Emercency Manaaement Acency:
. 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
{ Heritage Reporting Corporation (202) 628-4868
26035 ) APPEARANCES: (Continued) / For the State of New Hamoshire: GEOFFREY M. HUNTINGTON, ASST. ATTY. GEN. State of New Hampshire 25 Capitol Street j Concord, New Hampshire 03301 For the Seacoast Anti-Pollution Leaaue: a 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 AIGRE, ESQ. Kopelman and Paige, P.C. 9 . 77 Franklin Street Boston, Massachusetts
. WILLIAM LORD 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 Newburvporti BARBARA J. SAINT ANDRE, ESQ. JANE O'MALLEY, ESQ. Kopelman and Paige., P.C. 77 Franklin Street Boston, Massachusetts 02110 0 Heritage Reporting Corporation
'9 (202) 628-4888
I 26036 APPEARANCES: (Continued) For the Town of Newburv: R. SCOTT HILL-WHILTON, ESQ. Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street Newburyport, Massachusetts 01950 1 For the Town of Salisburv: CHARLES P. GRAIIAM, ESQ. Murphy and Graham 33 Low Street Newburyport, Massachusetts 01950 For the Town of West Newbury: JUDITH H. MIZNER, ESQ. Second Floor 79 State Street Newburyport, Massachusetts 01950 For the Atomic Safety and Licensino Board:
. ROBERT R. EIERCE, ESQUIRE Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission
_ Washington, D.C. 20555 d I Heritage Reporting Corporation (202) 628-4888 i i
26037
.; g I.E E E X-
- (\ j) WITNESSES: DIRECT CROSS REDIRECT RECROSS EXAM Witness.
-Stanley I Cohn
. (Prefiled) 26042 7 by Ms. Greer 26041-by Mr. Smith 26043 by Ms. Chan 26105 -
by. Judge Cole 26115 EKHIBITS: IDENT. REC. REJ. DESCRIPTION: Acolicants' 86 26055- 26127 Cover page and pages 20 through 23 " Application of computer-aided , dispatch in law (- i . enforcement, and introductory planning guide," 12-19-75
. 87 26069 26127 CFR Section 90.313:
frequency loading criteria 88 26071- 26127 Channel loading standards, cover page and pages 103 and 104. Heritage Reporting Corporation
, (, (202) 628-4888
26038 1HEEX INSERTS: PAGE: Testimony of 26042 Stanley I. Cohn on behalf of Massachusetts Attorney General, regarding - 1 communication deficiencies Applicants' cross-examination 26136 - plan for testimony of Stanley I. Cohn NRC Staff cross-examination 26136 plan for Stanley I. Cohn Massachusetts Attorney General's 26136 cross-examination plan for Applicants' Rebuttal Testimony No. 17 s Heritage Reporting Corporation (202) 628-4888
- - _ - - -- __ _ _ _ . ._ _ _ _ _ _ _ _ _ _ _ _ _ _ = _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ - _ _ . _ _ _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ , t 26039
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1 E E 2 C E E Q I E E E' k)\ 2 Whereupon, 3 STANLEY I. CCHN 4 having been first duly sworn, was called as a witness herein j 5 and was examined and testified as follows: 6 JUDGE SMITH: Is there preliminary business before 7 we proceed with Mr. Cohn's testimony? 8 MS. GREER: There is one preliminary matter I 9 would like to bring to the Board's attention as well as the 10 attention of the Applicants and the NRC. When Mr. Cohn was 11 going over his testimony last night, he noticed one clerical 12 transcription error on page 10. In a parenthesis there at 13 line 15, it had previous 1; under the copy that we had
/ 14 circulated earlier this week said, "25 percent".
(* ~ 15 He noted that the graph actually read "20 16 percent", and in fact it was changed over. Kelly Doherty, 17 our paralegal, is bringing down an errata sheet this morning 18 that she will then distribute for clarification on it. 19 JUDGE SMITH: There is no other preliminary 20 business? 21 MR. SMITH: No, Your Honor.
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22 MS. GREER: The only other preliminary thing I 23 would like to just raise to the Board's attention is that 24 our office will be making a motion. I can either do it now 25 in an informal way, or if the Board would like it and the Heritage Reporting Corporation
' \_,/ (202) 628-4888 i
i 26040 1 1 Applicants would like it to be in writing, we will 2 ultimately put it in writing, if that's the Board's 3 pleasure; to have the Board go on essentially a site visit 4 to the Massachusetts EPZ. 5 And the reason that we are going to be making that -
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6 motion is because, although I realize that you, Judge Smith, 7 have been up to the New Hampshire EPZ, Judge Cole and Judge 8 McCollom may not be as familiar with the Massachusetts EPZ. 9 And in order to get some kind of perspective on the area 10 that we have been talking abo 2t now for so long in these 11 hearings, we think it would be useful to the Board to be 12 able to have that kind of visit. 13 And, therefore, we would be happy to talk to the 14 Applicants about the best way this can be arranged. But we 15 do think it would be useful for the Board in rendering a 16 decision on the hearings. 17 JUDGE SMITH: The Board does plan to independently 18 take a site visit, but not with the parties. 19 N3. GREER: Okay. You have already in fact 20 planned to go out and look at the area? . 21 JUDGE SMITH: Yes, we were. 22 JUDGE COLE: We had planned to do that, Judge 23 McCollom and I. 24 JUDCE SMITH: We're waiting for an empty day and
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25 it never seems to come up. But we do have plans to do that. j Brritage e Reporting Corporation l (202) 628-4888 i _ _ _ _ _
-COHN - DIRECT 26041 7s, 1 And we'will report when that has been done.
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'N ,/ 2 MS. GREER: Okay, fine.
ir 3 JUDGE SMITH: Any other preliminary business? 4 MR. SMITH: . No , Your Honor.
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5 JUDG5' SMITH: All right. 6 Ms. Greer.
.7 JUDGE COLE: Before you start, Ms. Greer, the 8 correction you indicated on page 10, the change from 25 9 percent to 20 percent, you also indicated that your 10 assistance was bringing a correction sheet?
11 MS. GREER:- Yes. 12 JUDGE COLE: But page 10 on my version is already 13' corrected. f'" 14- MS. GREER: Yes. This is simply to point out the t . 15 difference between the original filing that we' circulated 16 earlier.and this actual copy here today. 17 JUDGE COLE: Fine. 18 JUDGE SMITH: If that's the only change, I don't 19 know why you need an errata sheet. 20 MS. GREER: Okay. 21 DIRECT EXAMINATION 22 BY MS. GREER: ! 23 Q Mr. Cohn, can you please state your name, business 24 address and position at that business for the record? 25 A (Cohn) I'm Stanley Cohn.
'N O Heritege Reportir.g Corporation (202) 628-4888 l
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r [. I f l l COHN - DIRECT 26042 l f' 1 I work for SFA, Incorporated, which was formerly 2 Sachs/ Freeman Associates, Incorporated. I am the senior 3 vice president for telecommunications and information 4 systens. 5 Our aduress is 1401 McCormick Drive, Landover, . 6 Maryland 20785. 7 0 And, Mr. Cohn, do you have before you a copy of 8 your testimony as it has been prefiled in this matter? 9 A (Cohn) I do. 10 0 And is that your testimony as it is to be 11 presented here today, and do you stand by that testimony? 12 A (Cohn) I do. 13 MD. GREER: At this time we vould offer the 44 testimony in'the record,
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15 JUDGE SMITH: Objections. 16 . MR. SMITH: No objection, Your Honor. 17 JUDGE SMITH: The testimony is received. 18 (The Testimony of Stanley I. 19 Cohn on behalf of 20 Massachusetts Attorney General 21 Regarding Communication 22 Deficiencies follows:) 23 24
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l Heritage Reporting Corporation (202) 628-4888 1 i l l I
nev' , UNITED STATES OF AMERICA NUCLEAR' REGULATORY COMMISSION l i:: ATOMIC SAFETY AND LICENSING BOARC
.. 'Before the Administrative Judges:
c:r
'Ivan W. Smith,' Chairman
? Dr. Richard F. Cole Kenneth A. McCollom
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC. SERVICE COMPANY ) (Off-Site EP)'
OF NEW HAMPSHIRE, EI E. )
)
(Seabrook Station, Units 1 and 2) ) June 9, 1989
)
U TESTIMONY-OF STANLEY-I. COHN ON-BEHALF OF
? .g JAMES M.~SHANNON, ATTORNEY GENERAL FOR THE COMMONWEALTH OF MASSACHUSETTS REGARDING COMMUNICATION DEFICIENCIES Department of the Attorney General Nuclear Safety Unit Public Protection Bureau One Ashburton Place -
Boston, Massachusetts 02108 (617) 727-2200 - L T e
UNITED STATES OF AMERICA NUCLEAR RECULATORy COMMISSION ATOMIC SAFETY AND LICENSING BOARD
~
Before the Administrative Judges: Ivan W. Smith, Chairman Dr. Richard F. Cole Kenneth A. McCollom
)
In the Matter of ) Docket Nos. 50-443-OL
) 50-444-OL PUBLIC SERVICE COMPANY ) (Off-Site EP)-
OF NEW HAMPSHIRE, ET AL. )
)
(Seabrook Station, Units :L and 2) ) June 9, 1989
)
TESTIMONY OF STANLEY I. COHN ON BEHALF OF - ( ~ JAMES M. ~SHANNON, ATTORNEY GENERAL FOR ! THE. COMMONWEALTH OF MASSACHUSETTS REGARDING COMMUNICATION DEFICIENCIES I. INTRODUCTION i This testimony addresses issues pertaining to the adequacy and effectiveness of SPMC planning concerning the provision of . an effective horizontal, or lateral, network of communications directly linking emergency field personnel with each other and to the delay, miscommunication and gaps in that communications network that exists in the system and may negatively impact the ability to provide for the health and safety of the general
.1 public in the event of a radiological emergency at Seabrook l'
l I _ _ . _ . _ - _ . . _ _ . _ _ _._.._...__m____ _ _ ___-__________- _ - _ _
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. )/~' Station. Specifically, the testimony addresses issues raised in Joint Intervenor Contention 31. The testimony also addresses issues raised in Contention Mag. Ex, 8b in that it discusses-a deficiency that was shown to exist in the communication network linking field personnel with the EOC, ORO
. facilities and each other during the FEMA Graded Exercise.
The regulatory requirements that govern the planning and exercise portions of the testimony are found in 10 C.F.R. 50.47(b)(6) and (b)(8) and corresponding requirements of NUREG 0654, Supp. 1 at II.F.1.b and c and II.H.10. The testimony contained herein focuses on deficiencies in ; the SPMC's provisions for communicating information between field workers; deficiencies in the SPMC's provisions for rapid i/~'N response by the New Hampshire Yankee Offsite Response
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Organization ("NHY ORO") to information received and transmitted by field workers; deficiencies in the Emergency Radio Network's ("ERN"). capability for transmitting information to field route guides; and deficiencies in the Emergency Radio Network's capability for transmitting information in a undelayed manner. ..
. II. SYSTEM CONFIGURATION The two largest classes of NHY ORO field workers who are served by the ERN are route guides and traffic guides. The ERN also provides a communication link between four facilities used by the NNY ORO: the EOC, the Staging Area, and the two .
Reception centers. The ERN is comprised of four paired channels O
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f 1 that operate,through.the use of four repeaters. .For-relatively-Os. i ' short range communications,, typically under a mile, NNY ORO ~ field workers such as traffic guides can talk directly to each-other via~.their portable hand-held radios. However, for the
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vast. majority of communications between field workers'the four
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-repeaters.must be used. This results in a radio capability such.that only four simultaneous conversations'can occur;at'any. 1 given time via the ERN.
ORO assigns,the four channels to four specific user functions. One channel is designed to handle communications between the four facilities previously mentioned: the EOC,.the Staging Area, and the two Reception centers. That channel is designed.to be us,ed primarily as a back-up communications link between the facilities.if..the primary communication linkage
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.(telephone)- is for sor36 reason unavailable. The second channel
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is assigned to'be.used by traffic guides. The third channel is assigned to the use of route. guides. Route guides are given portable mobile radios to take with them on their assigned buses so that they can maintain contact with the rest of NHY - ORO. The fourth channel is designated as an overflow channel. In theory it is to be used in the event that radio traffic on
. 4 one or more of the other channels becomes dysfunctional for 1 some reason. The 800 MHz ERN has a designed communication goal I of providing 95% reliability for communication within the EpZ.
O .,.
- - , - - - - - - - _ a , - - - - _ _ - - - -------._u---_- . - - - - - - - . -
ps: , p 1 7 .-A design" goal of-95% reliability is:' consistent with the design goals of public safety radio communication' networks..
,. III. ' RADIO COVERAGE
-In. evaluating any radio system, the first. consideration is
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the required range that the' system is designed to serve.. The NNY ORO operations have two primary coverage considerations. The'first is the ten mile emergency planning zone. Within'a 10 mile radius of'the Seabrook facility, portable radio coverage is-required. This is necessary to support the field operations-under the SPMC. During the Graded Exercise FEMA noted-that some of the route guides who were alerting _the' hearing impaired within-the EPZ expressed difficulty in radio communications with the. Staging Area.- Apparently, in some cases reception was' sporadic. NNY ORO has been' unable to ascertain why such reception was' sporadic, and hence, nothing appears to have been done to correct it. In connection with the SPMC, there is a secondary factor.
.This is radio coverage beyond the 10 mile EPZ. .The ERN system *!
was not designed to any specific goal of reliability outside of the EPZ. There are operations under the SPMC involving NHY ORO field workers that occur outside the EPZ. As part of the emergency plan, buses are to be used to evacuate transit dependent persons from the EPZ. The buses that are to be used ,: in the SPMC for that purpose are dispat.ched from bus yards from l '
3. (} throughout eastern Massachusetts. The buses begin their
\'") movement to the EpZ from towns outside the EpZ. These towns include Medford, Concord, Groton, Avon, Ashland, Shrewsbury, and Milbury. Because of the ERN's limited range, buses coming from those towns as points of origin may not be able to communicate with NNY ORO with any degree of predictability or reliability until they were within a radius of roughly 15 to 20 i
miles from (TOWN). (Because of concerns expressed by the Applicants, the Massachusetts Attorney General has agreed not to disclose the actual name of the [ TOWN]. However, for the purposes of clarifying this testimony the identity of the town will be made known to the licensing board in a manner that will take into consideration the Applicants' concerns.) j[g) s During the Exercise, FEMA found that as a consequence of this apparent lack of radio range or coverage by the ERN some route guides were out of contact with NHR ORO for up to two hours. Because the ERN was not designed to any degree of reliability for coverage beyond the EPZ, the existing ERN system may not provide communication reliably to buses on their , way to the EPZ nor to buses as they transport transit dependent persons such as school children to host facilities that are located, in many instances, some distance from the EpZ. For example, the SpMC apparently contemplates using Holy Cross College in Worcester as a host facility for all school children. Communications with buses going to that location
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ik, will be at best. unreliable for.a considerable period of time. , The problem posed by this lack of coverage is that when tne 4 g route guides are cut of communication with NHY ORO they
*L potentially will be unable to receive pieces of information.
During the Exercise several' route guides'did not receive the instruction to ingest KI. They may similarly be unable to receive other pieces of vital information or to transmit to NHY ORO information that may.be useful. For. example, during the Graded Exercise after a general emergency was declared,_the school buses that normally serve the Amesbury Public Schools were enroute to, if not actually at,.the schools to which they normally provide. transit. At 3:17, the'Amesbury School liaison called and told the schools
\ in Ahesbury that NNY dRO would be using its own buses for
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transit'and to release the buses that were already available at the school. That release direction was in part premised on j an estimated; time of arrival for the NHY buses of 3:55 p.m. In fact the buses'did not start to arrive at the schools until 4:34 p.m., some 40 minutes after the stated E.T.A. and over two hours.after the general emergency was declared. During the Exercise,.the last NHY ORO school bus did not arrive at its designated locale until 6:25 which was some four hours after the general emergency was declared. If NHY ORO had the capability of being consistently able to communicate with its
- route guides and had used it during the. Exercise, ORO would '
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' have had a more accurate picture to estimate the time of arrival of the buses in Amesbury.
N g There appears to be a similar range problem with respect to / N - coverag'E or the Emergency Medical System Service as ex t's or
. s -
ERN coverage. Ambulances used by NHY ORO are sup ed to communicate on this system. The EMS radig-apparently lacks the N., <' range to allow reliable commEhiqat even as far as. Boston s .. where some of the host hosp 1s for%the Massachusetts EpZ are
/ ., \
located. The same kin of problems that rigt for the ERN are also presente connection with the EMS syst 'trsause again many he ambulance companies that are under contract w j- ORO are located some distance from the EPZ. IV. COMMUNICATION,NS TRAFFIC m ( Another concern noted by FEMA that relates to the ERN system is voice traffic overload on the route guide channel. Normally, to determine the capacity of a communication system, the requisite message traffic to be handled by the system is analyzed. Every communication system has a finite average period of time which a user must wait to access the system. As - a system becomes more crowded, this wait gets longer. In designing any communication system and in particular designing a public safety communication system, the maximum allowable waiting period should be determined, and then the type of traffic can be analyzed to determine if this period is exceeded. , l V( ________________-__-__ _ _ - -
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'g/'~'s If excessive access time is found as a result of the analysis, t /
additional channels should be acquired to relieve the congestion. Apparently no traffic analysis was done in designing the ERN system.- Instead, the four channels that comprise the ERN system were selected to correspond to the four user assignments.rather than as a result of analyzing the capacity of the channels to handle a predicted volume of traffic. An acceptable system access time for.public safety communication systems is considered by the U.S. Department of Justice to be 2.5 seconds, in 90% of access attempts. A typical public safety communication system achieves this with a loading capacity of approximately 50 users per channel. Because all route guides are assigned to one [ ' channel, and under th_e SPMC nearly 170 route guides may be separately mobilized and assigned radios, that results in apprbrimately three times as many users on the route guide channel than is normally acceptable in a public safety communication system. During the exercise, FEMA noted that an approximately ten .
