ML20247F769
| ML20247F769 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 05/24/1989 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#289-8701 ASLBP, OL, NUDOCS 8905300171 | |
| Download: ML20247F769 (400) | |
Text
-- - - -
U--
r UNITED STATES NUCLEAR REGULATORY COMMISSION i;
W 3, g .
I g o.........................................................
ATOMIC SAFETY AND LICENSING BOARD In the Matter of: )
> . ) Docket Nos.
PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et al., ) 50-444-OL
) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING Pages: 22507 through 22783 Place: Boston, Massachusetts Date: May 24, 1989 SEh EhEhh.
, bo\
HERITAGE REPORTING CORPORATION OglaisfRaperfar 1220 L Street, N.W., Sake 600
%g gjG8g Washington, D.C. 200H (282) 62 HISS pcL s+0s30o272 spos;4 (DR ADOCK 05000443PDC l
K ,
il 22507
- r. . UNITED STATES NUCLEAR REGULATORY COMMISSION 7 ,e-
-(w/-
I ATOMIC SAFETY AND LICENSING BOARD L In the Matter of: )
) Docket Nos.
PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et al., ) 50-444-OL
) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING c-l EVIDENTIARY HEARING Wednesday, u
May, 24, 1989 Auditorium i Thomas P. O'Neill, Jr.
Federal Building 10 Causeway Street Boston, Massachusetts The above-entitled matter came on for hearing,
>T pursuant to notice, at 9:07 a.m.
BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JUDGE KENNETH A. McCOLLOM, Member Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JUDGE RICHARD F. COLE, MEMBER Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Heritage Reporting Corporation
' (202) 628-4888
l.
22506 APPEARANCES:
For the Applicant:
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.
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 Emeroency Management Acency:
H. JOSEPH FLYNN, ESQ.
LINDA HUBER McPHETERS, ESQ.
Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C. 20472 For the Commonwealth of Massachusetts:
JAMES M. SHANNON, ATTY. GEN.
JOHN C. TRAFICONTE, ASST. ATTY, GEN.
AL LAN R. FIERCE, ASST. ATTY. GEN.
PA1 TELA TALBOT, ASST. ATTY. GEN.
MATTHEW BROCK, ESQ.
LESLIE B. GREER, ESQ.
Commonwealth of Massachusetts One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Heritage Reporting Corporation (202) 628-4888
L 22509 APPEARANCES: (Continued) s f% ;.
\m/ For the State of New Hampshire:
GEOFFREY M. HUNTINGTON, ASST. ATTY. GEN.
State of New Hampshire 25 Capitol Street Concord, New Hampshire 03301 f pr the Seacoast Anti-Pollution Leacue:
RO3ERT A. BACKUS, ESQ.
Backus, Meyer & Solomon 116 Lowell Street P.O. Box 516 Manchester, New Hampshire 03105 JANE DOUGHTY, Director Seacoast Anti-Pollution League 5 Market Street Portsmouth, New Hampshire 03801 Il For the Town of Amesbury:
BARBARA J. SAINT ANDRE, ESQ.
Kopelman and Paige, P.C.
77 Franklin Street Boston, Massachusetts
\m./
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:
EARBARA J. SAINT ANDRE, ESQ.
JANE O'MALLEY, ESQ.
Kopelman and Paige, P.C.
77 Franklin Street Boston, Massachusetts 02110 Heritage Reporting Corporation (202) 628-4888
}
V
22510 APPEARANCES: (Continued)
For the Town of Newburv:
