ML20245J781
| ML20245J781 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/28/1989 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#389-8869 ASLBP, OL, NUDOCS 8907030161 | |
| Download: ML20245J781 (441) | |
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o UNITED STATES -
V NUCLEAR REGULATORY COMMISSION
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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 O
Pages: 27779 through 20050 Place: Boston, Massachusetts Date: June 28, 1989 Th.Ci o , .
1 HERITAGE REPORTING CORPORATION !
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5 27779 W UNITED STATES' NUCLEAR REGULATORY COMMISSION J;[
2- ' ATOMIC' SAFETY AND LICENSING BOARD 1
J In the Matter.of: )- f
)- Docket Nos. l PUBLIC SERVICE' COMPANY OF ) 50-443-OL' 'j NEW HAMPSHIRE,-et al., ) 50-444-OL
) OFF-SITE EMERGENCY .!
(SEABROOK STATION, UNITS 1 AND 2) ) PLANNING' EVIDENTIARY HEARING l
Wednesday, June 28, 1989 ,
Tax Court Courtroom i Thomas P.'O'Neill, Jr.
Federal Building 10 Causeway Street Boston, Massachusetts The above-entitled matter came on for hearing, pursuant to notice, at 8:32 a.m.
BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN ;
Atomic Safety and Licensing Board l U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JUDGE KENNETH A. McCOLLOM, Member .
Atomic Safety and Licensing Board l c U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JUDGE RICHARD F. COLE, MEMBER i Atomic Safety and Licensing Board i U.S. Nuclear Regulatory Commission Washington, D.C. 20555
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27780 APPEARANCES:
7.-
O For the Acolicants:
THOMAS G. DIGNAN, JR., ESQ.
GEORGE H. LEWALD, ESQ.
KATHRYN A. SELLECK, ESQ.
JAY BRADFORD SMITH, ESQ.
JEFFREY P. TROUT, ESQ.
GEOFFREY C. COOK, ESQ.
WILLIAM L. PARKER, 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 Manacement Acencv:
( l 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
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27781
.) APPEARANCES: (Continued).
" For the' State of New n== shires' l-GEOFFREY M. HUNTINGTON,. ASST. ATTY.. GEN.
State of New Hampshire
-25' Capitol-Street a Concord, New' Hampshire 03301 j For the Seacoast Ar)ti-Pollution Lenaue: , ..
ROBERT =A.:BACKUS, ESQ.
Baokus, Meyer & Solomon 116 Lowell Street P.O. Box 516--
Manchester, New Hampshire '03105 JANE DOUGHTY, Director Seacoast Anti-Pollution League 5 Market' Street Portsmouth, New Hampshire 03801 For the Town of Amesburv:
BARBARA J. SAINT ANDRE, ESQ.
! Kopelman and Paige, P.C.
-.Q , 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 Newburvoort:
BARBARA J. SAINT ANDRE, ESQ.
JANE O'MALLEY, ESQ.
Kope1 man and Paige, P.C.
77 Franklin Street Boston, Massachusetts 02110 Beritage Reporting Corporation b (202) 628-4888
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,,- , APPEARANCES: (Continued)
For the Town of Newbury:
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R. SCOTT HILL-WHILTON, ESQ.
Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street l Newburyport, Massachusetts 01950 ;
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l For the Town of Salisburv:
CHARLES P. GRAHAM, 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 Licensine Board:
- ROBERT R. PIERCE, ESQUIRE Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Heritage Reporting Corporation ;
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- 1E2&X
'g i WITNESSES: DIRECT CROSS REDIRECT RECROSS EXAM Panel No. 19: ,
Anthony M. Callendrello Dennis S. Mileti L' Gary Catapano L .
(prefiled) 27843 ..
by NW.. Smith 27841 by NW. Talbot 27844 by Mr. Traficonte 27936 .
by Mr. Turk 27967 l Colin J. High (prefiled) 27974 'j.-
by Mr. Fierce 27971 !
by Mr. Dignan 27975 by.Mr. Turk 27994 '
by Judge Cole 28004 by Mr. Fierce 28010 by Mr. Dignan 28017 by'Mr. Turk 28036 by Mr. Fierce. 28046 i
EXHIBITS: IDENT. REC. REJ. DESCRIPTION:
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INSERTS:
1 E D. E E PAGE 9l Applicants' Rebuttal Testimony No, 27843 19 (Media Center and Operation of EBS) l Revised Testimony of Dr. Colin J. 27974 High on Behalf of the Massachusetts Attorney General Re: JI-56 l l
(Monitoring Rate)
Estimated Weekend Vehicle Counts and 28027 Peak Population For Beach Areas J.987/1985 O
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s). 2 ' JUDGE SMITH: Good morning.
I ( _j i-3 Is there any preliminary business?
4 MR. TROUT: No, Your Honor.
5 JUDGE SI-IITH: All right.
6 Yesterday Mr. Turk had asked for reconsideration .
7 on our ruling concerning whether vehicle occupancy rates was 8 an issue within any of the contentions. We had previously 9 ruled that it is subsumed and understood to have been a
_10 reasonable evidentiary showing under Contention 21.
11 You now, as I understand it, wanted to bring to 12 our attention the reasons why that ruling should be changed.
13 MR. TROUT: I'm perfectly willing to do that, Your j
s 14 Honor.
~ '/ 15 The other thing we could do is perhaps what I 16 should have done yesterday if I had been more organized, 17 which is start at the beginning of the High testimony and 18 work through to the end, or we can just continue that 19 argument. Let's take that last piece out.
20 The argument that I would make, Your Honor, is a 21 two-fold argument, in response to the two-fold argument that 22 Mass AG made.
23 Their first argument is that vehicle occupancy 24 rates is in Contention 21, and therefore carries over into 25 56. And it's in 21 because in their interrogatory answers
(~%' Heritage Reporting Corporation (k' (202) 628-4888
27786 1 to 21 they refer generally to the High-Adler-Befort 2 testimony in New Hampshire.
3 I just cannot find a general reference to the l 4 testimony as being sufficient to put us on notice that that 5 particular issue is an issue that Mass AG was litigating in 6 this contention.
7 My second argument that' Mass AG made yesterday, 8 the argument that the Board accorded more weight to, which j 9 is that, in figuring out populations in general, vehicle 10 occupancy rate has been a major issue throughout these 11 proceedings.
12 I agree with Your Honor's characterization of 13 that. And that is why I was going to argue and propose 14 findings, and I'm perfectly willing to do'it now, that the 15 2.4 is res judicata.
16 JUDGE SMITH: Well, yes, you have already l 17 prevailed on that.
18 MR. TROUT: Well, it's more than --
I 19 JUDGE SMITH: You want to deal a double blow to 20 the --
21 MR. TROUT: Well, it's not that 2.6 is a cap.
22 That's what I prevailed on. It's 2.4.
23 JUDGE SMITH: Oh, excuse me.
24 All right. l 25 MR. TROUT: 2.4 is res judicata, Your Honor.
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, gj - 1 JUDGE SMITH: However,' are-you asking us now, for k 2 purposes of concentration, to change our ruling that vehicle 3 occupancy rates, whatever they may be, is an appropriate 4 evidentiary showing under Contention 217 5 MR. TROUT: Yes, I am, Your Honor.
6 JUDGE SMITH: At the end of'the day yesterday, I .
7 understood that that's what you were doing.
8 MR. TROUT: Yes, that's right.
I 9 And there are two reasons why Applicants were not
~
10 put on notice through 21 that vehicle occupancy rate was 11 going to be litigated under JI-56, accepting the bridge-12 theory that JI-21 puts us on notice of an issue in JI-56.
13 JUDGE SMITH: Yes.
-14 MR. TROUT: We'll acc'ept that. 'We have problems O 15 with it,-but that's been ruled on and I'm not going reargue 16 that.
17 The two reasons are: The first reason, all they
~
18 gave us was a general cross-reference to Befort, High and I
19 Adler.
I 20 JUDGE SMITH: All right.
21 MR. TROUT: And the second reason is that, even if l 22 we had been sufficiently put on notice that that general 23 cross-reference tags the footnote where they talk about
,24 vehicle occupancy rate, even if it were fair to make that 25 assumption, it still doesn't put us on notice that that's an l 1 Heritage Reporting Corporation (202) 628-4888 l
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- 1 issue they intend to litigate now, because we should presume 2 and we did presume that vehicle occupancy rate was res 3 judicata, j 4 It's res judicata because the Board, in the 5 partial initial decision at Paragraph 8.43, used the 2.4 I l
6 vahicle occupancy rate for its shelter, it's beach l 7 population shelter calculations. l 8 JUDGE SMITH: Simply as a question of subject 1 I
9 matter, you have nothing new to offer the Board with respect 10 to the logic of vehicle occupancy rates being used as a 11 standard for measuring population, and absent res judicata l 12 considerations, would be an appropriate evidentiary showing
- 7. 3 under Contention 21.
14 MR. TROUT: That's co'rrect, Your Honor.
15 JUDGE SMITH: Okay.
16 So now you are applying res judicata two ways.
17 MR. TROUT: That's right, Your Honor.
~
18 JUDGE SMITH: Directly to the testimony saying 19 it's res judicata. You can't litigate it. That's number 20 one.
21 And number two, we could not have been on notice 22 that vehicle occupancy rates were a part of the population 23 contention because vehicle occupancy rates were barred from 24 litigation.
I 25 MR. TROUT: That's exactly right, Your Honor.
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27789 1 JUDGE SMITH: So two uses. ,
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'iN,,/' ,2 MR. TROUT: Yes.
3 JUDGE SMITH: Two uses of that.
4 MR. TURK: One further point if Mr. Trout is 5 finished.
6 MR. TROUT: I am. .
7 MR. TURK: As'I look back in the documentation as 8 to the origin of JI-21, I believe that the origin, at least 9 as demonstrated by the Applicants' listing of contentions, 10 was Mass AG Contention 40 and Town of Newbury Contention 6.
11 And if Mr. Fierce contests that, I would like to 12 hear it now before I continue.
13 MR. FIERCE: The population contention, JI-21.
[N 14 MR. TURK: JI-21.
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\-s') 15 MR. FIERCE: Yes.
- 16 Don't go back to the history. We're not allowed 17 to do that. I
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18 MR. TURK: What's the origin?
19 MR. FIERCE: And it says right in our contentions 20 book, 40 and 6, just as you said --
21 MR. TURK: Did it?
22 Okay.
23 MR. FIERCE: -- that it's the language --
24 MR. TURK: Those two contentions, Your Honor, Mass 25 AG 40 and Town of Newbury 6, only questioned the absence of I 1
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.- 1 population distribution maps.
7 2 JUDGE SMITH: Yes, well --
3 MR. FIERCE: We've been through that before.
4 JUDGE SMITH: See, this is where -- ,
5 MR. TURK: But there is a history that's 6 important, Your Honor, because apparently the new theory 7 stems from a stipulation between the Applicants and Mass AG 1 8 which changed the contention.
9 Initially, all this was was two contentions that l 10 said there were no population distribution maps.
11 Then the Applicants and Mass AG, in February of 12 this year, entered into a stipulation whereby the Applicants !
13 agreed to provide population distribution maps and Mass AG 14 said, all right, now we're chan'ging the contention. And 15 that's where this language came from that says the estimates l 16 of the peak populations were too low.
17 It wasn't in the contention when Your Honor ruled 18 on it.
19 JUDGE SMITH: Okay, but didn't we address this 20 once and resolve it?
21 +
MR. TROUT: Yes. 4 22 Your Honor, let me --
23 JUDGE SMITH: This is very stressful to the Board.
I 24 MR. TURK: I apologize, Your Honor.
25 JUDGE SMITH: Well, when we have resolved an issue !
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V 1 and then it comes back to us without recognition that we
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- 2 have resolved'the issued, we struggle to find a new 3 application for the argument. And if there is none, then 4 it's confounding. -
5 MR. TROUT: Your Honor, I'm not sure that this 6! particular issues has been decided before. But I am .
7 constrained to disagree with Mr. Turk.
8 The language of JI-21 always contained the f
9 language concerning peak populations.-
10 In addition, there was the language about the
.11 absence of population maps. And what the stipulation of
'l 12 February 7th did was it stripped away the part of the 13 contention which said that you didn't have population maps
g 14 and left the language saying th'at the popQ1ations are wrong.
'%- 15 MR. TURK: In light of that, Your Honor, I 16 withdraw my comment.
17 JUDGE SMITH: Oksy.
18 MR. TURK: But I would also argue that there is no 19 fair notice that everything that was litigated previously 20 was suddenly up for litigation again, because the 21 interrogatory answers from Mass AG said, look at our 22 testimony in New Hampshire, and there's a lot of testimony 23 there.
24 JUDGE SMITH: Well, we've already assigned a minor 25 role to the information imparted by interrogatories.
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- 1 MR. TURK: All right.
2 JUDGE SMITH: We have assigned an important role 3 to the recognized fact in this litigation that you count 4 people by counting cars. And any allegation of erroneous j 5 population measurement reasonably carries with it, in this j i
6 particular litigation, the expectation that evidence could l 1
7 be adduced concerning vehicle occupancy rates.
8 MR. TROUT: Yes, Your Honor.
9 JUDGE SMITH: That is the ruling that you would 10 agree in a limited way is what we ruled. Although you may 11 disagree with it, we did rule that.
12 But now you are saying for another reason, 13 however, because you have to disregard vehicle occupancy 14 rates as a reasonable expectati'on for an evidentiary i
15 presentation because everyone ha,d known that that is res 16 judicata, so they must have been talking about something 17 else.
18 MR. TROUT: Yes, Your Honor.
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._x 27793' g 1 JUDGE SMITH: And, in'particular, the 2.4 persons.
2 104. TROUT:- Yes, Your Honor.
- 3. JUDGE SMITH: :What do-you'say'to that?,
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4 It seems like we're just exactly where we were 5 about two p.m. yesterday. afternoon.
6 MR. FIERCE: Yes. .
7 I thought we had been through this before, and I'm 8 happy to do it again, Your Honor.
9 First'of all, the. question I pointed out to in the 10 -interrogatories, and I put it away now, asked us what-11 information, all the facts --
12 JUDGE SMITH: No, no.
13 We're not talking about that.
14 I remember the footnote and all'of that.
15 Is'that it?
16 MR. FIERCE: Yes.
17 JUDGE SMITH: Yes, we're not talking about that.
18- We're talking about another issue.
19 You prevailed yesterday largely on the thou'ght 20 that when you count people, you count cars. I 21 He now says, as we're restated it several times, 22 that was not notice that you count cars, because car 23 counting had already been decided. It's res judicata, 2.4.
24 What do you say to that?
25 It says it two ways.
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i' 1 27794 1 MR. FIERCE: I noted the two ways. They are 2 different.
3 The first, he said we didn't provide sufficient 4 answers in the interrogatories, and I was going to argue 5 that we did.
6 JUDGE SMITH: You don't have to argue that.
7 MR. FIERCE: The second point was that the 2.4 was 8 res judicata based on your decision in New Hampshire.
9 And I don't think that's right for two reasons.
10 First of all, as we went through this yesterday, 11 in the Board's decision about monitoring rates where they 12 looked at the population arriving, the number that was used 13 by the Board was 2.6. And it was based on that, that you 14 ruled that it would be no higher than 2.6; but could 15 conceivable be between 2.4 and 2.6. And I think that's 16 right.
17 There is another section of the PID that Mr. Trout 18 is now referencing. And first of all, I don't think the 19 Board is actually making a finding there. They are just 20 noting what estimates of the beach population are, and it 21 does use the 2.4 figure.
22 But if you had adopted a 2.4 figure, then it would 23 have been inconsistent with the calculations that were done 24 for the monitoring trailer loads, because there would have 25 had to have been some averaging between 2.4 and 2.6, and Heritage Reporting Corporation
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27795 1 that you told you'did not do. You did no averaging.
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i N 2 .So I read that as saying you didn't make a finding 3 about 2.4 as being the number when you were talking about it 4 in the beach population context. You were just noting that 5 estimates had estimated as high as, and went on to make your 6 findings that.the total population number was a particularly -
7 material fact for your ruling on the beach issues.
8 You used-that number in the calculation. But I 9 submit it wasn't meant to have been a finding that that was 10 the number, and the proof is in the pudding when you did the 11 monitoring load calculations. You did not average.
12- So'I still submit that the PID is not going to 13 help Mr.-Trout here. The issue between 2.4 and 2.6 is at g 14 least open at this point.
s 15 JUDGE SMITH: I have to concede I have lost the 16 thread of your argument on why 2.4 is res judicata.
17 At one time yesterday you said our finding of 2.6 18 as the vehicle occupancy rate for measuring population 19 reporting to monitoring -- l 20 MR. TROUT: Was a cap.
21 JUDGE SMITH: Was a cap. I 22 MR. TROUT: Yes, it's certainly not higher than .
23 that.
24 JUDGE SMITH: It's res judicata as to a higher i
25 number, leaving open anything less. ]
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l 1 Now you are saying, in apparent contradiction to 2 your argument yesterday, that 2.4 is indeed the lower 3 number, is indeed res judicata.
4 Now what is missing?
5 MR. TP!/UT: Your Honor, I apologize if I've 6 created the imp roc sion of a contradiction.
7 What I had thought that I had said yesterday and 8 what I meant to say was that, for the purposes of deciding 9 the motion, of resolving the dispute we had yesterday, the 10 Board didn't have to decide right then and there the 2.4 was 11 res judicata, because it could look and see that it had put 12 in the 2.6 cap, and therefore you knew that all this talk 13 about 3.0 and 3.5 was out.
14 JUDGE SMITH: Yes. !
15 MR. TROUT: I had meant, and I thought I had, and 1
16 I apologize --
17 JUDGE SMITH: You may have.
10 MR. TROUT: I apologize if I didn't. i 19 JUDGE SMITH: There were a lot of words passed 20 yesterday.
I 21 MR. TROUT: What I thought I had said was that it 22 was our position that the Board did decide 2.4, did adopt 23 the 2.4 vehicle occupancy rate, but that I was perfectly I 24 content, if necessary --
1 25 JUDGE SMITH: For transients.
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1 lMR.-TROUT: -- to make'that argument in proposed k 2- ' findings.
3' But now that it's come back, and I might as well 4- -make it now.
5 JUDGE SMITH: All right..
6' Now lead us again to where we made a 2.4 vehicle -
7 occupancy rate finding.
8' MR. TROUT: In Paragraph 8.43 of the partial 9 initial decision,.the Board does population calculations.
10 It uses vehicle occupancy rate surveys and counts of 11 projected peak numbers of vehicles.
12- And the vehicle occupancy rate that it uses, I-13 mean it's not stated that it's 2.4, but it is. That's the 14- number there.
O 15 If you crunch those numbers out, and you look !
16 where.the numbers were drawn from, they were drawn from 17 Applicants' shelter testimony and which, in turn, drew from-i 18 Applicants' ETE testimony, and that's the 2.4 number.
19- And to address Mr. Fierce's point of $
20 inconsistency, I don't see there is any inconsistency. The 21- Board, in Part 5 of the partial initial decision, talked 22 about a cap, put the 2.6 cap on, and that was an easy and-23 convenient thing to do because then the Board didn't have to 24 do a calculation that was 2.4 for some and 2.6 for another.
25 JUDGE SMITH: That's right, i
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27798 1 MR. TROUT: It could just do 2.6 across the board.
. That was it.
3 JUDGE SMITH: That's right.
4 MR. TROUT: But in order to decide ETEs and in 5 order to decide beach population for shelter purposes, the 6 Board had to come to grips with what the vehicle occupancy 7 rate was. It did, and it adopted the 2.4. So I don't see a 8 contradiction.
9 JUDGE SMITH: Is it conceded that the numbers in 10 Paragraph 8.3 --
11 JUDGE COLE: 8.43.
12 JUDGE SMITH: 8.43 are derived from a formula 13 using 2.67 14 MR. ISOUT: You mean'2.4, Your Honor.
15 JUDGE COLE: 2.4.
16 JUDGE SMITH: 2.4.
17 It seems to be the case. If you are going to ;
18 challenge that number, now is the time for you to challenge 19 it.
20 MR. FIERCE: Well --
21 JUDGE SMITH: Not the principle involved, but the 22 number. But that does seem to be the case.
23 (The Board confers.,
24 25 1
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,y 1 JUDGE SMITH: All.right.
h 2 What' numbers did you use to arrive at'2.4?
3 MR. TROUT: Where did we get the 2.4 from, Your 4 Honor?
5 JUDGE COLE: Yes.
.6 JUDGE SMITH: Lead us to the conclusion that the .
7 numbers on 8.43 are derived from applying a 2.4 multiplier?
8 MR. TROUT: The vehicle occupancy rate is taken 9 from Applicants' Direct Testimony No. 7 at I believe pages 10 38 and 39.
11 JUDGE COLE: 38 and 39 of what?
12 MR. TROUT: Of Applicants' Direct Testimony No. 7 13 in the New Hampshire proceeding.
/~'Ni 14 The vehicle count that would be' multiplied by that f
15 2.4, I believe is also from that testimony, but I don't have 16 a page cite.
17 MR. LEWALD: Six.
18 MR. TROUT: I'm being reminded that it's in 19 Applicants' Direct Testimony No. 6, but I believe in No. 6 20 it was just cross-referenced from No. 7. I think we've got 21 to find it in No. 7. l l
22 (Counsel confers.) l 23 MR. TROUT: Oh, Your Honor, I'm sorry.
24 JUDGE SMITH: How was it yesterday -- and Mr. Turk ;
25 joined you -- how was it yesterday with rather reasonable l
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27800 1 assurance you said, well, that proves 2.4. And now we're iI 2 sitting here this morning and we don't seem to be able to 3 repeat the arithmetic.
4 Mr. Turk?
5 MR. TURK: I couldn't find the numbers yesterday, 6 Your Honor. I did make the argument that a portion of your 7 PID drew from that testimony, but I didn't have the 8 testimony here in order to make the arithmetic calculations.
9 JUDGE SMITH: The logic is correct if the numbers 10 are right.
11 MR. TROUT: Your Honor, Mr. Callendrello reminds 12 me of how the numbers were arrived at.
13 In Applicants' shelter testimony, Applicants' f 14 Direct No. 6, the numbers which appear in~8.43 are cited.
15 And those are the numbers that the Board adopts. They're in 16 an attachment to Applicants' Direct Testimony No. 6. That 17 testimony does not itself do the calculation.
18 It says that the numbers are derived from the ETE 19 calculations. The ETE calculations have -- the ETE 20 testimony has in it the 2.4 number; and that I just know 21 from memory because I had to look it up before. I know from 22 memory that's at pages 38 and 39 of Applicants' Direct No.
23 7.
24 Where the vehicle count comes from, that's also in 25 Applicants' Direct Testimony No. 7. I'm just not now able Heritage Reporting Corporation
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. j ,ss 1- off the top of my head to tell you where specifically the
(/- 2 vehicle count is. But-that's:where the numbers came from.
3 They came from Applicants' Direct No. 6. The number-itself 4 and the calculation is done in Applicant's' Direct No. 7.
5 MR. FIERCE: Your Honor, I don't think the 6 Applicants want to be bound by this in that way and let me -
7 explain why and I'll be above-board on this.
8 If their argument prevails, then-you have also 9 found that the numbe'r of vehicles for Hampton Beach is 10 23,841.
11 JUDGE COLE: No, that's population and not 12 vehicles.
13 MR. FIERCE: The population on Hampton Beach is
/"'N 14 that.many people. And we can then conclude how many i
15 vehicles are on Hampton Beach.
16 Now, I have another issue that's right in dispute 17 in this High testimony which is the distribution of vehicles 18 of your 31,000 between the Massachusetts beaches and the New 19 Hampshire beaches.
20 Your Honor, I would be more than overjoyed to live 21 with that number. If that's your finding for Hampton Beach, 22 I will tell you that that shifts down --
23 JUDGE SMITH: Well, it is.
24 MR. FIERCE: Of the 31,000 vehicles, many, many 25 more then are going to be down in Massachusetts and I don't
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27802 1 think Applicants want to live with that. j 2 Now if they do I'll subside, because I would Gi J 3 rather have the 23,841 than I would the 2.4.
i 4 MR. DIGNAN: We'll live with it. I 5 MR. TROUT: I'm instructed that we'll live with 6 it, Your Honor. l 7 JUDGE SMITH: Well, we're not bargaining. We're 8 not exchanging people. That's beyond our jurisdiction, 9 ' absolutely.
10 And it's not a question of whether this is a wise 11 or sound finding, but it seems to be the finding. Now 12 that's the only thing we're inquiring into now.
13 Do you agree that this finding was derived from a 14 formula of 2.4? 1 15 MR. FIERCE: I just don't know. I'm not disputing 16 it; I just don't know.
17 I do believe, however, that I would argue with 18 what you're calling the logic of this. I think this was an 19 example and it just says: "Recent estimates were made." And 20 you then show these numbers.
21 In order to get to a conclusion it looks like 22 there's going to be an adequate number of bus resources for 23 transients on the beach.
24 It's a rough calculation. I don't think the Board 25 intended this to be the fine calculation of exactly.
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27803 1 JUDGE SMITH: 23,841 is a rough --
,j(j- I No, that was a number that somebody Am ,/ 2 MR. FIERCE:
3 used as a recent estimate and you just looked to that recent 4 estimate to see whether there was sufficient bus resources..
5 I don't think this was meant to be a finding that that, in l 6 fact, is the number of people on Hampton Beach. .,
7 I think you were using the number, not making a l i
8 specific finding. And if you're telling me you've made a 9 specific finding and the Applicants --
10 JUDGE SMITH: I think what we did is, we just 11 adopted a proposed finding.
12 MR. FIERCE: And if the Applicants say that number 13 comes from their testimony and it's a multiplier of the ,
7 (s 14 number of vehicles observed on Hampton Beach times 2.4, I'm !
\' 15 not disputing that.
I 16 What I guess I am disputing is that you have made 17 a finding here.in this paragraph where it looks like you're 18 just looking at evidence in order to see the bus resources. l 19 JtJDGE SMITH: What finding is it that you're 20 talking about?
21 MR. FIERCE: In 8.43 -- the ultimate finding in 22 8.43 is that bus resources seem to be sufficient for any 23 transients on the beach. That was the focus of that 24 paragraph.
25 And I believe you were looking at evidence that
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27804 1 was available that bore on that question, but you were not
' 1 2 making a specific finding that s are were 23,841 vehicles on 3 Hampton Beach.
4 JUDGE COLE: No, no, that's population and not 5 vehicles.
6 MR. FIERCE: Excuse me, population or the number 7 of vehicles that that would be divided by 2.4.
8 JUDGE COLE: It's just a little under 10,000 9 vehicles.
10 MR. FIERCE: Right.
I 11 JUDGE COLE: Is that on anybody's list?
12 JUDGE SMITH: I think that the paragraph here, the 13 first sentence of that finding quite clearly takes the 14 projected peak number of vehic1'es and multiplies it by a l 15 vehicle occupancy rate which I am told, and it comports with 16 my memory, that for transients it was 2.4.
i 17 We cited the only evidence that I can recall on it 18 that we accepted. There's the product of that vehicle 19 occupancy rate. And in any event, you seem to be willing to 20 accept that figure. And if you accept that figure you have 21 to accept the formula by which it is derived.
22 MR. FIERCE: I don't know where it came from.
23 JUDGE SMITH: I know, but you're given an 24 opportunity ncw to dispute the count. Obviously, that is 25 the result of a multiplier of something, 2. something, and Heritage Reporting Corporation
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. I
- 1 it has now been convincingly explained to_us that it.had to j
'\m / 2 be 2.4 times projected peak vehicle count. I 3 So that will be our ruling.
4 . MR. FIERCE: And that is the number of people in {
l I
5- Hampton 1Ceach as well?
6 JUDGE SMITH: You don't have to worry about thatt 1 l
7 that's what that says.
8 MR. FIERCE: Okay.
9 I didn't read it that way and if you're telling me 10 that's the way to read it, I understand now.
11 JUDGE SMITH: The summer weekend peak population 12 estimates calculated 23,841 and 7398. That's what that 13 says; that's pretty clear.
14 MR. FIERCE: Those nu'bers m are clear. It's just
[~7
/ 15 the sentence when it says: "Recent estimates were made, here 16 is what they show." And I don't see a sentence that I -
17 normally would expect to see in a finding that says: "And ;
18 we adopt those estimates as our finding." ;
1 19 JUDGE SMITH: Okay.
20 That's what is troubling you?
21 MR. FIERCE: That's the only part that is 1 22 troubling me.
23 JUDGE SMITH: Well, we sometimes are sloppy.
24 Sometimes we just say things instead of saying, "we adopt 25 this," sometimes we just say it. l Heritage Reporting Corporation f
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I 27806 1 That's all right. That's a finding.
2 3
4 5 I 6
7
]
8 I 1
9 10 11 12 ,
13 14 l
15 .
16 17 18 ,
19 20 .
21 22 i
23 24 25 ,
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yp 1' ' JUDGE SMITH: So it doesn't really matter whether, .,
~
- s. '2 res judicata;is.directlyl applied-or.res judicata is used to o
~
3 interpret the evidentiary. bounds, it all comes out the same.
4 So.on two bases-then~. .
'5 (Board confers.) ~
i 6 JUDGE SMITH: All right. -
7 MR. FIERCE: Well, the.only other point I would 8 make,.Your Honor, is that those numbers -- 23,841 people in 9 Hampton and 7398:for Seabrook Beach -- are not-consistent.
10 with the numbers that you found for the monitoring trailer
'll load numbers in-the other section Of the PID.
- 12. There is an inconsistency there. Those numbers'do 13 not match.
. k/'~ 14 JUDGE SMITH: How is'your argument today going to V.t 15 differ from that made yesterday at the very end; do you 16 remember? You.said, we just simply disagree, we're going to -
' 1'7 : subside.
'18- I mean, are you making a different argument?-
19 MR. FIERCE: No, that.was on a different point, 20 Your Honor. .
21 JUDGE SMITH: That is what.I say causes stress 22 when we hear the same argument which we resolved, comes back 23 to us as to what you subsided; and here it comes again, if 24 it is. And I just struggle to find out what is different 25 about it.
i l
y Heritage Reporting Corporation l
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I 27808 1 Is there anything different about it? ,
2 MR. FIERCE: As I recall that discussion where we 3 subsided, Your Honor, was on the issue of over 2.6. We just 4 disagreed on the issue of whether we could present 5 additional evidence over 2.6. That there were other 6 studies. We subsided.
7 JUDGE SMITH: What you subsided on was that you 8 could present to raise the average somewhere up to 2.6, you 9 could mix in 3s if you want to.
l 10 MR. FIERCE: No. !
11 That a witness could offer an opinion that it 12 would be higher than 2.4 by pointing to evidence of studies 13 that showed it was higher than 2.6 or 2.8.
l 14 JUDGE SMITH: Right. !
15 And you lost on that. And you subsided. I 16 MR. FIERCE: We just disagreed with you. -
17 JUDGE SMITH: That's right.
18 MR. FIERCE: And we said rule; I'm not sure we 19 subsided.
20 JUDGE SMITH: Well, whatever it is you stopped. j 21 MR. FIERCE: But this is a different point, Your i
22 Honor. .
)l 23 JUDGE SMITH: What is the point now then?
24 MR. FIERCE: This is a point which is, again, you l 25 have made a finding in two separate portions of the PID. ,
I l, Heritage Reporting Corporation N (202) 628-4888
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. 1- lOne, now you're saying you made a finding about qfh ,
2 population.for Hampton Beach. .You.made a finding over in
[:l V j.
L 3 .another'section about monitoring loads'at reception' centers.
.4 The numbers'do not match.- This is a higher number.
J 5' ' People who would be directed to which reception
.6 center.from'Hampton' Beach -- .
'l 7 'MS. DOUGHTY: Manchester.
,8 MR. FIERCE: -
- Manchester.
9' The numbers you have for recipients st Manchester
- 10 .do not match-this number for Hampton Beach. The load.would 11 be higher over'~at Manchester now based on these numbers.
12 And that's why I say, you could'not have made a;
'13 finding that this was the number for Hampton Beach..
14' JUDGE SMITH: Now you're foreclosing just flat out
- 15. error.
16- MR. FIERCE: I am. I'm assuming somehow you meant 17 -- there is'a way to interpret what you did consistently 18 without error.
19 And I submit to.you that the way to do.that is to ;
20 look at this as not a specific finding of the exact number i 21 of vehicles.or people on Hampton Beach, but as a methodology- ;
22 that you used, a reasonable one, to calculate whether, bus 23 resources were sufficient. Because otherwise there would be !
. 24 an error some place. And the error I guess would be in the 15 monitoring load calculations.
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27810 1 1 JUDGE SMITH: I'm sorry, I don't understand your 4 2 argument.
3 MR. FIERCE: Because the number of people, 23,841 ;
4 plus all the other people who were directed to the 1
5 Manchester reception center --
6 JUDGE SMITH: Just stick with that 23,841 for a 7 moment.
8 MR. FIERCE: Yes.
9 JUDGE SMITH: How did we arrive at that again?
10 MR. FIERCE: They' re telling you that it comes 11 from their ETE testimony, apparently their overflights.
12 They saw that many "X" vehicles in Hampton Beach and they 13 have multiplied by 2.4.
14 JUDGE SMITH: And what does the' language clearly 15 say of that finding?
16 I don't have it in front of me -- yes, here it is.
17 What does it say? "Recent estimates of the peak beach 18 population for Hampton and Seabrook were made using the 19 results of the vehicle occupancy rate surveys and counts of 20 projected peak number vehicles."
21 What can be clearer than that sentence?
22 MR. FIERCE: Okay.
23 Take that number,'23,841 --
24 JUDGE SMITH: See, now you're doing what I asked 25 you to do earlier; either 'aspute the arithmetic or subside Heritage Reporting Corporation (202) 628-4888
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27811:
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\ 2 MR. FIERCE: Well, I can't dispute the arithmetic
~
'3 that got to;that number. If they'say it's 2.4 times the
'4 number of vehicles they.saw.on Hampton Beach, I can't. 1 y- ;
5 dispute'that.
6 What I'can do, Your Honor, is I go to Manchester -
- 7. reception center and I see the number of people.
8 MR. TROUT: Allan, remember that we're dealing 9 with 20 percent.
10 MR.-FIERCE: I think that's right.
11 JUDGE SMITH: What did you say, Mr. Trout?
'12 MR.. TROUT: Mr. Fierce is trying to compare the 13 total population in 8.43 to the population given for the
/O '14 . Manchester reception center in '5.25.- 1 i
~
15 -And one difficulty that you would have in making 16 that comparison is that you have to apply 20 percent to the 17 8.43 number to factor them in as a part of the 5.25' number.
18' I don't see the argument that he's making.
19 (Counsel confers.) j 20 MR. FIERCE: Well, I just believe that if you went .
21 -back to your mathematics in the reception center loads and 22 you took the number of vehicles that would be arriving in 23 Manchester and follow your arithmetic through here, I don't 24 think the numbers add up, Your Honor.
5 25 JUDGE SMITH: I'11 tell you what, we'11 rule now.
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1 You come back with written arithmetic using our 2 findings of 2.6 and 2.4 and the numbers there and you 3 demonstrate it from the record and I'm sure that they will 4 cooperate with.you in making the things available. l 5 But there's no use us sitting here talking about i 6 it when you don't give me any numbers or any arithmetic. l 7 MR. FIERCE: I apologize.
i 8 I thought we were done with this issue and moving ;
i 9 on to the next.
10 JUDGE SMITH: That's what I thought, too, until 11 you raised it again.
12 MR. FIERCE: I didn't raise it again. It came 13 from them this morning, Your Honor. They asked you to 14 reconsider.
15 JUDGE SMITH: All right, let's move on.
16 I know. We just ruled on it and then you raised i 17 the argument again, Mr. Fierce. Just now, the most recent 18 exchange is because after our ruling you raised it again, 19 which I deemed to be a motion for reconsideration as to 20 which we have been impatient, but we have indulged the 21 Applicant quite a bit in it in listening to you.
22 Now you come up with the numbers, so we can look 23 at the arithmetic on a piece of paper and we will 24 reconsider.
25 All right, the next one is the 40 percent?
- Heritage Reporting Corporation (202) 628-4888
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- 1 MR. TROUT: Well, Your Honor, I took the
~ (_,/ . 2 opportunity last evening to go back and review the testimony 3 of Dr. High as it was. revised. It has been revised from 4 June 21st to June 27th and there's some substantive changes 5 in it.
I 6 And also, frankly, I had an opportunity to .l 7 organize myself a little better than just coming in here and l 8 arguing the motion on the fly, the way I was going to have 9 to yesterday. !
10 The testimony as Your Honors notice breaks out I 11 into parts. The first part leads up to the calculation 12 which is in answer 6. And that has some subparts to it.
13 The second part is the part we've disposed of, gg 14 answer 7, which had two subparts. It had~the challenge to
\-- 15 ,the 20 percent and then had the challenge to the 2.4 vehicle !
16 occupancy rate. We have disposed of those two parts.
i 17 We go back to the earlier portion of the testimony 18 which leads up to the calculation. I have four problems. I 19 had identified two of them yesterday. l l
20 JUDGE SMITH: Yes.
21 MR. TROUT: I have identified four problems with 22 the calculation.
23 JUDGE SMITH: Right, i 24 MR. TROUT: Four reasons why I think that whole 25 portion leading up to answer 6, and the numbers in answer 6 I
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1 should be thrown out. ,
t 2 I'll give you what the four problems are and then 1
3 we can argue them one-by-one. l 4 JUDGE SMITH: That's where we were yesterday 5 afternoon.
6 MR. TROUT: All right.
7 JUDGE SMITH: We have town clerk data; 40 percent !
8 assumption of the cars in Massachusetts.
9 MR. TROUT: Right.
10 JUDGE SMITH: Vehicle occupancy rates; and the 20 11 percent assumption.
12 MR. TROUT: Okay. ;
13 JUDGE SMITH: We have disposed of two of those 14 four; right? i 15 MR. TROUT: Yes, that's right.
16 JUDGE SMITH: Two of the four.
17 Now we have left town clerk data and 40 percent 18 cars in Massachusetts.
19 MR. TROUT: Those are two of the four problems I 20 have with the calculation. I found two more than I had last 21 night.
22 JUDGE SMITH: You have a couple more now?
23 MR. TROUT: I'm afraid I do; yes, Your Honor.
24 One of them is just the result of the addition 25 that was made to the testimony yesterday.
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,rw 1, JUDGE SMITH: All right.
~
's_/
2 MR. TROUT: And the other one is the one I should ,
3 have mentioned yesterday because it was in the June 21st 4' draft and I just didn't break it out. I was thinking of it 5 as being part of the 40 percent split; but I didn't break it 6 out. .l 7 JUDGE SMITH: Okay.
8 MR. TROUT: So those are the 93 percent versus 50 9 percent for beach transients. ,
)
10 And the fourth one is the inclusion of employees 11 in the transients category.
12 JUDGE SMITH: Point to a page number here. .
13 MR. TROUT: All right.
14 I have broken it out by pages, Your Honor.
(}
' 15 My four problems are: the town clerk data, that's !
16 - at the bottom of page 4. I i
17 The 40 percent beach vehicles, that's page 5 from 18 the middie to the bottom. 1 l
19 The 93 percent versus 50 percent --
i 20 JUDGE SMITH: Now, this is the one that I want to 21 pause at because I don't understand that.
. 22 Where is that?
23 MR. TROUT: In Applicants --
24 JUDGE SMITH: In the first place, what are you 25 talking about?-
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, 1 MR. TROUT: All right.
7 2 If you recall the last time that Dr. High's 3 testimony was considered we had some very dramatic arguments 4 from Mass AG to the effect that we weren't applying 20 5 percent, we were applying 8.5 percent. And the way they 6 arrived at that 8.5 percent was, they said, you're not at he 7 peak of the peaks. This was the peak of the peaks fight.
I 8 JUDGE SMITH: Yes.
9 MR. TROUT: So you're not at the peak of the 10 peaks, you're at the reasonably expectable peak. And then 11 you're only looking at half of the beach transients.
12 13 l l
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2 are,even;taking'the reasonable expectable peak, that's the
.3 issue'of 93 percent versus 50 percent: .how many,of.the 4 beach transients do you put into the calculation. That's at 5 the top.of page 6.
.6' The fourth issue is in the middle of page 6, and -
7 it's'also.on worksheet two. This is the one that got added 8 yesterday and I didn't see until last night. And that's the
.9 inclusion of the addition of several thousand employees-to
'10 the transient category. That's page 6, middle, and the 11 numbers on worksheet two, the second page of Attachment A or l
' il2 -B. Attachment A, page 2 of Attachment A.
13 Those are the issues, Your Honor, and I'm willing 14 to take them up in turn, becaus'e unfortunately the arguments
'I
' 15- .are going to differ from one to the next.
16' JUDGE SMITH: Well, let's start with those that we 17 already have some familarity with. Let's start with your i
18 town clerk data. i i
19 MR. TROUT: I have a single argument on that, Your 20 Honor. It's a very simple argument. .
21 Mass AG filed testimony April 10th. They filed 22 testimony relying on the Luloff population data and the 23 Luloff methodology which was res judicata. When that was 24 ruled upon, the Board stated that it was res judicata and L 25 threw out the testimony.
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27818 1 Mass AG said, well, they were going to come back.
2 They didn't think that all of -- that just because part of 3 High was res judicata, that all of High was res judicata, 4 and that they were going to come back with the parts of the 5 April 10th filing which could be salvaged even under the I
6 Board's ruling on the April 10th testimony.
7 So what they were supposed to be coming back with, 8 whether Applicants were going to agree that it would be 9 filed or not, what they were supposed to be coming back with 10 was the same testimony with the objectionable materials l 11 removed.
12 Well, they've come back instead with a whole new 13 piece of testimony. They have said the Board has thrown out 14 Luloff. All right, well, we'll'put something in place of 15 Luloff. -
16 MR. FIERCE: Town clerk data.
17 MR. TROUT: Yes, Your Honor, that's right.
18 It's not something that was in the original April l 1
19 10th testimony. It's something new that they have put in 1
20 after the Board's ruling.
21 My argument is a simple one. They have one ,
22 opportunity to file testimony on point. They decided that )l 23 they wanted to litigate something that was --
1 24 MR. FIERCE: Oh, come on. )
1 25 MR. TROUT: They wanted to litigate an input that Heritage Reporting Corporation N- (202) 628-4888
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, .,A-( 1 was res judicata. That was their election. This testimony 2 -was struck as a result of that, j
3 To come back now and say,.oh, well, we were wrong, 4 and so we will redo it, we'll come in with a new input. I !
5 just think it's too late. I don't think it's within the 6 rubric that this testimony was supposed to be offered.. -
7 JUDGE SMITH: You mean originally?
8 MR. TROUT: When the Board excluded this testimony
'9 originally, Mr. Fierce explained that he didn't think that I
10 all.of the testimony should be thrown out just because two 11 inputs to the calculation were wrong. And he was going to 1
12 come back with the portions of the testimony that he thought 13 -should survive.
s 14 He hasn't done that. He's.come'back with the i
15 .whole' testimony, the entire testimony redone.
16 JUDGE SMITH: You began a statement that began 17 "within the rubric of what"? .
1 18 MR. TROUT: I' m sorry. j l
19 Within the rubric of what Mass AG said it was !
I 20 going to reoffer this testimony.
t i
21 JUDGE SMITH: They were going to come back. )
i 22 MR. TROUT: And as I said, Your Honor, it's a very ;
23 simple argument. They have no entitlement to a second i
1 24 chance on this, this late in the game.
25 JUDGE SMITH: Mr. Fierce.
i i
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- 1 27820 1 MR. FIERCE: Your Honor, I'm half inclined to move j 2 that you reconsider your ruling on the town clerk data based 3 on the cross-examination we heard from Applicants' Panel 4 last week. What they are going to do in the ETE updates is I 5 not use town clerk data. They are going to have Mr.
-6 Lieberman go and he's going to go to the State of 7 Massachusetts and gather some population data, and make some ;
8 projections, almost exactly what Dr. Luloff was doing. ,
9 They don't seem bound by your town clerk data 10 ruling. They are the ones that had moved in this proceeding l
11 that town clerk data was res judicata, and they are not even i 12 using it themselves. j 13 But all we have done, Your Honor, is substitute l
14 for those portions of a calculations --
i 15 JUDGE SMITH: But they say you are not allowed to 1
16 substitute, so go to that argument.
17 MR. FIERCE: All we have done is substitute.
l 18 Why aren't we allowed to substitute, Your Honor?
19 JUDGE SMITH: He says it's late.
20 MR. FIERCE: It's testimony that was filed 21 properly on time.
22 JUDGE SMITH: Well, what are the standards? What 23 are the rules that we should apply?
24 What guidance is there? You know, just the mood 25 we are in this morning, or what orders did we issue that Heritage Reporting Corporation l
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,j g 1 this. comports with or doesn't comply with?
\~- 2 MR. TROUT: Your Honor, frankly, I'm unaware of I 3 standards, i i
4 MR. TURK: I think Your Honor is looking for-the !
l 5 scheduling order wherein you said direct testimony should be 6- filed by some date in April. -
7 And in fact this part of the testimony, as I 8 understand Mr. Trout's argument, is that it's new testimony 9 'and not previously filed in April, but a whole new theory of )
1 10 testimony.
11 MR. FIERCE: . Ninety-eight percent of this is the 12 same, l d
13 JUDGE SMITH: Is this substitution of the town
<[N. 14 clerk derived data placing in there functionally the same as ]
' 15 the Luloff data? 1 16 Is it functionally the same? ]
17 MR. FIERCE: Exactly.
18 JUDGE SMITH: Exactly the same?
19 MR. FIERCE: It was a calculation. This whole l 20 piece of testimony explains a calculation that Dr. High has 21 done. In his calculation, he took out the Luloff data i
22 number and stuck in the town clerk' data.
23 JUDGE SMITH: And we had previously ruled that l l
l 24 everything failed because of Luloff, and now you took out 25 the only fatality.
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1 MR. FIERCE: No. l
/ j 2 JUDGE SMITH: Well. l 3 MR. FIERCE: There were two, there were two 14 issues.
5 The other was the peak of the peaks issues. ,
6 JUDGE SMITH: Yes, right.
7 MR. FIERCE: He took out the number that he was 8 using in his calculation and stuck in the reasonable 9 expectable peak, 31,000 vehicles. .
l 10 But the calculation results -- what we have here 1 1
11 is one of the very important issues in this case, the 12 monitoring load calculations. He wants to show you what 13 those calculations are with respect to all the other issues i 14 that are out there. Permanent' resident population, town 15 clerk data is now there, and the 31,000 vehicles are now ]
l' 16 there.
1 17 But the rest of his calculation is the same, Your ]
18 Honor. He's attached the worksheets. Mr. Trout wanted to l l
19 see the worksheets so that you can see the whole 20 calculation. All those other assumptions that he had made ,
1 21 are there, the same.
22 JUDGE SMITH: The argument is made that Mr. Turk 23 makes that it's all late because that testimony should have 24 been presented. You should have anticipated res judicata.
25 You should have anticipated these matters'. You didn't. It Heritage Reporting Corporation
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gs c1= . was. carved out. And now-you can't come-back.
E!j
u 2 And you're saying --
3' MR. FIERCE: Well, 98 percent of it's the aame.
'4 JUDGE-. SMITH: ' -- all'we are doing is comporting,
-5 we' re comporting to the Board's ' evidentiary rule.
6 MR. FIERCE:. Exactly. .
i '
7 And that 98 percent of the testimony is the same. .
8 It was timely filed. .There is a calculation that has 'l I
9 implicit in it a number of other items, and none of those 10 had been stricken from the testimony.
11 Your Honor' asked me what I wanted to do. And I 12- said it is not going to be meaningful, the testimony is not 13 ' going to be meaningful because you.have struck these two 14 items in the calculation.
.x 15 You didn't give me permission, but I. asked whether ,
1 16 we could come back, substitute in those two numbers, and.
17 show you'the rest of the calculation,-because-the rest of-18 the calculation is important.
19 They are doing things in their calculation that 20 are not right. Dr. High would like to show you how a proper 21 calculation would be done for monitoring loads. I 22 MR. TROUT: Your Honor, I agree with Mr. Turk that 23 the issue is lateness, and I had hoped that that was what I 24 had articulated. The Mass AG should have, if they were 25 going to rely on town clerk data, they should have done it
)
l F Heritage Reporting Corporation ok- (202) 628-4888 1
27824 1 in their April 10th testimony. ,
2 MR. FIERCE: Boy, I sure don't understand that one 3 since they're still using --
4 MR. TROUT: But Mr. Fierce's argument now, the 5 argument I believe I hear Mass AG making, is that they need 6 the town clerk data now in order to preserve the rest of the 7 testimony, i
8 Well, I have two responses to that.
9 First of all, I'm objecting to all of it. So you 10 can't leave --
11 JUDGE SMITH: Did you then?
12 MR. TROUT: Yes.
13 I objected to all it. It was all struck.
14 I'm objecting to all 'of it now. And Mr. Fierce's 15 argument is you should leave the town clerk data because you 16 need it to save the rest of it. So there is my first 17 response, that I'm objecting to all of it. So that argument 18 shouldn't be accorded much weight.
19 But even if we assume that other parts -- l 20 JUDGE SMITH: I think you are begging the argument 21 there.
22 MR. TROUT: No, I'm not, Your Honor, because I can 23 go right to the heart of it.
24 The only reason you would need the town clerk data 25 is if you want the final results. If Mr. Fierce persuades Heritage Reporting Corporation
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27825 fs 1 the Board that one of more of these other three problems ,
(s / 2 that I have with Dr. High's testimony, that I'm wrong and f i
3 that part of the testimony should stay in, that portion, 4 - that analytical portion where he says how he doesn't the 5 calculation survives. That gets into the record. And
. J 6 you've got that. You've got the issue to be resolved by the .l r
7 Board in the findings.
8 The only thing that you lose, if you knock out 9 pieces but not all of this portion of Dr. High's testimony, 10 is the numbers at the end. The numbers in Answer 6 will no 11 longer -- you will no longer be able to use his end result 12 numbers because some of the inputs will have been knocked 13 out.
14 You don't need the end result numbers, Your Honor,
/}
-- 15 in order to set up the factual challenge which Mr. Fierce b
16 wants to set up in this testimony. You just don't need it. -
17 MR. FIERCE: Well, let's start with town clerk 18 data, Your Honor.
i 19 MR. TROUT: So I don't think any weight should be l
20 accorded to the argument that -- 1 21 JUDGE SMITH: Well, we will have to stop.
22 MR. FIERCE: All right. .
23 JUDGE SMITH: I can't resolve this. I just can't 24 do it. 1 1
1 25 Fifteen-minute break.
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27826 1 (Whereupon, a recess was taken.) ,
7 2 JUDGE SMITH: The issue pending before we took the 1
3 break was whether Dr. High should be permitted to put town 4 clerk data in as a substitute for the data that was ruled 5 res judicata.
l 6 The argument put before us is that it was late.
7 You were going to give us some advice on it, Mr.
8 Turk, and I told you that we wanted -- I ruled you out j 9 because Dr. High's testimony is very thought intensive, has 10 a lot of numbers which are difficult for me to understand.
11 And I wanted to see if I could get on top of it and 12 understand it a little better.
13 I do a part at a time. But you're throwing 14 information at the Tsoard, and m'e in particular, faster than 15 I can assimilate it. Faster than I can bring it into focus; 16 it's too much. -
17 The schedule that we had hoped to make this week 18 cannot possibly be met. The burdens are more than the Board 19 can absorb. We'll just take it a part at a time as we go 20 along and make the best judgment we can and forget the j l
21 schedule. l l
22 Now what were you going to inform.us?
23 MR. TURK: I would like to hold the schedule, Your .
24 Honor.
25 JUDGE SMITH: You can't do it. We'll just take it I
Heritage Reporting Corporation (202) 628-4888 G
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l 27827 1 and do it right.
2 MR. TURK: The only thing I was going to mention 3 is that if we compare the April 10th testimony with the new 4 testimony it's my belief that this is a whole new number 5 generation that he has done. He may be using his sate 6 formula.
7 JUDGE SMITH: Okay.
8 That's your belief; then we are just going to 9 have to take a lot of time, go back to our chambers and 10 compare the two pieces of testimony. And it's very 11 difficult. We have not had the opportunity to get on top of 12 this testimony as well as the parties have.
13 If that, you think, is the proper ruling, that may 14 very well be the case. This te~stimony has lots of numbers; 15 lots of opportunities to go zinging off with a 16 misimpression.
17 I mean, I'm reading it right now. I'm reading it 18 right now on page 6 and this isn't light reading. This 19 isn't like the comics; this is heavy reading.
20 So I don't think that that's practical. Let's 21 take it up a piece at a time.
22 With respect to the lateness, we can't decide. We 23 have no standards that we feel are applicable. Therefore 24 we're going to go to a default ruling and leave it in.
25 All right, the next one.
-9 Heritage Reporting Corporation (202) 628-4888
o _ _ _ _ _ _ _
27828 1 MR. TROUT: The next --
/
2 JUDGE COLE: Could you speak up, Mr. Trout.
3 MR. TROUT: I'm sorry, Your Honor.
4 The next problem that I have with the calculation 5 is on page 5 from the middle to the bottom where Dr. High.
6 says that you take 40 percent of the 31,000 beach vehicles 7 and you put them in Massachusetts. That was in the original 8 testimony, the April 10th testimony; I'm not arguing that 9 that's late. That is precisely the sort of thing that I 10 thought Mr. Fierce was going to come back in with after 11 April 10th, trying to save something that wasn't struck out 12 as res judicata.
13 I have one argument relating to the 40 percent and 14 that is the argument that it's'just not within the scope of 15 the contention. Remember, the Contention is JI --
16 JUDGE SMITH: Wait a minute.
17 Did you make that before?
18 MR. TROUT: No, I didn't have to, Your Honor, 19 because we threw the whole thing out.
20 JUDGE SMITH: Threw it out, okay.
21 Go ahead. j 1
22 MR. TROUT: I didn't have to cut it this fine. l l
4 23 JUDGE SMITH: Go back to the contentions.
24 MR. TROUT: All right.
25 JI-56 is the monitoring contention. As we've Heritage Reporting Corporation
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-- 1- already' discussed the.moni,toring contention does not-
[
2 expressly challenge population; it just challenges rate.
3 The Board has ruled that because JI-21 challenges
'4 the population you can factor JI-21 into JI-561-that's the 5' bridge discussion we had yesterday and today.
6 Taking the bridge as a given, Your Honor, JI-21 .
.7 itself doesn't put' Applicants on any' notice that Mass AG was-8- going to come in' April 10th with testimony saying that 40 9 percent -- that there is an issue about how'you split-out 11 0 the 31,000 cars. We were not put on_ notice by JI-21 of 11 that.
12 And therefore, even with the bridge from JI-21 to 13 .JI-56 --
/N 14 JUDGE SMITH: This is'the same pattern, same 15 argument; why is that not just an ordinary evidentiary 16 showing well within the scope of a population contention?
17 MR. TROUT: Because it's not in the interrogatory 18 answers, Your Honor, 19 JUDGE SMITH: ' All right.
'20 It goes to the interrogatories.
21 MR. TROUT: Yes.
22 And it's just not there.
23 JUDGE SMITH: What question was asked?
24 MR. TROUT: We had three questions, Your Honor.
1 25 JUDGE COLE: Could you speak up, Mr. Trout.
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27830 1 MR. TROUT: I'm sorry.
2 We had three questions under JI-21. The first i
3 question is number 159, it has to do with permanent resident 4 population; that's not relevant.
5 The second question is number 161. It says:
6 "Please state all the facts, estimates, and observations 7 underlying Interveners' assertion that the peak population 8 totals for both summer midweek and summer weekend are 9 significantly too low and define significantly."
10 JUDGE COLE: But that doesn't say about the 11 breakdown between Massachusetts and New Hampshire.
12 MR. TROUT: That's right, Your Honor.
13 I didn't ask the question specifically: what do 14 you contend is the breakdown? Because, of course, I didn't 15 know the issue was in their mind. It's not in the 16 contention. And so I asked: what are all the facts in 17 question. !
18 (Board confers.)
19 MR. TROUT: And then number 161 is: "What do 20 Interveners assert are the correct figures?"
21 JUDGE SMITH: What's the answer?
22 . MR . TROUT: All right.
23 The answer to 161: "What are the correct figures?"
24 "We don't know."
25 The answer to number 160 --
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1 MR. FIERCE: That's not the entire answer, Mr.
2 Trout.
3 MR. TROUT: All right, you're right.
4 "The most recent population calculation were those 5 set forth in Mass AG's NHRERP testimony."
6 MR. FIERCE: Which was the calculation that used .
7 Mass AG's aerial photo data which had a different 8 distribution of the cars on the beaches than the AVIS data; l
I 9 and therein is the answer.
i 10 I mean, you saw what we were doing with our 1 11 calculations; we were using a different ratio in those 12 calculations referenced right there.
13 You also saw in the testimony of Drs. Befort, 14 High, and Adler -
15 MR. TROUT: That's under 160; yes.
16 MR. FIERCE: -- that there was set forth town-by-17 town. Maybe Plum Island was grouped together with the Towns 18 on Plum Island. But at least beach-by-beach the number of 19 vehicles that were observed in that data.
20 Again, the ratios beach-by-bench were different 21 than the Applicants had shown in their photos.
22 This is not an issue the Board ever had to reach.
23 The Board did not reach. The Board looked at, you know, you 24 were focusing on New Hampshire issues.
25 JUDGE SMITH: This isn't res judicata.
\9. Heritage Reporting (202) 628-4888 Corporation
V 27832 1- MR. FIERCE: No.
2 JUDGE SMITH: So you're saying the simple 3 reference to your NHRERP testimony should have done it for t 4 them; they should have known.
5 MR. FIERCE: Absolutely.
6 MR. TROUT: My only retort to that would be, Your 7 Honor, that Mr. Fierce has just pointed out that the 8 distribution was not -- while the distribution was there it 9 was not an issue upon which anybody focused in New I
10 Hampshire. And so it didn't put us on notice. It's not 11 like occupancy rate where there was a lot of shooting about 12 that.
13 JUDGE SMITH: We've seen a series of replies, 14 blanket references to previous' testimony which do not seem ;
15 to be designed to inform, but seem to be designed to comply 16 with discovery rules. So we're not real happy about that.
17 On the other hand, they were answers to 18 interrogatories. You didn't move to compel more specific 19 answers.
20 MR. TROUT: Actually, on that one we did, Your 21 Honor.
22 JUDGE SMITH: You did. Okay.
23 Here we go; what did we rule on.that?
i 24 MR. TROUT: We moved to compel on that one -- l 25 JUDGE SMITH: Can you just go the whole way this Heritage Reporting Corporation
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L 2 MR. TROUT: :I'm sorry.
3 We moved to compel on-160 because the answer was:
4 the facts available to us include the testimony of Befort, ;
5 High, and Adler. And we weren't very happy with the word.
6 " include," as-Your Honor may remember. And so we moved to .
- 1 7- compel and the answer we got back to that'and all the other j t
4 l 8 ones that said " include" was, those are all the facts we i
1:
9 have.- Sk) we got no more specificity out of that. ;
10 And we didn't come in with yet another motion to 11 compel-after that.
12 JUDGE SMITH:. Because we probably would have been 13 impatient with you, if you had.-
14 MR. TROUT: I think that's a fairly safe guess, 0 15 yes.
16 MR. TRAFICONTE: Let me just comment on that since 17 I handled --
18 MR. TROUT: I'm not asking the Board to take that 19 into consideration. j i
20 MR. DIGNAN: You stay out.of it and I'll stay out 21 of it, and we'll- all get out of here.
22 MR.:TRAFICONTE: No , no, we're not bound somehow i
23 at the head. l 1
24 (Laughter) 25 MR. TRAFICONTE: The motion that you brought, just i
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( 27834 1 so it's clear, you did press us on the word " include."
2 MR. TROUT: Right. ,
3 MR. TRAFICONTE: As to what that word meant and 4 whether we were hedging.
5 MR. TROUT: Yes. j 1
6 MR. TRAFICONTE: But you didn't press us, for ]
7 example, "what do you mean, Mass'AG, when you refer to the 8 testimony.of Drs. Befort, High, and Adler in the New l
9 Hampshire RERP proceedings? What testimony are you 10 referring to and what specificity do you intend to refer to 11 it?"
12 MR. TROUT: That's not what he said, he brought 13 nothing but that " include" motion.
14 MR. TRAFICONTE: I ju'st wanted to make sure -- it 15 was a technical --
16 JUDGE McCOLLOM: Move up to the front.
17 MR. TRAFICONTE: -- motion to press on the word
'18 " include." It wasn't: what are you referring to.
19 MR. TROUT: Move to compel on 120 interrogatories, 20 and now you're telling me I should have moved to compel on 21 more. Well, maybe I should have. Maybe we would still be 22 fighting discovery.
23 JUDGE SMITH: We're going to let it in. It's 24 appropriate evidentiary presentation within the contention.
25 The discovery dispute doesn't help us one way or the other.
Heritage Reporting Corporation N (202) 628-4888
i 27835 1 MR. TROUT: All right.
l 2 MR. TURK: Your Honor, I would like to ask a '
3 question.
1 4 During the New Hampshire hearings there was quite i 1
5 a bit of testimony put on by Applicants and I believe there 6 are some by NRC Staff accepting Appl 3 cants' numbers; I .
7 assume all of that is available for findings again?
8 JUDGE SMITH: Yes.
9 We've previously ruled that.
10 MR. TURK: What I'm trying at this phase, if 11 there's a need for other parties now to file surrebuttal to 12 the High piece?
13 JUDGE SMITH: I don't know.
14 As we've seen in this' proceeding, as I stated, we 15 counted well over 700 discreet issues in this phase of the 16 proceeding. And it is quite possible, as we've seen now, to 17 overload the hearing system. And that's what's happening.
18 MR. TURK: Mr. Traficonte is smiling.
19 JUDGE SMITH: The system is being overloaded.
20 MR. TRAFICONTE: Mr. Traficonte is not smiling 21 unless this is a smile. This is a normal -- Mr. Lewald is 22 laughing.
23 (Laughter) 24 MR. LEWALD: Laughing at your observation that you 25 weren't smiling.
Heritage Reporting Corporation u (202) 628-4888
27836 1 (Laughter) 2 JUDGE COLE: Now you're smiling.
3 MR. TRAFICONTE: That's too subtle for me.
4 JUDGE SMITH: There is no question about it, the 5 Massachusetts Attorney General has overloaded the hearing 6 process. You have the Commission's rules of practice by 7 coming -- would you be quiet please.
8 MR. TROUT: I'm sorry, Your Honor.
9 JUDGE SMITH: You have taken the Commission's 10 rules of practice and by coming up with every conceivable 11 contention you could find and putting them into the mix.
12 And by having a police in discovery of telling as little as 13 you can give and getting away with it, you have successfully
, 14 within your rights overloaded the system.
15 If that was your intention you succeeded and you 16 will get away with it.
17 MR. TRAFICONTE: I just want to respond very 18 briefly, it's going to be a long day, I just want to respond 19 to one point and that is, we did not have a conscious 20 strategy to respond to discovery with as little information 21 as we could.
22 JUDGE SMITH: Oh, I think you did. I think you 23 did. I've seen enough. I have to decide either that you're 24 incompetent, and I know that you are not, Mr. Traficonte, or 25 you gave them as little information as you could and still Heritage Reporting Corporation
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27837 1 escaped a. finding that you were in default.
,f r-K
'ks_-) 2 MR. TRAFICONTE: We had 475 interrogatories to 3 answer.
4 JUDGE SMITH: That's right.
5 MR. TRAFICONTE: For which we needed additional 6 time as well as discovery from the Staff that involved .I 7 document review on the part of the government. j i
8 I reconstruct t'aat phase of the proceeding, I can 9 represent, to the e:1ent that we didn't put forth every fact )
J 10 and every piece of evidence that we would intend to use for 11 two reasons. One is, we were facing the extent of discovery 12 that we were in the time frames that we were.
13 And two, we didn't have it yet.
, f'] 14 JUDGE SMITH: I know.
U 15 MR. TRAFICONTE: Discovery obligations are at the 16 time at which you respond. You put forth what you have at 17 the time that you respond. And if you developed your case 18 afterward and there is no supplemental interrogatory, that 19 is not a default on the part of the responder.
20 JUDGE SMITH: In any event, you have overloaded l 21 the system but that's not the end of it. The system is 22 infinitely expandable and we will handle it. We'll just l
23 take the time as needed to do it. )
1 4
24 25 j
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27838 i HR. TURK: Your Honor, since the prior testimony 2 is of record in New Hampshire and since the Mass AG's
[
3 interrogatory answer simply said, see our testimony in New 4 Hampshire, then why should they be permitted to file new 5 testimony?
6 At most, they should be allowed to say, Your 7
Honor, look at our prior testimony New Hampshire, because 8 that's what we said in our interrogatory answers, and that's 9 it. We're not filing anything new, and that would be a fair 10 disposition.
11 JUDGE SMITH: That has real great appeal. We I
12 could have cut this hearing down a lot, but that wouldn't l l
have provided due process to anybody.
13 You would have to 14 pretty well guess. There is a'large pool of evidence there. l t
15 It wouldn't have focused. It would have been chaos. Just 16 to go fishing into that large pool of evidence of up in New 17 Hampshire, and now at this time offer new proposed findings 18 for different applications would have been chaos.
19 Nevertheless, we are here today, We made this 20 ruling, and let's proceed with it.
21 MR. TROUT: Your Honor, counsel for Applicants 22 have been conferring. And as long as we can still argue res 23 judicata and those kinds of arguments in proposed findings, i 24 and I believe the Board has already indicated that we can, 25 Applicants care a lot more about keeping to schedule than I Heritage Reporting Corporation (202) 628-4888
27839 1 they do about whether these particular witnesses come on or j t
(- 2 not. '
3 Frankly, we think if these witnesses -- we feel.
4 now and we have always felt that if these witnesses come in, l
5 their testimony isn't worth very much. They would be cut to 6 pieces, and they will be cut to pieces.
7 So we're not going to fight the rest of these 8 motions. There are no more motions in limine from 9 Applicants on the High testimony, the Renn testimony, the.
10 Adler testimony. Forget it. Let's move on.
11 JUDGE. SMITH: Mr. Trout, that's your call.
12 MR. . TROUT: Yes, that's right.
13 JUDGE SMITH: I'm telling you the Board will stay ;
i
., (} 14 to work here, taking up in a deliberate fashion every motion 15 and every argument that's put to us until it is done. We 16 will work hard and we will work with dispatch, and we will 17 just do it in a deliberate way.
18 MR. TROUT: Your Honor, I --
~
19 JUDGE SMITH: Now we have to --
20 MR. DIGNAN: Your Honor, the call was mine, not 21 Mr. Trout's, and I fully appreciate Your Honor would, very 22 deliberately would.
23 I am making a tactical judgment here on behalf of 24 the Applicants. I think we can deal with it on cross-25 examination. We can deal with it on findings.
i l Heritage Reporting Corporation
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i 27840 1 And I think what I'm trying to do is avoid ' 1 2 overloading the system, which I think these motions do in 1
3 the detail that they are prepared. And I think it can all 4 be handled on findings, under cross-examination.
5 I fully appreciate that the Board has indicated 6 they are prepared to work hard and resolve these motions. I 7 just think I'm asking the Board to do an unnecessary task.
)
8 I think it's something that we can handle equally well by I 9 succinct cross-examination coupled with appropriate 10 proposals for findings and rulings. And it's that simple.
11 I fully appreciate that Your Honor has made it 12 clear that the Board is not requiring us to, or even 13 suggesting that we withdraw the motions.
14 JUDGE SMITH: That's'right. We~are not.
15 MR. TROUT: I meant no --
16 JUDGE SMITH: I just bring it to your attention.
17 MR. DIGNAN: Right.
18 MR. TROUT: I meant no criticism of the Board, 19 Your Honors. Quite the contrary.
20 I just don't think we need to burden the Board and 21 the parties with this any more. Let's bring the witnesses 22 on and see how they do. -
23 MR. FIERCE: We've juet sent Kelly to get Ms.
24 Talbot and she'll be right up from the coffee shop. We l 25 didn't anticipate needing her quite so quickly, but we will Heritage Reporting Corporation (202) 628-4888
l )
)
)
REBUTTAL' PANEL NO. 19 - DIRECT 27841 1
1 need three or four minutes. H
!(
2 JUDGE SMITH: Nobody else has had a break.
3 MR. FIERCE: No. -]
4
'4 JUDGE SMITH: We didn't have a break, so.let's j 5 take a coffee break-or a mid-morning break and get prepared. -
6 "- (Whereupon, a recess was taken.) .
.1 7' MR. SMITH: Your H'onor, _on the subject.of EBS ]
8 messages the Applicants are presenting a Panel composed from 9 your left'to right of Mr. Gary Catapano, M. r Anthony 10 Callendrello and Dr. Dennis-Mileti.
11 Whereupon, 12 ANTHONY M. CALLENDRELLO E 13 GARY CATAPANO
',., 14 DENNIS S.'MILETI .
5
- 15 having been previously duly sworn, were recalled as 16 witnesses herein and were examined and testified further as l
17 follows: .
i 18 DIRECT EXAMINATION l
)
19 BY MR. SMITH:
l 20 Q Gentlemen, I have caused tp be placed before you a 21 document 59 pages in length, plus Attachments A through E, 22 entitled " Applicants' Rebuttal Testimony No. 19, (Media'
]
23- Center and Operation of EBS) " .
24 Do each of you have that document before you?
l 25 A (Callendrello) Yes, I do.
l I
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REBUTTAL PANEL NO. 19 - DIRECT 27842 l I
1 1 A (Mileti) Yes.
2 A (Catapano) Yes.
3 Q I would like each of you to examine that document, 4 if you would, and identify it.
5 A (Ca11endre11o) It's a document that incorporates 6 my testimony regarding the subjects of the operation of the 4 7 media center and the operation of the emergency broadcast 8 system, EBS.
9 A (Mileti) It contains my testimony as well.
10 A (Catapano) And my testimony as well.
11 Q Gentlemen, is that testimony true and accurate to 12 the best of your knowledge and belief?
13 A (Callendrello) Yes, it is.
, 14 A (Mileti) Yes.
15 A (Catapano) Yes, it is.
16 MR. SMITH: At this time I offer the testimony of i
17 the Panel into evidence, to be bound into the transcript as i
18 if read.