.. minute delay occurred in transmitting information requesting dispatch of la wrecker from the transfer point because of heavy bus dispatch traffic on the route guide channel. FEMA also noticed that route guides for the hearing impaired expressed difficulty in radio communications because in some instances the assigned channel was overloaded. While FEMA recommended further
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l /' training to impreve radio protocol used by ORO field workers, it l N
'N] is not at all clear that merely improving training will correct i ,
- l l the communications traffic overload on the route guide channel because the overload of users on that chann. *- in excess of three times normally acceptable levels.
. As a method to determine if congestion can be cured on the route guide channel, a traffic study follows which is based on normally acceptable public safety radio channel use. The assumptions made are:
1 the average message length per transmission equals 15 seconds;
- 2) one message per user on the route guide channel per hour during an evacuation after the declaration of a general emergency.
7_ The basis for system response time evaluation is x,) equations taken from queding line theory. For the single , chanrm1 case,. and a single class of call, the average waiting time can be escimated using the following formula: 1 W=u -a9 yu ,,
. Where: ,
a= average message arrival rate = 170/3600 u=. average message servicing rate = 1/15
. Solving for this equation, we find an everage waiting time in excess of 30 seconds to access the channel. This is significantly greater than the 2.5 second recommendation from the U.S. Department of Justice. .
7
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4 In order to determine the appropriate number of channels that a radio system should have in order to handle to the up to 170 route guides, the following equation is used: Channel Work Load - (PCR) x (CD)
'3600 Where: PCR = Peak Calls per Hour = 170 CD = Average Call Duration = 15 Solving for this equation shows a channel workload equal to 0.708. If 90% of access attempts are successful, this corresponds to 10% maximum blocking rate (unsuccessful attempts). Referring to Figure 2, this traffic load requires over three channels to support the desired system availability. If three channels were assigned to route guide usage under this. formula, and the 170 potential users in the group divided among these channels, the blocking rate would exceed 10% (approximately 20% according to Figure 2). These calculations have been made with the assumption of a relatively short average message length of approximately 15 seconds and one message per user during peak activity. Should a study show that the average communication per route guide is in excess of 15 seconds, that would increase both the waiting time and the number of channels required.
The obvious problem with having this kind of delay built into the ERN communication system is that information cannot be communicated or received in normally acceptable time tolerances , for public safety communication networks. It means that because k --..________-__________.___um _ _ _ _ _ _ _ _-_ _____m--_______m-_-__.___ _______a__________.______m.
,f D of the ERN's system design delays in communications may well V occur. Safety related information may not be communicated in a timely manner. Having all route guides assigned onto one channel results in having an already limited radio system, where ,
only four persons can talk at once, reduced down to an even more , truncated system. V. PROCEDURES While NHY ORO has proposed certain procedures that are meant to alleviate some of the channel congestion, it is not clear that those procedures will be adequate to deal with the channel loading problem for route guides. For example, ERN users are supposed to be trained to assign one of three levels of priority to each transmis,sion: Emergency; priority; and Routine. The , J assignment of level of priority is at the users discretion. However, if a route guide is transmitting, the channel is tied up until he is through, and no emergency message can be sent by any other user on that channel even though it has a higher priority status. Therefore, even if a route guide has an emergency level transmission, he will not be able to gain - access to the channel until another route guide is through transmitting. While ERN users are given certain guidelines as to what constitutes a routine as opposed to an emergency message, ultimately, the decision as to the priority level of a message is in their hands. l t
,[' Another procedure that NHY ORO is planning to implement in connection with the ERN system is designed to circumvent the deficiency resulting from the lack of radio coverage range.
Under th'is proposed procedure, radio dispatchers will go through a roll call of all ERN channel users when a piece of information application to all users on a channel is transmitted to them. For example, with respect to instructions to ingest KI, the proposed procedure would call for the dispatcher to go through a rollcall of all route guides to make sure that they had the received the message. The rollcall procedures would theoretically enable NHY ORO to ascertain whether all route guides received the KI instruction or whether some did not because they were out of range. The problem with this procedure being implemented to circumvent the range coverage deficiency in the ERN is that it exacerbates the channel overload that exists on the route guide channel. The ro11 call procedure puts an additional overload burden on the ERN because it calls for the dispatcher to put out an additional 150 + messages. The dispatcher must then wait for . and confirm' receipt back an additional 150 + messages. Even if each communication takes only 10 seconds, that results in the route guide channel being in use for approximately 50 minutes simply to make sure that every route guide received the original communication. If for some reason a route guide is out of range and does not receive the original transmission as .- ___ ___m-- ______m-_..__ _ _ _ _ _ _ _ ._.m__m__._.____._._._.- - _ _ _ _ - _ _ _ . _ _ _ _ _ _ _ _ . _ _ _ _
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( ,, confirmed by the rollcall procedure, the transmission and rollcall are to be repeated until all route guides acknowledge that they have received the original transmission. In sum, the proposed procedure to circumvent the range coverage limitations of the ERN will serve to burden an already strained system potentially causing further channel overload problems in the ERN. v - W e (
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ATTACHME.NT 1 1 t . CXNf, STRIKar I. security H r +: 7CP SECRET - DISCO ahnention: 3sEE, Illinois Institute of Technology, Chicago, IL,1950 < MSEE, Illinois Institute of Technology, Chicago, IL,1952 Askiitional 1952-1956Phc Graduate work (32 hours) at IIT, Chicago, IL, Affiliations: Institute of Electrical and Electronic Engineers, senior Member Aaaociated Sigma Xi Public-Safety Communications Officers Eta Esppa Nu Tau seta Pi Armed Forces Consuunications Electronics Association Chairman, IEEE Electromagnetic Compatibility Comodttee (27) 1961-1963 Member, IEEE Electromagnetic Compatibility Comedttee (27) 1959-Present Member, various National Electronics Conference Committees and on the soord of Directors, 1952-1962 Chairest, Fourth, Fifth and sixth Annual Tri-service Radio Interferenceofmoduction Department Defense Conferences spannored by the IEEE Representative to A45! Canadttee C63, Radio Electronic coordination Member, IRE Standards comodttse, 1960-1962 Chairman, Fourth Annual Joint Military Industrial Electronic J tw hni iso on Electronnipietic Compatibi$ity (63.1) and Chairman ofCom Geo g on AnE ysis Techniques (63.1.3) Liaison Member of J!nc subcommittee 71.1 on Radio Noise Chairman, second and third National symposta on Law enforcement seience and Technology Esperiamos summary:
. Over thirty-six (36) perfoamanos of sultid:..sciplinevers of experience in the management and policy formulation, econcedes, programs involving management social science, statistics, systems, telesemmunications engineering, engineering analysis, mathematical
, data bene design and management, and computer simulations set. ion in the fields of program management, telecommunication and apostmas management, electromagnetic compatibility analysis, fiber optics applioetions teleocumunications and information systems, radio wave propagation, radio interference, radar, and electronics research and development. Major responsibility :or establishing mana p t and
- operating electromagnetic compatibility analysis capabilnt bases for DoD and rederal Spectrum Management Authorities.y and data>.
5
Professional Emperience!
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1982 - Present Sachs/ Freeman Associates, 'Inc., tandover, MD Sernor Vice President, Telecommmications and Information sciences. Overall annagement responsibility for three departments concerned with systems engineering, congmter system and public safety systems as well as for maltidiscipline programs involving analytical and evaluation studies concerned with long-range planning, ennagement systems, telecommunication management, spectrum management, mc systems engineering, data base design and management, ADP management, management information systems, and office automation. Provides technical guidance to the Navy on national and international mana Responsible for the meervision of cell , paying,gement.and notdie radio desipi and licensing projects. Nas participated and provided technical guidanos for evaluation of narrouband technologies for lane mobile use, lonr range spectrua planning for the roc and wr!A, and in many te;.eoammunications y. state and local government and commercial c @lients.s for federal,
~
1978 - 1982 National Teleccagunications and Information Administration e wran) Us r+-f- r; or commerce nela several emve positions at wf!A. Am Deputy Administrator for operations, was roepensible for the overall day-to-day operation of the agency and was first line supervisor of all line and staff office heads. Had direct responsibility for pl W a , resource allocation and management, budget justification, fiscal management, personnel management, ensuring work quantity and quality and advising the Assistant secretary (Administrator wrzA) on icy and mens p matters. Mas responsihte for evalua peer and , po anscutive direction for all 13 Nf!A propans ty as interdisciplinary staff of over 420 engineers, ical solentists, computer analysts, attorneys, economists social scientists. the programs concerned chimp eies for telecommmications and information (Tt!) iss, mao for imprwins Tu systems, managng teleoamunication ressurn, mi pvviding pubLac teimaa==saiestions faci ilM, As Associate Administrator was responsible for managing wtrA's protrams and staff of the office of Teleocumunications Applications concerned with more effective use of a teleommamiestions and information technologies. This involved identifying user noede, evaluating new applications, sucts as satellites and fiber optics, deve methods to serve the needs, working with various Federal agencies to implement more efficient and effective systmas, ( removing regulatory barriers impeding introduction of i \
r , Ccest, 95 Wear I. (caff!NUED) Profeemianal Esperience (Contirmand)
- new technologies, condue: ting or coordinating experimental and pilot tests, and managing grant pr rams for Publi: Services satellite use and Public Tel cations Pacilities.
As Deputy Associate Administrator was responsible for the internal management of the office of Federal Systems and spoetrum Management which has the responsibility for managing the Federal use of the radio spectrum, chairing the Inter-department medio Advisory cosenittee, developing long-range plans in conjutetion with the rcc for overall national spectrum management, developing rederal positions and coordinating national positions for international spectrum matters, planning rederal telecosamications syetams and telecommunications protection. Projects involved studies, evaluations and po11cv formulations concerning procurement, management and operataan of federal systems; spectnse allocation and assignment in the federal, national and international sectors; and telecommunications protection. Was directly responsthis to the Assistant secretary of Commerce
, for comenstications for direction and overseeing the program managers for three programs, and coordination of the
, Management of Telecommunications asseuroos audget Activity, and the spectnan Management _ and Planning pudget submetivity.
,1971 - 1978 office of Telecesamications (OT), US Department of Commerce As cnter, spectr e =; 2 support Divtston, was responsible for the managenera of the activities of the division and served as the Entity Program Manager (spectrum Management support). In the latter ongesity, directed the-program in the office of telecomunanications concerned with the
= of the radio spectr a. This present and futurethe progran supported --- office of Telecommunications Policy, ,,
Executive office of the President. neepensibilities included
, the following program elements: spectra t and Information tienent which provided the frequency managannat support, congester support and software developments , spectrum Analysis tiement which analysed the use of the spectrum resource from an electromagnetic compatibility standpoint and reviewed new radio systems for provision of spectnas my43 and, the spectnam insering Development tiement whic1 developed analysis quos ans provided measurement support.
While performing regular duties, Mr. cohn also served as Acting Chief, Analytical support Division for 15 months and as l acting Deputy Director, Office of hiecomummications for seven months. As Acting Chief Analytical support Division, was responsibis for the management of the Analytical support Division which l
}
O CGar, suusar I.' (CGrf!NOW) Professicasi asperience (continued
\
provided policy analysis support to the office of Teleccmamications policy, Executive office of the President.
* '1his division perforand analysis of various issues in the federal government and international policy areas.
Recommended policies and policy options concerning procurement and management of federal systems and international issues. Evaluated federal research and development including the .. initiation, improvement, expansion, testing, operation and the I use of the tec5 cal telecommunications systems and programs. As Acting C-i,4.i Director, aided the Director /Or in the management of the office and assumed the Director's duties in his absence. The office had three major program areas.' These wre: Improvement of Telecommunice,tions (Oirect and other Agency funded), spectrus Maaafammar support to the cry and Policy Analysis support to the OFF. In addition to aiding in directing these technical activities, this assigunertt also involved supervising the administrative and pub,1c inforantion
. functions of the office.
1951 - 1971 IIT-Research Institute (Perustly Assour Research roundation) cnicago, IL ana Annapolis, m Held various management and technical positions. As Director
. of Research, directed the systems science Research Division (East coast operations). Activities included supervision of a staff of over 300 persons engaged in electronics, electromagnetic compatibility analysis, engineering mechanics, law enforcement science a technology, operations research, physics and social sciences research and development.
As Associate Director of Asenerch, Electronics Division was responsible for the Technical operations of the Electrasagnetic compatibility Analysis center (scac), ' Annspolis, 2 with a staff of 260 persons providing contract services to the DS in the BIC/11edia Frequency Interference
- field. Functioned as scpc's Director of 1*chnical operations,.
As Assistant Director of assearch, Electronics Division, OLicago, IL was responsible for the operation of six sections concerned with communications, radar, radio frequency interference, microisves, instrumentatient recording and I computer systems. , As supervisor, casummications a nadar faction, Electronics Division supervised a staff of engineers conducting research projects on various communications and radar projects. - As member of technical staff, Electronics Division, communicat*wis a Radar section. conducted research and develope activities in projects involving various electrouc systems'. Project Engineer on a variety of proju:ts.
COIEt, STINJrY I. (CCNTINUED) Putdications: CMNIDIRECTICtEL CCAXIAL SIOf AN2124E ARRAY, IRE National Convention Rec 1953, also the National Electronics C_onference, 19$4. DESIG4 & DEVP.IOPMENT OF A SthlCARD NNITE NOISE GENERA INSTRUMENT, ,*o-authored with H. Zucker, Y. Baskin of IITRI, and A. Rosenbloan and 1958. I. I,orner of USAROL, Ft. Monmout#, NJ, IRE Transaction of Instrumentation,
^
of the 1959 National Aeronautical Electronics Conference, D with Electronics R. Arndt, J. Erstansky and R. Sachs, Proceedings of the Conf., 1959. A MtJLTIPLE PSCSE ME11100 0F M MEASUREMENT OF REFLECTED IN A CQhXIAL MVE3JIDE, Co-authored with C.M. Knop, Proceedings of the 6th Conf. on Radio Interference Reduction and Electronic Ceepatibility, Oct.,
. 1960, also the Proceedings of the National Electronics conf.,1960.
ELECSCMA NETIC COMPATIBILITY, Frontier, Fall, 1961. M TECHNICAL PROGRAM AT M ANALYSIS CENTER, Proceedin9s of the 7th Conference 1961. on Radio Interference Reduction and Electronic Compatibility, Nov., ELECDOMAG4 ETIC CCMPATIS!LITY, The Speaker, IEEE, May 1962. TEORCCAL PROGRESS AT THE ANhLYSIS CENIER, Proceedirrys of the 8th Tri-service - Conf. on Electromagnetic of NAECON, May 1963, compatibility, Oct.,1962, and also the proceedings THE DEPASSENF Lecture QF DEFEMBE ELECDCMAGEETIC CGirATIBILITY ANALYSIS CENTER, series, Aug.1965. AM Nr CRIENIED Marcie 1966. PERronMANCE CCN!RE MODEL, IEEE International Conf., JW APPRohCI TO CC99E3t! CAT! qts COMPATIBILITY ANALYSIS, Digest of 1944 IEEE International Communications Conference, June,1966. EMC - A SYSTEMS SCIDICE, Keynote Address,1967, IEEE Electromagnetic compatibility Symposius, July, 1967.
'ELu.snavGIETIC COMPATIBILITY - A NECESSITY FOR HIGDEAT COPOSICATI Highway Research Record, Jan. 1968.
SPECIRUM ENGINEERING = THE KEY TO PROGRESS, Co-authored with R. Gifford, et
,al, Joint Technical Advisory Casubittee (JDC), March,1968.
_ _ _ _ _ _ _ ------ - ~
C01st, hassar I. (coff!NUED) Publications (Continued)8 LAN WFCItCDENT SCIENCE & TECmotmY II, Jan.,1969, Edited by S.I. Cohn LAW WFORCEMDFF SCIENCE & TECID10t@Y III, Dec.,1970, Edited by S.I. Cohn and W. McMahon. ANALYSIS TECIBf! QUES FOR SPECIIUt MANAGEMBrr, Delivered During EUROCQf,1971 on Oct. 20, 1971. SPECTMSI MANRGBENT SUFFORT PROGRAft - AN OVENIBf, IEEE Bec International Symposium Record, July, 1972. TIIE FEDERAL GOVEltSEbrr'S SPECTIul MANRGDENr FRotMAN - AII OVENINF, - Co-authored with W. Dean, Jr., IEEE Electromagnetic Compatibility Sympoeign Record, July, 1974. M Of SpecTzat MAIIAGEMstt SUNCItr PROGRAN- ell CVERVIst, IEEE DIC Transactions Special Issue on Spectria Management, Aug.,1977. [ 0 TDI YEARS OF PROGIESS IN 911, Keynote Address, BIntional 911 Conference, June, 1981. - COLLECTICH AND DEVEECHElf? 0F INFCIIthTIG8 TO SUNORT ICNtMIADER EWCr3 Rat
- PLA8081NG,. Final Report Contract tifr-81-aAC-00072, Aug.,1982.
EVALUNTION OF IMFIOVED SPEC 5Est (FFILIZAT!tl38 G3CEPTB, Final Ilopert Contract
#ttr-82-RAC-26010, Feb., 1983.
. EVAE2JNTICII 0F TWE UBE OF NBt NhERDISAID Tamawatran IN TEE BEIS','DIO PRIVATE IAPD MOBILE RADIO F5300ENCY ALIAXATIQt, Final Report for Land Molaile Caesunications Council, Aug.,1984. Co-authored with s.A. Freeman. .
,METIrwerrw FOR DEIE35tDf!NG SPECTIUl EFFICIBICY, Final Report cratract 43 SAlfr 503717, Aug., 1985.
- A00455tS OF QFFIQW FtX COC2DDRTIGt OF THE RIGBEW thDffEHhMCI PADIO SERVICE, Finab Begert for American Association of State HlWway and Transportation offielens, June, 1984.
tape MRIIA - TEmelotm!ES, DEC T50B00t4Gr, September-October,1986. Co-authored with Jerry Macker.
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j. 3 COHN - CROSS 26043
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1 =MS. GREER: I have no further questions at thic' 2 time.- 3 JUDGE SMITH: All right. 4 You may cross-examine.