R. SCOTT HILL-WHILTON, ESQ.
Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street Newburyport, Massachusetts 01950 For the Town of Salisbury:
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 01050 For the Atomic Safety and Licensino Board:
ROBERT R. PIERCE, ESQUIRE Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Heritage Reporting Corporation (202) 628-4888
22511 1 EDEX l, 's DIRECT CROSS. REDIRECT RECROSS EXAM (y l- WITNESSES:
Witness:
Richard W. Donovan by Mr. Traficonte 22514 (Continued) 22667 by Judge Cole by Ms. Chan 22669 by Mr. Dignan 22671 by Mr. Flynn 22674 by Mr. Traficonte 22686 Panel 23:
John W. Baer Anthony M. Callendrello George R. Gram (Prefiled) 22702 by Mr. Lewald 22692 by lir. Brock 22703 EXHIBITS: IDENT. BEC. REJ. DESCRIPTION:
O Mass AG 101 22608 22608 Blank set of FEMA EEM objectives 97 Prev. 22666 REP exercise process for FEMA by Theodore Sarry &
Associates, August 1985 Heritage Reporting Corporation g
(202) 628-4888 (J
22512 J H P_ E X INSERTS: PAGE j Resmne of 22694 George R. Gram II Resume of 22695 John W. Baer Applicants' Rebuttal 22702 Testimony No. 23 Regarding Scope of Graded Exercise O
l i
Heritage Reporting Corporation '
I (202) 628-4888 i
l l
I
_ _ . _ _ _ _ _ _ _ _ _ _ . _ . _ . _ _ _ _ _ _ _ _ . . ._. _ J
22513 1 E B'Q Q E E Q I N G E
- j. p
( 2 JUDGE SMITH: Good morning.
..( ' '
3- Is there any preliminary business?-
- 4 MR. TRAFICONTE
- Your Honor r there is only a very 5 short piece of preliminary business.
6 .I just want to notify, primarily the parties,-but 7 also the' Board as to the Mass AG's present intent. At.or 8- around noontime today in the absence of any relief from the 9 Appeal Board on our motion seeking to have this Board's 10 order of Monday, May 22nd dismissing Contention EX-13, Basis 11 D.
12 JUDGE SMITH: 19.
13 MR. TRAFICONTE: Sorry. -EX-19, Basis D and 14 expunging it.from the record. In the absence of relief, I 15 either in the form of a stay or in the form of a. reversal of 16 that order by noontime, it's the Mass AG's intent to present 17 to the Commission a late filed contention with that same 18 identical language, based on the ruling of this Board that 19 EX-19, Basis D is material and relevant to a low-power 20 license. And for that reason the Board erred when.it-21 admitted it did not have jurisdiction.
22- We would take the same contention and bases and i
23 with that holding and ruling of Monday and present it to the 24 full Commission; and we intend to do that in the form of a 25 motion for admission of late filed contention at or around Heritage Reporting Corporation (202) 628-4888
(
1
DONOVAN - CROSS 22514 1 noontime today.
2 JUDGE SMITH: Any other preliminary business?
3 (No response) 4 Whereupon, 5 RICHARD W. DONOVAN 6 having been previously duly sworn, resumed the witness stand 7 herein, and was examined and further testified as follows:
8 CROSS-EXAMINATION (Continued) 9 BY MR. TRAFICONTE:
10 Q Good morning, Mr. Donovan.
11 A (Donovan) Good morning.
12 _Q That's the earliest I've had an opportunity to say 13 good morning to you.
14 I would like to pick up pretty much where we left 15 off yesterday. I had some questions about New Hampshire 16 schools and I may have inartfully asked you I think the very 17 last question on the record from yesterday.
18 It's a fact, is it not, that schools in New 19 Hampshire were not in session on either of the two exercise 20 days; correct?
21 A (Donovan) By schools in session, if you mean 22 students in attendance at schools, that's correct.
23 Q Right.
24 But the exercise simulated, did it not, that it l I
25 was a school day? l Heritago Reporting Corporation (202) 628-4888 1
l
S DONOVAN - CROSS. ~22515
, 11L - A' ;(Donovan) Yes, it did.-
.ML f 2 Q And it did that-both'in New Hampshire and 3 Massachusetts?
4- A (Donovan) That's correct.
.5- Q Now you recall that I asked you a series ~of 6 questions concerning the EBS, the ORO EBS message number 7 three.
8 Do you recall those questions?
l _
9 A (Donovan) Yes, I do.
10 Q And then you recall that I pointed out to you that 11 at some point, approximately at 1536 I believe EBS number 12 three was released to the news media in the form of a news 13 release; correct?
14 A (Donovan) That's correct.
[ ,
15 Q And you also recall your testimony concerning what
\
16 the purpose of using news releases or making news releases l17 .i s .
18 Do you recall that testimony?
l 19 A (Donovan) I believe I do.
20 Q All right.
21 Now, just to summarize.that line: it's a fair 22 statement, is it not, that in your opinion news releases are 23 not designed to notify the public of' protective action 24 recommendations- correct?