19 MS. TALBOT: I have no objection.
20 JUDGE SMITH: The testimony is received.
21 MR. SMITH: And the attachments thereto.
22 JUDGE SMITH: Including attachments.
23 MR. SMITH: The testimony is received?
24 JUDGE SMITH: Yes.
25 Heritage Reporting Corporation (202) 628-4888
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' REBUTTAL PANEL NO. 19 - DIRECT 27843
'1 .
(Applicants' Rebuttal'
.!
- L' 2- Testimony No. 19 (Media-3 center and Operation of EBS) 4 and Attachments follows:)
5 6' ,
7 8
9 10
-11 12 13 14 .i 15 16 17 18 i
19 20 21 22 l
23 24-25
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P June 28, 1989 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD I
l
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL
)
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
- ) .
p U APPLICANTS' REBUTTAL TESTIMONY NO. 19 (MEDIA CENTER / RUMOR-GONTReb AND OPERATION OF EBS)
Panel mew 2gra: Anthony M. Callendrello, Manager, Emergency Planning Licensing - New Hampshire Yankee Dennis S. Mileti, Professor of Sociology and Director of the Hazards Assessment Laboratory, Colorado' State University Gekby-Br-Wekke;--Presidenb--Wehl-e-heseesebes -
Gary Catapano, President - ALLCOMM, INC.
I I
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June 28, 1989 O
UNITED STATES OF AMERICA I
NUCLEAR REGULATORY COMMISSION before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL l
)
(Seabrook Station, Units 1 and 2) ) (Off-site Emergency
) Planning Issues)
)
, ERRATA TO APPLICANTS' REBUTTAL TESTIMONY NO. 19 !
( (MEDIA CENTER / RUMOR CONTROL AND OPERATION CF EBS)
The following changes have been made to the testimony filed on April 18, 1989:
Pace (Line) Errata Title Page Strikeover " Rumor Control" Title Page Strikeover "Colby E. Wells, President - Wells Associates" 11 (22) Strikeover line lii (8-11) Strikeover lines lii (16) Strikeover line ;
iii (20-21) Strikeover lines lii (22) Insert " Attachment E:
Applicable Section of Applicants' Rebuttal Testimony ;
i k .. monn.n l
l t
o_____ _
Pace (Line) Errata
,. p_
k
_', ) No. 18 - School Protective Actions" l'(21-22) Strikeover lines 2 (4-6) Strikeovar lines 3 (2) Strikeover " rumors or other"
~
4'(13) Strikeover " rumors or" 4 (17-18) Strikeover " Rumor Control is also discussed in Section III of this testimony." i Strikeover "from the public l 5'(24) and" 6 (2) Strikeover " rumors or" 6 (8-9) Strikeover "The rumor control process is described more fully in Section III.B.3, supra."
jg-~g 7 (15-21) Strikeover. lines A l A- ' 8 (8) Strikeover "both" 8 (9) Strikeover "and Rumor Control Assistants" i 8 (15) Strikeover "and Rumor Control"
(
11 (17-18) Strikeover "which the ASLB concluded were adequate (LBP- ,
88-32, 1 7.96)"
13 (9-10) Strikeover "or public as appropriate" 13 (10) Strikeover "and Rumor Control" !
)
13 (12) Strikeover "both" 13 (13) Strikeover "and Rumor Control" 16 (24) Strikeover "and Rumor Control" 17 (21) Strikeover " rumors or" l
t
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l Pace (Line) Errata 18 (22) Strikeover " Rumors or" 18 (23) Replace " misinformation are" l with " Misinformation is" l l
19 Strikeover page 20 Strikeover page 21 (1-4) Strikeover lines 26 (12-25) Strikeover lines 27 Strikeover page 28 Strikeover page 29 Strikeover page 30 (1-18) Strikeover lines 32 (8) Replace "prescriptied" with "prescripted"
, 38 (13) Strikeover "and Rumor Control" ]
Strikeover "and public" j 38 (14) 38 (17-181 Strikeover "or the public" 38 (19-2)) Strikeover "The rumor control process is detailed in Section III.B.3."
39 (7) Strikeover "and Rumor Control" 39 (15) Strikeover "On the other hand, minor and" 39 (16-20) Strikeover lines 1
41 (9) Replace " Notifications" with {
" Notification" !
43 (18) Replace "SPMC at 5.6.7, 5.7.2" with "IP 2.12 at 5.45, 5.63" 44 (4) Strikeover "See also, response" 44 (5-29) Strikeover lines
\_. l 1
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\ )
45 Strikeover page 46 Strikeover-page 47 Strikeover page 48 (1-7) 'Strikeover lines
, 49 (17-18) Strikeover " Egg Applicants' Rebuttal Testimony No. 7 for a detailed description of pre-emergency information."
50 Strikeover page 51 (1-4) Strikeover lines 51 (6). Insert " Attachment E" after .
" addressed in" 51 (7) Strikeover line 51 (8) Strikeover "No. 18 (School
, 7-
, Protective Actions)"
i 51 (25) Insert " Attachment E" after "in" 51 (25-26) Strikeover " Applicants' Rebuttal Testimony No. 18 (School Protective Actions)"
54 (22-23) Strikeover lines 56 (12-32) Strikeover lines 1
57 Strikeover page 58 Strikeover page 59 Strikeover page Attachment C Strikeover attachment Attachment D Strikeover attachment Attachment E Insert attachment
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TABLE OF CONTENTS I. INTRODUCTION . . . . . . . . . . . . . . . . . . . 1 II. DESCRIPTION OF PUBLIC INFORMATION RESOURCES AND .
PERSONNEL . . . . . . . . . . . . . . . . . . . . . 2 A. Media Center . . . . . . . . . . . . . . . . . 2 j
- 1. Facility and Equipment . . . . . . . . . 2 l
- 2. Staffing and Functions . . . . . . . . . 3 B. Joint Telechone Information Center (JTIC) . . 5 i
- 1. Facility and Equipment . . . . . . . . . 5
- 2. Staffing and Functions . . . . . . . . . 5
- 3. Information Available to JTIC for !
I Responding to Inquiri'es . . . . . . . . . 8 i
C. Emeraency Ooerations Center (EOC) . . . . . . 8
- 1. Facility and Equipment . . . . . . . . . 8
- 2. Staffing and Functions . . . . . . . . . 9 III. COORDINATION OF EMERGENCY INFORMATION MATERIAL . . 11 A. Description of Emeraency Information Material 11 i B. Development and Coordination of Public Information . . . . . . . . . . . . . . . . . 13 l
- 1. EBS Messages . . . . . . . . . . . . . . 13
- 2. News Releases . . . . . . . . . . . . . . 17
}r Remer-Genbrok . . . . . . . . . . . . . . --F9 l
- 4. Coordination with commonwealth of ,
Massachusetts . . . . . . . . . . . . . . 21 IV. CONCEPTS FOR EFFECTIVE EMERGENCY INFORMATION . . . 23
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\ V. DISCUSSION OF SPECIFIC CONTENTIONS i JI-35, Basis A . . . . . . . . . . . . . . . . . . 31 JI-35, Basis B . . . . . . . . . . . . . . . . . . 34 JI-35, Basis C . .. . . . . . . . . . . . . . . . 36 JI-35, Basis D . . . . . . . . . . . . . . . . . . 37 .
JI-35, Basis E . . . . . . . . . . . . . . . . . . 41 JI-36, Basis A . . . . . . . . . . . . . . . . . . 42 JI--3&r-Basie-A . . . . . . . . . . . . . . . . . . --H
--+5 JE-3&r-Basie-B . . . . . . . . . . . . . . . . . .
JE-3&r-Beeis C . . . . . . . . . . . . . . . . . . --+6 JP-3&r-Beeis-B- . . . . . . . . . . . . . . . . . . --+9 MAG EX-9, Basis A . . . . . . . . . . . . . . . . . 48 MAG EX-9, Basis B . . . . . . . . . . . . .'. . . . 51 I \ .
53 l MAG EX-9, Basis C . . . . . . . . . . . . . . . . .
MAG EX-9, Basis D . . . . . . . . . . . . . . . . . 55
. . . . . . . . . . . . . . . . --96 MAG-EM-Wr-Basis C i
Attachment A: Prescripted EBS Messages Attachment B: Massachusetts Emergency Information l
Flowchart 1 Abbachment-et GRe-News-Rel-ease-t&&fGRe-BB9-f6 ;
i Abbachmenb-Bt GRO-News-Rel-eese-FE9 Att; Ment 5: Applicable _Section of4ppl-icants' Jabuttal-Tesbi=0..y NO.-10 Sches-1 EzG=cti;aA+1ons l
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l dissemination of accurate information and instructions to the public in a timely fashion after initial alert and notification had occurred.
MAG-BX--FHei-t The -Exerei-se -demensbrabed -bhab -bhe -ORO was -unable -be -estabFish -and -eperebe -rumer -eenbrek -i n -a -bi me ky and-efficient-fashient The above contentions and their bases will be specifically addressed in Section V of this testimony.
Sections II, III and IV of the testimony will generally discuss the resources, procedures and concepts for public information dissemination embedded in the offsite radiological emergency response plans. l II. DESCRIPTION OF PUBLIC INFORMATION RESOURCES AND PERSONNEL A. Media Center
- 1. Facility and Equipment To ensure the unified, prompt and accurate dissemination of instructions and information to the general public and any necessary media feedback, a Media' Center has been established by NHY. It is located at the Newington Town Hall in Newington, NH approximately 3-4 miles from the Seabrook Station Emergency Operations Facility (EOF). It provides a centralized location and facilities for the issuance and coordination of news media releases issued by NHY and the various Federal and State agencies. It also provides a
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centralized facility where the various response organizations can deal with ritmers-er-ether misinformation in the public ,
domain that can be readily corrected through subsequent news releases or briefings. The Media Center has been established to effectively facilitate the dissemination of information to the media without the media interfering with emergency response functions.
The Media Center has a media briefing room available to accommodate about 200 people. It also has equipment available needed for the typing, copying, telecopying,
' displaying and processing of media information by the Media Center staff. Meeting rooms and telephones will be available n
k) to receive and transfer information to and from the-Media Center. SPMC, Figure 5.2-11. The Media Center has been established to assure that adequate resources are available for the timely and effective dissemination of a vast amount of emergency information which likely will result if an accident occurs at Seabrook Station. However, the functions l
and the process embedded in the SPMC for Media Center 1
operations also assure that consistent and accurate I information is disseminated.
- 2. Staffing and Functions The Media Center is activated and staffed at the ALERT l level. The Public Information Coordinator (PIC) is the g) official spokesperson for the NHY ORO at the Media Center. l C1s /
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C The PIC is responsible for the dissemination to the media of
! news releases and EBS messages and is the assigned ORO individual designated to coordinate and participate in the news briefings at the Media Center. These functions also require the PIC to interface with utility, State, and Federal public information officials, thus ensuring his overall familiarity with the emergency conditions and the information being issued. How news releases are prepared by the Public Information Staff and coordinated with and through the PIC !
for dissemination is discussed in Section III, pages 17-18 of this testimony.
.s section also provides details on the preparation and coordination of EBS messages. The PIC is also provided information regarding remers-er misinformation so that there is feedback concerning the accuracy of the information being released through the media. These functions and processes concerning emergency information will
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maximize the consistency of that information. Remer-eenbret is -a lee -diseessed -in -Sreebien -FFF -e f -thie -besbimony-The Seabrook Station Emergency Response Organization's (ERO) Emergency News Manager conducts news briefings with the media at the Media Center. The Emergency News Manager acts as the moderator at the news briefings and directs the briefing or questions to the appropriate utility or state official for response. He and the Media Relations / Rumor Control Liaison at the Media Center interact with the PIC to l
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ensure that inaccuracies, if any, in the news releases are j corrected by subsequent news releases, EBS messages, or -
through news briefings. The ERO, through its Technical Advisor at the Media Center, is responsible for receiving updated plant status information froth the EOF Technical Advisor so that it can be discussed, if appropriate, at the news briefings. A similar function is performed by the ERO Health Physics Advisor at the Media Center with respect to radiological information.
I B. Joint Telephone Information Center (JTICl_
- 1. Facility and Equipment The JTIC is located in a separate building adjacent to
,( ) the EOC in Newington. The JTIC is equipped with the
%J necessary communications links and equipment to carry out its functions as defined by the SPMC and described below.
- 2. Staffing and Functions The JTIC operates and functions as a combined facility staffed by personnel from the NHY ORO, NHY ERO and State of a
New Hampshire (SONH). SPMC, Section 3.7.3.C. This combined staffing approach ensures coordination of information with the various response organizations.
The function of the JTIC is to provide accurate and l
current information in response to telephone inquiries received frem-the-pubFie-and from the media. As part of the l
l ,f s process of responding to inquiries, the JTIC provides a
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public information " steering mechanism" by providing for the identification and reporting of remers-er false information.
Once identified, this information is promptly documented, reviewed and reported from the JTIC to the Media Center.
This information is then made available to the public l 1
information staff at the Media Center and the EOC for consideration in the formulation of news releases and/or EBS I messages. The -remer -eentrel--process -i s -deserhed -mere -fal-Fy i-n-Seebien-EFErBr};--seera r l
Radio and television broadcasts are also monitored at {
1 the JTIC. Equipment is available to record broadcasts if necessary for further review. News releases will contain information regarding the appropriate JTIC telephone number for public or media inquiries.
JTIC positions and staffing are described as follows:
Media Relations / Rumor Control Supervisors:
- Three (3) supervisors per shift, one each from ORO, ERO and SONH.
- Responsible for the coordination, briefing and support of the activities of the Media Relations Assistants and Rumor Control l Assistants.
- Responsible for providing information to the Media Center through their respective l
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organization's Media Relations / Rumor Control Liaison present at the Media Center.
. Ensure that the information contained on their !
respective organization's prerecorded status lines is kept current. .
Media Relations Assistarttg:
. Staff of eight (8) per shift, three (3) from ORO, three (3) from ERO and two (2) from SONH.
- Responsible for responding to inquiries from the media.
. Responsible for monitoring television and radio broadcasts.
- Reports to the appropriate organization's Media Relations Rumor Control Supervisors.
Rwmer-eenbrel--Assi-stanbet
- Staf f -e f -six - t&)--per -shifb r -bwe - t& P -each -frem GROr-ERe-and-SONHr
- Responsibl-e-for -responding-be -inquiries -frem the-pubMer
- Reperbe-be-the-appropriate-ergeninabien's Media-Rel-abi-ens /Remer-eenbrel--Saperviserer Administrative Staff:
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Staff of four (4) per shift, two (2) from NHY ORO and two (2) from ERO.
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+ Responsible for the support of the activities of the JTIC.
- 3. Information Available to JTIC for Responding j to Inquiries The JTIC ctaff will be provided with accurate and 4 current official information so that they can effectively respond to inquiries. This information has two primary sources; the first being the staff position manuals for both the Media Relations Assistants and-Remer-Genbrek-Assistants 7 i and the second being the news releases and EBS messages. The i
staff position manuals contain generic background facts concerning the response organizations and prepared responses to general information requests from'the media'and the .
1 public. EBS messages and news releases are provided to the JTIC for use by Media Relations and-Remer-Genbrel personnel in response to inquiries. In addition, any special requests for information are conveyed to the Media Relations / Rumor Control Supervisors for their action. IP 2.12 at Attachments 11, 14.
C. Emeraencv Operations Center (EOC)
- 1. Facility and Equipment The Seabrook Station NHY Offsite Response EOC is located in part of a building which also houses the EOF and the State i of New Hampshire Incident Field Office (IFO). This building is located at the Newington Station site. The EOC functions N ..
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as the command center for directing and controlling the offsite emergency response, including the preparation and dissemination of new releases and EBS messages. It serves as the location for the following response activities:
- Coordination of Seabrook Station, State and Federal response organizations
. Radiation Health Support
. Emergency Communications Support
- Evacuation Support
- Public Information Support
- Dissemination of plant information
-N The EOC provides both a working' location and the
'- equipment for performing each emergency response function.
Work areas and equipment have also been allocated for the Commonwealth of Massachusetts and Federal representatives.
- 2. Staffing and Functions The EOC will be activated upon the declaration of an ALERT or higher classification. Upon arrival at the EOC, the NHY Offsite Response Director will establish contact with the Seabrook Station EOF, the New Hampshire EOC and IFO, and the Governor of Massachusetts for the coordination of decision-making and response activities. .
1 The NHY Offsite Response Director exercises operational )
control of the NHY Offsite Response Organization through the
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following functional assistant directors, advisors and coordinators. -
. Assistant Offsite Response Director, Response Implementation i + Assistant Offsite Response Director, Support _
Liaison
+ Radiological Health Advisor
- Public Information Advisor
- Public Notification Coordinator
+ Emergency Preparedness Advisor These assistant directors, advisors and coordinators will be responsible for providing the NHY Offsite Response Director with accurate and timely assessments of the accident situation and the operational status of the NHY Offsite Response Organization and facilities. In turn, the NHY offsite Response Director will keep State and Federal officials informed of response activities. At.the EOC, the Public Information Advisor (PIA) is responsible for the preparation, coordination, and dissemination of public information, including news releases, developed by the NHY ORO. The Public Notification Coordinator (PNC) is l responsible for the development and coordination of EBS =
messages. These functions are discussed below.
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III. COORDINATION OF EMERGENCY INFORMATION MATERIAL A. Description of Emercency Information Material The public, including the media, obtains official l
information concerning a Seabrook Station emergency from
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three sources: (1) EBS messages, (2) news releases, and 1
(3)-generic, factual information available from JTIC 1 personnel.
EBS messages which will be broadcast to the public are either prerecorded, prescripted or modified, as appropriate, from the prescripted messages. This use of and development from these prescripted messages ensures that the EBS messages l will be consistent, accurate, clear and specific, among other O attributes. Prescripted messages, Attachment A hereto, will be incorporated as part of IP 2.13 in the next revision of the SPMC. These prescripted messages are based on similar i
messages in the New Hampshire Radiological Response Plan (NHRERP) . whieh-the-ASLB-eenel-uded-were-adequabe-tLBP-a&-}2-f-7r96W The EBS messages were developed in accordance with the criteria in NUREG-0654, II.E.5 and the guidance contained in FEMA REP-11, "A Guide to Preparing Emergency Public Information Materials," June 1987. If, at the time of an emergency, modifications to the prescripted EBS messages are l considered appropriate, SPMC procedures for development and approval, as discussed below, ensure that adequate and fm effective information is relayed to the public.
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Prerecorded messages will be maintained at the ORO EBS radio station. Upon authorization of the Commonwealth, the PNC will contact the ORO EBS station and advise it of the title of the prerecorded advisory message appropriate for broadcast, or advise them that the authorized EBS message for broadcast will be telecopied to them. The station is also notified of the frequency of the broadcast. IP 2.13 at 5.1.11.C.
News releases, including information provided to the media at press briefings and over the telephone at the JTIC, are developed to give up-to-date information regarding plant status, emergency operations, and response actions underway !
affecting the public. SPMC procedures have been developed to ensure that news releases address some or all of the items listed below if appropriate to the message (see IP 2.12, at 5.2.2.B):
- Issue number Date/ time issued j
- Approval of NHY Offsite Response Director
- Subject
- Event classification and definition t
- Radiological release status l
- Protective action recommendation as approved by l Massachusetts and the NHY Offsite Response Director
+ Location of evacuees from special facilities such as schools, nursing homes or hospitals l
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Status of Commonwealth of Massachusetts:
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- Actions being taken'by NHY:ORO or Massachusetts to mitigate consequences of event'
- Rumor _ Control phone numbers -
- Instruction for public to' listen to EBS radio stations The generic, factual'information contained in'the position manuals is provided to the media er-ptthMe-as appropri-abe by Media Relations and-Rtemer-eentret Assistants.
Factual information which has been approved'for dissemination is contained.in staff position manuals for both Media-Relations : and-Rtemer-Genbret Assistants. The information s/
'\ pertains largely to background _ facts concerning.the response organizations and prepared responses to general information' -
sought by the media and the public.
B. Development and Coordination of Public Information
- 1. EBS Messages The Public Notification Coordinator (PNC) is the ORO i
position responsible for the development of EBS messages and the coordination-of EBS messages with appropriate l Massachusetts and New Hampshire officials. The PNC is ,
mobilized at the ALERT or higher emergency classification and reports immediately to the EOC. Upon arrival at the EOC, the PNC coordinates with the NHY Offsite Response Director to determine whether contact by the Seabrook Station ERO has k
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been made with the EBS station and whether an EBS broadcast S
is underway. Prior to EOC activation, EBS messages can be initiated by the ERO Short Term Emergency Director using the prerecorded messages maintained at the EBS station. If an EBS broadcast is underway, the PNC is not to assume responsibility for these functions until after the public notification process has been completed. IP 2.13 at 5.1.
When EBS message functions have been assumed by the ORO, the PNC takes the following steps to begin the EBS process:
- Contact ORO EBS station and place it on stand-by status.
+ Contact the New Hampshire EOC Operations Officer and the appropriate Massachusetts official to establish coordination.
+ Verify that the position packet has current EBS messages.
- Begin preliminary planning of EBS messages based on information from the Radiological Health and Technical Advisors in the EOC.
a Inform NHY Offsite Response Director of preparatory activities.
If the PNC receives a direction to prepare an appropriate EBS message from the NHY Offsite Response Director, he begins the development of EBS messages for dissemination by:
- Preparing the EBS message by use of the most appropriate prescripted messages,
- Reviewing the EBS message with the NHY Offsite Response Director and noting modifications, if any,
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- Coordinating the message with the New Hampshire EOC I I
Operations Officer in the Concord EOC and the appropriate Massachusetts official, and
+ Obtaining approval of the EBS message from the NHY Offsite Response Director.
I After initial review by the Offsite Response Director, I i
the PNC telecopies the draft EBS message to the appropriate Commonwealth official for review. IP 2.13 at 5.1.6.
Provisions for coordinating EBS messages with the i
Commonwealth are included in the responsibilities of the NHY Offsite Response Director, who must obtain the concurrence of the Governor of Massachusetts or designee prior to any EBS message broadcast. IP 1.1 at Attachment 2 (Conditional jf'"3 Response Activities), page 3 of 10 ' Action #4. In addition,
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'- ' the Offsite Response Director is responsible for maintaining l contact with the Governor of Massachusetts or his designee with regard to emergency response status, ORO resource availability, and protective action recommendations. IP 1.1 at Attachment 3, Action #3.
Coordination of EBS messages with local governments is j not required since, in accordance with the SPMC, the responsibility for authorization as to message content and activation rests with the Governor or his designee. Local governments will be made aware of EBS message content as soon as possible through the ORO Local Liaisons who will report O
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local concerns and requests back to the EOC through the Local S l EOC Liaison Coordinator. IP 1.8.
After the EBS messages are approved by the NHY Offsite Response Director and the appropriate State officials, the PNC will attempt to coordinate the timing of EBS message broadcasts with Massachusetts and New Hampshire officials. ;
i The PNC's procedure, however, includes a cautionary note that public notification must occur within 15 minutes of the Massachusetts Governor's or his designee's authorization to notify the public. IP 2.13 at 5.1.11. This process recognizes the importance of timely public notification and ensures that all organizations are aware of each other's immediata and impending actions.
After the EBS messages undergo the requisite coordination and approval process for broadcast, procedures are in place to ensure consistency and accuracy of broadcast.
IP 2.13 directs the PNC to provide a copy of each broadcast EBS message to the Public Information Advisor (PIA) who is I
co-located with the PNC in the EOC. The PIA supervises the development of news releases by the Public Information Staff, thus assuring consistency of the news releases with EBS
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messages. The PIA also provides the EBS messages to the l Media Center for use as a news release, and to the JTIC for l
use by the Media Relations and-Remer-Genbrel Assistants.
IP 2.12 at 5.1.6. This ensures that press briefings at the
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Media Center and telephone responses at the JTIC are l consistent with EBS messages. . A graphical depiction (flow chart) of Massachusetts emergency information.is set forth in
' Attachment B hereto.
Overall coordination of EBS messages is further ensured. l by the fact that the Media Center provides the necessary facilities to allow representatives from each of the principal State, Federal and utility response organizations to interact on public information matters, including EBS broadcasts. In addition, at the JTIC, Media Relations / Rumor j
. Control Supervisors of the ORO, ERO'and the State of New Hampshire review all news releases, bulletins and EBS !
j ) messages. prior to distributing them'to their staff. These, processes provide a mech'anism whereby inconsistencies or inaccuracies in an EBS message would be noticed and the issuing organization immediately contacted for corrective action.
- 2. News Releases As stated in Section II.C.2, suora, the PIA is responsible for the preparation and issuance of news releases and responding to remers-er misinformation. The PIA obtains approval of all news releases developed by his staff from the NHY Offsite Response Director and then directs the transmittal of the approved release to the Media Center and the JTIC. IP 2.12 at 5.1.5.C. This assures that the timing l
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and content of news releases are coordinated with EBS messages. If a bulletin news release is to be issued, the PIA verbally communicates the information to the PIC and provides the content via a Bulletin Release Verification Form to the Media Center and the JTIC. IP 2.12 at 5.1.5.D.2 and
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5.1.5.D.3.
Upon receipt of an approved news release from the PIA, the PIC reviews it and coordinates with the Seabrook Station Emergency News Manager and Federal and State Public Information Officers prior to briefings and dissemination.
IP 2.12 at 5.3.4. The PIC, in turn, keeps the PIA informed :
of feedback from the briefings and provides copies of all news releases and EBS messages issued by other organizations at the Media Ce'nter to the PIA and the JTIC. IP 2.12 at 1 5.3.3 and 5.3.8.
In addition to the prompt distribution of EBS messages and news releases from the PIA to the Media Center and the JTIC, the SPMC also provides for the coordination of information between the Media Center and the JTIC to ensure that the Media Relations and Rumor Control Assistants have accurate and timely information for responding to media and public inquiries. IP 2.12 at 5.5.4. Rumors-er Misinformation is fed back to the Media Center to be addressed if appropriate in future press briefings.
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To-ensere-eensi ebent-hn fermabien-is-disseminated-be -bhe pubMe-and -be -ensere-eeerdinabien -o f-informabien-whh-ebher l
respense-erganisabiene r-the-SPMe-provides-for-remer -eenbret j er -eentrek-e f-misinfermabien-through-the-personneF-and i reseerees-ab-the-FPler- 'Phe-Media-Rehabiens-and-the-Rumer eentrek-Assiebants-are-instreeted-te-respond-be-kngetries -by using -information-f rem -approved -BBS-messages -and-news .
releasea r -es -weh -as -bhe -pre-app reved -f aebeak -in formabi-en -in their-peshien-packeber sPhe-Medie-Rehabiens-Assi-stands-are akse -assigned -be -menher-bekevision-and-radio-breadensts -fo r mis in formabien r --M i-s in formabien -i s -reperbed -be -the -Med i-a
-(A) v RehabienefRemor -GenbreF-Gupervisers-ab-the-FPEG-whe r-in -burny bransmh -the-in formabien-be -the-Media-RehabiensfRemer -Genbrel Liai-sen -ab -the -Medie -eenber -for -immediabe -aeb ien r -i-f appropriate r -by -the -Ple -ab -press -brie finge r --EP -a rEE -ab
& v5 r& rB r -5 r+ r? r ~5 rk r& r --See -aFse r -Ah,baehmenb -B -herebe r-The -PFG -akse -een -direebl-y -interae b -whh -the -PFA eeneerning -rumors-er -misin formatien r--Whi Fe-h-ie-neeessary and -appropriate-be -respond -be -pubMe -i nquiries -esing -o f ficial approved -in fo rm adien r -h -m igh b -be -necessary -fer -the -PEA -be devekep-and-disseminate-supplemenbaF-i n formabien -regarding the -emergency -and -r esponse -aebiv h hes -be -eeenter -any mi-s in forma bien -b readeast -or -issued -by -the -news -media -er -be d ispek -persistent -pubbie -remers r --Sinee -the -PEA -and -the Q
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i PubMe-Enfermabien-Sheff-are-Feeabed-in-the-Bee r-they-are-in O
the-besh-pesibien-be-devel-op-news-releases-and-ebher-aceurabe in formatien -because -they -have -access -be -al-F -the -Fates h -plan t and -emergency-response-information r-and-they-een-e ffeebiveFy I eeerdinate-the-response-threugh-appropriebe-eRe -BROr-and r Sbabe -e f fic heks -ee-Feeated -in -the -Bee r --Thus r -the -PEA ,
i eeerdinabes-any-necessary-teehnicab-or gevernmentaF-input inte -news -re beases -er -buhl-ebine -requi red -be -dispel--rume rs -e r i to -eerreeb-miein fermabien -in-an-aceurate-and -effeebive _l manneer i
The-remer -eentreF-previ sions-eenbeined-in-the-SPMe-at )
l EP -E rF& -supplemenb -the -in formabien -de -be -disseminated -be -bhe pubMe -via -BBS -messages r --The -NHV -ore -wul--use -the -BBS -te eenvey -aeeurabe -in formabien -and -iestruebiens -be -the -pubbi-e 7 regardieg-the-effaibe-emergency-response-including i information -be-eeunter -rumors-er-miehnfermabien f approprieter--SPMe-EP-Erha .ab-SrFr}rer--The-genereF-publie-is j directed -to -bane -be -BBS -radio -s babiens -for -e f fieleF -emergeney i n fermation r --The -BB9 -stabiens -are -Meted -in -bhe -NHV -Pebhe En fermation -Meterhaks -di-stributed -be-BP&-househelde-and -ether leeabiene r -and -ORO -news -releases -disseminated -to -the -medier The ERumor-eentrek-PeFicy-Guide n-(-EP-&rlb Abbachmenh-F+) -provides-the-Rumer-eenbrek-Assisbants-with guidance -en -hew -be -respond -be -pubFie -inquiries -en -the emergency r --En -addition r -Rumer -Genbrel--Assistants -wnl--advise Q. .
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the-pubbie-te-Fishen-be-the-BBS-radie-stabiens-fer-bhe-mest earrenh -e f fiekeh -in fermabien r --The -PNG -i s -Feeated -in -the -BOG- )
l and-ean-eeerdinate-any-necessary -beehnicek-or-efevernmenta3: !
inpub-inte-BBS-messages-recruired-fer-remer-eentrel r
- 4. Coordination with Commonwealth of Massachusetts Coordination of EBS messages and news releases between 1 NHY and the Commonwealth of Massachusetts is assured through several mechanisms in the SPMC. Prior to dissemination, ORO officials in the EOC coordinate the content and timing of the messages and releases with Massachusetts officials as noted above.
gg After dissemination, several processes for coordination
'\_ exist. First, the ORO State Liaison will be present in the State EOC in Framingham, Massachusetts and is provided copies of all EBS messages and news releases via telecopier.
IP 1.11 at 5.2.1. This assures that State officials at the Massachusetts Civil Defense Agency (MCDA) are promptly and >
accurately apprised of current information regarding the emergency. The State Liaison also informs the NHY Assistant Offsite Response Director, Support Liaison of all decisions made and actions taken by the MCDA Director in response to the emergency. Another State Liaison reports to the MCDA Area I EOC at Tewksbury, Massachusetts. The State Liaison who supports the Massachusetts Department of Public Health
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(MDPH) also coordinates information flows between ORO and O
MDPH in a similar manner. IP 1.11 at 5.3. These State Liaisons coordinate information dissemination between the ORO ,
EOC and appropriate State officials.
Second, if MCDA and/or MDPH dispatches representatives )
to the EOC, consistent with the provisions of the Comprehensive Emergency Response Plan (CERP) of Massachusetts at page ONE-61, Applicants' Exhibit 57 (see Mass. AG's Answers to NRC Staff's Third Set of Interrogatories and Requests for Production of Documents, dated December 19, 1988 at page 5), public information flows can be directly established and coordinated between those representatives and ,
the PIA and the PNC. Local governments are also directed by the CERP (at page ONE-61) to coordinate their public information activities with that of the Commonwealth. Thus, local governments can establish communications with the ORO I through the MCDA representative at the EOC, or through the Local EOC Liaison. SPMC at 3.5-2.
Third, public information is coordinated between the l l
various utility, State and Federal organizations at the Media I Center. The PIC is responsible for the exchange of ORO l
f information with all of these organizations on the changing )
\
\
status of emergency response functions and facilities. l j
IP 2.12 at 5.3.7. l C .
l l
l J )
' ' ~
IV. CONCEPTS FOR EFFECTIVE EMERGENCY INFORMATION o
The basic concepts used in evaluating the effectiveness of_ warning messages, including the prescripted EBS messages in the SPMC are as follows:
First, the content of an EBS message or news release should provide information which.is specific, consistent, accurate, certain and clear about the risk, the ,
risk' location,-public response guidance, and response timing.
Second, the-messages should be repeated often in a
_ pattern.
Third,.the source of the message should be identified and, when possible and appropriate, ,the source
- fg i (j should-be a mix of persons and organizations.
Fourth, the channel of communication to the public should be diverse as is practical. i 1
EBS messages should be well-focused and need not provide- j an explanation of the inter-organizational chart regarding i
-emergency management and response. Messages should instead l I
focus on the factors of risk, its location, guidance about '
response and. response timing. The messages in the SPMC have i
i a correct content focus and it should not be diverted except 1
when necessary as determined by the PNC. Additionally, all ;
EBS messages intended for issuance upon declaration of a Site Area and/or General Emergency, including all messages recommending protective actions, state that the New Hampshire 3s, i
f ;
Yankee Offsite Response Organization (NHY ORO) is responding to the emergency. -
An emergency message which is repeated frequently is more likely to be confirmed in the mind of the listener, and confirmed messages are more likely to be believed. The EBS I l
messages in the SPMC are designed to be broadcast every 15 '
minutes. However, it is not necessary to repeat emergency ;
I messages every 15 minutes, especially in situations where the !
emergency status remains relatively unchanged over a period of days. It should be emphasized that messages in the SPMC j are sample messages which can be altered in an emergency to suit actual circumstances and events.
Consistent with these basic concepts, the prescripted EBS messages in the SPMC identify the Massachusetts Governor as the source of emergency information being disseminated.
Although not ideal, this is an accurate ascription of the source as these messages would only be broadcast upon I authorization from the Governor or his designee. It is not necessary for these messages to further explain who and what is " controlling" and " directing" the emergency response.
Even though it is not necessary for the messages to discuss the relationship between ORO and the State and/or local governments, language in these messages indicates that the ORO and the Commonwealth are in communication regarding the j
( ; r^N i
)
.. .J incident, clearly reflecting an emergency response relationship between the two entities.
In addition to accurate and effective messages, communication systems and processes must be in place to .
assure that the emergency messages and information get to the right people / organizations in a timely manner for an effective response. Similarly, the communications systems and processes must assure adequate and timely feedback, if necessary, for corrective actions. The SPMC has been designed and developed to assure simple, redundant and flexible communication flows between the various NHY, State !
and Federal organizations. Communication processes must be 7-~N 9
( ) simple so that information flows are timely -- that is, the j v
information should not be lost or delayed in a bureaucratic j structure. Communication processes must be redundant so that i
a failure in one process or system does not result in a total !
loss or delay of needed information. Communication processes 1
must be flexible so that information can be developed, coordinated and disseminated in accordance with the circumstances -- that is, a short-circuit or bypass of a j
" normal" process may be in order in some circumstances. l The SPMC provides simple primary and backup communication systems and processes for emergency information flows. With respect to EBS messages, they are provided to:
r 'y (1) ORO EBS stations, (2) the Media Center, and (3) the JTIC i(%)
~
by either telecopy or hand-delivery. Accuracy of delivery is e
assured by feedback to the Media Center or the JTIC. With respect to news releases, they are provided to the Media ;
l Center and the JTIC by telecopy or hand-delivery. Feedback l also comes to either the Media Center or the JTIC. Ring down circuits and commercial phone lines also exist between the JTIC and the Media Center, and between the Media Center and the EOC for primary and backup communications. Corrective actions, if necessary, can be accomplished orally at news briefings or through telephone responses at the JTIC, or by subsequent news releases or EBS messages.
Br r -earter -has -ne b -been -eare fub -ner -eemprehensive -in develeping-the-eriterke -with-whieh-he-woul-d-fudge-the i
adequacy -o f -the -SPMe -and -exerei-se -BBS -messagee r--Seme i l
kl-Fustrahlens-fehl-ew r-en-page o f -hie -prefited -besbimony r -Be r-earter -has ;
dismissed -the-Fieb-of-imperbanb-emergency-pubbie-in formabien i l
! f achers -provided -i n -earFier -testimony r --He -then -o f fers -a j
\ l j subsbibabe-kieb-of-ten-fachers-en-pages-7 -bhrough-FG-ef-his l l 4 bes timony r --Th ie -Fieb -ie -taken -frem -a -publicabien -by l l
l Serensent-Vegb-and-Milebir We -eens ide r -bhe -Fie e -o f - f aebers -in -p rie r -best imony -be -be i mo re -eemprehensive -than -bhe -subsbitubed -Fish -by -Be r -earberr The -reader -was -eau biened -in -bhe -pubhicabien -e ited -by -B er ea rter r --Fb -stated -tha b -bhe -ten - f actors -were -lim ited -be C
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generak -f knd knge r -and -bhab -h -was -neb -bhe -purpose -e s -thah 1 i
pubMeaMen-be-ge-kabe-the-bepie-in-depthy - i Mereever r -the -Msh -ef -ten -f aebers -presented -by
- Ber-earber-purperbe-be-represent-bhe-Meb-previded-in-the referenced-pebMeabien r--Eb-dees-se -aeenrabeby-i a-reference be -some -pointe r --Eb -disterbs -whab -was -said -ka -referenee -te ether -peinte r --Eb -else -segges te -that -things -were -said -in -the
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pubhicabien -whieh-were-net-saldr Br r-earter -then -reviews -some -eenchestens -from -a -beek -by ,
l Perry r -Linden-and -Greene -en -pages -kk-15 -e f -his -tesbimony l
(-See-Renald -W r-Perry r-Michael--N r-Linden-and -Marierie -R Greene r-19&b r-Byaeuabien -Phanni-ne -kn -Emereeney -Manacement r-O g Lexingbear-Massaehusebbse-Lexinsten-Beeks) r--Ber-earter states-en-page-k2 -es-his-tesumeny-thab-bhis-research idenufied -perceptien-of-severhy -e f-impaeb-and -percepbien -of
. proximhy-be-the-aree-of-impaeb-as-the-bwe-hey-ebements-le-a persen 's-perception -e f-personal--risk-dering -emergeney I
warn i ngs c --On -pages -1}-1+ r -Be r -earber -states -thab -thi-s researeh-idenufied-three-f aebers-whieh -facihtabe-baking preteenve-aebiens r--These-were-idenuficabien -o f-an !
l appropriate-and-ef feenve-actien r-the -exiebence-of-an j l
individeak-er-fam hy-emergency-phan r-and -a-seeial-eenbexb -in j wh ich -the -f am My -i-s -begethe r -e r -etherwise -aceeenbed -for l during-the-emergeneyr l(
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i Rehance-en-the-resehs -o f-ene-pubMeabien- fparbienharFy i
when -many -ebhers -exisb F -ie -daneferees -in -bhe -seeiaF -seienees r-Seme -f achers -found -be -be -imperbanb -in -ene -sebbinef -may -net i I
appby -in -anether r --The -rehabieneh kp -between -two -variables -ean chanefe-when-obhers-are-inbredu;cd r--tPerry-and-his-eeneaefues did -ne b -exam ine -en -er -even -mesh -e f -the -faebers -thab -impact i pubMe -risk-percepbien-and-response-in -emerefeney -warninej sebbinefe r F --Per -exampFe r -h -has -been -found -thab -f am ny -uni by fachhabed -preteenve-aebiens-in-the-F969-Benver-fFeed r-but h -had -no -impaeb -en -prebeebive -actions -durinef -the -F9M -R apid ehy-fFeed r--h-is-inappropriate-be-pick-stabiebicaF-findinefs from-ene-emerefeney-or-one-sbudy-tbhe-Perryr _eb_ -gir publicabien -was -en -feer -fleed -evends P r -ief nere -en -ebher studiee r-and -then -make-efeneraheabiens -aeress-eme -and -space as -Be r -earter -has -done -wnh -the -Perry r -eb -eF r -publicabient Hereever r -Br e -earber -has -nob -dene -a -ekese -readinef -ef seme -e f -bhe -Perry r -Maden-and -Greene -text r --Per -examp her B r r -earter -s habes -en -paefes -M-F+ -e f -h ie -besumeny -thab -ene -ef bhe-three-faebers-whieh-Perry _eb_-gir-found-be-faciMbate preteenve-aebien-was Sa-seeiet-eenbexb-in-which-the-famny is -teefebher -er -o bherwise -eeeeenbed - for -ab -bhe -Mme -o f -the emerefeneyr*--Phe-Perry _eb_-gir-beek-suefefests-bhab-bhe-authers themsebyes-theuefhb -bhey -had -insu f fielenh -daba -be -fu hy examine-the-hypothesis-e5-famny-unhy-en-responses-tsee paefe
+5 F -bub -bhey -were -abbe -be -eenekade -bhab -reen h inef -f am ny
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members -a fber -evaceabien -weeM -be -use feF -be -address -in phanning-feee-pages-MF-M2-) r--Albheegh-Perry-g_t-gir-de-net dismiss-famhy-enhy-as-unimperbanb r-h-is-hardky-ene-ef )
three -f aebers -revealed -in -bheir -dabe -seb -as -directing prebeebive-actiener Ber-earber-has suggcebed-bhab-bhe-Fieb-ef-feebers presented-in-19&7 -AppFieantsL-besbimeny-(disbhbed-frem-aH avahable-publications-en-pubble-response-be-warnings)--he disregarded-en-the-greends-thab-h-is-tee-abstraeb-er theo rebicab r --He -seggests -bhab -h -be -rephaeed -whh -a -ten peinb-eheekkieb -whieh-comes -frem-a-publicabien-by -Serensen7 Vegh-and-Milebh-ia-whieh-bhe-reader-vas-eaubiened-bhab-bhe Fieb-was-Hmited-sinee-h-was-neb-the perpose-ef-the pubheabien -be -ge -inte -depth -en -the -topie r --The -ten -point Heb-le-then-presented -(eemetimes-eerreethy-and-semebimes neb r-ebher-bimes-the -authers-are-abbribebed -with-saying things-that-are-nob-said) r--Then-semething-eahed-the-Perry medeF -le -presented r --The -abl-eged -modeb -eemes -from -ene -ef Be r-Perry 's -earki-esb -works r--The -modeF-presented -aeeerabeFy refheebs-seme-of-the-findings-in-the-Perry _e_t-gir pubhicatione r-disterbe -ebhers r-and-hardby-bears -resembFanee de-the-modeb-whieh-Perry _e_t-gir preposes-as-a-summary-ef j I
their-ewn-werk-feee-pages-FF9 7-and-ehapter-&)r i
ear -eeneles ien -is -simpty -thab -B r r -earter -has -not -been p earefeF-ner -eemprehensive-in-developing-a -seienbi fie -basi s
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l' fer-bhe-erherie-he-preposes-as-a-device-whh-whieh-te l evakeabe -t-he -SPMe -and -exercise -EBS -messages r --Thie -has -Fed -be .
seme-ineerreeb-evakeabien-erheria-in-bhe EeheekMsh-en-Level of-Betaned-Enfermation8 E-whieh-he-effers-en-pages-FG-M-ef I
hi-s -besh kmeny r --Fer -example r -en -page-M -ef -h ks -testimony -he i proposes-bhab Er r r-messages-disseminated-be-the-Media eenber-sheeM-be-disseminated-bhreugh-EBS rE--The-ameenb-ef informabien-er-messages -whieh-eeeM -be-disseminated -in -bhe informabien-and-debah-rich-environment-of-the -Medie-eender is -berge r --Me ssages -eeeM -eeme -through -press -een fereneeer press -rel-eases -and -ebher -waye r --Sere 3-y -Be r -earter -weeM -net have-the-Media-eenber-information-disbribebien-fanebien eensbrained-by-the-Hmhed-eapachy-ef-the-EBS-sys.%m t -er eenverseby r -se -overburden -t he -EBS -system -w hh -dedans -that imperbanb-EBS-information- tfer-exampl-e r-proteebive-aebien reeemmendabiens)--is-ebseered r-EBS-messages-eanneb-be frequenbl-y-repeabed r-er-expeeb-a-radio-stabien-to-rehnqui-sh I
l ah -o f -hs -al r -bi me -be -the -EBS -fenebien r - - -------
l l V. DISCUSSION OF SPECIFIC CONTENTIONS l
l The following are specific responses to the admitted contentions concerning the adequacy of information disseminated to the public in the event of an emergency at Seabrook Station.
l l
l
( ,s
f/ )
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JI-35. Basis A alleges that: l 4
"The messages prepared by the ORO are misleading, confusing, self-contradictory {
and ignore important characteristics of j public in Massachusetts and its response j to a radiological emergency at Seabrook." J As noted in Section III.A, the prescripted messages I
contained in the SPMC were developed in accordance with '
applicable NRC and FEMA guidance, and are essentially similar to the messages contained in the NHRERP which have been found to be adequate. These messages are based on solid concepts about how to warn a public at risk in an emergency including, for example, those who might have high pre-emergency fear, the older population, or other particular characteristics. !
,3 i Indeed, the messages are designed to convey accurate and
}
factual information in a clear and concise manner. The messages focus on the factors of risk, its location, guidance about response.to the risk, and the timing of that response.
This type of information also can be developed for subsequent news releases based on public inquiries or rumors. The j j
process for the development of this information and its j i
dissemination is discussed in Section III, suora. l l
Dr. Carter has asserted that the SPMC prescripted EBS l l
l messages contain a number of fundamental problems which occur i 1
repeatedly throughout the messages. First, he asserts that l
"a large number of the messages consistently fail to give fx instructions to all members of the public within the EPZ" s
K ))
7__-___---_
1 (Carter, page 20). In essence, this criticism concerns messages informing one group in the EEZ (e.g., boaters, beach and wildlife refuge visitors, and residents of distinct towns in the Massachusetts EPZ) to take protective actions without informing other groups within the EPZ of those actions and why they are being taken. Dr. Carter asserts that this division of instructions creates confusion and anxiety.
The prescripted messages do give recommended actions to all members of the EPZ. These messages are designed to give recommended actions to people in the EPZ based on the risk which they face. Everyone in the EPZ is advised to stay ,
t tuned to the EBS station. People in towns are advised to consult emergency information materials sent to their homes or information flyers at beach and recreatioh facilities.
People who would be safe if they sheltered are advised to do so, and those who should evacuate are so advised.
Moreover, putting additional information in the EBS messages regarding why people who are safe are not at risk would detract from the needed information required to be disseminated to the public who is at risk. FEMA /NRC guidance suggests that warning messages must not be cluttered with extraneous information. Plans for an emergency at Seabrook correctly provide other formats for the presentation of non-EBS relevant information, for example, in new releases and press conferences.
l t'
Second, Dr. Carter asserts that the messages must contain information relating to "the actual or forecast severity of the release or to the potential health effects of the release" (Carter, page 21). Again, this assertion s ignores the reality of a radiological emergency. For example, it would take too long to calculate actual or projected releases in order for such information to be effective in moct messages. Additionally, it is not appropriate to include potential health effects in the messages because (a) a majority of the public does not understand the terms or the health effects relating to radiation and an EBS mesLage is not the place for basic science education, (b) any information relating to potential health effects may detract from the needed certainty of the message, and (c) we are unaware of any analogous emergency warnings in which the physiological affect of exposure to a hazard are explained in community warnings, (for example, the physiological character of drowning in storm surge associated with the landfall of a hurricane). The content of EBS messages in a radiological emergency should not permit the public to discount or second-guess the risk. This could detract from the public taking the protective actions recommended in the message.
Third, Dr. Carter asserts that the prescripted EBS messages contain no information "on future preparedness
l l
I
( '
needs" (Carter, page 22). However, as Dr. Carter acknowledges, the EBS messages do refer listeners to the q public information materials for further information and to stay tuned to the EBS station or a local radio station. Any further preparatory information, as Dr. Carter suggests, would be based on speculation regarding the unknown course of the emergency. Such speculation is not required for the needed attention and focus to the message. To the contrary, i this type of speculation would probably induce more of the j anxiety and confusion that Dr. Carter wants to avoid.
In sum, Dr. Carter's basic premise regarding EBS message content that "more information is better" although generally true, should be limited to relevant information and be based on the realities of a radiological emergency. The content and focus of the SPMC prescripted EBS messages are based on concepts that assure accurate and effective messages during a radiological emergency.
JI-35, Basis B alleges that:
"The SPMC makes no provision and provides no procedure for coordinating emergency messages with participating and non-participating state and. local governments as required by NUREG-0654, II.B.7.d and Supp. 1, II.E.8."
The SPMC procedures and the processes that provide for I the coordination of emergency messages between the ORO and appropriate State and local officials in Massachusetts are L.
l
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\s,/ 1 set forth in Section III.B.4 of this testimony. These i procedures and processes assure that these officials have adequate input, knowledge of, and feedback concerning EBS messages and news releases.
Dr. Carter contends that the SPMC should take "into ]
account" the needed coordination with local officials at the county and municipal levels in Massachusetts (Carter, page i
37). He admits that this coordination planning is
" difficult" because of the nonparticipation by Massachusetts governmental agencies. With respect to the coordination of county and municipality input into emergency messages or information,.the NHY ORO coordination with state and local governments is discussed in-Section III.B.4. Both the SPMC l
((~~}\
and the CERP require local governments to coordinate their public information activities with and through the Commonwealth, not directly through the NHY ORO. This has been established because state officials need to be directly involved in these activities to assure consistency and accuracy of messages. Hence, Dr. Carter's suggestion of direct coordination between ORO and local governments on emergency messages would be contrary to both logic and established procedures. !
l l Dr. Carter also asserts that SPMC provisions are I
" sparse" regarding the ORO's coordination cf emergency g information with New Hampshire officials (Carter, page 38).
-%g
He identifies only the coordination between New Hampshire and ORO done at the Media Center by the PIC pursuant to SPMC, IP Section 2.12. The SPMC, however, contains numerous l provisions for coordination of information between ORO and State of New Hampshire officials. For example, ORO personnel are co-located with New Hampshire personnel at the ORO EOC/NH IFO, at the JTIC, and at the Media Center. This permits coordination of EBS messages, news releases, media briefings, and responses to public and media inquiries. Combined functional drills and exercises provide practical training for these coordination processes.
JI-35. Basis C asserts:
"The messages do not adequately address the issue of their source and do not
' explain who and what is controlling and 9l 4 directing the emergency response. There is no discussion in the messages of the emergency relationship between ORO and the state and/or local governments. See NUREG-0654, Supp. 1, II.E.7."
As noted in Section IV, the EBS messages clearly state that the actions being taken in response to the emergency are being carried out by the NHY ORO under authorization from the Governor of Maccachusetts. This informs the public that the NHY ORO is controlling and implementing the response, but the Governor has authorized the response. Any further information regarding this relationship between ORO and the State need not be contained in the messages for two reasons.
(. .,
~36-
f3
( ). He identifies only the coordination between New Hampshire and ORO done at the Media Center by the PIC pursuant to SPMC, IP Section 2.12. The SPMC, however, contains numerous I provisions for coordination of information between ORO and )
~
State of New Hampshire officials. For example, ORO personnel are co-located with New Hampshire personnel at the ORO EOC/NH IFO, at the JTIC, and at the Media Center. This permits coordination of EBS messages, news releases, media briefings, and responses to public and media inquiries. Combined functional drills and exercises provide practical training for these coordination processes.
JI-35. Basis C asserts:
l
'/N .
q j "The messages do not adequately address
\d the issue of their source and do not explain who and what is controlling and directing the emergency response. There is no discussion in the messages of the emergency relationship between ORO and the state and/or local governments. See i NUREG-0654, Supp. 1, II.E.7."
As noted in Section IV, the EBS messages clearly state that the actions being taken in response to the emergency are being carried out by the NHY ORO under authorization from the Governor of Massachusetts. This informs the public that the NHY ORO is controlling and implementing the response, but the Governor has authorized the response. Any further information regarding this relationship between ORO and the State need not be contained in the messages for two reasons.
(O)
L_.
l 1
First, the mersages indicate in a precise fashion that the Governor is the source and authority behind the response.
Thus, the public is assured that the State is informed and involved. Second, EBS messages should not provide a detailed explanation of the emergency responsibilities of ORO or the State and/or local governments. EBS messages should be well-focused and provide clear and concise information regarding the risk, its location, guidance and response timing. More i l
detailed information concerning the relationship between the )
Governor and the ORO is contained in the public information materials disseminated to the households and businesses in i
the Massachusetts EPZ.
JI-35. Basis D asserts:
"The SPMC provides no adequate procedures )
for ensuring that the emergency messages broadcast to the public correlate with the messages and information provided to the media by the NHY ORO and other officials."
The SPMC contains numerous provisions and procedures to assure that the broadcast EBS messages are consistent with information provided to the media and ultimately to the public. First, EBS messages are given to the PIA who is i responsible for the development and issuance of news 1
releases. Since the PIA must obtain the approval of the NHY Offsite Response Director prior to dissemination of news releases, timing and content coordination with EBS messages b
4 l
l
)
l!
/ /~s {
N, s is assured. ..The'Offsite Response Director at the EOC must approve both EBS messages and news releases before dissemination and, therefore, he is the common link to. assure consistency notwithstanding the coordination between the PIA and the PNC'in:the' developmental process. Second,.EBS messages are provided to the media.and the ORO.at the Media Center. Any inconsistencies'between the messages and the news releases would be readily ascertained and could be corrected, if. appropriate, in a timely manner before public; dissemination.- Third, SPMC. procedures provide for'the coordination of information between the Media Center and'the.
JTIC. This assures that not only will the Media Relations j and-Rumer-Genbret Assistants have accurate and timely information for responding to media and-pebkke inquiries, but also that they will review the information for accuracy.
Any
-inconsistencies in the information would be discovered in the review process or subsequently be. reported by the media er hhe-pubbie. Corrective action, if appropriate, could be taken immediately. The -remer - eentrek -preeeee -ke -deta kl-ed -kn Seebken-EllrBrEr Obviously, it is better to discover inconsistencies before dissemination to the public and the provisions and procedures embedded in tha SPMC provide a good mechanism to discover inconsistencies before dissemination. However, should inconsistent oi incorrect information be disseminated
.k
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ l
l{ .
to the public through EBS messages or news releases, the incorrect information can be ascertained through feedback processes at the Media Center and the JTIC so the correct information can be provided quickly through (1) subsequent messages or news releases, (2) press briefings, and (3) telephone information provided through the Media Relations and-Ramer-eentre3: Assistants at the JTIC. The process chosen to disseminate correct information would depend on a number of factors, including (a) the original format of the information, (b) the seriousness and extent of the incorrect information, and (c) the immediacy of the ;
needed correct information. To be sure, widespread information of a serious nature would be corrected immediately and corrected information would be available through all three processes. On-the-ebher-hand;--miner-and isehabed -m ksinformabien -er-Feealized -remers -might-be eerreeted -enhy -threegh-bel-ephene -inquiries -ab-the-PPle -in order-n ab-be-een fuse-or -eenbradieb-the-eerreeb-information ,
being -made -ava kkable -be -the -pubbie -through -the -EBS -messages and-news-releace-preees ,
{
Dr. Carter takes issue with the SPMC procedures that establish a separate entity to develop and disseminate ORO EBS messages -- the PNC -- and a separate entity to develop and disseminate ORO news releases -- the PIA (Carter, page 32). While recognizing that there are valid reasons for V
! ) <
E,l designing and implementing a decentralized information )
organization, Dr. Carter's criticism of a decentralized approach is based on what he terms a " fallacious distinction" I
between EBS messages and news releases. Id. at 33. In his j view, " emergency information is emergency information" and, thus, the processes for development and dissemination should be uniform -- i.e., centralized. Ibid. This, he concludes, would result in more consistent information being disseminated through the media to the public.
The SPMC procedures, however, do recognize a necessary distinction between EBS messages and news releases. EBS
)
messages in a radiological emergency need to be clear,
,y
( ) concise and timely. They provide definitive instructions to s- .
the public that often require an immediate response. They need to be developed, coordinated, approved and disseminated in an expeditious and effective manner. They do not have the luxury of a 36-hour lead time (or more) that is available for a response to a hurricane. News releases, on the other hand, l
provide more information to the public and usually can be i developed over more time. This distinction regarding the time for dissemination and the content of the message necessitated a division of labor to assure effective information was developed. However, the development process is not a decentralized approach as alleged by Dr. Carter.
f-~g EBS messages and news release approval is centralized in the
-_ ~
l l1 NHY Offsite Response Director. Consistency in public information is readily assured because the NHY Offsite ,
i Response Director must approve all EBS messages and news l
releases prior to dissemination.
JI-35. Basis E asserts:
"The pre-established messages set forth in the SPMC at Pro-2.13, Attachments 2-24, may be altered or modified by the Public Notification Coordinator. Pro-2.13 at 8. No guidance or training is provided this individual on the essential )
components of an effective emergency ]
message. As a result, the message (s) j actually broadcast may be less effective j than those set forth in the SPMC."
The PNC is able to perform the EBS message developmental and coordination functions because he has been specifically trained in these functions as part of the ORO Emergency Plan i
Training Program. SPMC at 2-1, pages 2.1-14; see also Applicants' Rebuttal Testimony No. 20 (ORO Prerequisites and Training) page 28-30. Supplementary training in the concepts and components required for effective emergency information f
{
including ad hoc message modification, will be provided to the persons filling the position of PNC. This training stresses the importance of clear, concise messages directed at the public that explains the dangers in terms the public can understand so as to leave no doubt about the existing conditions. A draft training program agenda has been b
On ,
T e ,q .
U .
developed and will be included in the next (1989) ORO
. training cycle to address ad hoc message development.
JI-36, Basis A asserts:
. -"NoLprovision has ever been made.in the SPMC for the news media at the Emergency. .
Operations Facility (EOF).' .The Media Canter is located in'the Town' Hall, Newington,.New HampshireE(Plan 3.7-6) which is-three to four-miles from the EOF and the EOC (Plan 5.1-2).. However, the Public Information Advisor who is responsible lfor issuing news releases and directing public information activities is located at the EOC and not the Media center.- No adequate' procedures for coordinating the activities'of.the-public-information staff at the EOC and the-personnel at~the. Media Center'are' provided. -Adequate procedures also do not exist for the coordination of the
- f e activities of Media Relations-L- representatives who will be communicating directly with the press by telephone."
Facilities and equipment for the media have been provided at the Media Center, not the EOF. Consistent with current NRC guidance, the media need not be acco'modated m at the EOF as alleged. " Functional Criteria for Emergency Response Facilities", NUREG-0696 (February, 1981). In fact, their presence there might interfere with emergency response activities. With respect to accommodating the media, it is important to provide them accurate and timely information, as well.as reasonable cocess to authoritative sources of information. The Media Center functions and processes, as described in Section II.A above, provide this type of
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1 f
=_=-_: = : -__- _ a .- - _ _ _ _ _ = _ - .
. . _ - _ . ~i
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information and access to official utility and governmental i information without interference with response activities.
Similarly, the PIA functions and processes at the EOC, as described in Section II.C, provide for the coordination of information between the EOC and the Media Center. Finally, the close proximity of the Media center to the EOF and EOC and their equipment assure that information flows will be prompt and authoritative sources of information can be readily available that might not otherwise be already !
available at the Media Center.
Dr. Carter contends that the SPMC procedures for the Media Center are faulty because news releases will be ;
t distributed only to those broadcast m'edia in attendance at the Media center (Carter, page 33). However, widespread dissemination (both local and national) of news is assured l
regardless of attendance at the Media Center because SPMC procedures require news releases to be provided to AP and UPI wire services (IP 2.12 at 5.45, 5.63). Therefore, local and national broadcast media stations will have access to all news releases in a timely manner since virtually all TV and l
radio stations rer.C ve either or both wire services.
The SPMC also provides adequate procedures to ensure that media inquiries to the Media Relations Assistants at the JTIC will be responded to with official utility and governmental information. Current EBS messages issued by the t g.
i f~ f eeerdieebe-h-respense-threegh-appropekabe-ore r-BRe r-and ababe-e f f kekeke-ee-leeabed-ka-the-Bee r--Skmuerly r-bhe-PNer .
Feeated-ka-h-Bee r-ean -previde-en-identiceF-funetten-whh respeet-be-BBS-eessageer- 'Pheer-h-Bee-ke-the-eendeh-er
.)
eenbraheed-seeree-ef-aH-informabien-be-be-disseminated-be the-pehkier JE-&&r-Baske-B-aseerbet l
- Phe-ORO-heelf-wub-be neble-be-previde 1 eeerdinated-remer-eentreb r--The-SPMe-prevides -hb bhe-Peblie-Enfermabien-Adviser-ehaH-designabe-ab the -b ime -ef-an -emergeney r -e -remer -eenbrek -eba f f7 and-appeiab-a-lead -be-assign-responshuhicer including-briefing-the-ebaff-en-the-Rumer-eentret Pekiey-Geider--Pre-arf &-ab-&rFr+r- 'Phe-Pebhe Fnfermabien-Adviser-le-be-develep-a-strategy-for reopending-be -ineerreeb-medie-breadeaebe-and g{ pereiebenb-pebble -inquiriee r--Pre-P rF&-ab-& rk rke r- ;
h -mideb -e f -an -emergeney -he -neb -the -bime -te -set -up
'V ,
the-remer-eenbrek-ebreebere-or-be-develop abrabegies-fer-reepense-be -remere ru As -e f -Amendmenb be -bhe -SPMe - f&f&&f&& P r -the -Remer eentrek-Ameisbanbe -have-been-designated-as-permanent-members of -the-ORO r--These-peshions r -there fere r-are-net-required -be l be -ebe f fed -by -the -PEA -ab -bhe -bise -e f -an -emergency -as -asse rbed by -bhie -een tenblen -basie r --Sim ha rky r -bhe -Med ie Rehabiene/Remer-eentreF-Lielsen-and-Seperviser-are l
predes igna bed -ka -the -ORG r --91 nee -h -Remer -Genbre F -Sta f f -is predeel gnated r -bhey -reeelve-h-requis he -eRe -braining -en remer -eenbrek -preeederee -and -the -Remer -GenbreF -Pekiey -Gelde r-Based-en -bheir-pes hiens -and -brahn kng r -the -Remer -Genbret Sha f f r-directed -by -bhe -Media -RehabiensfReme r -eenbret
.h
1 Sepervisar r-he-respenoble-fer-respending-be-remere r-4his reopene b hky -deee -neb -reside -le -We -PEA -ee -assertedy JF-1&r-Basie-e-aseerbet
- Phe-Rumer-Genbrek-Pekiey-seide-tPre-a rlar A%achment-bF-mandabee-Web-enky-We-Pubbie Enfermabien-eeerdinater-er-individeake-he '
designabee-are-be-disc ;;-We-emergency-whh-We !
medie-ab-newe-briefinge r-4he-knebruebiene-be-We j Pebble-Enebreebien-eeerdinater-tPre-a rba-ab-& r} riet j diree*-Wa-pereen-ecy-be = par *ieirae -in-new.
briefi nge r --Media -briefinge -are -ene -en -We -hey beeke -be -be -used -in -heeping -We -puhkie -ka fermed -and hereby-eentrekking-rumore r-4hese-briefinge-sheeld knvolve-fekk-eee-ef-experbe-end-viseek-and-graphie
' aide-be-eenvey-beehnieak-informabien-in-en underebandable-manner r-4he-9PMe-dees-neb-previde fer-seeh-an-approachru The -Rumer -Genbrek -Pel icy -Guide - t1P -a rF& r -AWeehment -1+)
has -been -revised -be -delete -any -referenee -te -We -PEG -er -We f
proper -fenebiene -ef -any -ore -persennek -ab -news -briefinge r--As nebed -earkier -in -Seebien -PF rA r -We -Ple -ie -We -e ffiehal apekeepersen -fer -We -ore -and -he -fenebiene -ab -We -Medie eenber r--he -euch r -he -ie -We -eesigned -ore -kndivideak -be inhiebe -and-parbiekpabe-in-bhe-news-briefinge-regarding-GRe reepense-fenebiene-er -aebivhies r--An-BRe -Teehnicab-Adviser i
and -a -HeakW -Physice -Adviser -ere -avahable -et -bhe -Media !
eenber-be-eeerdinabe-and-previde-beehnicakfradiebegical in formabien-frem-We-BOP-eeneerning -pkant-ebabee -and !
fenebiene -fer -prese-briefinge r-4he-Seabreek-sbabien I Bmergency -News -M anager -at -We -Media -eenter -is -respena ble -fer i he -eeerdination -and -di-seeminatien-of-news-releases v
i l
1
.t s (
eeneerning-radiekegieal-er-beehnicab-planb -hafermabien r--En l I
addhien r-the-Buergeney-News-Manager-ean-direeb-media ]
. ingekekee-be-the-appropriebe-ebuhy-er-gevernmenbat I enfleiele-ab-bhe-Medke-eenber-fer-reepense-ab-news -briefinge r-Bquipmenb r-reseereee r-and -pereennek-are-akse-avanable-ab-bhe Medi a-eenber-fer-neeeeeary-viseal-er -graphie-aide-whieh-might ,
benefh-bhe-eenveyanee-ef-beeknieak-informabien-be-bhe-media-JF-3&r-Basis-B-asserbet
- Phe-SPMe-eeeigne pubbie-informabien-pereennet reopensenhies-wnheeb-any-guidanee-ee-be-bhe manner-in-whieh-these-respensenhies-are -be-be earried-eebr--Enfermabien-een-net-[-eie} -be enfeebiteky-eemmenleabed-be-bhe-publie-enkees pebbie-infermabien-ebaff-are-fekky-informed-ef deveFepmenbe-and -have-eeeeee-be -beeknicaF-experts
( eapable-e f-addreseing -areas-e f-eneertaiaby r--Any i
g plan -whieh -deee -neb -reeegnine -bhe -public 's extraordinary-appebkbe-fer-informabien-and-dees-not specificaFFy-assign-a-rele-in-information preparabien -and -dieseminabien-te-beehn ketane-and experbe-ie-knadequaber8 The -SPMe -reeegni nee -bhe -pubbie 's -need -fer -and -right -be elear r-eeneise r-and -prempb -in formation-regarding-en-emergency ab -Seabreek -Shabien r --As -indiea bed -earlier r -the -PEA -and -the Peb Me -En ferma bien -Sha f f -ab -the -BOO -are -the -feeal -pe inte -fo r j l 1
! the -development r-eeerdinabien -and -dieseminabien-o f -publie l information-bhrengh-news-releaseefballebine-en-the-emergeneyr-The-PNe -i e -respene bbe-fer-bhe -development-and -eeerdi nablen of-BBS-messages-ab-bhe-Beer- 'Phe-BRO 'Peeknicab-Adviser-ab-bhe BOO -ke-respena ble-fer -ebbaining -beehnieak-i n fermabien eeneerning -planb -eendhiene -and -fenetiene -frem-the -Seabreek r
( I
~47-1 1
l
)
l f~
\
Sbabien 'Peehnieek-Sbaff-threuef h -the-inberface-with-the Seabreek-Stabi-en-BOP-eeerdinaberr- 'Phie-beeknicak-information l Es -bhen -made -ava kkable -fer -the -preparabien -e f -pubbi-e
- l. informabien-ab-the-Beer- 'Peehnieak-kr;fermabien-is-alee-made avaikable-be-the-BRO rfeehnieek-Adviser-and-the-BRO-Health l l
Physies-Adviser-ab-bhe-Media-eenber-se-bhab-ib-ean-be j ineerperated r-i 5-appropriate r-inte-the-news -bri-efinefsv j
)
MAG EX-9, Basis A asserts:
"The EBS messages and the news releases actually generated during the Exercise were confusing and contained conflicting information. An average member of the public who had heard over the radio or on television the ORO news releases and EBS messages in sequence would have come away with all kinds of unanswered questions. Confusion would g
have been generated, for example, regarding who/what ORO was, what had happened to town police and civil defense, what the role of the State was, what it meant that ORO was " activated," what it meant to leave the " beach areas" (how far should I go?" "what if I live there?"). Much confusion would have been generated about school children, what schools were doing, and what parents should or should not do (as is more specifically described in MAG EX-10). There was even confusion generated on Day 2 of the Exercise with respect to what people would be let into the EPZ to care for animals.
Much confusion was also' generated on both days of the Exercise due to the conflicting nature of the ORO and New Hampshire EBS messages and news releases."
To the extent that this contention asserts that EBS messages were, in general, confusing because of improper development and inadequate messages, the SPMC conceptual 4 framework for developing clear and concise messages is discussed in Section IV above. The messages identify the i
C s
l
(? s eeneerning-radiebegieal-er -beeknieak-phant-informabien r--En addibien r-bhe-Buergeney -News-Manager-een-direet-medie kagekriee-be-bhe-appropriate-abkhby-er-gevernmentet ef ficieke-et-bhe-Medie-eenber-fer-reepense-ab-newe-briennge r-I Bqeipmenb r-reneureee r-and-pereenneh-are-ahee-avanable-ab-bhe Media-Genber-fer-neeeseary-viseaF-er-graphie-aide-whieh-might ;
i i benent-the-eenveyanee-ef-beehnicab-information-be-bhe-medie-JE-}&--Basis-B-eeserbst
- Phe-9PMe-eesigne-pubkie-lefermabien-pereennet reopenekbkhbies-withenb-any-guidenee-ae-be-bhe l manner-in-whieh-bhese-responsibi Mbies-are-be-be !
earried -emb r--En fermabien -een -neb - feie 3--be l effeebively-eemmenicabed-te-the-pubbie-enless ;
pebbie-informanen-ebai5-are-feFFy-informed-ef l development-and-have-aeeees -be-beeknical--experbs
.Q eapable-e f-addreeeing-areas-of-uneerbeinty r--Any '
,Q
, plan -whieh -dees -net -reeegnine -bhe -pebbie 's embraordin ary-appebibe-fer-lefermabien-and-dees -net speekficeFFy-aesign-a-rele-kn-informabien ,
preparabien-and-dieseminabien-be -beekniciene-and 4 experbe-le-inadequater*
The -SPMe -reeegninee -bhe -pubbie 's -need -fer -and -right -be elear r-eeneise r-and-prompb-informabien-regarding -an-emergeney ab -Seabreek -Shabien r --As -i nd icabed -earlier r -bhe -PEA -and -the Pebbie-Enfermabien-Sha ff-at-the-Bee -are -bhe-feeak-peinbe-fer the-development r-eeerdisabien -and -diesemina bien-of -pubbie in formabien -threagh-news-releases /beFlenne-en -the -emergeney r-The-PNO-le-responsible-for-bhe -development-cind-ceerdinablen e f -BBS -messages -ab -bhe -Bee r--The -BRG - PeehniceF-Adviser -at -the Bee-is-responsible -for-ebbekning -beehnicak-ka fermabien
' eeneerning-planb-eendibiene-and-fenebiene-frem-bhe-seabreek r
Stabian-Technical-Shaf f-through-bhe-katerface-with-bhe O
Seabreek-Sbabien-BOP-eeerdinater r--Thie-beehnicab-informabien is -then -m ade -available -for -the -preparabien -e f -pebl-he informabien-ab-bhe-Bee r--Technieek-informabien-is-alse-made
.q avai4able-be-the-BRe-TechnieeF-Adviser-and-the-BRe-Heekth i
Physies -Adviser -ab-bhe -Media -eenber -se -bhab -kb -ean -be kneerpera bed r-if-appropriate r-lete-the-news-briefinger MAG EX-9, Basis A asserts:
"The EBS messages and the news releases actually generated during the Exercise were confusing and contained conflicting information. An average member of the public who had heard over the radio or on television the ORO news releases and EBS messages in sequence would have come away with all !
kinds of unanswered questions. Confusion would ;
, have been generated, for example, regarding ,
who/what ORO was, what had happened to town police ano civil defense, what the role of the State was, what it meant that ORO was " activated," what it meant to leave the " beach areas" (how far should I go?" "what if I live there?"). Much confusion would have been generated about school children, !