-5' CROSS-EXAMINATION
~
. 6. BY MR. SMITH:
7 Q Good morning, Mr. Cohn. 8 A (Cohn) Good morning. 9 Q My name is. Jay Smith. I am one of the attorneys 10 'for the Applicants.in this proceeding. I'm going to ask you 11 a few questions today regarding your testimony. 12 How long did you spend preparing to file your 13 profiled testimony?
./ \ 14 A (Cohn) The tot &1 time I spent was relatively 15- small. It was a review. I had one of my associates
~16 . preparing the testimony.
17 Q And how long did you spend in your review 18 ' capacity?
.19 A (Cohn) Probably a total of four hours of actual ,
20 review and some guidance prior to that, discussing it with 21 the individual. 22 Q All right. 23 And do you know how long your associates or 24 associates -- 25 A (Cohn) I don't know offhand. 3 Beritage Reporting Corporation (202) 628-48PP
COHN - CROSS 26044 1 I could find out when I get back. 2 O So did your review include reading or reviewing 3 any of the documents on which your testimony is based? 4 A (Cohn) I reviewed some of the documents, yes. 5 Q Have you read the SEMC? 6 A (Cohn) I have read portions of the SPMC. . 7 Q And those would be which portions, sir? 8 A (Cohn) The portions that are pertinent to the 9 testimony. 10 Q Have you read the plan itself, or parts of the 11 plan? 12 A (Cohn) I hr.ve read parts of the plan. I have 13 certain parts of it extracted here by my associate. .. 14 Q And parts of the procedures? 15 A (Cohn) Procedures are also here, the appropriate 16 portions. 17 Q How about the ORO field personnel procedures? Fcr 18 example, route guides, traffic guides? 19 MS. GREER: I'm sorry, Mr. Smith. I'm having a 20 hard time hearing you. , 21 Can you also pull the mic a little closer? 22 MR, SMITH: Full it a little closer. 23 BY MR. SMITH: 24 Q The question was, have you read any of the 25 procedures for the ORO field personnel. i Heritage Reporting Corporation (202) 628-4888 __ m m -._________.--_-__-_-_m_m--_m_____.____m _-
-I COHN - CROSS 26045
,f b
y 1 A (Cohn) I have read the procedures regarding i
' \ -) 2 communications for the field personnel. I 3 Q Do you believe you are generally familiar with the 4 communications sections and any relevant procedures that 5 would relate to that in the SPMC?
6 .A (Cohn) I do. 7 Q Have you read the FEMA graded exercise report of-8 the June 28-29, 1988, graded exercise at Seabrook Stations? 9 A (Oohn) Portions of it. 10 Q. Do you believe you are familiar with those 11 portions of that report? 12 A (Cohn) Yes. 13 Q Have you observed any drills or exercises of the 14 SPMC?
.["
s 15 A (Cohn) No, I haven't. 16 - Q So then you have no direct knowledge of what-17 occurred during those exercises or drills? i 18 A (Cohn) We were retained after the exercises were 19 held.
. 20 Q If you could turn to page 6 of your testimony.
21 A (Cohn) Yes. 22 Q The paragraph beginning, "For example". 23 A (Cohn) Okay. 24 Q About half way down through that paragraph, you 25 state that, "That release direction was in part premised on Heritage Reporting Corporation (202) 628-4888 l l l
COHN - CROSS 26046 1 an estimated time arrival for the NHY buses of 3:55 p.m." 2 Is that correct? 3 A (Cohn) That's correct. 4 Q What was the basis of that statement?
~
5 A (Cohn) The basis is a log taken from the Amesbury 6 station. . 7 Just a moment. I think I can find it here. 8 Yes, it was a chronicle events log at that 9 facility, Amesbury school facility. 10 Q And you have not read the transcript of Richard 11 Donovan's testimony in this proceeding? 12 A (Cohn) The transcript of Richard Dunegan? 13 Q Donovan.
. 14 A (Cohn) Donovan.
15 I don't remember the name offhand. Let me just 16 double check. . 17 JUDGE SMITH: You would not find it there. I 18 think he's referring to his testimony here at this hearing. 19 MR. SMITH: Yes. Yes, I am. 20 THE WITNESS: (Cohn) Let's see. I have a number , 21 of items here that I have been supplied, and I have read 22 through them. 23 I believe not. No, it doesn't appear to be here. 24 BY MR. SMITH: 25 Q Then you are not aware, then, when you drafted Heritage Reporting Corporation , (202) 628-4888 i
l I i COHN CROSS 26047 j
,'~} 1 your testimony that the release direction was not premised ' '/ on an estimated time of arrival for the New Hampshire Yankee 2
3 buses, but rather, was an exercise artificiality created by 4 the control cell? 5 MS. GREER: Objection as to form.
. 6 I'm not cles.c that everything contained in that 7 question has in fact been established in the record so far 8 in this proceeding. It appears to be that at least a 9 portion of the premise in the question is in fact a 10 characterization of Mr. Donovan's testimony that in fact 11 remains at issue here.
12 JUDGE SMITH: Well, what portions do you believe 13 are not -- [mi 14 MS. GREER: Well, he said, then you are not aware ' 'Q)
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15 that in reality the release was in fact a -- and he went on 16 from there. I'm not sure that that is in fact established 17 by the record here. 18 JUDGE SMITH: I thought it was. 1 19 MR. SMITH: I have a copy of the relevant . 20 transcript pages if that would help. 21 JUDGE SMITH: Would you read the question back? 22 (Accordingly, the pending question was played 23 back by the court reporter. ) 24 JUDGE SMITH: It's been established. 25 MS. GREER: I'm sorry. The portion that I got f3 () Heritage Reporting Corporation (202) 628-4888 ___________-__-___-_a
i 1 COHN - CROSS 26048 1 hung up on was the release direction was not -- I believe 2 the first part of the question was the release direction was 3 not premised on an. estimated time arrival. 4 And, of course, the release direction, if in fact
~
5 he's referring in the question to the plume release -- 6 JUDGE SMITH: No. . 7 MR. SMITH: No , no. 8 JUDGE SMITH: See, I went along that tangent to. 9 That's a good point. But that's not what he's referring to. 10 MS. GREER: Okay. 11 JUDGE SMITH: Restate your question and make it 12 clear that you are not talking about the plume release. 13 MR. SMITH: No, I'm actually referring to the
- 14 language in your own testimony.
15 MS. GREER: To release the buses. I 16 - MR. SMITH: To release the buses. 17 THE WITNESS: (Cohn) The buses. 18 THE WITNESS: (Cohn) Yes. I have lost track of 19 the question. . 20 JUDGE SMITH: The direction to release the buses. . 21 MR. SMITH: Yes. 22 THE WITNESS: (Cohn) Yes. 23 JUDGE COLE: The order to release the buses. 24 THE WITNESS: (Cohn) Right. 25 The log states at 3:17 route guide considered. Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26049 (~} (' ,/ 1 "At 3:55, we will be using our" -- the writing is not toc-2 clear here. "I must call schools and tell them to release 3 buses." 4 BY MR. SMITH: 5 Q No, my question, sir, was rather whether you were
. 6 aware that, based on the testimony of Eichard Donovan, at 7 the time you wrote your testimony, that the direction to 8 release the buses was not actually based on or premised on 9 the estimated time of arrival of the buses, but rather, was 10 an artificiality in the exercise scenario created by the 11 controller.
12 A (Cohn) No, I was not. 13 Q When were you first contacted by anyone from the
/x
[ 14 Massachusetts Attorney General's office?
} ~ </
15 A (Cohn) Several months ago. I don't remember the 16 exact -- - 17 Q And with whom was that contact? 18 A (Cohn) I believe it was with Ms. Greer there. 19 Q Ms. Greer here? 20 A (Cohn) Yes. 21 Q Did she give you an assignment at that time? 22 A (Cohn) Not at that time. 23 We negotiated a rate, and an agreement. 24 Q When were you given an assignment or a contract, 25 whatever it would be?
/3 I ) iseritage Reporting Corporation
# (202) 628-4888
COHN - CROSS 26050 1 A (Cohn) Probably about a week later, I guess. 2 Q And did Ms. Greer give you the relevant sections 3 that you referred to earlier that you have read? 4 A (Cohn) To my associate, yes. 5 6 , 7 8 9 10 11 12 13
. 14 15 16 - .
17 18 19 . 20 , 21 22 23 l 24 25 1 i l Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26051
- 1 Q When.did you agree to testify?
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2 Was it at that time as well?' 3- A (Cohn) At the agreement, yes. 4 Q What was the nature _of yoor initial assignment? 5 'A- (Cohn) To review the situation, review the
. '6 communication system and come up with an opinion of how the 7 system would function. How the tests were run. What the 8 results were. And come up with testimony reflecting our 9' evaluation of the communication system.
- 10. Q When did jou read the SPMC? Was it before, at 11- the beginning, when the assignment was first given or was it 12 tbefore you reviewed your associate's work?
13 A (Cohn) My associate read it first; I reviewed it ((5 14 atthetimekreviewed'myassociate'swork.
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'15 - Q So as a check'then of your associate's work?
16 -- A (Cohn) Yes. 17 Q Is that the only time you read the SPMC? , 18 A (Cohn) Correct. 19 Q How about the exercise report, when did you read .
- 20 that?
21 A (Cohn) At about the same time. 22 Q And that also was the only time? , 23 A (Cohn) Except for a review yesterday. 24 Q In preparing to come in? 25 A (Cohn) Yes, in preparing to come in. Beritage Reporting Corporation (202) 628-4888
COHN - CROSS 26052 1 Q Did you have any contact with Geary Sikich with 2 respect to your testimony? 3 A (Cohn) I did not. 4 Q Did your associate? ,
~
5 A (Cohn) I am not aware that he did; he may have. 6 I'm not even sure who Geary Sikich is. , j 7 Q Initially in the proceedicags the testimony was ! 8 tied -- it was called the Sikich and Cohn testimony, and Mr. 9 Sikich -- the Massachusetts Attorney General withdrew his 10 testimony, and the Sikich and Cohn testimony then became the 11 Cohn testimony. 12 A (Cohn) Okay. 13 0 You were not aware of that sequence, then, I take
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14 it?
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15 A (Cohn) No. My associate probably was, but I was ' 16 not. 17 Q Do you know whether your testimony at all was 18 based on anything that Mr. Sikich stated? 19 A (Cohn) Not to my knowledge. . 20 Q So it was independent? , 21 A (Cohn) Yes. 22 Q Did you review this testimony prior to it being 23 filed by the Massachusetts Attorney General? 24 A (Cohn) Yes, I did. 25 Q And at that time you did not notice that it was Heritage Reporting Corporation (202) 628-4888
l l COHN - CROSS 26053 l l
/~'N 1 Sikich and Cohn's testimony?
, )
2 MS. GREER: Objection. When you say "this 1 3 testimony," are you referring to this testimony that's 4 presently before us here today or are you talking about the 5 testimony that was filed back in April?
~
. 6 MP.. SMITH: I was actually inquiring about the 7 original, just to make that clear.
8 THE WITNESS: (iCohn) The original testimony? I 9 believe that I was supplied a copy of it. I did not have a 10 chance to fully review it except to skim it. My original 11 testimony was going to be later in the month because I was 12 going to be away during this period. 13 So by the time I reviewed it in-depth it was the [L/ 14 testimony.that was essentially here with some corrections 15 made. 16 - BY MR. SMITH: 17 Q So you did not review it prior to -- 18 A (Cohn) Only to skim it. 19 Q -- the filing. . 20 But you did review it prior to your c- ing in to 21 ' testify? 22 A (Cohn) I'm not sure what version was filed, to 23 tell you the truth. 24 JUDGE SMITH: Mr. Cohn, would you pull the 25 microphone closer.
,r' (j
Heritage Reporting Corporation (202) 628-4888
I COHN - CROSS 26054 L 1 THE WITNESS: (Cohn) Maybe I should sit forward. 2 JUDGE SMITH: Whatever, but it's difficult to 3 hear. 4 THE WITNESS: (Cohn) Okay. 5 BY MR. SMITH: 6 O So then I take it you were not involved in the , 7 process of cutting down the Sikich and Cohn testimony? 8 A (Cohn) No. 9 Q And your associate, I assume, was not as well? 10 A (Cohn) I'm not sure. 11 Q How much time did you spend coming in to prepare 12 to testify today? This would be not your initial review of 13 the actual document, but just to prepare to testify. 14 A (Cohn) About two hours earlier in the week and 15 about a half to three quarters of a day yesterday plus some 16 additional reading last night of some material -- 17 JUDGE COLE: I'm having trouble hearing you, sir. 18 THE WITNESS: (Cohn) Plus some additional reading 19 last night of some material I hadn't had previously. . 20 BY MR. SMITH: , 21 Q And that was the time in which you noticed the 22 error in the 25 percent versus 20 percent? 23 A (Cohn) I noticed it prior to coming here 24 yesterday. 25 Q Okay. Heritage Reporting Corporation (202) 628-4888 l
COEN - CROSS 26055 (~ 1 I would like to turn to page 9 of your testimony,
\ }S 2 sir. On page 9, at the very bottom, I'm reading the last 3 sentence of that page. You testify that: "This is 4 significantly greater than the 2.5 second recommendation 5 from the U.S. Department of Justice." . 6 Is that correct?
7 A (Cohn) That's correct. 8 Q Are you aware of a document entitled, " Application 9 of Computer Aided Dispatch in Law Enforcement," an 10 introductory planning guide prepared by the U.S. Department 11 of Justice? 12 A (Cohn) Yes. 13 Q Dated December 19, 19757 [' ) 14 A (Cohn) Yes. I have it right here, as a matter of V 15 fact. 16 - Q And you do have a copy in front of you? . 17 A (Cohn) Yes. 18 MR. SMITH: At this time I would like to mark for 19 identification this document. It would be Applicants'
. 20 Exhibit No. 86.
21 (The document referred 22 to was marked for 23 identification as 24 Applicants' Exhibit 86.) 25 MR. SMITH: I don't have a full set at this point Reporting Corporation (O) Heritage (202) 628-4888
COHN - CROSS 26056 1 of copies; they should be coming. 2 I do have enough copies for the Board and for Mass 3 AG at this point. 4 MS. GREER: 867 5 MR. SMITH: Yes, 86. 6 (Document proffered to all parties.) . 7 BY MR. SMITH: 8 Q What I would like to do is show you my copy just 9 to make sure we're talking about the same document. 10 A (Cohn) Okay. 11 ' Q This document is the basis of your testimony that 12 the U.S. Department of Justice recommends that the average 13 waiting time to access a channel is 2.5 seconds; is that 14 correct? 15 A (Cohn) That and another document published in 16 March of ' 85 which has the same information and references 17 the first document. 18 Q Right. 19 The 2.5 seconds, Mr. Cohn, isn't really a U.S. 20 Department of Justice recommendation, is it? , 21 A (Cohn) It is a general recommendation that police 22 agencies use. I don't believe it ever came out as an 23 official recommendation. i ( 24 Q Well, what I'm referring to, if you could turn to l
- 25 page 21 of that document, and I'm looking at the right hand Heritage Reporting Corporation (202) 628-4888 l _ . _-_ ___-_-_-_
i L COHN - CROSS 26057 c.. 1 column, the last paragraph on that right hand column. l [ 2 A (Cohn) It is listed as a typical waiting time for 3 a call placed in queue. 4 Q Right. 5 And if you could.just read the sentence or
~ . 6 'actually the phrase following the semicolon?
7 A (Cohn) "No more than five calls out of each 1,000 8 shall receive a busy signal. Two, the e.verage waiting time 9 for a call placed-in the primary operator queue shall not 10 exceed two and a half seconds." 11 ~Q What I'm referring to, sir, is actually the 12 paragraph following that. The one which you quoted before 13 which says: "The numbers entered in the blanks above are 14 typical?" 15 A (Cohn) Yes. 16 Q And then there's a semicolon, if you could just 17 read the rest of that sentence? 18 A (Cohn) "The planner should establish these for 19 his own system on the basis of his measurements at peak load ,
. 20 and his estimates of how frequently a given call rate may be
' 21 exceeded."
22 Q So the number is somewhat flexible according to 23 this document? a 24 A (Cohn) Yes, e 25 O It's not the absolute standard by any stretch? Heritage Reporting Corporation (202) 628-4888
l l-COHN - CROSS 26058 1 A (Cohn) No. 2 The intention was, this is typical of what we have 3 found in law enforcement agencies and in other public safety 4 agencies on the order of two and a half seconds. These are 5 what these are designed for. And we were trying to point 6- out that this was considerably cifferent than that estimated , 7 for thia particular system which was 30 seconds. 8 Q And the U.S. Justice Department does not 9 necessarily subscribe to this 2.5 second standard, is that 10 not correct? 11 A (Cohn) The Justice Department has not published 12 this as an absolute standard, no. 13 Q And this is really the opinion of the authors, not
. 14 of the Justice Department ?
15 A (Cohn) It is the opinion of the aathors as 16 approved by the National Criminal Justice Information and 17 StatisPic Service of the Department of Justice, who 18 commissioned the study by the Jet Propulsion Laboratory. 19 And also, reflected again in the Department of 20 Commerce report in 1985, prepared for the National Institute , 21 of Justice of the Department of Justice. 22 Q I guess my question is: the U.S. Department of 23 Justice does not necessarily adopt that as the standard; is 24 that not correct? 25 A (Cohn) That's what I said in the beginning. .It Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26059 1 is not a standard. 9 2 O In other words, they do not adopt the number even It's not necessarily 3 with this flexibility, necessarily? i 4 their recommendation; it's just the recommendation of the 5 author?
~
6 This hasn't been official sanctioned by the U.S. 7 Department of Justice; this is just a report? 8 MS. GREER: Objection, asked and answered. I
.9 believe that Mr. Cohn has already stated that the U.S.
10 Department of Justice has not officially adopted this. 11 MR. SMITH: I didn't understand that's what he had 12 said. 13 BY MR. SMITH: 14 Is'that the case, sir? 9 15 Q A (Cohn) That's what I said. 16 - Q Okay, I'm sorry. . 17 If you could remain on page 21. I have looked 18 through the page on which the 2.5 second number is discussed 19 sevaral times. And I also read some pages around that
. 20 number and I did not see the word "two-way radio" mentioned.