25 A (Donovan) That's correct.
Heritage Reporting Corporation t
s (202) 628-4888 i
A
DOMOFAN - CROSS 22516 1 Q EBS messages broadcast in a normal course, if that 2 can be called the normal course, EBS messages are the 3 primary vehicle for notifying the public. And in your view 4 you used the new release format simply to document what has 5 occurred; correct?
6 A (Donovan) Well, two aspects. Number one, you 7 would expect most news media do routinely monitor radio 8 broadcasts, so the news media themselves are going to 9 monitor the EBS broadcasts when they're being broadcast.
10 And the process of providing the text of the 11 message to the media assembled at a media center or to the 12 wires - you realize, every time a release is released at 13 the media center it also goes to the two wire services. The 14 wire services are not present.
15 The procedures call for the media center to call 16 up the wire services. In this case, AP and UP, and give 17 them the text of the releases. So they are in effect 18 continuing the flow of the information to the media which is 19 a mechanism to reinforce and document the offsite response 20 organization steps and decisions regarding protective 21 actions and steps to implement those protective actions.
22 O Could I ask you to turn to page 160 of your 23 report.
24 Now, it's a fact, is it not, that New Hampshire, 25 in fact, relied on 2ews releases to broadcast essential Heritage Reporting Corporation ,
(202) 628-4888 '
d-4
- . DONOVAN - CROSS 22517' 1 emergency information; correct?
'(t 2 A (Donovan)' I don't .)uume what -- with respect to A
3- what?
4 Q I'm referring to issue number 17 5 JUDGE McCOLLOM:' Issue' number 1 of what?
6 MR. TRAFICON. .: I'm sorry, on page 160.
7 JUDGE McCOLLOM: On page 1607 8 MR. TRAFICONTE: Page 160 of the report, issue 9 number 1 which is attached to FEMA's discussion of objective i
E 11 0 number 13 for the State of New Hampshire.
11 THE WITNESS: (Donovan) Some information was more 12 appropriately -- could have been more appropriately included 13 in the EBS message versus the release.
14 BY MR. TRAFICONTE:
15 Q Well, it appears in terms of your recommendation.
16 set forth on that page, your recommendation is: " Train staff 17 all information dealing with school children and protective actions such as sheltering or school dismissals should be 1
. 18 19 broadcast as EBS messages."
i 20 Do I take that to mean that New Hampshire 21 broadcast such protective action decisions in the form of 22 news releases?
23 A (Donovan) The only decision that was issued as a
- 24 news release before it was issued as an EBS message was the 25 issue dealing with late dismissal of the schools that was Heritage Reporting Corporation (202) 628-4888 1 1
\
l 1
_ - _ . _ _ _ _ _ _ _ _ - _ _ _ _ - _ _ - _ _ _ _ - - _ _ _ _ _ _ _ _ - _ _ _ _ - = . - . . _ - - - _ - _ _ _ _ _ _ _ _ _
DONOVAN - CROSS 22518 1 decided shortly after 12 o' clock.
2 Q And New Hampshire broadcast that information and 3 that recommendation to the public vis-a-vis those school 4 children in the form of a news release?
5 A (Donovan) Well, in form of a news release and in 6 form of statements at news conferences. And it was later 7 included in the first system-wide EBS message that was 8 broadcast.
9 Q How much later?
10 A (Donovan) I'll have to research the records. I 11 don't have the answer off the top of my head.
12 O Would you be turning to one of the tables at the 13 outset?
14 A (Donovan) Yes.
15 Q Would you be turning to the combinatic.i of table 9 16 and table 8 for New Hampshire?
17 A (Donovan) No.
18 Right now I'm looking at table 10 because that 19 would be the first place they would have introduced it, 20 which is the summary of the news conferences.
21 All 39 which is on page 99, table 10, it says at 22 the bottom of the page the last paragraph that starts on the 23 bottom of the page, "The state has asked all students in 24 the EPZ, all schools in the EPZ to hold students until l l
25 1700."
i Heritage Reporting Corporation (202) 628-4888 i
DONOVAN - CROSS 22519
- 1. And at that time there was site area emergency,
( ) 2 and according to the New Hampshire's plan they have an s m /-
, 3 option of making a precautionary protective action at a site 4 area emergency.
5 O Let's take this in steps.
6 So table 10 tells us that at that time, 1239, the 7 State of New Hampshire at a news conference and informed the 8 assembled media that the state had asked the students to be 9 held; correct?