I what schools were doing, and what parents should or should not do (as is more specifically described in MAG EX-10). There was even confusion generated on Day 2 of the Exercise with respect to what people would be let into the EPZ to care for animals.
Much confusion was also' generated on both days of the Exercise due to the conflicting nature of the ORO and New Hampshire EBS messages and news releases."
To the extent that this contention asserts that EBS messages were, in general, confusing because of improper development and inadequate messages, the SPMC conceptual framework for developing clear and concise messages is dircussed in Section IV above. ,
The messages identify the
.i
/
role and relationship of the ORO and the State of l Massachusetts, p_ee also discussion on JI-35, Basis C, suora.
Providing more information as suggested by this contention would detract from the required message and, ultimately, result in' confusion to a large segment of the receiving population. The amount of detailed information in EBS messages suggested by this contention is not needed for an effective emergency response.
In addition, EBS Message #3 which announced the GENERAL EMERGENCY specifically directed attention to the pre-emergency information that was distributed to residents and businesses in the EPZ. It is in this material that people would find the answers to general questions such as:
"who/what ORO was," "what had happened to town police and Civil Defense," "what the role of the state was" "what it meant that ORO was ' activated'," "what it meant to leave the
' beach areas'?" Egg-Appkicante2 -Rebubbeh 'Peebimeny-Nor-7-fer a -debakked -descripbien-of -pre-emergency-informabient EBS Message #1 also referred people to the pre-emergency information. Thus, at the SITE AREA EMERGENCY, which closed the beaches, people were referred to more specific information which might provide the answers to their general questions concerning the emergency and the responding organizations.
k.
-_-___-_--_----_______-____-.-_-_______________=_
The-issues-raised-eeneerning-the-eenfesien-le-the-BBS {
messages-eeneerning -the-eare-of -Hvesteek-i n-the-BPS -are whheeb -basis r --ORG -News -Release - f a5 -a nd -eerrespending -BBS Message - f & -i-seu c d -en -Bay -& -e 5 -bhe -Bxere kse - FAhachment -e hereber-speci ficany-directed-farmers-whh-Hvesteek producing -feed -preduebs -en -where -and -hew -be -temporarhy -re-enter-the-Massachusebbe-perbien-ef-the-pleme-BP&-to-bend-be their-animake r--Eb-ahee-sbated-bhab-the-acMen-had-been approved -after -extensive-sampHng-and-analysks-ef-the-six Massachusehe-eemmenhicer- 'Phis-message-was-ehear-in-thab-it pertai ned -be -no -obher -an kmeks -whieh -may -have -been -le ft ena bbended -in -the -BP& r --Perthermere r -News -Reheese - f a& -and -BBS Message-f&-repenbed r-and -thes -rein fereed r-informabien previcesky -issued -be -f armers -en -Bay -F -e f -the -E xercise r --eRe News -Release - f k9 - tAtbachmenb -B -herebe F -issued -en -Bay -F -e f -bhe Bxe re kse -beld -d ai ry - f a rmers -w hh in -the -BP& -be -eenbeeb -NHY e f flekels-ab-access-eenbrek-points-fer-specifie -instreebiens for -reenbe ring -if -bhey -had -a -need -be -rebern -be -bhei r -f a rms r-The -message -en -Bay -a -ahee -directed -the -feed -predeet -hvesteek farmers -be -speci fied -aeeess -eenbrok-peinbe -where -bhey -weebd receive-desimeters-and-wr hben-insbreebiensr-EF-any-farmers were -enelea r -w hh -respeed -be -the -message r -bhey -eeeld -ehher can-the-specified-nember given-ab-the-end-ef-the-messager-er p reeeed -be -bhe -eeeess -eenbrek -pei nb r --Howeve r r -f arme rs generany -knew -whieh -animake -sheeFd -be -abtended -be -and -thes
f weeld -neb -be -een fased -by -the -message r --Per -example r -gra eing animake - te rg r r -horses r-eabble) -de-neb -need -dai Fy -eare -if -feed is -avaklable -whereas -peekbry-and-dairy-animake -require -dakhy earer The issues raised in this contention basis regarding the conflicting school messages in Massachusetts are addressed in Attachment E MAG-BX-9r-Basi-s-B-and-in-Applicants'-Rebebbet Tesbimeny-Ner-3-9-(-Geheeh-Prebeehive-Aebiens) r Additionally, to the extent that this contention asserts that there are inadequate provisions in the SPMC regarding the coordination of the Massachusetts EBS messages and news releases with the New Hampshire messages and news releases, this coordination at the Media Center and the EOC is discussed in Sections III.B.1 and III.B.2 above.
MAG EX-9. Basis B asserts:
"The EBS messages and news releases wete not accurate in many respects. For example, there was misinformation about the Newburyport schools in ORO EBS #3, as FEMA has noted. Also there was a serious mistake in News Release #15, which said that the overturned lumber truck (described in more detail in MAG EX-13) was blocking traffic on southbound I-95."
The alleged inaccuracy in ORO EBS #3 concerning the Newburyport schools is addressed in Attachment E Applicanbel Rebubbab-Testimony-Ne r-3-&-f&eheel--Prebeehive-Aebiens) r With respect to the language in ORO News Release #15 which gave the location of the overturned lumber truck as blocking
(
i traffic on southbound I-95, it is conceded that the i l
description of the location was not as clear as it could have been since the location of the truck was on an entrance ramp to southbound I-95. However, this description was not a l
" serious mistake" as alleged.
To be sure, the mistake could have caused some people l t
southbound on I-95 to think that their route was blocked at that location. However, if they would have been actually i experiencing free-flowing traffic on I-95, they probably would not pay too much heed to the information. Evacuees wanting to enter southbound I-95 at the scene of the incident, on the other hand, would have been successfully re-routed by the news release or traffic guides / police to another I-95 entrance to avoid the overturned truck. This fact is confirmed by the FEMA Exercise Report, Applicants' Exhibit 43F, which states (page 224 of 428): "Some, traffic had to be diverted to another freeway entrance and the detour g i
t description in the message was correct."
In any event, the amount of traffic on I-95 that would have been affected by the confusing location description 1
would not have significantly impacted a timely emergency response. Any traffic exiting from southbound I-95 because of the news release would have gone westward or southward !
l away from the EPZ in response to traffic control point l directions.
f d
.q Li, ;
u l((' ~4 .
\ss i MAG EX-9 ' Basis C asserts:
"The news releases were not timely in many )'
instances. Events were repeatedly not reported at' the Media Center.until long after they had occurred, as was the case with the overturned lumber truck, which was not reported-until long-after it had began (sic] blocking traffic. -
Messages and information were not forwarded promptly from the EOC to the Media-Center and the Joint Telephone.Information Center, as can be seen from the times notes on many of the player generated material. See also FEMA report at 217.
- In addition, and perhaps more serious, ORO generally. lagged behind New Hampshire in' issuing PARS to the public,.as can be.seen clearly in the time lines contained in the FEMA report. On Day 2, for' example, it took a very long time after the State of New Hampshire for ORO to get'an EBS message out regarding farmers re-entering the EPZ to care for livestock.
The overturned truck creating a traffic impediment
!q s q_,/ occurred at 1745.
News Release #15 was issued at approximately 1900. Under the circumstances, this was not an unreasonable delay in the dissemination of the information considering that the information must be conveyed and confirmed in some manner. Upon notification that an impediment had occurred, traffic guides and/or police would have been dispatched to the impediment to establish appropriate rerouting as determined at the EOC. While some l traffic may have been impacted by the impediment, most traffic would have been physically rerouted in an efficient manner in advance of the broadcast. In short, the news of the impediment would not have affected the efficient and coordinated emergency response to the impediment.
N .. j
-sa-
[ _ _ _
This contention also asserts that ORO generally lagged O
behind New Hampshire in the issuance of PARS to the public as j depicted in Table 9 of the FEKA Exercise Report (pages 88-96 of 428). This assertion illustrates a misconception by the Interveners. ;
1 In a real emergency, PARS will depend on the risk to the l affected public. Recommendations to evacuate a specific population, for example, will depend on the existing and i
projected risk of exposure. That risk is location and time specific depending on meteorological conditions, distance from the release, and other factors concerning the status of .
response functions. These factors pertaining to risk are built into the Exercise scenario. Thus, communities in New Hampshire might De evacuated sooner than communities in Massachusetts depending on meteorological and distance factors. The Exercise scenario indeed required communities in New Hampshire to take protective actions sooner than communities in Massachusetts based on the plume trajectory.
Thus, EBS messages reflecting the PARS were issued sooner in New Hampshire than in Massachusetts. This was consistent with the Exercise scenario and found to be adequate by FEMA.
See-else-Apphi-eants'-Rebebbah 'Peshimony-Ner-26-(-Prebeehive Aebien -Reeemmendabiens -Made -by -NHV -ORO -Bering -bhe -Exerc ise )--
FEMA found no deficiencies in the demonstration by ORO of Objective #13:
(
m i
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ )
9 ,
" Demonstrate the ability to coordinate the l formulation and dissemination of accurate information and instructions to the public in a '
i timely fashion after the initial alert and notification has occurred."
In the FEMA Exercise Report (page 223 of 428), FEMA stated that " Instructions (EBS messages) were formulated, approved,:and distributed according to the system described-1
'in the plan." .j MAG ~EX-9. Basis D asserts: l j
"The timing'and content of ORO's public information was not coordinated in any systematic way with the public information (sic) being released by New Hampshire. This_would have' led-to further-
. confusion and mistrust. Comparison of the messages released attabout the same time by NH and ORO reveal-numerous differences that needed to be 7O, resolved and were not. Th'e process for coordinating the.information-released was shown to be ad hoc and therefore' inadequate."
The process by which the ORO and the State of New i
Hampshire coordinate the-dissemination of emergency ,
information at the Media Center and the EOC is described in Sections III.B.1 and III.B.3 above. That process discloses that coordination does exist between ORO and the State of New Hampshire before EBS messages or news releases are disseminated to the public.
EBS messages for Massachusetts are developed by the o l
Public Information Staff in the EOC and are coordinated with
'the New Hampshire EOC Operations Officer in the Concord EOC as well as New Hampshire officials in the EOC prior to final ,
- k. '
l
s approval by the NHY Offsite Response Director. Overall coordination of EBS messages is further ensured by the fact that the Media center provides a mechanism and a facility for representatives of the principal State, Federal and utility response organizations to coordinate and interact on public information matters. In addition, representatives of the ORO, ERO and the State of New Hampshire review all news releases and EBS messages at the JTIC prior to distributing them to their staff. This provides another process for the review, coordination and correction, if necessary, of EBS messages and news releases.
MAG-BM-F7--Basis-e-asserbst EBering-the-exereise r-eRe-persennel-responded-be various -inquiries -frem -bhe -pubbie r --As -ks -shewn -in f the-feFFewing-examphee r-bheir-responses demensbrated -eRe %-inabiblby-be-dispek-remers r-te eerreeb-misinformation r-be-previde-neeessary7 aceurabe-and-bimely-informabien -be-the-pubbie-and be -ensere -bhab -seeh -i-n fermatien -is -eeerd in ated -and nen-eenskiebingr- rPhese-examples-ef-repeabed-errers demensbrabe -a-fundamenbek-fkaw e-Enquiry /Remer-Memes f EERM E P -i c,g g e d -ab -bhe -feFFewing -bimes -with -the fehlewing-eahkers e -F r}&- fBrownP r-& r&&-Randolph r- tne timeP- tekark P r-} eF&- teeFFinsP r-} e}&- fLynnP r-+ r&B terand P P-b rF&- fBavi4P r-a r+5-tSanders P r-} r10
(-Bradshaw P r-G el&- tPrances P P-F r&&- fShoneP P-7 P10 fMeenirePr-16e+&-(GenesPra The -process -of-handking -misinformation -and-remer -brends is -described -in -Seebien -EEE rB r} -e f -this -bes timony r --The -remer eenbrok -p rocess -le -designed -be -ensere -bhab -the -Media Rehabiens -and -bhe -Remer-Genbrek-Assistante-respond -be -media er-pubbie-inquiries -by-esing -enhy-in fermabien-frem -approved ;
)
\
BB9 -seeeages -and -news -releasee r -ae -wen-ae -We -approved i
feetuak-kafermabien-ka-Weir-peshien-packebe r--While-Weee Aeekebenbe-eheeld-abtempb-be-be-reepensive-be-the-kngeiryr .;
they-are-knebreeted-te-respond-by-eekny-effielek-kafermatien r-
\
They-eheeld-neb sp;;ukate-er-previde-any-kafermabien-ewer Wan-We-ef fiekeh-knfermatien-er-reasonable-knfereneee-frem )1 Wab-informabien r--Thie-aseeree-Wab -kafermabien-given-be l l
inquiriee-win-be-elear r-eenei-se r-aeenrabe r-and-eurrent r-PBMh -;;;;;;; d -We -remer -eenbreF-preeeee -deri ng -We -Exerei se ka-he-evakeabien-of-ebjeehive-H-whieh-ebatest EBemenebrabe-We-abuhy-te-eebahneh-and-eperate rumer-eentrek-in-a-eeerdinated-and-bimeFy-fashienra The-PBMA-Brereise-Reperb-(-pagee-2&&-&M-ef-+1Q
(
eenekuded-Watt
- Phe-New -Hampehire-Yankee-effeite-Reepense -
Organkeabien-demenebrated-We-abuhy-be-eebabbish and-eperabe-remer-eenbrek-in-e-eeerdinated-and timeky-feehlenru The -FPle -wee -eebabbished -adiacenb -be -We -NHY -ORO Bee-for-We-eendueb-en-remer-eentrek-eperabiener-The-fachhy-wee-abaffed-by-remer-eentret assiebanbe-frem-We-NHYr-NNY-orer -and-We-Shabe-ef New -Hampshire r --As -many -as -six -eene -eeeld -be handled -eimehaneensi-y r --AH -e f -We -eba f f -were -weH i n fermed -and -were -generany -heph -ep -be -dabe -en exereise -evenbe r --AH -e f -We -eba f f -per formed -weH .
in -respending-te-eene-and-were-kafermabiter help feF r -and -eympahebie r --h -wehben-reeerd -was made-ef-each-eaHr-inekuding-a-brief -syn;psis-ef We -eaHer 4 -eeneern r --eane -were -re ferred -de -We supervisere-when -a-quesbien -er-problem-requi red fenew -up r --The -supervise rs -i a -bu rn -were -very responsive-in-leeating-We-requi red -i nfermabien -er heFP -and-caning-back-We-individualer 1
(
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earefek-ahenbien-was-paid - be-idenbkfieebien-ef 0,
remer-brende r--The-abaff-and-eepervisere-eeeperabed in-debeeting-brende-in-the-eener--EF-anr r r
[-sietr r r-bring-it-be-the-ahenbien-of-the ,
superyksere r --The -NHY -ORO -supervieer -akse -keph -a running -leg -en -bhe -eene r -serbed -by -bep he r -be -help l idenbify-remer-brende r--Any-seeh-brende-debeebed !
were-prempey-breeght-be-the-abtenbien-eF-the Maison-in-bhe-Media-senberr i 1
While-MAG-BM-Me-mahee-a-bkankeb-ababemenb-bhab-eRe I k '
efferbe-be-respond-be-pubble-ingelries demonstrated-a fendamenbek-flaw rt-a-eleser-leek-ab-bhe-InquiryfRamer-Memes (EERME) -kiebed-in-the-eenbenbien-and-shews-the-feHewingt et Sufficienb-expkenation-be -quesbiene-with-respeeb-he idenbiby-ef-braffie-guides-ab-interseebiene r-( tearksen-frem-Amesbury-ab-Ha&F 4 by Bispened-fears-of-the-safeby-ef-rehabtves-within the -BPa r -- feeHins -ab -M k& -and -Games -ab -k&} &t et eerreeb-advice-be-persen-who-wanted-to-rebern-be bhe -BP& -fer -personak -e f feeks - fLynn -ab -M}&t i l
dt Gerreedy-channeled-media-regnesbe r--(Sanders-ab MM r -Bradshaw -ab -ME& r -Shene -ab -MG& r -and -McGui re ab-WF&t 1
l In -etdditien r -the -ERMs -shew -thab -o f ben -bimes -the -Rehe -weeld l l
read-an-appropriate-News-Reheese-be-answer quesbiens-ef-the e aHers r -- fea rkeen -a b -Ma& -and -Geni ns -ab -Mi&)-r l The -abl-eged -inaceeracy -o f -ORO -News -Reheeses - F G -and - H eeneerning -the -PARS-fer-Sahi-abury-and-Ameebery-Scheeks -and
(
-S8-
seheek-ehkFdren-le -addressed-in-AppFieants '-Rebubbat Tesbimeny-Ner-F&-(-Schoeh-Prebeehive-Aebiens)-r- 'Pe-besh-bhe J'PFO -precess-reef ardknef-misin formabien r-the-PBMA-Rhe-chairman end -the -NHV -ore -Bxereise -Bi reeber -had -bhe -eentrek -eeFF -place eaFls-be-the-J'Ple-r cia c s binef-eFari ficabien-o f-the-in forma bien in-the-news-releaseer-'Phe-remer-eentrek-process-described-in Seebien-EEE rB r}-werhed-es-designed r-and-eFarifyinej informabien-was-made-avaiFable-be-the PPle-and-in-a subseefuenh-news -release-and-BB9-messaefe-disseminated approximately -one-hear -af ter -News-Release-Ne r-7--was -issued r-PEMA-Exerekse-Reperbr-APPFleants'-Bxhibib-+}Pr-ab-page-E2 +-ef
+2&v
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t_-_____-____-____ _- _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ - -. _ _ _ _ _
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ATTACHMENT A (Prescripted EBS Messages)
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-Attachm3nt-A (Pago 1 of 76)
-EBS Title Pago 1 of 2 file'name
., Prerecorded Generi Alerting Message
,9t "7502.TXT'
)
'A s_J203.TXT Prerecorded Beach Closing Alerting Message EBSO4.TXT' Prerecorded EBS Activation Advisory Message '
.53505.!XT Prerecorded Alert Message f ESS06.TXT Alert Message (No Release of Radioactive Material)
ESS07.TXT Alert Message-(Release of. Radioactive Material) I
- E3508.TXT Prerecorded Site Area Emergency Message ISSO9.TXT Prerecorded Site Area Emergency (Seasonal Closure of Beaches and Wildlife Refuge) Message (May-15 to Septemmer 15)
IBSl .TXT ~ Site Area Emergency Message (No Release of Radioactive Material: Seasonal-Closure of Beacnes and Wildlife Refuge)
ESSil.!XT Site' Area Emergency Message (Release of Radioactive.
Material: Seasonal Closure of Beacnes and Wildlife Refuge)
ISS11.TXT Site Area Emergency Message'(Sheltering / Communities; Seasonal Closure of Beaches and Wildlife Refuge),(No Release-of Radioactive Material)
'MP12.IES Site Area Emergency Message (Sheltering / Communities ;
[i[s,s/ .
Seasonal Closure of Beaches and Wildlife Refuge) (No Release of Radioactive Material)
I EDS13.!XT Site Area Emergency Message (Sheltering / Communities:
Seasonal Closure of Beacnes and Wildlife Refuge) (Release of i Radioactive Material)
TMP12.E25 Site Area Emergency Message (Sheltering / Communities;.
Seasonal closure of Beaches and Wildlife Refuge) (Release of i Radioactive Material)
EBS14.TXT Prerecorded General Emergency Message EDS15.TXT Prerecorded General Emergency (Seasonal Closure of Beaches and Wildlife Refuge) Message (May 15 to September 15)
EBS16.TXT General Emergency Message (Sheltering / communities; Seasonal closure of Beaches and Wildlife Refuge) (No Release of l Radioactive Material) ,-
l TMP16.EBS General Emergency Message (Sheltering /Communitient Seasonal closure of Beacnes and Wildlife Refuge) (No Release of Radioactive Material) .
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Att2chscnt A (Paga 2 of 76)
Page 2 of 3
'ECS17.!XT General Energency Message (Sheltering / Communities: Seasonal Closure of Beaches and Wildlife Refuge).(Release of Radioactive Material)
TMP17.ISS General Emergency Message (Sheltering / Communities: Seasonal l Closure of Beacnes and Wildlife Refuge) (Release of Radioactive Material)
ISS18.TXT General Energency Message (Evacuation and Sheltering; !
Seasonal closure of Beacnes and Wildlife Refuge) (No Release l of Radioactive Material) {
TMP18.ESS General Emergency Massage (Evacuation and Sheltering; Seasonal closure of Beacnes and Wildlife Refuge) (No Release of Radioactive Material)
I3519.TXT General Emergency Message (Evacuation and Sheltering; Seasonal Closure of Beacnes and Wildlife Refuge) (Release of Radioactive Material)
TMP19.I55 General Emergency Message (Evacuation and Sheltering; Seasonal Closure of Beacnes and Wildlife Refuge) (Release of Radioactive Material)
E3520.TXT General Emergency Message (Evacuation; Seasonal Closure of Beacnes and Wildlife Refuge) (No Release of Radioactive Material) .
TMP20.EBS General Emergency Message (Evacuation: Seasonal closure of Beacnes and Wildlife Refuge) (No Release of Radioactive Material)
ESS21.TXT General Emergency Message (Evacuation: Seasonal Closure of Beacnet and Wildlife Refuge) (Release of Radioactive Material) .
TMP21A.ESS General E=ergency Message (Evacuation; Seasonal Closure of Beaches and Wildlife Refuge) (Release of Radioactive Material)
TMP213,EBS General Emergency Message (Evacuation; Seasonal Closure of Beaches and Wildlife Refuge) (Release of Radioactive Material)
EBS22.TXT Downgrading of Energency Message EDS23.TXT TerminationofEmergenchMessage ELS24.TXT Supplemental Message 1 - Bus Route Times EDS25.!XT Supplemental Message 2 - Parents with School Children in Evacuation Areas
.s L___ -_ _ _
I Attachmsnt A (Pago 3 of 76)
Page 3 of 3 l
// 1526.7%T Supplemental Message 3 Precautionary Actions for Farmers,
\,,) . Farm Workers, Food Processors and Food Distributors TMP26A.E35 Supplemental Message 3 - Precautionary Actions for Farmers, Farm Workers, Food' Processors and Food Distributors TMP265.E55 Supplemental Message 3 - Precautionary Actions for Farmers,
< Farm Workers, Food Processors and Food Distributors 1
EDS27.TXT Supplemental Message 4 - Emergency Actions for farmers, Farm
- l Workers, Food Processors and Food Distributors DELDISA.IBS Delayed School Dismissal l DELDISS.EES Delayed School Dismissal l a
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Attachm2nt A (Pago 4 of 76)EBS02.. .s_. ,
i Page 1 of 1 l
FiEREC:EID GDERIC ALERC2C MESSA2 i
k Data P m uge Released ****** '
Time Massage Released ******
Baleased bf:
NHY Cffsita Raspct'sa Directc:-
"Attent.icn. 7.ere is a proclem at Seatrcok Nuclear Power Station. L7 cn your radic fcr :x:re ir.fcr:ati:::n,a l
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-.. Attechmant A ( Pag 3 5 of .76) .3503.TX,. j j
Page 1 of 1 nextn.nuw EEAG CZSDC ALERrrG MISEME I (English and Ca. M an Frencn)
Data Massace Released **
- Time Massage Released ****** - -
Faleased By:-
NHY Offsita Response Di. m "At:anticn. There is a Wem at featzeck Nuclear Power Staticn. Imave
- .".a teacn area at ence and ::.7 cn your radio fcr :rze inferrauen."
e
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Attachm3nt A (P ga 6 of 76)
EBSO4.TXT Page 1 cf 1 j rw.r " ww EES ACIn%TIQi ADVI5ORY N l
i Date Maca ?e Released ****** i Time Maauge Released ****** .
Released bf :
NHY Offsite Rascense Direcm--
',% L~ cert'.:= tais p= cram because of a local emerceref. ~ ~ ant ir.fc:matien will fcliew. his is tc; a test."
(TGE)
'% intar==t this rw&- to aed. vata the 1ccal hgency B.h. System at the request cf the Governor cf Mammam and public health officials. I This messace is direc ad to Wus in the c=munities of e=H* f.
An=en -/. Me -e. Newtir/. Mest Newtirt 5.nd Newtirih m.
N iS E a taSt."
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c c ' Attachment A (Page 7 of 76)-
- EB505.TXT
- ('
Page 1 cf 1 FRERB%:RDED ALZRI MESSME Data Massaan Released ******
- i::n Massage Releasac ******
Released by:
NHY Cffsita L gsut Dillictcr "We intal"r"*",t this pgam tc br IX2 you the follow 1nl2 messace. I.cDCriant 4 .fcr::stion fcr una c=mmunities of o14 =W*v. Am==nw. Mew. Newtury .-
- f. Wert Newne/ and Newna ,*TP*
Will fcllCW. This is 33 & tast.
t f
2.are is a problem at Saabreck Nuclear Power Stacon. It has baan classified as an ALERT. An ALERI presents no danger to puclic health and safety - any release of radioactive natarials would 1:a .11mitad to levels
.all below those. sat by the United Statas Envarenarntal Precaccion Acency.
' The GcrJernce of Massachusetts --.i that no action is required by the
,( general punlic at this time.
The purposa of darlaring an ALERE is to make sure that samtgency workers are
- avm41=h1= to i g.1 if the situation h more marious.
The alarting system for Sammetok Stat:.cn.- which includes sirens, m alert radios and m.q massaams - will be put into action if plant safety is threaraned.
~.n additien, anarcanc=/ information br:cnuras are mailed annually to residents of the Massacnusects comunities of <=1d**w A " "v .
Man w. Nauhw. Weme rir *wv and !!r %wvervr e. If you are in any of these connunities you should look up that amargency information. If thana are unavm41=h1=, information can be found in area talephans books. This inferze-icn could be helpful in urA.- drq eature massages.
If you know of any naiahbces or cce with hearing or lary;uaos proclans, please inform them of this message.
.Q1cm again: An ALERP has been declared at 'Seabecak Nuclear Power This - will be repeatad frequently an this station until new l information is availahla. Stay tuned to this station for the latest ;
official irlczzation. '
l p If ieu are in any of the New F=Wre eastarn Rockingham County cxzmaru. ties, you should tuna to a local radio staticn in New Feire for D. news about your community.
Actions reccamorried in this messaan are intended only for perscra in ommmmities within tan allas of Saabrock Station."
Attachmsnt A (Pcgo 8 of 76)
IBS06. TIT Page 1 of 1 Gi ALERP PF SAGE
(?C RELEASE CF RADICACII'/E FATERIAL) i i
Date Maenge Releasec ****** !
Time Ma*wre Released ******
i Relone.ari bf:
NHY Cffsite Respcr:se Di.h~-
"An Alert ==ndition was +1 m'ud at ****** t-day at Seabrock Nuclear Power Stacen. An ALERP presents ne danger to public health and safety - any release cf recicac=ve ratanals uculd he li=im:i to levels well belcw those set Of the L?.:ted Sutes Er:v1._ ad Pr=acticn Acency.
The Governcr cf P.sssae-~ met:s reemmanos that no a=i::n is recuired 6f t .e general ;:uclic at t".is time.
For additicnal emercerx::y infomation, residents of *A14eM'"/> Va*M"v-ww. Newtx=-/. West NewMW and NewMm should lock.up tua annual
%=c/ informanen t=ecnures ab:ut Seat =cok Staticn which were mailed to them. If these are unavntlable, infomation can also be fcund in area i talepnene tecxs. Sis irdemation could to useful in ucha@ fut=e me= =ges.
If you knew cf any neichb:=s er coMr.us with hean.g er larquace prcela, please infcm tnam of this messace.
Once acain. SeadrocK Stancn is in an Alert ==rdition. 2ere has been no release of radianen. No release of radiacen is atout to ccc=.
This nessace will te repeated every fifteen mirnrc.as er urrtil new infcmancn is available. Keep tunnd to this statien fcr the latest cfficial intcr:auen. ;
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If you are in any of the New Ma-him eastern NJmt Ccunef j emimmities, you snculd tune to a local radio stancn in New Fa=Mi'llt for 1 news about your cc=nunit'/."
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. . t m , 'Attachmtne A (Pag 2 9.'of 76). .j l'
- l. EBS07.TXT
- Q '
- \M ;Page 1 of 1-
~
ALERT MESSAGE ;
i 1
(REEZASE CF RADIOACTIVE MATERIAL) - .
Data Fa==me= Released ******
, -Time Massage Releasec ****** -
Released bf:
NHY Cffsita n r .a Director "An Alert condition was declared at ****** tcday at sentrack Nuclear Power Station. An AT.Dtr presents no dancer to puclic health and safety - any.
. j releases of radioact:.*/s matar:.a1 would be 11.mitad to levels well below those
-set by ca United Statas Erm w .M Fhuen Acency. . A limitad release !
cf radiation into the air did occ:.:r at ******,. tut it does not present a dancer to people'near e.e plant.- ,
The Governor of Massachusetts rarrmerids that no action is re@ by the general public at this time.
3"( _ For additional emergency infernation, residents of salisher[ Ammatury. '
/_ = = -- ;*-M*v. Weert t'-%wv arti NS**W should lock up the annual
, amargency information tracnures uru.ch were mailed to them.. If case are unavailahla,'inforEntion can also be found in area talepnene backs. This intcrmation could-be useful in urA.-uing future messages.
If yc.a know of any nelchtcrz 'er co-+cekers with hearig or languace proclams, please intczm them of this message.
Cnce again, Seatz:cck Station is in' an Alert ctruiition. "here has been a limitad release of rad 4=e4m at taa plant sita. It does not present a !
danger to papple near the plant and is well below levels set by the United i Statas Environmental Precaction Agency.- i This message vill be repeated.every fifteen minutes until new information is ,
available. Stay tunsi to this station for the latast official information. 1 If you are in any of the New Fe_re ematern Rockingnam County l communities, you should turn to a local radio station in New ."P4m for news about your ccumunity." .. ;
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1 Attachmnnt A (Pago 10 cf 76)
ESS08.TXT Page 1 cf 1 G l rmw c<.uID SITE AREA EMER22CY MESSAGE !
Date Fam age Released ******
Time Fa=u ge Released ******
Relam ad bf:
NHY Cffsite Response Direc=r "A SIIE AREA EMERG2CY has teen r'ar 1ared at Seabctek Nuclear Pcwer Station.
A SI*I AREA EMERGE 2CY neans that scme sien.lficant release of radicac=ve raterials cculd cc=.::, althcuan any releases are ne excected = cc teycrd levels set ty tra Lhited States Erth.=d Pr tection Agency, e.w near
- na SeacrocK Station site b:undary.
l ?a New Ha::nshire Yankee Offsite Resa::nse Organization Pas teen nctified and is i.T=m. ming to the Wem. Da New Hamosni e Yankee Offsite Respense Direc=r is reviewing site ccnditions at this ti:na and is dheing tra s1=atrien with Ma==-~w.s govern:nent efficials. '
3a Governcr of Mamur-'t:satts rW the fcilcwing:
'!he Lhited Statas ccast Guard has been recuestad to enforce a five .ile safety =ne in the ocean waters near Seatecak Station. All offshcre teaters near =a plant are advisad to relocate to vatars f:rther than five alles frc=t tna planc. cr return to their local marinas. Eontars snculd not reenter ::a ocean safety =na until fur =ar notice.
".n addition, sa=.y= y infermaticn trcct:2res are mailed annually to resicants of the cc::anun.1 ties of e.al kher. ma=Mer. hw . Newbtr-r *h Newbtry. afd Newhw. If you are in any of these r"mmnities, you shculd lock up that emergency information. If these are unavailable, information can to found in area telepbcne teoks. 'Ihis information could bli helpful in urzkasding f.:::re ne== rust.
If you know cf any neightcrs or cNM pith hearing er languace Wems, please inform them of this message."
~
"cnca acain: A SITE AREA EMEH22CY Pas been declared at Seabetek Nuclear l Power Station.
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'Ihis messace will be repeated f.Wy en this station uncil new infc=natica is available. Stay t:rmd to this EES station fcr the latest official 1.fcr:ntion.
If you are in any of the New F-MIM eastern Rockingham Ccunty
'u c'rmrtities, you sbculd t:.rm to a 1ccal radic station in New Hamosnire fcr news ateut your caccunity.
Acticns rarw=andad in this r==ar= are intended only for perscms in ec=nunities within tan miles of Seabetok Station."
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Attachmont A (Paga 11 of 76) )
EBSO9. HT ll Page 1 of 2 FIERB%:RDED '
Srrr AREA DesGEncY (SEASONAL C*.CSURt CF BE7 DES AND WIII: LITE REFUE)
MESSAGE (May 15 to Sepr=*=r if)
Ditta Messace Released ******
Ti:le Massaan Released ******
Released ty:
NHY Cffsita Response Dialect =r "A SIII AREA DG3CENCY has been Har imrad at Sentreck Nuclear Power Station.
A STIE AREA DGWGDiCY neans that same slan.ificant release of radicaccve ratarials could cc==, althouan any reinases are not expected to ce bevond
{'
evels set by cA United States Enyt.-d Prcraccen Agency, excect near ce Seacrecx Stacen site bouncary.
?A New Hamcanire Yankee Offsite Rescense Or=ani:stion has been notified and is responding to the prcolen. ?A New Hancanire Yankaa offsita Rescense Directer is reviewing sita corstitions at this time, and is d4=-"*=rx; t'2a situatien with Massachusetts governcent officials.
As a pr=-me4rwt, 24 Govutnce of Massachusetts has roccessended the clositzr i of beacn and parx armas, frca '214=^m/ to Plum Island, incluiing the Parkar River Nananal Wildlife Ratuga. Perzens at trase beaches and parks or visiti:xJ the nauenal wildlife refuge should leave tncse areas i--wiiataly. ;
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'n additi=n, tre united States c=ast cuare has been requestad to enteres a five-elle safety ==ne in ocann Waters near Sandccok Stauen. All cffshcre
.Tatars near the plarre are advised to relocate to waters further can five 1 nles f:=m the plant,' cr return to their local mannas. Scatars snould not reentar e.a ocean safety zone until f'm notica.
l
?.e cicaings cf the Wildlife Refuge, tasches and testing armes are !
precautionary measures based on policy /- p M lorsy tafers Seabrcok Station
- us operational. It does not mean that a release of radiation bag occurred or 'M m. " - !
"In addition, ema'_gency infernation broctanges are mailed annually to residents of the ccumunities of w 4 =wme. Am==^ev. w-=< . Ns*er. were Ns-/ ard N=*w. If you are in arr4 eTthane towns, you should look up that emergency internation. I.f these ase unavailable, infernation also can ta fcund in area telephone teoks. English and Ftench emergency infer:stion flyers also have been nada avai1=h1= at beacn facilities arri recreauen areas. 3is infernanan could be helpful in u#.-.eing future nessaaes. .
1 If you kncw of any naiabbses or co-wrkers with haanny or languace l
( ;=cclana, please infarm than of this mameman.
Cnce acain, Seabeeck Station has Har-inrad a SIII ARIA DGmGENCY.
Attachmsnt A.(peg 2 12 of 76)
EBSO9.TXT Page 2 of 2 2 mee Vill t;e repeated frequently en this station u:ttil new V.fcrnanen is available. Stay tuned to this E2S stan en fer the latest offinal ir.fer:nacen.
If you are in any of the New Hawrii*e eastern Rockincnam CATf
-nu.nas, you snould =.e to a local radio staticn in New We for news atout Stur -witty.
Accens recomenced in this meane are L6 only for >=s in
-ru.nes Vittu.n ten mies of Seabctek Stauen."
(NCTIE: his m a ,e is also W ri-> W in Frencn.)
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Attachmant A (Pago 13 of 76)BS10.I:C I
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Page 1 of 2 'j 7 SITE AREA IMERGENCY MESSAGE i (IC RELIASE CT RADIOACTIVE MATIPIAL; SEASCNAL COSURE OF BEACMES AND WT.M.III REFUGEr 1
cata n.asaa. Ra1.as.d - .\
Ti:3a Massage Releasai ******
Released bf:
NHY Cffsite Response Directcr "A SITI AREA IMERGENCY us declared at ****** tcday at Sentreck lerlear l Power Staticn. A SIIE AREA IMERGENCY means that scue slanificant release of l rscticactive matarials could cc::u: , althcatan any releases are not excoccan to p cayend levels sat by tna Unitad Statas Enviu d Protac r.:.cn Anencf, '
except near tne Seacrxx staticn sita bounery.
At this tims, c.are has been ng release of radioactive matarial.
As a precaution, the New F=in Yankee Offsita Raspcmse Organization has been activated and is 5--Wuing to the problem.. Iha New F e ire Yankee '
Offsita Response Di. rector is reviewing sita canditions at this time and is diwwaitig the situation with Manamenummets government officials.
The dovernce of Massachusetts roccanands the following:
Iha United Statas Coast Guarti has been requestad to enforce a five-mile safety zone in the ocean waters near Seabrock Station. All offshore boatars near the plant are adv:umd to relocata to waters furtbar than five miles from the plant, er reman to their local narinas. Scatars snould not reencar the ocean safety zone until further notice.
(Seasonal only) a==r M mM =* ar=== fmn <=14 =ww to pitnn Talat irraltv44m the Parkar P19er Nae 4 meal Wi1M1i fa Ref5 . are fr5W c1 ==d .
Aw6 at & - - P- 7m and r-. . G er vieitirn the rerimmal Vi1diifa ref'N
- - ;i1 d 1 ==v= C.= at - i ; --- ;4 me=1 V, h r=1 mime of *he !--- rs , htifs arm == arvi the V11d1ifa refv m are pwi,Ttary acP4mna Emmad en mIieV ademead lern rafare sentrmt statien was tut ime emerar.icn."
Tar additicnal emergency infd- h, residents of ==14=hamf, .**wy, Marrizac, Newtury, West Newtury and Nadutypact should look up tna annual energency information becenuras which 1are mailed to them. If thane are unavailable, information can also be found in arms talapdene books. This information could be useful in u-4 .-.iing future messages.
If you know of any neighbces or m with hearin:; or language pecclems, please inferm them of this messaan.
x once again, Sentrcok Staticn has daniared a Sita Area Ew f.
(Senecmal only) As a - vei m..
- and = * - f mn ca14=hnmr to !
. pitnn ret and. L,di,sd4 m van parwar p1ver Natsm.a1 wilalire F#+=. w e h==_m j M .
Attachment A (ptga 14 of 76)
EBS10.TXT Paos 2 cf 2 SITE AREA IMERENCY F.5.'.'SNE (NO RELEASE CF RADICACI'"/E MATEPJ.AL:
SEASQDL N CF BEACHES AND WII.DLUT RETUGE)
(contir d )
Ihis ressace will be repeated ever/ fifteen minutes er tmtil new intcrmatien is avai1mh1e. Keep tr ad to this EES station fcr the latest official information. .
If you are in any of the New Fa-mh eastern Rockingham Coune/
c=mmunities, you shculd t:. n to a 1ccal radio staticn in New Hampsn.L7 for news ao::ut your c=mmunirf.
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1 Attachment A (Pago 15 of 76) .
EBS11.TXT Page 1 cf 2 SITE ARIA namGecy MESSAGE
.(REIASE CT RADICAC1"'/E MATERIAL; SEASGE C:.OSURE CF EDGES AND WIIIIIFE REFUGE) 3 l
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Data Massaae Released ****** i Ti:::a Massaae Released ****** *]
Released by:
NNY Cffsita Response Direcccr :
1 A SITE AREA DiGCnCY was declaract at ****** today at Sead.tek Nuclear Power Station. A SITE AREA EMERGENCY :neans that suna significant release of radioactive matanals could cce':r, althoucri any releases are not excoccad to go cayend levels set by the United Statas Envia. d Pretacticn Aaency, e.Xcact near O.a .SeacrecX Staticn Site tcuncary.
?.are was a release into the air cf radioactive matanals fr::::t e.e Seatrccx Stancn at ******.
The New Hangshire Yankaa Offsita Respcrise Organization has been activated and is recipanding to the 2.ncidant. Iha New F=-% Yankee offsita Rasconse Directcir is rwiewing sita ccinditions at this time and is
- d4=r-*==ing the situanen with Massachusetts gevernment officials.
i Iha Goverfor of Massachusetts reccamande t!m fc11cw2ng:.
?A United Statas Ccast Guard has been recuesta:1 to enforce a five-fu.le safety zcna in the ocean uatars near Seabecck Station. All cffshore tents:s near OA plant are advisect to relocate to watars f.:rther than five alles frce the plant, cr return to thai.r local mannas. !!catars should not
. reentar OA satety cne until f.: rear notica. ;
t < mammal m1v) ma=m and meie ar=== fn Cm14 =hwv te Pitun Teland.
L*lt"Itv441'TF 'ha Parker River Nat"it'ifinl Wildlife Mm. are neW c1 h .
Lua at *5- P--m and - 6 er visitim the airwm1 v11dli#e Igf33 i erutir4 laava thens ar=== i=wmar44 memiv. ?m c1mminces of the W *ti?"icf ar=== and the wild 14 4's raffirum are ever unw"irwmrv nerirmia Numer4 en milev A 4r"ir'f"ar4 1efTr heftern Caa>fra"rW C*1.1t9 m was r1TP d 'fts ofteritP9 !"*ft.
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Attachm:nt A (Pago 16 of 76)
E3511.I.T; Page 2 of 2 SITE AREA EMERGI2Cl FSAGE (RELEASE CF RADICE TIVE FRIIRIAL SEASCtDJ., C.CSURE CF BEACHES Ato hTrnr.T7'E R"T.UE) l (conunmi) i For a&titicnal L.f-tien, residents of ra14 =Mme. AmM-/- w -e.
Newutr/ West Newtir/ Snd Newtitrvoer-2 s.M lecdC UD the annual em gerz-'y inforcat:.cn t: rec:t:res unich were ma.tled to them. If these are unavatinhie, inforcancn can also be found in area talephone teoks. '!his inforcancn could be useful in urc==A future m= anes.
If ycu know cf rny neienbars or cc%dsu.s with heari.g er language proclems, please e.fer= them of this rupasaae.
Cnce again, Seacrocx Stancn has riar-lared a Sita Area Dnezuency.
/ 9a=cral cr.lv) is a c* ecautim. beacn and e =_*=== fm Sali chr/ S Plt = Islarn. .ci-
- c _.e .on_-ve* Pive" Naticaal Wildli fe Cefuce . Elve h clcsec.
2 maage vill be repeated every fifteen c. intr::as er until new inforcatien twrnas ava11ahle. Stay tunad to this E=S station fer e.e latest efficial information. ,
i If you are in any of the New Hawrwh eastern Rockinanam County t've' amities, you sn:x. tid turn to a 1ccal radio station in New W. ire for news aceut ycur c==mL~.u.rf.
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Attachannt A (Pags 17 of 76)
E3512.~XT Page 1 of 2 SITE AREA DEGDiCY P.5'eSAGE (SIMM.DG/CCHMLWITIIS:
SEASONAL C:.CSL7d CT BEACHES AND WIIDLIFE RETUGE)
(NO RELEASE CT RADICACCVE PATERIAL)
Data Massace Released ******
- Ti:na Massaae Paleased ******
- Released bf:
NHY Cffsita Resocnse Directcr "A SITI AREA DECDICY was Hw-1ved at ****** today at Seacrock Nuclear Power Staticn. A SITE AREA DSCDCI means tnat scan sicnifi:::snt release of
- sitoactive materials c=.11d - . althouen any releases are net exoected *J go teyond levels set t f the United States Dw2 --.m.a1 Pr= tac lcn Agerx:=/,
em: apt near tna Seatrecx Stati n sita tcuncary.
here has been no release of radioac=ive material fr=:t Seatreck Station; however, it is re*1e t*:st ene could oct::.= .
Based en conditions at Om sita, the New Hamnraire Yankee Offsite Resp::nse Creanitation has been activated and is K4dirq to the problem. The New Heu:enire Yankee Offsita Response Di4= w a. is reviewing sita c=rxiitions at this time and is die >eeig the situation with Mammatt.a. setts gowu.-g.
officials.
- te Governce of Fxacri.:satts L- - -4 the following:
Residents in the c::mmunities of ****** c14 eW/ Awe / and W-ac/
Newtinv/ Wert Newbtr// Newetm m a are advised to SHELTIR Di PIACE. This mans you snould remain Indccrs. Staying t h will provida you with i.waamd rwwacn frcm radioact:.ve matarial releassa fr=m tra Seabrook Station. In crder to get the greatast benefit 'fr=m the prcrac c.icn providad b/ snaltarirg, you should taka the follow 1rq actions:
o Sheltar inck3ars. -
o Make sure all windows and dcors are closed tightly.
o If you are in your car, close all windows and vents while you cx:ntinue to travel to your destination.
o Turn off all fans, heats:q or air candition2ng systacc if they bring in.
GF*4d* air. ~
o Take a radio with you and rave to tha room with fewest wirdows arri l doors. *;
o Keep all =*=rs of your household indcors and stay t1:ned to your local Em-f enm System radio saticn.
o Ramatin irdocrs until told by local or stats officin1= trat it is safe to go or*4da, er t:ntil f',u-3.ar rww:.ve acticns are L- > - esd.
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Attachment A (Page 18 cf 76)
EBS12.TXT Pacja 2 of 2 SIII AREA DEPG2Cl Fre.SME (SHEL"ERING/C:26: j SEASONAL C"f:SURE CF BEACHES AND WIIlLIII REFU"E) ,
1 (NO P"%SE CT RADICC/E PATERIAL)
(cuntinued)
Schools, hospitals and cear insu :tiens in the ccenunities advised to shaltar are takirq simi1 A* sheltering actions. Officials have irstruccians fcr r sc 4 7 the en11dren er c =ar ;.m. = m in their care until shelterim is no longer nar,meu ry. Parents and relatives are advisaa net to call tra scncels cr other instie.:tions, ner to Mve to the senocls to attamat *a pick um their cnildren. Cennunity safety will be better sw d if the scncels are pemitted to c=nduct snalta.r:.y activities ever the next several hours.
Please do not use the en=ne excect in case of perscral emercency.
T.e United States ccast Guartl has ceen recuested to enfc a a five-mile safety :ena in tra ocean waters near Seamrecx Stauen. All effshore osatars near em plant are advised to relocata er dock in varars fur =er than five miles free the plant.
( %=rwuti erily) Baam ='Ti mrk arma= L_a esal d ehw *m Pits Islard. .
incid m t**.m Parke- Divee Nat* e**a1 Wildl i fe Refine . are tvs classt , .
Derwms at **amm em arri mv.s er v'sita'.n th.e riarWal sildlife &lre shouM leave t* -wem ar=== m g g .
If you are at home, Icek uc the annual -v. y infcrmatien mailed *c you fcr f.~.aar intcreau en. :'f you are analtering at your scrxplace er c: Par puclic _HH1d49, eneck e.e local telegnana back fer additional information.
~:his infermanen could be useful in urha@ fr.a.:re twances. .
- 'f you krm of any neichb::rs er co-wrxers with hearing er lancuace preolens, please be sure tney are aware of this rwtuge and urhuwd stat tray snculd do.
Ib repeat: Seabccok Station has declared a Sita Area E-y=Jy.
This messaos will be repeated every fittaen minutas or until new intcr:ntion hammaa available. Stay r.:nad to this EBS station fcr tra
- latast efficial infccmatien. ,
If you are in any of tha New Fa w hi'e eastern Rockinchac County m-tities, you should tune to a local radic staticn in New Fa-Mire for news accut your c=mmunity.
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Attachmant A (Page 19 of 76)
E3513.!XT Page 1 of 2 SITE AREA 1MCl ." SAGE (Sim'GDG/C"HMUNITIIS:
SEASCNAL C.CSURE CF EDGES AND WIIILIFE REREE)
(RELEASE CF RADICACrr!E MATERIAL)
Date Paa u ge Released ******
Time Passace Released ******
Released bj:
?Off Cffsite Response Direc~a "A SITE AREA IMERGENCY was declareci at ****** t:: day at Seatrock ttuclear Power Stat:.::n. A SITE AREA EMERGDCI neans tnat same significant release of radioactive matarials c::uld cc==:r, althoucn any releases are net expec~ad to p beyond levels set bf the Unitai Statas EnvL.-ai.nl F.ww. :. n Agency, exceut near t.a Seacrock Staticn sita touncary.
A release cf radioactive ratarial into the air ccc:. red at ******
2'A New Hatz:snire Yankee Offsite Restx::nse Dizec:cr is reviewirn site concitions at this time and is d**mg the sire.:stion with Pa=c~n:setts gcNw.4 amaai cfficials.'
Iha GCVerncr Cf Pacue?1:setts L a - .15 the follCWin:J:
Famdartts in the c=mmunities of ****** c1 %w/ AmMm/ and M*Mme /
Newourv/ west Neveurv/ Newnwrv- are aavised to SHELTER Di PUC. This neans ycu snould remain index2rs. Stay 1rx; i.h. will provida you with 1.rcreased rwJct:.cn fr=m radioactive matarial released frt=1 the Seaterck Staticn. Also, :n order to get the greatast 1:enefit f::t:m rwwicn wtided b/ snelterirn, you snould taka the fellowine ac:=.cns:
o Shaltar 'rrk:crs.
o Maka sure all windows and decrs are closed tichtly.
o If you are in your car, close all windows and vents stiile you c=ntinua to travel to your destination.
o !\.trn cff all fans, heating er air ccnditienin:; systems if they.brirx; in outside air.
o Take a radio with you and cove to the roca with fewest winius and doors.
o Keep all members of your hous#cid ixxiocrs and stay t=ned to your local Z w y EL. h System radio staticn.
o Ramaan inters urttil told bf local cr stata officials that it- is safe Jed.
to go curside, er until furaher pretaditive actions are 1.w 1
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s Attachmont A (Pago 20 of 76)
E3513.!XT ,
Page 2 cf 2 '
SITE AREA EEGENCY ."SAE (SHEITIREG/C2MJNITIES:
SEASONAL C~DSURE OF BE7GES AND WIITLIFE REFLUE)
(RELEASE OF RADIOACTIVE MATIRIAL)
(conunued) !
Schools, hospitals and other instir.:Cicns in the cc=cunities advised *w shaltar are taking similar shaltartg actions. officials have inst::vr:ti=ns for i JCC19 t"A c*.ildren or other im.awiM in their Care until shaltarity is no 1crs;ur n - =" y. Parents and relatives are advised tg; *4 call tra scncois or other insur.:tions, nor to drive to the schools to attampt to pick up their enildren, carman 11ty safety will te tuttar e.v A ii=1 if tra scncois are perr.itted to ccncuct shaltarirg acnvities over the next several hours. .
Please do not use the pnana excect in case of personal -yac/.
- he Lt.itad States Ccast Guard has been recuested to entcree a five-mile safer / =cne 2n taa ccaan waters near Seatztex staticn. All offshcre ccatars near tna plant are aavised to relocata er dock in waters further taan five miles fr=m the plant.
(ema=r nal enivi cam.s at Mae h and mrk arma= fm calieh nv e Plum 41and. LTbv44ncr t**.e Darker Divar Natic'.a1 Wile *11 fe Defucre are ev_7,.t civ4 Par m at ***mem hame am and mrks er visitim **.e narienal vildlife Mme, shenld leave th*ws ar=== imuwiint miv.
p If you are at hcne, look up the annual =i-,.y cf infc:tation mailed to you for f.rtner inferencen. If you aru sheltersra at your ucrkplace er other paelic m4 Wm, eneck the local taletmane trek fcr additional intermation.
?.is informancn c=uld be useful in urderstarriing fu *=e mannaces.
If you Know of any nelenbcrs or cce with hearLW or larcusse
- =colems, please ce sure they are aware of this r=mne and understard stat tray snould do.
'Ib repeat: Seabetek Station has declared a Site Area E-y=cf.
This nessage will ta repeated every fif*Jen minutes or until new info:tation har,r=== available. Stay tuned to this EBS station for the latest efficial infer:anan.
If ycu are in any of the ((ew H=whire esitarn Rcckirnham County ementies, you should tune to a local radio staticn in New Hampsnire fcr news accut your -wtity. -
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Attachmsnt A (Pago 21 of 76)
~3S14.!XT k FIEREICRDZD Page l'cf 1 GENERAL r N MESSAGE Cata Massaae Released ******
- '"i:ns Messace Releassa ****** .
Faleased 1:y:
NHY Cffsita ResporAa Director "A GDfERAL INIRIENCY has 1:een riar-lared at Sentrock Nuclear Power Station. A GDEPAL IMERENCY means that events are in procross that could result in scale sianifi:: ant release of rscitoactive materials with releases excocted to co beyona levels set ::y OA United States DivL. M Pretacticn Agency cutside the SeatrecK Staucn sita tmundary." !
"*'.e New Hancantre Yankee Offsita Response Organi auen has t:een natifia:1 ,
inci is rescortium to O.e amarcancy. S a New Hanmanire Yankee Offsita !
Restense Director is reviewing the sita conditions at this tima and is !
- e-maing OA sic.:ac:::n wic. Massachusetts gavm -K. officials. j i
'ha Governce of Massac=,:setts roccanands the fellowing:
ha United Statas Coast Guarti has been requestad to enforce a five-mile.
O s"'afety zone in the ocean wtars near SentreciK Station.All effshcre bestars
- near the plant are aavised to relocata or dock in watars fure.ar than five miles frcm the plant. ,
-"In addition, amarcancy information trochures are mailm:1 annually to residents of m 4 =ser. A- -r. w e. Nowher. were Namme ard NeWDury;nft. If you are in any of theue etsnunities, you shculd lock up I
.nat emergency informanon. ~f these are unavailable, infcenation can be fcund in area talepnene tz:cks. 21s information eculd be helpfu). in t.;rd .. A fut.ure messages. i
" Residents in these ocumunities are advised to stay irdcces and stay tuned j to t.ts station until effical instruccens are providad. .
"If you know of any neightxrs or ccm with hearing or language problems, please inferm thaat of t.W m===mge. .
"Once again: A GDtERAL DGKENCY has beddeclared at Seakztek Station.
"'his mammann will be repeated f.Wy Dn this station unul new
-intcrustucri is ava11mh1e. Stay tuned to this station for the latest officisi informuen."If you are in any of the New Hampshire eastarn Rockinonsa 0:unty cxanunities, ycu should tuna to a local radio station in New Hancanire fcr news about your ccanunity.
Actions retzzmarded in this messace,are intarded only for persens in
-Q crusunities within tan miles of Seabreck Station.
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Attachm3nt A (Pago 22 of 76) l EBS 15.T'C ]
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1 Page 1 of 2 '
n<m.www GENERAL IMEPGNCY '
(SEASCNAL C.CSURE OP EEACHES AND WU21III FIFUGI)
N i (May 15 to Sepr - 15) 4 Data Fa" ane Raleasec ******
T1:ae Message Released ******
Released by:
NHY Cffsite Response Director i "A GDIERAL IMERCINCY has been declared at Seabrock Nuclear Power Statien. A
]
GDERAL DG2GDCY neans that events are in moss that cm.11d result in 'l sc:ne sicn.lfi:: ant release of radicac=ve matenals with releases excec:ed *c cc revena levels set by the United States Env1 . .=d Prctecucn Acerc/
.:: side the Seam cx Statica sita councarf."
?.e New Hamrmnire Yankee Offsite Restense Creani::ation has Men nc*1fied and is D=sr .udirn to the i .y-cy. 24 New Hamosnire Yankee Offsite Rasmanse Dim- is reviewing sita ccnditiens at this t1:na and is die ~==ing em i situacen with Maame- :setts gov .4 -s efficials.
'"ha Goverfor of Massachusetts has rar==nded the closing of beach and park areas, fr=m 014chr/ to Plum Island, includitx; cA Parker River Natic:al Wildli#e Rafuce. Persons at these teacnas and parks er visiting the Natic:al Wildlife Refuge should leave those areas 4"=44=taly.
"!n addition, em Unitad States Ccast Guard has been requestad to enfcree a five .11e safety :cne in ocean vatars near Sentrccx Staten. All effshore tcatars near e.e plant are acvisen to relocate er deck in waters furt".er than five miles frc= em plant.
"E:=y=Ly information t=cc:tmes are mailed annually to residents of the ;
m'emities of *14 =H7, Aew, Marnmac, Newbury, West Newtzmy and Newourypert. If you are in any of these comaznities, you should leck up that a .y- cf information. If t!mse are unavn11ahle, information can be found in area tale;tene backs. Dx;11sh and Frenen hvocf infer:stian i flyers also have been made available at beacn facilities and recreation !
areas. 'Ihi.s infer::sticn could be helpful ,in urh A future r====.
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Attachm3nt A (Pago 23 of 76) )
EBS15.TXT - i
.r 0 s
l Page 2 of 2 PRIRIECRDED GDERAL DERGDCI (SEASONAL N OF BDOIES AND WIIJ1III FDIXZ)
MESSAGE (May 15 to Sepcamcar 15) ,
(cont 2nuad)
"If you kncu of any neichlers or cce with hear 2.txJ cr languace preclams, please infcm can of this nessage.
"Once again, Seabrook Station ras declared a GDERAL DERGDCI.
Ms messaae will be remated frecuantly en this statien until new ir.fc=acen is available. Stay tunad to tr.is stan en for e.a latest official ir.fecatien.
"If you are in any of t'.e New Hampsnt*.e eastern Red.inonam C=w/
==munities, you snould t ~m to a local radio staticn :n New Hampanire for i news aceut your ccmnunir/.
Actices racc manced in this m=== arm are lir ided only fer M - s in
..,p communities within tan mies of Sentrock Station. ,
(wrE: m m message is also p e rec m ied in Frenen.)
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Attachment A (Page 24 of 76)
EBS16.TXT i Page 1 of 2 GDE2tAL i'iERGDCI **., .SAGE (SHEL*"ERUG/C2MUNITIES:
l SEASCfD1 CT.CSURE CF BEAGES AZO d W~"T.JITE Rt.tws)
(10 REE.ZASE CF RADICACII7E PAIERIAL)
Data Pa= m e Released ******
'"ime Maa94 Ralaa=ad ******
Ralaa=ad bf:
PDfY Cffsite Resp::nse Directer A GDERAL DiERCDCl sus dar-inrad at ****** today at Seabctek Nuclear Power Station. A GDERAL DERGDCl means that events are in r.wa that c:uld I result in sama significant release of radicac=ve starials V10. releases exeected to ce beyonc levels set bf the United Statas Divh .r.r.uW Preter ten Acency cutside the Seat 2ttck Staticn site b:unda2*/.
?.are has been no release of radioactive material frcm SeawJ Staticn; however, it is possible that cne c=. tid oc==.
Based en conditions at the site, tha New Hamt:stib e Yankee Offsite Response Organization has been activated and is raar.adirg to the proclem. ~ha,New Hampanire Yankae offsite Rascanse Direct =r is reviewing site c=rciti=ns at ttLis time and is d4= = =1 m the sit..aticn with Pa m ca.'.tsatts gw ernment ;
officials.
?.a Governor of Pamc*t:setts recommends the follevin:J: {
Residents in the c~mtities of ****** sa14 e*=r/ Imaan-/ and eme /
Ne"r/ Waert Newetrv/ Newrxn-m-r are aavised to sm rmt rt pI;g E. ?.is saans you snculd remain indocrs. Stay 1rc i.h will provida you with in:reased me.icn frcm reinar-ttve material releasai fr::m the Seabetek Station. In order to get the greatest benefit fr=m the pectactica provided bf snaltarirg, ycu snculd taka the following accions:
o shalter indccrs.
o Maka sura all windows and dcors are closed ticfItly.
o If you are in your car, closa all windows arzi vents while ycu c=ntinue to travel to ycur destination.
o Turn off all fans, heating or air ccm:liticrung systems if they briny in n m ida air.
o Taka a radio with you and reve to tas rom with fewest windows and doors. "
o Keep all rwer=rs of your h=usehold indocrs and stay tuned to ycur, local E.mw faEtnadr-a=t System radio station.
o Esme.in indcors until told bf 1ccal er stata efficials that it is safe to go cu: side, er t m::11 fur:nar g. mive acticns are r+ - ~M.
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S Attachm3nt.A (Pago 25 of 76)
E5516.TXT t
Page 2 cf 2 GDERAL DERGDCI MESSAGE (S&"IEDC/C2MNTITES:
SEMICNAL C.OSURE OF BEnGES AND WIIE.ITE RDU2) 4 (NO REI.ZASE CT RADIOACTIVE MATERIAL)
(omnt nued)
Schools, hospitals and cear i.stitut:.=ns in the cconunitias aavised to snaltar are taking simlar snaltaring actions. officials have instruct:.cns .
fornoprotact:.ng is em children or etnar persons in their care until shaltar::.g lorner necessary.
Parents and relatives are advised tus *c call t%
scncois er other institut:.cns, nor to drive to the a::ncois to attempt *e pick um emir c .ildren. Ccneunirf safety will M battar procacted if t%
sencois are permittad to conduct shaltaring activities over tM next several hours.
Please do not use the pnene eaccent in casa of A 1 emergenc /.
O.e LY.itad Statas Coast G. lard has been resuastad to enfcrce a five-n11e safety tone in c.a ocean waters naar Seatrock Station. All cffshore boatars near ca plant are advised to relocata or dock in watars furrar than five elles frcm t M plant.
( e =..el eniv) R am at S- n arri r. 4 an= f - m e.a14=W er to plin Tuland. Lw4.,er e mw p1ver Nae *,,nal wild 14 *n nee-: are reu c! w .
A m s at 9- P--m arri r 6. cr viniti'ici en nat* ca.al vi 1dii *e arm . ewsiid leave t % ar== i wi nemi v.
If you are at home, icok 1.gtha annual ausrauncy information mailed to you for furchar informan en. ~ you are shaltarLg at your war)miam or ochar punlic Ms4144ne, enack em local talapnana took for additional information.
?.is informauen eculd be useful in u A.= ding fu=zra messaces.
Of.you know of any neienbors or cce with Maring or larcuace
.crcelems, please ce sure tMy are aware of e.is massage and uncarstand what they snould do.
To reper.t: Sanbecok Station has dar 1ared a General hv.cf.
This ==== will be rupeated every fiftman minutas or until new information har=== available. Stay tunsi to this IBS station for the latast official.intarmaticm.
If you art in any of the New Hanzahire sa :arn Rockincham County ccanunities, you should tune to a local radio station in New Hampanire for news absut your c=neunirf. '
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Attachment A (Page 26 of 76) !
.1 EBS17. X"' i 4
l Pace 1 of 2 GENERAL EMINCY !'NAGE (SHELTEREKi/cmHLWrl*:2:S:
SIASCtaL CT.DSURE CF BEAGES AND WIIl1ITE REftCE)
(RELEASE CF RADICACT"/E l'ATERIAL)
Cata M m=ane Released ******
Time Messace Released ******
Released bf :
NHY Offsita Rascorse Director A GDERAL DEGINCY was declared at ****** today at Seatrock Nuclear Eder Station.
A GENERAL DSGENCY caans that events are in smi=Es that cculd result in same slanifi:: ant release of radioac=ve matar'ak with releases emec a:t to go bevens levels set 1:y the United States Erin--..-ad F=tecucn /cency cutnda t .e SearM Station site txxrr.arr.
j i
A release of radioactve material into the air cc== red at ******
The New Fa-te Yankee Offsite Response Direc=r is review 2rc site carditions g % u.a at this c::a ancs is eHee=ing the situ.vW with Massac= set:::
w cfficials.
The Governor cf Ma==ar-'t:setts remma ds the follcuing:
Residents in the eme.ities of ****** s.aH eM*// k==w/ and Ww/
Newetr// the!rt Newbtzrv/ Newtirce- are aavisaci to shWM IN PLACE. Siis naans you snculd remain IJnocrs. -Staying 2.a.as 4.s will prt"nde you vith 1:x:reased r ima.:. n frcm radioac=ve material released fr=1 the Sear =cok Stau en.
Also, in orcer to get the cractast benefit frcm prera:n:len p:=:"nded bf snelterira, you sneuld take the fellowing accens:
o Shelter L'dcCrs.
o o Make sure all v2ni:ws and dcors are closed tightly.
If you are in your car, close all v2Jxt:ws and vents wttile you c=nti:ssa to travel to your destL.ation.
o 2.trn outsideoff air.
all fans, haatiry or air canditicn2rq systems if they bnng in o
Take a radio with you ard move to the room with fewest W2ndows and dears. i o
Keep all e., of your household irbccrs ard stay tuned to your local E% cf B:m+-a=t System radio staticn.
o Ramasa irdecrs iritil told b/1ccal or-' state officials that it is safe to go outsida, er until further rvv=.J.ive acticns are rarm=Med. j 9:
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Attachment A (Page 27 of 76) 1 EBS17.TXT l
- i. \ ;
l Ll
> Page 2 cf 2 GDE*AL rMCY !"esAGE (SHII.T!RDC/C:NMUNIT35: I i
SEASGA C.CSURE CT BEACEES AND WIIDLEI REFUGE) l l
l (RELEASE CT FACICC.*E )RTERIAL) o 4 lased)
Schec1s, hcapitals and other insut:.t. .cns in the cacunnitias aavised to shaltar are taking similar shaltaring accons. officials have instr *x:tions for W - . q- the enildren or etter persons in their care until shaltar2ng is no lancer necesrary. Parents and relatives are advised run; to call the 1 scncois er other institutions, nor to' drive to the schocls to attacet to pick up c. air enildren. Ocrzainir/ safety will be tarttar precacted if the
. senccis hours. are permit:ad to conduc= shaltaring acuvities ever ca next several Please do not us.a c.e tmna excact in casa of %d emeroency.
?.e United Statas Coast Guard has been recuestad to anforce a five .11e safety zona in the ccean waters near Seanteck Stan on. All offshe':1t tcatars near O.a plant tre navised to relocata er dcck in watars fure.ar e.an five miles from em plant.
, p F = = e1 eniv) h w at F =m aM re w Tsi nM .
a_== = e--
c 14=MW ?m P1's a
( _ ritviim t".a Patrker River Natimal Wildli R s s at 9-~ ~ F- vm and ri, u . er P wi tim the P.atimal sn lare
- e Raf'm. new & . -t
\ d1 ! *e
_ e m . s.w id leave e nem arame an :4armiv.
If you are at hcne,1cck up the annual c v.cf information mailed to you for fure.ar informanen. If you are shaltari:xy at your taxplace er cthar puclic M"1d4 -
3g, c n. acK e.e local talecnens teck for additional inforcamen.
"his inte= anon could be t.saful'in urd . ding fn:ure messaces.
If you know of any neient:mrs or cmdcars with hear 2ng er lancuace rMeus, please be sure they are aware of 9.1.s' message and ure .d st1at they should dc.
To repeat: S&M .etation has declared a Ganoral I y-J/.
'Ihis rassage will be repeated every fiftaen mit.1utas er until new infernaticn h===== available. Stay tuned to this IBS sta::.c for O.a latest official 1.nformaticn. j If you are in any of the New sammn.ua eastern ax::kinonam County I cxamasu.tias, you should tune to a 1ccal radio staticn in New F-MM for 1 news aceut your ccanunity. -
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Attachment A (Page 28 of 76)
ESS18.TX-s Page 1 cf 4 GDERAL EDGZ2Cl PNME (EVACCATIC2i AND SHEL7IRI!C:
SEASCNAL CI.CSURE CF BEACEES AND h"U.CLL"E REPUE)
(?C RELEASE CF RADICACI""!E MAIIRIAL)
Data Massace Released ******
Time Messaae Relamad ****** ,
I Released 4/:
NHY Cffsite Rasp:rse Director A GDTERAL DERCDICY vaa Hac1wed at ****** t: day at Seabetok Nuclear Power Station. A GDERAL USCENCY means that events are in p. muss that cculd result in same significant release of radioactive materials with releases expected to ce teyond levels set by the United States D n - d Pretect:.:n Agencf cursida.the Seacrock Stati n sita tcuncary.
2.ere has been no release of radicac-dve material into the air fr:c Seabteck Stati:n: however, it is possible that ene c=uld occur.
The New Fa-nim Yankee Offsite Rescanse Creanizatica has been activated arzi is r==r uine to the preclem. Ma=mam:setts gcVernment officials have been notified.
The Govern::r of Pnnamusetts r+ = - cas the fo11cwuxp T-maniata evacuaticn is r- > = dad for people in ****** e.J_19h-//
Am**'n_
/ and Marmc/ Nawburv/ Wst Nee // Newbu' .m.
For A"=*n~1, the Recection Centar is located at the Mammadzusetts Elec=c :
Facility at 1101 L A Street in North Andover. e k h ""t, For al the Recep:10n Canter is at the Massact.".:setts Elec=c Fae'llity at 44 River Street in Beverly.