21 I didn't actually see the word " radio" mentioned. 22 Isn't it true,- Mr. Cohn, that this section of the 23 document does not include a discusuion of two-way radios? 24 A (Cohn) That's correct. 25 This is a computer aided dispatch document. 9 Heritage Reporting Corporation (202) 628-4888
COEN - CROSS 26060 1 Q In fact, Mr. Cohn, this section of the document 2 discusses telephone trunk line requirements for a police 3 command and control center? 4 A (Cohn) That's correct. 5 Q So, in other words, Mr. Cohn, this section of the . 6 a document discusses trunk line requirements and waiting times 7 for telephone calls into a police switchboard reporting 8 armed robberies, assaults, all life and death situations 9 requiring prompt police assistance? 10 A (Cohn) And other than life and death as well. 11 Q Yes. 12 And other then life and death as well? 13 A (Cohn) Yes. 14 In"the absence of a telephone such calls can come 15 In through radio. 16 . Q Putting aside the question of whether -- well, 17 your basic complaint is that there will be overload on one 18 of the ERN radio channels; correct? 19 A (Cohn) Well, I don't have a complaint; that's my 20 conclusion. . 21 Q Okay, your conclusica. - 22 And that's the route guide channel in particular? 23 A (Cohn) Yes. 24 0 If you could turn to page 10 of your testimony. 25 MR. SMITH: The extra copies have just arrived. I Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26061 1 will give those to the reporter and another two for the 2 Board. 3 (Documents proffered to all parties.) 4 BY MR. SMITH: ; i
~
We're back on page 10, Mr. Cohn. j 5 Q 6 A (Cohn) Right. 7 Q The essence of your testimony there is that, that 8 over three channels would be required to achieve a 10 9 percent maximum blocking rate; is that correct? 10 A (Cohn) That's correct. 11 Q You perform a calculation on thttt page, and I 12 would like to walk you through that, if I might. 13 A (Cohn) Certainly. 14 Q I'm referring to the formula on the top of page 10 9 15 which is entitled: " Channel workload equals." 16 . Multiplying the number of route guide channels per 17 hour by the average call duration equals the total number of 18 seconds that route guides calls would occupy a channel in an 19 hour; is that correct? 20 A (Cohn) Correct. 21 Q And if that number is divided by the total nuuber
~
22 of seconds in an hour which is 3,600, then you arrive at the 23 channel we'akload or the number of Erlangs; is that correct? 24 A (Cohn) Correct. 25 Q And based on the assumptions that you have made in
- O Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26062 1 your testimony that equals .708 for the route guide channel; 2 is that correct? 3 A (Cohn) ' Correct. 4 It's based on 170 calls per hour with an average 5 call duration of 15 seconds. 6 Q 15 seconds, right. . 7 A (Cohn) Which is sort of standard practice in 8 estimating the traffic load of a system for the. busy hour or 9 peak hour? 10 Q For the peak hour? 11 A (Cohn) Yec. 12 Q If we could now turn to figure two of your 13 testimony, on the last page of your testimony.
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14 15 16 - 17 18 19 20 , 21
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22 23 24 25 Heritage Reporting Corporation (202) 628-4888 )
COHN - CROSS 26063 l' .Q Have you found that table, sir? j
$r-}
q i(_/ J2. 'A (Cohn)' .Yes. 1 3~ Q The horizontal axis depicts the Erlangs or 4 workload;.is that correct? 5 A (Cohn)' Yes.
~
6 Q And the vertical axis depicts:the. percent of busy
- 7. calls or the blocking rate to which you refer in your 8 testimony?-
9 A (Cohn) Correct. 10 Q- .In your testimony you state that if 170 potential 11 route guide users were divided among.the three channels, the
- 12. blocking rate would exceed 10 percent, and now with the 13 corrected version, actually would be about 20 percent f
14 according to' Figure 2; is that correct?' ' 15 A- -(Cohn) That's correct. 16' . Q -Now, if we take the .70'8 Erlangs to which you 17 testified and reading Figure 2 for'three channels, at .708 18 Erlangs that really corresponds to a blocking rate of about 19 three percent and not 25 percent; is that not. correct? 20 A (Cohn) If the system were trunked, The system is 21 not trunked. - 22 Q Our system? We have a conventional system; is 23 that correct? 24 A (Cohn) You have a conventional system. And so 25 you have to really divide the workload amongst the three O seritage Reporting (202) 628-4888 Corporation
. _ . -_ ._ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ =
l-i COHN - CROSS 26064 l 1 channels and each one then would have one-third of that 2 workload or approximately .23, roughly a quarter or .25. 3 And then each channel would then have about 20 tercent, if 4 you read up on the bottom scale units of workload, go up on i 5 a quarter the C equal 1 line crosses the 20 percent line at - 6 that point. . 7 So if you divided these calls amongst the three 8 channels equally you would have approximately 20 percent on 9 each channel. 10 If you trunk the system you would have 11 considerably better performance. Which, by the way, is the 12 way that I probably would have tried to design such a 13 system. The .708, sir, is the total. workload'for all three 14 Q 15 channels; is that not correct? 16 . A (Cohn), .708 i's the total workload based on 170 17 calls with an average call duration of 15 seconds, whether 18 it's spread amongst two, three, one or four or five 19 channels. 20 0 But each channel would not receive .7087 , 21 A (Cohn) Each channel would receive .708 divided by 22 the number of channels. 23 JUDGE COLE: Well, sir, then how did you get the 24 20 percent? 25 THE WITNESS: (Cohn) If you take and go roughly Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26065 i g i halfway -- well, if you take the bottom scale. i 'l l ',/ ) 2 JUDGE COLE: Yes. 3 THE WITNESS: (Cohn) Okay. The first mark on the 4 bottom scale would be .5. Go just a little bit more than 5 halfway back. 6 JUDGE COLE: The bottom scale is in units of 7 workload and it goes from zero to 10? 8 THE WITNESS: (Cohn) Right. 9 The first identified one is 1. 10 JUDGE COLE: Yes. 11 THE WITNESS: (Cohn) In between there's a mark 12 that isn't identified, that's a half. 13 JUDGE COLE: All right, sir. ( 14 TH$ WITNESS: (Cohn) And if you were to take and k'
'- 15 divido that roughly in half again.
16 - JUDGE COLE: All right. 17 THE WITNESS: (Cohn) And go up to the "C" equal 1 18 line it's in the order of 20 percent. I suppose one could 19 say 2.'4 percent or approximately 20 percent. 20 JUDCS COLE: And that's how you got it? 21 THE WITNESS: (Cohn) That's how you get it.
~
22 Because that's -- 23 JUDGE COLE: But that looks like two percent. Oh, 24 no, I'm sorry. 25 THE WITNESS: (Cohn) It's 20 percent. Going up ex Heritage Reporting Corporation f}
%- (202) 628-4888
r- --- - COHN - CROSS 26066 1 to the "C" equal 2 line it would be' about two percent, but 2 that's not what the situation is. 3 JUDGE COLE: All right, sir. 4 Thank you. 5 MR. SMITH: Could I have just a moment. 6 (Counsel confers. ) . 7 BY MR. SMITH: 8 Q So, Mr. Cohn, I take it then, your position then 9 is that the only way you would read this table at .708 10 Erlangs and going up to the three channel is, only if this 11 applies to a trunked system; is that correct? 12 A (Cohn) Except for the "C" equal 1 case, in which 13 case --
. 14 Q Trunking wouldn't apply'?
15 A (Cohn) Yes. 16 - There are also formulas for calculating this, but 17 they are rather complex. 18 Q As I see that. 19 A (Cohn) It was easier to show a curve. . 20 Q Isn't it true, Mr. Cohn, that people knowledgeable . 21 in the field of a two-way radio system loading, would agree 22 that loading factors vary depending on certain parameters? 23 A (Cohn) Certainly. 24 Q In other words, loading factors may vary vastly 25 between various types of radio users? Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26067 l 1 A (Cohn) That's correct. 2 Q For example, one parameter is whether a single 3 user has exclusive use of a channel; is that correct? 4 A (Cohn) I'm not sure I know what you mean by I 5 " exclusive use" in that case. 6 Q Well, what I mean by that is, there is only one 7 user assigned to that particular frequency; it's not a 8 shared frequency? 9 A (Cohn) One user meaning a number of units all 10 controlleo by one user? 11 Q Yes, that's what I mean. 12 There would be several radio units. 13 A (Cohn) When I say " users" it's the number of 14 mobile or portable. 9 15
~
Q Yes. 16 . I'm referring to it as the licensee, if you will? 17 A (Cohn) Yes. 18 Q one licensee. 19 When there's a single user having exclusive use of 20 a channel you could have more units on a channel; is that 21 not correct? 22 A (Cohn) Not necessarily. It depends on the call 23 duration. 24 Q But all else being equal? 25 A (Cohn) I'm not sure I can answer that question. O Heritage Reporting Corporation (202) 628-4888
COHN - CLOSS 26068 1 Maybe I didn't understand it. 2 Q Let me rephrase it then. 3 When there's a igle user -- I'll refer to user 4 as one licensee and units as actual -- what I guess you were 5 referring to as users, if that's okay. 6 A (Cohn) Yes. . 7 Q When there's a single user having exclusive use of 8 a channel, all else being equal, all of the factors being 7 held constant, you can have more units on a particular
- 10. channel; is that not correct?
11 A (Cohn) I don't see why. 12 Q Mell, isn't t;he reason that you have the ability 13 to impose radio discipline? 14 A (Cohn) Suppose two users share the channel, can't i . 15 they impose radio discipline on their people independently? 16 - Q But not coordinated? 17 A (Cohn) As a matter of fact, it turns out that in f la taxicab radios, by necessity because there are so many 19 assigned to a particular channel that they get very 20 disciplined. Almost like a market force. , 21 Q But it is easier when one person as opposed to
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22 four or five or six licensees are on a particular frequency. 23 A (Co.hn) I can't necessarily agree with that. It 24 depends on the situation. 25 Q One factor that will be taken into consideration Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26069 1 in determining loading criteria would be the type of use; is 2 that not correct? 3 A (Cohn) That's correct. ; 4 Q And some uses are less tolerant for delays then , 5 others? 6 A (Cohn) That's correct. 7 Q Mr. Cohn, are you familiar with Part 90 of the FCC 8 regulations? 9 A (Cohn) Yes, I am. 10 Q The ERN system is a private land mobile radio 11 system, is it not? 12 A (Cohn) It is. 13 Q And thav's what Part 90 goes to? 14 A (CShn) Correct. O 15 However, Part 90 also applies to state and local 16 government systems as well as nongovernment systems. 17 Q Right. 18 MR. SMITH: At this point I would like to mark for 19 identification Section 90.313 of Part 90 of 47 CFR. That
, 20 will be Exhibit 87.
21 (The document referred 22 to was marked for 23 identification as 24 Applicants' Exhibit 67.) 25 O Heritage Reporting (202) 628-4888 Corporation
i i l COHN - CROSS 26070 l 1 MS. GREER: I have no objection to identifying 2 this document. And, in fact, it may well be useful for the 3 purposes of the examination here today for everybody to have 4 a copy if in fact a lot of questioning is to go on about it. 5 But I would query whether it would be appropriate - 6 to actually have this go in as an evidentiary exhibit since, 7 this is part of the Code of Federal Regulations, is it not? 8 MR. SMITH: Yes, it is. 9 MS. GREER: And that would in fact just be a ! 10 matter of law that I believe this Board would have to 11 take -- 12 MR. SMITH: Judicial notico 13 MS. GREER: , Yes. 14 JU6GE SMITH: Well, yes, that is exactly correct. 15 however, for citation convenience, this is a good way to 16 handle it. Give it an exhibit number and it doesn't send 17 everybody scurrying off to a law library to find the code 18 and read it. So this is a good way to handle it. But you 19 are right. 20 BY MR. SMITH: 21 Q I have placed before you, Mr. Cohn, a copy of 22 Section 90.313 and it's entitled " Frequency Loading 23 Criteria". 24 Do you see that section? 25 A (Cohn) That's correct.
- Hinritage Reporting Corporation (202) 628-4888
COHN - CROSS 26071 mj u 1 .Q The lowest loading c5iteria, in other words,.the ( -2 fewest number of mobiles per channel is for'public safety 3 radio service. 4 Is that not correct? 5 A \Cohn) That's correct. , 6 Q And that's on page 3917 7 A (Cohn) That's right. 8 It is the maximum loading, by the way. 9 Q That's correct. 10 A (Cohn) And it also is in the 470 to 512 megahertz 11 band which is not applicable to this band. I 12 Q You are not saying that for conventional systems 13 the' loading criteria in 90.313 is frequency-sensitive,.are 'W ,(
.14 .you?
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\- -15 A (Cohn) I am not-sure what it says in the 800 16 megahertz band, whether it agrees to this or not. It may
~
17 just refer back'to it. But I'm not sure. 18' MR. SMITH: At this point I would like to mark 19 another document for identification. This one would be 88. 20' (The document referred to was 21 marked for identification as 22 Applicants' Exhibit No. 88.) 23 BY MR. SMITH: 24 Q This document is an excerpt from Docket No. 18262 25 which was adopted May 1, 1974, by the Federal Communications l l'3 Heritage Reporting Corporation L 's (202) 628-4888
COHN - CROSS 26072 1 Commission, and is in shorthand is referred to as the second 2 report and order. 3 And the title of the document is called "An i 4 Inquiry into the Future Use of the Frequency Band 806 to 960 5 megahertz, An Amendment of Parts 2, 18, 21, 73, 74, 89, 91 - 6 and 93 of the Rules". And this appears at 30 Radio 7 Report 2nd 75. 8 This is a discussion as to the use of the 9 frequency band 806 to 960 megahertz. And they are i 10 discussing at this point, the excerpt I have given you, is 11 channel loading standards, and underneath that it says, "In 12 general". 13 What I would like to do, Mr. Cohn, is call your 14 attention to' bullet No. 85.
~
15 A (Cohn). What was the date of this again, sir? 16 - Q This was in 1974, May 1. 17 A (Cohn) Okay. 18 Q And this is the so-called second report and order. 19 If you could just have a chance to read through 20 bullet No. 85. . 21 (Witness reads document.)
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22 A (Cohn) Okay. 23 Q And you may want to familiarize yourself with the 24 other sections if you would like. 25 (Witness reviews document.) Heritage Reporting Corporation (202) 628-4888 Ol
g . n COHN ' CROSS- 26073 1 Q. Have you finished : reviewing the document, sir? 2 A (Cohn) I am familiar with it, in general.
'3 'O Oh, okay. I'm sorry. I just wanted to give you 1
l 4' .enough. time to - 5- A (Cohn) Yes. Okay. 6 It is very similar to the previous document.
-7 Q Yes. And it'is for the 800 --
i 8 A (Cohn) Yes, and it's for the 800 based on the l 9 fact that that was when the rules were being developed and
~
10 they used the previous rules as a starter in the Notice of. 11 Proposed Rulemaking. I 12- Q- Okay. 13 .A (Cohn): I might also note that, going back to the
.14' previous document, if you will note 90.313 (1) (3) (a) (4) .
15 Q Yes. 16 - A (Cohn) One hundred and fifty units in the taxicab 17 radio' service.- Except in New York, northeast New Jersey 18 urbanized areas where the loading is 200 units, these 19 standards are based on a shortage of frequencies. And when
, 20 they go to 200 units, for example, they recognize that there 21 just aren't enough frequencies to go around, 22 Q In New York?
i 23 'A (Cohn) In the New York area. 24 Q For the taxicab service? 25 A (Cohn) Yes. C s ,; Beritage Reporting Corporation (202) 628-4888
t ! i COHN - CROSS 26074 l 1 And these standards are generally used to 2 determine when someone can apply for another frequency. 3 Q Right. 4 A (Cohn) In other words, if you are loaded, they 5 figure you are saturated at these numbers. - 6 Q Yes. 7 Turning back to that document again and looking 8 under (a) (1) , the document states that 50 units is the P loading factor for public safety radio services. 10 A (Cohn) Yes. 11 Q The police would be the most constricting use 12 there, I would assume. 13 Is that not correct? 14 A (Cohn) Police or fire.
~
15 Q Maybe fire? 16 . A (Cohn) Yes. Ambulances. 17 Q And police face a variety of life and death 18 situations, is that not correct? 19 A (Cohn) That's correct. 20 Q And a lot of the decisionmaking is ad hoc, on the , 21 spot? 22 A (Cohn) That's correct. 23 But I might note also that these standards, the 24 public safety radio service includes all local government i 25 radio services, including administrative radio government Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26075 zw 1 service who may, I admit, may not need that 50 unit loading i ) k_) .2 hve:ause their function is not an emergency function as much 3 so as police, but sometimes the road people or the water i 4 people do get into an emergency situation.
^
5 Q But not on a daily basis like police. 6 A (Cohn) Well, but une does not design there things 7 for average. One designs them for peak loads, because 8 that's when you really need the thing, which is the case in { 9 the Seabrook facility, too. 10 If there is not an emergency, the channels aren't 11 used, but they must be there when there is an emergency. 12 Q So when there is ad hoc decisionmaking in the 13 field, radio communications really substitute for previously ,/^'S 14 adopted procedures to affect the decisionmaking in the \ -
-} 15 field.
16 . Is that not correct? 17 H3. GREER: Objection. I'm not sure whether I 18 even actually heard it all. But if I heard it all, I 19 believe the question went something like, so when is ad hoc
. 20 decisionmaking a substitute for --
21 JUDGE SMITH: Yes, your voice trailed off at the 22 end. 23 MR. SMITH: Oh, I'm sorry. 24 JUDGE SMITH: Would you restate the question? 25 MR. SMITH: Yes, I'll start that again. r\ Heritage Reporting Corporation (N_/ j (202) 628-4888
COHN - CROSS 26076 1 BY MR. SMITH: 2 Q As you testified earlier, Mr. Cohn, with the 3 police communications, that there has a tendency to be a lot 4 of ad hoc decisionmaking in the field. 5 That's correct? 6 A (Cohn) I didn't say that. 7 Q Well, I asked you a question that the police face 8 a variety of life and death situat. ions. 9 A (Cohn) Yes, but that dcasn't necessarily mean 10 that's ad hoc decisionmaking in the field. There is a 11 command and control function. 12 Q Well, I believe the question I asked you was that 13 a lot of their decisionmaking is ad hoc and in the field; is 14 it not? , A Some decisionmaking is. I don't know if I l 15 (Cohn) 16 would characterize it as a lot. 17 Q And to the extent that there is ad hoc 18 decisionmaking, radio communications substitute, do they 19 not, for previously adopted procedures? I 20 Is that not correct? , 21 A (Cohn) I'm not sure what you mean by that. 22 Q Well, let's look at it this way. 23 Say somebody -- say a police officer was on a call 24 and a certain situation arose which they weren't sure what 25 to do with. If they didn't have -- and if they didn't have Beritage Reporting Corporation , (202) 628-4888 1
COHN - CROSS 26077 j 's 1 an_already adopted -- you know, something that wasn't in
\ )
\_ / 2 their procedures, they would call on the radio to find out 3 what was going on.