10 A (Donovan) That's correct.
11 Q And we understand then that that is the first 12 notice the public gets? That's the first time New Hampshire 13 broadcast that information?
14 A (Donovan) That's correct.
15 But that's within minutes of the time the decision
%j 16 was made.
17 0 Yes.
18 A (Donovan) So it's timely.
19 Q I understand that.
20 But the decision was made and then the way it was 21 broadcast was via a news conference?
22 A (Donovan) Well, you asked me what the comment 23 report says. The comment report is suggesting that they 24 could have appropriately included that message on school 25 closure in the EBS message that they broadcast at 1215.
Heritage Reporting Corporation
/}
v (202) 628-4888 l
I
DONOVAN - CROSS 22520 1 Q Now, that is set forth, I take it, in synoptic 2 form in table 8?
3 A (Donovan) Table 8 and that's on page 80.
4 Q I'm sorry, on page?
5 A (Donovan) 80.
6 JUDGE SMITH: Is the point there that the EBS 7 message to that effect could have been broadcasted earlier 8 or is it the sequence which is the point?
9 THE WITNESS: (Donovan) No.
10 The point we made in the teport is that the state 11 went through a deliberative process to arrive at a decision 12 to implement, as a precautionary protective action, late 13 dismissal.
14 In other words, the Board of Education called the 15 SAUs, which is the school administrative units, and informed 16 them that they should not dismiss students at any of the 17 schools in the New Hampshire communities until 5 o' clock.
18 The school system was in the process of making 19 these calls. And I think, perhaps, in the states thinking 20 they did not want to go out with an EBS message until they 21 had completed the calls to all the SAUs. After all, you 22 don't like to hear about what you're supposed to do on the 23 radio.
24 We didn't consider this to be the major issue.
25 Our point was that the state could have included that we are Heritage Reporting Corporation (202) 628-4888 l
t
DONOVAN - CROSS 22521 1 recommending, for example, to the SAUs or we're requesting 2 the SAUs to have late dismissal at this EBS message, (v) The next EBS message that they filed was following 3
4 the general emergency declaration and it cuntained 5 appropriate instructions to the public on the status of 6 schools.
7 And again, in a time frame, this is at noon --
8 JUDGE SMITH: I don't think you need all that.
9 My question was: your recommendation was not an 10- implicit criticism that the news release preceded the EBS; 11 it was only that the EBS was unnecessarily delayed.
12 THE WITNESS: Well, that the EBS could hav) 13 contained the same information as they mentioned at the news 14 conference and news release.
{(^)< 15 BY MR. TRAFICONTE:
G' 16 Q Well, Mr. Donovan, the fact of the matter is, they 17 decided on a protective action for schools, and they 18 communicated that decision in the first instance to the 19 public the parents, for example, of the school children via i
20 a news conference and a news release; correct?
21 A (Donovan) That's correct.
22 Q And it's your testimony from yesterday and you 23 adopted it again this morning, that news releases are not 24 the appropriate form for notifying the'public concerning 25 protective actions; correct?
Heritage Reporting Corporation
/~ (202) 628-4888 i
DONOVAN - CROSS 22522 1 A (Donovan) But in this case the public was not 2 being asked to do anything.
3 Q Well you were notifying -- wasn't the purpose to 4 notify the parents of these children as to what the 5 disposition of their children was?
6 A (Donovan) Well, normally in the context for 7 protective actions you are asking people to take actions.
8 And in this case they were not asking people to 9 take actions. And they advised --
10 Q Had the siren --
11 A (Donovan) -- in an emergency of this consequence, 12 e news conference, the messages delivered by the public 13 officials to the media, the public is going to be aware of 14 what those messages are.
15 And in this case, the public would have been aware 16 that schools were going to be -- there was going to be late 17 dismissal of schools.
18 Q So in other words, using the news media in this 19 format does communicate this information to the public?
20 A (Donovan) It does.
21 Q It does.
22 A (Donovan) And in this case, again, the public was 1
23 not being asked to take action instantaneously. The public {
l 24 was being advised that the state was implementing late 1 25 dismissal to the schools at both the news conference and in l
l Heritage Reporting Corporation (202) 628-4888 l 1
DONOVAN - CROSS 22523 1 the news release.
m Well, if now your testimony is that it was not
( _-
.2 O 3 completely inappropriate to use the news media to this a 1
4 extent, what is your judgment now going back to ORO's 5 repetition in a news release an hour after it sent off EBS 6 message number 3, as you will recall from yesterday you had 7 seen the hard copy and noted a lack of clarity.