Tcr Newhmt and NewMm.arr*, the Reception Centar is lo=ated at T.a ;
Massacrz.:setts Elecmc Facility at 44 River Street in Beverly. For lies; '
Newh f arti Mem*:ac, the Recepticn Cantar is at the Maeur*t:setts EleC=c Facility at 1101 L".Tzpike Street in Nceth Andover. I e
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Attachment A (Page 29 of 76)
E3S18.TXI
[\
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Page 2 of 4 GDERAL IMERGENCY MESSAGE (EVACCNITCH AND SHEI.TERING:
SEASCHAL C*.CSCRE OF BEACHES AND WIIEITE REINGE)
(No REIASE OF RADICACT. IVE MNI1 RIAL)
(conti:n.1md)
?A United .etatas Ccast Guard has been requestad to enforce a five-mile safety zona in the ocean waters naar Seatrcok Station. All offshore 1:catars naar OA plant are adnsed to relocata or dock in waters further than five r..11as fr::n tra plant.
( " m-M eniv l =_-sens at '="1 and navic ar=== f-- =t ac 14 =hwv ts pitm i mi nner. 5-1"M4 m __m patrxar River Narimal Wild'i de h0m. Mv"nti d evar'"Sta
~_wm ar=== *m =v*mestv. -* vou are at a r--- i* cal kMwv er Pim reland.
er at -am W11411*e Raftr a. r - do net ave vour evn -
ea m. air at
-2n a=avent *-side 1 r sr* m fer a rum. ' zalt f r = - --- -- over _
- s nE* m annc'.2ne*LT %Tlat *** ** m - & C/ Ntee= Will t.Skm vcu to a re 'ent"im & #
Ct.Tf"Eles *19 evac = ***='4 sm. "J a n =rit"*c wi &&g %=111 - - E de he1 fi and ar'er - .=.2v sneita .
Services offerno at the Recaction Cantars and rewnaridad for all evacuses includa: nmitnig fer c=ntamination; d-wation if necessary; information and naamane cantars; and referral tc' congregata care cantars, Persons in the c=::nunities directed to evacuata are advised to take the umst convenient roads scutn to main reutas - Rauta 1, Rauta 1A, Interstates 95 or 495 - and travel south in the directicn of tha % den Cantars.
Traffic g'u. des vill assist you.
All scncels within the ccumunities directed to evacuata are being evacuated
- ' to em deslanated PS*cn Cantars fer tra camounity in whic:h they are located. Parents snould not drive to scnoel to meet trair children since scaccis are now being evacuated and children ars bein:y taken safely by tus directly to their Receotien Cantars. School children vill than be sent to tha ****** in ****** unare they may be picked up.
If you have been alvised to evacuata but do not have your own w..mdan and cannot get a rida from a pai?h= or sammene alsa, txisas will travel alcmq main emergency rtutas to pick you up and take you to a Raceuticn Cantar. Wait for an announcement statim what time buses will l bemin travelig thana amargency roucas in your examunity. For more information m the bus and evacusticn rtutas, look up the meerigarcy infertaticm betenures about sentrook staticn whicts were mailed to yeu.
If you have a bedridden, handicapput or other perscm in your hczne who needs en=" = 1 evacuation help and who has not made prencus arrangements with New F--=rtire Yankaa, please call the New Haecanire Yankao Offsita Raspansa r y. -y operations Cantar at ******. If you have already registarud, trare is no need te call now; help will scan be en its way.
b . All ;mrsens in the arma to be evacuatai are urced to be good naiabtxzs and help one another by shar:M ridas and helpig others with protd.ams.
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Attachmint A (Paga 30 of 76) .
1 E3518.IX; GDE'RAL tM. ICY !*E' (EVACC;&ICN AND S*""IP.ING:
Page 3 of 4 O
SEASCNAL C.OSURE OF BEACHES AND WTTNT F.EFUGE)
)
(10 RELEASE OF RADICACIT/E }#ATERIAL)
(conti:t.2ad) l If you know of arry neicnters or cNKm.s with languace or Paarirn I
- Colem, please c.ack cn them to be sure they have been informed of the -
i emergency and uncerstand what they should do.
Safore you leave your hema or torkplace, maka sure you have p:t cut all fires and closed fireclace ceners. Icck all doors vnen you leave. nke blankets and pillows with you for your own use and any =44ches wnich you reaularly taka. Pack enouan c1cthirc for several days. If you are a".surk curside the evacuaticn area, tut live inside it, you may return n=me to act:==clisn these c .=res and c=11ect family memcers or r""U belcrnires.
Peoole livirn in the m.ities of ****** "# * ~// A"""'~r and WL mc/ Newti // wam Nh-r/ Nh e will te safer if they E!"'IIR 21 PIACE imwiiately. ?.is neans to remain i.e. Staying e will provida you with i x::reased prerdan from radioactive material released fr=m Seacreek Staticn. To get the greatast Masfit frcm praracticn provided by shaltar:.:g, you snculd take the fellowin:J acticns- ,
o Shaitar i h.m.
o 'Maka sure all windows and decrs are cica=r4 tightly.
o If you are in your car, close all vindows arri vents sttile you travel to your destiratien.
o ?rn off all fans, heating er air c=nditicrura system if they t: ring in outsida air.
o hka a radio with you and move to the recm with fewest 'm arxi decrs.
o Keep all mancers of your housanoid indccrs and stay turad to your local Em cy Brwic"t System radio statien.
o Ramain indoors u:n:11 told by local or stata officials trat it is safe to go outside, or urrtil further rwsdve acticns are r+ -M.
Schools, hospitals and ether institutions in the c=munities advised to shaltar aru takirg similar shaltaring actions. officials have instr.zrticos fer rweng the c:it1dren er other persons in their care until shaltaring is no 1coger re ===ary. Parunts and relatives aru advised Dgg, to call the schools cr other 1rstit..:tions, rar to drive to tra schools to attamcc to pick up their enildren. Ccumunity safsty. Vill to battar r w r d if the senocis are pemitted to c=n:tuct shaltaring activities over the next several hours.
Please do rnt use the pnana except in case of im.wl emergercy.
If you are at hcme, icek up the annual %=Ly infcrmati=n mailed to you.
If you are shaltarirq at ytur workplana or otbar public MH1rHm, check the u local talepncne tcck fcr additional information. mis information could be usatul in h.muding future r===n==. ]
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Attachmsnt A (Page 31 of 76)
( , E3518.!XI f %-
(d M NICY .*E Pace 4 of 4 (5%L'ATICN AND SMILTEPriG: i SIASOE C"OS2E OF BEACHES AND WIIDLU'E TEFUGE)
(No RELTASE cr hADICACi!VE PATERIAL)
(contim:ad)
To repeat: Seabetek Station has declared a General Ibargency c::ndition. *1 1
2 p-= will be repeated every fifteen m nrtas or u:n.11 new I informan en is available. Faep t:.:ned to this EES station for taa latest I official informan en. l l
l If you are in any of tne New F="*e eastam Rccki.m h/
j
==munines, you snould *=4 to a 1ccal radio station in New Hamn=rtire for
.ews acout y:rm - m ;f.
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Attachment A (Page 32.cf 76)
]
- E3519.TXT l Page 1 cf 3 O1 )
GENERAL I2" ERG 22fCY l*eME (I'v"nCCNTICN AND SF"E? LNG:
.cEASCNAL CCSURE CT BEACHES AND WIIDLD"E RUI.UI)
(RELEASE CT RADICAC:""/E !%TI?J.AL)
Jate Message Rsleased ******
"" ice Message Released ******
<, Released hy:
NHY offsita Restrnse Directcr
. A GINERAL IMI3EI21C"I was declarna at ****** today at Seabteck Nuclear P::Mer Statien. A GINFRAL IMEPENCY neans e.at events are in r+==i,s O.at cculd result :.n scoe significant release of radicact:.ve ratarials witn releases excected to ao beyond levels set t:/ e.a Uni +4 States EnvL. r.aa
?rctect:.cn Acency curside c.e Seac::ccx .etatien sits truncary.
A release of radioactive materia.1 1.- c the air cec = ed at.******
1ha New F=r=ni e Yankaa Offsita Restansa Orcanitation has been activated and is % di.ng to the problem. Mk=nes:setts governcent efficials have been notified.
".te Governce of Famem:setts remmmands the following: 1 1
i TmmmHiata evacuation is rammmarried fer people in ****** CA14 eW"// l Amann=/ arti Me****me/ Newtit*// Wast Newcurv/ Newturae. j i
Tor A"==n ~/, the Receptien Center is located at the PAmcm:setts Electric Tacility at 1101 n:rnpika Street in Nortn Andover. For *A1ie -r, the
]
{
Facection Cantar is at the Pa=nenusetts Electric facility at 44 River {
street m Beverly. . I Tor Newt 2.try and Newburyp::rt, the Reception Cantar is located at the Mamecusetts Elec=ric facility at 44 River Street in Beverly. Ter higEr, , 1 Newt 1="I and Merrimac, the Recepticn Cantar is at the Massachusetts Electr1C l Tacility at 1101 Turnpika Street in Nortn Andover.
l The United Statas Coast Guard has been requestad to enforce a five-mile safety tone in the ecman waters near Seabteck Staticn. All offshore 1:cetars near O.a plant are advised.tc relocata cr.ii::ck in waters further e.an five niles f*cm the plant.
- f ememal enlV) " -
cm at M and mrie armae f*'*mt cAldeh wV to Plum 41arn. Lvitviirrr t"E P8LWer River Natic*nal Wile'li fe Pmf'irve, thentid evammte
- m e araae 1*ner44 mi alv. If ved are at a M in Cali=MW c' Plimt TMland.
er at *** Wile 114 *e Refuce tut ds not have vaur ewn ma. m ica valt at
- A fWrent i**i cia IcCat'c'i fer a bus. Wait fer a P== amen
- Over t*ls statiofi
(, antruncin:t vtist *4-m --c/ Mieme vill *h veu to a rar"me"ff"F"i Cerf*Er CumMe t*E :*/mmmenti area. Parmric'eg a s ,_ 3 vi11 m yide ha1n and
=-'n-T v unmita".
Attachmont A (Pago 33 of 76)
E3519.TXT G Pace 2 cf 3 GENERAL DG2EENCY MESSAGE (EVACCATICN AND SHECTIRING:
SEASmAL C.CSURE OF BEAQE5 AND WU.DLIFE RITTJGE)
(RIIZASE OF PADICMG'E MATIRIAL)
(conti.~2ad)
NCTII: "HE P: ETCHING IS 'IC BE READ ONLY IT ADVISED BY THE NIN
, HAMPSHIRE YANKEE Of75ITE RESPONSE DIRICICR THAT THIS INCICDC MAY CR WILL PRCCUCE A CENU.MINATING ACCIDDC.
There is a gaat pcasibility fcr this anarcrency to produce a contaminating accident. It is stronaly rarm-ncied that as a precaution, persens leaving the towns told to evacuata go to their desicnated reception centers fcr ::en1*=1a.
] I Services efferec at the Receotion Canters arn recommended for all evacuees includa: uniterrig fcr contamination; detion if rar=ef; infestation and message cantars; and referral to congreaata care cantars.
Persons in the c=mmunities directad to evacuata are advised to taka ca mest convenient reeds south to main rautas - Routa 1, Route 1A, Interstates 95 g or 495 - and travel south in the direct.icn of eA~ R wdon Cantars.
( Traffic guidas will assist you.
\
All. scncois within the communities direc:ad to evacuata are bairn evacuated to the desicnated Raception Cantars for em cczeunity in which cay are locatad. Parents should not drive to sencol to meet their children sirca schecis are new being evacuated and childrrn are being taken safely by bus j directly to their Reception Cantars. School enildren will than to sent to
.PJ " - in - wnere they may be pickad up.
If you have been advised to evacuata but do not have your cun
-=%.ation anct canncre get a ride fram a neighb- or sczneene else, tuses vill travel along main smargency reucas to pick yc9. up and taka you to a Racection Cantar. Wait for an announcement statirx; what time buses vill bepin traveling tPAma amargency rautas in your czzmunity. For ucts infor:stion en the bus and evacuation reutas, look up the amargency infortaticri brtsmurus about Saabreon Staticri which were mailed to you.
If you have a bedridden, harrHe-=4 cr other perscm in your hcme who needs special evamantion help and who has not cada previous arrangements with New Hancanizt Yankee, plaosa call the New Hangsmire Yankas offsita Ras;cnse Em cy Operations Cantar at ******. If'feu have already registered, there is rc need to call news help vill scan be on its way.
All persons in the area to to evacuated are urged to be good neighbces and help cna another ty sharing ridas and helping others with problems.
If you know of any neighbors or h6. With lanouage or hearing
(' prtclams, please check on than to be sure they have teen infenari cf eA amercancy artl understand what they should do.
Attachmint A (Paga 34 of 76)
ESS19.TXT Page 3 of 3 GE!EFAL DEPGE2 ICY FreeAGE (EVACCATICN MC SIM"'.U. DIG:
SEASCNAL C'.OSURE OF BEACHES Mc WII.DLIFE REPT.UE)
(RELEASE CF RADICACIIVE FATERIAL)
(cont: :md)
Before you leave your h=me or soltmlam, raka sure you have put cut all fires and closed fireplace d a m m . La::k all d::crs %tten you leave. Taka
, blannets and pillows with you fcr your own use and any M4r+1es which you regularly take. Fack enotun clothing for several days. If you are at scrx outside e.e evacuanen area, b.it live inside it, you may return home to a-lich e.ase encres and c=11ect family r=mmm er r-=q belcrnin;:s.
People living in the c=== unities of ****** e_e1 %-r/ A-wr and w m/ wvtm-r/ Wst Newtiri/ Newt 2re will te safer if e.ey 5"E Of FUCE i -1ataly. This means to renain 1.nt:crs. Staying indocrs kill
=t nde you with increased r ecticn fr~' radicactc + "satenal releasea frcm Seac=cx Stacon. To get tne createst ::enefit irra r .acticn provided )
cy snelter:.ng, you snculd take tne folicwinc act..es: )
o Shelter :.mocrs.
o Make sure all sirdows and doors are closed tig::r.ly.
o If your are in your car, close all windows and vents stille you travel to your destinancn.
o Turn off all fans, heating er air ccnditiening systams if they bring in ,
outsida air.
o Taka a rad.to with you and rave to em room with fewest windows and decrs.
o Keep all rwww-s of your household indccrs and stay t:. ad to your local Emmc/ 2:--Me wt System radio stancn.
o Ramain th until told by 1ccal'or stata officials tnat it is safe l to go cursida, er until f.: rear protec c. ve acc.~:s are K- - - -u. l Scheels, h::soltals ard ether irstiti:tions in ca n-entities advised to shalter are takira sm1m snaltaring acticns. Officials have inscucticns fcr protectrag the enildren or other perscns in their care until shaltann; I is no 1creer rmwy. Parmts and relatives are acvised agg to call tha l scncols er crhar insutution, ner to drive to tra scncels to attempt to pick l up their children. Ccununity safety will he bettar protacted if the scnocLs are pamittad to conduct sheltanng activities over the next several hours.
Please do not use the phcne except in e a== f p=.wid -y=J/.
If you are at hcne, look up the annual R - ;= cf infc2";1ation mailed to you. j If you are sraltering at your workplace craccher punlic b'41<44og, check the l local talegnane b:ck fcr additional intcmaticn. This intcrmation could be useful in u:r.au.awaiing future messages.
Ib repeat: Seabcock Station has declared a General E .y-cf cardition.
This r=='e will be repeated every fifteen minutes er ur:til new s, inte=ntL~1 is avr ilahle. Keep tuned to tr.is EBS station fer the latest official intc=nnen.
If you are in any of the New P==Mm eastern Rockimnam County ccumunities, you snould tuna to a local radio stancn in *N Ha-M*e for news ateut your c=muunity.
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Attachmsnt A (Pcg3 35 of 76)
E3520.TXT Page 1 of 3 GDGRAL D".ERGDCI MESSAGE (EVAC:aTION:
SIASQRL C:M.:RE OF BEACHES AND WIIR.2Z RI2VGE)
- i
)
(No RELIASE OF RADIOACTIVE 2dAT! RIAL) ;
Data Massaan Released ****** .
Time Message Released ****** -
Released bf :
NHY Offs 1.a Resocnse Director A GDERAL DERGDCI ' as declared at ****** today at Seatztek. Nuciaar Power 1 Staticn. A GDERAL DERGDCI neans trat events are in progress trat c=uld result in scane slanifi:snt release.cf radioacta.ve materials with releases excocta:t to ao beyonci levels set by tra United Statas Dh M Protaction Agenc / curside tra Seatrook Station sita bouncary.
tare has been no release of rzdicactive matarial fr:m Seatrecx .etaticn; however, it is possible trat ene could occur.
.p Osa New Hamcshire Yankee Offsite Responsa Organization is r w@ to tha l t 4
. proclam. Mammarn.1setts government officials have been notified.
l The GOVerT1cr. of Massachusetts recxIsnmids the following actions.
~~narti sta evacuation is rumm=sidad foi people in ****** a c lie *//
Amascura/ and Mitra-**w=/ NeWMm// Want NewhW/ NewMr.me'?*.
Dr Ammur/, the Recsetion Cantar is located at the Mammar nusetts Electric Tacility at 1101 tznpika Street in North Andover. For *A14'*M m/, tha l Re:eption Cantar is at the Massachusetts Elecede Facility at 44 River L Street in Beverly.
For Hgldag;y and Newburartnet, the % don Cantar is located at tra Massachusetts Electric Facility at 44 River Street in Beverly. For M Newtzr/ and Marrime, the Receptian Cantar is at the Massachusetts Electric '
Facility at 1101 trnplXa Street in North Andover.
1 -
l- nia United States coast Guard has been requestad to enforta a five-mile safety zone in the coman waters near Sentrook Staticrt. All offshore teaters j near the plant are advised to relocata or dock in waters furthat than five 1'
. miles fztzt the plant.
1
( c=== wial eniv) Pamemn at h, arri - k ar== fr - caliehw to Plum '
Te1me ine 11w94m the Parker P_iver Natiewini Wild 1if a Referim. e>rmsid evne*?ata er== aN ' m =r49arniv. ** veu arm at a P22 , in ca14 eMwv er Plurri TelmM.
- j. cr at the Wi1#41i fa Raftwm. hrt de Frye have vente owr 1 u - ; ret. %rait at Q *he r-est in=1e4m I w *rwt fT a Min. Wait fcr a = OVer
- hie = "T't arirwwww-9 m what ** *= ---- -a Miam= 3' . taka veu to a t- m ef't h "
~Jtside the evacuated arsg.
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_ _ ___ _ -_-_--_-__ ---- - - - - - - - - - - . ~
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Attachment A (Page 36 of 76)
ESS20.TXT J Pace 2 cf 3 j GDEAL DEG2Cl FFSAGE (EVACL7CICN SEASCNAL C*.OSGIE CT BEAGES AND WTTnL*E REFT.UE)
(NO F'"%SE CT RADICACIT/E 19CERIAL)
(centinued)
Services offered at the Rececticn Canters and & - wad for all evacuses '
l incluce: x:: nit =ruxy fer c=ntaminancn h e tien if re m en g; l
infc=nucn and rma age centars; aM referra.1 to ww ta care a carrears.
Persons in the ernmnuties direc:ad *w evacuata are advised to take em rost c=nvenient reads south to rain rcutes ocuta 1, Rauta 1A, I.T.arstates 95 cr 495 - and travel south in the direc=cn of the Raception Canta:s.
~taffic guides will assist you. ;
All scncois within ca c=runlues directed to evacuata are beira evacuated
.c t .e cesienstad Receccen cat. .crs f::r v.e r~mm.ty in %nica .ney are
- ccated. Parents snould not drive to scnoc1 to meet their cnildren sux
- :e scnocis are now being evacuarad and c::.11dren are being uken safely by b.:s directly to their Recep=cn Centars. Schoci children will than be sent to '
tha ****** in ****** vnere they ray be picked up.
If you have been advised to evacuate but do not have your own .
urw.u.utien and canrot get a rida frem a neighter er emrem else, tuses will travel along' rain ruu.gac/ rour.as to pick you up and take you to a i
Racerit.icn Cantar. Wait for an announcement stating stat time tuses will begin traveling these emergercy :tutes in your town. For Ex= e infer =ation en e.e cus and evacuaus:1 rcutas, lock up the euerigency infc=ntien
=tc.l.:res accut Seadrecs Statien knicn were railed to you.
, :f ycu have a tearidden, barritcacped er cther perscn in your hcme wnc needs l special evacuancn help arx1 who has not mada previous arrangements with New
! Fmrwnre Yankee, please call the New Fa-ni'e Yankee Offsite Rasa::=se i E;,5.g=cf operatiens Cantar at ******. If you have already registerec, there is no need to call now; help will seen be on its way.
All pu.ws in the area to ba evacuated are urged to be goed neighl:crs arx1 help cne anothar by snaruxJ ridas ard halpirzy others with problems.
If you krx:W of any neicrtcrs cr co-workers with language or hearux; l preclems, please check ca t.*uen to he sure they have been infermed of tha l
==u.3=cf arrt undarstand stat they should do.
Before you leave your hcme or ucitpirem, thxa sure you have put cut all fires arxi closed fireplace ria==m. I.cck all doors when you leave. Taka ,
blankets and pillcus with you fer your own use ar:1 any *4c4_'uns stich you regularly taka. Pack ercuch c1cthing fcr severni days. If you are at work cutside tha svacuation area, tut live insida it, you may ret:c:n home to a-H % thasa cncres and cc11ect fantly ==rwm or n===q belornin::s.
C Please do ret use the pncrie excect in casa of ru.eni %= cf.
- f ycu are at hcme, taka with you tha annual emergen::y infcrcaricn mailed to you snich ircludes evacuancn rtutas and w twas. If these are !
unavni1ah1e, chacx the local taleix1crie teck fcr adiitional intcr::nticn. I
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Attachment A (Page 37 of 76)
EBS20. TIT Page 3 of 3 GDERAL DMICY FeME (EVACLL*'ICN; EMICNAL CT.DSURE OF BEACF.ES AND WIIDLI2T REINGE)
(NO REEASE CF RADICW.T PATIRT.AL)
(contuM")
T::: repeat: Seabrocx Staticn has declared a General hv=c/ c=ndition. *
~his messace will be repeated every fif*m mumtas or until new informan en is available. Keep r.:ned tc this E2s s:ation far t..e latest cfficial informan en.
If you are in any of the New HanE'e eastarn Rockinaham County c=munities, you sin 11d tune to a local radio statien in New HammLd.re f::r r.ews atout your c==munir/.
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Attachment A (Page 38 of 76) f E3S21.!:*!
Page 1 cf 3 O 1 GD EALm W. ICY MESSAGE (E'.ACCA!':Oi;
{
SDSGaL C:.DSURE CF BEAGES AND WTIl1IFE TdM) !
(RELEASE CF RADICACT3'E 19&EP.U.L)
Data Maa urie Released ******
Time Maa @ Released ******
Released by:
NHY Cffsite Response Direct.nr A GDIERAL DDGDICY vas declared at ****** today at Seatrcck Nuclear PcWer Station. A GDDAL HSGDICY means that events are in g.wi-s that cculd result in some sic:.lfi: ant release of radioact1*/e materials with releases excected to ec tevena levels set tv the United States Env1.v.. M Prctect:.:n Acency cursida tne Seatecex Stati::n site ccuncary.
A release of radicact.t.*/e material inr.c the air ::c=:.*. ted at ******.
The New Haneshire Yankee Offsita Respecse Organir.ati:n is i-u ualing to tra problem. Massac:t:setts government officials have been notified.
/
The Governce of Ma==me-;asetts r- - -a.i.s the following actions.
Imadiata evacuaticn is recommended fcr people in ****** calicH e//
Ammer.'"/ an:1 Mar *"mc/ 'Teh-// West Newent*v/ Newt 2.r. m _.
Tcr A m am m/, ".e Recepticn Centar is lccated at t".a Massachusetts Electric Facility at 1101 ?:::: mike Street in North Andover. Tc r ac l 4 c h e f , t ".a Facection Center is at t*a Maurar-r:userrs Electric Facility at 44 River Street in Beverly.
For Newtiet and Newtxrrrra, the Raception Centar is locatad at the Massachusetts Electric Facility at 44 River Street in Beverly. For k!as Newt 2.try and Mar- me, the Raception Centar is at the Fammarrmsetts Elec=c Facility at 1101 n:rnpika Street in Netth Ardover.
I !
The United States Coast Guarti has been requestad to enfort:e a five-mile Safety Zone in the ocean Watars near Sethn: cst Station. All offshore tcatarS near the plant are advired to relocata er dock in waters further tran five miles fr=m the plant. .
(hemal enivi Ca*sers at % and mMt rana f*--'t ca 14 eHm/ to Pits Taland. L9eltv44 ner t".m P=-kar River Nat4 mal Wi1dii#e Ref5vm. t-M tid evarnate thr sta ame i m mr44memiv. If you are at a haar-m in c.m14ch er er Plum Tsland.
or at t".m Wildlife Raftre t2.rt do not have veur ersn tsrw - w en . %1 Lit at
- he i'ie- i a iftside ICCRtion fT 3 t123. Wait f** 3 7.- .- OV4tr th.is station anncf:nc1:q unat - -m e-- umc/ treme vill ttke m1 te a reden N**
, gg,gida t*.D evacusvari a?Ha.
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Attachment A (Page 39 of 76) l ESS21.IXI ;
l 1.(
Page 2 of 3' "
GENDAL D!ERGDiCY MESt%GE (E7ACCATION: 1 SEASONAL C:.CSCRE CT BEAC2fES AND WIIDLUT REFttEl .
(RELEASE OF RADICACT.'VE MATDJ.AL)
(czantinuan)
MXE: D!E FCLICWDG IS TO BE READ CNLY IJ ADVISED BY DIE NIN HAMPSHIRE YANKiZ Cusm REEKNSE DIRE:ICR DIAT THIS '
INCCDir MAY CR WILL FRCDUCE A CNlAMINATING ACE::2NT: l There is a gecd possibility for this amertwey to produce a , i ccrn:aminat:ng accidant. :t is strongly retammenced that as a i
precaution, ;mrsens. leaving the tcWns told to evacuata go to !
l their desicnated recoction cantars fer ronitorina.
i :
1 Services offerec at trA Recoction Cantars and ram ==rced fer all evacuaes includa: -:x:rtiterinct fer c=ntamination: decentanination if r - ==ry intcreation and messace cantars; and raferral to congregata care cantars.
Persons in the ccennities directed to evacuata are advised *a take tra m:st convenient :::mds soutn to main reutas - Rauta 1, Rauta 1A, Interstates 95
,7 or 495 - and travel south in the direction of the Reception'cantars.
Traffic guidas will assist you.
All' %chocis within the a:emsatities directed to evacuata are tming evacuated to the desianated Recepticin Cantars for the ex:mmunity in wnich they are located. Parents should not drive to schec1 to most their cr.ildren since scncois are new beirx; avacuarad and children are being tak2n safely by tus directly to tPAir Reception Cantars. Scheci cnildren will than ce sent to tha ****** in ****** wnare they may be picked up.
- f you have toen advised to evacuata but do not have your cwn transcortatien and cannot get a rida.from a neighbor er smoone else, tuses ;
will travel along main emergency toucas to pick you up and take you to a Raception Cantar. Wait for an announcement stating what ti::le buses will bacin traveling these emergency routes in your tcWn. For more information on the bus and evacuation reutas,1cck up the amargency infor::stian brecnures about Saabetok .*.,tation which were mailed to you.
If you have a bedriddan, harw44e=W cr cchar person in your hcna who needs W =1 evacuation help and who has not mada previous arrangements with New l Haapartire Yankee, please call the New MAnt Yankaa offsite Raspmse E- g cy operations Cantar at ******. If Teu have already registated, there is no need to call now; help will accri be cr1 m way. .
. All perscris in the area to be evacuated are urged to tm gecd neighbors and help one another by snaring ridas and helping others with precisms.
If you know of any neighbors or h. with language er hearing
( problems, please check cri than to be sure they have taan informed of t!m amargerry and tnkrirtarti what they should do. 1
Attachm:nt A (Pago 40 of 76)
ISS21.TXT l
1 l l Pace 3 cf 3 GDEPAL I2'ZFGEICY P AGE (DTACla n 0N:
SEASONAL C."StEE CF EDGES AND WIIILIFE F.EFTIE)
(RELEASE CF PADICACnVE MAIDIAL) 1 Before you leave your h=ne or *.crk= lace, make sure you have put cut all !
fires ard cicsad fireplaca c'=7. Icck all doors sten you leave. ?.ka I blankats and pillcvs with you fer your cwn use and any m= die 4_.as snich you !
recularly taka. Pack encuan cletnine fer several days. 'f you are at .orx cutside ca evacuation area, tut live irside it, you may return home to ac==clisn these encres and ecliect fsmily twerers er n-=q belcra:ms.
Please de rot t'se the pn=ne excect in case of perreal %=ic/.
- f you are at h=me, take with you the annual emercerx:y inf=ranen ra.tled to you,'-nicn includes evac _nu cn rcutes and r,c M
- es. :f these are
=available, c .eck the 1ccal taleat:na teck fer aoditi=.al infer:stien.
~c repeat: Seatrecx Stanen nas declared a General Emercenc/ ccminen.
his rmsage vill be repeated every fifteen minutes er tr:til new informcen is avminhle. Keep ::.=.ed to this ESS statien fer the latest official infomanen.
If you are in any of the New F*mmL-= eastern Rockin:; nam cetrrr/
C ccLrunes, you Should t.*A to a 1ccal radio staticn in New F.a:Dsnire for news accut your mmmnurf.
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l Attachment A (Page 41 of 76)
EBS22.TXT O Page 1 of 1 1 1
CCWNGRADDG CT DEG2 ICY MESSAGE Cata Messace Released ******
Ti:De dt.essage Released ******
Released bf :
LEY Cffsite Resprse Directcr At ****** T.e emarcancy classification of *.us downgraded to the e:ner ency classification af ******
2.e Governer Of Massacnusercs and p.:=lic health efficials r-- > = 4 em f alle.vc ac 10:s:
O .
Please say er.ed to this EES statien fer fu:-ther i:fermation.
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I Attachment A (Page 42 of 76)
ESS23.T.TT Page 1 of 1 TERHDIATIQi OF IMERGDICI P."S. AGE Cate N u ge Released ******
Time Messaae Raleaseo ******
Released bf :
NHY Cffsite Response Direc cr At ******, the Goverre of Massacr::.:setts and public health officials deterrened that an eimq=c/ conditicn no lencer exists at Seatreck Statien.
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1 (Racean anwnnt cne tWae. )
- - _m_ _ ~ 1_1 __, _
t:tmW staticns ray new resume nemal Lh. cperations.
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'Attachmsnt A .(Pago.43 of 76)
EBS24.TXT u
i Page 1 of 1 SUPPUMDbL MESSA2'1-BUS RotJII T2ES l
Data Messaae Released ****** '
Time W Released ******
Released t:y:
!Gft offsita Resp:nse Directcr ~
i
[
' Attanticn, all residents and visitcrs wit.*n:t t::2 m.tien in the ******
cf ******
Suses will begin traveling emergency routes at:-
=14.w.f _
M/ ******
Marzuac ******
Newbury ****** '
'T' . West Newt:ury ******
, Newtuypert ******
C=nsult the amorcuncy intcr: nation miled to you fcr street names and locations of your ecmmunw/'s tus reucas.
Aaain, at::
buses will beenn traveling -wcf rcutas f.n ths ****** of ****** .
, e.al i ehw y **eeee hf ****e*
Marr2mac ******
Newbury ******
West Newbury ******
Newburfport ******
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Attachmsnt A (Paga 44 of 76) l ESS25.T:C l Page 1 cf 1 O l l
SUPPI .DTIAL 1.*eSJE 2 FARWIS WI'IH SC-!CCL CM UT EVAC.:ATDG APuAS l 1
I Cata Mauge Palease:1 ******
l Time Ma u ge Released ****** l Paleased bf :
NHY Cffsite Restense Direc::cr i
e t
i tCII ;
i .
?.is armramam: shall be t:rmdcast *. ten i irst: :c=crs to do so are given cy tne Public J.nfu a uen Adivser
?.e fellevity message centairs additional instr.::=crs to paren s v:.th scncol children in evacuat:.cn areas artunci Seabrcok Staticn.
Parents with cnildren attendira scnoci within ****** *Al d eh / M** / and hw. Newtmv. West Newtirv. Newbuwu - are advised tPAt I" Air mildren ,
i are 'cu: rent:ly beirq safely evacuated by tus di:1ctly to a recaccen centar curside the affected area. C111dren will then be sent to a desicnated host facility wnare they ray be picked up.
Parents sto are DG3; in tPA evacuaticn zcne may go directly to ce test facility. Parents ir. side the evacuanen ena are u ced to first rea:rt to ce Recection Center fcr their m mity. ;
?A desicnated host facility fcr all rc: col children evacuated fr::2 Massactn.:setts scnocis is the ****** in ******.
?.is ra=me applies to all public, privata and partenial sencois ard presencol facilities within the affected area. To avoid confusicn. parents are t.' ged DC3; to arts:Ett to pick up their enildren at scncels within tPA affectai area. Rather, parents are asked to pick up tha.ir children at tha in , ,
(Repeat this announce mnt eno time) $,
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, Attachment A (Page 45 of 76)
EBS26.TXT I
Page 1 cf 1 SUPPL 1252frAL !ESSAGE 3 FRECWIICNARY ACTIONS FCR FARMERS, TARM hGKERS, KCD FM -*T6 AND KCO DISIRISUICRS 1
Data Message Released ****** ~
Time Message Raleased ******
Released tf:
NHY Cffsite Resp:rse Di.recr=
(Select Actions As A p rinta) 7.e fellowing naawte is direer.ad te famers and food diaw M a in e.e m-des of ****** c 14a ew,-/ . A-*=m f and Me- me. Newrurv. West Newrn-r. ewrur nr-_.
Due to e.e emergency c=nditien stics has been declared at Seact:cx Stac en, Stata aucenties have rarwe=nidad eat precautionary acticns be taken cy farmers ard food s -wa in same areas surrounding the plant. ?ase 9 ac-dens are called preventive sMdve ac-dens and are insed en ;clicy adopted 1cng betcra Seabreck Statien was operational.
release of radiat:.cn tas occ=ted er nll occu: .
?Ay do not rean a Wi.N to Stata officials, farmers ard dairf operat=s in the c==munit //rymaru.tias of ****** cA i em-r . .im==M-/ and Ma--*-ac . Newtu "f-West Newtu r. Newtur nr-- should:
o Move all milk-predtx::ing lism and other grazim animals insida a barn er other snaltar.
o Provida the animals with stcred feed and water and reduce sources of outside air into their ht41 dim s.
o }bve cutsida feed supplies indc:crs er cover them, if pessible.
o Stma back-um suoplies of %3 tar irside Hsild4gs and ec' ate cu-docr walls, rautarrels, tanks er cTAr sources of Collected Vatar.
o call ****** fer ::cra intcrmation. ~
Food rarkatars ard re =" ra in tha ****** of ****** should:
o Stay tuned to this station to stay aware of ra,remmded acticr3 recarding fccd i* m .
o Call ****** for rcra informattdn.
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l Attachmont A (Pago 46 of 76)
ESS27. :C ;
Gli Pace: 1 of 2 !
SUPPI.DENDJ., FreeMT., 4 EMEPENCY ACI'D"lNS TCR TARMERS. TARM kCRKERS, TDCD cm >M4 AND FCX:0 DISIRIEUICES !
i I
Data Messace Released ******
Ti:ne Nuge Releasac ******
Released by:
NHY Cffsite Resp::nse Direct =r i
i
?.e follcuina emercency acticns for farmers and feed w_ _ ;m :.n the nortnaastern a
..ru. *.es of Mw acnusetts are r r -- ued. by Stata '
autn rities:
l
- Sali H -r A ==e! and .%- -se. 'fewtu--/. 5:ast Newbury. Neweur frer- .
l Fm Nx-2 Authorities are m: niter:rx; milk, water, arri feed to detarn:Ine if they are safe to market. c ner "a=r-v any fmd -- r- t a t tla== veu a' = teld te da so tr etarm efficiC a. Deta.11ed inst:racns win te given to you by them.
Milk. Milk from animals arri dairies should not be marketed. Teod pr"a*"s in these tevns stxmld held = ilk fer a perled of time to allow fcr
~ e'M e radicacave materials to decay. FJ.lk can te frozen, carnantrated, cada into enmese, er dehydrated to allow this to cccur. Milk in sucres arxi haces is okay to drink.
Meat. I.imL.d. awm=4 to extarnal c=nta=1natica may be used for food if they ars =Wraly wasnad and renit= red by auttx:rities before slatantaring. Meat anunals with internal c=rrmnation cannot te slatxrrt.ared until you are told by Stata authorities that it is safe to de so. If the animals' skins are c=ntaminated, tha rwiim tive materials can be washed off with soap and water. In handling animals, you should wear pcutactive clothing, such as that used in.pesticida applications, to pnrvent contaminating yourself. -
Grain. Prer% are asked to held harvestad c:ains trrtil told that they are sate to unrket. If some adiitional action is r q, it zny include c.1111:x; and polishirxy. State officials will advise you about what is n*""* **?y.
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ir Attachment A (Pags 47 of 76)
E3527.T.C t
Page 2 of 2 SUPPI.ZMDITAL MEESAE 4-FARMERS, FARM ICRKERS, PDCD PPN*nR,5 AND FCCO CISIRIBt.7ICKS (continu.ad)
Mai_s and vener*N es. 'With green vegetables, sxins or outar leaves snould be removed and the remainder washed thorouenly. Potatoes, melons, i
- :tec creps, peas, and taans require normal cleaning. Fruits that do not-have to be picked i:nad.tataly should be saved and pic.W after any radiation has decayed. Cannim, freezing, or cther sg of fruits or veestables all also allow decay cf sans radioactive eart:cles and make them safe to eat. You will to t=1d stian'lt is safe to harvest and marxet your fruits aM veostables.
Persemal e v e w l
I Stata authorities are renit: ring the area. ': hey all tall you when it is !
safa to worx your fam acain er resume your fcod marxeting operations. :f you have been t=1d you may cultivata your land, you shouldr i
_ 1) Wash hands thorcuatily before eati m . .
- 2) Wear protective clothing (such as that worn dur::x;r pesticide .
' applications)- stien worxing ot.rh . Remove cutar clothing before
- entering your hcme.
- 3) Wear a dust filtar ever your nosa and rouch if. you are plowing er -
cultivating dry lar:1. You might also need to wear a filtar if you are harvestine corn.
MLtar Well sacar can be used fcr your family and arilmals. Pend or stream water (circle which is amwr.ata) can/cannet be used for your family and animals. Normal human drinking water outlets (circle which is am vr iata) are/are not suitable fer use.
Insurance If you suffered preven scalamic loss due to 1 nuclear accident, you would be w ami. Seatztek Station carries insurance. This insurance covers W id injury ani.i damage to property, incitriirn animals and crops.
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i Attachstnt A (Pago 48 of 76) i
'MP12.E35 Page 1 of 2 SIIE AREA IMEPGE:ict P" SAGE (SHELs wC/C 2tGm .m:
SEASCtDJ., CT.llSURE OF EEACHES AND WIIIGE REMEE)
(lO TCEASE CT PADICACIT/E MATIRIAL) 1 Data Massage Released ******
Time Message Released ******
Falaa=ad by:
NHY offsita Faspense Direct =r "A SITE AREA IMERCINCl was Har-1aved at ****** today at Sea &4c Nuclear :
Power Statien. A SITE AREA IMTRCI2tcl means that sczna sicnifi. ant release of radioactive ratanals cculd cccur, althcxxzn any releases are net e>=ected to ;
l go beyond levels se by em United Statas Env1 .,,.md Protect:,:n A: enc'y, l
exce=t near O.a Seabr::cX Stati::n site boundary.
1 i-
?.are has been no release of rtdicactive material f=xn Seabrock Staticn I
however, it is pessible that :na c:uld occur.
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Sased en canditions at e.a sita, c.a New Fa-hi u Yankaa offsite Respense Organization has been acrivated and is %A to the p=clem. ?.a New Hampanire Yankaa offsita Raspx:nsa Directcr is reviewirq sita ceniiticns at this time and is d4-=*i_q em situaticn with Massachusetts gevarmant i officials.
The Governcr of Ma==am.:sete roermands the fellcuing:
Fasidents in tha ccanunities of Marnmac, Newbury, West Newburf and f NewburaTxsrt y should monitcr emir Frau.y.cf Broademrc staticn. No acticn is 1 .d in e.a- c==mti..
Fasidents in the errmmities of SalieN.try and AmmaMm/ are advised *w SHEIZER IN PI. ACE. This means yet snould remain 1rx$ cots. Staying ihrs Will provida you with increased pr=caction if rad 4'=-"1ve matanal is ralaasad f=zn the Seabreck Station. In crdar *w get tra greatest benefit fuzn the pre"='-"% providad by shaltarirg, you should taka the felleving actions:
o Shaltar irr$cers.
o Makesureallwindowsanddecrsareciesedtightly.
o If you are in your car, cicae all wirx[cus and vents while you centinua to travel to your dastinaticn. 1 e nzrn off all fans, hanti:q cr al.r c=nditienirq systems if they brirg it.
cutsida al.r.
o Take a radio with you arx1 ::eva to tra recun with fewest vindcus and I decrs.
o Yaeo all =mh="s of your h::usehold irricers arri stay tunad to your 1ccal Eay.cf Et.m-Lo,wt Systen radio staticn.
o Famaan indecrs in1til told by local er stata eff4Ha1= that it is safe to go outsida, cr C!cil fu::C.ar grdvs actions aIn r9rm='I$ad. ,
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Attachmont A (Pags~49 cf 76) ,
W 12.E35 Page 2 cf 2 SIIE AREA DER 22Cl MESS;G (SE" IRING /C2f0NITIES:
SEASCNAL C.05URE CF EDGES AND WIICUI'E RETU2) l (NO REIEASE OF RADICACC7E MAIIRTAL)
(cont:.rt.:ad)
Schecls, hospitals and cthar instit::ti=ns in the ccamaunities advised to snaltar are taking similar shaltart2:J actions. officials have inst:.:cti=s -
- I f= r .ect.inJ the enildren er ether persons in tha.tr cars until shaltarLg j is no langer r= ====vy. Parents and relatives are aavised not to call em l scnccis er ether institu icns, nor to drive to the scnocis to attempt to j pick up their candren. C:xmunity safety will be battar protactad if tha senocls are permittad to c=n:tuct shaltaring activities ever the next several hours.
l' Please do net use the pnene except :.n casa of personal emergency.
ha United Statas C=ast Guard has heen recuestad to enfer:a a five ile safar/ :=ne in em cesan waters naar Seabr:cx Station. All effsh=rn ccatars near e.a plant are advised to relocata er dock in watars further e.sn five ciles f=m tna plint.
he 'i and mek ar=== f_ _.a ca 14=hnv to Plum Island, incin44m the P=_ War River Natier al Wildlife Refucre. are N:w clw. Dersens at these tanca.ee ,
, and '-arr.s er visitLT the t'atienal *ildlife renace sneuld leave erra ar===
M.
If you are at ham, leek up the annual emergency information melled to you 1 f= f=ttar intcuati=n. If you are snaltarLM at your workplace er cear puoli: .%11 ding, check the local talepnene bcek for additi:nal inf =ati:n.
?.is Infernation could be useful in understanding fut..:rs messages.
If you know cf any naichbcrs er ccmrxars with hearin:J cr language p==lems, please be sura emy are aware of this message arzi urnerstarn .' tat they s:muld do.
To recent: Saabztek Staticn has declared a Sita Area Emm v cf. !
1
?.is message will be rupeatad every fifteen m.inutar er until new j inferration becomes available. Stay tuned to this EBS station for tha latast official informat:.cn. ,
j
( If you arm in any of the New Hamashin eastarn Rockingham County cm ounities, you should tuna to a local radio station in New Hampanirs fer news aceut your consnut/.
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Attachm3nt A (Pago 50 of 76)
M 13.I35 s
Page 1 of 2 SIII AREA IMEPG2ict PRESAGE (SF -@X;/Ct291]NITIES:
SDSONAL N CF BEACES AND trrTm'nT RETUGE)
(REIZASE OF PADICACI""E PATERIAL)
Cata Passage Released ******
Tima Massage Raleased ******
Raloaam4 by:
1GIY Cffsita Responsa Directer "A SITE AREA E9G2TCl %as declared at ****** tcday at Seabrecx Nuclear Power Statien. A SIII AREA EMERCDICY means that sama significant release of radicac=va materials c:2. tid , althouan any releases are not excecad to ec beycrd levels sat by the Unitzd Statas Dr.rL. M Prctecti:n Acancy, am near O.a Seabreck Staticn sita tcuncary.
A release of radioactive ester:21 into O.a air m n!d at ** * *.
?.a New FA - niru Yankaa offsita Rescense Director is reviewiry s:.a curriitiens at t".is tina and is d4-e*1rq tha situaticn with Massac=satts goverr: ment effir4*.
?m Governcr of Fametrasatts rnm-'mands the fellow 2Jg:
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Residents in tha m inities of Marrirac, NewLury, West Newbury ard Newburypsrt should monitor their D.muw...y ph=t statien. No acticn is required in these cc== unities.
Residents in the mMties of Sa14ehirv =_M A&*nry are advisas to SF"*4 I t PIACE. ~his maLns yua sneuld remain 1.%:nrs. Stayirn inicers will pr=vida you Vith irx:rnased prctacticn if radicact:ve is ratarial released f:=s the Saabrock Staticn. Also, in creer to get the createst ,
benefit L pretacticn provided by shaltarirn, ycu should taka the '
fellcwuq actiers:
o shaltar indocrs.
o Maka sura all windcus ard decrs are cicsad ti:;htly.
o If you art in your car, close all w2ndows and vents stila you c=ntinua to travel to your destiratien.
o 'Ittrn off all fans, hastirq or air c=nditi urg systams if they brirg in
~
outsida air. ~
o Taka a radio with you and mcvs to the recm with fewest wirdcus ard decrs. ., l o Keep all caneers of your household 1.%scrs ard stay tuned +a your !
local IWq ede a*t System radio staticn.
o Ramaan indocrs until told by local or stata efficials that it is safa to go cursida, or until further pretact:.ve acticns are r-- - ;M.
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Attachmant A (Pago 51 cf 76)
I'MP13.E3s
- (N Page 2 of 2 SITE AREA DDGENCY MESSME (Sim* DING /C:2ENITIIS:
SIASC204 C'3URE OF EEACHES AND WIIII:EE REFUGE)
(REIZASE OF RADIOACTIVE MA222IAI.)
(ccrie:.~:ad)
Schocis, heapitals and other instir.:tiens in tra cenounities advised to shaltar are takim similar shaltar2ng actions. Officials have iratr.:cticns !
{scrm.whN e
. icngerem cnildnenParents necessary. er cther andpersons relativasinare their care Dag acrvised untiltoshaltan.g call em scncels er cchar instit ~icns, nor to drive to tha scncels to attempt to pick up thair children. ccumunity safety will be battar .wed if the e
scnocis are par ==ad to concoct shaltanng activitias cvar the next several hcurs.
Please do me use the pncna except in casa cf perscral amargency.
?a United 'Statas Coast Guard has baan recuestad to enfer=a a five .ila safecy zona in tr.a coman watars naar Seabrock Statien. All cffshcre beatars naar em plant are advised to relocata er dock in watars f.:rtrar e.an fiva
=11as fr=m em plant.
n== m and m W a_ma= fm Salf *m te Plum Islard. LTli' Aim the Parkar River Nattenal Wildlife Pefuce. are new c1w. :ersons at t a== 9= mas
', and narks er visiti.n te natienal wildlife nfu=e. emld leave thesaM:EAS 4
fJggLiaggd.
%)
If you are at h=ca, lock up the annual' amargency infczmation mailed to you for f.: rear infer =acen. If you are shaltaring at your sockplaca er otrar P*14c M41d4m, enack tha local talachena back for additicnal infer:atien.
?.is infermam~1 could be useful in understanding f.=:ra massacas.
If 'icu know of any naichbcrs er co-wcrxars with haanm er lamuace preclams. please re sura tray are awars of this massaca and undarsca:xi stat
- ?my snculd dc.
Tc repeat: Saabrock Station has declared a Sita Area Esiu.3.. y.
I
?.is massage will be rupmated avary fi."aan minutas or until new information bactnes available. Stay tuned to this E35 station for em latest efficial infer =aticn.
If you are in any of the Hg Hannshire east [trn Rockingham County cumunities, you snculd tuna to a local rat'Io station'in New F=P4ra fer news about your c===unir/. ;
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Attachmant A (Pcgo 52 of 76)
M 16.E3S Page 1 cf 3 ;
GDERAL D'HCCICY .M (SIEL.TERUG/CCNMUNIT:ES:
SEAscatAL C .:stw. CF EIACE:S AND hhr P.c.:0GE)
(10 REEZASE CF RADICACTr/E 2"ATEPJ.AL1 Cata Massace Paleased ****** l Time Massace Paleased ****** i 1
Paleased by:
}DIY Cffsita Resex::se Direccr 4
A GCERAL DEPCCICY vas daclared at ****** tcday at Saabreck Nuclear Power Stati:n. A GDIERAL DERCCTCY .. mans that events are in r ws.ss that ==uld result in same significant release of radioactive matanals with releases ;
expected to go beyond levels set b/ the United Statas Dr/1.w.tal {
Frr: action Acen:y curside t .a Seacrecx Station sits bounda:/.
?.ere has been no release of r'iirar ive material fr:m Seabr:ck S::anen:
however, it is possible test ena c=uld occur. .
i Based en c=nditi:ns at the sita. 2.a New Fa-hhe Yankaa Offsita Fasecrse CIvanization has baan activated and is r-- .Nding to the pr= clam. ~ hit New FA='liru Yankaa offsita Paspense Direct =r is reviewinJ sita c=nditi:ns at ;
this time and is d4e"=irxJ the situaticn with Manamer:usetts g=v ...-m cfficials.
?.a Gevarner of Pmac't:satts ri =us the following:
Rasidents in the cc== unities cf Marrimac, Newbury, West Newoury and Newouryport should monit:r tnair tw y.rcf a::mdewt stauen. No acticn is rect:, red in these mties.
Fasidents in tha crmmities of Salieh.try and Amhrt aIn advised to S*""IR t Di FIACE. Siis means you stu:x. tid remain Indocrs. Staying i.-dcors will provida you with increased pree-4r*1 if radioactive is material
- tleased fr=m the Seabrocx statien. In ordar to get the greatast banafit fr=m the rs ----W provided by shaltanny, you should take tha followin:J acti::rs:
o Sheltar inicCrs.
o Make sure all windcws and.dcors are cidsed tightly.
o !! you ara in your car, close all windows and vents while you wdnue to travel to your destination. j e Turn off all fans, haatin:J cr air c=r:11tienirg systams if they bring in i eutsida air.
e Taka a radic with you and rave to the rocm with fewest v2ndows and doors.
o Keep all memrwrs of your housencid indocrs and stay t=ned to your
, local E;. y..;f arcaocast system radio station.
o Reunin irdocrs until told by local or stata officiala that it is safe
.C to go cutsida, er until further s wi dva actions are 2.--- - -W. ,
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-Attachm2nt A (paga 53 cf 76) i 1
1 n!P16.E3s f
D
\ '
Page 2 of 3 GDG2%L D"J2MNC'l P25SME (Sr'21:2RDC/CI2MNIT:ZS:
SEASQRL C:.DSURE CF EDGES AND WTTnrTTI REIU2)
(No RIZZASE CF RADICACI'"/E }RTERIAL)
~
(cnnti..e.ad)
Schocis, hospitals and cear iracit=tions in em cxsmunities advised to sneltar are taking similar shaltari.g actions. officials have instre.=nces
- fcr pretactirx; the children er cchar persons in their care until shaltari.g j is ne icinar necessary. Parents and relativas are sevised Dgr,to call tha s:necis er other msti. :tions, nor to drive to the sancois to attempt to pick up their children. Ccumunmf safsty will be battar pretacted if em scncels aru permittad to cernu=t shaltari.m activities ever the next several hcurs. ,
1 Acc:c '1.T to stata officials, farmers and dairy cparators in e4
- m=unicas of Salieh?.rv and A ==r r-r, snculd:
M.cVe all r. ilk-p r *-ing liverecer. inside a barn er ce.ar shaltar. j l
Previda em animals with scred feed and vatar and .e. sources of outsida air into e. air b41d4Ws.
McVe cursida feed supplies i:r'.ccrs er cover them, if possible.
P '
Stctre back-uc supplies of watar irsida N41d4ms and cover cutdcer wells, rainbarrels, tanks er ether sources of ecliected water.
Please do net use the pncina excact in casa of W d amargency.
?.a United States Coast Guard has been recuestad to entc1:a a five-ils safety rena in the ocean untars near Seabrcok Station. All effshcre beatars near tha plant aru advised to relccata cr dock in watars fJrther than five niles fr:r: em plant.
Samm. and -avie ar=== f_ .a Sal 4 eWm_ t ~_c pits Island, incitv44m the Pa9.er Plver Natienal Wild _ life Refuca, are new ciw. Parscina at tW hae.as ard rarxs. cr visitLT ?.m nati~.al wildlife refuce. shenid laava t%
armas 2.'".nad11taly.
If you are at hcan,1cck up the annual emergency information mailed to you for further infcznation. If you are shaltaring at your uurkplace or ethar public M41d4W, check the local talognana bcnk fcr additional infer: anon.
2.is infctmaticn eculd be useful in h.9 ming future Fa===nes.
If you knew of any naice2ces er cce bth hear 1.n:f er languace problems, please be sure they aru aware of t.W massage and m.J what they should do.
To recent: Saabreck Stati=n has declared a General Ecargency.
3 Diis -====r= will be repeated every fiftaan minutas or until new
' infor=auen hamn== available. Stay tuned to this EBS station for em j latast official intcr=ation.
Attachmsnt A (Paga 54 of 76)
M 16.E3s l l
M MC5 sM ($"rTRFQ/'Mg 9 i SEASC2E C".OSUP2 CF EDGES Mc h7I.DLIIT REFU2E) ]
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(NO REI2ASE OF RADIN.T MA2E!UAL)
( m m ad) i If ym are in any of tha New Hamim eastam Wm wf mMties, ym shculd t=:na to a local radio statien in New Hamrwitm. to:-
nas amou: your m mitf.
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1 Attachm3nt A'(Pago'55 of 76)
[; TMP17.E35 I
[ .
Page'l of 3 !
L GENERAL ESR2NCY .N (SHELNG/C29CNITIES: 1 s
SEASCNAL C:.OSURE CT BEACEES AND M REFUGE)- F (RI235E C' PADICACTr/E MATERIAL) i 1
Data Massaan Raleased ******
Time W Paleasect ******- .
Released by:
NHY Offsita Responsa Direccer A GENERAL 22GR2NCY %2s declared at ****** today at Seabrook Nuclear Power Sta1 1. A GINIRAL ESRENCY means that events are in progress that c=221d result in same slanificant release'of rad 4 = - 1va ratarials with releases excocted to go beytrz2 levels set by the United Statas Env16w.-n.al Protaction Acancy outsida the SeabrooK Stati::n sita bourcary.
A releams of rmMw 17e material into the air oct:.*.* Tad at ******.
. ha New F= min Yankaa Offsita ."+4 a Dirmeccr is reviewing sita f conditicns at this tica and is diummair J the situation with Massachusetts !
goverment offMinim.
p _
h ':he Governctr of Massachusetts recommerzls the folleving:
Residents in the ccumunities of Marrimac, Newbury, West Newbury and Newburypcet L*i:.ald .cniter their hv.cf Broadcast staticn. No acticn is wquarut in these cc=munities. -
Residencs in e.a tr:=munitias of sal 4% and A-m.trv are advisad to 7 - m IN PIACE. ~his means you snculd rummin 1 m. Stayir J i x2cors will pzwide you with irx.raased em - Td e. fr:n r=d4=~ive matarial released from tha' Saabrook Staticri. Also, in ordar to get the greatast .
bermfit fr=m v wsacn prwidad by shaltar:ulg, you should take the folicw2try actions: .
o Shcitar 1: dams, o Maka sura all wind.ws and decrz are clemed tightly.
o If you azu in your car, . close all windows and vents while you centinua to travel to your destination.
o Turn off all fans, hastirzy er air exszittioning syntams if they brirx; 2n casts 1Gn a1z. ~
o Taha a radic with you and acvs to tha'~ctzza with fewest v2ndows and desses.
o Knap all menbars of your household indcors and stay tuned to your 1ccal E-v- f Becadcast system radio station.
o Remain 1:xiczars until told by 1ccal or stata officials trat it is safa to go outs 1da, er until 1:re.ar protact:.ve actions are rarw-widad.
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Attachmsnt A (Pcga 56 cf 76) !
TMF17.E35 CJ2EFAL EMEPCCIOl .*5NE (51M"-"C3G/C2MDu.w:
Page 2 cf 3 9, SEAScraL C*M CF EZACIES AND WTTnt FE xt.w.u.)
(REIZASE CT FADICACC/E RTERIAL)
(cent:rt.:ad)
Schools, hospitals and ce.er r. stir.:t.icns in e.e ce=un.:. ties aavised to anelter are takirn similar sneltermg ac::icns. officials have irstr.:c icns
!cr ,.. m.Lg the enildren er etnar pm.-s in their care urmil shalta=g is rc icrner maarf. Parents at relatives are advised Dm; to call the sencois er cther irstir=:.cns, nor to drive to the sencois to actamcc to pick up their enildren. C:x:ce .r/ safeef vill be betr.ar r act.ad 'if the scncois are pe.r,sittad to c=nr.:r: :nalter:g activities cvar e.a ncxc several hcurs.
k:ccrf.irn to Stata offi-41". fl'.tw.rs and dai: / cperate.::s in the a ties of Sal'enurv =M A esmerv en::w.d:
McVe all r.:.1k pr:cuer= livestocr. inside a tain er e her snelter.
P::vida ca ani=als wie. s = red feed and %ater and recuca sources of cutsida air i::co e.a:r cuildi.gs.
McVe cutsida feed supplies indocrs er c::ner e.em, if possible.
Store back-up supplies cf sater insida bt41a4Ws arri c::ner c':r.dcor walls, rainbarrels, tanks er cear sour =ce of c=11ect.ad watar.
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Please do not use the pnene e.g in case of perre.:nal e"argenc'/.
2a Unitori States Ccas Cuare has been recuestad to enfe::=e a five-mile safer / :ene in the ocean kutars near Seacreck Staticn. All effe.c:n teaters near the plant are advised to relocata or deck in waters t= her tnan five
- .tles f:=m the plant.
Beacn =M rark ireas *---' Sa14 eh *e Plu-t Islard helm 4m the Parker z
Piver '7atieml Wildli*e Peere. are now cimar1 Wesens at t ese ceacnes aM rarr.s. et visitim te natica.a1 vilM 4 de mere, thculd leave those arm" L--=rW talv.
If ycu are at hcma, Icek up tha annual %=c/ infc=mtien railid to you
!=r emear inferraticn. If you are shaltir:.g at ycur *mrkplace er cther p:blic b'41d4g, check tha 1ccal *=1=nhene tex:Oc fcr a$iitional infation.
?.is intcreati 1~ c=uld be usaful in uhWMg e,r.::re reme. aces.
If ycu krew cf any n:=ight:crs er c:: min u.F.m.s with heari.g er larquace proclems, plcasa be sure eay are aware ( f tr.is message arri uh ari stat
. they snculd do.
"b rupeat: Seah:tek Station tas dev-larad a Ganeral Er.mu.3=cf.
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Attachssnt A (Pags 57 of 76)
M 17.E35 2
GENEPAL I2"ZR22K"i N (S'sZL,mC/C2tiNIT25:
SEASQaL C:DSURE CF EEAC22S AND WIICIFI RE2VGE)
(REIZAsE cr PADICCIE PATERIAL)
(cx:rme ~.e.ed)
~his :wasage will be receatad every fi.:.aen mir . stas er until new inf =ati=n becomes available. Stay c..und to this EBS static:n f=r t".a -
latast effir41 inf a ti=n.
If ycn are in any of the New F=wh eastarn Peckirzgham Ccunty ,
c:2=:rnties, ycu should tune to a local radio staticn in New Hampsnire fer i 1
DEWS ADCUC ycur NMt*f.
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l AttachmGnt A (Pego 58 cf 76) !
" TMP18.E35 I I
l Page 1 cf 4 )
catERAL nEncicy FSAct (EVAct;e:TCN AND S'rECERDC: j SEASC2IAL C.*SURE CF EEACHES AND WILDLIFE PIFUGE)
]
(10 REIZASE CT RADICL.lZ FATERIAL) i
(
Data Messace Relammari ****** !
Time Message Palame.ari *****= .
Released.h,f:
NHY Cffsite Resper.se Di. rec _ r i
A GDERAL D'IPGN0'l was riarimred at ****** today at Seabrock Nuclear Power Staticn. A GDIERAL EMERGDICY reans tr.at events are in r w&uss that eculd result in sczna sicnificcnt release of radicac ave matar:als with releases excected tc go teyond levels set by the United Statas DTIL. .ud Protact:.cn Acencf curside the Seabrecx Statien site boundary.
'Iherc _"as been no release of radioact:.ve ratarial into the air .:.a Seabrock i Stat'ss however, it is pcssible that ena c=uld cecur.
J
'Iha hew Fa-Mhu Yankee offsita Raspense or=anizaticn has been activated and is r- r.u. ling to the problem. Massacr..:setts gcVerncent efficials have been rxr4 *4 ed. '
9
'Iha Gcverncr of F*e==+ eacts r- . -- ds tha follevim:
1'--4 ata evacuaticn is *- = - -Med fer pecple in Sald eh:ry and A escur /.
Fcr A esa.e_/, tha Recep'---1 Cencar is located at the Facmam:satts Electric Facilit/ at 1101 TurTipika Street in North Ancicvar. Fcr Sal 4e M /, the Racecticn cantar is at tr.a Massac:::setts Electric Tacility at 44 River Street in Severly.
'Ita United States Coast Guard Fas been recp.:estad to enfer=e a ******-mile Safety Icne in the ocean waters near Seabrock Station. All effshcre beatars near the plant are advised to relocata er deck in waters further than ******
miles from tha plant.
PeNcns at beach and tTtrk arwa= P - n SalieWI to Pltrn Islanet LTIM4T trut Parker River Naticanal Wildli*e Refuse. e2culd le2ve thw ar===
_f amar4 4 mr_miv.
in.1ues: m t=== m fer _ u cn, e _ u cn if - y , i infc matica and message centars and referral to % yu ..tre centers. j O,
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Attachment A (Paqs 59 of'76)
TMP18.E35 O
Page 2 of 4 q GDERAL uMICY l'."SME (EM*"I37 MC SHEI2ERDG; SEASCtRL CLOSGG CF EDOEl5 MO WIIICIE REFIXE)
(}C REIZASE CF REICL.1E MNIERIAL)
(continued)
L Persons in the c=nunities directed to evacuata are advised to take the most -
- convenient Innds scuch to nain r=utas - Rauta 1, Rcuta IA, Interstates 95 cr 495 - ard trsval scuch in the direction of the Raception Cantars.
Traffic guidas will assist you.
All scncols within the cr== unities di.h to evacuata are baang evacuated to the designated Racimation Cantars for the cmmunity in which they are locatad. Parants snauld not drive to school to meet their children since scncels are new emirrJ evacuated and children are balng taken safely hy bus directiy to their Pm:acticn Cantars. Schoci children will than te sent to
-'.a Most Far-4 ' dOf :.n A where tray ray be pickad up.
If you have been advised to evacuata but de not rave your cwn-assdien and cannot get a rida fr=m a nelcpler er =evaarwie else, buses will travel along =ain amargenc f r=utas to pick ycu up and take you to a Recepten cantar. Walt for an announenn=ric statig what tima buses will begin travelirq thasa emergency twcas in your c:mmality. For cra information on the bus ard evacuaticn rcutas, lack up the emerigency -
infor=ation brecr= ras about Saabruck Staticn which were mailed to you.
. l If you have a badnddan, harri4r-a# cr other person in your hema who needs j
==-4 a l evacuatien help and who has ncre mada previcus arrangements with New {
F2n-tira Yankaa. please call tha New Fmh Yankaa offatta Responsa Emercancy Operations cantar at 555-1234. If you have already reginared, thara is no need to call new; help will'secr2 be en its way.
All persens in tha area to be evacuatad are urged to be good naichbors ard help ena another ty snaring ridas and halping et.sts with preelems.
If you knew of any neighbors or cce with language or hearing q problems, planas enack on them to be sure they have been infcirmed of tha j emargency and undarstard what tray sta11d do. 1 Before you leave ycur hcza or workplace, make sure you have put out all l firms and elemed fireplaca dampers. Inck all decrs when you laava. Taka J blankets arti pillcus with you far your own' usa ard any wari4r-inas which you :
regularly taka. Pack enough clothing for several days. If ycu are at work cutsida the .svacuaticr2 area, but live insiSa it, >w nay return hcna to t
-14* these chcras and collect family :emmers er rar====vy belongirgs.
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Attachmant A (Pt93 60 of 76) {
DIP 18.E35 Paca 3 cf 4 O
G2ERAL DfS2NCl F"92 (E'7ACL7.TICN AND SF"~IF.3G:
SEASC2IAL NRE CF EEACHES AND WIIM ar. EEFUE)
(10 FIIZASE CT PADICACI'WE MNIEP.!AL)
( - drr.:ad)
Peccle livirq in the c:s r.ities of Mer-i se/ Newbur-// West Newburv/
Newbur,m Vill be safer if 2.sy SIELTER Di F7J4E %4=taly. *his mears to recain irricors. Stayin:J inisers vill previda you with irr.:nased r wricn fr=:2 radioactive raterial released f..u Seaureck Stati=n. To get em createst benefit fr== p. *~1 pr=vided by sneltarirg, you sneuld *2ka e.a fclicwirq ac::=s:
o shaltar Lxicers.
c o
Mska sure all wini:vs and deers are cicsee ti=h:1*/.
l :f you are in your car, close all winiews and vents snile ycu travel to your castratien.
c ~ urn off all fans, heatira er air conditi.~urg systa=s if they brirq i.n outsida air.
c ~'aka a radio with ycu and ::rne to the r:cm with fewest vini:ss and decrs.
o Yaee a.L1 rancers cf your housencid ini:crs and stay :=ad to your local I; uW/ Br* Mmc System radio stati=n.
o Remain indocrs tr:til told by local er stata officials that it is safe to go cutside, er tr:til f.:r::har pr=: active actirs are .= - --W.
1 Scheels, hospitals and cc.er i.stit::tirs in the r==: mities advised to 1 shelter are takdrq s1=ilar shelterirg actir.s. Officials have irm.:ctirs )
f:r r. acting the enildren er cear perrais in c. air cars tr:til s%1terrq !
is no icnger naw"==== 7 Parer::s and ru.latives are advised ts; o call tra scaccls cr cther r.stit.: 1=.s. ner to driva to the senec1s *a atta::ct to i
p rk im their children. Cct===nty safety vill be bettar p.
rad if 24 scncels are per=1ttad to c=ncu=t 241ta:".,ng accavities.cver em next several ha.::s.
L.24 to Stata offi=ials, far ars and dairy war in tha hties of galkhurv. Amentiv. 9m ac. Newbury. West Newburv, and Newour.m, shce. tid:
M:r/a all milk-produ=irq livestcck insi,da a barn er ce.ar shaltar.
l Ptevida the arm 1m with secred feed airi vater and red =ca sources of cutsida air into their tn4 94_'z;s.
~
M:rie cu:sida feed supplies irdecrs er c::ver them, if P=4hle.
I Stcra back-um supplies of vatar insida bu11dfn::s and c:ner cu*d""
sells, rairbarrels, tanks er othar sour =es of cc11ected water.
Please do not use the pnene excect in casa of p-l emergency.
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' Attachment A (Page 61 of 76)
TMP18.E35 Page 4 of 4 GZ2EPAL IMER22iC"I 12:ESAGE (EVACIATICN AND SHECIRI!C SEASCtRL CICSURE CT BEAGES AND WIIILUT REFUGE)
(NO REIZASE CT RADIOACTIVE MNIERIAL)
(continued)
If you are at h=me, look up the annual emergency informarien mailed to you.
If you are analtaring at your -urglaca er other pumlic clilding, c .ack the local talognone book f=r additi=nal information. Siis information could be unaful in understanding fut:.7 messaaes. l l
T: recent: Saabreck Station has decla:sd a General En- y= f c=nditi9 . ,
i "his messaae will be repeated every fi.". aen ranutas er until new i .f:=amm is available. Faem t:=.ac to this EES statien f=r e.a latest Officisi i . formation.
- f you are in any cf the New F1mie eastar:. Rockin:Inam C unef c:c= unities, you should t.:ne to a local radio station in New Harare. ire for news aceut your -trtu f.
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i Attach:nant A (Page 62 of 76) f
-'MP19.E35 Page 1 cf 4 ,
GENERAL DEPGENCl MESSAE (E7ACIATION AND SimNG: 1 SEASCtaL C:.:EURE OF EEACNES AND hE1DLur FIFUGE)
(REIZASE OF PADIC7w-.E MATERIAL)
Data Fa*=.ame Released ******
Time Mesrace Raleased ****** )
8 Raleased Lf: 1
}DIY Cffsita Rasp:r.se 01:1tet:r i
A GENEPAL DERCENCl was declared at ****** today at Seabrcok Nuclear Power ,
Staticn. A GENERAL EMERGENCY :neans that events are in s + r.55 th?t could !
result in sczna sicnif1=:L*:t release cf. Ndim :: va tatarials with re. lease.s excecta:1 to go beyers:1 levels set b/ the United States Envu-ud Pr= tac::len Agency outsida the Seabrecx Stata:n sita bourstary.
A release cf radioactive ratarial into the air ccc:.* Tad at ******.
Iha New F*=MM Yankee Offsita Pastensa Cr=:mizaticn has been activated I and is re.5r.u.drz:J to the pr=ble:n. Missac rt.satts geve . nr. officd$1= have been notifiad. l i
The Govern r of Massac:t.setts u- - .;s tha f=11 cuing:
\
7-=d4 *ta evacuatien is ramernandad f r people in gg]4e51rv and A eserv. i' l For k'insarv, the Racecti:n Cantar is 1ccated at the Fa===*'=tts Electra:
Facilit/ at 1101 ? 1.km Streat in North Ancicver. Fer Sa14"M.try, O.a i' Tuscacti:n Cantar is at the P.usac:::setts Ele IW-4' 4t/ at 44 River Streat in Beverly.