4 Is that not correct? 5 MS. GREER: Objection. I believe the question is 6 asking this witness to speculats about what a policeman 7 might do. I'm not sure that such a question 13 pertinent to 8 the testimony that this witness has offered here today. And 9 I believe it's irrelevant to the issue of channel loading 10 and range of radio communications that is the substance of 11 the testimony before us here today. 12 (The Board confers.) 13 MR. SMITH: All I'm doing is asking him in terms
/~'N 14 of radio communication usage, as to his experience as to
' ) 15 what type of uses would be used in various circumstances.
16 . MS. GREER: What types of pieces? 17 MR. SMITH: What kind of uses. 18 MS. GREER: Uses. 19 MR. SMITH: Of the communication system.
. 20 JUDGE SMITH: Objection overruled.
l 21 THE WITNESS: (Cohn) Could you repeat the ) - 1 22 question? 23 MR. SMITH: Sure. 24 BY MR. SMITH: i 25 Q Radio communications substitute for previously
-( Heritage Reporting Corporation A-_/ (202) 628-4888
COHN - CROSS 26078 1 adopted procedures to affect decisionmaking in the field; do - 2 they not? 3 A (Cohn) They can. 4 Q I would like to turn back to Section 90.313 and we 5 had just been looking at public safety radio services at a 6 loading of 50 units. I guess in that same document it says , 7 that 70 units for industrial radio services. 8 Is that correct? 9 A (Cohn) That's correct, except for business. 10 Q Which is 907 11 A (Cohn) Yes. 12 Q If we could take one more example. If we could 13 look at intra-urban passenger carriers, and that's under 14 (a) (5) . the very bottom of the page? 15 A (Cohn) Correct. 16
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2 These are buses that are like MDTA buses in 17 Boston? 18 You may not be familiar with the buses in Boston, 19 but those are basically public transit buses. , 20 A (Cohn) That's correct. . 21 Q And bus drivers seldom need to use the radio 22 because they are confronted with life or death situation. 23 They r. tight occasionally, but in general, they don't. 24 Is that correct? 25 A (Cohn) You are talking ab.7vt the motor carrier Heritage Reporting Corporation (202) 628-4886
E f COHN - CROSS 26079
,m 1 radio service? / \
k x_ l 2 Q Well, I'm talking about the intra-urban passenger. l 3 In other words, the buses. 4 MS. GREER: Objection. It's not clear merely from-5 this document that bullet No. 5 in that parenthesis is in 6 fact talking about intra-urban or whether it's talking about 7 inter-urban. It certainly mentions railroad there which 8 would typically be inter-urban, or even across country, 9 going through rural territory. This is not clear that -- 10 MR. SMITH: No. 11 MS. GREER: -- in fact that No. 5 is applicable to 12 the situation being premised in the question. 13 NR. SMITH: I think the document speaks for itself i
,/^N 14 there. It says 70 units in the railroad, motor carrier and
( ) i
\'/ -
15 automobile emergency radio services. That's talking in 16 general. That would include inter- and intra-urban 17 transportation. They are singling out a specific category 18 in there called intra-urban passenger carrier. And I 19 believe that's very clear what that -- I mean, they say what 20 that is. That's intra-urban. 21 MS. GREER: Right. But I'm not -- 22 THE WITNESS: (Cohn) Intra-urban is -- 23 MR. SMITH: Intra-urban with an "a". 24 THE WITNESS: (Cohn) -- 150 units is what they 25 say.
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( Heritage Reporting Corporation
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--_____________.____________________i
COHN - CROSS 26080 1 MS. GREER: Okay. 2 THE WITNESS: (Cohn) That's correct. 3 MS. GREER: But is that in an of itself going to 4 buses or is that going to taxicabs or do taxicabs count as 5 intra-urban? Is that referring back to 4? . 6 MR. SMITH: No. There is a separate taxicah -- 7 JUDGE COLE: Number 4 refers to taxicabs. 8 HS. GREER: I know, but is that second exception 9 referring back to 47 10 THE WITNESS: (Cohn) No. It does refer to buses. 11 That's correct. 12 MR. SMITH: All right. 13 BY MR. SMITH: 14 Q Th5 bus drivers pretty much go along their 15 assigned routes? 16 . A (Cohn) They have assigned routes. They seldom 17 need to use the radio except if they have a breakdown. 18 That's why there is 150 units. 19 Q Right. 20 So basically, they use their radios for a limited . 21 number of communications such as breakdown problems, things 22 like that. 23 A (Cohn) Yes. 24 Q If you could just state for the record what 25 Section 90.313 states the loading criteria for -- I believe 1 Heritage Reporting Corporation (202) 628-4888
, COHN - CROSS 26081 h 'l -you-have, but just to make sure it's clear, what the intra-
.2- -urban' passenger carrier loading criteria is?
3' -A (Cohn) Intra-urban passenger carrier. subcategory i4 'of the motor carrier radio'eervice where the loading is.150 5 units. 6 Q- Mr.'Cohn,_what do you know about what the ORO 7- route guides.do?
'8 A (Cohn) *4 hat I have read.
9 10 11 12 13-14 ~'
'15 16 .
[17
'18 19
. 20 21 22 23 24 25 A '
Heritage Reporting Corporation (202) 628-4888
! COHN - CROSS 26082 1 1 Q What is that? 2 A (Cohn) They are sent to a staging area and are 3 used to guide buses to various places such as nursing homes 4 or schools to evacuate people to safer areas. 5 G In fact, there are several different functions - 6 that route guides perform; is that not correct? 7 A (Cohn) Yes. 8 Q Anything else besides evacuation-specific 9 positions? 10 Is that all they do is assist in evacuating 11 individuals and guiding buses? 12 A (Cohn) I believe that's correct. 13 They may have other functions that I'm not aware
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14 of.
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15 Q Are you aware that a separate group of route 16 guides notify the hearing impaired? 17 A (Cohn) Oh, yes. 18 Q What is your understanding, Mr. Cohn, of the two-19 way radio communication procedures for route guides? 20 MS. GREER: Objection as to form -- it seems to me . 21 this is a relatively broad question. 22 Are you asking about specific procedures? 23 MR. SMITH: I'm asking his understanding. 24 MS. GREER: Or when they would use them or are you 25 asking about the discipline that they're supposed to go Heritage Reporting Corporation (202) 628-4888
1 *h*
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- s. 1~ through?- The procedural steps they're supposed to go l )
, \_,/ 2 through when they actually want to use it? 3 MR. SMITH: Yes, all of it. 4 Whatever his understanding of the procedures are. 5 MS. GREER: -I'm going to stand by my objection a. 6 to. form. I think it's just too broad to, in fact, focus in -
. on.
8 JUDGE SMITH: Are you able to answer it in the way 9 it's presented? 10 THE WITNESS: (Cohn) I'm not sure I understand it 11 completely.
-12 JUDGE SMITH: Well, that settles that.
13 THE WITNESS: (Cohn) It is a little broad. t
/ 14 MR.' SMITH:
I'll rephrase the question and be a
'- 15 little more specific.
16 . BY MR. SMITH: 17 Q Under what circumstances would a route guide 18 initiate a radio communication? 19 A (Cohn) A route guide may initiate a radio
. 20 communication if he needs further instructions. However, if r 21 there is a block in the traffic he might want to, you know, 22 determine an alternate route to take.
23 He may not necessarily initiate communications 24 himself, but the dispatcher may initiate communications to 25 him which he has to respond to regarding rerouting of buses, Beritage Reporting Corporation [(. (202) 628-4888
l COEN - CROSS 26084 e 1 ingestion of potassium iodide, for example, other such ! 2 instructions. 3 Q Do you know -- when you say "other such 4 instructions," do you know of any other instructions? 5 A (Cohn) The dispatcher may be aware of a blocked - 6 route and instruct the route guide to go and take a 7 different route. 8 The dispatcher may find that local buses have f 9 already evacuated people at that group and he may reroute 10 the route guide to a different location. 11 Q So a lot of those are calls going from the -- 12 A (Cohn) The dispatcher. 13 Q -- dispatcher to the route guide? 14 A '(C5hn) The route guide, yes.
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15 Q If we could just limit it at this point to 16 communications from the route guides to the dispatcher or to 17 -- I believe you have testified that they would report 18 blockages in t:affic, I believe that's the only one you 19 mentioned. 20 Is there any other communications that they . 21 would -- 22 A (Cohn) That they would initiate? 23 Q They would initiate? 24 A (Cohn) Breakdowns. 25 Q Breakdowns. Heritage Reporting Corporation (202) 628-4888
i COKN - CROSS 26085 1 So in other words, they' re just reporting l 7-S
- 2 problems?
3 A (Cohn) They are just reporting problems. 4 However, the channel is used in a two-way sense. 5 Calls can be initiated from either end and I would expect
. 6 that calls initiated by the dispatcher to the route guide 7 v.- =1 generally exceed those initiated by the route guides.
8 Q If there was, for example, a general instruction 9 to ingest KI or something like that, is that what you're 10 referring to? 11 A (Cohn) Or just general information about what's 12 happening to allow the route guides to be aware of 13 situations that are developing. [} 14 Q Mr. Cohn, based on what you knew when you drafted
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(.'~' 15 your, testimony you concluded -- well, I guess initially you 16 concluded that there would be -- over two channels would be 17 better than one for route guides, and then you revised your 18 testimony to say there would be greater than three? 19 JUDGE COLE: I'm sorry, I didn't hear your
. 20 comment, Mr. Smith.
21 MR. SMITH: I'm sorry. 22 BY MR. SMITH: 23 Q Initially when the Sikich and Cohn testimony was 24 filed, the initial prefiled testimony, you concluded that l 25 over two channels? 1 ('- Heritage Reporting Corporation (202) 628-4888
V COHN - CROSS 26086 1 A (Cohn) My associate' concluded that. 2 Q Concluded that there were over two, and that was 3 revised? 4 A (Cohn) Correct. 5 When I reviewed it I felt that more than three -- - 6 JUDGE COLE: Two channels for route guides? 7 MR. SMITH: For route guides, sir, yes. 8 BY MR. SMITH: 9 Q Were you aware when you wrote the testimony that 10 there would be a fourth backup channel that has no primary 11 functional use? 12 A (Cohn) The fourth channel -- my understanding of 13 the fourth channel is that it is to be used for cases where 14 the telephone service is not available. ,
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15 Q I think you're getting that a little confused.- 16 . There's an inter-facility channel which is used 17 for that purpose; is that not correct? i 18 A (Cohn) I'm not sure what they call them. I know 19 one channel is used in the case of a telephone system j 20 breakdown. . 21 Q Were you aware that there was an additional 2f4 channel -- 23 A (Cohn) There are four channels that I am aware 24 of, yes. A total of four channels. 25 Q And that fourth channel, as I'm calling it -- Heritage Reporting Corporation , (202) 628-4888 1 1 l
l 1 COHN - CROSS 26087 l 1 A (Cohn) Is'an overload channel. ] 7-~ (_j) 2 0 -- is an overload type channel. I 3 A (Cohn) Okay. 4 JUDGE COLE: That's right on page 3 of your 5 testimony, sir? 6 THE WITNESS: (Cohn) Yes. 7 BY MR. SMITH: 8 Q If the need arises, Mr. Cohn, a complete solution 9 would be to meve some route guides to these backup channels, 10 would it not? 11 A (Cohn) Then you would have two channels 12 available. But one must plan to do this because how do the ! 13 route guides know to move unless they hear information to 14 move. If they are out of the coverage area they would never fN
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N, 15 know to move and may not be aware of a call for them because 16 they are tuned to the wrong channel. So this should be a 17 preplanned thing. i 18 Q Were you aware, Mr. Cohn, that an operational 19 analysis of route guide functions has been performed?
, 20 MS. GREER: Objection. What time and by whom?
21 MR. SMITH: Excuse me? 22 MS. GREER: Objecticn. It's not clear what the 23 context of your question. You said, are you aware that an 24 operational analysis has been done? It's not clear from the l 25 context of your question whether you're talking about one 7-s
' Heritage Reporting Corporation s (202) 628-4888
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I COHN - CROSS 26088 1 done by New Hampshire Yr.nkee or one done by FEMA. 2 MR. SMITH: I'm sorry. 3 By New Hampshire Yankee. 4 THE_ WITNESS: (Cohn) An operational analysis? 5 I personally am not aware unless you are talking - 6 about the testimony that I get yesterday, the Rebuttal No. 7 22. I think there was something referenced in that about 8 route guides. 9 BY MR, SMITH: 10 Q What I'm referring to is an analysis which 11 demonstrates that operationally route guides can be 12 allocated by function between the channels. 13 For example, as we were discussing earlier, there 14 are some route guides who notify the hearing impaired. 15 There are other route guides who are assigned to special 16 facilities. "here are further route guides who are assigned 17 to schools. 18 That functionally you could break down between -- 19 A (Cohn) I am aware that that could be done, yes. 20 Q Okay. , 21 A (Cohn) But I'm not aware of the analysis. 22 Q And I take it from what we were saying, I'm not 23 sure if the answer was clear, I would like to just ask it 24 again. Were you aware that the int.er-facility channel is 25 not used except for instances of commercial telephone Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26089
's
. 'l faildre? I believe you testified to that.
2 A- (Cohn) Yes. 3 Q So route guides in the absence of a commercial 4 telephone failure could be assigned to that channel; is that.
-5 not correct?
A 6 (Cohn) .That's correct. 7 'Again, provided that they are preassigned to that 8 channel or there is a plan to assign them to that channel. 9 Q Well, one way, of course, to avoid this problem 10 would be to use the channel -- a second or third channel and 11 simulcast over both channels; is that not correct? 12 A (Cohn) If one simulcasts over both channels one 13 increases the loading and you might just as well go back to 14 one channel."
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15 Q' True. 16 . What I'm saying is, you could, for example, use a 17 DTHE rwitch and cut them off if the loading got to a point 18 where~that one channel was overloaded. 19 For example -- I'm not sure if I'm clear, I see
. 20 some confusion in your face. Let me see if I can explain it 21 a little better.
22 You could have one channel -- actually have three 23 channels and be simulcasting over those three channels; 24 that's correct? 25 A (Cohn) Certainly you could. l (' Heritage Reporting Corporation (202) 628-4888 l
COHN - CROSS 26090 l' Q And your testimony, I believe, was that while 2 there would be lots of loading because you would have three 3 channels and everybody would be on the same one because of 4 the simulcast there would be high-loading. 5 The question I was asking was: if you use a DTMF 6 switch you could actually segregate those channels into 7 three separate channels. And if they were divided 8 functionally each individual route guide on a particular 9 function, for example, a route guide for notifying special 10 facilities would then be on that channel by themselves. 11 That's technically possible, is it not? 12 A (Cohn) Certainly. 13 Q In other words, it's really a relatively simple 14 planning fix? 15 A (Cohn) I'm'not sure if that's a fix, but it v ald 16 segregate it into three channels, which is the case that we 17 talked about which would still result in a blocking rate of 18 approximately 20 percent, if they were divided equally. 19 If they were not divided equally one could exceed 20 20 percent. One might be close to 10 percent. It's hard to , 21 say. I don't know how many, you know, what the distribution 22 of these functions are. 23 Q Right. 24 But assuming that they could be divided equally 25 that would -- Heritage Reporting Corporation (202) 628-4888 l l l ( _ _ _ - _ _ _ _ _ _ _ _ _
r r COHN'- CROSS 26091
- p. 1 .A. (Cohn) You would:have a blocking figure of 2 approximately 20 percent baced on our' calculation.-
3 Q Based on your calculation? 4 A- (Cohn) Yes.
$ Q I understand.
L, 6 A (Cohn) You could also use a trunk system in which - r 7 came you would considerably less -- 8 JUDGE SMITH: Would you explain what you mean by 9 "trunking" or using'the " trunk system?" 10 THE WITNESS: (Cohn)- Okay. 11 JUDGE SMITH: How that affected what you referred 12- to of what happened?
- 13. THE WITNESS: (Cohn) A trunk system allows a.
f~ 14 conversation'to be held between a user or user group 15 regardless of what channel is used. In other words, if you
- 16. were to have, say, four channels for this system and it were 17 trunkeld, you don't really care what frequency you're using 18 if you want to talk to a particular individual.
19 JUDGE SMITH: It maximizes the available --
. 20 THE WITNESS: (Cohn) Yes. The system chooses the 21 frequency that's vacant and maximizes the use of the space.
22 I have a diagram here if you would wish. 23 JUDGE SMITH: No , I understand. 24- THE WITNESS: (Cohn) Showing how blocking -- 25 JUDGE SMITH: No. The concept is what we wanted. Beritage Reporting Corporation (202) 628-4888
n-COHN - CROSS 26092 1 BY MR. SMITH: 2 Q Mr. Cohn, all else being equal you're not saying , 1 3 that it's better to have more channels -- in other words, ] 4 it's better to have one channel than two, if you don't hurt 5 the loading criteria -- if you don't overload the channel; - j 6 is that not correct? 7 MS. GREER: Objection as to form. I'm having some 8 problem hearing you, but I'm also having some problem 9 actually following the question. 10 MR, SMITH: Why don't I rephrase it. 11 THE WITNESS: (Cohn) So am I. 12 MR. SMITH: I'll rephrase it. 13 , BY MR. SMITH: 14 Q You're not saying, Mr. Cohn, that assuming there
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15 is no overload, you're not saying that two channels would be 16 better than one? 17 A (Cohn) If there is no overload one would use the 18 minimum number of channels. 19 Q And that's because there is a certain amount of 20 benefit with two-way radio communications to be able to hear . 21 what everybody else is saying? 22 A (Cohn) That's correct. 23 Q That's a benefit? 24 A (Cohn) If they, you know, if they' re performing 25 similar functions. Heritage Repor'ing Corporation (202) 628-4888
U .a. i I j COHN - CROSS 26093
;r l' Q. ,Oh, sure, d 2 .A -(Cohn)' You may not-want to hear other things
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3 because hearing a lot of information tends to overload
'4 P*0P le'and they may not hear the things that they're 5' supposed to hear because they get bored listening.