8 What is your view now on the fact that an hour 9 later they went ahead and repeated in the form of a hard 10 copy the same EBS message to the public, containing the same 11 lack of clarity?
12 A (Donovan) Again, there was part of a documentary 13 process to give the media evidence.
14 Q I see.
(O)
\v 15 A (Donovan) If you look at the release it clearly 16 states that this message was released at such and such time 17 over the radio station, so it puts the information in the 18 context of the time.
19 Q I see.
20 So in the case when ORO releases a message which 21 has a lack of clarity in the form of a news release it is 22 simply a documentary fact or just documents what they had 23 done an hour before.
24 But when New Hampshire uses a news release, in the 25 first instance, that's an appropriate use of the news media Heritage Reporting Corporation
/ (202) 628-4888
DONOVAN - CROSS 22524 1 to notify the public?
2 A (Donovan) No, that isn't what I said. That isn't 3 what I said today.
4 Q Now, you mentioned a few minutes ago that after 5 the news release and the news conference New Hampshire 6 followed this up appropriately, I think you said, with an 7 EBS message containing this information; is that right?
8 A (Donovan) That's correct.
9 Q And I think I had asked you -- we got back to 10 these tables by my question which was, when was that.
11 Now, can you, in consulting table 8, can you tell 12 me when the State of New Hampshire, in the normal fashion 13 through an EBS message, notified the parents of these 14 children, what was happening to their children?
15 A (Donovan) It should be the message that starts on ,
16 the bottom of page 81 and is carried -- excuse me. It 17 starts on the bottom of page 83.
18 Q So it's message number -- New Hampshire EBS number 19 2-A?
20 A (Donovan) Right, 21 Q All right.
22 Well, that, of course, is not the immediately --
1 23 let me withdraw that. That is not the next message that was 24 sent out after the news conference, was it?
25 I believe the news conference was 1239?
Heritage Reporting Corporation (202) 628-4888 '
DONOVAN - CROSS 22525 1 A (Donovan) The news conference I referred to is A
I I 2 news conference number 4 that started at 1239.
V 3 Q Right.
4 So they notify the public in this news conference 5 at 1239 regarding the protective actions for some school 6 children.
7 And it's your testimony that they essentially 8 corrected this or they made up for this by going out on the 9 EBS system and notifying the public by EBS.
10 But they didn't do it on the next message, did 11 they?
12 A (Donovan) AcLording to my information the next 13 EBS message that they broadcast from 1215 was at 1420.
14 Q Well, wait a minute.
i 15 The EBS message number 1 from New Hampshire was at 16 1215, that's on page 80; right?
17 A (Donovan) Right.
18 And their next message is number 2.
19 Q And that's at 1420; right?
20 A (Donovan) Right.
21 Q And that message doesn't contain any information 22 about the disposition of the children, does it?
23 A (Donovan) Yes, it does.
24 This time the conditions have changed. The 25 communities are being evacuated. And New Hampshire's plans Heritage Reporting Corporation
,O (202) 628-4888 G'
____m__________ . . _ _ _ _ _ _ _ _ _ . _ _ _ _ _ . _ . _ . _ _ _ . _ _ _ _
DONOVAN - CROSS 22536 1 are that schools are the equivalent to the general public.
2 So when communities are being evacuated schools are being 3 evacuated.
4 So there was only late dismissal at this time for 5 those schools who were in shelter. There is an insertion of 6 one word that should be added in the text on page 83. If 7 you are there it's the fourth line -- excuse me, the sixth !
8 line down and starts with the sentence: " Residents of other
.o towns," currently reads, " listed above should shelter in 10 place."
11 And it should read: " Residents of other towns not 12 listed above should shelter in place."
13 Q All right.
14 A (Lonovan) And at this time there was no longer 15 late dismissal, there were schools being sheltered, schools 4 16 being evacuated.
17 Q Well, let's takt a look again at what the 18 information is that's broadcast in news conference number 4.
19 And I'm on page 99 over on to 100.
20 At the bottom of 99 in that column we find: "The 21 state has asked all schools in EPZ to hold students until 22 1700;" correct?