Tha United States C sst Guarti has been requestad 'tc enfer=a a ****** T'tila safety ::=na in the ocean watars nau- Saabrecx Station. All offshcre beatars near the plant are advised to relocata er dock in vatars further than ******
- ales fran the plant.
1 Pecns at M and rark ar=== ^
._a Salielurv to Pltra Island, incl"Mi-rr the I PeltAr Pive.r Natienal Wild' 4 *e Paftre, eheuld leave tW armam i n 11 F siv..
ICIE: "3E TVIEWI!C IS 'IQ BE READ CtfLY IF ADVISED BY EE NIN 1 EhMPSHIRE YANKEZ CITSITE RESTCNSE DIREI:ItR WAT 'IHIS DK"ICDC MAY CR WIII. Fa.su.u; A C=CAMURTnG ACC DE. i i
'Iharm is a gocx1 possibility f=r this a wm 9/ to produce a .
=mtin:7 am4 Ment. It is st:=ngly rarmmanded that as a 1 r w W , p.4.w . leaving the towns told to evacuata go to !
their de"ignated Illcapti0n cantars fcr tunit:::r.*JI:J.
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Attachment A (Page 63 of 76)
TMP19.E35
_(
L
\ Page 2 cf 4 GENERAL IMERENCY MESSAGE (E7ACC7CI2T AND SFFTTF5UNG:
SDSOEL C*M CT EDGES AND WIIIlLI2T EEFUGE)
'(REEZASE OF PADICACIT,*E FATERIAL)
(cnntinuad)
Services .cffermi at em Raception Cantars and rwmmmerled for all evacuses ,
include: monitcring fcr contamination: decontamination if rammannimf; information and cessage contars; and referral to ccr gregate care contars.
Persons in the ccumunities directed to evacuata are advised to taka the mest convenient toads scucn *J main reutas - Rauta-1, Ecuta 1A, Interstates 95 cr 495 - and travel south in the direction of the Racegre.icn Cantars. 1
~taffic guidas v11';, ass 2st you. l All schecis within e.a c:=:= unities dira:=ad to evacuata are beinc evacuated to the desicnated P- m Cantart fcr ca ci=munity in which they are
'.ccated. Parents snctild nce drive to sc21cci to mest e. air enildren since scncels are now esing evacuated and childran aru ba2ng takan safely cy. bus
' directly to their Raception Cantars. Scheci children will than ce sent to
- ha Host Tad 14ty in A kners they ray be picked up.
.If you have been advised *J evacuata but do net have your own u -g.mation and cannot get a rida fram a neight:cr er scuinons else, buses y( will travel along ma2n anergency rautas to pick you up and taka you to a.
W h Centar. Wait far an announcement stating what time buses will begin. traveling e. ass energency rautas in your c=mmunity. For more
'information en em bus and evacuatican rautas, icnk up the amargency infor=ntion brec=:rus c.bcut sembrtek Station which were mailed to you.
If you have a beeedan, handicapped er ethar persen in your hc=is who naeas special evacuaticn halp and who has not mada previous arrartrements with New FJmq:ianira Yankaa, please call the New Fa*m Yankas Cffsita Respons:t .j T = v= c/ operaticns Cantar at 555-1234. If you have alreacy rayistared, there is ne noen to call now; help will scan te en i+J way.
All persens in tha area to be evacuated aru urged to be gecd neighbers and help cna ancthar by sharing ridas and halping echars with problems. ;
If you kncw of any neighbcirs cr cc - with language or haar.:x; precians, please check on than to be sure they have been infnmad cf tM energency and underscani what they should do.
Before you leave your hcna or werkplace, make sura you have put cut all fires and ciceed fi1Ti em '4==m. Icck 811 decrs when you leave. Taka blankats and pillows with you for your cwn use and any ==44r 4'us which you i regularly taka. Pack ancima clothing for several days. If you are at werk cumida the evacuation area, but livo 2nsida it, you may return hces to amt 4* thane chccus and collect family mancers or necessary belongines.
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Attachssnt A (Pcg2 64 of 76) i i
UfP19.E35
{
Page 3 of 4 GDIERAL DTG2iC'l "mc (EVACC7CICti MC SHEI s r uRD SEASQtAL ORE CF EEAGES MD WTTnr.T7E m) ,
I (REI.ZASE CT PADICAct!VE PATERIAM j (c=rti:tleci)
Feccle livirry in the c===muties of Mar-- se/ Newburv/ wm Newburr/
Ne'Ax: voor will be safer if they S*m. Di PIACE i mamateJ.y. Otis neans to re::n.1.n Indocrs. Stay 2ra 2.ndccr= will prtvida you with ir.= eased j prctacticn L a radioactive ratarial relamud fr:2n Seabronk Staticn. ?c get i t *ha createst benafit fr:2n pr=tacticn pr=vided by shaltar::.n:J, ycu saculd take the !clicwirx; actira:
c Shaltar irri::crs.
c Paka sure all wirris.s and decru aru cleced tichtly.
o :: your are :.n your car, clesa all wirriews are vents -nile you travel to your destraticn.
'o ?.:In off all fans, neat.rm er air ditierenr systa if they brirx; in outsida air.
o ~hka a rudio with ycu and rcve to tra ro=n with fewest. wini:ss arri decrs.
c Keep all memcers of your hm=+1d ini:crs and stay e.=.ed to your local E::argerx:V 2:ead= st Systa:n radio station.
c Famain irri:cru um11 *Md by 1ccal er stata cfficials rfat it is safe to go outside, er tr:t:a f. ther , m.ive acticns are rm =rz:ied.
Scheels, hespitals and cther irstit:.:tiens in the m-mmities advised to shaltar are taking st-i h chaltering acticns. Cfficials have irstz.:cticns fer pr:tectirry the enildren er cther persons in their care ur:til shalterig is no lerner racew' /. Parents and relatives are advise:1 n g to ca 1 the scn::cis er ether 1rstit:.:ticn, ner to drive to the scncels to attu e to pick ;
uc tra4 children. Cec::s=ntf safety vill be bettar pr=tected if the scnocls are perrmand to c=n::u=t sneltenrxJ acr.ivities ever -he next several hcurs.
W -iirx; to Stata cfficials, farmers and dairy cperatcrs in tra m-mmities of Sal %urt. Amer M--me. Newburv west Newburr, and Newbur/ccrt, should:
Msve all milk pr
- rig livestcck inside a barn er cther shaltar.
l
- Previda the animals with secred feed and vatar and recuca sources of j cutsida air it:tc their btildigs. ~
l 1 -
(
- Msve outsida feed supplies irdocrs cr c=ver them, if pcssible.
Stcre bar k-uc supplies cf water insida biiladms arti c:ver ce"Mr walls, rainbarrels, tanks er cther razrces of cc11ecta:1 satar.
Please do rce use tha ph=na excect in case cf parra:al e:nergencv.
If yea are at hczna, Icek up tha annual m.m y infc:=atica railed to you.
_ :f you arm sheltenrry at ycur workplace or etbar p*r bd1d4W , check the 1ccal *=1% bcck fer additicnal infc:=atica. ':his infermat1=n c=uld be aseful in urt. . xiirrJ f.:::re maanes.
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l Attachment A (Page 65 of 76)
DT19.E35 Page 4 of 4 GINDAL DG5EDCl F255;E (r/AC W AND Shu.a.wC:
SEASCNAL C.CEURE CT EDCHES Am WU.ILUI REftXZ)
(REIZASI CT TADIAT/E MNIERIAL)
(conti.~:ad)
To repeat: Seabrcok Stati=n has dar-lam a General Ecargarrf c=ndition. ,j 1
Otis massaae will be repeated avary fiftaan minutes or until new .I infc.M en is available. Kamp t.:nad tc this EBS statien for the laast ,
efficial inf::cmation. i i
- f you are in any of tha New Fawnin eastarn Rockingham CCLErf ,
Mc= unities, you should t:,:na t.= a loca.L radio station in New Hamcnnire for news about your c:: mun:.t f.
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Attachmsnt A (Pcg3 66 of 76)
OT20.E35 GDERAL D'IRG2TCl *aEAGE (EVACIATICti; Page 1 cf 3 9i l SEASCtDL C".OSURE CT EEACIES AND WII.DLur REFUGE) l
.1 1
(to REIZASE CF RADICC/E MAIERIAL) -
4 Cata Maenne Ralcazari ****** j TitaPmtcaheReleased****** q Paleased by:
lHi Offsi a Raspense Direc==
A GENERAL E"2RGE2TCt sus declared at ****** t: day at Seabreck Nuclear Power Staticn. A GE2ERAL EEGZ2 ICY neans that events art in precress that c:uld result in sme sicnifi=2nt release of radicacuve catar?J11s Vlth releases expec:ad to go beyon:t levels set Ly em UW.ed States Envia. ru21 Pr=tacta:n Agency curside taa Seacr::cx Sta"~1 sita bcundary.
? tare has baan no release of radioactive ratarial fr:2n Seabrecx Staticn:
however, it is possible that cne cculd .
Da New Hancsnire Yankae offsita Rasemise organizat.icn is respcmirn to the probism. KN governcent effi+1= have been notified. -
2a Gcvernce cf !"assac:re.setts Ir- - -- 4.s tha fellevirzy acti=ns.
-==M ata evacuatica is re f:: peple in saliehrr/ A". eebr'r/
Mam_ _ se/ Newbrt/ West Newburv/ Newbure.
l Ter I:9aerr. '**ast Newburr and Ma_m_-se O.a Recepticn Cantar is 1ccated at >
the Ma=w rasetts Electric Facilitf at 1101 Tarr:pika Street in Ncn: n l AndcVer.
- For Sal 4-Hrr. Newbury and Newbre the Reception Cantar is at the
!"-m.J.setts Elec=.c fac1.Lity at 44 River Street in Beverly. i ta United Statas Coast Guard has been regaastad to enferta a tan-mile Safety zone in the ocean Vatars near Seabr:ck Staticn. All offshore boatars near the plant are advised to relccata er dock in watars further than ten-miles fra the plant.
Persens at bGach and rark ar=== n .a !!alie to Plu-t Island, LTl"44m PA Parkm* River Natienal Wiglife Pefuce, should leave tW areas i"lmtK115telY.
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Attachment A (Page 67 of 76)
~
TMP20.E35
] )
Page 2 of 3 GDERAL IMERGE2R"Y MESSAGE (EVACCATICH:
SEASCtaL C*l:SURE OF EEACHES AND WII.*mE IE2VGE) .
(NO REIZASE OF RADICACI'IVE MATERIAL)
(ccritinuad)
Services offarad at tha Pacepticri cantars and raccanarded for all evacuses
- includa: mesur. .nq fer --- - -tion: d e m tien if necessary; !
infezziaticn and message omntars; armi referral to ccrgregata care cantars. ]
Persons in tha a:x=mInities directed to evacuata are advised to taka em most cerrvenient 1: ads scarth to maan reutas - Pouta 1, Rauta 1A, Interstates 95 or 495 - and travel scuch in the directicn of tha Pacepticn Cantars. l Traffic guidas will assist yeu. '
All scncels within tha cc=nunities dirsecad to evacuata are balncr evacuated
- m em deslanated Racuat:.=n cantars fcr ca ec= ; 4ty in whicn they aru locatad. Parents snculd not drive to schoci to met trair cnildren since !
scncels are now ca2rg evacuated and children are bairq taken safely by bus directly to thair Recept 1=n cantars. Scheci children will than be sent to cw-fota Cars cantar A in Waltham waara they may be pickad up.
If you have been advised to evacuata but do noc+. ave your own LoreW.icri and cannot get a rida frun a r=4?* c scannone alsa, buses v wi.11 travel alcrg rain emergency reucas to pick you up and taka you to a P w len cantar. Wait for an announcement stati:q wnat tina h= will begin traveling thase emergency teutas in your town. For nears information l en the bus and evacuati=n reucas, look up em amartgency information brocnuras about Saabrecdc Staticn which were mailed to you.
If you have a bedr:4!an, hard4"===4 cr ethar person in your hcuns who needs *
==-u 1 avacuaticn nalp and who has not mada previous arrangemern:s with New I
Hamosnira Yankaa, please call the New Hampanira Yankaa offsita Response Em=i y operations cantar at 555-1234. If you have already registared, tharu is no need to call new; help will soon be on its uay.
All persons in tha area to be evacuated are urged to be geuf n-i@W and help cna anothar by shari:q ridas and halping others with problems.
If you know of any :=4?* cr ecMerkats with language cr haarire problems, planas check cn than to be sure they have been infamned of the emergency and undarstarsi what they shca11d do.
Befers you lasva your hena or werkplaca, ::aka sura you have put out all firma armi closed firuplaca dampers. Inck all decres unen you lasve. Taka blankats armi pillows with you fcir your own use and any =44e%a which you rugularly taka. Pack enougn clothing for several days. If you are at work l cutsida the evacuaticrt area, but live insida it, you naf return hczna to j amlish these c= crus and cc11ect family mammars er necessary belongings. ;
I jg Please do not use the phens except in cash of punanal emergency. j i
If you are at hamn. taka with you the arruzal emergency informaticri vmind to )
you which imin4== evacuation rautas and sm . If thans are t unavailable, cracac tha local *=1= Mria book for additional information. ;
Attachment A (Pago 68 of 76)
TMP20.E35 Page 3 of 3 GDE"RAL D'IRGDiCY METSACE (E7ACCATIC21; SEASGML N OF EEAQu3 Aht WIIILUT FIFUCZ)
(10 RET.ZASE CF PADICm/E FATERIAL)
(conti.~. M )
To ngeat: Seabreck Staticn has declarai, a General frargenc/ %dition.
S.is ratssaae will be re=eated every fi?aan rirurtas er wW. new int ==ation is avni1ahla. Faep c:ned cc tb_is EBS statien fer tha latest offi '*1 intczmaticn.
If ycu are in any of tha New FLMire eastarn Rockimham C=urr/
cer: uuties, you should t=ne to a local radio statien in New Ha-E, fer news amaut your e- mnuty.
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Attachment A (Page 69 of 76)
OTRY.E35 J/4 Page 1 of 3 CENERAL . Nict ."_ SME (E7ACATIC2O SEASC2Ud CI.TJRE CF n~d' EES AND WIIE.III PZFUGE)
(REIIASE CF PADICACIT/E PATERIAL)
Data Messaga Raleam ******
Ti::n Massage Released ******
~
Teleased by:
1001 Offsita Paspcnse 01:3c:cr A C22ERAL 1 MicY vas dar-lamd at ****** Way at Seabreck IMclear Pewnr Staticn. A GENERAL ZMER22iCl :aars that events are in m r.ss c.at c:;.1.1 result in some sicnifi::nnt release cf radicact:c/e ratarials vie. releases ex ac:ed to go beyond levels set by e.a United States Env1 acal P: octicn Aganc/ cursida the Seabr:cx Staticn site boundary.
A release of radioactive ratar:.al i.:::c the air ecc.'. Ted at ******.
2.s New Hamcahire Yankaa offsita Pasp::nse organization is si= edin; to the p:cclem. Pammar+.usetts g=ver. Tent efficials have been notified.
The Governer of Massac:t:satts rm g is the fc11cwmg acticns. .
4
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data evacuaticn is ruer- wided fcr people in Sal 4+ur// eescu-v/
Mer-i sc/ Newburt/ Wst Newburv/ Newbur,m.
Fcr A" awl, the Pm'eticr. Cantar is located at c.a PAmmar 'r.:satts Elia. .c Facilir/ at 1101 Te:rT:paka Stract in North Ardevar. For Sal %u--/, 2.a 6cn Cantar is at the Pm tam:satts Elec= c Facilief at 44 River -
Street in Beverly.
Tcr Newburt and Newbur,e, O.a Paceccicn Cantar is located at the Massac:".:satts Elect:::.c FaciliT/ at 44' River Street in Beverly. For F.gs Newburv and h_-ac, the Recencien Cantar is at the Pancam:satts Elec= c Facility at 1101 Tu=pda St= net in North Andever.
2.a Unitad Statas Coast Guard has been requestad to enforca a tant.ila S&fET/ Zcne in the ocean vatars near Seabrock Staticn. All offshcre beaters near the plant are advised to relocata or dock in vatars further than ten-milas fran the plant. -
Persens at benen and rark ar=2s L _.. Sal 4br to Pltrn Island. LmelM4m the Part.ar River Natienal Wildlife Pefu:re, s.heuld evacuate these areas L-"=ncti atm i v .
Attachment A (Pago 70 cf 76)
M2M.EIS
-!']
Page 2 cf 3 G2EFAL D'IRGDiCY "SME (N41aTI3f SEASC2aL CLOSURE OF EZAGES AND WTTr:L rz RI2VGE)
(REIZASE CF PADICACr"lE 1%TZ3.IAL)
(cen L :ad)
NCIE: EE FOLIGfDG IS 'IO BE READ CNLY IF ADVISED BY 'IEE 1E34 '
IGMPSHIRE YAfDCEE Ctt: ant F25R21SE DIRECTCR 'DET 'IHIS DiCI:22fr FAY CR WIII Fmwd A C:2 TIT 402RTI20 ACCII22TI:
'Ihare is a goed possibility fer this emergercy to produce a h -- ' acLg accidant. It is str:rgly rammarried that as a precautlen, g.w leavirq em towns told to evacuata go to !
their designated rececucn centers fer ::enit=r:rg.
Servicas efferec at c.a Racecticn Cantars and rer nerzied fer all evace.ees i.T1ude: enitorirq fer wa::u.rauen dec=r::.a::u.natica if remry; i .ferratien arri meege cantars; arx1 referral to my&prota care cantars.
Fe.:sens in the m' tities directed t svacuata are advised to taka the z:est convenient reads south to main routes - Route 1, Rotrea 1A, Ltarstates 95 or 495 - arxi travel south in the directicn of tra Racepticn Cantars.
Traffic guicas will assist you. -
All scncels within the m="1ities directed to evacuata are berrq evacuatai to tha casignatad Rececti=n Cantars fer the m=wtity in which they are lccated. Ferents shcx11d not drive to schec1 to mest their children since scncels are new being evacuated arri children are bearn takan safely cy L:s directly to their Racepticn Cantars. Schcol children will then be sent to C y*r.gsta Care Cantar A in Waltham %nere they ray be pickad up. -
If you rave been advised to evacuata but do net have your cun wuwatien arti cannet get a rida frem a neighbcr or *.r-ne else, buses will travel along rain emergerurf routes to pick ycu up armi take you to a Ix eptien Centar. Wait fer an announcement stating what time buses will j tagin travalirs thara %- f rcutas in your town. Ter mere information j
cn the bus and evacuatien rectas, icek up the %.cy irife::stien j h:te:t.=es abcut Seabrock Staticn which were mailed to you. !
If ycu have a bedriddan, hard--4 cr other person in your hcme who needs specia.1 evacuatien help arri vbo has not rada crevicus auo.iy -s with New Fa="i's 'lankaa, please call tha New F==*t's Yankaa Offsite Rasp =.se !
D:sergency Cperatic:s Cantar at ******. IfM have already registared, trare j is no need to call neu: halp will scen be en its way. j l
All Aw in the area to be evacuated are urged to be gecx1 r=i? crs arri help ene arcther by sharirs ridas and helpirq ctners with prtblems. {
3 If you know cf any neighters er co-verkars with language er haar rg l proclams, please check en them to be sure they have been ir a cf tha j emergency and urxhan what they should do. !
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1 Attachmsnt A (Page 71 of 76)
F.P 2+5. E3S j
.: r- :
- t. !
l l l Page 3 of 3 ]
l GDGPAL IEEK22iC'l PJ!3 SAG: (LVACCATIC2O SEASCt&L C::SURE OT BEADE3 NiD WIIM.III ruww:.)
(REIZASE OF RADICACII*.*E MA:tIP.IAL)
Before you leave your h::na or workplace, :aka sure you have put out all fires arri elemed fi.71r=da m . Lock all doors when you leave. hka j blankats and pillows with you for your own use and any medicim which you 1 l
ru:Jularly taka. Pack enougts c1cchmg fer several days. If you are at work ,
, outsida tha evacuation arum, but live insida it, you may return home to I
a-14*h t!mme encras ami miim family remoers or necessary belongmgs.
Accertiing to Stata officials, farmers and dairy cperators in the ccumunities of SA14 *m_ r. k'==ner. Merr-ac, Newbury West Newtxzrv, and Newburveert, should:
{
Fove all -4ik-precu=: ry livestecx and e-J.ar graz1:x; animals insida a barn or cther snaltar.
Provida the animals with stored feed and water and recuca scur=es of outsida air i. to their b'41M4mJs.
- Move outside fasi supplies in:lcers or cover them, if possible.
- Stars back-up ==14== of untar insida bi41dimps and cover outdoor ,
i walls, ilu.nbarrals, tanks or ether sources of cmilected water.
Please de not use tha phone except in case of p
.-.el emargency.
If you are at h:=is, taka with you the annual emergency information railed to you, whicn includas evacuatsan rtxatas and proceduras. If these are unavas.lable, c.ecx tha local talepnene took f:::r additi ~
al inferraticn.
To reenat: Seabrock Station has declared a Genarni Er .y.cy ceniiticn.
i 211s messace will be repeated every fittaen mi:LT.as or urreil new intcrmation is available. Maap tuned to this I25 staticn fcr the latest ;
official infe:=mtien.
If you are in any of tha New Hammshire eastarn Ecckingham county catmunities, you, should t=na to a local radio station in New Hampshire far news about your c::maanity.
e
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l i Attachment A (Page 72 of 76)
TMPM(. E3S 7- / b Page 1 cf 3 GDERAL DSGDiCY MESSAGE (IVACCAC3f SEASGtAL N CF EEACHES AND bTT.EE PHUGE)
(REIZASE CF PADICAcrr2 PMI CAL)
Cata Maataeva Released ******
Time Manage Ralemee ******
Ralammari by:
}DE Cffsita Responsa Direct =r A GCtERAL EECDR.! vas declared at ****** tcday at Seabr ck Nuclear Power Statien. A GDERAL DERGETCZ means tnat events are in w rs.s ca.t could result in same sicnifiesnt rnlease of imr44r ar tive matarials Wie. relaa==
e.v=-~4 to cc beyens levels set 1:/ the United Scatas Env _.r. ara.1 Frc :ac:icn /cency cu:sida t .a Seabrtek Statica sits b:: =r. arf.
A release of I"dicac 1va catarial 1::co tha air e~ rad at ******.
The New FJ:nsni.M 2arJa.e Offsita Paspense organization is re.gdi:x; to e.a problem. Mmar-~: arts gch -w officials have been notified.
The Governcr of Pmar :setts mrxis tha follcWirx; ac:icns. -
m-44ata evacuatien is rammerxiad fcr peccle in saliew/ hescurr/
Mer- -se/ Newburt/ Wart Newburr/ Netter .
For Ar==t r. WaEt Mawbu'-r and Me _-ac the Racec d 7 Cantar is lccated at the Massaccuset :3 Elec=.c Facility at 1101 h.1ka Street in Ner:n AndcVer.
For Salieh2rr Newbur r *_'d Newbur.-en, the Paca:'tien Cantar is at 2.0 Mame msat*s Elec=.c Fac1.lity at 44 River Street in Eevarly.
Tha United States ccast Guard has been Inquastad to enfcrce a ten-mile safety zcna in the ocean vatars near Saabrock Station. All offshcre boatars near the plant are advised to relocate or dcck in vatars further than ten- I miles fr::n the plant.
Per%E at beach ard taw areas f --! Saliehurv te Pits Island, inclM4 'a the l
Pader River Natic .nl Wildlife Refuce, ehecid leave t**w areas !
1:'lmediatalY. .
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Attachment A (Page 73 cf 76)
IMP 21A.E35
\ . !.
Page 2 cf 3 GREPAL E5:CICY ."93Z (EVAC.ATICN;
,' SEASC2DL C:f:SCRE CF EIAGES AND WTTNM "EFUCE)
(Nr. CF PADICACII"E MATER.TAL)
(conti:tt.ed) 5ervices offa.ra:1 at the Racepticn Cantars and rm - --- dad fer all evacuees
- B
- rcluda: moniter:.M. fcr c . a=1rati n; decentaminanten if necessary; inf =aticn and messaca centars; and referra.1 *w w qeta cr.re centers.
Fersens in the et?nties directed to evacuata are advised to taka the most
- cnvenient reads south to rain routes - Poma 1, Rauta 1A, Interstates 95
- 495 - and t=svel south L. the directicn of the Recepti:n Centers.
nffic gmden vill assist you.
All s=cols within tha -J. tics direccad to evacuata aru tein: evacuated t .e desicnated Rece=t1=n Canters f:r the ccumunity in wnica e.sy are
' cated. Parents sea. tid not dnva to scncel to meet cai~ c- 'd en since s=::cis are new bears evacuated an:i c.ildren are being taken sately ty has directly to their Rece=ti:n Canters. Scheci children will than te sent to C e.% ta Cain Cantar A in Waltham knere they ray be pickad up.
f you have been advisad to evacuata but do net ,have ycur cwn
[ t::anstcreaticn an:1 cannet get a rida fr:xn a neighbcr er -,na else, buses 5 will travel alern rain emergency r=utas to pick you up and taka yeu to a Eacepti::n Cantar. Wait f=r an armouncement stating what time buses will beg:n' traveling thasa =r%=c/ rcutas in ycur twn. For rcre infer =stien en the bus ard evacuarien reutas, lock up the omrgency infcmanen brtc:::res about Seaa dc Stat:.:n stic:*. were railed to you.
- ! you have a tedridden, handicapped er other pers2n in ycur h=me sne needs spac:.a1 evacuaticn help and uno has n=t rada previous arrarce::nnes with New P-tire Yankee, please call the New Ha~mrtire Yankaa Offsite Fascense L:r.- =c/ Cperaticns Centar at 555-1234. If you have alreacy racistered, OJ:re is ne need to call now; help will seen te en its way.
All persens in the area to be evacuated are urged to be goed neianters and help ene anothar by sharirg ndas and halping cthers with pr=blems.
If ycza know of any neigh!:crs er co-worxars with larquage er hean.g prtclams, please check en the:n to be sure they have been irst wd of the e::argency and undm.au what they shcx11d de.
l Eafere ytx2 leave your home er werkplace, maka sure you have put cut all films ard closed fireplace H+-nam. I.cck all decrs stan you leave. Take blankats and pillows with you fer ycur own use arx1 any tw44+.as snich you rsgularly taka. Pack enough c1cthi.g f::r several days. If you are at ucrk cursida the evacustica arma, hre liva inside it, you may return rane to a<
.-lish these chcres ard c=11ect fa=ily members er r ===q belcrgirns.
s.
Attachment A (Page 74 of 76)
I W. m A.E25 Pace 3 cf 3 GZ2tEFAL zM.;C l .me-E (E7ACI:ATIC21:
SEASCNAL C3RE CF EIACHES MiD WIIT.:L':2'I m.ivra.)
(REIZASE CF PADICACTI'/E PATERIAL)
(cmm1 Accc:"im t: State officials, fam? s and dairy cperaters in the c:r--'nities of Sal k ury.
sto. tid: Ama=-c.rv. M - - se. Mawbury. kese Nawbury, and Newtxtr m,
- 1 Move all m'1k-prod:cing livest:ck inside a barn or ethar shaltar. '
Previda e.a anm1= with st= red feed and vatar and reduce sources of outside air into their b.:11di.cs.
Fa/e o.ttside feed scplies 1.ccers er ==/er them, if possible.
Stern tack-a.:n srplies of varar :. . side bei W cs and c /er ctrd:cr I walls, rain =arrels, .snks er c=er sources cf c=llected water.
Please do net use the ph=ne except in case of perscnal emergenc'y.
l If you are at h::=e, take with you the annual e%wcf infati n : ailed c you, '-nich i.ne-D d ae evacuatien rectas and re. If these arn unavailable, cnack tha 1ccal talephena bcck f r additienal infer =an::n. .
To repeat: Seal.Ak Staticn ha.s declared a General Emergency c=nditi:n.
This ressace vill be repeated ever/ fi."aen minutes or until new infer =at:.:n official is available. Faeo tuned ec this EES statien fer e.e latest i .f:r=ata=n. .
If 'icu are in any cf the New R==al e eastarn Rcckincham Courr/
= nities, you snould t:.:na to a lo::al radio staticn in New Ha::=sn:.re f r neWE atcut your -'nitf.
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Attachmant A (Pcgo 75 of 76)
TMP26A.E35
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.(V)' Page 1 cf 1 SUFFIIMEND1 MESSAE 3 FREI:7J.TrIC!tARY ACI!O S TCR INNDS, FAMi W2KERS, FCOD PPTAT4 AND IDCD DIS"mIE7ICRS s
Cata Masnaca Released ******
- Time Massage Released ******
Ralmacad by:
200f Offsita Easperse D1.vm (Salect Acti=rs As Apr patta) l The fellow 1rq ressaca is directed to farmers and food distr .butcrs in the l l
c==munities of Salieer and Am==er.
Due to the a-w f c=ndition which has been declared at Seabrock Stati=n, 4 Stata authorities have mridad that precauti= nary actions be taken by 4 fames and fcod pr-ems in ses areas surrcundirg the plant. Thesa
-O actions are called pzwventive prcreactive actions an.t are based on policy
.j V
adopted icng befera seabrecdc Station was cparaticnal. They do not mean a release of radiatien bag eccurred or v.ill occur.
Acccrdirg to Stata officials, fa-rs and dairy cperaters in the ccrnmunities of Salieve and Amamarrv shculd:
o Mava all :.ilke -in:y livwn and ethaI grazirg arm =1= insida a barn er cr.har smitar. i o
Previda tha animals with sttW. feed arxi water and recuce scu~.ar.s of cutsida a.1.r into their bt41 dims, o McVe outsida feed supplies dixicers er cover them, if r=4hla.
o Stars back-up supplies of water iasida bt4144ngs and c=ver cutdecr wells, rainbarrals, tand or othar scurces of collected watar. ;
o cau ***4 ** for rcra infor:naticn. -
Teod rarkstars and sw ers in tha ****** of ****** should:
o Stay tuned to this station to stay awars of r - ---a acticns m M iry focd itams. ,
i O
Call ****** fer Cert infctmation,.
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Attachment A (Page 76 of 76) j M 266 E3S .
Paga 1 of 1 SUFFmCTIAL 1^25 SAGE 3
\
NEC7CTIQDM ACTICNS TCR P" ARMERS. i 1
TARM W3RKERS, FCCD E -WR5 AND FOOD Dhau.cuwsci Data Massaca Paleased ******
- Time Massage Released ****** I Faleased by:
!M offsita Faspense Directcr (Salect Acticns As Apr g .ata)
Sa follcuing r**=aga is direc:ad to farmers and food distrib::c::s in em m mities of Salie ttt r. -
A-==
urv and Mer ene. 'iewtxtr r. West Newtxtrv.
Newtxr .e.
Cum to the amargancy c=n11 tion which has baan dar lared at Saabrock Statien, I Stata autivarities have reer:=imanded that prw-='We nary acticns be taken by farmers and food ee. = = _ra in sma areas sur:rr:11ng tha plant. Seas acticns are called trevantiva pretactiva acticr.s and are based en policy adopted lary bafera Saabr:ck Station was operational. tay do net maan a release of radiatien bag occ= Tad er wM occ=r. l AWL *q to Stata officials, farmars and dairy q=ha in the
.mities of Sa14 * - t mi A-*=s-v and Me--me. Newbury, west Newburv j Newbur etera-- L*1culd: '
o Mova all milk-prot 2cirrJ livastock and other gra:irq anirals inside a barn er othar shaltar.
o Previda the an2mals with sttrad faad and watar and ratsca sources of outsida air into their huidings.
o Mova n*=4d= feed supplies indcors er c=ver them, if possible.
o Stcre back-up sucplies of water insida hi41 digs and cover cutdecr walls, rnit+="rals, tanks or othar sources of collac:ad water.
O '
Call ****** f:r 2%2ra infctmation.
Food rarkaters and p_ " ' ~m in tha ****** cf ****** should:
o stay tuned to this statien to stay awara of r=.
IngardirrJ focd itams. - w acti=ns
(. o call ****** fcr :cra intcrmation.
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l ATTACHMENT B l
(Massachusetts Emergency Information Flowchart) l O .
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G D A OS NI T C I E - -
M f E RE PPS O I E BA ET LA BO UR M -
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4 T I T R S A O F T F S S N Yt O ClE 0
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ATTACHMENT C (ORO News Release #25/ORO EBS #8) 4 4
4 S
- - - - - . Attachment C (Page 1 of 6)
(-
.. i n :n w
M H: NEWS RELEASE Massacnuse::: Offsits Resconse Greanization of New Hamesnire Yankee
- ~5:5 IS A EKt L *** *** ':HIS IS A IIGIL ***
20C0 PRIXI:' 127E5ICCK TMOGR REINIRY Page 1 of 3 l
- 1anse i rc m once Hammano Raleases: osryeV 9 T.an naamaan asGemeen: M)nP7 8 ~Q,. ,
Releases ty: IW / A^ s.-
t mr.c: cerv, .
1 V.
= f=u tm/ y- ==svin: ,.-zt
- - .. Yarmas under tyts.
Mammacraasects autnerszy v.4 offsita ty tas Rampense Goverrze crym-m af NamP. , '?
of NN.'.
e After arcamtve mangiap ten tcuns of Ammatzacy,
. - y, . m,.sr:1 anal .~. ..
Yankee Cffsita Rampmma 9mpur'*d= bas deihtesunsi12st at p::ssanc, only farse.ru raam:.:q livestecthiergui' aurt ernmuseeuws any r ,- . g-ny 21syssit A their farms. Kameurs of%khmatimLidiais are ama-kM- e F- '-h-rT47't*.
-1_%.w'- -- K---- -
' V in ten t:wns of Ammacury, $nlistzscy, Metr :mac. Sedzaty, Most Nessimir, Neucuryyzec saculd fc11c. this6 Mar - ..t asms=ruze rannen oefsica mass === pun s::cc==: rete ====rar ly rev2=1t-tamar farms.".4 f t,-
9" man vestemt far i arxxId trity picture
. ~ .f t,. f _mers i w of-$ %.-
r
--- or em gaz;gg
...g GGEE"tpetDWn 4,/ .T - ..
I:tatsscticr1 of Jackman arIi
.~ streets
\ u3
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1t. -
'g At L ?-- - im of '23xcicw anti N'*EE 88E8"'
I \\ ef GrovelarsiY, Me- 3 Bear Hill, pffield, severt star A V' armi u tfis sceas Seven Star M. arsi.NSt:
,i W W N. Y (RW 113) 9 e* .
. . . . m...,.. . . ,
1 Attachment C (Page 2 of 6)
I"' ** '* '
7 neDi. ... t s a P. u P
Wf C NEWS REl. EASE Massachusetts O!! site Aescense Organization cf New Harnoshirs Yankee I
l i
- Dtts 3 A GtIII.** **THIS IS A DR221** 6 ~3 A C3tII.L**
Page 2 of 3
. nric-esm manen er aos EE22l:::E i
'b.
Haverrm_ 5 gg tm og 3,,,mgy Line Acan & Metz:ame mand
~
EIr+=r-rm'Qu.aishsy
- a, .
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- ? *. AtIntiSt3m31Ettof W /
Sf., Liam E%srzt Hasta amed e .
\r 4-sa ,. At I-495 2::cerc=srups witti 4W
- R
\ oute 110 5
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g ? At h e of Routs 108 :
25, . s* 4' ""i8""'"llT,N
= 1 sr.
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en n,in st. mo=== . to .. .
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M xm==rr cr====
DeGuinapuune
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- p' 6 At Idbaramecum of carazzi St.
- at:1 U.S. 1 At wm of Hillside St. and Gian St.
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At the accums " ; - " livestaust ftE3m3 Will W.
A tuumacar is a ammal devios runsive for mamma:2m.= a dcminucar
.*='4m and %g- 7 b' will tut logget in and.cus of the aram2P/rg:'..-:,7 otts e - ent aumegener 6 .
,f .
Fue t:liLh cenurticut, W rumadents snould listan to their leeni L, * _ systant radio scuticru WueT-FM (92.3) and lesLV-AM (1490 \
v k-------
= de== ini=y == ans qu-=icri., t=n-er m.m n== ==en - l
( , establishna f=r .h residents. 'Diese seculd be used to.chetic
- -4-1= inscrust
- en accum the aumegurcy.
':2 roomtve uiten=uszcat, .$4me==r=== cts rusadents aart call-1-400-111-2222.
i Attachment C-(Page 3 of 6')
f h ,:#<ose ini:t raon to nestaesursa .,e3 0'
w % NEWS RE. EASE Massmenuiacts Offsite Aesconse Organization of New Hamesnire Yankee
- 1HIS IS A CPIIL** **1EE5 IS A tstIIL** **!EIS IS A IstIII,pe Pega 3 of 3 3 J
FCE :"WCIEdal1 Mf2::Et2.CE3 C5 mem 4m errd4+=dmin emiv, rugdEElE CEt CEU
-soo-ul-22.u. .
1 -
e.4, Rr ruann:ts.d i=famre:m c=rs.cmzzy tkmszzamEEE, :'an% can can t
- .-Soo-111-2112. *[1; l /Er.
rer :.c===a me=:=cs.cn -m s. h, :=2eE=.c== ==u
- .-soo-tu-2ns. g # '
m oce. iinvie A ene.wwm===-1.v m erem c n cau :-soo-tu-2m. .m ce as. ii .r. -,=we ci:= = to.
a.ua c.ic., in u. =,==. x.a. g y
.s81mm a %.
s 4 m_O A 11 \ cut./ Tim.: MMk //!47 j
- A., _Yi f one.m= / M//76
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- !EES II"A
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IIt%EE>* **!HIS IS A IIIZIL** ' **!EIS IS A M
14=h7, f W9ar*, Newtury, West Newtury, Newt 2xry;c== sbculd follow this New W"t-a Yankee offsita Responsa plan r-u to tem.ily revisit their fa:ms.
Teod i : 11, 4 farmats in need of reent: / shcx11.d Lh= W r*7t ih*'+9 :s cne of the fc11cw2ng access c=nt==1 peints:
MMMMI NUMEER CF ACPS LOCATICN hv.a 3 At II:terzac-dm of Jademn arzi Hazzen Streets At I-95 Lhw4. with Ecuta 133 At Irztats*m cf ~1= and j North Streets Grov=1and 3 seer Hill, syriald, Seven Star and Id.ttle Reeds i Sciun Star Rd. and Cantar St.
. Seven Star Rd. and Main St.
x.
I (Rt.113) i i
es Attachment C'(Page 5 of 6)
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- DCS IS A- CICI1** **EIS IS A CRIIL** **" IS A CRIIL**
Paga 2 Of 3
)
MONICMI1""? NtM!E OF ACPS M Havazhf.11 S At Lt- -- W of ?-- -y Lina Road ti Harr:.:ac Road At Lt ---- ' ~1 of ?= - -q Line Read and Rauca 110 :
i At Lt-= -- 'en of 3 7 ;
Line Road and Heath Road ;
At I-495 Lt.arctumga witti R:uta 110
<{/
At LJ- -+ 'em of RourN 108 arzi Rouca 110 EculaY 3 art Main .*t. antrance to Kittary & 47 M=47 Dev=im At Ltarse=c =n of central St.
arzi U.s. acazca 1 At Tem ==e Hcm of Hillside St. and Glan St.
At the access 11:ctint, f::cui sw livestcck farmurs Will -
receive a h- ani written instruc= ions. A densmucer is a saml1 device far measurzaqr r=44*m acpceurs. Fatmags will ha 1cgped in ami cut of the area by New @ offsita Response y4=Hm ammegency wodours.
Ece the latest i=eccmscicz1, W zusidents abauld listen to their local W/ an:md:ast System raidic scacicm WI2T-FM (92.5) and l HHAV-AM (1490).
D addrums I.annes and cuestians, tail .* ins- numbers have 1:ssn i es"=MH=w far Massacn= sects residancs. *ase acculd 1:a used to check W ""*' " h ' =- ;9 about tha. anecgency.
_ D MYa InfccEEC121, . 1EMP'PT h C3R ggl1 1-.oo-111-2 m .
(
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1 Attachment C (Page 6 of 6) a u
l
- EIS IS A F* ** *e IS A CR221** **DCES IS A CRILL**
l Page 3 of 3 For ;- - - M i:: fwd . cn Mm MM-s elv, residants can call l 1-800-111-S m !
Fcr r- - 'u" i::fc=:mr4m u d.ng F===* set *s, r==4dm can call .
1-800-111-2112. I Fce r-- - '-i dr. fwd . wmdra New F=~ HEN, rasicarn:s can call 1-800-111-7 " 9 Mambers cf the Eg l can call 1-800-111 m,iig Vie.
qc.asucns Mascars en theare of the media New F-h to urges Ymkee c=me NMY to thaCDO !
Media Cantar in Newin==n, N.H.
- "IECS IS A F' ** **MES U A CR2IL** **EIS IS A CR221**
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e ATTACHMENT D I l '
(ORO News Release #19) l i
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_ _ _ . _ _ . _ _ _ ____._.c.- __.._ _ . _ . _ _ _.
L
@B[C Q-NEW5'II$fEXS5 Massachusetts Offsite Response Organization of New Hampshire Yankee l
1 THIS IS A DRILL
- THIS IS A DRILL
- THIS IS A LEILL+
Release ! II --
ESS HISSAGE
- Page 1 of I aA
+p,%.
Y Date Message Releast.d: 6/28/88 D s Time Message Released: 9:45 p.m. d% '.',.r'[#
\g ' 9.r Released By: S. J. Ellis \g
- NHY Offsite Response Dir,ector ' -v., % s..-C .
<> ..v ,,r
\p, *r.%rf' Ki i \p At.,9:30p.m.,todaythoggpeuation6p,Amesbury,Merri=ac,Newbury, Newburyport., Tilisburyg#en'd4We4+t,r sy Newbury caA W%.completed, All schools in th ix cd unities will be closed until further notice.
Schools outsidejthe EPZ fJ{[o[oMfsp as scheduled. 6 Offg $ dee Or i u,ation ersonnel have completed s ,,,ing off,access 1
to the sit: communities. ga kkF 6%
s
%.\
';+*\.a {\
sa '1.5 %e'l&
g .e Dairy fMers.h;,. . need to return to their fisrgs can receive specific instructions Ef8r.deentering the restricted area fhg NH Yankee officials at accesscontrol'iphdits. ~hese proceduits will be dhe4 ped.ss'ad distributed at a later time.
- \A \b%#
'rA yr This message will be J.epeapd everyS.hf teen esinutes or until new infor-marion is available. Ke4 official l information. %h.-}p,Adhid
., t to 37 this E%h, station for the latest i To address rumors a fi;tNih.dh' toll-free numbers have been established g M forMassachysktteresident%y.T f # .g'44 ' ' ,
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- 4. \, 4'# ***THIS IS A DRILL **
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JREBUTTAL PANEL'NO.)l'9 -' CROSS 27844 f
.x 1 . MR. : SMITH:. The Panel is now available for cross-
-2' examination.
3 MS. TAL30T: Thank you.
4 CROSS-EXAMINATION 5 ,BY MS. TALBOT:
6 Q Good morning,. Panel. .
7 My name is Pamela Talbot. I am Assistant Attorney 8 General for the. Commonwealth of Massachusetts.
9 Panel, what portions of the testimony were drafted 10- by Ms. Colby Wells?
L Ms. Wells is a Panel member, and 11 A . (Callendrello) 12 her1 expertise is in the design of public information 13 . systems, and that is relating to the development'of joint 14 information centers and joint information systems.
15- So she brought that specific expertise to the 16 testimony. .
17 I can't point to any specific testimony that she 18 drafted. I know that she had-reviewed that testimony and 19 felt satisfied that it incorporated and included her 20 specific testimony regarding those subjects.
21 Q Mr. Callendrello, you participated in the June j L i l
22 exercise, correct? .
l 23 A (Callendrello) I was a controller in the June 24 exercise.
25 Q Can you describe for me the role of controller?
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> 1 REBUTTAL PANEL NO. 19 - CROSS 27845
- g; 1 A (Callendrello) Contro"11er'has two functions.
~
2 '- ,one is to act to keep tho' exercise on track with.
3 the scenario, and that is, to supply data, information or ll- messages at an appropriate in'the, or predetermined point in 5- the exercise in order to make'sure that the scenario' moves 6 at the pace that it is expected to move at. .
7 The second function 6f the' controller is to act'as 1
8 an evaluator. That is, to observe, note points where there 9 may be. actions that need to be corrected so that it can be 10 fed back into the system and appropriate corrective actions 11 taken.
12 Q What portions of the exercise did you observe?
13 A (Callendrello) I observed two specific functions.
14 One is the function of the public notification t
\s. 15 coordinator at the offsite response organization EOC.
16 And the second was the communicationsLfunction and
-17 specifically, the communications coordinator, also at the 18 offsite response organization EOC.
19 Q Mr. Catapano, you participated in the June 20 exercise also, correct?
21 A (Catapano) Yes, I did.
22 Q And what was your role?
23 A (Catapano) My role was that of the communications 24 coordinator.
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REBUTTAL PANEL NO. 19 - CROSS 27846
, 1 held on June 28th and 2bth of 19887 s
2 A (Mileti) No, I did not.
3 Q Panel, did any of you draft the pre-recorded EBS 1
4 messages?
5 (Pause . )
i 6 A (Callendrello) I did not draft those message.s, j 7 although I have worked on predecessor versions of those 8 messages both in the New Hampshire plan and in fact going 9 back as far as the plan for Shoreham. So --
10 Q Dr. Mileti -- I'm sorry. )
11 Are you through?
12 A (Callendrello) The answer is, no, I did not work i 13 on those specific messages, but I have worked messages 14 similar to those. )
15 Q Dr. Mileti, did you participate in drafting the 16 prescripted EBS messages?
i 17 A (Mileti) No, I did not.
18 But the rest of my answer would be similar to Mr.
19 Callendrello's.
I 20 I worked a bit, as I recollect, or at least 21 provided feedback on the messages in New Hampshire, and then 22 I also helped terite the messages at Shoreham.
23 Q Do you have expertise in fission background, l 24 health effects and source terms?
25 A (Mileti) No , I absolutely have no expertise in f f Heritage Reporting Corporation
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REBUTTAL PANEL NO. 19 - CROSS 27847 1 fission.
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( 2 I didn't hear your last one.
3 Q It's my Boston accent.
4 Socrce terms.
5 A (Mileti) Oh, absolutely not. No.
If 6 Q Have you ever been present in an EOC during an .
7 actual technological or natural disaster?
8 A (Mileti) Yes, I have.
9 Q Where, please?
10 A (Mileti) Well, I've been at an EOC at exercises.
11 In terms of actual emergencies, I was at the EOC, 12 well, I'll begin with my first one in 1972, during the Rapid 13 City flood.
14 I was at the equivalent of the -- it really wasn't 15 an EOC, but it was the central communications station in 16 response to the earthquake in Soviet Armenia this December.
17 I was not in during the emergency, but certainly 18 in the recovery period, the communication center in several 19 communities around the Nevado del Ruiz volcano in' Colombia a 20 few years back.
l 21 I was at the emergency operations center for an 22 earthquake prediction in 1976, as I recollect, in l
23 Wilmington, North Carolina, which I may add was an l
l 24 earthquake prediction that actually did occur during the 1
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1 REBUTTAL PANEL NO. 19 - CROSS 27848 j '
1 Dr. Carter didn't, didn't study it. It didn't meet his 2 criteria. And a few others but --
3 Q Would you repeat that last reference to Dr.
4 Carter?
5 A (Mileti) Well, yesterday Dr. Carter said that 6 there were no earthquake predictions in the United States 7 during the time period of what he referred to as the 8 Minnesota study.
9 And, in fact, there was one, but it didn't meet 10 the criteria his study established for studying an l
11 earthquake prediction.
12 13 14 15 16 17 18 ,
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C REBUTTAL PANEL No. 19 - CROSS 27849 1 Q I see.
- l. ~ .
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y 2 So the only time you were actually in an EOC 3 during an actual hazard was in 1972, during a flood, and in j 1
4 1988, during the Armenian earthquake. l 5 Is that correct? 1 1
6 In other words, contemporaneous with the actual .
7 hazard, not before, not after?
k 8 A (Mileti) No, that's not true, because many of the 1 1
4 9 hazards involved, for example, earthquakes, and, for 10 example, volcanos, don't have an immediate end point.
11 In fact, the problem at Nevado del Ruiz, the 12 larger problem when I was there wasn't that it had erupted 13 and so many people lost their lives, but that scientists
, 14 were expecting a larger subsequent eruption, and they were s_s 15 trying to get emergency information out to the communities 16 regarding that more dramatic eruption.
17 And in reference to actual earthquakes, 18 earthquakes don't just happen. You have sometimes fore-19 shocks, but you definitely always have after-shocks after.
20 the main shock.
21 And so it's difficult to say that the hazard per 22 se ended because there still was risk.
23 Q I see. y
?
24 JUDGE SMITH: Excuse me a minute.
25 NG. TALBOT: Your Honor, I just realized I didn't
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REBUTTAL PANEL NO. 19 - CROSS 27850 1 hand out my cross-examination plan.
2 (Document handed to the board. )
3 JUDGE SMITH: That's all right.
4 MS. TALBOT: Sorry.
5 JUDGE SMITH: I don't know if I want to tell you 6 this or not, but last night we excused the parties from l
7 preparing cross-examination plans.
8 MS. TALBOT: Oh, It's very abbreviated, so I was 9 afraid you would think it was too abbreviated.
10 BY MS. TALBOT:
11 Q So, in fact, Dr. Mileti, you have never been in an 12 EOC during a technological hazard. All the ones you have 13 just listed to me are natural in nature, correct?
14 A (Mileti) Not during the warning period, that is, 15 before impact. But I certainly have interviewed people 16 about what went on in EOCs and other places like that after 17 the event occurred.
18 For example, the Livingston train derailment in 19 Louisiana, and the train derailment in Denver. I don't 20 ,
remember the year. It would have been in the '80s some 21 time, in the mid '80s.
22 Well, one of the things I do when I do research is ,
23 investigate emergency information.
24 But in terms of physically being there prior to 25 the impact of an actual technological dicaster, just the l
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REBUTTAL PANEL NO. 19 - CROSS 27851
- 1. ones I've talked about.
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2 Q Which are natural in nature?
3 A (M11eti) Well, earthquakes are, yes.
4 Q Right. Okay.
5 A (Mileti) Except, however, there is certainly a 6 technological aspect associated with natural hazards. .
7 Q Certainly.
8 Panel, who did draw up the prescripted EBS 9 messages if no one on the Panel did?
10 A (Callendrello) They would have been prepared by 11 the planning staff of New Hampshire' Yankee.
12 Q And none of you are on the planning staff?
13 A (callendrello) That's correct.
7- 14 Q. Panel, did any of you draw up the implementing 1- t
\m ,/ 15 procedures for the dissemination of EBS and news releases 16 contained in the plan?
17 A (Callendrello) No, I did not.
18 A (Catapano) No , I didn't.
19 A (M11eti) I didn't, no.
~
20 Q Again, were those prepared by the same body of 21 -people that prepared the prescripted messages?
22 A , (Callendrello) Yes.
i 23 In addition, as I recall, there were some j 24 additional individuals who assisted in the preparation of 25 those. Some individuals who had been working with our
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REBUTTAL PANEL NO. 19 - CROSS 27852 1 corporate communications group who assisted in the i 2 development of those procedures.
3 Q Panel, you would agree that the role designated )
1 4 for the development, coordination and dissemination of EBS ]
5 messages is the public notification coordinator, correct?
6 A (Callendrello) I'm sorry, I missed the first part 7 of the question.
8 Q You would agree that the role designated for 9 developing, coordinating and disseminating EBS messages is 10 the PNC, public notif'.;ation coordinator?
11 A (Callendrello) The public notification 12 coordinator is assigned the responsibility for the 13 development of EBS messages and obtaining their approval, 14 and once approved, disseminating them, distributing that to ,
15 the EBS station for broadcast.
16 Q . Similarly, the role designated for the 17 coordination, development and dissemination of news releases 18 is the PIC or public information coordinator, correct?
19 A (Callendrello) No, that's not correct.
20 The public information advisor --
1 I
21 Q PIA.
22 , A (Callendrello) -- prepares the news releases for 23 the offsite response organization.
24 The dissemination at the media center is the 25 responsibility of the public information coordinator.
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J REBUTTAL PANEL NO. 19 - CROSS 27853
. , . .1 .Q' Just bear with me'one minuter not even one minute,-
7 l '2'a please?
3 (Pause . )
't BY 113. TALBOT:
5 Q Panel, . in our- testimony you'say that the public 6 information advisor is responsible for the preparation, ,;
7 . coordination and dissemination of public information,.
8 including news releases.
9 Isn't that true? !
10 A (Callendrello) Yes, it is.
11 Q How does that square with the distinction you just 12 made?
13 A (Callendrello) The dissemination of the public gs 14 .information, which includes news releases, is to multiple
'\s_) 15 locations. One of those is the media center, and 16- specifically, to the public information coordinator who is 17 at the media center.
18 The public information coordinator.is actually the 19 person who gets up on the dias and provides information 20 directly to the media in a press briefing.
I 21 So that as far as the physical act of-22 communicating that to the media at a press briefing, that is 23 the responsibility of the public information coordinator. ,
i 24 The public information advisor is, however, {
25 responsible for everything that it says in the testimony
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REBUTTAL PANEL NO. 19 - CROSS 27854 1 regarding public information.
2 Q So am I correct in thinking that the three main 3 players are the PIC, the PIA and the PNC? j i
I 4 A (Callendrello) Three main players as regards the 5 development of public information?
6 Q Correct.
7 A (Callendrello') And public instructions?
8 Q3 Correct.
9 A (Callendrello) The distinction being the first 10 two you mentioned.
11 The public information advisor and public 12 information coordinator are responsible for public 13 information; that is, news releases.
14 Public notification coordinator'is responsible for 15 public instructions, or the EBS messages.
16 Q Correct.
17 Panel, isn't it a fact, then, that no one on this 18 Panel acted in the role of either PIA, PIC or PNC during the 19 exercise?
20 A (Callendrello) Yes, that's correct.
21 Q So, to the extent that you describe or explain the 22 development, coordination and dissemination of information 23 insofar as you're concerned with the roles of the PIA, PIC 24 or PNC, in fact you are describing or explaining actions 25 that someone else actually took or didn't take during the Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 19 - CROSS 27855
,as 1 exercise, correct?
)
i ): 2 A That's correct.
'(,,/ (Jallendrello) 3 12 Dr. Mileti, are you familiar with the work of 4 Ronald Perry?
5 A (M11eti) Some of it, yes.
6 Perhaps most of it. Maybe all of it. .;
l' 7 Q Wow.
8 And you would agree that Ronald Perry is a well-9 known authority'in the area of evacuation decision-making?
10 A (M11eti) I don't know if I would word it that 11 way.
12 Ron Perry has certainly studied many evacuations 13 as a sociologist would, and other sociologists in the field rs 14 know of him and know of his work. l N_- 15 Q In fact, you cite to him six times in your own 16 book, " Evacuation - " the name of the book you did with Mr.
17 Vogt and Mr. Sorensen. You have numerous cites, in fact, to 18 Ronald Perry in that book.
19 A (Mileti) I'm sure there are, but it's.Ms. Vogt.
20 In fact, she's married to John Sorensen.
21 Q Oh.
22 It's amazing what you learn on cross.
23 (Laughter) 24 A (Mileti) I might add, Ron tends to cite me a 25 whole lot more than I cite him.
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l 1 Q Excuse me, I didn't hcar the last comment.
2 A (Mileti) We tend to cite each other as we would 3 anybody who has done research in the field that's relevant '
4 to what we're writing about.
5 0 I see.
6 Panel, the emergency news manager in the media ,
7 relations room or control liaison at the media center are 8 supposed to work with PIC to ensure that inaccuracies'in 9 information to be disseminated are correct, right? .
10 A (Callendrello) Yes.
l l 11 That's one place where -- that's where those three 12 individuals are located and that is one step in the process 1
13 in correcting information or misinformation.
14 Yes.
15 Q Where are the other places, Mr. Callendrello?
16 A (Callendrello) The joint telephone information 17 center is one place where there are individuals located 18 known as media relations assistants, some of which are 19 monitoring electronic media -- radio and television -- for 20 news stories related to the emergency and looking for 21 misinformation that may be broadcast during those stories.
22 There are also media relations assistants that 23 staff telephones and respond to media inquiries, and would 24 identify misinformation or rumors being brought up by the 25 media. And in turn, those would be brought to the attention Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 19 - CROSS 27857 1 of the media relations rumor control supervisor who is also
.x ;
x- ) '2 located at the joint telephone information center. j 3 That supervisor reviews the information being j 4 brought to him, and then passes along to the media center, 5 to the media relations liaison at the media center, areas 6 where it's felt that information needs to be corrected and ,
7 needs to be corrected through either a press release or l 8 incorporation into a press briefing.
9 Q Do you think that the number of players involved 10 in that correction procedure affects the timely correction 11 of information?
12 In other words, is it too much of a bureaucracy, 13 in your opinion?
, -s 14 A (Callendrello) No , I don't think it is.
's.- 15 It seems to have worked in the exercise.
16 Q Oh, really?
17 A (Callendrello) We did have an area where we 18 aeeded to improve performance by distributing news releases 19 earlier to the joint telephone information center. And we 20 have made that change in the procedure so that news releases 21 are sent simultaneously to the joint telephone information 22 center and the media center, so that those media relations 23 assistants have the most up-to-date information.
24 Q Prior to that change, how did the procedure work?
25 A (Callendrello) The news releases, the approved
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REBUTTAL PANEL NO. 19 - CROSS 27858 1 news releases were sent to the media center. When the media l 2 center got the sign-offs of the individuals there, they were 3 then sent back to the joint telephone information center, i
4 and that caused some delays from the time the release was 5 first available until the time it was made available to the
~
6 joint telephone information center.
7 Q So initially it used to go from the JTIC to the 8 media center, to the JTIC?
9 A (Callendrello) No.
10 It would go from the EOC to the media center, back 11 to the JTIC.
12 Q And now how does it go?
13 A (Callendrello) Now it goes from the emergency 14 operation center, the EOC, to two locations. Well, it goes 15 to more than two locations, but for our disc'.tssion here, two 16 locations.
17 One, the joint telephone information center; the 18 other, the media center.
19 Q I understand.
20 Where inaccuracies in news releases are found, 21 they are corrected through subsequent news releases, EBS 22 messages or news briefings, correct? ,
23 I can refer you to your testimony.
24 A (Callendrello) Yes, that's correct.
25 I'm just thinking about the EBS message portion of
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() 2 But, yes, that's correct.
1 I
3 Q Wouldn't you agree that corrections should be ]
4 aired as soon'as possible?
5- A (Callendrello) Yes.
6 Again, it would depend on the level of correction. .
7 If it's something -- there are some corrections that are 8 more important than others. I can think of a spectrum of 9 corrections.
10 But, in general, I would say it's important to get 11 corrected information out there as soon as possible and as 12 soon as is needed.
13 Q When you say level of corrections, some are more 14 important than others, are you talking about the content of
.t
\ 15 the information that was disseminated?
16 In other.words, the nature of the information?
17 A (Callendrello) The nature of the information 18 that's in error.
19 Q So, in other words, some inaccurate information is 20 not as important as other inaccurate information?
21 A (Ca11endre11o) In my mind, yes, that's true.
22 Q ,What is the criteria used for determining what 23 channel corrected information will be aired over?
24 A (Callendrello) Just give me a moment.
25 (Witnesses review document.)
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REBUTTAL PANEL NO. 19 - CROSS 27860 l 1
1 THE WITNESS: (Ca11endre11o) I don't see any )
2 place where that criteria is defined.
3 BY MS. TALBOT:
4 Q So, in fact, that's an ad. hoc decision that's made 5 at the time awareness of the inaccuracy becomes apparent? '
6 A (Ca11endre11o) Well, it's an ad hoc decision, but 7 there's certainly some general guidance and that is, if it'd 8 information that was incorrect in an EBS message it's likely 9 that another EBS message would be used to correct it, 10 although I'll defer to Dr. M11eti on what's the appropriate 11 mechanism for correcting that.
12 A (Mileti) I would agree that the best way to 13 correct an EBS message is through a subsequent EBS message.
14 Q Does it follow down the line then that the best' 15 way to correct news release is by way of a new release; the 16 best way to correct information given from that generic 17 factual information packet that JTIC workers have is to have 18 that go out through the JTIC?
19 I mean, is it parallel down the line?
20 A (Ca11endre11o) I think that is a first indicator 21 of how it should be corrected; yes, that would be 22 appropriate. There may be some information that shows up or 23 misinformation that appears in press releases that may be I
24 appropriately corrected in an EBS message, as with 25 information that would come into the joint telephone ,
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REBUTTAL ~ PANEL NO. 19'- CROSS 27861
.; l 1' information center. ~That may be'ap'propriately corrected YO
} _,) 2' either through an EBS message or through a press release.
^3 Q '. But it's'unlikely that-if there was an error in an 4 EBS that the. correction would, in fact, be made for the.
5- JTIC, for example?
6 .I'm getting an image that it's parallel.except it ..
7 can also -- the correction can also be made one step up or.
8 'two steps up?'
9 (Witnesses confer.) ,
10 THE WITNESS: (Mileti) If I could just say.
.11 BY MS. TALBOT:
12 .
Q Sure.
13 A (Mileti) I think it would depend on what it is 14 that needs correcting. I think, for example, if it's a L{
\_ 15 protective action recommendation, you told people to shelter-16 and they should, in fact, be advised to evacuate; obviously, 17 EBS is the way to go. In that ' circumstance I would also do 18 it in a press release and every other way.I can think of.
19 So I think it depends on the circumstances, in my 20 judgment. )
21 Q So determination of what's important and what 22 isn't, that also depends on the circumstances?
23 A (Callendrello) I don't understand the question.
24 Q Well, I'm just following up on what you said 25 earlier concerning the level of correction. j l
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REBUTTAL PANEL NO. 19 - CROSS 27862 1 That some inaccu'racies are more important than 2 others, and I was just wondering if there was any criteria 3 for determining level of importance or, in fact, it's the 4 same idea where it's all relative? l l
5 A (Callendrello) I'm sorry, even with that 6 clarification, I don't understand the question.
7 Q In other words, there's no procedure extant that 8 tells you what kind of an inaccuracy is deemed important or 9 what kind of information is deemed important as opposed to 10 information that is of lesser importance?
11 A (Callendrello) As far as correcting information?
12 Q Yes.
13 A (Callendrello) Misinformation. I'm not aware of 14 any.
15 There is guidance in procedure IP-2.12 which 16 indicates what information should be contained in press 17 releases. But I don't know of criteria that says, if you 18 have this type of misinformation or this specific level of l
19 misinformation correct it using this mechanism; and with 20 another level correct it with a different mechanism.
21 Q Okay.
22 A (Callendrello) I think that they would attempt to 23 use as many types of media as they could to correct 24 misinformation. And, in fact, the system supports that.
25 If you put out an EBS message to corract I
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., . 'l , misinformation,- that EBS message becomes a press rolesse..
C( )
- 2 And it also is provided'to the joint telephone information 3 -center so that callers.who are raising those rumors would in 4 turn get the.t information, corrected information.
5 So the system interlocks and. interconnects.
6 Q Thank you. ..
7 Wouldn't you agree, Panel, that secondary sources 8 of information like friends and relatives are more.likely'to 9 result in further misinformation or contradictory 10 information?
11 A (Mileti) More.likely than what?'
12 Q More likely than official information like EBS or-13 a news release?-
o--- 14 A (Mileti) Yes, I would have to agree that the sm 15 probability of EBS conflicting with EBS is substantially 16 lower than neighbors and relatives' words conflicting with 17 EBS. I think that's a potential' source of conflicting 18 information; yes.
19 Q In fact, the public is most likely -- the~public 20 views EBS as the least likely to contain wrong information 21 and, in fact, the most credible, in your opinion?
22 A (Mileti) I think I could agree with that in some 23 instances and it wouldn't be necessarily true in other l 24 instances.
25 I think, for example, in situations like emergency l
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REBUTTAL PANEL NO. 19 - CROSS 27864 1 planning such as we have here at the Seabrook Nuclear Power 2 Plant, that part of the design of the public information and 3 warning system through EBS would result in people viewing 4 that information as more believable than if we didn't devote 5 the planning attention to that system than ww had.
6 Dut there's also overlap between that EBS system 7 and what neighbors and relatives, for example, might be 8 saying. I'll just illustrate simply: because EBS is being 9 repeated frequently it certainly isn't going to alter the 10 chance that a neighbor might say something off the wall.
11 But it reduces the probability of that occurring because it 12 increases the odds of that neighbor who would have also 13 heard the EBS message and might therefore repeat similar 14 things. But it certainly doesn't negate the potential for a 1 15 neighbor or relative saying something off the wall. )
16 Q Right.
17 Dissemination of information through the JTIC is 18 one-on-one; correct? In terms of telephone inquiry?
19 MR. SMITH: I just want to object.
2'O I just want to see where you're heading with this.
21 We seem to be getting towards rumor control, which has been 22 withdrawn by the Mass AG. I just want to make sure that 23 we're not going down that line.
24 MS. TALBOT: No, I'm not asking as to rumor 25 control.
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REBUTTAL PANEL NO. 19'- CROSS 27865 1 MR. SMITH: Maybe we could get a sense of where-i' L, 2 you're heading with'this. -I mean, the conversation:--
o 3 MS. TALBOT:- Can1I respond to the objection or is
~4 it overruled.
5 JUDGE SMITH: Just as that discussion was going on-6 the Board was reviewing the testimony noting that that; .
7 aspect.of the testimony was deleted and was wondering'how it'
-8 fit int'what you were going to. So I think it's something 9 you have to address.
10- MS. TALBOT: Sure.
-11 JUDGE SMITH: I didn't hear the objection,-just 12 the sense of it.
13 MR. SMITH: Yes.
-14 The objection was: I thought we were getting into 15 areas that dealt with rumor control. And that maybe the-16 best way to handle.it is to get some sense from Ms. Talbot 17 where she was heading, if she's not getting into that.
18 It seemed to me the question that was asked, the 19 one-on-one conversation, was a rumor control function.
20 MS. TALBOT: I think I can alleviate your fears, I 21 think.
22 One of the ways that inaccuracies in information 23 was handled during the exercise was through information let 24 out through the.JTIC. It's independent of rumor control; it 25 was a dissemination --
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REBUTTAL PANEL NO. 19 - CROSS 27866 (
I 1 JUDGE SMITH: To the media?
2 N3. TALBOT: To the media and to --
3 JUDGE SMITH: Individuals calling.
4 MS. TALBOT: -- individuals calling up. And 5 that's the focus of my inquiry.
6 JUDGE SMITH: But that aspect of the direct 7 testimony has been deleted.
8 Well, there's two aspects of the testimony that 9 has been deleted physically and that is: on page 5, 10 telephone inquiries received from the public. And other 11 pages where rumor control itself is deleted; page 7, for 12 example, 6. So there you are.
13 MS. TALBOT: So I'll ask no questions about public 14 inquiry to the JTIC.
15 JUDGE SMITH: That I think would be our rul::.ng, 16 yes.
17 MS. TALDOT: Okay.
18 JUDGE SMITH: Unless we misunderstand. I don't 19 think we do.
20 MS. TALBOT: No.
21 JUDGE SMITH: All right.
22 BY N3. TALBOT: ,
23 Q Panel, you would agree that despite various 24 procedures in the plan for consistency and accuracy FEMA 25 found many instances where disseminated information was, in Heritage Reporting Corporation
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'l fact,. inaccurate and/or inconsistent; correct?
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' 2 A (Callendrello) I don't know if I would agree that 3 it was many. I know they identified the areas where they 4 found inconsistent information in the exercise report.
5 Under objective 13 they identified one issue
. I 6 related to one of the EBS messages containing some 1
-1 7 inconsistencies. That's objective 13. j 8 And objective 14, there were no issues related to confusing information; that's how I understood your i 9
10 question.
11 Q You would agree though that FEMA found some 12 instances of inaccuracy or confusion?
13 A (Callendrello) They also found one news release
, 's 14 contained in our study. They found two instances: one EBS l l That's under objective 13 of 15 message and one news release.
16 the ORO. .
17 Q All four pages; correct, of the summary?
18 A (Callendrello) I was'just looking at the issue 19 identified, issue number 1.
20 0 In any event, wouldn't you agree that the ;
21 procedures per se can be no guarantee of accuracy, 22 consistency, or timely dissemination?
23 A (Callendrello) I don't think you can guarantee 24 anything. The procedures are designed to minimize that. I 25 And I think considering that we put out well in excess of 12 I
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1 EBS message and I think on the order of 20 or so news 2 releases that we achieve that goal with having one of the 3 EBS messages with some inconsistencies and one of the news 4 releases with a mistake in it.
5 The procedures are designed to have a common 6 individual review of that material to minimize that from 7 happening as well as the fact that the two individuals at 8 the emergency operation center who are tasked with 9 developing those messages sit next to each, physically next 10 to each other in the EOC and provide each other with copies l 1
11 of their releases, either EBS message or news release. l 12 Q Panel, did the prescripted EBS messages contain 13 information about Mode 1 and Mode 2 responses?
14 A (Callendrello) No, they do not. i 15 Q The ORO is the source of the prescripted messages; G!
16 correct? I.mean, the source of the disseminated messages; 17 correct?
18 A (Callendrell6) They' re the source in that it is 19 an individual at the emergency operation center who would 20 take the prescripted message and make whatever modifications 21 are needed. But they are not the source in that, that 22 mgssage then goes through an approval process.
l 23 It's approved by the offsite response director who 24 therefore has responsibility for being a uource of that 25 message. And then it is sent to the Commonwealth of Heritage Reporting Corporation t
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l' Massachusetts and it's.either the governor.or the governor's Il designee who reviews.that message and approves or
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disapproves or modifies the content of that massage, so that 3
4 ultimately it's the Commonwealth that becomes the source of 5- that. message.
6 Q Don't you think you're' confusing source with ,
7 authority?
8 A (Callendrello) No.
'9 Q Don't you think in light of the fact that Mode 1 10- 'and Mode 2 aren't mentioned in the message that ascribing 11 the' source to the governor lends some confusion, an element 12 of confusion?
13 A (Callendrello) - No, because no message will be 14 broadcast on EBS unless the governor or governor's designee tO 15 has approved that message. That's proceduralized.
16 Q Isn't it necessary under the regulations that the 17 message address any delegation of authority by the 18 government to the ORO to issue warnings?