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I 6 - 7 l 8 9 ! ~10-11 12 13
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. 20 21 22 23 24
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25 Heritage Reporting Corporation - (202) 628-4888
COEN - CROSS 26094 1 Q And that's a benefit that, for example, that you 2 don't have with a telephone? You can't hear what other 3 people are saying? 4 A (Cohn) Not unless you have a party line. 5 Q If you could now turn to page 8 of your testimony. 6 A (Cohn) Page 8. . 7 Q Looking now at the last paragraph on the page 8 beginning: "During the exercise?" 9 A (Cohn) All right. 10 Q You state there that: "An approximately 10 minute 11 delay occurred in transmitting information requesting 12 dispatch of a wrecker from the transfer point because of 13 heavy dispatch traffic on the route guide channel." Is that
. 14 not correct?
15 A (Cohn) That's correct. 16 - Q You're not saying here that anyone had a key-down 17 for 10 minutes, are you? 18 A (Cohn) No. - 19 Q In fact, you can have a key-down for 10 minutes? 20 A (Cohn) Well, it depends on the system. , 21 O You're familiar, I assume, with time-out timers? 22 A (Cohn) Yes. 23 I assume if there is a time-out timer on the 24 system that would -- 25 Q And the time-out timer, just for the education of 1 Heritage Reporting Corporation N (202) 628-4888 L__________
p o COHN - CROSS 26095
;fw. .1. the people.in the room, it's a circuit and transceiver that l . .
2- starts a timer when the transmitter is keyed; that's l -3 correct, is it not? 4 A (Cohn) Yes. 5 Q And then after a predetermined amount of time if 6 the operator hasn't already unkeyed the transmit circuit is 7 automatically disconnected? 8 A (Cohn) That's correct. 9 Q or released. 10 In fact, during this 10 minute period of time then 11 there must have been a series of messages and pauses; 12 correct? 13 MS. GREER: Objection. So far we don't have in
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, 14 the record a premise in the question which is, in fact, this
( - 15 system does have a time-out timer in it. 16 . I don't believe that's anywhere established in the 17 record so far.
-18 MR. SMITH: That has nothing to do with this 19 question. The witness testified that he was not saying that 20 somebody-had a key-down for 10 minutes,
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21 MS. GREER: That's correct. 22 MR. SMICH: And then from there the question 23 follows that there would have been a series of pauses and 24 conversations. 25 MS. GREER: Well, I'm not sure that he said he Heritage Reporting Corporation (202) 628-4888 l
, COHN - CROSS 26096 l-1 didn't know whether they had it down for 10 minutes or he 2 doesn't know otherwise either. I don't think he has 3 testified that he knew, in fact, that there were many breaks 4 in it either.
l 5 I don't think he has testified to the point one 6 way or the other. l l 7 JUDGE SMITH: How did you arrive at the premise 8 that the channel was necessarily busy? 9 MR. SMITH: I'm just using actually the statement 10 in his testimony saying that it was -- a 10 minute delay 11 occurred. 12 Oh, I see, how I got from the 10 minute delay to 13 the fact that the channel was busy. 14 JU$GE SMITH: Yes. The busyness is the indication 15 you made. 16 - MS. GREER: That, I believe, is from the FEMA 17 report, Your Honor. 18 THE WITNESS: (Cohn) That's page 204 of the FEMA 19 report is where I got that information. 20 JUDGE SMITH: What did you get from there? , i 21 THE WITNESS: (Cohn) The information that, "We 22 were delayed for a period of approximately 10 minutes." 23 JUDGE SMITH: Did you get the cause of the delay 24 from there? 25 THE WITNESS: (Cohn) I don't believe it gave the *l l Heritage Reporting Corporation l (202) 628-4888 l h - - - - - _ m___,,__.m .__
COHN - CROSS 26097 cause. 91 2 MR. SMITH: And I was just assuming on the 3 witness' statement that it was heavy bus dispatch traffic, 4 and that's why I assumed that it was because of radio 5 traffic. . 6 JUDGE COLE: Mr. Cohn, where did you get the i 7 information in your testimony that says that it was 8 attributable to heavy bus dispatched traffic on the route 9 guide channel? Did you assume that or is it stated there? 10 (Witness reviewing document.) 11 THE WITNESS: (Cohn) I'm not sure where my 12 associate got that. He references page 204, but I don't 13 read the words directly that it was heavy bus dispatch 14 traffic. He'may have found it somewhere else. 15 MS. GREER: I think it's actually on page 206, two 16 pages later. Down at the second bullet in the FEMA report. 17 JUDGE COLE: Yes, that's the language. 18 THE WITNESS: (Cohn) Okay. 19 JUDGE COLE: "Because of heavy bus dispatch" --
. 20 THE WITNESS: (Cohn) Yes.
21 It's referenced in two places, I guess. 22 MR. SMITH: Is there an objection? 23 JUDGE SMITH: There is an objection, but I've lost 24 the thread of the relevance. 25 MS. GREER: The objection was -- and we can read Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26098 1 back the question. My understanding of the question, and 2 tell me if I'm wrong, was that your question had a premise 3 in it that -- you went from the premise that somebody didn't 4 necessarily have a key-down for 10 minutes. And it was his 5 statement that he didn't know whether the heavy dispatch was - 6 because somebody had a key-down for 10 minutes to the 7 fact that -- 8 MR. SMITH: No, no. The testimony was, the 9 witness agreed that somebody would not have had a key-down 10 for 10 minutes and I asked him, if that's impossible and he 11 said, yes. 12 MS. GREER: Okay. 13 MR. SMITH: That's the basis on which we're 14 starting.
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15 MS. GREER: Why don't you try your question again. 16 . BY MR. SMITH: 17 Q There must have been a series of messages and 18 pauses; is that not correct? 19 A (Cohn) I would assume that would be the normal 20 case because no one would -- at least not with good . 21 discipline would hog a channel for 10 minutes. 22 Q So a person could have elected to break in during 23 on of these pauses but for some reason chose not to? 24 A (Cohn) It depends, if he is faster on the key 25 than somebody else he would be the next in line. i i Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26099 l' r- s 1 Q But somebody could have done that?* k- s 2 A (Cohn). Somebody else could have done it, too, and 3 grabbed it before the other person. And that's what happens 4 when you have excess loading. Just too many people are 5 trying to get on at one time. 6 Q Are you aware, Mr. Cohn, that route guides have 7 been trained in radio -- trained to break for a priority 8 message? 9 A (Cohn) If they're aware a priority message is 10 there, yes. 11 Q If they are aware that it's a priority message 12 that they need to send, they've been trained to do'that? 13 A (Cohn) To break in? f 14 Q Yes. t
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15 A (Cohn) They may or may not be able to break in. 16 There's a capture effect in FM radio. 17 Q But they have been trained? 10 A (Cohn) Oh, sure. 19 JUDGE SMITH: Are you suggesting they have been
. 20 trained to take a break and permit a break into it for 21 priority messages?
22 MR. SMITH: Yes, Your Honor. 23 JUDGE SMITH: That's two thoughts? 24 MR. SMITH: Yes, they have been trained to pause. 25 And -- I don't want to testify. Heritage Reporting Corporation (
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I COHN - CROSS 26100 I I I 1 BY MR. SMITH: 2 Q Are you aware that they have been trained to 3 pause?
- 4. A (Cohn) I have seen information on their training.
5 JUDGE SMITH: Yes. But are you aware ~that they've - 6 been trained to pause? 7 MS. GREER: Objection. Obviously, Mr. Cohn bas 8 never attended the training. 9 JUDGE SMITH: Well, if he's not aware of it then 10 he can say, no. If he is aware of it then I assume he can 11 say, yes.- 12 THE WITNESS: (Cohn) I would say, no, as far as 13 being completely aware that that's included in their
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14 training. ,
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15 BY MR. SMITH: 16 . Q So you do not know that they have been trained to 17 pause? 18 A (Cohn) I do not know that they have been trained 19 to pause, t?at's 2 correct. 20 JUDGE COLE: Excuse me, I don't understand what . 21 " trained to pause" means? What does that mean, sir? 22 THE WITNESS: (Cohn) Are you asking me? 23 JUDGE COLE: Yes. l 24 THE WITNESS: (Cohn) In a normal radio situation 1 25 being off the air for a short period of time before replying Heritage Reporting Corporation (202) 628-4888 t _ _ - _. _ _ - _ _ _ _ _ _ -
COHN - CROSS 26101
,- 1 allows someone to capture the channel. And that pause would
..- 2 allow someone else to capture the channel.
3 I think that's what the gentleman was referring 4 to. 5 JUDGE COLE: And what would~be the advantage of 6 being trained to pause? 7 THE WITNESS: (Cohn) This would allow someone to 8 break in, in case they had an emergency situation. 9 JUDGE COLE: Then he would have to get back on 10 after the pause? 11 THE WITNESS: (Cohn) Yes. You would finish your 12 conversation later. 13 JUDGE COLE: All right, sir.
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Thank you. THE WITNESS: (Cohn) In a trunk system there is a
'- 15 16 preemption capability which allows you to preempt a message 17 once the person breaks the conversation. ,
18 There is one that's called " ruthless preemption" 19 as well. 20 BY MR. SMITH: 1 21 Q Mr. Cohn, you said, I believe you testiried 22 earlier that you have read our rebuttal testimony? l l 23 A (Cohn) I got it yesterday and read it last night. i 24 Q Have you read Attachment E? 25 A (Cohn) Attachment 8? l l [ Heritage Reporting Corporation
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COHN - CROSS 26102 1 Q "E" as in Edward? 2 A (Cohn) I have read parts of Attachment E. As a 3 matter of fact, I went through Attachment E last night, at 4 least the first parts of it, and looked at some of the 5 standard messages and read them out loud to myself without a - 6 pause between breaks and did a timing on them. 7 Q What about page 5, have you read that page? 8 That's page 5 of 117 9 A (Cohn) Yes, okay. There's the short pause. 10 Q Did you read that page? 11 A (Cohn) Yes. "Someone may have an emergency 12 method." 13 Q And you said you read that page?- 14 A (Cohn) Yes, I did.
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15 I'm sorry, I didn't remember that as being as part 16 of the instructions. 17 Q Are you aware, Mr. Cohn, that a message went out 18 almost immediately on the traffic guide radio requesting 19 dispatch for a wrecker with respect to this incident you are 20 referring to in your testimony? . 21 A (Cohn) Repeat again. 22 Q Were you aware that a message went out almost 23 immediately on a traffic guide radio requesting dispatch of 24 a wrecker in reference to this situation of which you're 25 testifying? i
. Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26103 1 A '(Cohn) I am not aware of it. No, I'm not. G 2 l 4 I 5 6 7 8 9 10 11 12 13 14 9 15
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I COHN - CROSS 26104 1 Q Mr. Cohn,.to your knowledge, no necessary 2 communications were precluded during the exercise, were they i 3 to your knowledge? i 4 MS. GREER: Objection as to the term "necessary". 5 It's really calling for a judgment call by this witness. I 6 THE WITNESS: (Cohn) I can't comment on what is . 7 necessary and what is unnecessary. l ( 8 MR. SMITH: Okay, that's fair. 9 THE WITNESS: (Cohn) But I might comment on your 10 radio rules, by they way, going further. 11 MR. SMITH: I don't think there is a question? 12 THE WITNESS: (iCohn) Pardon? 13 MR. SMITH: I don't have a question posed at this . 14 point. , 15 THE WITNESS: (Cohn) Okay. , l 16 - BY MR. SMITH: 17 Q I just have one more question. 18 What was the name of your associate? 19 A (Cohn) John Didanato. 20 Q That's D-I-D7 , 21 A (Cohn) A-N-A-T-0, I believe.
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22 MR. SMITH: I have no further questions. 23 JUDGE SMITH: Does the Staff have questions? 24 MS. CHAN: Yes, I do. 25 Would this be an appropriate time to take the Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26105 1 morning break and I can review my cross plan? 92 JUDGE SMITH: All right. i 3 Ten minutes. No more. 4 MS. CHAN: Thank you, Your Honor. 5 (Whereupon, a recess was taken.) 6 JUDGE SMITH: Ms. Chan. 7 CROSS-EXAMINATION 8 BY MS. CHAN: 9 Q Mr. Cohn, my name is Slaine Chan. I am counsel 10 for the NRC Staff. 11 Can you please tell us your specific experience or 12 training in planned radiological emergency response? 13 A (Cohn) In planned radiological emergency 14 response? 9 15 Q Yes. 16 _ A (Cohn) I have had some experience primarily in 17 local government radio systems, some of which have emergency 18 operating groups which deal with radiological response. 19 Q Are these based on a pre planned procedure? I
, 20 mean there's a specific plan which they follow?
21 A (Cohn) There is a plan that they follow, yes. 22 Q Would you anticipate that a response to an 23 evacuat.4cn that follows a pre planned procedure would differ 24 substantially from a police situation where ad hoc responses 25 are more common? . Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26106 1 MS. GREER: Objection. 2 I don't believe it's been established as a premise 3 that in fact ad hoc responses by police are more common than 4 you may have in a radiological emergency situation. 5 MS. CHAN: Well, if the witness can answer, he can - 6 agree or disagree with the premise. 7 JUDGE SMITH: All right. 8 MS. CHAN: Would that satisfy your objection? 9 JUDGE SMITH: It seems to, yes. 10 THE WITNESS: (<Cohn) Let me make sure I 11 understand the question again. 12 Would you mind repeating it, please? 13 MS. CHAN: Can I have it read back, please? 14 (Accordingly, the pending question was played
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15 back by the court reporter.) 16 . THE WITNESS: (Cohn) If in fact the response is 17 ad hoc in a police situation and is completely pre-planned 18 in an evacuation situation, yes, they are different. But an 19 evacuation situation is an emergency situation and I'm not 20 sure that there are ad hoc responses in all cases. . 21 To put it another way, things do go wrong. 22 BY MS. CHAN: 23 Q In response to some Applicants' questions about 24 the preparation of your testimony, you testified that a John 25 Didanato was an associate working for you who prepared the Heritage Reporting Corporation (202) 628-4888
I COEN - CROSS 26107 i tustimony and you spent approximately four hours reviewing l
, -~s 1 l }
\m / 2 the results of his work.
3 Is that correct? 4 A (Cohn) Four hours reviewing the testimony, but 5 some supervision on his normal work. 6 Q Do you know whether he reviewed any of the l 7 training modules of the New Hampshire Yankee ORO emergency 8 plan training program? 9 A (Cohn) I believe he did. 10 Q Did you review any of those? 11 A (Cohn) No. 12 Q So that the testimony, as you understand it, takes 13 into consideration a review of the training modules? j'~%g 14 A (Cohn) I'm not sure what you mean by " training
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b) 15 modules". 16 . Q Well, the New Hampshire ORO emergency training 17 program has pieces of training, and they are called training 18 modules. 19 A (Cohn) Okay. 20 Q And they address different parts of the procedures 21 that the traineos have to address. 22 A (Cohn) Okay. 23 The only procedures that I looked at personally 24 are those that are attached to this No. 22 rebuttal 25 testimony. There are some procedures in the back. 1 l [/-~) Heritage Reporting Corporation (202) 628-4883
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COHN - OROSS 26108 1 Q So those were the only ones that you personally 2 reviewed? 3 A (Cohn) That I personally reviewed, other than 4 perhaps looking at small sections, if it were appropriate, 5 in the testimony. - 6 Q Are you aware of what training module information 7 might have been provided by the Massachusetts Attorney 8 General for you to review in preparation of your testimony? E I see you have a notebook before you. 10 A. (Cohn) I have a notebook and certain portions of 11 the information provided by the Massachusetts Attorney 12 General are in here. 13 Q Are one of those tabs on the side, does that have 14 a training tab on it or --
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15 A (Cohn) That's what I'm trying to see. 16 - There is a staffing one which I assume is part of 17 a training guide. It may or may not be. 18 Q Is there a title on the page? 19 A (Cohn) Well, it's just a chart, a staffing chart. 20 Q I see. , 21 A (Cohn) And then, let's see, what else is in here. 22 (Witness reviews documents.) 23 A (Cohn) I don't see any direct thing titled 24 " Training". 25 Q I see. Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26109
~~ ' ' '" ' "' '"' " ""* "' '" ~^' ' "' *"' '~ "
(' . 2 about public safety wystems that you had planned.
'3 And were those related to police and law 4 enforcement'primarily?
'S A (Cohn) Police, law enforcement and emergency 6- response systems, emergency response centers for -
7 coordination of all public safety f, unctions. 8 Q Did the associate who prepared your testimony have 9 the same experience as you did in these areas? 10 A (Cohn) He's had considerable experience. He's 11 had about, I guess, eight or nine years of experience, where 12 I've had close to 38. 13 Q And this is in the same area of police and law 14 enforcement?' P
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15 A (Cohn) His had been in police and federal 16' communication systems. . 17 Q Would you know if -- 18 A (Cohn) Incitiding the FBI and those types of
. 19 systems.