23 A (Donovan) That's correct.
24 Q Now that's an important piece of information, is 25 it not?
Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22527 1 A (Donovan) Yes, it is.
'(s_ 2 Q And is it your view that normally if they were 3 going to do things right that should go out over an EBS I 4 message?
5 A (Donovan) That it should have been included. It 6 could have been and should have been included an EBS 7 message. They put it in the next appropriate EBS message, 8 but at that time --
9 Q Let me stop you right there.
10 You say, they put it in the next appropriate EBS 11 message, and chat's what I want to probe a little bit.
12 Let's get the time first. When is the next 13 appropriate EBS message?
14 A (Donovan) I've told you.
D
( j\ 15 Q It's EBS message number --
16 A (Donovan) 1420.
17 Q 1420, all right.
18 So in other words -- and 1420 is set forth in 19 synoptic form in the bottom of 81; correct? On the bottom 20 of page 817 21 JUDGE Mc;OLLOM: It continues on 82.
4 22 THE WITNESS: (Donovan) It starts on the bottom 23 of 81 and continues on 82.
24 BY MR. TRAFICONTE:
25 Q Well, I don't believe --
Beritage Reporting Corporation
[' (202) 628-4888
\
r I
l DONOVAN - CROSS 22528 1 A (Donovan) Excuse me, it starts on 83 and stops 2 on 84.
l 3 Q Yes. I don't believe it continues en 82, does it?
l 4 A (Donovan) 83 and 84.
5 Q No. Isn't the message at the top of 82 another .
6 message?
7 A (Donovan) I said, starts on the bottom of 83 and 8 continues on 84. I 9 0 I'm completing confused. I'm sorry.
10 Can we look at the bottom of 81 first.
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
DONOVAN -_ CROSS 22529 1 Q The bottom of 817 Maybe my volume is different.
- r- N s i ! 2 ~ have New Hampshire EBS No. 2.
V' 3 Do you see that?
4 A (Donovan) Yes.
5 Q Okay. Now turn to the next page.
6 A (Donovan) Okay, I see what you are saying.
7 Q Isn't there another message that begins at the 8 next page by another organization?
9 A (Donovan) Well, there is message on the bottom of 10 page 81 at 1420, and at 15 minutes later they amended that 11 message at 1435, 12 Q Yes, but I dor.'t want to talk about the amended 13 message.
14 A (Donovan) Okay.
O
! 15 Q I want to talk about the next message.
16 A (Donovan) Okay.
17 Q I understand that they amended it, and I 18 understand that that's labeled 2 (a) . The way I would 19 normally count, I would use the next number; for example, 20 three. I understand that this is here as 2 (a) . I just want 21 to focus on No. 2, which is the next message, right?
22 A (Donovan) Right.
23 Q Now did they in the next message communicate this 24 important emergency information to the public concerning the 25 schools?
_, Heritage Reporting Corporation f, (202) 628-4888
\
i
DONOVAN - CROSS 22530 1 A (Donovan) The situation had changed. The 2 schools were no longer in a late dismissal. They are in a 3 shelter mode which means they are going to be held in 4 shelter regardless of school closure until the state arrives 5 at a decision.
6 Q Did they communicate the fact in the next message, 7 Mr. Donovan, that the situation had changed as you have just 8 indicated?
9 A (Donovan) Yes. To me, they did.
10 Q Did they communicate it in the next message that 11 what we communicated to you via the news release an hour 12 earlier -- no, in fact, two hours earlier -- has been 13 superceded by a new protective action recommendation for the 14 schools?
15 Is that, in any form of words, is that part of the 16 content of New Hampshire EBS No. 2?
17 A (Donovan) If you ,o back to EBS 1, they are 18 telling the public of New Hampshire that they have a 19 precautionary closing of the beaches a maritime safety zones 20 is being established. So at that ^.ime the public was aware 21 that the only protective actions in place was a maritime 22 safety zone, which means no boaters in certain areas on the l 23 open waters, and the beaches were closed.
24 Q Yes. We are focusing on --
25 A (Donovan) Let me finish.
Heritage Reporting Corporation (202) 628-4888 l
l
=
DONOVAN - CROSS 22531 1 And the next protective action message that the
( ) 2 public gets via the EBS at th'is time is that certain 1
v 3 communities are being evacuated and other communities are 4 being sheltered. Based on the public education documents 5 and the public education program, the public would know that 6 the schools in the communities being evacuated would be 7 evacuated, and the schools in the communities being 8 sheltered would be sheltered. And sheltered at this time 9 would mean that they would not be dismissed in a normal 10 manner.