19 A (Callendrello) I know.of nothing in the 20 regulations that require that.
21 22 23 24 25 l j
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REBUTTAL PANEL NO. 19 - CROSS 27870 1 Q Do you think the regulations require that you 2 draft messages that reflect the emergency response 3 relationship? ,
4 A (Callendrello) If you're referring to NUREG-0654, 5 Supplement 1, I think that the guidance certainly suggests 6 that.
7 But you asked me the question whether the
'8 regulations require it, and I don't know of any regulation 9 that requires it. )
10 Q My poor choice of words.
11 I should have said "suggest".
12 You would agree that the regulations suggest that 13 you address delegation of authority issues?
14 A (Callendrello) I don't have a copy of Supp. 1 15 with me. But I think Element E-5 or E-7 -- E-5, I think it 16 is, does address the content of the EBS mGasages.
17 I don't recall whether there are specific ones 18 there. But if you represent that it's there, I'll accept 19 that.
20 Q In fact, your E-5 designation is correct.
21 It says the prescripted messages should cddress 22 the various conditions such as delegation of authority.
23 I don't think that the messages could be more 24 clear with respect to delegation of authority in light of 25 the fact there is no reference to Mode 1 and Mode 2, in that Heritage Reporting Corporation
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< REBUTTAL PANEL NO. 19 - CROSS 27871 l 1 the governor is identified as the source, rather than just
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4 3_ A (Callendrello) I don't think adding the words j 4 " Mode 1" or " Mode 2" would add _anything to the comprehension i
5 of the roles of the organizations for the general public, 6 although I'll defer to Dr. Mileti on how they would .
7 understand that.
. 8 -The messages do indicate that the New Hampshire 9 Yankee offsite response organization is responding and 10 discussing it with Massachusetts government. officials. And 11~ indicates further that protective actions or precautionary 12 actions come as recommendations of the governor, which is 13 consistent with both the protective action recommendation 14 procedure whereby authority to recommend a protective action
(
. 15 is first cleared with the governor.
16 And second of all, the fact that the message 17 content itself is approved by the governor or the governor's 18 designee prior to its being broadcast.
19 Q Isn't it true that almost all the prescripted 20 messages refer the listener to pre-emergency information 21 sent to homes or to pre-emergency flyers at beach and 22 recreational facilities?
23 A (Callendrello) Yes, that's true.
24 Q What data do you have that resident listeners will 25 have the information on hand?
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REBUTTAL PANEL NO. 19 - CROSS 27872 1 A (Callendrello) I don't have any cata.
2 I know that, as far as the calendars go, we have 3 mailed, gone through an extensive mailing of that 4 information to residents in the EPZ.
5 We have not yet distributed the transient 6 information, the emergency information flyers. So that I 7 wouldn't expect anybody to have that ut present.
8 I have no information as to what percentage of 9 people have the calendars. !
10 Q How do you intend to distribute the information to 11 transients?
12 A (Callendrello) We've made commitments in the plan 13 to distribute information to transients in a number of
, 14 manners. I'll try and remember them off the top of my head.
15 They are described in the plan in Section 3.7, I believe.
16 But just off the top of my head, I can recall that 17 we have committed to distribute flyers to various types'of 10 facilities that transients would frequent such as hotels, 19 motels, restaurants, campgrounds and parks.
20 Also included with those would be bus flyers, 21 which are somewhat different, and those would explain or 22 show the bus transient routes for people who would be 23 without transportation.
24 Further, there are posters that are provided, f
l 25 decals that indicate the emergency broadcast system l
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i t i REBUTTAL PANEL NO. 19 - cross 27873 1 stations. There are letters that_go to employers and some f 2 types of' facility owners, hotels, motels, restau(ant owners.
J 3 That's all I'can recall at-the present time. I know it'is
.4- described in the plan.
5 Q These are all places where you believe transients 6 would-frequent? g, 7 A -(Callendrello) Yes, I believe so.
- 8. Q Transients. frequent the beach, correct?
9 A (Callendrello) Yes, they do.
10 Q 'How do you intend to disseminate information to 11 transients at the beach?
12 A (Callendrello) Through the mechanisms I just 13 . described.
14 Q Through brochures sent to hotels and motels. You f-ss
(_- :L5 just listed a. lot of mechanisms that, without going through 16 each one of them, you, I'm sure, agree that some of them 17 aren't intended to reach people. Or if they are, they 18 won't. !
19 A (Callendrello) Well, I can't address the last 20 part of your question.
21 But they are -- the mechanisms I described are 22 intended to reach transients, where they are beach people or 23 transients at other locations.
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O REBUTTAL PANEL NO. 19 - CROSS 27874 1 particularly Salisbury Beach and Plum Island.
2 So, yes, those are intended to reach beach 3 transients.
1 i
4 Q You would agree that not all beach transients stay 5 in hotels or motels?
6 A (Callendrello) Yes, that's correct.
7 Q Bear with me one minute, Mr. Callendrello. I just 8 want to look to the part of the plan that you cited to.
9 (Cov.nsel peruses document.)
10 BY MS. TALBOT:
11 Q What's the procedure, Mr. Callendrello, for 12 disseminating information at parks and campgrounds, wildlife 13 refuges and beaches?
14 What's the procedure?-
15 I know that you send them to hotels and motels. i 16 You send them to parks.
17 How does it get into my hands if I am the 18 transient beachgoer?
19 A (Callendrollo) I don't know the specifics.
20 JUDGE SMITH: Are you a camper?
l 21 Is that what you are?
22 MS. TALBOT: I could be a camper. ,
23 JUDGE SMITH: Or a day tripper.
24 MS. TALBOT: I could be sunbather. I could be l 25 wildlife refuge bird watcher. I could be a number of Heritage Reporting Corporation
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1 . things. l
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([~'j) 2 THE WITNESS: (Callendrello) Beyond the 3 commitments that are identified in the plan, I don't know 4 the specifics as to whether there will be a rack or'a shelf, 5 or whether they will.be hung on the wall. I don't know the 6 specifics on that. .
7 BY MS. TALBOT:
8 Q So, in fact, there is no procedure for, day 9 trippers, for instance, to actually get the information?
10 A (Callendrello) I don't know whether there is a 11 distribution or not. I don't know of any.
12 I know the commitment that's in the plan. I don't 13 know whether there has been a procedure since devised as g;~s 14 part of the administration of the emergency plan program
_ 15 that addresses distribution of public information to those 16 facilities. .
17 Q Excuse me.
18 Could you repeat that l'ast sentence?
19 A (Callendrello) I'll try.
20 We've made the commitment in the plan to make 21 those distributions. I am not aware of the procedures or 22 whether procpdures have been developed for implementing the 23 commitment in the plan. Those would be procedures as part 24 of the emergency plan implementing organization.
25 I don't know what state those plans are in yet, or b
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REQUTTAL PANEL NO. 19 - CROSS 27876 1 procedures.
i 2 Q How often would flyers be distributed to parks and-3 campgrounds?
4 A (Callendrello) The commitment, as I recall, in 5 the plan is that the information will be updated annually.
6 Part of what is sent to those facilities is a card 1 7 that enables the facility to request additional copies of d
8 the materials in quantities, I think, of 10, 50, 500, 9 something like that.
10 So there is a mechanism for a facility, if they 11 run out of materials, to request additional materials.
12 Q Do you have any information on the proportion of 13 beachgoers -- this is in the Mass EPZ, of course -- the 14 proportion of beachgoers that are day trippers? !
15 A (Callendrello) Evacuation time estimates 16 indicates that about 50 percent of the persons in the beach 17 area are day trippers.
18 Q So as it stands now, there is no mechanism for 19 about 50 percent of the transient population to receive the 20 information.
21 A (Callendrello) No, that's not what I said.
22 ,
I said that there are a number of facilities that 23 receive this information. And those facilities certainly 24 are frequented by day trippers. Day trippers go to parks.
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REBUTTAL PANEL NO._19 - CROSS 27877 1, me, they wouldn't go to a campground if they are a day t 2 tripper, but they may be a. day tripper --
3 12 They may be visiting someone at the campground.
4 A- (Callendrello) -- who is starting from a
-5. campground and going to the beach.
l 6 So I'can't agree'with that statement. .
7 Q So there'is a mechanism that exists to send the 8 information from ORO to the campground, the park, the beach, 9 the refuge, shelter area where there are maps, but there is 10 no additional mechanism to'get the information to the 11 intended recipient.
12 A (Callendrello) I guess I don't understand what 13 you mean by "get the information to the intended recipient".
>~ 14 We take it as-far as we can take it. We get the
- 15 information to the facilities.
16 Q Okay.
17 Isn't it true, Panel, that almost all, if not all, 18 of the prescripted messages -- no, it's not all of them.
19 Almost all of the prescripted messages refer the 20 listener, who may have no pre-emergency information, to the 21 phone book?
22 A (Callendrello) That's correct.
23 That phrase is in'the EBS messages. As you are 24 aware, we are no longer planning on using the telephone book 25 insert as a mechanism for distributing information. And i Heritage Reporting Corporation 4 (202) 628-4888
REBUTTAL PANEL NO. 19 - CROSS 27878 1 that sentence will be removed from the prescripted messages s 2 in the next revision. j 3 Q And from the plan?
4 A (Callendrello) Yes, it will be removed from the ]
5 plan as well.
6 0 Will it be removed from FEMA's finding of adequacy 7 as to the dissemination of information?
8 A (Callendrello) As I recall, Mr. Traficonte asked 9 Mr. Donovan that question.
10 I honestly don't remember what the answer was, but 11 I know that's a call that FEMA makes. That's not a call 12 that I would make.
13 Q Mr. Callendrello, what will the substitution be 14 for the phone book reference in the emergency warning 15 messages?
16 A (Callendrello) There will be no substitution.
l 17 Q So there will be no reference to an information 18 source for those who don't have the pre-emergency 19 information on hand?
20 A (Callendrello) There is a reference there to the 21 flyers that are available at beach facilities and recreation 22 areas.
l l 23 So to that extent, your statement is incorrect.
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REBUTTAL PANEL.NO. 19'- CROSS 27879, q
,s 11 'beareference'to flyers that someone else. received and q l
1 C . 2 retained, and that's it?
3 A (Callendrello) Yes, that's correct.
4 That's all that is referenced in the EBS' message, 5 although recognize that the EBS messages themselves contain 6 a_ great-deal of information regarding the actions to be. ..
7 taken.
8 Q' In some of the prescripted messages, you alert 9 beach _ people, for lack of a better word, to the fact that 10 buses will beLavailable to pick them up and they should go 11- to the near indoor shelter and wait for the bus, correct?
12- A (Callendrello) Yes.
13 :And those messages relating to'--
g 14 Q I think message No. 17, for example, was one, if
'k 15 you are looking for an example.
16 A (Callendrello). Yes.
- 17. Yes, general emergency message on seasonal -- it's
-18 sheltering of some communities, seasonal closure of beaches 19 and wildlife refuges.
20 Q So it's reasonable --
21 A (Callendrello) No, I'm sorry. l 22 Q I'm sorry.
23 A -(Callendrello) Let me just correct that.
24 Seventeen-does not include that. However, 18 25 does.
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REBUTTAL PANEL NO. 19 - CROSS 27880
'l Q Did you want to continue? ;
2 I don't want to interrupt you.
3 A (Callendrello) No, no, I was just looking at the I
4 message.
5 Q So it's reasonable to assume then that these 6 transit-dependent beachgoers upon hearing the message will i
7 in fact go.to the nearest indoor shelter and wait assured of 8 the transportation?
9 I mean that's a logical presumption based on if I 10 hear that message.
11 A (Callendrello) For those people who will rely on 12 a bus for transportation, that's correct.
13 I think Dr. Mileti has some opinions, and has 14 expressed some opinions about the level of ride-sharing that
(
15 would occur among that population.
16 Maybe you can add to that.
17 A (Mileti) I was just going to say, some of them 18 would and some of them wouldn't. 4 19 Q Sure.
20 Some people get rides. Some people don't. I 21 understand that.
22 In other prescripted messages, you simply tell 23 people to leave the area immediately. These are the same '
24 people, the same transit-dependent beach people.
25 Isn't that correct?
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1 In other words, there are other messages. In
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( ,j 2 fact, proportionally speaking there are more messages, more-3 prescripted messages that simply tell the people to leave i
4 and there is no assurance of any forthcoming bus.
5- P. (Callendrello) The messages I think they are 6 referring to are the-messages that are used at levels .
7 earlier than a general emergency, and that is a site area 8 emergency.
9 We were not talking about evacuation of portions 10 of the Massachusetts EPZ, but we are talking about the 11 closure of the beaches.
12 The portion of the message you've referred me to 13 on the buses talks about persons at beach and park areas
,,- g 14 from Salisbury to Plum Island, including the Parker River
\_s 15 National Wildlife Refuge, should evacuate those areas 16 immediately.
17 Whereas, other messages talk about the areas being 18 closed. Please leave those areas immediately.
19 Q So is the criteria used to decide between the two 20 types of messages the level of emergency?
21 A (Callendrello) Yes, that is the case. With the 22 exception being message 17 you pointed me to appears to have 23 a mistake in it, in that it doesn't have that information.
24 Q That's serendipitous. I hadn't even realized that 25 and that's the ono I plucked up.
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' REBUTTAL PANEL NO. 19 - CROSS 27882 1 Is that correct, though, Mr. Callendrello, that ;
2 the criteria used to decide whether you disseminate the 3 information saying, beach people, hang on, the bus is i I
4 coming; as opposed to, beach people, leave to your own l 5 devices, is the level of emergency?
6 A (Callendrello) It's whether you have ordered an 7 evacuation of the beaches or whether you have closed the 8 beaches.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 ,
23 24 25
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' 1' Q 'So1I guess it's just'an assumption that people'can f3
(, '2 get a ride or get out on their own with no danger at a beach, 3' closing as opposed to an evacuation?
4 A (Callendrello) The reason we take a precautionary 5 action.and' term it a' precautionary action is the fact that; 6 it's taken before there is.a need to take a' protective .
7 action. 1 8 So by the' definition of the fact thAtLit is a l 9 precautionary action there'is not a danger. If there was a 10 danger -- and I'll use your term -- meaning if there is a-11' release or'a potential for a release that would exceed the 12 protective action guides we would recommend a protective 13 action and the bus provision would come into play.
It is the intent of the-beach' closing, isn't it, r- - 14 -Q
- (/ 15 to remove the beach population from the zone?
16 A (Callendrello) It is to reduce the beach 17 population in the immediate area of the beaches. I wouldn't 18 say it's the intent to remove these people from the 19 emergency planning zone, although I think in.some cases that 20 would happen because those people that live outside the 21 emergency planning zone would go wherever they live.
22 Q The. intent is to remove the' people from the 23 beaches, then not necessarily the zone?
24 A (Callendrello) The beach area.
25 Q Are you aware that Parker River refuge is about Heritage Reporting Corporation N. (202) 628-4888 I _ _
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REBUTTAL PANEL NO. 19'- CROSS 27884 1 four miles long? 3 2 A (Callendrello) Yes, I am, j 3 Q That there's only one ranger shelter at the north 4 end of the refuge?
5 A (Callendrello) Yes, I believe that's correct.
6 Q You said just a minute ago, Mr. Callendrello,.that 7 the purpose of the early beach closing is to reduce the
- 8 population at the beach?
9 A (Ca11endre11o) I said that was one of the 10 purposes.
11 Q So you figure that you can reduce the population 12 but you can't remove them all from the beach?
13 In other words, there will be some left?
i 14 A (Callendrello) No, that's not what I meant by ,
15 that.
16 What.I meant was, I would expect that those 17 precautionary actions would tend to remove day-trippers, 18 roughly half of the beach' population; and likely some of the 19 people who are weekly, monthly, seasonal residents.
20 Although it's intended to get people moving from the beach, 21 reduce the beach population so that later protective actions l 22 cou14 be achieved more quickly.
23 Q ORO decided to reroute traffic at 1910 -- I think 24 that's 7:10 regular time -- correct?
25 A (Ca11endre11o) Just give me one minute and I'll l
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1 check.
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2~ sQ Sure.
3 MR. SMITH: Could you just repeat, I'm sorry, I 4 missed that.
5 -N3. TALBOT: Oh, that's all right.
6 BY MS. TALBOT: .
7 Q ORO decided to reroute traffic at 19107 8 MS. TALBOT: That's military time.
9 MR. SMITH: Okay.
10 THE WITNESS: (Callendrello) No , that's not what 11 my review of the exercise documentation indicated. It 12 indicated that the reroute was in place and in assuming the 13 rero'ute, we are talking about the traffic impediment, the
- 14 nonremovable traffic impediment that occurred as part of the 15 scenario at traffic control point NNO-3.
16 My review of the exercise documentation indicated 17 that the reroute was complete about 1845.
18 BY MS. TALBUT:
19 Q Okay.
20 There seems to me, just for clarity sake, some 21 discrepancies between FEMA noted times and the times that 22 were noted on the face of the actual releases.
23 So I have stuck with the times that FEMA uses and R 24 maybe this is a good time to find out what time is what.
25 A (Callendrello) The way I understood your question
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REBUTTAL PANEL NO. 19 - CROSS 27886 1 was: you' asked when we implemented the reroute.
2 If you're talking about the news release, the news 3 release time is 1910 according to the exercise report.
4 That's consistent with the actual news release. The last 5 signature was at 1904, so it's about 1910 that it would have 6 been released. I l
7 Q The actual reroute'was 19457 i
8 A (Ca11endre11o) It was implemented at 1845.
9 Q Okay.
10 A (Callendrello) Or in place at 1845.
11 Q This decision to reroute was disseminated to the 12 public ab:ut an hour and a half after the accident; correct?
13 A (Ca11endre11o) About an hour and 15 minutes, 14 actually.
15 Q The rerouting of traffic sent people who were 16 heading west to pick up I-95; correct?
17 It sent people - people who were heading down to 18 pick up I-957 19 A (Callendrello) Yes.
20 Q The rerouting of traffic would have sent them 21 further west if they were on the east side of I-957 22 A (Callendrello) No , it would have sent them down 23 Highfield Road to Middle Road to Orchard Street and then to 24 the west. It would have actually been to the south and then 25 to the west of 95.
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' REBUTTAL' PANEL NO. 19 - CROSS l' Q .So'uthwest?
2 A. (Callendrello) ' Excuse me,~not "of" 95, but south 3 and to the west of where they were diverted from.
4 Q' Right. Okay.
5' Isn't it reasonable to assume that traffic, flow on 6 the reroute roads would be slower than traffic flow'on the .
7 interstate?
8 MR. SMITH: Are we getting into the substance of 9 traffic management here?
10 MS. TALBOT: No, we're not.
11- We're getti:ag into what'you tell the public in 12- EBS.
13 MR. SMITH: Well, I'll see where it goes.
14 MS. TALBOT: Okay. -
15 THE WITNESS: (Callendrello) I'm sorry, could you 16 please repeat the cpaestion, I missed part of it.
17 BY MS. TALBOT:
18 Q Isn't it just common sense that traffic flow on {
19 reroute roads is slower than traffic flow on an intersta'te?
I 20 A (Callendrello) I would expect that to be true in l
< 21 this case. I have no independent expertise on that, but I 22 recall-Mr. Lieberman saying that traffic was free-flowing'on 23 Route 95, so that would indicate to me that they would be 24- traveling at higher speed than a 1r> cal road.
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REBUTTAL PANEL NO. 19 - CROSS 27888 1 rather, evacuees heading south on I-95 may have looked for 2 an alternative route; correct? ;
3 In other words, I'm driving in my car and I hear 4 the message saying: drivers, there's a block on I-95. And I 5 say, oh, my, I think I'll avoid the block and I get off. )
6 I'm asking if you think that's reasonable to !
i 7 assume that.that's how listeners might respond when hearing 8 an official news release or an EBS? l 9 MR. SMITH: I'm going to have to object here.
10 I think we're getting into all sorts of matters 11 and not the issue at hand. And the issue at hand is whether 12 the EBS message was timely or not; and not how people would 13 behave with respect to that. It's not where they will go.
14 I just think that we're getting beyond the scope 15 of this testimony.
16 MS. TALBOT: Your Honor, I would just respond that I
17 the issue I'm getting at here is not so much timeliness, 18 although that's an element of it, it's the content of the 19 message.
20 MR. SMITH: Well, what I would respond: just from 21 the question it seemed to be what people will be doing 22 before the message even went out, so I don't see how that 23 connects up with content.
24 MS. TALBOT: I'm asking I think just a, you know, 25 it's a preliminary question, I can get to my point without Heritage Reporting Corporation s
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1 it. But I think it just bears on, you know, common sense 2 observations.
3 JUDGE SMITH: You're just laying the ground work j j
4 for a scene that will prevail when the EBS message comes 5 out?- j 6 MS. TALBOT: Exactly. .
7 JUDGE SMITH: Well, you do seem to be getting into 8 traffic management litigation. Under this subject matter we 9 could relitigate almost anything we have.been litigating for 10 the last 10 weeks. )
11 MS. TALBOT: That's true.
12 Well, I'm on my last section of pages, if that's 13 any consolation.
g; 14 JUDGE SMITH: All right.
(/
Is_ 15 Go ahead. Yes, that's consolation.
16 (Laughter) 17 MR. TRAFICONTE: He took you up on it.
18 MS. TALBOT: Mr.' Fierce is bringing my appendix 19 from the office.
20 (Laughter) 21 BY MS. TALBOT:
22 Q So, Mr. Callendrello, again, isn't it just common 23 sense that when the message is aired a driver -- an evacuee 24 heading south on I-95 hears the message before they hit the 25 traffic guides and says, I think I'll jump off here and i j
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RE!UTTAL PANEL NO. 19 - CROSS 27890 1 avoid the mess?
2 A (Callendrello) First of all, you have 3 characterized this as an EBS message; it was not an EBS 4 message, it was a news release.
5 Q Oh, my apologies.
6 A (Callendrello) And I think as our testimony 7 states on page 52, looking at the text of the message it 8 certainly was not as clear as it could have been. I'll 9 defer to Dr. Mileti. But it may have been that somebody 10 could misinterpret that message as saying that I-95 was 11 blocked.
12 However, they certainly would not, if they were 13 traveling southbound on I-95 they would not have experienced 14 any backup because the impediment was actually on the 15 entrance ramp.
16 Q I appreciate that, j
17 My question though was: pretend that you' re a 18 driver anywhere and you hear a news release over the radio 19 saying, there's a big log jam coming up; isn't it reasonable 20 to think that you or someone else in your situation might 21 get off before they even hit the log jam in order to avoid 22 it?
23 A (Ca11endre11o) Well, rather than speculate on l 24 what the message said, the news release -- again, not an EBS 25 message. I can read it. It said: "An overturned lumber Heritage Reporting Corporation I
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RE!UTTAL PANEL-NO. 19 - CROSS 27891 i l' truck on' Route I-95Esouthbound at the junction of Scotland s)
Road is blocking traffic. flow southbound. Traffic out of
,( ,/ 2 3 . the emergency planing zone has been rerouted around the 4 obstacle.. Traffic is being detoured south on Highfield Road 5 to Middle Road to Orchard Street to Central Street then 6 rejoining I-95." .
7 What that message would say--to me as traveler is:
8 if.I'm on 95 and if I keep going I'm going to be rerouted 9 around the obstacle','just like a construction zone or a 10 construction detour.
11 Q This is not a true question: isn't it reasonable 12 to assume that some drivers may seek another alternative-13 route?
j f-- 14 -A (Callendrello) I'm not qualified to' answer that. ,
) l '
15 -Maybe Dr. Mileti is.
16 A (Mileti) Yes,.it's possible; given these 17 particular circumstances it's not probable. I would suspect 18 that most people would have stayed dn the highway that was 19 free-flowing. But it is quite possible that some would have ;
20 done something else, but then it always is in reference.to 21 human behavior.
22 Q So in.other words, Dr. Nileti, you're saying that 23 some people may seek alternative routes off the interstate?
24 A (Mileti) I said, yes, it's possible.
l 25 Q Thank you. ;
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1 A (Mileti) I might also add, however, that one 2 would hope that they're focused on the EBS messages and 3 perhaps listening to that station. That this was a news 4 release probably would have reduced the possibility even 5 further than had it been an EBS message. f 6 Q How is a listener supposed to know which station i 7 has news releases and which station has EBS or how are they 8 supposed to know that stations have one or.both?
l 9 or how are they supposed to discriminate?
10 JUDGE SMITH: Pick your choice, whatever question 11 you want to answer.
12 (Laughter) 13 THE WITNESS: (Callendrello) There are a couple 14 of indicators that an EBS message is an EBS message.
I 15 First of all, there is a tone, there's an 16 activation tone. And there's also an introductory sentence, 17 and I don't recall it exactly. It's called an activation 18 advisor. In fact, it's in Attachment A to our testimony, as 1 l 19 I recall.
20 THE WITNESS: (Mileti) While Mr. Callendrello is 21 looking for that I can point to you that at the end of most, 22 if not,all, EBS messages it says: " Keep tuned to this EBS 23 station for the latest official information," which names it 24 as an EBS station. That this is an EBS message.
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1 BY MS. TALBOT:
( ,) 2 Q And this was never aired on the EBS?
3 A (Ndleti) I would have to look to answer that. 1 1
4 A (Callendrello) No, I don't believe it was.
5 Q So does that mean this information wasn't that j i
6 important? .]
7 A (Mileti) I wouldn't say that it wasn't important.
8 Certainly different sorts of emergency information can, in 9 someone's judgment or my judgment, be ranked according to 10 importance. One would mean important in reference to what 11 in order to do that.
12 However, it wouldn't have reached as many people.
13 So in terms of public behavior, if it had gone out over the
,- 14 station as an EBS message, more people at that point in the
\-s/ 15 emergency would have likely heard it than might have heard j 16 it because it was given to some people in the form of a news 17 release and then further down in the communication chain 18 somebody might put that into a story or talk about it over, 19 for example, the television or radio.
20 Q So news releases are heard by more people but 21 contain less important information than EBS which are heard 22 by fewer people?
23 A (Mileti) I didn't say that.
24 Q Well, isn't it a fact that EBS is only carried on 25 local Essex County stations?
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REBUTTAL PANEL NO. 19 - CROSS 27894 1 A (Callendrello) The EB'S station that is identified 2* in the SPMC is located in Essex County. However, I wouldn't 3 call it a local Essex County station, it's a 50,000 watt FM 4 station. Mr. Catapano can address the range. But I know it 5 has got a substantial range. I've picked it up probably 40 6 or 50 miles away, although he can talk about what the 7 licensed range of that would be.
8 Q If he wants to, fine.
9 A (Catapano) It is an area that extends well beyond
! 10 the emergency planning zone.
11 Q Isn't it a fact though that the news releases are 12 carried by big Boston radio stations that have the largest l 13 listening public?
14 A (Callendrello) I don't know what the Arbitron 15 ratings are for the various stations.
16 It's true that the news media -- large numbers of 17 the news media can be accommodated at the media center and 18 as such would have access to the news releaser.
19 Keep in mind, if we're off this specific incident, 20 the EBS messages are also put out as news releases. The l
21 text of an EBS message is repeated as a news release and as 22 such is disseminated to the various media with a phrase that 23 identifies it as having been broadcast over the emergency 24 broadcast system.
25 A (Mileti) But in addition to that, it's not just Heritage Reporting Corporation
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l REBt'.'TAL PANEL NO. 19 - CROSS 27895 1 what radio station has the largest audience in an area like Ad 2 this one. Normally, we've_tried to devise in an emergency
~3 plan that when people need to be listening to an emergency 4 information, would help focus people's attention on the EBS 5 station.
6 So that a person who might normally' listen to one .!
7 station in this emerge.ncy will want to increase the 8 probability of listening to the EBS station.
9 10 11 12 l 13 r 14
{b 15 .
16 17 18 ,
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REBUTTAL PANEL No. 19 - CROSS 27896 1 A (Mileti) For example, that's why we have things 2 in here that say stay tuned to this EBS station for the 3 latest official information.
l 4 That's just one example of one of the ways to try 5 to do that.
6 Q Does an EBS or news release message ever tell 7 someone to turn to another station?
8 A (Mileti) It's possible. I'll have to check and 9 see.
I 10 A (Callendrello) Certainly an EBS message does not.
i' 11 A (Mileti) I think the answer is yes.
12 If people in Massachusetts are listening to the 13 New Hampshire EBS, it tells them to turn into the ,
14 Massachusetts EBS. ,
15 A (Callendrello)- And, yes, the news releases do 16 instruct Massachusetts residents to turn to their local i l
17 emergency broadcast system radio station and identifies the 18 stations by call letters and frequency.
19 Q So all EBS information is disseminated'in the form 20 of news releases aside from dissemination as EBS, correct?
21 A (Callendrello) Correct.
22 Q But not all news releases are disseminated in the 23 form of EBS?
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24 A (Callendrello) That is also correct. l 25 Q So some information that's parleyed by way of news i Heritage Reporting Corporation s-- (202) 628-4888
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1 REBUTTAL PANEL NO. 19 - CROSS 27897-1 release does not get parleyed by way of EBS.
,: ' .~h- l lq ,/ 2 A (Callendrello) I'd say that there is no ]
3 requirement and nothing procedurally that would require EBS J
4 messages to contain all of the information in the news 1 7
5 releases. l J
6 Some information that's in news releases may also .
7 be in the EBS messages, but there is no procedural 8 requirement that that occur.
9 Q So it's just a judgment call as to what's 10 important?
11 A (Mileti) Well, it's more than a judgment call.
12 The EBS messages were designed to focused people's attention 13 on the most important information for getting them to make I
fs 14 good decisions and then follow through on them about what to i (\~ ') 15 do in response to the emergency.
16 There may be a raft of bits of information that --
17 Q Excuse me.
18 There may be a what?
19 A (Mileti) A lot of information. I said " raft".
20 Sorry, 21 Q I like that.
22 A (Mileti) There may have been a lot of information 23 that could go out in a news release or in some other form 24 that would detract people's focus from the more important 25 information in an EBS message.
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RE2UTTAL PANEL NO. 19 - CROSS 27898 1 Q To get off this and back to what we were talking 2 about before that about some people might seek alternative 3 route.
4 You would agree that the plume at that time was 5 moving from the east to the west during the time of the 6 rerouting and airing of the message, correct? i 7 A (Callendrello) I don't think --
8 Q I can show you the METPAC printout if it will 9 refresh your memory.
10 A (Callendrello) It would.
11 I don't recall that to be the case.
12 (Document proffered to witnesses) 13 A (Callendrello) This does not refresh my memory in 14 that it doesn't have any time of analysis on here.
4 15 Q What does the T 1845 --
16 A (Callendrello) Oh, okay, thank you. Thank you.
17 Yes, there is.
18 Yes, it shows the plume generally, although the i 19 wind was blowing from east to west at about 79 to 89 degrees 20 at the time, so that the plume was heading almost due west.
21 Q And no information was disseminated mentioning the l
22 position or direction of the plume, correct?
23 A (Callendrello) That's correct.
24 Q So isn't it true, then, that when selecting 25 alternative routes, evacuees may have unwittingly driven Heritage Reporting Corporation s_s (202) 62P -4888 u_.- _ _ _ _
RE!UTTAL PANEL NO. 29 - CROSS 27899 1 through the plume?
O T j 2 MR. SMITH:
Your Honor, I think we're getting'into 3 a lot of substantive areas here that go beyond the. scope of 4 this testimony.
5 MS. TALBOT: The only point, Your Honor, is that i 6 should public information -- if you'are taking someone off a .
7 main route that is going to bring them from Point A to Point 8 B in a lot less time than it's going to be to go through 9 everyone's cow pasture, and there is a chance you' re going 10 to maximize your dose when you are on your reroute, should 11 you know, should you know that?
12 Should the message disseminated over the wire tell 13 you?
, - , 14 Well, that's the only point.
$s s 15 JUDGE SMITH: Just that. That's all.
16 MS. TALBOT: Well, yes. I think it's a pretty big 17 point. That's the thrust of that line of questioning, is 18 that the listener is never told that they could maximize 19 their dosage by seeking alternative route.
20 It's a whole different scenario if the plume is 21 blowing east or if it's blowing north. But when it's 22 blowing from east to west, and people are traveling due west 23 or south to the west, then there is a chance they drive into 24 the plume.
25 JUDGE SMITH: We don't have an objection actually.
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l REBUTTAL PANEL NO. 19 - CROSS 27900 1 MR. DIGNAN: Is there any assumption as to dose 2 that would be received?
3 MR. TRAFICONTE: Is that someone from the audience 4 who is --
5 (Laughter)
)
6 MR. DIGNAN: It's pulling a Traficonte.
I 7 MR. TRAFICONTE: I don't think I can recall 8 sitting back there and --
9 JUDGE SMITH: There's no microphone, Mr. Dignan.
10 (Counsel approaches microphone.)
11 MR. DIGNAN: Is there an assumption in the 12 question as to the dose that would be received, because I 13 think the answer might be different, depending on whether 14 PAG doses are going to be received? !
15 MS. TALBOT: The assumption in the question is 16 that you get from Point A to Point B quicker on an artery or 17 an interstate than you do in Farmer Jones' back road.
18 And the further as'sumption is there if you are in 19 the middle of a plume, you're going to get out quicker on 20 the artery. And if you are going to reroute, you should be 21 told.
22 , MR. DIGNAN: To what?
23 MS. TALBOT: You tell me. You guys drafted the 24 messages.
l l 25 MR. DIGNAN: Well, my question is, in yonr l
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. ,r 1 question, is there an assumption as to the'. dose that will be .
2- received at one route or another.
3 In the question, is there an assumption?
4 MS. TALBOT: I don't know anything about -- l 5 MR. DIGNAN: ' Okay.
6 MS. TALBOT: -- health effects'of radiological .'
7 accidents.
8 JUDGE SMITH: Do you understand the significance 9 of his question?
10' Would a PAG --
11 MS. TALBOT: I knew it would litigate dosage.
12 JUDGE SMITH: No.
13 Explain that, Mr. Dignan.
.jrs g 14 MR. DIGNAN: I would think -- I would personally, 15 if I were answering the question, not give a hoot about 16 giving this information out if I was clear that they were 17 not going to receive a dose above any EPA PAG, because I 18 think by sticking it in the message all I would do is cause 19 worry that shouldn't be in the picture.
20 On the other hand, if I was convinced that the 21 dose was a real zapper, I probably wouldn't route them there .
i 22 in the first place.
23 MS. TALBOT: That was my point.
24 MR. DIGNAN: But, yes, we would at least to a 25 point where maybe I think they ought to be given a choice. ,
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i REBUTTAL PANEL NO. 19 - CROSS 27902 1 But without knowing whah the dose assumption is in 2 '
the question, I don't think it's a fair question to put to 3 the witnesses because that's going to be key to the answer.
4 MS. TALBOT: Let me put this question to the 5 witnesses.
6 BY HS. TALBOT:
7 Q Witnesses, where on the prescripted EBS message is 8 there any language that gives people the choice as to the 9 rerouting of traffic? j i
f 10 MR. SMITH: Do you understand the question?
11 BY MS. TALBOT:
12 Q A generic, generic language. ]
13 A (Callendrello) The EBS message, first of all, did 14 not address the reroute. That was addressed in a news 15 release.
16 Q Because reroute is not as important as other 17 information? !
18 A (Callendrello) Yes, that was the judgment that 19 was made.
20 Q Okay.
l 21 Dr. Mileti --
22 A (Ca11endre11o) If I can just add to that also.
l 23 Q Sure.
24 A (Callendrello) The fact also is that people ,
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REBUTTAL PANEL NO. 19 - CROSS 27903 1 encounter the reroute if they were on 95, and soraebody 2 thought they were going to encounter it.
3 If somebody was traveling on Scotland Road, they 4 would encounter the reroute and therefore would, in essence, 5 have no choice. They would follow the reroute to get to 6 their selected evacuation route, which would be I-95 .
7 southbound.
8 So that the information that's being conveyed, 9 it's being conveyed through the person that's standing at 10 that traffic control point saying, don't go straight. Make 11 the right turn and go down Highfield Road.
12 Q It's also being conveyed over the air?
13 A (Callendrello) It's being conveyed through a news 14 release and the media and mechanisms that would utilize that
\O 15 news release. .
16 Q Dr. Mileti, could you turn to ORO EBS No. 27 1" Maybe you are already familiar with it enough you 18 don't have to.
19 A (Mileti) Well, I do have it.
20 Q That's the one that advised residents of Amesbury 21 and Salisbury to evacuate, but said the school children 22 would be held.
23 A (Mileti) I don't think it is.
24 A (Callendrello) No, it's not.
25 Q What number is that?
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l REBUTTAL PANEL NO. 19 - CROSS 27904 i 1 A (Mileti) I think you might mean three.
2 JUDGE SMITH: Are you looking at it?
-1 3 MS. TALBOT: I had it on my notes. I didn't have 4 it in front of me. I wrote the wrong number down.
1 I
5 BY MS. TALBOT:
6 Q Everyone is familiar with this EBS?
7 A (Callendrello) I don't know if everyone is.
8 I m. ,
9 (Laught #
10 Q It will only take a minute to dig it out.
11 (Witnesses review document.) i 12 A (Callendrello) We've got it now.
13 JUDGE COLE: Which one is it?
14 THE WITNESS: (Callendrello) EBS message No. 3 15 from the exercise.
16 MS. TALBOT: Oh, it's No. 3?
17 Okay. l 18 N3. TALBOT: Your Honor, could I have a three-19 minute break?
20 JUDGE SMITH: All right.
21 MS. TALBOT: Thanks.
22 (Whereupon, a recess was taken.)
23 MS. TALBOT: Okay.
I 24 I'm towards the end of my reroutes.
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l' BY MS. TALBOT:
.-p('
A .2 '
Q -Dr. Mileti, you don't think that EBS message.No. 3 f 3 was clear.and accurate,.do you? i 14 A (Mileti) I think in many regards.it was clear and !
5 : consistent, but not entirely.
6 Q The EBS message that corrected the inaccuracies in .
7 t'nis message, that was at about an hour and 45 minutes 8 later,. correct?
9 A (Mileti) I called at-1.75 myself, which is, of 10 course, an hour and three quarters. ,
11 Q 'Okay.
12 .Within that one hour and 45 minutes, isn't it 13 ' reasonable to assume that many people would have acted on 14 the initial information?
$0 15 A (Mileti) Well, it depends on what you mean by 16 " initial information" and which information and what action.
17 Q Exactly, there is two pieces of information going 18 out. Pick up your kids, don't pick up your kids.
19 Isn't it reasonable to assume that some people 20 would pick up their kids, some people wouldn't?
21 A (Mileti) I'm sorry.
22 My recollection of EBS message No. 3 is not that 23 there was information said suggesting that people pick up 24 their kids.
25 Q Excuse me.
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REBUTTAL PANEL NO. 19 - CROSS 27906 1 People would have gone to host facilities to pick 2 up kids.
3 (Witnesses confer.)
4 A (Mileti) Would you mind repeating that question?
5 Q Within the hour and 45 minutes that lapsed between 6 the subsequent EBS that clarified EBS No. 3, isn't it !
i reasonable to assume that many people would have acted on j 7
i 1
8 inaccurate information?
9 In other words --
10 I'm sorry, go ahead.
I 11 A (Mileti) I believe that many people would have 12 acted.
13 I don't know that I can agree that they would have 14 acted on inaccurate information.
15 I'm sorry, I just don't understand the question. ;
16 Q I'll try again.
17 You've agreed that the message is as clear and 18 accurate as it could have been?
19 A (Mileti) I believe I said that I thought the bulk 20 of it was.
21 Q Right, okay.
22 A (M11eti) But that there were some conflicts in 23 it.
24 Q Among other things, the message says kids will be 25 sent to host facility where they may be picked up.
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~ l' . :A (Mileti)- It'says, " School children.will-then be-2 sent.to the host' facility," in A, "where they.may be-picked 3, up."
4 Yes, it-says that.
5 Q So isn't it reasonable to assume that some people 6 'may have gone to pick up their children? ,,
.7- A .(Callendrello) At the host facility.
- 8. And the host facility.being.the Holy Cross-College 9 in. Worcester.
10: .Q Also reasonable to assume that some parents would-11 go and pick up the1 children at school, because'the message 12 also said children are being held at-school?
13 A (Mileti) In response to hearing EBS message-3,
-s. .14 -yes, I agree,.some parents would have gone to-schoolLto pick
\ -
15 up their children.
16 Q Okay. .
17- In your opinion, Dr. M11eti, is an hour and 45 18 minutes a reasonable ~ time to let this kind of information i
19 stand where parents are doing two different things, one of 20 which they are not supposed to be doing?
21 A (Mileti) Well, I'm not sure I understand your 22 question. ,
l.
L 23 Q Okay, I can rephrase it.
24 You would agree that the protective actions for 25 school children is important information?
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i I I REBUTTAL PANEL NO. 19 - CROSS 27908 1 A (Mileti) ,
Yes, I do.
2 O You would agree that telling parents what to do 3 about school children is important information?
4 A (Mileti) Yes, and giving them information about y 5 what's going on at school as well.
6 Q Do you think an hour and 45 minutes to correct 7 confusing information about protective actions for school 1 l
8 children and what parents should do is indicative of timely i 9 dissemination?
10 A (Mileti) Well, I could only really answer that 11 question in context of the particular emergency.
12 Let me say, in general, that it would be my 13 preference that this inconsistency not happen at all. And 14 then if it did happen, that it would be corrected as soon as 15 possible.
16 But whether or not an hour and a half -- I'm 17 sorry, an hour and 45 minutes is timely or not really can i 18 only be judged in terms of whe'ther or not it had any 19 negative impact on public health and safety.
20 But, in general, I think it would be nicer if 21 there wasn't any inconsistent information to begin with.
22 And the sponer it's corrected, in general, the better.
23 Q In general, is an hour and 45 minutes a long time 24 to correct, in your experience, to correct EBS information?
25 A (Mileti) Well, you mean based on my experience at l
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i REBUTTAL PANEL NO. 19 - CROSS 27909 L
11 ENCs that don't involve technological. emergencies? q X/ j\ . 2 Q
- No, I meant-besed on you --
3 A (Mileti) Wall, in general, I can say this.
f 4 That most emegency wnrning messages that go out ;
5 have inconsistencies in them. And you really are in search 6 of the Holy Grail to go through an emergency, a real .
! 7 emergency or maybe even an exercise where'there aren't 8 inconsistencies.
l-9 some never get corrected. Some get corrected 10 quickly. ;
)
11 I think it would be nice if we could correct 12 inconsistencies like this one quicker than an hour and 45 13 minutes.
f 14 But that with hindsight one can-only really judge D 15 whether or not that was a timely correction or not on the 16 basis of whether or not it would have had a negative impact l 17 on the public health and safety.
18 Q Message No. 7, which was released around 2:20 I 19 p.m., I believe that told transit-dependents to wait for l 20 announcement of bus routes? ,
21 A (Callendrello) I'm sorr'y, I'm not sure I have the j 22 right message.
23 Which messages are we talking about? EBS messages 24 or the news releases?
25 Q News release.
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-' 1 THE WITNESS: (Callendrello) I've got that
- [(_j)/: 2 message or~I've-got:that news release.-
3 MS. TALBOT:- Right.- Okay.
4 BY-~MS. TALBOT:
5 Q In your opinion, Dr. Ndleti,.when there is a 6 protective action to evacuate, do you think three-hours is a .
7 long time to wait for a bus?
8 A (Mileti) I can't imagine ever thinking that 9 three-hours is a-short wait for a bus be it an evacuation or 10 not.
11 Q 'But, in fact,.the news release that actually 12 announced the bus routes occurred three-hours later; 13 correct?
14 (Witnesses reviewing document. ) -
O\ 15 THE WITNESS: '(Mileti) -I'm sorry,'I' don't 16 understand your question.
17 Right now I can't find what part of news release 18 number 7 talks about buses. It may be there, I just can't 19 put my finger on it right now.
20 BY MS. TALBOT:
21 Q For the record I'm looking at the FEMA exercise 22 report.
23 MR. SMITH: What page is that, Ms. Talbot?
24 MS. TALBOT: 43F on page 91.
25 THE WITNESS: (Callendrello) ORO news release
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REBUTTAL PANEL NO. 19 - CROSS 27912 1 number 12 was a repeat of EBS message number 6; and that was ;
2 issued as a news release at about -- well, as it says there 3 at 1730 -- it was issued as an EBS message at about 1700 or 4 about a half an hour before that.
5 (Pause) 6 THE WITNESS: (Callendrello) 1711 or about 20 i i
7 minutes before that. 1 8 MB. TALBOT: I'm just trying to find my copy of 9 the actual messages, excuse me a minute.
I 10 (Pause) 11 BY MS. TALBOT:
12 Q News release number 7 tells people to wait for the 13 bus; correct?
i 14 MR. SMITH: I don't see that either, Ms. Talbot, l
15 if you could just point to a line. {
16 MS. TALBOT: The second page, the last paragraph: 1 l
17 "If you don't have a ride buses will travel along emergency 18 routes. Wait for an announcement stating what time the 19 buses will begin traveling and where the emergency routes 1
20 are."
21 THE WITNESS: (Callendrello) Correct.
22 MR. SMITH: Oh, I see, okay.
23 BY MS. TALBOT:
24 Q The emergency routes didn't come over the wire 1
l 25 until release number 12; right?
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1 REBUTTAL' PANEL NO.;19 CROSS- 27913 .'ll
- 1. A (Callendrello) As~that news release' indicated - ' j 3..
[~ . .
I
& 2 and again,: t'.aat news release was a repeat. of EBS message j 3- number 3 and it indicated that buses would begin running the. jl 4 routes, wait for an announcement stating what' time buses q 5 .will begin traveling the-emergency _ routes.
6 As indicated in that message a subsequent message. .
'7. that was released first as an EBS message at about 1711, and 8 that EBS message was message number 6, and it was also 9 released as news release number 12 aboat 20 minutes-later, 10' 'and indicated when buses would begin running.the emergency 11' routes.
12 A (Mileti) I would be willing,'for what it's worth,
, 13 to wait 20 minutes for a bus.
- 7- 14 Q; Panel, can I refer you to Attachment E of your i
15 testimony for a minute.
16 A (Callendrello) I've got that.
17 Q Which of you on this panel also sat on the panel-18 for Rebuttal 18?
19 A (Callendrello) I did.
20 Q Did you,.Dr. Milsti?
21 A (Mileti) Not that I recollect. But I don't 22 remember things by number. If it was, where this comes from 23 I know the answer is, no.
24 A (Callendrello) Let me correct myself, I ldidn' t .
25 sit on the panel and we did not offer that testimony. I was Heritage Reporting Corporation l
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REBUTTAL PANEL NO. 19 - CROSS 27914 l 1 indicated as a sponsor of that testimony in its prefiled j 2 form.
Rebuttal No. 18 was withdrawn; I 3 MS. TALBOT:
4 correct? j l
5 MR. DIGNAN: Correct. l
)
6 MR. SMITH: That's correct. l 7 MS. TALBOT: Your Honor, at this point I want to 8 move to strike Attachment E.
9 MR. DIGNAN: Attachment E came out of 18 j j
10 originally. Attachment E to this testimony was once in 18, i
11 JUDGE SMITH: Mr. Dignan, you' re not on the 12 record, if that's all right with you.
13 MR. DIGNAN: I'm sorry, Your Honor, ,
, 14 MR. TRAFICONTE: Kind of a limited appearance 15 statement.
16 MR. DIGNAN: No.
17 If what you're wondering is, Attachment E to this 18 testimony was once attached to 18 which was never offered; 19 yes.
20 And it gains its vitality through this piece, not 21 through 18 which has been withdrawn.
l 22 BY MS. TALBOT*
l 23 Q Mr. Callendrello, who testified as to Rebuttal 18 I 24 aside from you?
25 MR. SMITH: Nobody actually testified.
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t REBUTTAL PANEL NO. 19'- CROSS 27915 1 MR.-DIGNAN: Itwas withdrawn.
2L BY MS. TALBOT:,
3' Q. Whose testimony.was it?
4 Al (Callendrello) I know Mr. Sinclair was also on 5 the cover sheet of that testimony and helped prepare that
~
6 testimony. . I think.that was it. I don't recall whether- .
7 anybody else was indicated.as a sponsor of that testimony.-
8 Q And you were on that, too, correct?
'9 A (Callendrello) Yes, I was.
10 MS. TALBOT: Your' Honor, I move to strike this 11' testimony. I' don't have an opportunity to cross-examine the 12 witnesses who prepared that.
13 JUDGE SMITH: Strike what?
p 14L MS. TALBOT: Attachment E, Your Honor, m- 15 MR. SMITH: I'm not sure, Your Honor, that it has 16 been established that the witnesses who prepared this 17 particular. portion of the testimony are not available.
18 MR. TRAFICONTE: Well, would w'e be able to 19 establish it since one of the witnesses on the Panel 18 20 testimony is not before us. 1So we'couldn't put the question 21 to him whether he contributed any portion of Attachment E, 22 could we. .
23 MR. DIGNAN: Well, you can ask Tony if he supports j
~
24 it. It's in as part of his testimony. ;
- 25. MR. TRAFICONTE: I'm going to respond to counsel l
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REBUTTAL PANEL NO. 19 - CROSS 27916
. 1 at table and then you can communicate to the audience.
i 2 But the basic thrust here is that the panel 3 testimony is sponsored by all the panel members.
4 MR. DIGNAN: That's right.
5 MR. TRAFICONTE: That's been clear from day 1.
6 And this piece is a piece of panel testimony of 7 Mr. Callendrello and Mr. Sinclair, and Mr. Sinclair is not 8 in the room.
j 9 MR. SMITH: Well, the thing you got to remember, 10 this piece of testimony was referenced in our testimony 11 that's right now sitting in front of you.
12 MS. TALBOT: Yes, and I'm objecting to it.
13 MR. SMITH: Well, in that respect Mr. Callendrello 14 could be qualified to state whether he sponsors this 1 15 testimor .y.
16 JUDGE SMITH: That's where we are.
17 I don't think it matters where this ever appeared 18 before and what happened to it. The issue right now is: can 19 any witness before us right now defend this testimony.
20 MR. TRAFICONTE: So it's as if -- opposed to 21 seeing this as an attachment they want to treat this >
22 Attachment.E as an additional portion of their direct 23 testimony.
24 JUDGE SMITH: Whatever.
25 MR. TRAFICONTE: Well, we would object on these Heritage Reporting Corporation s ._ (202) 628-4888
REBUTTAL PANEL NO. 19 - CROSS 27917
'l grounds: I don't believe that was ever filed'on April 18th k,) 2 when they filed their direct case in this matter. They 3 filed Applicants' 18; they then never offered it. I 4 They have subsequently in June 27 taken a piece of 5 18 and put'it on as attachment.
6 JUDGE SMITH: For the first time. .
7 MR. TRAFICONTE: For the first time and now they 8 want to define that as direct testimony sponsored by the 9 panel; they can't do that.
- 10. MR. TROUT: Why not?
11 MR. TRAFICONTE: Well, it's late.
12 MR. DIGNAN: Oh,'ch --
13 MR..TRAFICONTE: To use a phrase of yours, they're 14
, late.
15 JUDGE SMITH: Wait a minute.
16 Let's unravel a couple of things. Number one, 17 you're not on the record.
18 Mr. Trout, did I hear you get into this?
19 MR. TROUT: Sorry, Your Honor.
20 JUDGE SMITH: No, that's fine. We need all the 21 help we can get here.
22 (Laughter) 23 JUDGE SMITH: Mr. Traficonte has a litigative 24 advantage over you, he got here early, he got a seat at 25 counsel table.
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9 REBUTTAL PANEL NO. 19 - CROSS 27918 1 (Laughter) 2 '
MR. SMITH: It isn't fair, Your Honor, they've got 3 four seats and we've got a mere two.
4 MR. TRAFICONTE: Well, you have the Staff on your 5 side.
6 (Laughter.)
7 JUDGE SMITH: Let's take'it one at a time.
8 HR. TRAFICONTE: Yes.
9 JUDGE SMITH: The first objection, do you withdraw 10 the first objection in favor of the second objection, 11 timeliness? Or are you going to persist in the first 12 objection, we'll rule on that and then move to the second 13 objection.
14 MR. TRAFICONTE: We're going to persist in both 15 objections.
16 JUDGE SMITH: All right.
17 Number one?
18 MR. TRAFICONTE: Objection number one is --
19 JUDGE SMITH: Is it the testimony or is it 20 sponsored by a witness present that can be cross-examined; 21 that's number one.
22 MR. TRAFICONTE: And the answer to that appear to 23 be, as I understood how it developed, that this panel would 24 then or Mr. Callendrello of this panel would sponsor this 25 testimony as his own.
Heritage Reporting Corporation m .. (202) 628-4888
- l. REBUTTAL PANEL NO. 19 - CROSS 27919 l JUDGE' SMITH: Right.
2~ MR. TRAFICONTE:- And.then I said in effect,Lthat
'3- would move this from the attachment status into a portion-of 4 the direct testimony.
5- c JUDGE SMITH: And I say it.doesn't matter.
6 MR. TRAFICONTE: And then I said, if that's how -- .
U 7 you have'to understand the history of this thing. We had 8 another attorney, myself in fact,-who-was prepared to cross-9 examine Applicants' Panel No. 18. They. chose for the'ir own 10 strategic reasons at the time to not offer that Panel 18 11 into evidence.
12- JUDGE SMITH: Right.
13 MR. TRAFICONTE: Even though they had' filed it-on ,.
14 April the 18th.
\- 15 Now, we've come to the EBS panel-and they decide
'16 to take a portion of 18 which -- they did this not on April 17 18th obviously.
18 JUDGE SMITH: Right.
19 MR. TRAFICONTE: In fact, I believe they did this 20 -- when did we first receiva this most recent version of 21 Panel 19? I believe they just did this two days ago.
22 JUDGE SMITH: Two days.
23 MR. TRAFICONTE: In addition, if you turn to page {
24 51 of this newly fashioned Panel 19 testimony. If you turn i 25 to page 51 they have struck over sections and added, I take Heritage Reporting Corporation
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REBUTTAL PANEL NO. 19 - CROSS 27920 1 it. In fact, you can see quite clearly on page 51 what they 2 have done.
3 In the paragraph that begins on that page, the 4 first paragraph: "The issues raised in this contention basis 5 regarding the conflicting school messages in Massachusetts I
6 are addressed in," and I believe what has always been there 7 before is MAG EX-9, Basis B and Applicants' Rebuttal 8 Testimony No. 18. They struck that over and they now 9 substitute Attachment E.
10 That's an action that they have taken after April 11 the 18th, after their direct case has been filed.
12 So if they want to construe the attachment as a 13 part of their, not direct, but their direct rebuttal case; 14 then that portion is late filing.
15 JUDGE SMITH: All right.
16 It's just that I would like to -- you're 17 persisting in both.
18 MR. TRAFICONTE: Because the first may prompt a 19 response by them, i.e., that it's Mr. Ca11endre11o's 20 testimony and he is here to be crossed. And we would come 21 back and say, well, if that's the case then it's late 22 testimony proffered by Mr. Callendrello well after April 23 18th. ,
24 JUDGE SMITH: But are you persisting on -- this is 25 one of those things where you want two rulings. You want it i
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REIUTTAL PANEL.NO. 19 - CROSS 27921 ]
1
. - 1 out on two bases: lateness and it's not sponsored by a j
,! ~\ : i 5
s ,J. 2 witness appropriately.
3 MR. TRAFICONTE: Yes.
4 JUDGE SMITH: I'm just saying, do you persist in 5 the first after'the explanation?
6 MR. TRAFICONTE: Yes. .
7 JUDGE SMITH: Why?
8 MR. TRAFICONTE: Do I persist -- I see.
I 9 JUDGE SMITH: There is a witness here who is 10 prepared to defend this.
l' 11- MR. TRAFICONTE: I understand.
L 12 JUDGE SMITH: And the difference between an 13 attachment and testimony, I don't understand.
14 MR. TRAFICONTE: I understand. -
s_/
/ 15 I will not persist in the first objection on those 16 grounds that it's now characterized as this panel's direct 17 testimony.
18 It just so happene, it finds itself as an 19 attachment, but it is, in their view now, part of the direct 20 testimony.
21 JUDGE SMITH: It doesn't matter.
22 MR. TRAFICONTE: So I will subside on the first 23 objection.
24 And then move to the second objection which is 25 now, it's late filed direct testimony.
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REBUTTAL PANEL NO. 19'- CROSS 27922 1 JUDGE SMITH: All right.
2 MR. SMITH: I would respond to that, Your Honor, 3 in that both -- the schools piece No. 18 and EBS piece No.
t 4 19 were both filed on the 18th of April. Therefore, at that 5 point Mass AG had ample notice that this testimony would be 6 sponsored.
7 Number two, this testimony was also No. 18 and was 8 referenced in our No. 19. So the person cross-examining No.
9 19 should have been aware that issues raised in No. 18 may 10 be issues that could be raised in No. 19.
11 JUDGE SMITH: What was the date that 18 was 12 withdrawn?
13 MR. DIGNAN: Sometime ago, Your Honor.
14 JUDGE SMITH: Long time. ,
N 15 MR. DIGNAN: Mr. Traficonte's characterization, I 16 believe, is totally fair.
17 JUDGE SMITH: Okay.
18 MR. DIGNAN: It was withdrawn and it was just 19 added. And if the Board's ruling isn't too late I certainly 20 would like to leave it in view of the lateness rule this 21 morning.
22 JUDGE SMITH: I don't understand that.
23 MR. DIGNAN: The Board has said --
24 JUDGE SMITH: Well, wait a minute, you're not on 25 the record.
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ie REBUTTAL PANEL NO. 19 - CROSS 27923
.. . 1 MR. DIGNAN: The Board has said that:it has no r~'s l( ,)
2 real standards to govern lateness by, and on that basis --
3 JUDGE SMITH: . We didn't say that.
4 MR. DIGNAN: . All right.
5 Then if you didn't say,.then I shouldn't have said 5 you said that. .
7 The point being simply that, I'm about tofeross-8 examine Dr. High and I. guess.I get the same ruling, if we 9 pressed it,.on Dr. Renn on late filing. If he presses it 10 and you agree with it, then I guess we should leave it 11 whether this stuff that came in the past few days is also 12 late filing.
13 MR. TRAFICONTE: Apples and apples'and cranges and
,e g 14 oranges. This is rebuttal testimony, that's how we have k,m 15 offered the Renn piece. The High piece we didn't 16 ' characterize as rebuttal. But.the Adler and Renn pieces are 17 rebuttal.
10 MR. DIGNAN: The High piece is,* exactly should 19 have been filed before.
20 MR. TRAFICONTE: It was. And then there was an 21 objection and it was sustained.
22 MR. DIGNAN: ,
And it was sustained.
i
-23 MR. TRAFICONTE: And we revised it. I 24 The point is, it came in the context of rebuttal.
25 There is nothing rebuttal about this 18. This is, quite l
(/
sh Heritage Reporting Corporation (202) 628-4888 l
l t
1 I
i REBUTTAL PANEL NO. 19 - CROSS 27924 l 1 frankly, kind of open trick. They have taken a piece of 2 testimony, they have made the decision that they didn't need 3 to put the Panel on, 18. i l
4 They have revisited a portion of what they had to !
5 say in 18 and they decided that they better have a pisce of
- 1 6 the testimony dealing with the school message back in the ]
7 case, in the record; and they stuck it in as an attachment 8 to 19, 9 And they have one consistent witness who will 10 adopt it as his own. But in effect, it is simply late 11 filed, nonrebuttal late filed direct rebuttal testimony by 12 the Applicants.
13 JUDGE COLE: But it was referenced in the early 14 filing of Applicants' Rebuttal No. 19.
15 MR. TRAFICONTE: Yes.
16 That's to say the early filing of 19 referenced i
j 17 18.
18 JUDGE COLE: Yes.
19 MR. TRAFICONTE: And then they withdrew or at 20 1eart they didn't proffer Panel 18. And, in fact, Your 21 Honor, I think it's clear they have now in their revised 22 version of 1,9 struck the references to 18.
23 JUDGE SMITH: Yes. !
24 MR. TRAFICONTE: And substituted Attachment E.
25 MR. DIGNAN: Mr. Traficonte, I have told you, you i
, Heritage Reporting Corporation l (202) 628-4888
REBUTTAL PANEL NO. 19 - CROSS 27925 1 have fairly characterized the situation. You're' arguing
'l
'Q 2 something you don't have to. You'have. absolutely fairly 3 characterized the situation. The old reference was to 18 4 and we did decide for various reasons to put it in as an 5 attachment here. And the issue is whether it's late filing.
6 JUDGE SMITH: Yes, it's late. ,
7 The problem that you present, Mr. Dignan, how do 8 we reconcile that ruling with Mr. High's ruling.
9 MR. DIGNAN: If this goes, High goes right behind 10 it out the door.
11 JUDGE SMITH: Then what are we vorried about? You 12 have decided.
13 (Laughter) fg 14 15 16 17 18 19 20 21 22 23 24 f
25 l
[n c
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1 REBUTTAL PANEL NO. 19 - CROSS 27926
]
1 MR. DIGNAN: I'll take that* ruling.
2 ' And Renn, the whole crew -- out the door.
3 MR. TRAFICONTE: Not only would you take it, but I 4 think_His Honor thinks you made it.
5 MR. DIGNAN: No.
6 (Laughter) 7 MR. DIGNAN: I'm just saying that you said what's .
8 late. This is later -- indeed, I think it's a little 9 earlier than High.
10 JUDGE SMITH: High's we viewed as a rather novel l 11 situation, that we recognize that it was being argued that l
12 once having lost on the Luloff approach and they were 1
( 13 conforming what they argued was their testimony to the 14 Boards' ruling, we simply didn't know how to handle it. ,
1 15 We didn't know if there was unfair notice to the 16 Applicants with respect to that when given they had other 17 parts of their calculation that you did have fair notice.
I 18 In other words, Mr. Dignan, it created a 19 complexity that we didn't know how to handle.
20 MR. DIGNAN: All right.
21 JUDGE SMITH: We just didn't know how to handle 22 it.
23 But it wasn't based upon lateness, because you .
i I
24 always had all the information absolutely. And not only 25 that, but you brought, yourself, all the way into the 4
f l ,
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REBUTTAL PANEL NO. 19 - CROSS 27927 1 hearing, the town-clerk-approach to counting people.
2 MR. DIGNAN: Then they've had just the same 3 information. This piece was sitting there as Applicants' 18 4 for some time. I don't know the exact date it was 5 withdrawn.
6 JUDGE SMITH: Now you would be on better ground if .l 7 Attachment E had been taken from their testimony and put 8 into yours. But, see, that situation was High.
9 MR. DIGNAN: No, it's from ours.
10 JUDGE SMITH: Yes, right.
11 MR. DIGNAN: No question about it.
12 JUDGE SMITH: See, the situation of High is he was 13 saying, okay, you want town clerk data. That's what you
, 14 got, that what you presented. And the Board says that's 15 fine. I'll take that and still make my preexisting point.
16 So we didn't view it as lateness and we didn't 17 know -- I didn't know what it is. It's not in my evidence 18 book back there, believe me.
19 This is your own data that you are offering for 20 yourself as your case in chief, as affirmative evidence to 21 support your rebuttal. That puts it, I believe, in an 22 entirely different es.tegory.
23 MR. DIGNAN: Well, it also is App 2.icanta.' So I 24 would remind the Board of this.
25 Let's assume the Board strikes it and assume, Heritage Reporting Corporation s_ (202) 628-4888
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REBUTTAL PANEL NO. 19 - CROSS 27928 l
1 which I'm not sure at all is the case, but let's assume that 2 that creates a gap in the record. In other words, that is 3 to say, that either yourselves or the Appeal Board rule that 4 without this evidence they can't decide the case.
5 All it gets is a remand, and we come back down j l
6 here and -- .
7 JUDGE SMITH: Do you want to look at it on that 8 basis?
9 If we rule that it is late, do you want to move 10 the Board to accept it notwithstanding lateness?
11 MR. DIGNAN: Well, I will so move --
12 JUDGE SMITH: All right.
13 MR. DIGNAN: -- that you accept it notwithstanding 14 lateness. I don't think that there has been unfair notice.
15 They knew it was around, and there's no problem.
16 I'll be glad to make that notice.
17 JUDGE SMITH: The notice, the way this case goes, 18 you know, we note on the record that we observed that the 19 parties and the Board was becoming very burdened. And; for 20 example, we relieved the parties of filing cross-examination I 21 plans.
22 They had every right to drop Rebuttal Testimony 18 23 from their agenda of concerns --
24 MR. DIGNAN: I agree they did.
25 JUDGE SMITH: -- some weeks ago.
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l REBUTTAL PANEL NO. 19 - CROSS 27929
. 1 MR. DIGNAN: I agree they did. 1
/ " I i l 2 JUDGE SMITH: And now it is two days -- two days R
.\
3 ago, it's back in.
4 MR. DIGNAN: Right.
5 JUDGE SMITH: And it may be that they had notice, j 6 but that notice is of little practical value to them in the' .
I
- 7. context of the litigation we are facing toc'.ay.
8 Now, if you believe that it's 7.n essential part of 9 your case, then that's your call. But we have to give them 10 an opportunity to timely address it.
11 MR. DIGNAN: Well, are they saying they can't 12 cross-examine it today?
13 Are they saying that with a straight face? l I
js 14 JUDGE SMITH: I don't know. I don't know.
\s / 15 But I'll tell you, if we were applying the 16 standards that you are asking the Board to apply across the 17 board. accepting identical arguments from that side of the 18 room about, well, you know, it may be late, but it la an 19 important part of our, and ossential part of our case --
i 20 MR. DIGMAN: Well, Your Honor, they have won -
21 everyone of those.
22 JUDGE SMITH: What?
23 MR. DIGNAN: They have won all of those this 24 morning, at least got decided. l 25' JUDGE SMITH: You two are counting?
3 1 l 7
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REBUTTAL PANEL NO.'19 - CROSS 27930 ,
1 Who is counting, Mr. Dignan?
2 MR. DIGNAN: I always count, Your Honor. You 3 can't help it.
1 4 (Laughter) 5 MR. DIGNAN: All the thing a trial lawyer has when 6 he hangs up his spikes is a won / loss record. We've got to 7 keep track of it.
8 JUDGE SMITH: The only thing that that tells me is 9 that you are losing a lot. I don't know. You better just 10 really worry about that. ;
11 You're still a young man, Mr. Dignan.
12 (Laughter) 13 MR. TURK: Your Honor.
14 MR. DIGNAN: Certainly lost my share, j 15 Your Honor, look, this is clearly, as I said 16 earlier, Mr. Traficonte has fairly exactly che.racterized j 17 what took place. It is quintessentially a matter of Board 18 discretion, in my opinion.
19 The only thing I would add to that as a practical 20 matter the Board should consider.
21 As Judge Bloch taid in the hearing, there is one i'
i 22 unfair advantage an Applicant has. And that is, you can't 23 shoot him dead until he says he's dead.
l 24 So that if he's right that this is -- whic'n is ;
25 what I think he's hoping is that there is some essential Heritage Reporting Corporation x,- (202) 628-4888
REBUTTAL PANEL NO. 19 - CROSS 27931 1 matter that I can't cover some ot'.ser way in the record, and O ,
.I ,) _
2 he persuades either you or the Appeal Board that without 3 this piece of testimony the license can't issue,'the remedy, 4 as it always is, is going to be we're all back here to 5 cross-examine these four pages later. !
~
6 JUDGE SMITH: I agree with you entirely. .
7 It is your call. If you want that in evidence, 8 you have a right. But with that necessarily goes the right 9 to confront this evidence and with timely notice. And it's 10 part and parcel of it. j 11 MR. DIGNAN: I want it in unless they are going to {
l 12 sit here with straight face and say they have got to go over id until July.
14 Is that the position they want to take?
- f-s i
\s / 15 MR. TRAFICONTE: I haven't taken any position.
16 MR. DIGNAN: That's what I thought.
17 MR. TRAFICONTE! I was opposing the admission of 18 the Attachment E.
19 MR. DIGNAN: Well, it's already been admitted.
20 You should have made that objection before the ruling )
21 admitting the testimony took place.
22 I mean there.is that little technical problem that 23 your motion -- ;
i 24 MS. TALBOT: Your Honor, I would move to 25 reconsider that ruling in light of the fact that --
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REBUTTAL PANEL NO. 19 - CROSS 27932
[ 1 MR. DIGNAN: You didn't even object to it.
2 JUDGE McCOLLOM: No.
3 She made a motion to strike that just before we 4 got into it.
~
5 JUDGE SMITH: She made a motion at the outset.
6 MR. DIGNAN: No, no.
7 I'm talking when it was originally admitted.
8 There was no objection made to it, as I understand, and it 9 was in. l i
10 So the objection at this point is late to start 11 with, but I'm not going hang on that.
t 12 I'm just saying if he really thinks that he's 13 going to ask you for five days to get ready to cross- )
i 14 examine these two pages, then I may have to rethink it. But l 15 at this time I do move it.to be in.
16 MR. TRAFICONTE: I can cross-examine it, Your 17 Honor, if the Mass AG is permitted to change lawyers ;
18 midstream on this Panel.
i 19 JJDGE SMITH: Oh, have we --
20 (Laughter) 21 MR. DIGNAN: Oh, gee, since when was that a 1
22 problem? .
23 ' JUDGE SMITH: Yes, that's been honored in the --
l 24 (Laughter) 25 JUDGE SMITH: So I think, in essence, Mr.
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REBUTTAL PANEL NO. 19'- CROSS 27933 1 Traficonte, with.that understanding you've resofved the-fO 2 dispute. s 3 MR. TRAFICONTE: I'm not going to withdraw my 4 objection.
5 I think you should go ahead and let it in.if'you 6 want to and grant his motion that, in the absence of having- .:
7 it in there, that --
8 MR. DIGNAN: Well, if we're going to get super-9 technical, all right..
10- My answer to the motion at this time is the
- 11: objection'should have been made at the time the testimony 12 was admitted and it's too late.
13 JUDGE SMITH: Wait. I think we've got it now.
14 MR. DIGNAN: I mean if I've got to --
\/ 15 JUDGE SMITH: Overruled.
16 - Now where e.re you?
17 HR. DIGNAN: All right.
18 Well, then, overrule him and'we'll go forward like 19 I thought we were going.
20- JUDGE SMITH: Now here is where we are.
i 21 Now you have got to make your call, vou've got to l l
22 make your call. j 23 MR..DIGNAN: I want it in.