20 Q Would you know if Mr. Didanato had e::perience in 21 radiological emergency planning? 22 A (Cohn) I do not know for a fact. 23 Q You've testified that in preparation of this 24 testimony you or your associate reviewed the SPMC, or parts 25 of the SPMC implementing procedures and, you believe, parts Beritage Reporting Corporation (202) 628-4888 - _ _ _m__m_ __ _ _____._________..m_ _ _ _
COEN - CROSS 26110 1 of the training modules. 2 Can you tell me whether or not you reviewed any 3 additional information prior to your oral testimony today 4 such as the Applicants' Rebuttal Testimony No. 22? 5 A (Cohn) I did review that last night. - 6 Q Would you please tell us the basis of your 7 understanding on page 3 of your testimony where you state 3 that, "Four paired channels limited the radio capability to i 9 four simultaneous conversations."? l l 10 This is in the first paragraph on that page, on 11 page 3. 12 A (Cohn) Okay. l l 13 This is a repeater system. And where the 14 repeaters are in operation, they generally will preclude any 15 other conversations from going on. 16 - It is conceivable that in certain instances where 17 two people are in a portable trying to talk around and they 18 are far enough away that they could talk independently, but 19 it's probably a fairly rare case. 20 Q If you would assume for the purposes of this , 21 question, that the repeaters permitted conversations among l l 22 eight field workers simultaneously, and that communication 23 from an individual to all others with ERN radios on that 24 channel was possible, and also, that there was talk-around 25 capability; would this alter your understanding of the Heritage Reporting Corporation (202) 628-4888
l
. COEN - CROSS 26111 1 capacity of the communication system in the SPMC?
9 2 A (Cohn) No, it would not alter. 3 By the way, the four simultaneous conversations 4 can be between field workers or between a field worker and a . ' 1 5 dispatcher. 6 Q But your understanding of four conversations - 7 taking place, do you take under co.asideration the 8 possibility that one individual can address others on the 9 ERN radios on the same channel? 10 A (Cohn) Of coarse. 11 He can address anybcdy who is on the channel, or 12 all. 13 Q I would like to refer you to page 4 of your 14 testimony, piease. And in the first full paragraph you have 9 15
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a sentence which begins, "During the graded exercise, FEMA 16 noted that some of the route guides who were alerting 17 hearing impaired within the EPZ expressed difficulty in 18 radio communications with the staging area. And further, 19 apparently, in some case, reception was sporadic."
. 20 Can you tell me whether or not the instances of 21 sporadic reception and difficulty in radio communication 22 with the staging area could be attributable to other causes 23 such as equipment problems and not solely to the design of 24 the communication system?
25 A (Cohn) I would guess, in these cases looking at 9 Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26112 1 the terrain and going back on some experience we have had in 2 measurements of a system that we developed for the St. Louis 3 police. The rolling hills, there are shadows in radio 4 coverage due to the hills. We have found that in St. Louis. 5 It can only be rectified by having multiple - 6 transmitters simulcast. So it's just a natural function 7 of -- I guess it's not really the design unless you want to 8 spend a considerable amount of funds trying to fill in these 9 gaps. 10 Q So what you are saying, as I understand it, is 11 that it's not just a design fault. It could be due to the ; 12 topography of the land and perhaps maybe where -- 13 A (Cohn) Well, yes. If it gets severe enough, then 14 it's a design fault because you should take those things
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15 into account. 16 . Q But there are a lot of factors that might 17 influence communication? 18 A (Cohn) Well, generally one puts a reliability 19 factor on there, and this accounts for some holes in 20 reception. . 21 Q On page 5 of your testimony, on the first full 22 paragraph, the second sentence, you state, "Because the ERN
- 23 was not designed to any degree of reliability for coverage 24 beyond the EPZ, the existing ERN system may not provide 25 communication reliably to buses on their way to the EPZ, et l
Heritage Reporting Corporation l (202) 628-4888 1
a . p p COHN -~ CROSS 26113 1 : cetera." 7 k 2, Can you please tell us the basis for your opinion 3 that it's not designed for coverage beyond the EPZ7 4' (Witness' reviews document;)
.5 6
7 8
- r. 9 10 11' 13 13'
.14' 15-g -16 ..
17 18 19
. .20 21 22 23
'24'
=
25 Beritage Reporting Corporation (202) 628-4888 1 m___ _.____.___...--.___________._.__..._______.__.____.____--________._______m _____.___m-__________._______ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - ______
COHN - CROSS 26114 1 THE WITNESS: I believe it's as a result of review 2 of the FEMA Exercise report. 3 BY MS. CHAli: 4 Q Can you make specific reference to a page? 5 A (Cohn) That's what I'm trying to find. - 6 Well, it's between that and Mr. Catapano's 7 testimony indicating that the coverage -- I can't find the 8 exact place -- but the coverage area was based on the 9 location of the repeaters in the town -- was between 15 and 10 20 miles. 11 Q So it was based on the Applicants' testimony? 12 A (Cohn) Yes. 13 The previous sentence, the sentence starting the 14 paragraph was based on the graded exercise.
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15 Q I see. 16 . .But your conclusion about - you're saying that 17 your conclusion about the reliability beyond the EPZ is 18 based on the 15 to 20 mile range? 19 A (Cohn) Right. 20 Q In Mr. Catapano's testimony? . 21 A (Cohn) Yes. 22 And just the general power antenna -- just the 23 power and the antenna heights of the system. ( 24 Oh, I see. 1 Q 25 JUDGE SMITH: Excuse me, finish your answer. Heritage Reporting Corporation (202) 628-4888 l l l l 1
I 1 26115 7- 1 THE WITNESS: (Cohn) Just the antenna heights, s, , 2 powers of the system would collaborate that assumption, yes. 3 JUDGE SMITH: Off the record. 4 (Discussion off the record.) 5 EXAMINATION BY JUDGE COLE 6 JUDGE COLE: Page 9 of your testimony, Mr. Cohn, 7 you have the average message servicing rate, how did you get 8 one over 15? Is that one over the average length of the 9 transmission? 10 THE WITNESS: (Cohn) That's correct. That's how 11 it's defined. , 12 JUDGE COLE: Fine. Thank you. 13 It wasn't clear to me that's what it was, but I (N 14 wanted to maice sure. i, ~
'- 15 Thank you.
16 - JUDGE SMITH: Now, Ms. Chan. 17 l 18 19 20 21 22 23 1 24 . 25
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) . Heritage Reporting Corporation 4d (202) 628-4888
COHN - CROSS 26116 1 CROSS-EXAMINATION (Continued) 2 BY MS. CHAN: 3 Q on page 7 of your testimony under the topic 4 entitled, " Communications Traffic," page 7 and continuing on 5 to page 8, you suggest that a traffic analysis be done to - 6 design the system. 7 Kould you agree that in most cases empirical data, 8 in other words, information derived from the exercise, would 9 be a more accurate reflection of the actual situation than 10 theoretical data for the purposes of system design? 11 A (Cohn) Not necessarily. 12 The empirical data from the exercise is one 13 snapshot. It may not cover all situations. 14 Theoretical data, on the other hand, is just 15 theoretical data. So it probably should be based on a 16 combination of the two. 17 Q But would you agree that information derived from 18 an exercise would be valuable in the design or refinement of" 19 a system? 20 A (Cohn) Certainly. , 21 Q You made some assumptions in your testimony that 22 only four channels were available and that the repeaters 23 would have certain limitations. 24 And you further calculated that t'..: ta channels 25 would be needed to handle the route guide communications; is Heritage Reporting Corporation ' (202) 628-4888
COEN - CROSS 26117 1 that correct? 2 A (Cohn) I said three channels were really 3 insufficient because they would result in a 20 percent 4 blocking probability. I said, over three channels are 5' required.
. 6 Q Did you consider at that time that one or more of i 7 the other three channels could be used to deal with the 8 postulated overflow?
9 A (Cohn) That's exactly why we looked at other 10 channels. If there was only one channel available -- 11 Q But this is the first channel and the fourth 12 channel? 13 A (Cohn) Yes. 14 JUDGE COLE: And that overload assumes 170 calls 15 an hour in an 15 second average length? 16 - THE WITNESS: (Cohn) Yes. Which is a normal way 17 of doing it, not only for public safety systems but for 18 cellular systems except the message length is different. 19 JUDGE COLE: Understood; thank you. , 20 BY MS. CHAN: 21 Q And your assumption of one call an hour was based 22 on your review of the plan and what you thought the needs 23 would be? 24 A (Cohn) No. Thwt is the normal way that one 25 performs a traffic study for the peak hour. Heritage Reporting Corporation (202) 628-4888
COHN - CROSS 26118 1 Q I see. 2 A (Cohn) In fact, in reality there are messages 3 that are longer. There are messages that are shorter. Not 4 all people necessarily talk in the rebuttal testimony, for 5 example, containing the radio information, Attachment E, . 6 page 4 of 11, I just last night read these things without 7 pausing and at a fair rapid rate. And each of these were 35 8 seconds, which would probably result in really about a 45 9 second conversation between the dispatcher and traffic 10 unit-2 with a few minute slaps in between. 11 So that one pair of conversations would result in 12 a 90 second elapse time to this traffic unit No. 2. 13 Q If the SPMC restricted the requirements or even 14 the need for'these route guides to call in or for contact to 15 'be made with route guides once they departed their 16 destination for some other part outside the EPZ, if the 17 number of calls was different from the assumptions that you 18 made in your estimate of one call per hour, wouldn't that 19 substantially change the blocking time? 20 A (Cohn) Ce rtainly. If the length of messages were 21 different, that would change the blocking time, too. 22 But again, this is an emergency situation. It is 23 not comparable to a normal bus situation where earlier the 24 150 unit loading was quoted from the FCC or a taxi situation 25 which has a 150 unit load. Heritage Reporting Corporation (202) 628-4888
i COHN - CROSS 26119 l.
.,s. 1- Q Fine. I believe you've testified to that earlier.
t \ k,I 2 A (Cohn) Yes. l 3 Q Are you aware of the procedure for net control 4 which permits the EOC to interrupt all ERN communications 5 with an' alert tone? A I read about it in the rebuttal testimony, - 6 (Cohn) 7 yes. 8 Q But in the preparation of your testimony you were 9 not aware of that? 10 A (Cohn) I was not necessarily aware. I.can't say 11 whether my associate was. But that can be done in any 12 system. We're aware of other situations where that occurs. 13 Q If you are to assume that the field personnel were 14 aware that once they heard the alert tone they were to
/-~ ~
-/ 15 standby for an important message, do you think this might be 16 a means of interrupting longer conversations on the radio 17 network to interject important messages or emergency 18 information?
19 A (Cohn) Assuming that everyone hears the alert 20 tone, which they may or may not. I'm sure that's the reason 21 that the procedure allows for pauses between conversations. 22 The radio coverage doesn't necessarily cover that. 23 Q So assuming that everyone who had a radio heard 24 the alert tone and was standing by, that additional messages 25 such as, "Please restrict all radio transmissions to Heritage Reporting Corporation 1 (202) 628-4888 .
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i. COHN - CROSS 26120 1 emergency or high priority traffic," that that information 2 could be transmitted? 3 A (Cohn) I would also assume that that's standard 4 operating procedure anyway. 5 Q My last area of inquiry is regarding the roll-call 6 procedure that you describe in your testimony. e 7 A (Cohn) Yes. 8 Q As a suggestion from FEMA. 9 A (Cohn) Right. 10 Q I wanted to find out if the roll-call were to 11 reveal that a route guide din not receive a particular 12 message, what would be the next step? Would it be to 13 rebroadcast the message? 14 A (Cohn) That would be the only way you could do 15 it, and then you wouldn't guarantee that that person 16 received it. 17 Q Wouldn't it be possible to have the confirmation 18 of mescage receipt made at the destination of the rout'e 19 guide, if you weren't sure that he could have received it 20 enroute, wouldn't that be a practical solution? , 21 A (Cohn) I'm sure that would be a practical 22 solution. 1 I 23 I don't think very much of the roll-call 24 procedure, obviously. 25 Q So in your view, you could do without the roll-Heritage Reporti.7 Corporation (202) 626~4888
COHN - CROSS 26121 1 call procedure and just rebroadcast the message and then 2 confirm later when they reach their destination? 3 A (Cohn) Except you run into the difficulty of -- 4 for example, I guess the example used was the potassium 5 iodide, that they might get into an area without knowing 1 6 they should have taken the potassium iodide earlier. 7 Q But aside from any urgency that you, yourself, 8 might attach to the immediacy of taking potassium iodide 9 enroute, you think that a system would be to rebroadcast the 10 message and check to see if it was received when the route 11 guide appeared, would be sufficient? 12 A (Cohn) If it's an all points kind of thing, yes. 13 If it's specific instructions trying to reroute somebody, 14 then you would have to rebroadcast the message until you G 15 have a positive confirmation. 16 . O But the solution would be to rebroadcast, I 17 assume? 18 A (Cohn) Yes, in that case. If you can't get in 19 touch with a particular individual you try again. 20 Q Thank you very much. 21 MS. CHAN: The Staff has no further questions. 22 MR. SMITH: Your Honor, I just have one brief 23 matter. 24 I would like to, at this time, remark and move 25 into evidence Exhibits 86 and 88 and have them bounri into
- O Heritage Reporting (202) 628-4882 Corporation
I COHN - CROSS 26122 1 the transcript. 2 MS. GREER: 86 and 88? 3 MR. SMITH: 86 and 88. 86 I would like pages 20 4 to 23 and the cover page. 5 JUDGE SMITH: Did you say you want to remark it? 6 MR. SMITH: Yes. . 7 JUDGE SMITH: Change its identification? 8 MR. SMITH: Yes, rather than putting in the entire 9 document I want to put in the cover page and pages 20 to 23, 10 rather than clutter the record. 11 JUDGE SMITH: Yes. 12 MR. SMITH: And I would like to put in 88 as well. 13 JUDGE SMITH: And you're not offering 877
- 14 MR. SMITH: That was the CFR.
15 JUDGE SMITH: That's right. 16 - MS. GREER: I'm not sure that 88 -- I'm not clear. 17 JUDGE SMITH: We're going to receive 87 anyway, 18 just for bookkeeping purposes. 19 MR. SMITH: That's fine. . 20 Thank'you, Your Honor. , 21 MS. GREER: I'm not sure that 88 has ever actually 22 been identified by this witness. 23 MR. SMITH: I believe he said he was familiar with 24 the document. 25 MS. GREER: I'm not cure he said he was familiar Heritage Reporting Corporation (202) 626-4888 l
c._-_-- . _ _ _ - _ - _ _ _ _ _ _ - - _ - _ _ _ - _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ - _ _ - _ _ - _ _ _ _ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _- COHN - CROSS 26123
'~1 with the document or familiar with the principles. .He
'2 certainly knew about the development of the. rules.
3- MR. SMITH: He said he'was familiar with the 4 document.
*: J5 .MS. GREER: If we could have this clarification.
l 6 Are you familiar with these two pages that were 7 marked as Exhibit 88? 8 THE WITNESS: (Cohn) The Pike and Fisher 9 document? 10 MR'. SMITH: Yes, exactly. 11 THE WITNESS: .(Cohn) Yes. I did remark, however, 12 that those are comments on proposed rulemaking.and not 13 necessarily what came out in the rules. 14 MR". SMITH: We're putting in the cover page as O 15 well. And we will supply the necessary copies to the 16 reporter. . 17 MS. GREER: Not having the full document here in 18 front of me I would at this" point simply ask that, if these 19 two pages are to go in that the-full document be provided so 20 that we may then offer the full document if it appears to be 21 appropriate. Because I'm not sure what context -- these two q 22 pages taken out of context are in light of the full 23 document; and therefore, I think it's inappropriate to just 24 snatch two pages. 25 MR. SMITH: Your Honor, I'll be gladly give this "i Beritage Reporting Corporation
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COHN - CROSS 26124 1 -- I have the full document and I can provide that now to 2 Ms. Greer. 3 JUDGE SMITH: All right. 4 MS. GREER: And if 86 is going to go in, we would 5 have no objection to 86 going in if the whole document goes - 6 in. 7 MR. SMITH: Why do you want the whole document in? 8 MS. GREER: Because I think if you're going to 9 talk -- you, in fact, made reference to beyond the two pages 10 in that you said, this is, in fact, is the general 11 discussion of telephone communications on -- 12 MR. SMITH: No, I limited it to that section of i 13 the document, 14 MS.' GREER: If those two pages are going in we 15 would object unless the whole document goes in to put in 16 context what these two pages are dealing with. 17 MR. SMITH: If you want the whole document in we 18 have no objection.*It just doesn't seem -- 19 JUDGE SMITH: Well, usually we don't favor putting 20 in large documents. . 21 MS. GREER: These are only going into the record 22 as exhibits, they're not going -- 23 JUDGE SMITH: I understand that. 24 But the mischief that flows from that is that, lo 25 and behold a part of a document is cited in proposed Heritage Reporting Corporation (202) 628-4888 m-- __ _ _ _ _ _ - _
COHN - CROSS 26125 11- findings that never came up in hearing and never were ' /.,_s\
-( f 2 thought to be relevant.
3 I'think more precision is needed in the evidence 4 that is being received. , 5 I mean, there are parts of this document that i 6 would be totally irrelevant and there's no guidelines as to - 7 what part is available for proposed findings. 8 So I'll tell you what you do, you work it out with 9 Mr. Smith as to what parts go in. And since he's willing to 10 put the whole document in and you insist upon the whole 11 document, you certainly should be able to agree on something 12 less than that. We don't want the keyboards in there. We 13 don't want anything that's not relevant. So you can work it
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j- 14 out. t' - 15 MS. GREER: Fine. 16 . JUDGE SMITH: If you can't work it out come back 17 to the Board. 18 MS. GREER: Fine. 19 JUDGE SMITH: So 86 is received as is 87; 88 we 20 will accept in principle but defer ruling on it until you 21 work out the portions to be -- 88 we're talking about now. 22 MR. SMITH: Right. 23 JUDGE SMITH: Until you work out with Ms. Greer as 24 to the portions that go in. 25 MR. SMITH: She wants to take a look at it and I Heritage Reporting Corporation j O' (202) 628-4888 i
COHN - CROSS 26126 1 make sure whether she's want to offer the whole thing. 2 JUDGE SMITH: The Board doesn't want irrelevant 3 aspects of that document and most of it is irrelevant. 4 MR. SMITH: Agreed. 5 JUDGE SMITH: You both agree to have it all in, . 6 but the Board doesn't want it all in. So I want you to 7 agree as to the least that can go in. 8 MR. SMITH: At this point could we admit those two 9 pages and then if Ms. Greer wants to offer -- 10 JUDGE SMITH: All right. 11 Would you object to that? At least that much is 12 done and then you could offer additional pages. 13 'MS. GREER: Fine. 14 JU8GE SMITH: Let's do it that way.