11 Q All right. Now let me make sure I understand 12 this.
13 Yes, 1215 there is EBS No. 1, is there not?
14 A (Donovan) Yes.
15 Q But we just went over the fact that at 1239, some 16 15 - 20 minutes later, the public is communicated with 17 vis-a-vis protective actions for the school children through 18 the news conference which tells the EPZ public that the 19 schools in fact -- the children are going to be held in 20 schools, correct?
21 A (Donovan) It says late dismissal, yes.
22 Q The children are going to be held in schools, 23 right?
24 So it's a fact that the public -- I mean. it's 25 either one or the other. Either they failed to notify the Heritage Reporting Corporation
/N (202) 628-4888 f
DONOVAN - CROSS 22532 1 public of the protective action that their children were 2 going to be held, or they notified the public, as you say 3 through the news release, and the public was informed at 4 1239, through the news release, thrt that was the protective 5 action.
6 It's either one or the other, right?
7 A (Donovan) At what time? 12397 8 Q At 1239. -
9 You are going to have to call it one way or the ,
10 other, Mr. Donovan. Either they didn't notify the public or 11 they did at 1239. The report says they did, but they did it 12 through a news release format and that that wasn't 13 appropriate.
14 I think that's a fair statement, isn't it?
15 A (Donovan) It says they did it two ways: Through 16 news release format, they did it through a news conference.
17 That's two separate ways of informing the public.
18 Q We' re going to label them both non-EBS 19 notification formats, okay?
20 A (Donovan) Okay, 21 Q Now let's just take it by the numbers.
22 It's your view that that is a notification of the 23 public as to that protective action, right?
24 A (Donovan) Yes.
25 Q All right. I take it from that that it's your Heritage Reporting Corporation (202) 628-4888
. DONOVAN - CROSS 22533 1 view that the public is now informed that that is the 7s j 2 protective action for children?
N 3 A (Donovan) At that time, yes.
l 4 Q At that time.
5 Now, in light cf that, now focus on the ver next 6 EBS message, No. 2 that goes out almost two hours later.
7 Does the next message inform the public, who had 8 been informed two hours earlier that their children were 9 being retained and held at school, does the next message 10 tell them that that is no longer the case?
11 Does it tell them that?
12 A (Donovan) In my mind, it does.
13 Q Okay. Can you indicate, and I take it that right 14 on the bottom of 81 we have a synopsis of that message.
-~
15 A (Donovan) That's correct.
(s 16 0 It's a brief synopsis. I take it, it means it was 17 a brief message.
18 A (Donovan) That's correct.
19 Q If I got the message -- I don't, unfortunately, 20 have the message with me -- if I got the message out --
21 well, let's stay with your report.
22 Can you indicate the language in the synopsis that 23 would refer or communicate to the public that the protective 24 action that they are apparently aware of for their children 25 has been modified?
Heritage Reporting Corporation (202) 628-4888
(
_ _ _ _ _ . _ - _ _ _ . _ . _ _ . _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ _ _ _ _ _ . _____. ___.___________ _ _ _ A
DONOVAN - CROSS 22534 1 A (Donovan) Yes. Again, school children are the 2 same as the public. It says, "Immediate evacuation of 3 Seabrook, Hampton Falls, Hampton, Kensington, South Hampton 4 and North Hampton. Residents of other towns not listed 5 above should shelter in place."
6 Q Okay. So it's --
7 A (Donovan) And that is a char.ge in protective 6 actions. And in this case you do not attempt to confuse the 9 public by giving them a protective action that has been 10 overrun by a new protective action. The protective action 11 of the day at that time was that certain communities were
.12 being evacuated and other communities were being sheltered.
13 And by default, this means that the schools in the 14 communities being evacuated are being evacuated. And the 15 schools in the communities being sheltered are being 16 sheltered. And in this case sheltered would be the same as 17 late dismissal, because there is going to be no normal 18 dismissal of the schools that are being shelter'ed.
l 19 Q All right. So it's your view then that standing 20 alone a parent who heard or was somehow communicated the 21 information from the news conference and the news release at 22 1239, that a parent who heard that there was going to be 23 late dismissal, that kids were going to be held in school 24 until 1700, 5:00, parents who heard that, who then heard two 25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> later New Hampshire EBS No. 2 which says -- at least Heritage Beporting Corporation (202) 628-4888
av ,
DONOVAN - CROSS 22535 4 ,
1 the synopsis on the bottom of 81 -- parents who heard No. 2-
- rs 2 would now understand that their children, the appropriate
}J %
J 3 children are no longer being held at school?