24 JUDGE SMITH: You want it in.
25 MR. DIGNAN: Yes, Your Honor, i
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s REBUTTAL PANEL NO. 19 - CROSS 27934
~
1 JUDGE SMITH: All right.
2 ' Mr. Traficonte has solved your problem.
l 3 MR. DIGNAN: That's what I thought, too. l 4 JUDGE SMITH: Yes, right.
5 And he's prepared to cross-examine on it, if he i 6 can do it. i 7 And you don't oppose that. ;
8 MR. DIGNAN: No.
9 JUDGE SMITH: So there is nothing before us.
10 MR. DIGNAN: That's right.
11 JUDGE SMITH: So we are going to receive it and 12 allow you to cross-examine and we will give you until after l
l 13 lunch, if you wish, whatever you wish.
14 MR. TRAFICONTE: Yes.
15 JUDGE SMITH: So that's the ruling.
16 Okay, everybody happy?
f 17 Don't worry i 18 (Laughter) 19 MR. DIGNAN: I just keep track of one loss, not
)
20 happily.
21 M3. TALBOT: I have no further questions, Your 22 Honor.
23 JUDGE SMITH: Shall we break for lunch then and i
24 return and let Mr. Traficonte examine on this?
l 25 MR. DIGNAN: Yes.
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_ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . . . _ ._ f
REBUTTAL PANEL NO. 19 - CROSS 27935 1 N3. TALBOT: That's a good idea.
2 (Whereupon, at 12:30 p.m., the hearing was 3 recessed, to resume at 1:30 p.m., this same day, 4 Wednesday, June 28, 1989.)
5 6 .
7 8
9 10 11 12 13 14 15 1
16 l 1
17 ]
18 19 20 21 22 23 24 .
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REBUTTAL PANEL NO. 19 - CROSS 27936 1 AEIEBHQQH aEaaIQH i 2 (1:34 p.m.)
i 3 JUDGE SMITH: On the record.
4 MR. TRAFICONTE: Okay.
5 JUDGE SMITH: Yes.
6 MR. TRAFICONTE: Thank you.
7 Whereupon,.
8 ANTHONY M. CALLENDRELLO 9 DENNIS S. MILETI 10 GARY CATAPANO 11 having been previously duly sworn, resumed the witness stand 12 herein, and were examined and further testified as follows:
13 CROSS-EXAMINATION 14 BY MR. TRAFICONTE:
15 Q Dr. Mileti, this Attachment E, this is your ;
16 testimony as well; is it not? ,
h 17 A (Mileti) No, it's not. <
18 Q Are you going to adopt it or are you not going to j 19 adopt it as your testimony? j 20 A (Mileti) I' m not . l i
21 Q Are you not adopting it because you reviewed it I 22 and you disagree with what it says? )
23 A (Mileti) Well, I can't say that I reviewed it in 24 detail; I read it. To be honest with you, I read it for the j l
25 first time this morning and my judgments are, as I said they l Heritage Reporting Corporation (202) 628-4888
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l RE1UTTAL' PANEL NO. 19,- CROSS 27937 1
-- .1 were earlier this morning,'not what this says.
j(~h 2 .Q Your judgments as to the adequacy of certain 3 messages? Let me withdraw that.
I 4 When you say, your judgment is as it was this i
5 morning, the judgment-regarding the adequacy of certain j 6 messages? .{
7 A (Mileti) No,.what I thought some parents would R 8 have done in response to hearing EBS message No. 3, up until j the time EBS message No. 5 was issued one and three quarter i 9
10 hour later.
11 Q So to the extent that Attachment E'makes certain I 1:2 statements about what parents would or would not do in light, 1 1
\
l 13 lof the'information available to them at the time, you 14 disagree with what's set forth in Attachment E?
15 A (Mileti) Well, that's a pretty broad statement.
)
16 Q Well, the beginning of the statement was a :
1 17 limitation.
18 To the extant that Attachment E makes certain ;
19 statements about what parants would or would not do in light 20 of the public information available to them, you disagree ;
21 with that testimony?
22 MR. SMITH: I think what Dr. Mileti is saying here 23 is that, he has already expressed an opinion based on the 24 questions from Ms. Talbot. ,
25 , He is saying that he has not specifically looked
( .
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l 1 at the testimony and the exact wording in there in detail to 2 make that determination. l 3 So I think what he's saying is, he wants to stand 4 on the testimony with regard to those messages that Ms.
5 Talbot asked this morning.
6 BY MR. TRAFICONTE:
7 Q Mr. Catapano, this Attachment E, is this your 8 testimony?
9 A (Catapano) I've reviewed the testimony and I 10 adopt it. However, I'm not a subject matter expert on this 11 particular area, so I don't know what weight I can lend to l 12 that.
13 Q That was going to be my next question.
14 You' re going to disqualify yourself then as having 15 -- the Board should disregard it essentially and give no l 16 weight to this testimony to the extent that you're adopting 17 it?
18 Is that an affirmative; yes?
19 A (Catapano) That's affirmative.
20 Q Mr. Callendrello, this may make it all very 21 simpler if you don't adopt it we can go home. j l
22 (Laughter.) l 23 Are you going to adopt the testiraony?
24 MR. SMITH: Is that a promise?
25 MR. TRAFICONTE: Is that a promise?
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I REBUTTAL PANELz NO. 19 - CROSS 27939 1 Yes. Sure, of course it is.
2 (Laughter) l 3 BY MR. TRAFICONTE:
4- Q Are you going ,to adopt the testimony that appears 5 .here as Attachment E?
-6 A- (Callendrello) Yes. This was originally part of .
7 Applicants'. Rebuttal Testimony No. 18 which I was also a 8 sponsor of and so contains --'and incorporated my testimony 9 and still does. ,
l 10 -Q This morning in answering questions put to you.or 1 11 the panel, but you particularly, Mr. Callendrello, in answer 12 to. questions put'to you by Ms. Talbot you deferred.in 13 various questions to Dr. Mileti's expertise as to how people 14 would respond and how messages would be interpreted by the
- ( 15 pt blic.
16 I understood that to be.in a sense recognition by 17 you that Dr.-Mileti has -- of the members of this panel --
'16 has the expertise in that regard.
19 To the extent that this Attachment E touches on 20 those subjects, do you now assert some expertise in those 21 areas?
4 22 A (Callendrello), No, I'm not an experb in human 23 behavior, j 24 Q Are you an expert in how to interpret and judge 25 the adequacy of EBS messages?
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1 A (Callendrello),
To the extent that I have worked 2 with Dr. Mileti over the past six years I understand the 3 concepts of effective warning messages. I have reviewed Dr.
4 Mileti's concep.ts first raised in the Shoreham -- in the )
i 5 creation of the Shoreham EBS messages; and then in )
~
6 subsequent messages in which I have worked with Dr. Mileti. .
l 7 So I feel I have an understanding of what the 8 concepts are of effective warning messages; yes.
9 Q That's fine.
10 MR. SMITH: I think a distinction here has got to j 11 be made between the content of the messages which Dr. Mileti i
12 testified to this morning as opposed to the testimony in r
13 Attachment E which as I read it, goes through an explanation l 14 of the various events that occurred which is what Mr.
15 Callendrello is testifying to.
16 MR. TRAFICONTE: Mr. Smith, do you have that i 17 Attachment E in front of you?
18 MR. SMITH: Yes, I do.
19 JUDGE SMITH: I can see at least one --
I would like you -- I 20 MR. TRAFICONTE:
21 JUDGE SMITH: Oh, I'm sorry.
f 1
22 MR. T,RAFICONTE: I'm sorry.
23 Go ahead.
24 JUDGE SMITH: No.
25 MR. TRAFICONTE: Well, look on page 15 the very ,
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,. 1- first page, the second full paragraph, the last sentence:
- r i ) 2 "While it is acknowledged that there is some lack of V
3 precision in the quoted language of the EBS message, the 4 information was adequate to inform parents that the students 5 were being protected," et cetera, et cetera.
6 .We can go through it, and there are series of .
7 sentences like this that are judgments on the quality of the 8 information made available to parents and statements about 9 what parents would do in light of the information available 10 to them.
11 Now, those statements are in the testimony.
12 There's no question that there's certain places, a rather 13 ministerial explanation of how certain things occurred which 14 cribs on, for the most part, what the exercise report says.
7-t 15 If the testimony is going to be limited to that 16 aspect, we can make short shrift of this cross. If it's 17 going to be -- if the testimony is offered for the 18 substantive judgments about the quality of the public i
19 information I think my cross is well within those 20 parameters.
21 MR. SMITH: Could I have one moment to consult.
22 (Counsel confers.)
23 MR. SMITH: I'll subside.
24 BY MR. TRAFICONTE:
25 Q Mr. Callendrello, I don't want to put words in n
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REBUTTAL PANEL NO. 19 - CROSS 27942 l 1 your mouth, but do you think it's a fair' statement that your 2 expertise to the extent that you're here testifying as to i 3 the statements in Attachment E, your expertise is almost 4 entirely based on information and knowledge you have gleaned 5 from your contact with Dr. Mileti, is it not?
6 JUDGE SMITH: With respect to the --
7 BY MR. TRAFICONTE:
8 Q With respect to the matters discussed in 9 Attachment E?
10 A (Callendrello) The expertise?
11 If you're addressing human behavior aspects of 12 this testimony, yes, my expertise is that which I have l l- 13 gathered from working with Dr. Mileti.
14 Q Well, beyond just human behavior narrowly or 15 broadly understood, your knowledge-base as to the quality of 16 an EBS message -- what an EBS message should or should not 17 contain matters in that regard.
18 To the extent that you're here representing I
! 19 yourself as an expert you have gained that knowledge from f
l 20 your contact with Dr. Mileti over the period of several i
21 years; correct?
22 A (Callendrello) No, I don't know if I'm 23 representing myself as an expert.
1 24 Q Well, that's fine.
25 If you want 'to disqualify yourself as an expert in l
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.' 1- those matters,'that's fine. l r\ ~
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2 I had understood'that you'were here advocating-3 .this testimony or adopting this testimony.and representing j 4 that you have some knowledge in these matters, and,ILjust 1 5 want to make sure that that knowledge is, for the most part, 6 based on things you have learned from Dr. Mileti over the' .
7 years?
8 MR. . LEMALD: - Is the question: entirely or in part 9' or what?
10 ' JUDGE' SMITH: .-I,think you should be.more precise 11 here.
12 You're talking about the quality of the message 13 and its capability to accurately inform the parents. That's j . 14 all you're talking about in the- context of this question.
15 .'Many of this is simply.an analysis of the events 16 and the significance of the timing and of the undisputed 17 aspects of the messages.
18 MR. TRAFICONTE: Yes.
19 To the extent that Attachment E -- and that 20 distinction I was hoping to make clear, I thought I made i 21 clear -- to the extent that Attachment E sets forth matters 22 of fact concerning what messages said.and did not say. And' 23 matters of fact about when events occur, I wouldn't cross-24 examine him.
25 JUDGE SMITH: And more than that; and the Heritage Reporting Corporation 3 (202) 628-4888 l
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REBUTTAL PANEL NO. 19 - CROSS 27944 1 reasoning and the consequence of a sequenco, too, he's fully 2 competent. It's that narrow issue of what the parents learn 3 from the messages that you're challenging him on.
4 MR. TRAFICONTE: And what do they do in light --
5 JUDGE SMITH: And what they do when they learn f I
6 them.
7 MR. TRAFICONTE: And the judgments that are 8 contained in the testimony as to the quality of the 9 information made available to the parents.
10 JUDGE SMITH: The accuracy.
11 MR. TRAFICONTE: Quality including the accuracy, 12 the timeliness, the consistency.
13 Those matters that, in my opinion from a legal 14 perspective, address the issues in contention.
15 JUDGE SMITH: I don't think they are being precise 16 enough.
i 17 MR. TRAFICONTE: All right.
18 Maybe I should walk through the testimony with the 19 panel.
20 JUDGE SMITH: I don't know how you can avoid it.
21 Dut it seems to me I can pick out without too much 22 difficulty the parts that should not be disputed and those 4 23 which you might legitimately -- l 24 MR. TRAFICONTE: Well, let's do that, so we're 25 precise, i
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.,A 1. BY MR. TRAFICONTE:
- ) } '
(7 2 Q. - Take it'on page 15, Mr. Callendrello, do you see 3~ the.second fu11' paragraph on that page?
4 .A . (Callendrello) ' Yes, I do.
5 Q The last sentence of that paragraph?'
6 Do you see that: "While it i,a acknowledged?" .
7 A (Callendrello) Yes.
8 Q Now, that's1your testimony now; correct?-
9 A (Callendrello) Yes,.it is.
10 Q And the informational base that you have to make 11 that representation is, for the most part, something that 12 you have gleaned through.your contacts with Dr. Mileti; 13 correct?
7 14 :A -(Callendrello) And my own assessment of the s_ 15 message and the level of inconsistency in that message.
16 Q So' you are making that independent judgment auxi 17 you're representing that you have. expertise in that area to 18 make such a judgment? -
19 A (Callendrello) I'm representing that I have 20 expertise and whether something is inconsistent or not.
21 Q Now, on the next page at the top in the last 22 sentence of that carryover paragraph.
23 Do you see the last clause'that says: "The 24 information proceeded through the organization and correct 25 information was issued in a subsequent EBS message." ,
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REGUTTAL PANEL No. 19 - CROSS 27946 1 Do you see that?
2 A (Callendrello) Yes, I do.
3 Q And that judgment that the information that was 4 broadcast in a subsequent EBS message -- the judgment that 5 that was correct, that's your judgment then?
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6 A (Callendrello) In that case that is reliance on 7 the exercise report.
8 So in essence, it's FEMA's or their evaluator's 9 judgment. I 10 Q But you're repeating?
11 A (Callendrello) Correct.
12 Q Now, at the same page 16, skipping the next 13 paragraph and going to the last one that begins there:
14 "These discrepancies in the EBS messages and news releases 15 would not have caused adverse effects on the health and 16 safety of the students in EPZ schools."
17 That's testimony that you're adopting based on 18 your expertise in those matters?
19 A (Ca11endre11o) It's based on a logical extension 20 of the possible consequences of various actions in response 21 to the EBS messages.
22 Q Doesn't that include or haven't you drawn some 23 inferences here regarding human behavior?
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gj. 1 together.with-the:one that begins on 16 and carries over'to Il 2 17 . ,
j l
3 That's m. statement -- that's a paragraph that runs: 1 l
4- to human _ behavior in response to the public information made
~
.5 available to the public;'is it not? !
6- A (callendrello) Well,;the one sentence that says: .i 7 " Parents would have proceeded to the school' host facility to 8- wait the arrival.of their children," would have been an 91 outcome of. compliance with the EBS' message.
10 Q Yes.-
11 Doesn't that fact include some judgment as to the 12 effectiveness of the EBS message?
13 A '(Callendrello) Yes, it does.
14 Q And to the extent that you're able to make cuch a Q 15 judgment.that the EBS message was good enough to-have this 16 impact on human. behavior, you' re able to make ~that judgment 17 based on your contacts with Dr. Mileti and what you have 18 learned-from him; correct? I 19 You don't have an independent knowledge-base or 20 experiential-base other than what you've learned from Dr.
21 Mileti in this regard, do you?
22 A (Callendrello) .No, I don't have any independent 23 knowledge-base.
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_ 1 move that since Mr. Catapano has indicated that he doesn't 2 have any experiential-base, and Mr. Callendrello has 3 indicated that he's relying for these statements on things 4 he has learned from Dr. H11eti, and Dr. Mileti has not 5 adopted this testimony, I would move to have the paragraph 6 that begins: "These discrepancies" and carries over and ends 7 with "have evacuate," I move to have that paragraph stricken 8 of having no fundamental expert basis.
9 JUDGE SMITH: Do you oppose the motion?
10 Would you like to have him restate it?
11 MR. SMITH: No, that's fine.
12 MR. TURK: I oppose it, Your Honor.
13 I would like to speak after the Applicant.
14 MR. DIGNAN: I don't understand the motion.
15 There is no rule that says one expert can't rely 16 on knowledge gleaned from.another expert in making his 17 judgments. I never heard of such a rule.
18 All the witness said is that he is clearly an 19 expert in the general fiel~d of emergency planning; there is 20 no question about that. He says his expertise that he 21 professes to have with respect to this particular matter he 22 relies on what hg has been taught by Dr. Mileti; that's what 23 we brought out. What's wrong with that?
24 Would it be better if he was saying, Dr. X instead 25 of Dr. Mileti?
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REBUTTAL PANEL NO. 19 - CROSS 27949 1 JUDGE SMITH: No, he's inviting the Board, I
' /j:. \
i_j( 2 think, to read into Dr. Mileti's statements a disavowal of 3 the testimony; therefore, any reliance that Callendrello has 4 upon Mileti is cut short by Mileti's disavowal.
5 MR. DIGNAN: Well, I wasn't here when M11eti 6 disavowed, but I would have assumed what happened is Mileti .
7 said he didn't adopt it because he hadn't read it'and 8 written it.
9 MR. TRAFICONTE: No, he went further than.that.,
10 MR. DIGNAN: Well, why don't we find out.-
11 MR. TRAFICONTE: We did.
12 MR. DIGNAN: Let's ask if Dr. Mileti disagrees 13 with what's in the testimony. l f~ss 14 JUDGE SMITH: But even assuming that he did, you
\s- 15' got slightly a different factor. This is new.
16 Here is the expert imputing his expertise to 17 another witness. Now the other witness is now an expert.
18 And his expertise disagrees with his imputor's expertise.
19 That's precisely by rule 1203 imputed expertise 20 disagreeing with each other in Boston.
21 (Laughter) 22 MR. DIGNAN: I'm at a disadvantage for not having 23 been here when Dr. Mileti put this alleged disavow.
24 Did Dr. Mileti say he disagreed with the testimony 25 or did he say he couldn't adopt it?
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.: 1 JUDGE SMITH: I don't think that'was developed as l 2 well as'it could have been.
3 MR. DIGNAN: Yes.
4 Why don't we ask Dr. Mileti if he disagrees with 5 it. ;
6 MR. TRAFICONTE: We did.
7 I'll go over it again just for'your benefit.
8 l
9 10 11 12 13 14 15 16 17 la 19 20 21 22 23 {
I 24 1 i
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-REBUTTAL PANEL NO.' 19 - CROSS- 27951.
t 1. BY MR. TRAFICONTE:-
2 Q .Dr. Mileti, you have not adopted Attachment E as
~
.3 your testimony, correct?
ll A (Mileti) That is" correct.
5 'Q And as to the paragraph that we are now discussing 6 that begins on the bottom of 16 and carries over, have you ..
7 -had an opportunity to read that paragraph?
8 A (Mileti) Lyes.
.i 9 Q And can you tell us why you are not' adopting that 10 paragraph as your testimony?
11 A (Mileti) There is a part of it that I don't agree 12 with.
13 Q Can you indicate which part you don't agree with?
14 A (Mileti) Yes. -
\ 15 On page 17, the first full sentence.that begins 16 with the word " parents". " Parents would have proceeded to
~
17 the schoo1 host facility to await the arrival of their 18 children."
19 I think some parents would have done that. And as 20 I said this morning, I think some parents would have gone to 21 the school to get their children.
22 Q Dr. Mileti, let me turn you back to page 16 at the 23 bottom, the last sentence on that page, "In Newburyport and 24 Merrimac where the public was sheltering, students would ;
1 1 25 have arrived home to their sheltering parents." !
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1 Do you see that?
2 A (Mileti) Yes, I do.
3 Q Are you adopting that sentence?
4 A (Mileti) As I said when you first asked me 1 5 whether I adopted this --
6 Q Yes. .
7 A (Mileti) -- I said I had just seen this for the 8 first time this morning.
9 0 Yes.
l 10 A (Mileti) That's an example of something I've not 11 had a chance to explore. I don't understand the details and l i
12 don't recollect the details of the exercise enough right now 13 to be able to answer that question.
14 In other words, I need to know what was the 15 circumstance underlying that.
16 Q All right.
17 Then as to the second, the next page 17 at the 18 top, you don't agree with, " Parents would have proceeded to 1 19 the school host facility to await the arrival of their 20 children."
21 You disagree with that statement?
22 MR. TURK: He disagrees with it as a statement of 23 the entire population.
24 THE WITNESS: (Mileti) I'm sorry.
25 I don't understand the difference between that Heritage Reporting Corporation
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,_s 1 question and the one you first asked me.
I h
( / 2 BY MR. TRAFICONTE:
3 Q It was confirming that you don't adopt that 4 because you disagree with it.
1 5 A (Ndleti) Well, what I said was I would adopt it 1 6 if it had the word "some" in front of it. And I would also .
I 7 add the sentence, "Some parents would have gone to school to 8 get their children", as I said this morning.
9 Q Mr. Callendrello, are you prepared to change the 10 testimony to conform it to what Dr. Mileti is indicating he 11 would agree with?
12 A (Callendrello) I certainly would accept his 13 opinion. It carries more weight in my mind than mine on 14 human behavior, s- 15 JUEGE SMITH: Now that the matter has been brought 16 to your attention, do you believe that all parents would 17 have proceeded to the school host facility without fail, all 18 of them?
19 THE WITNESS: (Callendrello) No.
20 JUDGE SMITH: So, in essence, you agree with Dr.
21 Mileti on that point?
22 THE WITNESS: (Callendrello) Yes.
23 JUDGE SMITH: What's the other point?
24 MR. TRAFICONTE: We're going to have to come back 25 to the other point.
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REBUTTAL PANEL NO. 19 - CROSS 27954 !
1 BY MR. TRAFICONTE:
2 Q Mr. Callendrello, do you have some opinion as 3 to -- would this have been a large number of parents going 4 to the schools, or a small number of parents, or an 5 inconsequential number of parents who would have gone to the 6 schools?
7 What's your sense for that?
8 (Pause . )
9 A (Callendrello) I don't know.
10 I know, in general, that people will follow 11 official information that comes over EBS. There will be 12 behavior at both ends of the spectrum, both extremes of the 13 spectrum.
14 And that as Dr. Mileti has indicated, some parents 15 would report to the school no matter what kind of 16 information was given, and some parents would not report to 17 the school not matter what kind of information was given.
18 I can't put a percentage on -- I think that the 19 word "some" is appropriate. As worded, it probably implied 20 all. But "some" is more accurate.
21 Q All right, just so we can continue, Dr. Mileti, 22 why would parents have gone to the schools to pick up their 23 children?
24 Why would some of the parents have gone to schools ,
25 to pick up their children?
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REBUTTAL PANEL NO. 19 - CROSS 27955 1 A (Mileti) That's a broad question.
2 Q Well, in the context in which this sentence 3 appears in the testimony, some of the parents would have 4 proceeded to the school host facility to await the arrival 5 of their children.
6 A (Mileti) Yes. .
7 Q And now some of the parents would have gone to the 8 schools to pick up their children.
9 A (Mileti) Yes, I still believe that.
10 Q And why would they have done that in the context 11 of the events?
12 A (Mileti) Well, if you look at EBS message No.
13 3 --
14 Q Yes.
\w- 15 A (Mileti) -- where this began.
16 Q Yes. .
17 That's also attached, is it not, to the testimony 18 as the next exhibit, Exhibit G?
19 A (Callendrello) Attachment G.
20 Q Attachment G, yes.
21 MR. TURK: That's the one at 2:20 p.m.?
22 MR. TRAFICONTE: .I'm sorry, Mr. Turk?
23 MR. TURK: This the one that was released at 2:20 24 p.m.?
25 MR. TRAFICONTE: Yes.
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REBUTTAL PANEL NO. 19 - CROSS 27956 1 THE WITNESS: (Mileti) Yes, on 6-28-88.
2 On the first page there is a paragraph, the fifth 1
3 paragraph down, it says, "Immediate evacuation is 4 recommended for pe.ople in Salisbury and Amesbury." q 5 BY MR. TRAFICONTE:
l 6 Q Yes.
! 7 A (Mileti) On the next page, third paragraph down, !
8 the first sentence says, "All schools within the communities 9 directed to evacuate are being evacuated", et cetera.
10 Two pages later, on page 44, the second paragraph 11 says, " Parents with children attending school within i
12 Amesbury/ Salisbury", et cetera, "are advised that children 13 are currently being safely maintained at the school", so on 14 and so forth.
15 There is a conflict in terms of what this message l 16 says is being done with the. children who go to school in 17 Salisbury and Amesbury.
18 In one place it says they are being evacuated, and 19 in another place it says they are being maintained in the 20 school. All of this is going on when parents purportedly in 21 the EPZ, in Salisbury and Amesbury, are being asked to l 22 evacuate themselvgs.
23 Q A pretty clear contradiction in the message, is it l 24 not?
l 25 A (Mileti) Yes, I think that's why I am pointing it Heritage Reporting Corporation (202) 628-4888 I
' REBUTTAL PANEL NO..19 - CROSS 27957
. . - . . . l1 out.
3
[j S
'2 JUDGE SMITH: As a consequence of these 3 ' discrepancies, parents.can take a' limited number of actions, 4 -depending'upon how they understand it and which they heard.
5 List those limited number.of actions.
.6 -What are the different.. things they.could have .
7:
'done?
8 THE WITNESS: (Mileti) I'll list them in terms of
'9 what I think is the probability of their being engaged in.
10 JUDGE SMITH: No, not necessarily. You don't have 11 to give the probabilities.-
12 What are the possible, reasonably possible - you l 1
13 know, they wouldn't have gone to the. circus. They would
.;f-14 have gone to the host facility or something.
{
- 15 What are the possible actions?
16 THE WITNESS: (Mileti) One action is they would 17 have called the school to find out what was really going on 18 with their children.
19 JUDGE SMITH: Okay.
20 THE WITNESS: (Mileti) Another action is they 21 would have evacuated to the host facility to await the ,
22 arrival of the children.
23 JUDGE SMITH: All right.
24 THE WITNESS: (Mileti) Another action is they 25 would have gone to the school to pick up their children.
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REBUTTAL PANEL NO. 19 - CROSS 27958 1 And another action is they would have tried to get 2 additional information in other ways.
3 JUDGE SMITH: Mr. Traficonte, can you suggest any 4 other actions that they may have taken because of these 5 messages?
6 MR. TRAFICONTE: I have to confess to not being an 7 expert in human behavior, but the purpose'of the cross-8 examination --
9 JUDGE SMITH: Well, we are all people reasonably 10 articulate and aware of the meaning of the English language.
11 And what else could they have read from any of 12 these discrepancies?
l 13 MR. TRAFICONTE: Oh, I think the likely outcome, l 14 as a parent myself, if I heard this message, is I would have 15 gone to the schools and picked up my children. O. !
l 16 JUDGE McCOLLOM: Without telephoning? j 17 MR. TRAFICONTE: I would have tried to telephone.
18 And no doubt, because many other people would have had the 19 same response that I would have, I would not have been able 20 to get through.
21 I would have tried once, perhaps twice, slammed 22 the phone down, and gone to pick up my children, which of 23 course the EBS message in other locations and other 24 locations instructs me not to do, but I would have gone 25 ahead and done it.
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REBUTTAL PANEL NO. 19 - CROSS 27959 1 But just so everyone is clear, I don't think the -
( 2 - I mean I appreciate that the Board would like to get to 3 the bottom line as to what difference it all makes, but Dr.
4 Mileti is an expert in the impact of public information, the 5 EBS system generally, and the import'ance of consistent, 6 coherent messages to the overall believability and . __
7 credibility of the public.information system.
8 And his last point, which is that they would seek 9 out information from other sources, is as important to the 10 issues on the table, i.e., the effectiveness of the public 11 information, as the concrete actions that any given parent 12 would take.
13 I agree there is a limited universe of actions l
l i 14 that any given parent would take.
15 The contention is, however, that the public 16 information that was broadcast during the exercise had 17 enough holes in it and was inconsistent enough in important 18 particulars to impact on the quality of the overall public 19 information. I think that's exactly what Dr. Mileti's last 20 point runs to.
21 JUDGE SMITH: Well, then perhaps the problem is 22 that the paragraph that says the discrepancies would not 23 have caused adverse affects is irrelevant to your cross-24 examination and to the issue.
25 MR. TRAFICONTE: I'm sorry.
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REGUTTAL PANEL NO. 19 - CROSS 27960 1 What paragraph is that?
2 JUDGE SMITH: The discrepancies on the bottom of 3 page 16 that those discrepancies would not have caused 4 adverse affects is irrelevant to the issue.
5 MR. TRAFICONTE: On the health and safety of the 1 6 students -- ,
, 7 JUDGE SMITH: Right.
l 8 MR. TRAFICONTE: -- in EPZ school.
9 JUDGE SMITH': Right.
10 MR. TRAFICONTE: Well, there may be an indirect 11 link. I think it is relevant, because there is a link 12 between a quality public information system, Dr. Mileti can 13 say this much more gracefully and eloquently than I can.
14 There is a link between the quality of a public 15 information system for school children, for example, and !
i 16 their parents, and effect emergency response. And I would 17 like to put that question to Dr. Mileti, whether this 18 statement is something he would adopt or not.
19 Because I think ultimmtely it can have and would 20 have an impact on the health and safety of the school !
21 population if the pubito information vis-a-vis schools was 22 not coherent and consistent, and it resulted in a chaotic 23 response on the part of the parents.
l 24 JUDGE SMITH: If it fortuitously turns out that l
\
25 the discrepancies did not cause any adverse affects, if that l l
Heritage Reporting Corporation (202) 628-4888 9 ])
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REBUTTAL PANEL NO. 19 - CROSS 27961 1 is just'how it happens, it is really irrelevant to your sj -2 point.
1 f
3 In other instances, discrepancies may not have 4 such benign results.
5 MR. TRAFICONTE: Before I accede to that, --
6 JUDGE SMITH: All right, go ahead. .
7 MR. TRAFICONTE: -- let me just ask Dr. Mileti 8 basically the same question you are putting to me.
9 MR. BACHMANN: Your Honor, before this goes a
'10 little bit further, there was a statement as to what the 11 contention was. And I read the contention, and the basis of i
12 the contention is there was misinformation about the !
t 13 Newburyport schools. I
-s 14 MR. TRAFICONTE: What contention are you reading?
k_/ 15 This is testimony running to the school 16 populations, Mr. Bachmann. Remember, this is Applicants' ,
l 17 No. 18, reconfabulated and snuck into Applicants' No. 19. !
i 18 MR. BACHMANN: Yes.
19 Well, I'm reading page 51, and it's addressing 20 MAG EX-9, Basis B, and it refers us to Attachment E.
21 MR. TRAFICONTE: Yes. ;
l 22 My point is there is another contention that l '
23 challenges the adequacy of the school PARS generated during
(
24 the exercise and the general handling of the school 25 populations during the exercise. !
f(9
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1' REBUTTAL PANEL NO. 19 - CROSS 27962 L
1 MR.'BACHMANN: But this Attachment E was only 2 being offered to address MAG EX-9 is the way I understood a 3 it.
4 MR. TRAFICONTE: Oh, I see. ]
\
l 5 So now we have another wrinkle on this. j l
6 Although this testimony was originally part of 18, 1 7 which ran to a different set of contentions, they cut out a 8 piece, they put it in an attachment 19, and now they want it i 9 to run only to the contention that 19 runs to, which is the l'0 adequacy of the public information and the EBS message. .
11 MR. BACHMANN: I'm just reading page 51 of their 12 testimony.
13 MR. DIGNAN: I didn't say that.
14 MR. BACHMANN: I'm just reading the testimony on ,
i 15 page 51.
16 MR. DIGNAN: I'm just saying I didn't say that.
17 JUDGE SMITH: Whatever you are saying, I don't 18 understand. Whatever it say, it says.
19 MR. BACHMANN: It says on page 51 of the main 20 testimony, they quote MAG EX-9, and they said, "The alleged 21 inaccuracy is found in Attachment E."
22 Now we go to Attachment E, and then we're going to 23 cross-examine -- I thought Attachment E was only being 24 offered for that very limited purpose to address MAG EX-9, 25 Basis B.
Heritage Reporting Corporation
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REBUTTAL PANEL NO. 19 - CROSS 27963 1 JUDGE SMITH: It's not that sharply focused.
2 MR. TRAFICONTE: I appreciate what Mr. Bachmann is 3 arguing, and I would make two responses.
4 MR. BACHMANN: I wasn't arguing. I was just more 5 or less seeking clarification.
6 That's the way I understood it was to be offered, .
7 and it seemed like you were saying something that I hadn't 8 understood.
9 MR. TRAFICONTE: I understand that this testimony, 10 which was a part of Applicants' 18, addresses in this 11 immediate sense our contention claiming that the message for 12 the school children was poor.
13 But it would also, by logical implication, address 14 MAG Exercise No. 10, which is the school exercise contention
\
15 which was the original location of this testimony in the 16 proceeding. .
17 So if you are now going to argue that I am going 18 outside the scope -- I note for the record that Mr. Turk is 19 smiling. At least, I think that's a smile.
20 If you are now going to argue --
21 MR. TURK: Mr. Traficonte, would you like to know 22 why I'm smiling? .
23 MR. TRAFICONTE: No.
24 (Laughter) 25 MR. TRAFICONTE: Unless you feel an absolutely Heritage Reporting Corporation (202) 628-4888
r REBUTTAL PANEL NO. 19 - CROSS 27964 l
uncontrollable urge to tell yun that.
1 2 MR. TURK: Well, obviously my comment earlier 3 today had a little bit of a sting to it for you.
4 MR. TRAFICONTE: Yes, it did. I felt very bad .
l 5 about that.
6 Your Honor, unless you are going to instruct me to .)
7 limit the cross to the issues raised in the Exercise 8 Contention 9, which is public information, and not let it 9 spill over into, or slop over into Exercise Contention No.
10 10, I would like to proceed.
11 JUDGE SMITH: Well, I'll save you the trouble, 12 because I haven't followed the argument. I don't know what 13 the argument is anyway.
14 MR. DIGNAN: Your Honor.
15 JUDGE SMITH: Whatever it is, it's there. i 16 MR. DIGNAN: Let me simplify everything.
17 JUDGE SMITH: Good.
18 MR. DIGNAN: At the risk of in* curring the wrath of 19 the Board, I hereby withdraw Attachment E. We can turn off 20 the cross. We withdraw it, and we can, by all means, get 21 Dr. High up here and keep rolling.
22 ,
23 24 25 Heritage Reporting Corporation (202) 628-4888
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<l" REBUTTAL PANEL NO. 19 - CROSS ~27965-
. . . 1< JUDGE ~ SMITH: . Having stuck this infin.the'deadiof f &' -2 the night:-- H
( j 3! (Laughter) ;1 4 fMR. TRAFICONTE: In the full heat of the day,'it' 5 is withdrawn.
6 (Laughter) ..
i
- 7. MR..DIGNAN: Well, no, and I take that comment i 8 correctly. I am.a little bothered.. .I-think we did try'.to .j 9 sneak it in.in the dead of night. It wasn't intentional.
10 But Mr. Traficonte,'I think, accurately-described'what went 11 on, and I'm not thrilled with the way it happened.
- 12. It was not deliberately snuck in in the dead of-13 night. But in any event, what I'm convinced of is we're
.14 chewing up.more time than it's worth, so'I will withdraw it.
t .15 JUDGE SMITH: Is that agreeable to you?
16 MR. TRAFICONTE: Is it agreeable to me?
17 ' JUDGE SMITH: Yes.
18 MR. TRAFICONTE: Absolutely. I don't-desire to {
19 cross-examine this Panel any further.
20 JUDGE SMITH: Well, then the cross-examination on
)
21 it will also be not available for proposals.
22 MR. TRAFICONTE: That's fine.
1 23 JUDGE SMITH: Is that your understanding? J 24 MR. DIGNAN: That's my understanding.
1 25 JUDGE SMITH: All right, that's our ruling then. !
c/ Heritage Reporting Corporation 'i 1( (202) 628-4888 !
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l RE'3UTTAL PANEL ' NO. 19 - CROSS 27966 1 MR. TRAFICONTE: We have to get Mr.' Fierce.
2 ' JUDGE SMITH: How on the copy that will be in the 3 transcript, it will be --
l 4 MR. DIGNAN: That was offered today, so it can be l
5 excised.
6 JUDGE SMITH: Physically excised. ) 1 7 JUDGE COLE: Now, that's the 12 pages of 8 Attachment E, right? l
}
I 9 MR. DIGNAN: Yes.
10 JUDGE COLE: Because it subsumes Attachment G.
11 JUDGE McCOLLOM: Those messages are ancillary 1
12 anyway.
13 JUDGE COLE: And I.
l 14 MR. DIGNAN: All of Attachment E is out.
i 15 JUDGE SMITH: The whole bit.
I 16 MR. DIGNAN: And that was offered today, so we can l
I 17 do that before the reporter leaves.
18 JUDGE SMITH: Okay. !
I 19 Mr. Dignan, while have a pause here, we thought we !
20 would take up this afternoon'the timing and the manner of 21 filing proposed findings, so that that will be done. We 22 have the time and we'll be done with that. I 23 MR. DIGNAN: Yes, Your Honor. I 24 JUDGE SMITH: Do you have examination, the Staff?
l 25 MR. TURK: I have one small point, Your Honor.
I Heritage Reporting Corporation (202) 628-4888 Ol
REBUTTAL PANEL NO. 19 - CROSS 27967
^
1 JUDGE SMITH: All right.
2 CROSS-EXAMINATION 3 BY MR. TURK:
4 Q Mr. Callendrello, earlier today there was some 5 questioning about what provisions exist for distributing 6 information, or for getting information to day trippers and .
7 other transients in the beach areas who may not be 8 frequenting hotels or restaurants in the area.
l 9 Do you remember that?
10 A (Callendrello) Yes, I do.
l 11 Q Do you also recall testimony in New Hampshire by 12 the Applicants, which I believe you were a member of the 13 panel, which addressed provisions in New Hampshire beach 14 area for distribution of information?
15 A (Callendrello) Yes, I recall that. -
16 Q And do you recall testimony concerning signs that 17 would be posted in New Hampshire beach areas?
18 A (Callendrello) Yes, I do.
19 Q What is the kind of information that would be on 20 those signs in the beach area of New Hampshire?
21 A (Callendrello) The information on the beach signs 22 would be a fairly simple message that said, and I'll l
23 paraphrase it.
l 24 If you hear the sirens, turn to one of the 25 emergency broadcast system stations, and then it lists the Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 19 - CROSS 27968 1 call letters and frequencies of the various emergency 2 broadcast system stations.
3 Q Do you have sign posts like that designated to go 4 into -- I'm sorry.
5 Have signs been put in place in the Massachusetts 6 beach areas similar to those in New Hampshire?
7 A (Callendrello) No, they have not.
8 Q And can you tell us why that is?
9 A (Callendrello) We originally considered that 10 means of providing information,. but felt that with the 11 noncooperation of the Commonwealth, that that was not a 12 feasible means of providing public information.
13 We certainly would be willing to pursue it if the 14 Commonwealth indicated that they would accept those signs.
15 In lieu of that, we are pursuing alternate means 16 of providing that type of information. For example, use of 17 billboards in that beach area.
18 MR. TURK: I have nothing further.
19 JUDGE SMITH: Mr. Callendrello, in the event that 20 Seabrook is licensed to operate, do the Applicants have any 21 plans to reapproach these governments about their 22 cooperation?
23 THE WITNESS: (Callendrello) Yes.
l 24 I discussed that with the planning organization, 25 in fact during the lunch break. And there are plans to Heritage Reporting Corporation l _ (202) 628-4888 l
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27969 j
- . 1 pursueLthat'and continue to pursue that.
3 sq -
(,
,)/ 2 And'as I mentioned, we are investigating the use 3 of billboards which would mean purchase space to provide ,
1 4 information similar to what would be on beach signs. 1 5 JUDGE SMITH: I was speaking not only of the issue
~
6 that Mr. Turk raised, the issue before us today, but .
7 particularly that, but in general.
8 1NHE WITNESS: (Callendrello) Oh, absolutely. 1 9 MR. SMITH: We have no redirect, Your Honor.
10 JUDGE SMITH: Okay.
11 You are excused.
12 (The witnesses were thereupon excused.)
13 MR. TRAFICONTE: Your Honor, we have gone to get 14 Dr. High and Mr. Fierce from the cafeteria.
( -) 15 Could we address now, unless everyone anticipated 16 it would be lengthy, could we address now the subject of the 17 schedule for proposed findings? l 18 MR. TURK: I would like to hold off, if we can.
19 MR. TRAFICONTE: You would like to hold it.
1 JUDGE SMITH: I beg your pardon? I 20 21 MR. TURK: I would like to hold off that until we 22 finish the High testimony.
23 I need to call Washington.
24 JUDGE SMITH: Just let me tell you what, just so 25 that you can be better prepared for the discussion of the Reporting Corporation
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Heritage (202) 628-4888
27970 1 schedule, the Board is thinking this time of a different 2 sequence where the Interveners and the Staff file 3 simultaneously, followed by Interveners and the Applicants 4 file simultaneously, followed in short due course by the 5 Staff, and both sides are permitted reply proposed findings 6 limited to matters raised only in the first round.
7 As we indicated before, we didn't believe that the )
8 Board had all the advice it needed as to the issues in 9 controversy from the proposed findings because of following 10 a traditional sequence of findings which really wasn't as 11 relevant to this case as the method we think we're proposing 12 would have.
13 That's generally what we' re thinking about. We 14 will come back to it later this afternoon; 15 We also might entertain some ideas about 94 16 limitation on proposed findings, page limitations, and 17 another ideas the parties might have and, of course, the 18 times would be discussed, too.
19 MR. DIGNAN: I'm extremely sorry, Your Honor. I '
20 was arranging my papers just as you started.
21 The simultaneous filing would be the Applicants 22 and the opponents, meaning the Interveners and the 23 Commonwealth, with the Staff filing after --
24 JUDGE SMITH: Somewhat later, yes.
25 MR. DIGNAN: -- that simultaneously.
Beritage Reporting Corporation (202) 628-4888 ,
HIGH - DIRECT 27971 F 1 -And a right of reply-in both parties.who had 2 previously filed simultaneously.
3 JUDGE SMITH: An expectation of reply limited to 4 matters raised -- reply, genuine reply.
5 MR. FIERCE: Good afternoon, Your Honor.
~
6 Our next witness is Dr. Colin High.- Dr. High is ,
7 here now.
8 Shall we proceed?
9 JUDGE SMITH: Please.
10 Whereupon, i 11 COLIN J. HIGH 12 having been previously duly sworn, was recalled as a witness 13 herein and was examined and testified further as follows:
- 14 DIRECT EXAMINATION Ns ,) 15- BY MR FIERCE:
16 Q Good afternoon, Dr. High. .
3 17 I have placed before you a document which is 18 entitled " Revised Testimony of Dr. Colin J. High, 6n behalf.
19 of James M. Shannon, Attorney General for the Commonwealth t 20 of Massachusetts, Concerning JI-56 (Monitoring Rate) " . ]
)
21 Do you have that document before you?
22 A (High) Yes. ,
23 Q Do you recognize that document?
24 A (High) Yes.
25 Q Is this the testimony that you have prepared for Heritage Reporting Corporation (f)g f
(, (202) 628-4888 i
HIGH.- DIRECT 27972 1 this proceeding? .
2 A (High) It is.
3 Q Do you have before you a document which is dated 4 June 27, 1989, which contains one Attachment A?
5 A (High) Yes.
6 0 I understand there was an earlier version of your 7 testimony, and this is the most current version of your 8 testimony dated June 27th?
9 A (High) It is, yes.
10 Q You understand that the Board has earlier, 11 yesterday and this morning as a result of motions in limine, 12 stricken from your testimony all of the Answer No. 77 !
13 A (High) Yes, I understand that.
14 MR. DIGNAN; Mr. Fierce, my understanding of the j 15 striking was that the second sentence -- excuse me -- the ,
16 third sentence, the sentence beginning "first" had remained.
17 It's all out?
18 Oh, I'm sorry. I apologize.
19 MR. FIERCE: Okay.
20 BY MR. FIERCE: j l
21 Q Dr. High, are there any other additions or 22 corrections you would wish to make to your testimony at this l
23 time? j 1
24 A (High) Yes. l l
25 I would like to draw attention to three Heritage Reporting Corporation (202) 628-4888 (
1
HIGH DIRECT 27973 1 ' typographical: errors.
-2 JUDGE SMITH: Well, they are just typos?
- 3 MR. FIERCE: -Yes,-they are.
4 JUDGE SMITH: Just correct them. !l 5 MR. FIERCE:- Okay.
6 JUDGE SMITH: And never' mind taking up time. .
7' Dr. High, you recall you were sworn ~in your*
8 earlier testimony in this proceeding. l 9 THE WITNESS: (High) Yes, I recall.
10 JUDGE SMITH: And you are aware that you are still 11 under oath?
12 THE WITNESS:' (High) I understand that I am under 13 oath.
14 BY MR. FIERCE: -
\m 15 Q Dr. High, at this time, is it your view that this 16 testimony which is true and correct to the best of your 17 knowledge and belief?
18 A (High) It is.
19 Q And it's the testimony you wish to offer into 20 evidence today?
21 A (High) It is.
22 MR. FIERCE: Your Honor, at this time I would like 23 to offer into evidence and ask that it be bound into the
. 24 record the revised testimony of Dr. Colin J. High, on behalf
.25 ' of James M. Shannon, dated June 27, 1989.
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HIGH - DIRECT 27974
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~1 MR. DIGNAN: I have no objection.
2 JUDGE SMITH: The testimony is received.
3 (Revised Testimony of Dr.
4 Colin J. High, on Behalf of 5 James M. Shannon, Commonwealth 6 of Massachusetts, Concerning .
7 JI-56 (Monitori'ng Rate) 8 follows:)
9 10 11 1
12 13 14 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation Is - (202) 628-4888 8
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l 77"%
ks_,) UNITED STATES OF AMERICA 1
NUCLEAR REGULATORY COMMISSION ATOMIC SAFETY AND LICENSING BOARD Before the Administrative Judges:
1 Ivan W. Smith, Chairperson .!
Dr. Richard Cole !
. Kenneth A. McCollom
{
)
In the Matter of ) Docket No's.
) 50-443-OL PUBLIC SERVICE COMPANY OF ) 50-444-OL NEW HAMPSHIRE, et al.
(Seabrook Station, Units 1 and 2)
) (Off-site EP)
)
) June 27, 1989-REVISED TESTIMONY OF DR. COLIN J. HIGH'ON BEHALF OF JAMES M. SHAliNON, ATTQRNEY GENERAL FOR THE
.f- COMMONWEALTH OF MASSACHUSETTS p ,CONCERNING CONTENTION JI-56 (Monitoring Rate) d Department of the Attorney General Commonwealth of Massachusetts
(_f,j; f Ona Ashburton Place pregg. Boston, Massachusetts 02108-1698 (617) 727-2200 O "
'e l
1 o '.
I I.
SUMMARY
OF TESTIMONY i 1
In this revised testimony, Dr. Colin High, an expert in the 1 area of air photo interpretation, survey techniques, and statistical methods, uses the "20% formula" set forth in the NHRERP PID at 55.19 to estimate the number of people who, for planning purposes, can be expected to arrive for monitoring at i
the SPMC's two reception centers. This revised testimony is intended to lay a foundation for JI-56, which cha11anges the SPMC's ability to achieve a monitoring rate that will permit the ORO to monitor 20% of the total population within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. The calculations reported in this testimony have been revised to use certain inputs to the "20% formula' Which the Board has ruled are res judicata, i.e., (1) the town clerk permanent residents data an6 (2) data for the Massachusetts baach atta evacuees which is based on an assumption that there are 31,000 vehiclea in the EPZ beach are.s.
II. IDENTIFICATION OF WITNESS Q.1. What.is your name and current occupation?
A.1. My name is Colin J. High and I am a Principal of Rdsources Systems Group, Inc., of Norwich, Vermont.
Q.2. WtpsW are your professional qualification,ns?
A.2. In addition to my work at Resources Systems Group I am also Research Professor of Environmental Studies at i
Dartmouth College, Hanover, NH...I hold BS and Ph.D. ,
I ,
O l
l l 1
l .
)
1 c.- ,
f ge- degrees in Geography.and Geology from the Universitysof ;
?! s- '
i Bristol, England. I have received formal undergraduate .
and graduate training in air photo interpretation, n
survey techniques and statistical methods. .
I.have been an instructor in geography, air' photo interpretation,. ,
remote sensing and statistical methods at the university level. I have 23 years experience in the-use of air photographs and statistical surveys in transportation,
' land use. studies, site evaluation-and environmental science. I have received grants and. contracts.from.
NASA, the U.S. Department of Energy, and the U.S. First Service which involves the use of air photography and statistical analysis. A copy of my curriculum vitate is-on file in the proceeding. It is Attachment l'to the
~
testimony which I presented to the Board for the hearing on the'NHRERP, December 1, 1987 (Vol. Tr. 6849).
III. TESTIMONY ,
Q.3. What is the purpose of your testimony?
A.3. This testi3ony is designed to lay the foundation needed -
t'oeassess the ability of the SPMC to achieve a l
..y monitoring rate that enables.the New Hampshire Yankee Offsite Response Organization ("NHY-ORO") to monitor 20% ,
'l of the total. resident and transient population within a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. period. My testimony provides an estimate of ,
l Q ..
3- __
s -
^
(
'l the. number of persons that, using the "20% method" described in Section 5.19 of the Board's NHRERP PID, may be expected to arrive at the monitoring trailers.at the SPMC's reception centers in North Andover and Beverly 1
during and after an evacuation of the Massachusetts part of the Seabrook EPZ, under peak population conditions, on hot summer days at midweek and weekends. l Q.4. What is the method you used to make this estimate?
A.4. The mathematical formula used in this case for estimating the reception center load is that formula which is described in the Board's NHRERP PID, section 5.19 at page 74.as follows:
Evacuee Load = (0.20 x.(PP -SFP -TDP) + TDP Where: PP= Sum of the peak population for the assigned communities; SFP=Special facilities population of the assigned communities; TDP-Transit dependent population of the assigned communities.
Q.5. Please describe the data used in this calculation.
A.5. The data.was obtained in the following way
..._ , The resident population and summer midweek hce ~
$>@#pon-resident
$f (transient) populations assigned to both North Andover and Beverly were calculated from latest available town Clerk derived data provided by the applicants in a memorandum of.a record of telephone ,
conversations dated 12/6/88 from Tom Rigney. The
%e s. J O
e 9
^
L
-summer weekend non-resident population assigned'to j
North Andover and the summer midweek non-resident population assigned to North Andover and Beverly were
' calculated from Table.3.6-1 of Section 6 of the SPMC.
The summer weekend-non-resident population of communities assigned to Beverly include' substantial number of visitors at the beaches of Plum Island and Salisbury. The estimated non-resident populatiion of the' Salisbury beaches.and Plum Island beaches which' are assigned to Beverly are calculated by using the BoarM s finding that reasonably. expectable peak vehicle population of the beach area of the EPZ for planning purposes is 31,000 (PID 59.12) and then applying the proportion of the total vehicles in the EPZ beach areas which are normally found at Salisbury and Plum Island bea'ches. Using the vehicle counts j based on air photography interpretation in beach areas made by.KLD and reported in Volume 6 of the NRRERP at E-5 and the counts reported in the testimony of Befort, l 1
.. Adler and High (Vol. Tr. 6849), I calculated that on
[ average 40% of the total number of vehicles in the EPZ f' ach areds are at Salisbury and Plum Island beaches on hot summer weekends. Therefore,' using 31,000.as the maximum EPZ beach area vehicles estimate times i 40%, I calculate the maximum. number of vehicles at ,,
1
(
_s_ l 4
- -)
f Salisbury and Plum Island beaches to be 12,400. Using the vehicle occupancy rate of 2.4 (NHRERP Vol. 6 at 2-12), this gives a maximum beach population of 29,760 to be assigned to Beverly. However, in order to eliminate the double counting of residents who are at i
the beach, the weekend beach population is reduced by j 7% based on the estimates of residents at the beach given in NHRERP Vol. 6, Appendix M. 'The reduced weekend estimate used is 27,677 persons. For the Beverly reception center the non-beach transients and non-beach employees from outside the EPZ are then added to the combined beach and permanent resident populations. These non-beach populations are taken from the'NHRERP Vol. 6, Appendix M, pp. 1-2,with the vehicle occupantcy rates of 2.4 and 1.16 applied for ;
transients'and employees respectively. The non-
. residents of the communities assigned to ethAndoverF425%Ei v! jggjjjk are calculated from the data given in Table 3.6-1 of Section 3.6 of the SPMC.
The transit dependent populations were taken from 3{ Table 11-7cfVolume6oftheNHRERP;andspecial
- p. .
M facilities populations of the assigned communities are taken from PSNH Intra-company business memo from B. ,
Bovino to D. Tai 11eart dated January 13, 1989 (a memorandum obtained through" discovery by the Massachusetts Attorney General). That memo appears to use special facility population data which are more l current than the data reported in the SPMC (Amend. 6).
l.
I i
(N;' Q.6.
What are the results of your calculation using the
- 's method and data that you have described?
A.6. The estimates for the monitoring trailer evacuee loads reporting for monitoring at the SPMC's reception centers in North Andover and Beverly are given in the following table. Please note that these load estimates are for the monitoring trailers; the special 1 1
facility populations, who are to be monitored in their vehicles, are not included in these numbers.
Monitoring Trailer Loads at Reception Centers Peak- Peak Summer Midweek Summer Weekend North Andover 7006 5756 Beverly 12267 13168
[}
\.j For the detai'As of my assumptions and calculations, see Attachment "A*. )
Q.7. Do you believe these estimates are the best possible estimates of the evacuee loads at these reception centers?
A 7. No. Si:7 -: lf li:217 i: ti;h:: f: ': :-- Str.
'Ttee% ILumad the-Appl-icants % ehicle Occup .- -ce 1,
, ;of 2.4 for the vehicles at Salisbury and Plum Island
\
h }9h5lbe' aches.In nion, the vehicle occupancy rate is Iv h4nhar than % :t,") ="r :y; ;..J _ ;
/
vehicle occupancy on hot summer days,a.6-Kew Hampshire beaches within the EPZ and ining the Massachusetts
- i g\ -
bf beaches (se VarGme 6 of the NHRERP at E-4, reporting
()' d 011 ctea oy cne souca...m.su ... o.myou s.
s .. . _ _ _ _ _ ___ .______
9 7%....1 Planutus uvumitosion e o u v ., vuvuvauvy s from 3.0 to 3.5 person per vehicle an occupancy '
rate of 3.0 were applied e beach area vehicle j i
estimates f eak summer weekend, then the evacuee
____ -t 7:;;; j- -..'a 4e-rome. *- 14 eea 7::7; , l l
'Om o m c.d , .u. 'v mul ;;y.eved Lj the ?:::d in s
'1 i
NHRERP PID, and used here, assumes that oni % of !
the non-transit dependent population '
,y 1 go to be s( monitored at the reception cen s. No evidence, based on conditions at ' s site, is given to support this assumption. e percentj*ge of the population that choose be monitored could be muc'h higher than 20%. that were the case, then evacuee loads at t h :::: t h .'.n f.. .. u..J --2 2 ;;.1 1 . maid i: high c.
Q.8. Does this conclude your testimony? '
A.8. Yes.
N M
72.
o,e.. t, e 0 0
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ . _. _ _ _ . ~@-
Anschment A to the Teodmony of Dr. Colin J High n .,
[ Seabrook (Mesaaehusette Plan) l\ 14 ,
Mesimum Eveoustins Populattene Host _ Community of North Andover Permanent Reeldente Summer 14dweek SummerWeekend Non-realdente Non-realdente Amesbury 14058 (e) 5101 (b) ' 3198 (c)
Merrimack 4583 (a) 1889 (b) 822 (c)
- West Newbury 3518 (e) 1334 (b) 837 (c)
Total 22157 0094 $855 Trenait Dependente 730 (d)
Special Pedlities 1152 (e) -
Day Care 753 (e)
Heat Community of Beverly Permanent Ree!dente Summer Midweek SumenerWc:kend Non-residente Non reel.; ente Ballebury 8990 (e) ,
Newburyport 17812 (e)
Newbury $100 (a) l, Total 30702 29770 (f) 34278 (g)
\' )
Trenait Dependente 754 (c)
Spedal Faciutles 2155 (c) ;
l Summery Permanent Residente Peak Total PyW Peak Total PyW Summer 14dweek SummerWeekend Ase10ned to N. Andover 22187 30251 27012 Aseigned to Severly 30702 80472 84978- l TotalMaesIPZ -
52859 90723 91990
- f-Eveeuee Leedo Hee 6 Community Feellitlee ( Monitoring Treller Loade)
Peak Peak 1 Summer ledweek SummerWeekend l North Andover l 7006 (h) 8758 (h) l Beverly 12287 (h) 13188 (h) ,,
Tosef Mese EP2 19273 18924 .
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Notes to Attachment A s.) Permancht residents Sourec: Town Clerk data provided by app!! cants in memorandum of telephone conversations dated 12/6/88 from Tom Rigney, b.) Summer midweck non-residents - Summer midweck peak populadon (Table 3.61) - Permanent residents (Table 3.61) of SPMC Section 6. ,
c.) Summer weekend non-residents = Summer weekend peak population Gable 3.6-1) - Permanent residents Gable 3.6-1 SPMC Seedon 6). ,
d.) Transit dependents, Tabic 11-7, Volume 6, NHRERP. [l c.) Special facilities and day care populations from PSNH Intra-Company business memorandum from H. Movino to D. Talliert dated January 13,1989 s: ,
f.) Summer midweek non-resident population for communiticsp<# signed to Heverly, acc worksheet 2. ;
1 g.) Summer weekend non-resident population assigned to Beverly, see ,
workshcct 2. l t t h.) Monitoring trailcr loads = 0.2 (Population =W to community - transit, +
dependents - special facilities - day carc) + transit dependents + day care.
1.) Vehicles of Non Desch transients and non EPZ employees from NHRERP Volume 6, Appendix M, page M1 and M2 using the vehicles at non-besch nodes only.
( m.) (Non-bcach transient vehicles x 2.4) + (Non-F.PZ Non-Beach cmployees x 1.16).
n.) Summer Weekend Beach Transients of Salisbury, Newburyport and Newbury
- 31,000 x 0.4 x 2.4 x 0.93:
0.93 is the connection for the 7% of the resident population at the beach !4 on Summer weekends based on NIIRERP Volume 6, Appendix M, Scenario l 1.
I 0.4 is the 40% of'the total EPZ beach population that are found at Manamelmaetta Beaches.
?!.i 245dtbrvehicle occupancy rate for transients.
g -. .-
o.) Summer midweek beach transient population of Salisbury Newburyport and Newbusy - 31,000
- 0.4
- 2.4
- 0.905:
As in Note (n), except .905 la the connection factor for the 9.5% of the resident population on the beach on Summer. midweek days based on ,, )
NHRERP Volume 6, Appendix M, Scenario 3. .
l p.) Sum of the non-bcach and beach non-residents from the previous calculations.
l '
Page 3
HIGH - CROSS 27975 1 MR. FIERCE: At this time, Your Honor, I turn the 2 witness over for cross-examination.
3 CROSS-EXAMINATION 4 BY MR. DIGNAN:
5 Q Dr. High, your figure appears on page 7, as I 6 understand it, is the maximum monitoring trailer load that .
7 you ate testifying will occur in Beverly, 13,168; is that 8 correct?
9 A (High) Given the assumptions that I have laid 10 out.
11 Q Right.
l 12 A (High) That is the case.
13 Q And you're aware that that's some 2800 or so 14 higher than what we believe to be the right number in our 15 testimony No. 17 where we calculated it?
16 A (High) Would you direct me to your testimony.
17 Q Are you familiar with our testimony No. 17, 18 radiological monitoring process?
19 A (High) Applicants' Rebuttal Testimony No. 17?
20 Q Yes.
21 A (High) Yes, I have read it.
22 Q Page 57 23 A (High) Yes.
24 Q And as you see, although we get it in the off-25 season and you get it in some peak, our peak monitoring Heritage Reporting Corporation (202) 628-4888
= = ' = ' ' ' = = = - - - - - - - - - - - - _ _ _ - - _ _ _ _ , _ , _ _ _ , _ _ _ , , _ _ _ , _ _ _ _ _ , , _ _ _ _ _ _ _ _ _ _ _ _ _ _
HIGH - CROSS 27976 i i
1 trailer load for Beverly is 10,712.
2 Do you see that at the bottom of the page?
3 A (High) Page 57 4 Q Yes.
5 A (High) Perhaps I'm looking at a different 6 document.
7' Q Are you looking at --
8 A (High) April the 18th, 19897 9 MR. FIERCE: I think Dr. High may have an earlier 10 version.
11 BY MR. DIGNAN:
12 Q June 12, 1989.
I 13 A (High) I'm sorry.
14 Q Applicants' Rebuttal Testimony No. 17.
i t
15 A (High) It appears I have an earlier version.
16 0 What number have you got in your earlier version?
17 A (High) For Beverly summer?
18 Q No , Beverly should be off-season?
19 A (High) Beverly off-season I have 12,830. i 20 Q That's a total evacuee load?
21 A (High) Yes.
22 Q That's not the same thing --
f l
23 A (High) No. Monitoring trailer load, sorry, l
24 10,712.
25 Q Yes, that's what I suggested it was.
Heritage Reporting Corporation (202) 628-4888 I _
1 I
- 1
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HIGH-- CROSS 27977~
'1' .A (High) I' m - sorry, I reading the bottom.
( 2- -Q so- your number is --
- 3. A (High) Is higher than'that.
4 -Q Some 2600 higher?
5 'A '(High) Yes. ,
q 6 Q 'Okay. .
7- JUDGE. SMITH: What.is the number that he just.
J l
8 read?
9 MR. DIGNAN: 10,712.
10 JUDGE-SMITH: What'is that for?
11 MR. DIGNAN: That's for the monitoring trailer.
12 load in'Beverly.-. We come up with the peak being Beverly 13 off-season.
14 JUDGE SMITH: Oh.
' MR. DIGNAN: And he comes up with it being peak 15 16 summer weekend 13,168.
17 JUDGE SMITH: I got you.
18 MR. DIGNAN: Okay.
19 BY MR. DIGNAN:
20 Q In order to get a number 2600 higher than ours you 21 had to get an evacuee number of about 13,000. higher than our 22 numbers; isn't that right? Because that 2600 represents 20 23 percent of the increase; isn't that correct?
24 A (High) Which number represents 26 percent?
25 Q Well, we're agreed that your number is some 2600 O
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HIGH - CROSS 27978 1 higher than ours?
2 A (High) We're agreed, yes.
3 Q And that 2600 would have to come out of what was 4 an original evacuee-base of some 13,000 more because it's 5 only 20 percent of that number that's included?
6 MR. FIERCE: Objection. There's no foundation for 7 that question. The Applicants have that population number 8 from which they then subtract 50 percent of the beach 9 population.
10 MR. DIGNAN: I asked him how he got his number.
l 11 MR. FIERCE: It doesn't necessarily apply that 12 there is --
13 MR. DIGNAN: He just nodded, yes. He agreed with 14 me.
15 MR. FIERCE: I objected. There's no foundation 16 for that question because of the way the Applicants 17 calculations are done. Dr. High's testimony does not have 18 to show a population of 13,000 people greater.
19 JUDGE SMITH: Overruled.
20 BY MR. DIGNAN:
21 Q Doctor, aren't we in agreement that that 2600 that 22 you have added meant that you had to get a population from ,
23 which to make the 20 percent calculation 13,000 or so higher 24 than us; isn't that right? Because the 2600 represents 20 25 percent from some other number?
Heritage Reporting Corporation '
(202) 628-4888
HIGH.- CROSS '27979' i
. 1 A- '(High) . The formula which was used and approved-(D ,)- 2 : and taken from the Board's PID involves a 20 percent formula:
3 for calculating.
4 Q I'm not.saking you to agree to that formula.
5 But the 20 percent is the 2600;-and so the <
- 6. original number -- the origina1' increase of your. total .i 7 evacuee-load over our total evacuee load had to be some 8 13,0007 1 9 A (High) The calculation is modified by the'20 10 percent number.
11- Q Right.
12 And what the original number was,1was 13,000 13 higher than ours and that's how you get the 2600?
j- s 14 A (High)' That wasn't the way in which I calculated 15 it. I didn't take the Applicants numbers --
16 Q I understand that.
17 A (High) -- and then modify them in that fashion.
18- Q I understand that, Doctor.
19 Let's just go to your basic number. Your basic 20 number down there is 13,168; right?
21 A (High) It-is. ,
i 22' Q For monitoring trailer loads.
23 A (High) Yes.
24 Q. And you started that calculation over with the --
25 this is over on page 4 -- you took 20 percent of the peak Heritage Reporting Corporation (202) 628-4888
HIGH - CROSS 27980 1 population minus the special facilities population minus the 2 transit-dependent population and then added back the I 3 transit-dependent population; correct?
4 A (High) Correct.
5 Q My point is: that number of 13,168 is 20 percent 6 of another number plus an add-back of TDP; right? I 7 A (High) First of all, I'm not sure about this
)
8 13,000 number, how you arrived at that number. That's not a 9 number in my testimony.
10 Q I took and multiplied -- 13,000 is in your figure?
11 A (High) The 13,168; yes.
12 Q Yes.
13 Now, the 2600 figure which we talked about was the 14 difference between that number and our number.
15 MR. FIERCE: Objection, it's 2456.
16 MR. DIGNAN: Fine, make it lower; 2456.
17 Fine by me.
18 BY MR. DIGNAN:
19 Q The 2456 difference between the 13,168 and our 20 number of 10,712; right?
21 A (High) Yes.
22 Q And I am saying that that 2456 represents 20 23 percent of something; correct?
24 A (High) Yes. l 25 Q And 20 percent means that if I multiply 2456 I Heritage Reporting Corporation '
(202) 628-4888
HIGH - CROSS 27981-1 will get the base you worked that number from; will I not?
(v ) 2 A -(High) That's not the way the number was 3 calculated.
4 Q I know that. But still won't I get it?
5 You multiply 2456 times 5, I will.get a number of 6 which 2456 is 20 percent; can we agree to that? .
7 MR. FIERCE: Objection. He's got the formula.
8 There's the add-in, Mr. Dignan, you keep forgetting the 9 add-in.
10 JUDGE SMITH: Then he can just answer, no.
L 11 MR. FIERCE: I mean, it's obvious from the 12 fcrmula.
13 JUDGE SMITH: Can you answer the question?
g 14 BY MR. DIGNAN: '
s 15 Q Can you answer the question, Doctor?
16 A (High) Please ask it again.
17 Q All right.
18 Is the 2456, does that represent 20 percent of 19 some number?
20 A (High) On the assumption that the figures used 21 for transit-dependents, special facilities, et cetera were 22 the same, then it would be 20 percent; yes.
23 Q Okay.
24 Now, the transit-dependent population of the 25 assigned communities that you used is not all that much l
([sjj
< Heritage Reporting Corporation (202) 628-4888 l 1
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HIGH - CROSS 27982 1 different than the one we used; is it?
2 A (High) I think they are pretty much the same, 3 yes. j 4 Q So that while there may be some small difference, ,
l 5 the fact of the matter is, the 2456 was generated out of ;
I 6 other factors, and the number of which it is 20 percent is 7 some -- now I have to do the math again.
8 12,280; right?
9 MR. FIERCE: Objection, confusing. l 10 (Laughter) 11 BY MR. DIGNAN:
12 Q Doctor, I don't want to confuse anybody in this 13 room. I don't really think I'm confusing you, but I may be 14 confusing somebody.
15 JUDGE SMITH: Well, I want to check in.
16 (Laughter) 17 BY MR. DIGNAN:
18 Q Can we agree that 2456 is 20 percent of 12,280?
19 JUDGE COLE: That's just an arithmetic question, 20 Doctor.
21 (Laughter) 22 THE WITNESS: (High) Do we agree that 2456 --
l 23 BY MR. DIGNAN:
24 Q Is 20 percent of 12,280?
25 A (High) 12,280, it is. '
l l
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HIGH - CROSS 27983 )
1 Q Thank you.
- 2 A (High) On the arithmetic we agree.
3 Q On the numbers, right.
4 So that means you -- by whatever method you got 5 your number, you got an extra 12,280 people in this evacuee 6 group that we did not include; isn't that right? .
7 MR. FIERCE: Objection.
8 It'a just not true from the formula, Mt. Dignan, 9 you keep forgetting the --
10 MR. DIGNAN: He has already agreed with me that 1
11 the transit-dependent population numbers that we both used 12 are essentially the same. We're agreed they aren't exactly 13 the same, but he agreed with me they -- l 14 MR. FIERCE: That's not the point.
15 You keep saying it's the population, the total 16 evacuee population.
17 MR. DIGNAN: That's right.
18 MR. FIERCE: It does not have to be -- the 19 difference is not that number. Because of the way the 20 formula works it's a smaller number.
21 MR. DIGNAN: Your Honor, I'm sure the witness will 22 tell me if I'm wrong. Can I cross-examine the witness?
23 MR. FIERCE: Well, I can object if the premise of 24 a question is just not supported by any of the evidence 25 here.
Reporting Corporation O
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I HIGH - CROSS 27984 i 1 JUDGE SMITH: What's happening? ;
2 Hold on a second.
3 (Board confers.) !
4 JUDGE SMITH: The Board believes that if you're l 5 going back to the formula, before we can follow the chain of i 6 logic here you would have to establish that the special 7 facility population is the same, is a wash, too.
8 MR. DIGNAN: No, I don't believe so, Your Honor.
9 Because that's within the 20 percent. Although I do believe ;
10 it is a wash.
11 JUDGE SMITH: That's within the 20 percent to 12 begin with.
13 MR. DIGNAN: Yes.
14 The 20 percent applies to -- because he split it 15 out and I'm sure the Doctor will correct me if I'm wrong.
16 JUDGE SMITH: Okay.
17 MR. DIGNAN: Is to peak, the special facilities 18 and the TDP. But then he adds back the TDP and that's why I 19 wanted to establish that there really wasn't much difference 20 between us on what the TDP is. I mean, not enough to l 21 significantly affect it, and I thought he agreed with me on 22 that.
23 JUDGE SMITH: Yes.
24 All right.
25 l
Heritage Reporting Corporation l (202) 628-4888
HIGH - CROSS 27985
,_ 1 BY MR. D'IGNAN:
1
() 2 Q So now I'm saying that since the difference is 3- 2456 -- and with the full understanding, Doctor, that 4 because the TDPs are slightly different, but let's call it 5 approximately 2400 and account for it and make everybody 6 happy.
7 To get that you had to get an evacuee population 8 during your calculations of 5 times that amount because the 9 2400 represents 20 percent of the additional numbers; isn't 10 that right?