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15 You can offer additional pages under that exhibit 16 number. 17 MS. GREER: Fine.- 18 MR. SMITH: Could we do the same thing with 86 as 19 well, Exhibit 86. 20 MS. GREER: That's what is being done with respect 21 to both. 22 JUDGE SMITH: With both of them. That will be for
- 23 both of them.
24 25 l Heritage Reporting Corporation (202) 628-4888 l l L
COHN - CROSS 26127 1 (The documents referred 9 2 to previously marked for 3 identification as 1 4 Applicants' Exhibits 5 86, 87, 88, were
. 6 received in evidence.)
7 JUDGE SMITH: Redirect? 8 9 10 11 12 13 14 15 ] 16 17 18 19 .
. 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
F-I COHN - REDIRECT 26128 1 MS. GREER: Yes. I have two questions on 2 redirect. 3 REDIRECT EXAMINATION 4 BY MS. GREER: 5 Q Mr. Cohn, during the course of your cross- - 6 examination, you were asked a series of questions on whether 7 route guides or other field workers being trained to pause 8 would allow other people to jump in with priority messages. 9 My question to you is, what impact would the 10 capture effect have on that as a solution for the overload 11 problem in the channel? j 12 A (Cohn) Well, if several people tried to jump in . 13 during the pause, generally the one with the strongest 14 signal at the repeater / receiver location would predominate
'and would capture the system, so to speak.
15 16 . Q How would one determine who had the strongest 17 signal in terms of jumping on to the repeater? 18 A (Cohn) One would not. 19 The system would determine it. 20 Q okay. . 21 How would the system sort that out? What kind of 22 factors would go into who the repeater picked up? 23 A (Cohn) The strength of the signal is determined 24 by the distance, the propagation characteristics of the path 25 between each of the transmitters and the relative powers, Heritage Reporting Corporation (202) 628-4888
i -
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COHN --REDIRECT 26129 s .1 effective radiated powers of each.
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b(s,/ 2 Q Would there be any assurance that somebody
- 3. transmitting let's say from the EOC with a transmitter would 1
4 be able to capture'the repeater as opposed to somebody with 5- a less-powerful transmitter up close? 1; l' ,_ 6 A' (Cohn) The less powerful one'could very well' - 7 . capture the system ~if it were close enough and its received l L .8 power were larger. ll l -9 -Q And would the same . situation also . pertain to an 10 alert tone going out on the channels?
- 11 A (Cohn) Conceivably it could, because that's just
.12 another signal.
13 Q You briefly mentioned that, in response to, I 11 4 believe it was a question from the NRC Staff, about problems 15 with shadows. 16 . When you say " shadows", can you explain for the 17 Board what kind of problem is inherent or can be found in a 18 radio system where there are such shadows? 19 First'of all, what do you mean by shadows? 20 A (Cohn) Dead spots due to blockage from terrain. 21 These are line-of-sight signals. And in slowly rolling 22 terrain you are behind a hill. Essentially a small hill is 23 blocking your line of sight to the transmitter. 24 Q Did you have an opportunity to look at a 25 topographical map of at least a portion of the EPZ? Heritage Reporting Corporation (202) 628-4888 4
COHN - REDIRECT 26130 1 A (Cohn) Yes, I did. 2 Q And are there such rolling hills in the EPZ? 3 A (Cohn) Apparently. At least in the portion I 4 looked at. 5 Q And the town that the repeaters are located in -- - 6 which side of those rolling hills is the' town relative to 7 the constal section of the EPZ? 8 A (Conn) It's to the west. 9 Q And are the hills then between the repeater site 10 and the coastal section of the EPZ? 11 A (Cohn) Correct. 12 Q Now you mentioned, in response to a question posed 13 by Mr. Smith, that you had looked an exhibit to the 14 Applicants' rebuttal testimony in this that included at
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15 1 east portions of training for radio communications. 16 . Did those portions of the training also contain 17 radio rules that field workers are supposed to use? 18 A (Cohn) Yes. I 19 Q Do you think that those radio rules are adequate
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20 to impose the kind of discipline that would be needed in 21 taking care of the channel overload situation? 22 A (Cohn) I can't say that they -- 23 MS. CHAN: Your Honor, the Staff would like to 24 object because the witness said he couldn't find the 25 training information that he referred to, and he didn't have 1 Heritage Reporting Corporation (202) 628-4888
COHN - REDIRECT 26131 s 1 it in his notebook as far as he could tell. x ,, 2 MS. GREER: No , he said he was at least aware that 3 he had looked at portions of the training attached as 4 exhibits to the rebuttal testimony. He said he looked at 5 that last night. 6 MS. CHAN: Right. But he didn't look at anything - 7 not referred to-in the Applicants' testimony. 8 So are you limiting your question to that? 9 MS. GREER: I'm limiting it to the Applicants' 10 testimony last night. 11 MR. SMITH: I would just like to add to that 12 objection a slightly different objection. 13 I believe she is now going beyond the scope of my f-~3 14 initial question.
~ 's - 15 H3. GREER: Mr. Smith asked about --
16 . MR. SMITH: I asked about pauses. I didn't ask 17 about the rest of the procedures. 18 JUDGE SMITH: No. You b:ought up the point that 19 when a channel isn't shared with other owners, don't you 20 have better discipline that will increase the capacity or ~I l I 21 the -- I thought that's -- 22 MR. SMITH: Well, yes, Your Honor. 4 I l 23 Specifically what I was asking at that point was I i 1 24 whether, in general, radio discipline would enable you to j 25 increase the number of users or units you could have on a I I s l ;
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COHN - REDIRECT 26139. 1 particular channel. 2 I do not believe I asked a specific question about 3 our procedures for radio discipline. 4 JUDGE SMITH: Well, then, what was the point of 5 your question? . 6 MR. SMITH: I wanted to establish that with radio 7 discipline you can have a higher number. I did not -- 8 JUDGE SMITH: But it's irrelevant if you don't 9 have radio discipline. 10 MR. SMITH: That's true, Your Honor. 11 JUDGE SMITH: So then why are you are asking 12 irrelevant questions? 13 MR. SMITH: Well, I was going to tie that up in 14 the proposed' findings.
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15 JUDGE SMITH: No, that doesn't work. 16 . Well, you can withdraw it, or permit the 17 examination. 18 You just can't ask generally the question, doesn't 19 discipline help, and then hope that we will infer that you 20 have discipline and go to your benefit, and then keep her 21 from asking whether the radio rules actually provide this 22 discipline. You are asking too much. 23 MR. SMITH: Yes, Your Honor. 24 JUDGE SMITH: So let's leave the record the way it 25 is, and then overrule your objection. Heritage Reporting Corporation (202) 628-4888 1
9 COHN - REDIRECT 26133
~ 1 -MR. SMITH: That's fine.
( BY MS. GREER: 2 3 Q- Okay, you may answer the question. 4 A (Cohn) Okay. 5 'Q If you remember what it is. ,
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6 A (Cohn) I'believe the question was will these 7 rules, the discipline -- maybe we had better repeat the 8 . question just so I understand. 9 Q You'did have a chance to look at the radio rules? 10 A (Cohn) Yes. 11 Q Okay. 12 Will they.take care of the problems that you 13 viewed as being demonstrated in the ERN? (N 14 A (Cohn) Not completely. ( 15 Q Okay. 16 - Why not? . 17 A (Cohn) Because there are still too many units on 18 a channel. The rules, for example, say that always make 19 your radio transmissions as short as possible. Remember, 20 you share the channel with up to 100 other radio units. 21 They share the channel with up to 170 other radio units.
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22 So there are just too many radio units on a 23 channel, on a single channel. 24 JUDGE SMITH: But you are not testifying that 25 those rules do not provide standard discipline.
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i COHN - REDIRECT 26134 1 THE WITNESS: (Cohn) They help, certainly. ! 2 One could go further and use the 10 codes that are 3 used by police and others. 4 . JUDGE SMITH: I don't know where we are going to 5 come out on this anyway, because it's not a quantifiable -
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6 aspect, to what extent discipline increases capacity. 7 THE WITNESS: (Cohn) It is very difficult. 8 JUDGE SMITH: So your testimony, in sum, is 9 there's disciplino there. It helps. But it could be 10 better. 11 THE WITNESS: (Cchn) Yes. 12 JUDGE SMITH: And in your view, you don't think 13 the discipline that you see in those rules is going to 14 compensate for lack of capacity? 15 THE WITNESS: (Cohn) That is correct. It will 16 help, but it will not compensate. . 17 JUDGE SMITH: Now how much more do you have? 18 MS. GREER: I think I've got about two more brief 19 areas which I think in fact may be limited to two questions. 20 JUDGE SMITH: Well, then, we're Joing to have to 21 make some other arrangements. - 22 MS. GREER: Well, it may in fact be as few as two - 23 questions. 24 JUDGE SMITH: See, I thought you only had two 25 questions to begin with. That's what you said. Heritage Reporting Corporation (202) 628-4888
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. 1 MS. GREER: .Well, really, I don't think I have y~,)
And I don't 2 been longer than five or 10 minutes so far.
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sm ) i 3- think I will be going.any longer than five minutes now. 4 JUDGE SMITH: Well, we will have to make another
- 5 arrangement then.
6 MS. GREER: Okay. l 7 JUDGE SMITH: Come back at 1:00. 8 I just can't believe it. Now, you told us what 9 you had. We made the plans for it and everything else. 10 Do you want your witness to come back or can you 11 wind up promptly? 12 MS. GREER: I can wind up promptly. 13 JUDGE SMITH: Go ahead. 14 BY"MS. GP3ER: s_,)
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A 15 In your opinion, is there any difference in terms Q 16 of design function that you would say between designing 17 communications for a police or other public safety 18 organization and designing a radio system, as you understand 19 it, that's going to be used in the SPMC7 20 A- (Cohn) They are both emergency communication 21 systems, although there are some differences. General 22 design guidelines apply, the same general design guidelines 23 apply to both. 24 MS. GREER: Nothing further. 25 JUDGE SMITH: Anything further?
/' Heritage Reporting Corporation I
(202) 628-4888
l 26136 1 MR. SMITH: No, Your Honor. 2 JUDGE SMITH: All right. 3 You are excused. Thank you, Mr. Cohn. 4 THE WITNESS: (Cohn) Thank you. 5 MR. SMITH: Just one housekeeping matter, Your 6 Honor. , 7 We have copies of Applicants' Rebuttal No. 22 and 8 errata to hand out. 9 JUDGE SMITH: All right. 10 And let the record show that you have done that 11 and we're adjourned then until 1:00 p.m., Monday. 12 .(Whereupon, at 11:32 a.m., the hearing was 13 recessed, to resume at 1:00 p.m., Monday, June 19, 14 1989.) 15 16 17 18 19 , 20 . 21 22 23 24 25 l l l Heritage Reporting Corporation (202) 628-4888 e
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June 16, 1989 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) l 50-444-OL
)
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
)
APPLICANTS' CItOSS-EXAMINATION PIAN FO)t TESTIMONY OF STANLEY I. COHN L . Applicants intend to ir. quire into the extent of the witness's preparation and knowledge of the relevant plans, proc $duras and the Graded Exercise. Applicants also intend to inquire into the technical merits of the witness's testimony on communications. In particular, that inquiry will focus on: (1) the witness's statement that the United States Justice Department recommends that the average waiting time to access a channel be 2.5 seconds. (2) the applicability of this 2.5 second number to two-way radio communications. . (3) the witness's calculation of the number of channels necessary to prevent channel overloading.
\ AS3PLit.NB I
i (4) the variability of loading factors based on the type of i . O. Ij two-way radio use. l (5) the witness's knowledge of two-way radio communications for route guides, i.e., the type of use to which the ERN. System will be put. (6) the witness's knowledge of the ERN System configuration. (7) the witness's statement that heavy bus dispatch traffic on the route guide channel caused a delay in transmitting information. Respectfully submitted, N Thoma's G. Dig' nan, Jr. George H. Lewald Kathryn A. Selleck 3 O. , Jeffrey P. Trout Jay Bradford Smith
- Geoffrey C. Cook William L. Parker Ropes & Gray One International Place Boston, MA 02110-2624 (617) 951-7000 e
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NRC STAFF CROSSEXAMINATION PLAN FOR STANLEY I. COIIN REGARDING COMMUNICATION DEFICIENCIES Experience and Qualifications
- 1. Determine extent of witness' experience and training in planned radiological emer-gency response.
- 2. Explore what types of public safety systems the witness has planned, i.e. police, fire, etc.? Determine whether witness agrees that police and fire responses are
. generally a_d hoc responses to a wide range of emergency situations and that a pre-planned evacuation contemplated in a radiological emergency might have different communication needs.
- 3. Detnrmine what documents or other material witnes reviewed in preparation of his e
I written testimony. Did his review include the SPMC, implementing procedures, ! training modules of the NHY ORO Emergency Plan Treining program? l
- 4. Determine whether witness has reviewed any additionalinformation prior to his oral testimony 1.e., any of the documents above and Applicants' Rebuttal Testimony No. 22.
I Testimony S. Determine the basis of his understanding (p. 3) that four paired channels limited radio capability to four simultaneous conversations. If the repeaters permitted conversa-tions among 8 field workers simultancourly and communication, from an individual to all others on the other-ERN radios on that channel, as well as a " talk-around capability, would that alter his understanding of the ERN communication system set forth in the SPMC?
- 6. Explore whether the istances of sporadic reception and difficulty in radio communi-
- cation's with the Staging Area (p.4) could be attributable to other causes such as equipment and not solely on the design of the communication system.
- 7. Explore the basis for witness' opinion on p. 5 that "the EERN was not designed to any degree of reliability for coverage beyond the EPZ."
- 8. Oct:- + c M fx %./ mm-uuug uuu E."O wiou m i equireu w uce the ,,
vngn + n e'^m m unicM ; ;g Oggvu bgj ',;j' M yM
- 9. Determine the nature of the public safety communications system considered by the l U.S. Department of Justice to require a 2.5 second acceptable system access time.
1 .
- 10. If the witness assumed that only 4 channels were available and therepeaters had the limitations he understood them to have and that 3 channels would be needed to handle route guide communications, did he also consider that one or more of the other 3 channels could be used to deal with the postulated overflow?
- 11. Determine whether witness was aware of the procedure for " net control" which
- permits the EOC to interrupt all ERN communications with an alert tone designed to alert field personnel to standby for an important message. Could the message alleviate the waiting time problem the witness describes on p. 9 by restricting radio transmissions to emergency or high priority traffic?
- 12. Concerning the roll call procedure, explore options if roll call were to reveal that a route guide did not receive a particular message. Solution would be to rebroad-cast the message and have confirmation of message receipt made at destination.
h i MASSACHUSETTS ATTORNEY GENERAL'S
'~'T CROSS EXAMINATION PLAN l
1
) FOR
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APPLICANTS' REBUTTAL TESTIMONY MO. 17 (Radiological Monitoring Process) I. Explore witness qualifications and find our what ORO positions they hold, if any. T L Are Mer addo*9 Y more m en ter o'n; rManar er set II. Go through each of the steps in the Monitoring Process to
. show that the Applicants estimate of only 10 seconds for all steps beside the frisk is unrealistically short, especially
- for bad weather conditions. (Board
- This will be a " baby-l step" approach that looks at the small details in the process, each of which adds a few seconds to the time to monitor each individual. Please bear with me.)
Tnese step-by-step questions will also point out the lack of plans, procedures, or training to deal with many situations likely to occur in the normal course of running a diverse population through the trailer. III. Have panel confirm that training modele instructs: move probe at 2-3" per second.
,as IV. Go through the~ frisk process step-by-step, totalling up the ! ) nu.pber of inches of.the body that must be frisked.
w/ V. Point out defect in procedure: Hands not monitored' VI. Re' view the Article frisking process and time. VII. Some questions about the trailer flow path. VIII. Questions about the time it takes to monitor /decon a monitoring station. IX. The monitoring. rate drills at the Graded Exercise and Dress
- Rehearsal.
X. Questions about the performance test of the Aptec probe /Bicon ratemeter to show that it answers the wrong question. XI. Review the Monitoring process for those who are monitored in their vehicles. Point out the problem with the probe going into warm buses from the cold out-of-doors: condensation. . XII. Questions about the Applicants' calculations regarding the expected number of evacuees arriving.
/
- Identify exactly how they determined the percentage of
( the 31,000 beach vehicles to allocate to Massachusetts.
- Explore justification for excluding 50% of beach vehicles from the monitoring load calculation.
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' MASSACHUSETTS ATTORNEY GENERAL'S d CROSS EXAMINATION PLAN-
'N for SUPPLEMENT TO APPLICANTS' REBUTTAL NO. 17 -
(Reception Center Parking) 4 "I . , Questions'regarding the actual availability of the parking spac,e shown on the diagrams. - a' II. Have-panel explain how they calculated the number of cars--that can be, parked in each of the lots. (Spaces available.) What parking lot " rows" would be. created? l
- i. 'III. Questions.to. explore the Applicants' estimates of "f acility stay time," pointing: out again how it was done under unrealistically ideal conditions.
Evacuees would on average spend.much more time at reception centers. l g a i l ..e e. f
. f~S CERTIFICATE i !(J 1
- This is to certify that the attached proceedings before the
. United States Nuclear Regulatory Commission in the matter
.' of:
l Name: Public Service Company of New Hampshire, et al. l (Seabrook Station, Units 1 and 2) Docket No: 50-443-OL 50-444-OL (Off-site Emergency Planning) I' Place: Boston, Massachusetts Date: June 16, 1989 were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear i Regulatory Commission taken stenographically by me and, l l thereafter reduced to typewriting by me or under the
- direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing ,
e proceedings.
/S/ ,
i (Signature typed) : Donna L. Cook Official Reporter Heritage Reporting Corporation O HERITAGE REPORTING CORPORATION (202)628-4888 __ _ -______ ___-_ _ _ _ _ _ _ - .__. . . - _ _ _ - - _}}