11 A (High) That's correct.
12 Q So if we can use, just for purposes of this 13 examination, the 2400 because I deal with zeros better than <
14 I do with 5s and 6s. You're adding about'12,000 people to f-ss l
( -
j
\ 15 the overall evacuee population?
16 A (High) I'm not adding numbers to the overall i
17 evacuation population.
18 Q Excuse me. Your overall population is 12,000 19 higher approximately than what we get by our methodology?
20 A (High) There would evidently be a 12,000 21 difference between the calculation the Applicants made.
I l
l 22 JUDGE COLE: And that would be in the peak 23 population on page 4 in the equation; is that right, sir?
24 THE WITNESS: (High) The primary difference will 25 be from the peak population.
I i-f'% Heritage Reporting Corporation s
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HIGH - CROSS 27986 1 MR. DIGNAN: Let's get at that.
2 BY MR. DIGNAN: )
3 Q The population increases, as I understand it from 4 reading your testimony and the attachment, particularly, i 5 Doctor, came from essentially four differences. This is 6 called upfront to let you know where I'm going.
I 7 Four differences between the figures and l 8 methodology you used and the ones we used. And I want to
(
9 check with you.
10 First of all, you used some newer clerk population 11 data than we did; right?
12 A (High) Correct.
i 13 Q And can we agree that that didn't add all that
)
In other words, that it was higher but it wasn't all 14 much?
15 that many higher?
l 16 If you can give me the number, I'll be glad to 17 take it?
~
18 A (High) It was a small increase, yes.
19 Q Okay.
20 The second thing I understood you to do which 21 affected this figure is, you redistributed -- and I don't 22 mean that as a loaded term -- you distributed the population 23 as between Massachusetts and New Hampshire beaches l 24 differently than we did; isn't that correct?
25 A (High) I used 40 percent.
'- Heritage Reporting Corporation (202) 628-4888
HIGH - CROSS 27987 1 Q Right. !
I' \
(v) 2 And we used some 30 plus percent; ' inn't that 3 correct?
~
4 A (High) You certainly used -- the Applicants used i 5 a number which was lower-than that.
6 Q Yes. .
7 And can we agree that that did not result in any i 8 really major increase? j 9 A (High) That resulted in some.
10 Q Some, but not -- well, how much?
11 Can you give me a figure?
12 A (High) Not immediately without calculation.
13 Q -Now,-another thing you did in you added into this
, 14 group some 4,000 -- between 3 and 4,000 employees who work
(
L 15 in the EPZ, did you not, that we did not add in?
16 A (High) My calculation included employees.
17 It's my understanding, however, that the 18 Applicants' calculations also included employees.
19 Q Well, if you'll accept my representation they 20 didn' t, we can agree that your inclusion of employees in 21 your scenario 1, you did get a substantial increase out of 22 that because as I understand your work sheet number 2 23 attached to your testimony that added some 3200 people?
24 A (High) I don't accept that.
25 MR. FIERCE: Objection.
1
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Heritage Reporting Corporation (202) 628-4888
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. {I I
l HIGH - CROSS 27988 !
I 1 THE WITNESS: (High) Sorry.
2 MR. FIERCE: The question'again was: if you can 3 accept that we didn't.
4 BY MR. DIGNAN:
5 Q Let's assume hypothetically, Doctor, that we did i
6 not include employees in ours. I understand you think we .
7 did. Let's assume we did not.
8 A (High) I believe that you did. j 9 But you can ask me the question.
10 Q Assume we did not. Then would you agree with me 11 your methodology would add 3200 pecple into this universe in 12 of and by itself?
13 A (High) Why 3200?
\
14 Q I'm looking at your w~ork sheet No. 2, Doctor, page 15 2 in which you calculate the employees in scenario 1. L 16 Scenario 1, I believe, is the scenario you're 17 working in. You have 1449 out of Salisbury; 1006 out of 18 Newburyport; and 838 out of Newbury?
1 19 A (High) Those are vehicles.
20 The population is calculated, if you look at 21 Attachment -- )
22 Q This is not individual employees; this is employee .
l 23 vehicles? I 24 A (High) If you note page 3 there's a note "L: ,
25 vehicles of nonbeach transients and nonEPZ employees from I
Heritage Reporting Corporation i
(202) 628-4888 l
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l' HIGH - CROSS '27989
~
i 11 the NHRERP,., Volume'6, Appendix M, using vehicles at nonbeach As ,j 2 . nodes'only."
3 Q 'Right.
4 So those'are vehicles and not people?
5 .A (High) The people are calculated further in.the-6 work sheet at Note'M.
'7 Q I'm asking you a question: work sheet No. 2, page '
8 2.
9 A (High) Yes.
10 Q That 1449, 1006 and 838 are employee vehicles 11 rather than employees?
12 A (High) That's correct. j 13 Q All right.
14 So what number should'I use for' employees?
/s 15 In other words, what did'you multiply that vehicle.
16: number by?
17 A (High) I'm looking here at Note on Attachment A, 18- page 3, Note M: "nonbeach transient vehicles multiplied by 19 2.4 as a vehicle occupancy rate. NonEPZ, nonbeach employees 20 by 1.16." I believe both of those numbers come from 1 21 Applicants.
22- Q So 3293 should be multiplied by 1.16 in order to 23 get the total number of' people you're putting in the 24- universe;.is that right? ,
25- A (High) The employees number should be multiplied Beritag6 Reporting Corporation
.k i (202) 628-4888 l
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HIGH - CROSS 27990 1 by 1.16. And the nonbeach transients by 2.4.
2 Q Let's hold the nonbeach transients.
3 The employee number I get is 3293 from adding up 4 the three figures on page 2; am I right?
5 (Wi*ne'as uses calculator.)
6 -
7 8
9 10 11 -
12 13 14 15 16 17 18 19 20 21 22 ,
23 24 25
. Heritage Reporting Corporation (202) 628-4888 l
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HIGH - CROSS 27991 1 A (High) 3293.
) 2 Q s Right.
3 And then I multiplied that by 1.16, I think is the 4 number you gave me, and the answer I got was 3819.88.
5 Can you confirm that?
6 A (High) 3820. .l 7 0 3820, all right.
8 So that we are agreed then, if you can accept my !
9 hypothesis that we did not originally include these 10 employees, your methodology would add 3820 people into this 11 population universe in and of itself.
12 Is that right?
13 A (High) If we accept that, yes.
n 14 Q Right.
/ \
(_,/ 15 Now, by the way, did you read Applicants' No. 7 16 before you wrote this testimony?
17 MR. FIERCE: Applicants' No. 77 18 BY MR. DIGNAN:
19 Q Seventeen, I'm sorry.
20 A (High) Frankly, Mr. Dignan, I can't remember 21 whether I read it before or after.
22 I would certainly have seen it before the final 23 revision that I made.
24 Q Now, the fourth difference between your 25 methodology and ours was that you included in the population j Heritage Reporting Corporation
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HIGH - CROSS 27992 1 universe, 2 believe it is 93 percen't of the beach transient 2 population.
3 Isn't that correct?
4 A (High) That's correct.
l 5 Q And we only included 50 percent of it.
6 Isn't that correct? .
j 7 A (High) That's correct.~ ,
8 Q And that in and of itself accounted for an 4 1
9 extremely large number of these 12,000 some people, did it j i
10 not?
11 A (High) That is the single most significant 12 difference.
13 Q And, indeed, it added some 10,000 to the number, 14 didn't it? -
1 15 Or maybe you have the exact number it would have I i 16 added.
17 A (High) I don't have the exact number in front of 18 me.
19 Q Can you agree with me that it's in the are of 20 10,0007 21 (Witness uses calculator.)
22 A (High) Approximately of that order, yes.
23 Q Yes.
24 A (High) Probably a little bit ware.
25 Q So, again, if you are willing to accept my Heritage Reporting CorpWation (202) 628-4888 1
_______________Q
.- 1 k
[, ,
l" HIGH - CROSS 27993 t
I hypothesis that we did not include employees in the EPZ, you.
2 : add your number that is derived from the use of the'93 3 percent figure in that, and that accounts for almost all of 14 the 12,000 increase that you got,.does it not? l 5; Indeed, in actually numbers,'if'we did the 1
6 calculation, it's higher. But f.t's fair to say that those .)
1 7 last two factors, the addition of employees if'it be an 8 addition, and'I understand you don't accept'that,.plus the 9 utilization of the 93 percent figure for the beach transient 10 population, that accounts for. virtually all of this-11 increase.
12- Isn't that right?
13 A (High) That's the most important difference, yes.
14 Q Well, can you do a little better for more than'the
}e-t
', 15- most important.
16 Doesn't it really account for virtually all of it?
17 A (High) Most of it is accounted for by the 18 difference between our using 93 percent and they using 50 1
19 percent. I 20 Without sitting down and doing the calculations on 21 a component-by-component basis, I won't want to tell y3u 22 what the percentage of the difference is.
23 Q Okay.
24 A (High) That's a calculation that could be done, 25 but I don't think the Board would wish me to take time to do f
n gs_,
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HIGH - CROSS 27994 1
1 it.
2 But I would agree with you generally.
3 MR. DIGNAN: That's all I have.
4 JUDGE SMITH: Do you have questions? f i
i 5 MR. TURK: Very limited, Your Honor.
6 CROSS-EXAMINATION .
7 BY MR. TURK:
8 Q Good afternoon, Dr. High.
9 I'm Sherwin Turk with the NRC Staff.
10 I wanted to ask you about the 40 percent number.
11 A (High) Yes, i 12 Q Which you applied to the ratio of cars present in 1
13 Massachusetts as a part of the entire beach vehicle 14 population.
15 Am I right that this number is derived from your 16 reference to aerial photographs which were made a part of 17 the New Hampshire proceeding?
18 This is on page 5 of your revised testimony.
19 A (High) It was derived from two sources.
20 The first source, from the testimony of Befort, 21 Adler and High in the New Hampshire proceedings.
22 And secondly, supported by the data produced by 23 KLD and reported in Volume 6 of NHRERP.
24 Q Does KLD use a 40 percent number for Massachusetts 25 beach vehicles as compared to the entire beach population Heritage Reporting Corporation (202) 628-4888
HIGH - CROSS 27995 1 number?
r%
( ) 2 A (High) If you look at the counts of vehicles from 3 the -- just one moment. Let me refer specifically to'the 4 document.
5 (Witness reviews document.)
6 A (High) If you take the vehicles counted and .
7 reporte'd in that source by KLD, take'the number of vehicles 8 which were counted on the Massachusetts beaches and take the 9 total number of vehicles counted throughout the EPZ in the 10 beach zone, then the ratio between the two is 40 percent.
11 Q' I don't understand.
12 Where do you find in the KLD study the 40 percent 13 number?
f-sg 14 A (High) In the NHRERP, Volume 6, Appendix E, page s_ 15 E-5, there is a table which gives the vehicle counts, and I -
16 tallied the number of vehicles on the Massachusetts beaches 17 and tallied the number of vehicles on the -- well, they 18 already tallied the number of vehicles for the whole EPZ.
19 I took the ratio of the two and it was 39.64 20 percent. I used 40 percent as the nearest round number.
21 Q But those numbers are not for weekends, are they?
22 Isn't that a combined number of vehicles found on i
23 the beach areas both weekdays and weekends? j 24 A (High) This is based, as I understand it, and I 25 believe it refers to on page E-5, a Sunday, August 11, 1985, j[ Heritage Reporting Corporation s ,/ (202) 628-4888 l
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HIGH - CROSS 27996 1 'in the early afternoon, a day which I believe was, to use ,
2 their own words here, considered to be ideal conditions for 3 attracting day trippers to the beaches.
4 I believe it is being considered to represent a I
5 busy summer day. Maybe a peak day of some kind, peak day.
6 Q Okay.
7 So you had 39.?
8 A (High) 39.64 percent which I rounded to 40.
9 Q Now you also reference aerial photographs which 10 were presented during the New Hampshire phase of this 11 proceeding.
12 A (High) Yes.
13 Q Do you have any notes there or any recollection of 14 what the percentage of vehicles were in those photographs 15 broken out between Massachusetts and New Hampshire?
16 A (High) Yes.
17 In the testimony which Befort, Adler and High 18 submitted, using the counts of vehicles actually made by Dr.
19 Befort July 5, 1987, using the same procedure, tallying the 20 vehicles counted on Massachusetts beaches, dividing that 21 number by the total number of vehicles counted on all 22 beaches within the EPZ, the ratio was 41 percent.
23 Q And can you give us those numbers?
24 A (High) Yes.
25 9,941 on Massachusetts beaches, 24,309 on all Heritage Reporting Corporation (202) 628-4888
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1- beaches'. .I i , 2- Q All'right.
3 The 24,309 then is substantially more than the 4 .18,220; reported in Volume 6,-which'had been.taken from the 5 1985 photographs.
6 Is that correct? .
7- A (High) You.are comparing the 24,000 in Befort's 8 testimony with which other data?
- 9. I'm sorry.
10 Q Well, the number you had used for your 39.64 11 percent, which you just' testified about, I understood that 12 was the data presented on E-5 of Volume 6 in NHRERP.
13 A (High). That's correct.
14 The total number of vehicles was smaller on that O 15 day than on July 5, 1987.
So there is a difference between 18,220 and this 16 Q 17 number of 24,3097 18 A (High) That's correct.
19 Q Now there was another set of aerial photographs 20 taken which Dr. Befort referred to, and that was July 19, 21 1987.
22 Is that correct?
23 A (High) July 19th.
24 Q And did you do a calculation to determine what 25 percentage of the vehicles on that day were located in Heritage Reporting Corporation 4
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1 Massachusetts as compared to the whole beach area?
2 A (High) Let me see a v.
3 Yes, I have done a calculation.
4 Q And can you tell us what the numbers were for 5 Massachusetts vehicles? l 6 A (High) I'm sorry.
7 I don't know the numbers. I don't have the 8 numbers in front of me for that, but I believe the t
9 percentage, if that's what you are concerned with, was 37 j 10 percent. Sorry. 36 percent.
11 Q In the Licensing Board's partial initial decision i
12 of last December, they indicated that the July 19th 13 photographs revealed 25,451 cars in the entire beach area.
14 This is PID, Paragraph 9.108. .
15 A (High) Yes. Oi 16 Q And you accept that, don't you?
17 A (High) Yes.
18 Q Now do you know how many vehicles then were 19 present in Massachusetts?
20 Do you have data available?
21 A (High) Yes, I will find that information if you 22 just give me one moment.
23 (Pause . )
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HIGH - CROSS 27999.
1- JUDGE McCOLLOM: What was that PID paragraph f% .
) 2 again?
3 MR. TURK: 9.108, it's on page 799.
4 (Witness searches for document.)
5 THE WITNESS: (High) I believe the number was 6 9752. I speak here from notes rather than from the exact. .
-7 original tallies. I do not have the exact original tallies 8 in front -- I do not have the exact original tallies 9 tabulated in front of me. As I say, I speak from notes 10 rather than from the original information. I believe that 11 is the correct number.
12 But the 36 percent, I believe, is the ratio 13 between the two on that date.
n 14 BY MR. TURK:
/ t
.(s,/ 15 Q So-you believe that 36 percent is the correct 16 ratio for the cars located in the Massachusetts beaches on 17 that date?
i 18 A (High) Yes.
19 Q Now, there's a third set of photographs whi'ch was 20 the subject of litigation previously, and those were the 21 photographs taken on July 18th, 19877 22 A (High) I'm aware of those. r 23 0 Those were the AVIS photographs; right?
j 24 A (High) Yes.
25 Q Have you looked at those photographs and counted 1
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HIGH - CROSS 280b0 1 the number of cars located in the Massachusetts beach areas?
2 A (High) During the proceedings for the New 3 Hampshire plan I did examine at great length some of those 4 photographs and the differences between our photographs and 5 their photographs and the procedures were subject to 6 considerable discussion.
7 Q Can you tell us, first of all, you don't disagree 8 with the Licensing Board's determination that in those 9 photographs a total of 26,850 vehicles were present?
10 A (High) No, I do not disagree with that number.
11 Q All right.
12 Now, have you -- do you have some notes with you 13 that you could use to tell us how many of those vehicles 14 were present in Massachusetts?
15 MR. TURK: Incidentally, Your Honor, that was in 16 finding 9.102.
17 THE WITNESS: (High) Yes.
18 My notes indicate that there was 8347 vehicles in 19 Massachusetts and 26,850 in the EPZ. And I believe that is 20 a 31 percent ratio.
21 BY MR. TURK:
22 Q That's what I get also, 31.09.
23 A (High) That's correct.
24 Q Now, in your testimony you indicate that on 25 average -- and this is on page 5 of your testimony -- on Heritage Reporting Corporation (202) 628-4888
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HIGH - CROSS 28001 1 average 40 percent of the total number of vehicles in the
_, )
$ 2 EPZ beach areas are at Salisbury and Plum Island beaches on 3 hot summer weekends. .
4 Now, when you say "on average 40 percent" you're 5 not reflecting the XVIS data, are you?
I 6 A (High) I'm reflecting as I state in the testimony .
7 the days of which we obtained them as given in Befort, 8 Adler, and High's testimony backed-up by the work of KLD.
9 But primarily dependent on Befort, Adler, and 10 High's testimony, and the counts which I was partially 11 responsible for.
12 Q So, in fact, the 40 percent is not an average 13 number of all these different data bases?
~~ 14 A (High) It's an average of those two.
\s/ 15 I didn't state that it was an average of all the 16 data available.
17 Q All right.
18 So you averaged the High/Befort testimony l 19 concerning the July 5th data with what? With the KLD data ;
20 from 19857 21 A (High) They're essentially the same. One is 40 22 percent and one is 41 percent. l 23 Q And in doing that then you disregarded the 36
)
24 percent number for July 19th, and the 31 percent number for 25 July 18th; is that correct?
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HIGH - CROSS 28002 1 A (High) What happened here is that I used data i 2 which best represented a reasonably expectable peak.
1 Can you answer the question, Doctor? l 3 Q 4 You disregarded the 36 percent and the 31 percent 5 data?
6 A (High) I chose to deliberately not use that data 7 for reasons which I will be willing to explain.
8 I did not disregard it. I examined it and chose 9 not to use it.
10 Q And the date on which more cars were actually 11 counted than in any of the prior cases was the AVIS 12 photograph data of July 18th; is that correct?
13 A (High) The date on which more cars were counted 14 in the photographs was on the AVIS data of July 18th. That 15 is not the same as saying that that was the date on which 16 the largest number of vehicles were present.
17 We believe that the number of vehicles actually 18 present on July 5th was larger because the photographs on 19 July 5th were taken rather close to the time in the 20 afternoon which is considered to be peak.
21 Sorry. The photographs on July 5th -- I wish to ]
i 22 correct that statement. ,!
l 23 The photographs on July 5th were taken later in {
24 the afternoon after the peak had passed.
25 Q What time were they taken?
s Heritage Reporting Corporation (202) 628-4888 O,
1 HIGH - CROSS 28003 1 A (High) They were taken between on the
( 2 Massachusetts beaches about 3:40 in the afternoon.
3 Q And in New Hampshire?
4 A (High) The overall flight was taken between 3:30 5 and 3:45, that particular strip that was used.
6 Whereas, the AVIS photographs were taken of the .l 7 Massachusetts beaches, as far as I car tell from looking at 8 the actual numbers, at about a few ma utys after 12:00 noon.
9 And the whole strip was taken between 1. 30 and I think 10 12:11.
)
I 11 Therefore, it seemed the case that the AVIS 12 photographs were -- I'm sorry, the July 5th photographs 13 taken by Befort did not represent the actual largest number 14 of vehicles that were present. And we, in fact, argued this 9 15 point during the previous hearings.
16 And there were, in fact, many more vehicles 17 present during the peak of the day as was evidenced by on-18 ground observations of people who were there. And also, by 19 the fact of the parking pattern on certain routes that we 20 observed in the air photographs, all of which suggests that, 21 in fact, July 5th was a higher peak day than July 18th.
22 Q Do you have any way of knowing whether the number 23 of cars parked in the Massachusetts portion of the beach 24 area on July 5th at the peak hour of 2:00 p.m. was the same 25 ratio that was present at 3:30 or 3:45 in the afternoon when G Heritage Reporting (202) 628-4888 Corporation
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28004 1 the photographs were taken? Th'e same ratio in relation to 2 the overall number of cars?
3 A (High) No. But it seems a reasonable assumption. {
, i 4 In the absence of any other data it's reasonable j 5 to believe that people come and go in roughly the same 6 proportions. .l 7 Q Would you agree that the number -- I'm sorry, the 8 relative percentages of vehicles in Massachusetts as 9 compared to the whole beach area will vary from day-to-day?
10 The data suggests that by themselves, don't they?
l 11 A (High) Oh, yes.
i 12 Q And just as they would vary from day-to-day they 13 may vary from hour-to-hour?
14 A (High) They may indeed vary from hour-to-hour.
15 Q Thank you. .
16 MR. TURK: I have nothing further.
17 EXAMINATION BY JUDGE COLE 18 JUDGE COLE: Just a few questions about the 7 19 percent value, Dr. High.
20 Could you tell me exactly what the 7 percent 21 represents? For example, you say: "To eliminate double 22 counting, the weekend beach population is reduced by 7 23 percent based on the estimates of residents at the beach."
24 THE WITNESS: (High) Yes.
I 25 Some of the people who are resident in the town Heritage Reporting Corporation (202) 628-4888
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28005-
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1 such as Newburyport and Salisbury _will have gone to tho' I ijr}
2- beach on a hot summer afternoon and probably'taken their (f
3 cars with-them.
4 JUDGE COLE: A good place to go. J 5 THE WITNESS: (High)' An excellent. place to go.- i 6 And as a result of that they will be counted'as .-:
7 part of the beach transient population as assessed by ,
8 photographs on which the beach transient populations are 1 9 -based.
10 However, they will also be part of the resident 11 population of_those towns. Therefore, they would be counted f
12 twice unless some allowance was made. s 13 Now, allowance can be made for that by using the 7,
14 data provided and cited here in NMRERP Volume 6 and-
' tabulated actually conveniently by the Applicants in a.
15 ]
16' separate document. .
17 If you look at those numbers you find that 7 18 percent of the people actually on the beaches are residents '
19 of those towns; and therefore, they would be in this 20 analysis double counted. So we subtract 7 percent. So it's 21 only 93 percent.
22 JUDGE COLE: You're aware of the Applicants' 23 calculation using a value of 50 percent?
i 24 THE WITNESS: (High). I'm aware of that, and I i 25 don't agree with it. I can see no basis for using 50 Heritage Reporting Corporation !
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28006 1 percent at all. .
2 JUDGE COLE: If these people at the beach were to 3 reside anywhere within the EPZ and we were to use the !
4 percentage of people at the beach that reside within the EPZ i 5 who happened to be at the beach, would you still use the 6 same value of 7 percent? .
7 THE WITNESS: (High) Yes, because the people who 8 are visiting the beach from other than those towns, if they are at the beach they will receive the emergency broadcast )
9 ,
i 10 which says, " leave the beach areas" and strongly recommends 11 them to go to monitoring stations. And they are directed to 12 go to the reception centers at Beverly or North Andover, as
{ 13 the case may be.
14 You should expect that they will behave or at 15 least a reasonable percentage of those people will behave 16 according to those instructions and travel to the monitoring I
17 stations for monitoring and become part of the monitoring 18 load at those reception centers at Beverly and North 19 Andover.
20 JUDGE COLE: Wouldn't they be double counted, ]
l 21 though? {
I 22 THE WITNESS: (High), Not for the purposes of 23 traveling to the -- not for the purposes of arriving at the 24 evacuation monitoring centers at Beverly and North Andover.
25 JUDGE COLE: Well, aren't they counted in the f 1
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28007 1 total population within the EPZ?
2 THE WITNESS: (High) Yes, but they're not counted l
( l 3 as part of the population of those towns arriving at those l
. J 4 reception centers. The load -- the monitoring load at those j l
reception centers is based upon the populations of those 5
6 towns plus the beach transients. w I mean, the formula 'hich .;
7 has been agreed upon.
8 JUDGE COLE: And the specific value of 7 percent, 9 tell me again how you arrived at that, sir, as compared to 10 some other figure?
11 THE WITNESS: (High) By taking the Applicants' 12 data as presented in NHRERP Volume 6.
13 JUDGE COLE: Where in that, sir?
14 THE WITNESS: (High) Well, let me show you the 15 precise - you take the summary table of that data and it's 16 from New Hampshire Yankee's document SEP892119, which was 17 distributed by Applicants as part of the Applicants' notice 18 of aciditional documents. I believe I have the correct 19 citation to that.
20 That actually simply summarizes a very large 21 amount of data which originally appeared in NHRERP Volume 6.
22 This document, I believe, has already been entered into 23 evidence.
24 MR. FIERCE: I'm not sure it has.
25 THE WITNESS: (High) I'm sorry.
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28008 1 Perhaps Mr. Fierce will tell me if that document 2 is --
3 MR. FIERCE: Not to my knowledge, at this point.
4 Why don't we just' refer to Appendix M, it might be 5 easier.
6 THE WITNESS: (High) Well, Appendix M has a very, 7 very large number of tabulations which the Applicants have 8 summarized here; and I simply used the Applicants' summary i 9 of that data for the purpose.
10 But if you look at that you can see that there are 11 -- the number of peak vehicles is given for 1985. And the j 12 number of residents found at those beaches is also given.
13 JUDGE COLE: Residents of? j 14 THE WITNESS: (High) Residents-of those towns.
15 JUDGE COLE: All right.
16 Which towns are listed, sir?
17 THE WITNESS: (High) Those towns of Plum Island; i
18 South Newbury; Rowley; and Ipswich; Plum Island North; 19 Newburyport; and the Town of Salisbury. The overwhelmingly 20 most important of those is the Town of Salisbury with some 21 over 8000 vehicles; the other two are quite smaller, only 22 1000 -- little over 1000 each.
23 In total there were 10,639 vehicles found on the 24 beaches on that day. And there were 780 vehicles of 25 residents of those towns found on those beaches. This was Heritage Reporting Corporation 2 (202) 628-4888 i
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18 19 20 21 l 22 ,
23 24 25 Heritage Reporting Corporation
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THE WITNESS: (High) The ratio of those two is l 2 7.3 percent.
3 JUDGE COLE: And that's where you got your 7 4 percent?
5 THE WITNESS: (High) That's where I obtained the 6 7 percent to avoid double counting of re.sidents who be on 7 the beaches.
8 JUDGE COLE: All right, sir.
9 Thank you.
10 JUDGE SMITH: Mr. Fierce?
11 REDIRECT EXAMINATION 12 BY MR. FIERCE:
13 Q Just on that point, Dr. High.
14 It's your understanding that the residents who are 15 subtracted out of the beach vehicles for each of those towns 16 that have beaches are residents of EPZ?
17 A (High) Yes, they are residents of towns within i
18 the EPZ.
19 Q Towns within the EPZ.
20 A (High) Residents of towns within the EPZ. ]
1 21 Q Not just the town that that beach happens to be l l
22 in?
23 A (High) That's correct.
24 Q The Applicants' number " discount 50 percent" is a 25 discount that includes more than just the people who are I l
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HIGH - REDIRECT 28011 1 residents of the EPZ, isn't it?
( 2 A (High) Yes.
3 Q What is the other component?
~
4 A (High) Well, in their testimony they state that 5 they exclude day trippers who live in the EPZ.
6 Q Do you have any reason to believe that day .
7 trippers should be excluded from the monitoring load 8 calculations?
9 A (High) None whatsoever.
10 They will receive the same broadcast and the same 11 information and strong recommendation to go to the 12 monitoring center. Can't see why they would behave 13 differently from others who might be on the beach and 14 receive the same message.
15 Q Is it your view that employees who work in the 16 EPZ, who live outside the EPZ, should also be considered in 17 monitoring trailer load calculations?
18 A (High) Yes.
19 They would receive the same message. They would 20 believe they had the same --
21 MR. TURK: Your Honor, I am going to object, and 22 move to strike the last answer and the portion of this 23 answer that's come out.
24 Dr. High is presented as a statistician, expert on 25 air photo interpretation and survey techniqpes.
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HIGH - REDIRECT 28012 1 He's now being asked to present testimony on human 2 behavior and emergency planning.
3 MR. FIERCE: I asked if he had any reason to 4' believe they wouldn't show up --
5 MR. TURK: He doesn't have the expertise.
6 MR. FIERCE: To the extent he has any knowledge .
7 why the Applicants have included this or any reason at all.
8 He's not offering any expert --
9 JUDGE SMITH: Do you have any reason within your 10 area of expertise?
11 THE WITNESS: (High) I believe I can answer the 12 question based on general professional judgment. I do not 13 claim to be a behavioral expert, however.
14 I will state that I don't -- I see no reason why 15 they would behave different than others receiving the same .
16 message.
17 JUDGE SMITH: That's a statistical air photo 18 interpretation, or what is your expertise that leads you to 19 that?
20 THE WITNESS: (High) As stated here, statistical 21 air photo interpretation.
22 My company also does a substantial amount of work 23 in traffic. And through association with that work in 24 cooperation with my colleagues in that area, I believe that 25 I can state that opinion.
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l HIGH - REDIRECT 28013- i 1 I don't wish to state that it should be --
[ JUDGE SMITH: Is your opinion a human behavior 2 ,
\s_ /.
3 observation or is it a statistical observation? !
I 4 THE WITNESS: (High) I think it's based on common 5 sense, Your Honor, 6 JUDGE SMITH: What's your position on the motion .fc 7 now?
8 MR. TURK: Well, he's obviously not expert in the 9 area, Your Honor. He's testifying as a layman.
10 MR. FIERCE: I'm not offering this as expert 11 testimony. Just as rational inference based on the 12 information available.
13 JUDGE SMITH: The motion is sustained. 4 J 14 MR. TURK: Unless Mr.'Dignan wants it in. I mean f
\ 15 I'll defer. I haven't heard him yet.
16 MR. DIGNAN: I would just as soon let that stay in I
17 for impeachment purposes only.
18 JUDGE SMITH: Too late.
19 It's out.
20 MR. DIGNAN: .I was afraid of that.
21 JUDGE SMITH: Reask the question.
22 MR. DIGNAN: I can bring it back in without 23 incurring the wrath of the Board.
24 JUDGE SMITH: No, the objection is withdrawn.
25 Do you want it in or out?
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l 1 It's your call. j 2 MR. FIERCE: Oh, if it's withdrawn, I will have it 3 in. l 4 JUDGE SMITH: All right. It's in. q 5 Disregard previous ruling. l 1
6 MR. TURK: Thank you anyway, Your Honor. .
l 7 MR. DIGNAN: Is that a win or a loss? '
- 8. (Laughter) l 9 BY MR. FIERCE-l 10 Q Is there any way, Dr. High, you can quickly 11 explain to us why you believe that the Applicants did 12 include employees in their calculations?
13 A (High) Yes. -
14 I back-calculated the numbers provided in Table 15 3.6-1 of the SPMC, and found that they agreed to within, in l 16 one case, exactly. And in other cases, within a very small 17 amount, when you included employees in the calculation. And 18 were different by several hundred when you didn't include 19 employees in the calculation, f
20 Q Can you take an example like the Town of Newbury 21 from Table 3.6-1 and show us that calculation?
22 A (High) I need -- no, no, I need --
23 Q Appendix M? l l
24 A (High) I need Appendix M and I need 3.6.1.
25 (Witness locates document.)
L.
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F HIGH - REDIRECT 28015 1- A -(High) Okay.
O, We take the Town of Newbury for the summer peak.
Q 2 ..
3 population:given in Table 3.6.1.
4 Q Is that 3.6-17 5 A (High): 3.6-1.
- 6. The. Town of Newbury has 11,349 as the peak summer .
- 7. weekend population. It has from the.same document 5,479 8 residents, which then leaves us with 5,870.
9 Q You subtracted the --
10 A (High) Subtracting 5,479 from 11,-349, I arrive 11 at 5,870 remaining.
12 If I take the beach transients, which are given in-13 the NHRERP, Volume 6, the number of vehicles is 1,792, 14- multiply that by a vehicle occupancy rate of 2.4.
15 Q Is that from Volume 6 or from the Applicants' Avis 16 counts?
17 A- (High) I'm sorry, you are correct.
18' Q I'm not sure. j 19 A .(High) Let sne double check that.
20 Q If you.look at the bottom of the Table 3.6-1.
1 21 A (High) Yes.
22 Q It says --
23 A (High) I'm sorry, I'm sorry.
24 That is, as stated on the bottom of Table 3.6-1, 25 it's from the Avis air map and data.
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HIGH - REDIRECT 28015 1 We subtract the beach transient vehicles of 1,792 2 times an occupancy rate of 2.4. We obtain 4,300, leaving 3 now a population to be accounted for of 1,570.
4 If we then take the non-beach, non-EPZ beach 5 transient number of 249, that's from NHRERP, Appendix M, l l
6 multiply that by 2.4. We get 598. ,j i
7 Q Can you stop.and show me where in Appendix M that 8 number comes from? !
9 A (High) It's Appendix M. Newbury is on page M-1, ,
10 and there are shown for non-beach Node 2080, 249 vehicles.
11 JUDGE McCOLLOM: You said Newbury.
12 Didn't you mean Newburyport?
l 13 THE WITNESS: (High) No. No, I said Newbury. I 14 JUDGE McCOLLOM: Oh, -okay.
15 THE WITNESS: (High) This calculation is for 16 Newbury.
17 For Newbury, on page M-1 of Appendix M, there are 18 249 transient vehicles Multiply that by 2.4 as the 19 occupancy rates. Gives 598.
i 20 If that number is then subtracted, we're left with 21 972 persons left.
22 Now, if we look at the employee number, the non-i 23 beach employees for that same area, we see, again on page 24 M-1, that there two notes, each with 419 employee vehicles.
25 That makes 838 employee vehicles, j Heritage Reporting Corporation (202) 628-4888 )
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HIGH - RECROSS 28017 l
1 'If 838 employee vehicles is multiplied by the i
' 1
) 2 employee vehicle occupancy rate of 1.16.
s._,j 3 BY MR. FIERCE:
l 4 Q Where did you get that?
5 A (High) That's taken from the Applicants' --
6 Q Is that from volume 67 .i 7 A (High) Volume 6 of NHRERP. Also, Section 3.
8 That gives us exactly 972.
9 So the Table 3.6-1 in the SPMC comes out exactly 10 to the right number when you include the non-beach, non-EPZ ,
11 employee numbers.
12 And it was on that basis that I found that they 13 were counting employees as we also counted these employees
-g 14 in the calculation that I did.
\s_,/)
15 MR. FIERCE: I have no further questions.
16 MR. DIGNAN: I have a little recross.
17 RECROSS-EXAMINATION 18 BY MR. DIGNAN:
19 Q Doctor, did I hear you correctly that you 20 disagreed with our not including 50 percent of the transient 21 beach population because they are day trippers, and you said 22 you disagreed with it.
23 Were you reading from our testimony? I believe 24 your counsel pointed you to page 3 of our testimony?
} 25 Is that right?
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HIGH - RECROSS 28018 1 MR. FIERCE: Number 17?
2 MR. DIGNAN: Yes.
3 MR. FIERCE: Rebuttal Testimony No. 177 4 MR. DIGNAN: Yes.
5 THE WITNESS: (High) Are you asking me to read 6 from it? ,{
7 BY MR. DIGNAN:
8 Q No, no.
9 I said were you at that time. I thought you were.
10 Maybe I'm wrong.
11 A (High) No, I was not reading.
12 Oh, oh, I'm sorry.
13 I did refer to that, yes.
14 Q Okay.
15 A (High) Page 3.
16 Q If you look at page 3 that you said you don't 17 agree with, in the determination of the summer evacuee load 18 for the Beverly reception center, it was assumed that 50 19 percent of the transient beach population were day trippers.
20 This value was then subtracted from the summer 21 peak population because if the day trippers live in the EPZ, 22 they are already account for.
23 And that's true, isn't it?
24 They are already accounted for in the basic 25 population data; isn't that right?
Heritage Reporting Corporation 1 (202) 628-4888
r HIGH - RECROSS 28019 1 A (High) They are not accounted --
fq.
i
., ) 2 Q No, aren't they accounted as residents in the 3 clerk data, for example, if they live in the EPZ?
4 A (High) Not for that -- not for that evacuation 5 reception center.
6 Q Certainly they are. ,
- 7. .If what we are doing is adding up the populations 8 of the towns from the clerk's data, any resident of those 9 towns is already included, isn't it?
10 A (High) The residents of those towns are only i
11 included for those towns, and that is precisely the 7 12 percent number that I calculated.
13 Q Well, let's hold then the 7 percent.
,_s 14 Would you agree with me that if a day tripper
\s / 15 lives in the EPZ, you shouldn't count him twice, because 16 you've already got him as a resident of the town?
17 I understand you don't agree with 50 percent. But 18 whatever day tripper lives in the EPZ, you don't want to 19 count him twice, and you've already got him as a resident of 20 the town.
21 Isn't that right?
22 A (High) I agree that you don't want to count him 23 twice.
24 Q And you've already got him in the population data l l
25 coming out of the clerk's reports in the towns in the EPZ. j i
h)
'l ,
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l HIGH - RECROSS 28020 l 1 A (High) No , that's not correct.
2 The clerk's reports for those towns only include 3 residents of those towns. ;
1 4 Q That's correct.
5 A (High) In this case, Salisbury, Newburyport and 1
6 Newbury. ,
7 If they are residents of towns other than those, 8 even though they may be in the EPZ, they are not counted as 9 residents in the clerk's reports that I have used.
10 Q Well, they will be gcing to a New Hampshire town, l 11 right?
12 I mean if you are not in those Massachusetts towns 13 but you are in the EPZ, you are in a New Hampshire town, 14 right? !
15 Is that right?
16 Please don't tell me there is a third state in i 1
17 that EPZ. I'll die if I learn it now. You've got two l l
18 choices: New Hampshire or Massachusetts.
{
i 19 A (High) If you are not a resident of 20 Massachusetts, you are presumably a resident of New 1
21 Hampshire, j 22 Q If you are in the EPZ.
23 A (High) But these people --
24 Q No, no. l l
25 Isn't that right?
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HIGH'- RECROSS 28021 11 A (High)- Yes, I. suppose that's-obvious.
O A '2 Q And they are going to New Hampshire.
3 JL- -(High) I don't think they are going to go New 4 Hampshire. They receive an emergency broadcast message 5 which said, "Go to-the reception center of Beverly or North 6- Andover. You are.strongly recommended to receive .
<J '7. monitoring," or words.approximately to that effect.
8 Q No,Lno.
9- Do you'really think a New Hampshire resident is 10 going to take'off to Beverly?
11 Is that your theory?
12 13 p 14
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% 15, 16 17 18 19 20 21 22 23 24 25 b Heritage Reporting Corporation u (202) 628-4888
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HIGH - RECROSS 28022 1 Q If it'is, say so.
2 I am just trying to find out the assumptions you 3 are working on?
4 A (High) Those are the instructions which they 5 receive.
6 Q Okay. -
7 A (High) And that's the assumption I perceived.
8 Q Now, the other thing they say is: if the day-9 trippers live in the EPZ they're already counted for; and if 10 they live outside the EPZ their evacuation destination would 11 be outside the EPZ.
12 In other words, they aren't an evacuee, are they, 13 they're going to go home?
14 A (High) I don't think that's an' assumption that 15 you can make. They are being given instructions to go to a 16 monitoring station.
17 Q So that all of this testimony is based on your 18 assumptions as to human behavior, is that right?
19 A (High) No.
20 Q That they will obey, what you understand to be the 21 message they're going to get?
22 A (High) No, that's not correct.
23 I have made a set of calculations based on the 24 information before me. It's up to the Board to judge ,
25 whether that is useful or not.
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S HIGH.-: RECROSS 20023
- ,,q '1 Q Right.'
1 t 2 And that's what I'm getting at: the difference 3 between your number and our number comes down to one thing,
- 4. whether or not one agrees with our view the day-trippers 5 will go home. Or they agree with.your view that having.
6' heard what you understand to be the EBS' message, they will' .
7 all.go to the monitoring station, isn't that right, or 20 8 percent of them will?
9 A. (High) Not correct.
. 10 I have made a set of calculations of which that
11 number is an important part. That isn't all of my 12 calculation or of my testimony.
13 Q Well, didn't we agree that the additional numbers jr- 14 that you got out of the newer clerk's data didn't amount to
(
15 much?
16 And didn't we also agree that the shift of 17 populations between the beaches didn't add very much?
18 Indeed, the reason you wanted -- I'm not saying 19 this pejoratively -- but the reason it was important to 20 include.that shift in your data, in your explanation is 21 because if you didn't shift the population to 40 percent in 22 Massachusetts, if you stayed with 30 you-were dead on the 23 summer weekend because with the schools out you wouldn't get 24 an absolute number high enough to worry about; isn't that 25 right?
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l HIGH - RECROSS 28024 1 MR. FIERCE: Objection.
2 BY MR. DIGNAN:
3 Q Wasn't it right?
i 4 If you didn't make the population shift you 5 couldn't get the number up the height you did?
6 MR. FIERCE: Objection. There's an implication .
7 that he's trying to jack the number up. He did a 8 calculation.
9 MR. DIGNAN: Listen, Allan, let's all be lawyers, i 10 Of course, he's trying, just like my guy is trying to push l 11 it down. I don't mean it pejoratively.
12 MR. FIERCE: I have a witness that I don't think 13 was trying to do that, Tom, I'm sorry.
14 BY MR. DIGNAN:
15 Q I'm asking you, Doctor, isn't it true that if you 16 did not assume -- the population shift was not important, as 17 you said, in getting the real difference that we're talking 18 about.
19 But it was important to get to that number because 20 if you don't use that shift and you assume on a summer day 21 the schools aren't in session, the result is you'd never get 22 near the number that we're talking about?
23 A (High) Mr. Dignan, if I was to use all of the 24 assumptions that the Applicants used I would come out with 25 the same conclusion.
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HIGH - RECROSS 28025 1 Q Exactly.
2 A (High) I have used a different set of 3 assumptions.
4 Q That's what I wanted to get.
5 Now, the other thing is: you say you believe the 6 data shows 7.3 percent are residents of the EPZ. I submit .
7 to you that the 7.3 percent data you're referring to is 8 residents at the beach as opposed to the whole EPZ.
9 Are you sure of your use of that 7.37 10 A (High) Are you referring to my testimony now?
11 Q Yes.
12 A (High) Would you tell me the line you're 13 referring to?
14 Q Well, you discussed it with Dr. Cole.
O 15 You said that the 7.3 percent figure was the 16 figure which would be double counted because 7.3 percent of 17 the people on the beach area live in the EPZ?
18 A (High) I said 7.3 percent of the people on the 19 beaches at that time on a peak summer day were residents of 20 those towns in which those beaches were.
21 Q So it is the beach area?
22 A (High) The people in the beach area who are 23 residents of those towns. The three I referred to:
24 Salisbury; Newburyport; and Newbury.
25 Q Now, what data do you rely on for that number?
O Heritage Reporting Corporation (202) 628-4888
HIGH - RECROSS 28026 1 You had a piece of paper; could I have it? You 1 2 were reading from a piece of paper as you answered those i
3 questions; may I have it, sir? j l
4 A (High) Which? i 5 MR. FIERCE: It was the attachment to the New ]
l 6 Hampshire Yankee memorandum or chart. .;
J 7 MR. DIGNAN: If I could just have the piece of 8 paper the witness was reading from.
9 MR. FIERCE: Which he said, summarizes Appendix M 10 data.
11 THE WITNESS: (High) That is the same as Appendix 12 M data except that Appendix M data is many several pages of 13 it with many numbers. That is a summary of it and I believe 14 that it comes --
15 BY MR. DIGNAN:
16 Q Would you point to me how you got the 7.3 number 17 from this?
18 A (High) Yes.
19 Q In this column of these communities, which are in 20 Massachusetts, the number of peak period vehicles for this 21 period 1985 was, if you tally those three number, 10,639.
22 The number vehicles of residents was 107, 208 and 23 465 which together make 780, given us a percentage of 7.3. j l
24 Q Now, where did you get that column beginning with l 1
25 107 from? Where did you get that data?
Heritage Reporting Corporation (202) 628-4888
HIGH - RECROSS 28027
.. 1 A (High) From the source.
i /'N '
.( ) 2 Q From that source?
-v 3 A (High) Yes.
4 Q All right,.let me have it.
5 JUDGE SMITH: We should bind that into the 6 transcript. .
7 MR. TRAFICONTE: Why don't we mark it as the next 8 exhibit.
9 JUDGE SMITH: Well, if you just bind it in the 10 transcript and it will be right where he has been cross-11 examined on it.
12 (Estimated weekend vehicle
- 13. counts and peak population 14 for beach areas 15 1985/1987 follows:)
16 17 18 19 20 21 22 23 24 25
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i1 HIGH --RECROSS 28028 1 E MR. DIGNAN: Did the Board indicate they wanted ,.
l 2 this in the record?
3 JUDGE COLE: Yes.
4 MR. FIERCE: Here is the memorandum it comes,from.
5 And tnat' attachment in our copy, in our original copy looks 6 like that. .l 7 I think we can figure outlwhat the town say: it's 8 Plum Island South; Newbury: Rowley; and Ipswich; then it's 9 Plum Island North; Newburyport; then it's Salisbury; then.
10 it's Seabrook; Hampton Beach South; and I'm not sure, 11 something again South and Route 51; then Hampton Beach 12 . North; and then Northampton.
13 MR. TURK: It would be in Volume 6.
14 MR._TRAFICONTE: No,'it's a compilation.
t L 15 MR. FIERCE: This is a compilation.
16 JUDGE SMITH: By whom? -
17 MR. FIERCE: Data that appears in Appendix M. f 18 JUDGE SMITH: By whom?
19 MR. TRAFICONTE: This is produced by Applicants. i l
20 MR. FIERCE: Well, I think we should say for.the 21 record it comes from -- and Dr. High mentioned this before 22 -- New Hampshire Yankee memorandum which has the number 23 SEP892119, it's dated May 31st, 1989.
Subject:
evaluation 24 of reception center staffing from D. Bovino; S. Hertel; J.
25- McArdle; and S. Bisson to D.R. Tailleart.
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HIGH - RECROSS 28029 1
1 And the cover sheet on the whole memo -- there's 2 many attachments -- says: "This memo demonstrates the 3 complete evaluation of vehicle monitors and number of ]
4 registration needed at the ORO reception centers. Please (
5 find attached the calculations and conclusions used to 6 analyze these two areas of review." .
7 8
1
}
9 j 10 11 12 13 14 l
15 16 . !
17 18 19 20 21 22 . 1 1
1 23 24 1
25 !
l
(
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HIGH - RECROSS 28030 1 ' JUDGE SMITH: Do you object to binding that in?
[},, Well,'could we reach the decision to MR. DIGNAN:
Q' 2 -
3 bind it'in later or what status it's going to get.
4 If you are just binding it in for the convenience
.5 of the Board following.the exam at this point, I have'-no L '6- . objection to that procedure. .
-7 JUDGE SMITH: Well, that was the primary. purpose.
8- MR. DIGNAN: Okay, that's fine.
9 In other words, there is no admission into 10 evidence at this point.
I 11 JUDGE SMITH: All right, that will be fine.
12' MR. DIGNAN: That's all I'm --
13 JUDGE SMITH: Until we address it further.
Yes, oka~y.
j- 14 MR. DIGNAN:
15_ (Counsel sits at witness table.)
- 16. MR. DIGNAN: Doctor, if you don't mind my joining 17 you here at the table.
18 THE WITNESS: (High) A pleasure, Mr. Dignan.
19 JUDGE McCOLLOM: Why don't you turn that 20 microphone around, Mr. Dignan?
21 MR. DIGNAN: And believe me, I'm not doing it for 22 any tactical reason. It's just that the reporter gets very 23 upset with me if I don't talk right into a mike, and 24- rightfully so.
25 JUDGE SMITH: And he's not under oath either.
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h-_---_d--a._.m__.u._.___g y_z.._CM e *: e > .
HIGH - RECROSS 28031 1- (Laughter.)
7g .
MR. DIGNAN: I'm not under oath. Never.
() 2 3 BY MR. DIGNAN:
4 Q Doctor, you have assumed, in using this document, 5 that the word " residents" as heading that column means 6 residents of the town as a whole. .
7 Isn't that right?
8 A (High) That's correct.
9 Q I am now directing your attention to Appendix M, 10 which is the raw data this came from. And let us take, for 11 example, the reference to 2084, Plum Island North, 12 Newburyport. ..
13 Do you see that in that column?
.,s -
14 A (High) Yes.
f\
\s ,/ 15 Q And I would like to direct you to the Appendix M 16 which is the estimated traffic demands at all origin 17 centroids, loading rates and origin destination patterns.
18 And that figure 208 appears, does it not. in the 19 table next to Centroid 20817 20 A (High) Yes, it does.
21 Q And what I submit to you, Doctor, is that these 22 are simply the resi, dents who originate at those centroids, 23 namely, the beach centroids, rather than the residents of 24 the whole town.
25 And I'm going to ask you take a moment.
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HIGH - RECROSS 28032 1 MR. DIGNAN: And if this is a convenient time for 2 the afternoon break, Your Honor, so that the witness can do 3 this without any pressure on him. ,
4 BY MR. DIGNAN.
5 Q And review Appendix M, the traffic demand for ;
6 Scenarios 1 and 2, and see if you can't satisfy yourself -
7 that this word " residents" up here which I agree appears, 8 actually refers to much less than the residents of the 9 entire town. But in fact refers only to the residents who 10 originated at the particular centroids that are near the 11 beach.
12 MR. DIGNAN: And with that, Your Honor, if we 13 could have a break and then the witness could perhaps give 14 us his answer, if that's agreeable to the' Board.
15 It will take him a moment, I'm sure, to review 16 this. -
17 JUDGE SMITH: All right.
18 Fifteen minutes.
19 (Whereupon, a recess was taken.)
20 JUDGE SMITH: Are you ready, Dr. High?
21 THE WITNESS: (High) Yes.
l 22 JUDGE SMITH: Mr. Dignan.
23 BY MR. DIGNAN:
24 Q Doctor, are you in a position to address the 25 question I asked you before the break?
l Heritage Reporting Corporation (202) 628-4888 l
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HIGH - RECROSS 28033 1 A (High) .Yes.
( / 2 Q 'Okay, could-you do so,.please, in your.own words? j 1
3- A- (High) Yes.
]
4 I would like to concede that the residents number 5 provided in the document taken from New Hampshire Yankee 6 SEP 89-2110 and listed as " Residents" in that table, .
7 referring to the original data from which that was .
i 8 tabulated, it's clear that the residents number includes
)
9 only those residents from the beach centroids areas, and not 10 residents from other parts of those towns.
11 Q Thank you.
12 MR. DIGNAN: At this point, Your Honor, I'm sor7.y, i
13 have we bound this in?
14 JUDGE SMITH: Not as evidence.
,7-~g
\_, 15 MR. DIGNAN: No, but I don't care to have it bound i
16 in as evidence. If anyone does, they can make their motion 17 now. Otherwise, I'm content to leave it just bound in so 18 that you can follow the examination.
19 JUDGE SMITH: All it does is explain his i
20 testimony.
21 MR. DIGNAN: All right. Thank you, i
22 THE WITNESS: (High) May I add an additional 23 point?
24- BY MR. DIGNAN:
i 25 Q Yes, certainly, Doctor.
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i HIGH - RECROSS 28034 l 1 A (High) That means that the 7 percent is still 2 correct allowance for double counting and should be i 3 subtracted as I did.
I' 4 Q Dut possibly more should be subtracted also?
5 A (High) But there is an unknown number for which 6 we have no data of others who may be on the beach and may 7 also be double counted.
8 I have no evidence before me to make an exact 9 estimate of what that number is.
10 Q Doctor, in your discussion with Mr. Turk, the NRC 11 counsel, you indicated that, when you were discussing data, i 12 you had no reason to believe that where photographs were 13 taken in the afternoon, the population distribution as 14 between the Massachusetts and New Hampshire beaches would be 15 any different than -- in terms of percentages I'm talking 16 about -- than it would be at the peak hour.
17 Do you recall that testimony?
18 A (High) Yes.
19 Q You are reasonably familiar with the beach area, 20 are you not? ,
21 A (High) Yes. I 22 Q Now, in Salisbury and near the Salisbury Beach, 23 there is an amusement park, is there not?
24 A (High) There is.
25 Q In your observations up there, have you come to l
l l
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il HIGH - RECROSS 28035 I
s 1 observe that perhaps a number of people leave the New 1 yN -
jq ,) ' '
2 Hampshire beaches at.or later than the peak to repair over 3 to the amusement park in Salisbury? ,
4 A (High) I'have not been there at the moment when 5 this movement of people from one area to the other is 6 alleged to have taken place. .;
7 It seems possible that it might, but observations 8 made by colleagues and others that I have spoken to ,
l 9 -indicates that it probably takes place-late in the j 10 afternoon, probably after the sundown or at least in the l 11 early dusk period when people are no longer interested in I
- 12. beach activities and prefer amusement. parks.
13 But I can't speak to the exact time at which that i
~
gs 14 movement, if it takes place, occurs.
, s_s 15 Q In any event, we are agreed, however, that there
.16 ' is no attraction up on the New Hampshire area similar to the 17 Salisbury Beach amusement park.
18 Is that right?
19 A (High) I don't know.
20 MR. DIGNAN: That's all I have, Your Honor.
21 Thank you, Doctor.
s 22 MR. TURK: I have a little bit of follow-on, Your 23 Honor.
24 l l
25 i l
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HIGH - RECROSS 28036 l
1 RECROSS-EXAMINATION l 2 BY MR. TURK:
3 Q Getting back to this deduction of 7 percent for
! 4 residents which we have now established are only those 5 persons whose trips originate near the beach areas. )
i 6 What towns are reflected in that 7 percent again, ]
7 or portions of which towns are reflected in that 7 percent?
8 A (High) Newbury, Newburyport, and Salisbury.
9 Q Not Amesbury?
10 A (High) Not Amesbury.
11 Q And not West Newbury?
12 A (High) Not West Newbury.
13 Q And not Merrimac?
14 A (High) Not Merrimac.-
15 The table, which has been bound into evidence from
, 16 New Hampshire Yankee's SEP 89-2119, also includes for the 17 area designated Plum Island South some persons from Rowley 16 and Ipswich. But I think that those numbers are quite small 19 and probably don't materially affect the calculation. It 20 might alter it by a very small fraction.
21 Q Do you know to what extent the resident population ,
l 22 of Newbury, Newburyport, and Salisbury are reflected in that i 23 7 percent data?
l 24 A (High) The resident population?
25 Q What percentage of the resident population, i
l 4
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..,i st 4
W l' HIGH - RECROSS 28037 j W 4
~
1 permanent resident population.of those three towns is ;
/ :2 reflect'ed in the 7 percent data?
3 A . (High) No, I don't know that percentage without 4 further reference.
5 Q .It could be substantially less1than all of the
'6 residents of the town, right? .
7 'A
-(High) .I'm sorry, I don't know the numbers.
,e 8 -Q You don't know either way.
9 There.was some testimony, earlier today in which 10 you expressed your opinion that people will follow .
11 directions to go to the reception centers, and I think we 12 established that you don't have any particular expertise in 13 that area, but you were expressing your opinion based on
- g. 14 common sense.
! \
k/s 15 Did you make any assumptions about what persons on 16- the beach might do with respect to going home first before-17 they leave the EPZ?
18 A (High) No, I didn't make any; assumptions.
19 Q You assume that they would not go home first?
- 20 A (High) Oh, well, the' assumption implicit in the 21~ calculation is that they would follow the instruction given 22 to them. And that 20 percent of.those, as the Board as 23 . determined for New Hampshire, would actually arrive at the-24 evacuation reception centers.
25 So, implicit in my work was that 20 percent would ;
I l
Heritage Reporting Corporation s (202) 628-4888 .
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HIGH - RECROSS 28038 1 a'rrive at the evacuation center as the Board had determined. l 2 As was clear from earlier drafts, I don't 3 necessarily support that point, but I'm using it for this 4 calculation. l l
5 Q Persons who live in other EPZ towns such as New 6 Hampshire towns who may go to Salisbury Beach which is, ,
7 'obviously as we all know, those of us who have been there, 8 it's an attractive, large state park beach, right?
9 A (High) Yes.
10 Q Nice sand dunes.
l 11 A (High) Very attractive.
1 l
12 Q Convenient parking. !
13 And there are persons from New Hampshire who may 14 well be in the Salisbury Beach' ares, correct?
15 A (High) There must be some.
16 Q But you assume that they went to the reception !
17 center identified for Salisbury, right? j 18 A (High) I assume that 20 percent of them did as in 19 the formula of the Board.
(
l 20 Q Now did you give any consideration at all to the 21 possibility that those persons might want to return to their l 22 homes in New Hampshire to pick up other family members 23 before going to a reception center?
24 A (High) I assumed that that was taken care of in 25 the 20 percent.
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HIGH - RECROSS 28039 1 Q How does that follow?
s 2 A (High) Well, only 20 percent of them actually 3 arrive at the reception center, according to the formula.
4 Q At some reception center. .
l 5 A (High) At this particular reception center from 6 that particular designated locations. ..
i 7 Q ' But if I followed if your logic, you assume that 8 20 percent of the persons at the Salisbury Beach will go to 9 the reception center designated for Salisbury Beach.
10 A (High) Yes.
11 Q And in doing that, aren't you really assuming that 12 they are not going to go to their homes in New Hampshire, if 13 that's where they live, first to pick up their wives or 14 children or parents, and then possibly going on to the 9 15 reception center for their hometowns?
16 A (High) I'm assuming that 20 percent of them would 17 go directly. The other --
18 Q Directly to the reception center for Salisbury?
19 A (High) To the reception center designated.
20 The remaining 80 percent in this calculation are 21 assumed to do something else which might include going home 22 to pick up their families. It might include not going to a 23 reception center at all. It may include going off to 24 Boston.
25 Q You also didn't make any assumptions that persons G Heritage Reporting Corporation (202) 628-4888
HIGH - RECROSS 28040 1 might go to their homes elsewhere in the EPZ in order to 2 lock the house before evacuating.
3 A (High) Again, those who might do that, and 4 clearly some would, would presumably be included in the 80 5 percent of those who did not go directly to the reception j 6 center.
7 Q And similarly, you didn't make any assumptions 8 that persons might go home to remove their valuables or to j 9 bring clothing with them for what could be a several day or 10 an extended stay away from home. You made no assumptions 11 about that.
12 MR. FIERCE: Objection, Your Honor.
13 I'm going to object to this basic line. I mean 14 what Dr. High testified to is he took the Board's formula. l 15 He said he isn't here making human behavior assumptions.
(-
16 The Board's formula was there and he plugged in 17 the numbers that we have available.
18 Now he's going to say "no" to a whole series of 19 questions we can put to him, and you didn't assume this and
.20 you didn't assume that.
21 JUDGE SMITH: Well, he claims some expertise and 22 then sort of backed away from it.
23 MR. FIERCE: His expertise is in the areas that we 24 have stated: in the aerial photo interpretation and 25 statistical analysis.
Heritage Reporting Corporation (202) 628-4888
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HIGH - RECROSS 28041 1 Only the observations that would be rational
/'~') l
- 5. ,/ 2 inferences.
3 JUDGE SMITH: He had no air photo basis nor 4 statistical basis for his previous testimony, nor does he 5 now. He's the one that decided he would go beyond 6 statistics and air photo interpretation in expressing an .
7 opinion.
8 ~MR. DOUGHTY: Your Honor, if I may add to Mr.
9 Fierce's point.
10 The history of SAPL-31, which is the contention 11 that_ generated this whole ETE litigation that has developed 12 was filed originally by SAPL. And one of the bases that was 13 thrown out by the Board that is constituted and preceding es 14 your ruling was the basis for '- we would have litigated the
/ \
klm 15 issue of whether people would go other where than where they 16 were directed by the KLD ETE study. And the ability to do 17 that, and any adverse impact of ETEs was thrown out.
18 And so now they are trying to impeach the witness 19 on something that they advocated should be disallowed 'as a 20 basis for a contention way back in the ions before.
21 MR. FIERCE: It was also ruled on by the Board in 22 the PID in terms of where drivers would go. It's some of 23 that issue.
24 But we basically have the Board's PID, and he I
c 25 filled in the number. l l l Heritage Reporting Corporation a,_ (202) 628-4888
, ____.J
HIGH - RECROSS 28042
('
1 JUDGE SMITH: But this line now is not that people 2 will go where they are told to go, but who are these people 3 and what are they told.
4 MR. TURK: It really goes to his calculation, Your 5 Honor. He has deducted out 7 percent of residents to avoid 6 double counting. And I'm trying to establish that he's ,
7 using the wrong number.
8 9
10 11 12 13 14 15 16 17 18 19 20 21 l 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
l:
HIGH - RECROSS 28043
,_~s 1 MR. TURK: My point is that New Hampshire I
\
T{s ,/ 2 residents are going to go to New Hampshire or likely go to 3 New Hampshire, get their families, close their house, get 4' their clothes, and then evacuate.
5 JUDGE SMITH: The ultimate point that you' re 6 making, if it's going to be within the scope of the issues .l 7 we admitted was that the New Hampshire people will go to New 8 Hampshire monitoring centers as told even though they happen 9 to be at Massachusetts beaches at the time the instructions .
10 are given.
11 Is that it?
12- MR. TURK: Not directly.
13 I'm trying to establish that there has already
,r~s 14 been a counting for those persons; and they're counted in A 15 the reception center numbers for New Hampshire.
16 JUDGE SMITH: But their point is, it may be that 17 you counted so many for New Hampshire, but we're talking 18 about Massachusetts now. You may have even a surplus up in 19 New Hampshire, but Massachusetts is going to be overloaded. !
20 MR. TURK: In other words, count these New 21 Hampshire persons in Massachusetts as well as in New l
22 Hampshire.
23 JUDGE SMITH: Yes.
24 MR. FIERCE: 20 percent of them.
25 MR. TURK: Is that the assertion?
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HIGH - RECROSS 28044 1 JUDGE SMITH: They're going to say, bygones are Now we're I 2 bygones, we don't agree with that decision.
3 talking about Massachusetts. l 4 MR. FIERCE: Just to clarify the argument, Your 5 Honor. 20 percent of the beachgoers in Massachusetts are 6 assumed to go the Beverly reception center in Dr. High' s .
7 calculation. It may well be that among the other 00 percent i
8 are all the other New Hampshire people who didn't go. It's 9 not part of the calculation.
10 It may well be that all of the New Hampshire 11 people went home. But 20 percent of the people on the 12 Massachusetts beaches are assumed by Dr. High to go to the 13 reception center.
14 And he doesn't make a human behavior assumption 15 like the Applicants did that somehow 50 percent of the 16 beachgoers are those who live outside the EPZ and they will 17 not go reception centers. He's not making that judgment.
18 He's following the Board's formula, plugging in the numbers 19 that we have for Massachusetts and really, is not making a 20 series of assumptions that seem -- we can go on and on.
21 But there is no implication here that Dr. High has 22 New Hampshire people either going to the reception center or 23 not going. But clearly, 20 percent of the people on those 24 Massachusetts beaches are going to go to the Salisbury and l
25 Plum Island designated center which is Beverly.
Heritage Reporting Corporation (202) 628-4888
4
! HIGH - RECROSS 28045 j- 1 MR.= TURK: Less the Massachusetts: residents.
I
\, 2 He makes a deduction from Massachusetts residents.
I 3 MR. FIERCE: 1He makes the'same-reduction that the 4 Applicants have done when they calculate what the total peak 5 population.is. That's.where he starts and he explained how
, 6 he got there. The total peak population number is part of .
7 the: formula that the Applicants used; that the Board used in 8 the-PID; and that Dr. High has used. The total peak 9 population number is a number which includes not the sum.
10 total of the permanent residents and the total beach 11 population, but the total beach population is discounted by 12 7 percent.
13 Now we say that we have learned because of the gN 14 number of people who would be double counted on those beach 15 centroids.
16 So that's how you get to the permanent resident --
17 the total peak number, in addition, adding in some employees 18 who live outside the EPZ and some transients who live 19 outside the EPZ; we say that is what the Applicants have 20 done to get to the number they have for summer weekend peak 21 in table 3.6-1 of the SPMC.
22 JUDGE SMITH: It's time to bring this tu) a close I 23 believe.
J 24 MR. TURK: I have no further questions, Your 25 Honor.
O Heritage Reporting Corporation (202) 628-4888 l l
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HIGH - REDIRECT 28046 1 JUDGE SMITH: What do you have? i 2 MR. FIERCE: I guess about two.
3 JUDGE SMITH: All right.
- J 4 FURTHER REDIRECT EXAMINATION 5 BY MR. FIERCE:
6 Q Just following up on Mr. Dignan's question about 7 the amusement park. There are some night club attractions; 8 are you familiar with Club Casino in the Hampton Beach area?
9 A (High) I am familiar -- I've driven past it.
l l 10 (Laughter) 11 BY MR. FIERCE:
12 Q How large a facility is that?
13 A (High) I think it would attract quite a lot of 14 people.
15 (Laughter) 16 BY MR. FIERCE:
17 Q Quite a lot of people meaning --
18 MR. DIGNAN: The right kind or wrong kind.
19 '(Laughter.)
20 BY MR. FIERCE:
21 Q This is not a small night club with a few chairs 22 at the bar, shall we say. Is it large?
23 A (High) It's a large facility.
24 Q And it plays big name entertainment?
25 A (High) I believe it does, yes.
i.
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HIGH.- REDIRECT 28047 1 Yes, it does. It's a large facility.
t i j
_, ) 2 Q .Just one point on this New Hampshire residents.
3 Is it your understanding that if people are on 4 Salisbury Beach the way the traffic guides are established 5 they would be discouraged from traveling north --
6 MR. TJRK: Objection, Your Honor. .
7 JUDGE SMITH: Well, I think that --
8 MR. TURK: There's no traffic guide in the aerial 9 photos;-and that's the expertise.
10 JUDGE SMITH: The traffic guide information is 11 already well established. You don't need his interpretation 12 of it.
13 BY MR. FIERCE:
-- 14 Q And just one last one.
N- / 15 If there is somebody from Merrimac on the EPZ --
16 on the Massachusetts EPZ beach and we know that all the 17 beaches are assigned to go to Beverly, and the Town of 18 Merrimac residsnts are assigned to go to North Andover, do 19 you have any rational inference on where that person might i 20 go to a reception center?
21 MR. TURK: The witness' facial expressions 22 indicate he does not.
23 (Laughter) 24 MR. TRAFICONTE: Mr. Turk, you're developing an 25 expertise here. Apparently, you' re able to read facial 7-s Heritage Reporting Corporation
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HIGH REDIRECT 28048 1 expressions.
2 (Laughter) 3 THE WITNESS: (High) Mr. Fierce --
4 BY MR. FIERCE:
5 Q Let me put the question a slightly different way.
6 A (High) I'm not quite sure. ,)
7 Q Would it be double counting -- let's put it that 8 way -- if a resident from Merrimac were on Salisbury Beach 9 and after hearing an emergency message went to the Beverly 10 reception center?
11 A (High) No, that wouldn't be double counting for 12 the purposes of this piece of analysis. I don't speak to 13 ETEs or other matters. With respect to this analysis, it 14 would not be double counting.
15 MR. FIERCE: No further questions.
16 JUDGE SMITH: Anything further?
l 17 (No response) 18 JUDGE SMITH: You're excused, thank you.
19 THE WITNESS: (High) Thank you, Your Honor.
20 (The witness was excused.)
21 MR. FIERCE: That's all we have for today, Your '
22 Honor.
23 I just want to quickly review the schedule. I do 24 have Ortwin Renn coming tomorrow morning.
25 What's the Board's pleasur7 on the starting time? 'l Heritage Reporting Corporation (202) 628-4888 1
1 I
i
28049 1L - He is to be followed by the Lieberman ETE' panel j-
'I 2 and I believe I do not have a long cross at all for them.
3 MR. DIGNAN: What about,-is Adler going to have a 4 piece on commuters?
5 MR. FIERCE: I'm promised a piece on commuters f h 6 sometime' tomorrow from him. I can't promise it will be in .
l 7 the morning. It's more likely to be in the afternoon and 8 perhaps toward the later part of the afternoon.
9 MR. TURK:. Then you got to finish Lieberman
, 10 tomorrow night.
11 MR. FIERCE: I will finish Lieberman if I started 12 with him after lunch at 1: 00, probably the middle of the 13 afternoon.
e 14 JUDGE SMITH: The rep'orting personnel had a big f"
k,
- 15 day yesterday. Let them go early today, if we can.
16 Anything further on the record?
17 MR. FIERCE: What time should I have Mr. Renn 18' here, 8:30 or 9 o' clock?
19 JUDGE SMITH: 8:30.
20 Anything else on the record?
21 MR. TRAFICONTE: When are we going to talk about 22 proposed findings?
23 JUDGE SMITH: Yes, proposed findings.
24 We can discuss it and then report --
25 MR. TRAFICONTE: Off the record we can discuss it.
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l l 28050 1 JUDGE SMITH: Off the record.
2 MR. TRAFICONTE: I see, yes.
3 That's fine.
~
4 JUDGE SMITH: If you don't mind.
5 MR. TRAFICONTE: I don't mind.
6 But I would just go back to the -- well, why don't 7 we go off the record, because none of this has to be on the i
8 record.
9 JUDGE SMITH: All right. ;
10 Off the record.
11 (Whereupon, at 4:15 p.m. the hearing was adjourned 12 to reconvene tomorrow morning at 9:00 a.m., Thursday, 13 June 29, 1989.)
14 I
15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
i Li CERTIFICATE O j
]
1 1
This is to certify'that the attached proceedings before the. ]
United States Nuclear Regulatory Commission in'the matter a
of -
Name:. Public Service Company of New Hampshire, et al.
(Seabrook Station, -Units 1 and 2)
Docket.No: 50-443-OL
.50-444-OL (Off-site Emergency Planning).
Place: Boston, Massachusetts Date:- June 28, 1989 were held as herein appears, an'd that this is the' original-
^(A
") transcript thereof for the file of the United States Nuclear Regulatory Commission taken stenographically by me and, thereafter reduced to typewriting by me or under the direction of the court reporting company, and that the transcript is a true and accurate' record of the foregoing proceedings.
/S/ J if (
(Signature typed) : Donna L. Cook Official Reporter Heritage Reporting Corporation HERITAGE REPORTING CORPORATION (202)628-4888
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