4 A (Donovan) In those appropriate communities that
.5 are being evacuated, yes.
6 Q Well, they then supplement it, didn't they, and 7 they sent out another message which is numbered here 2 (a) ?
8 A (Donovan) Yes, they did.
9 Q And'in that message -- and now we really are at a 10 two hour time frame.
11 In that message, they actually go into some detail 12 about the schools, don't they?
13 A (Donovan) Yes, they do.
14 MR. FLYNN: Two hours from what?
O 15 MR. DIGNAN: Yes, two hours from what?
-( )
16 MR. TRAFICONTE: 1239 17 THE WITNESS: (Donovan) No, it's 15 minutes for 18 one EBS message to the revision.
19 BY MR. TRAFICONTE:
20 Q Yes, yes. It's 15 minutes between the two EBS 21 messages, and it's, for the second message, approximately 22 two hours from the news conference, right?
23 MR. FLYNN: And a general emergency intervened.
24 MR. DIGNAN: That doesn't make any difference.
25 MR. FLYNN: Oh, excuse me.
Heritage Reporting Corporation
[ (202) 628-4888
\
1
DONOVAN - CROSS 22536 '
1 MR. TRAFICONTE: The general emergency intervened I 2 between the two EBS messages or between the news --
3 MR. FLYNN: No, You've identified a two hour 4 period.
5 MR. DIGNAN: You just belabored for Lord knows how 6 long.
7 MR. FLYNN: You identified a two hour period, and 1
8 I said two hours from what. You said the news conference.
9 Between the news conference and EBS Message 2 and 2 (a),
10 there was a general emergency. I think that's significant.
11 BY MR. TRAFICONTE:
12 Q What's the significance of the fact that there was 13 a general emergency in between the news conference and EBS 14 Message 2 and 2 (a) , Mr. Donovan?
15 A (Donovan) Again, they are going from ---
16 MR. DIGNAN: Wait a minute, Mait a minute.
17 Between the news conference and 2.
18 MR. TRAFICONTE: And 2 (a) , yes. Let's be clear.
19 Thank you.
20 BY MR. TRAFICONTE: j i
21 Q What is the significance of the fact that there l 22 was a general emergency declared between the news conference 1 23 at 1239 and New Hampshire EBS Message No. 27 1
24 A (Donovan) First of all, there was a site area l
25 emergency at 1239. The public has been informed, as l
Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22537 1 contained in the public education document, that certain
/ \
precautionary protective actions would be taken at site area (J)
L 2
3 emergency. And in those include beach closings, maritime 4 safety zones, and precautionary protective actions for 5 schools.
6 The public has also been informed that if the 7 emergency escalates to a general emergency, there would then 8 be protective actions which override or may be consistent 9 with precautionary protective actions.
10 In the case of the schools, the precautionary 11 protective actions were cancelled out by the protective 12 actions, because the school children are treated the same as 13 the general public.
14 So when you -- and the public is also aware there i
A i 1 15 is a significant difference between a site area emergency G
16 and a general emergency. In a general emergency you draw 17 their immediate attention to the instructions and the 18 decisions of the state.
19 0 So, in other words, your judgment that this was an 20 appropriate or not so bad sequence is that the pre-emergency 21 information packages that the public has would enable them 22 to understand that it was a site area emergency at 1239, and 23 that the news conference information should be understood as 24 precautionary. And then at apparently around 1:30, there 25 was a general emergency declared, and now the protective Heritage Reporting Corporation
['^ (202) 628-4888 i i
\s l
l l
_ _ _ . _ - . _ _ _._________.___.._________o
DONOVAN - CROSS 22538 1 action recommendations they are hearing approximately an 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> later are real protective actions recommendations.
3 MR. DIGNAN: Wait a minute.
4 BY MR. TRAFICONTE:
5 Q Is this something that you are assuming the public ,
6 understanding?
7 MR. DIGNAN: Wait a minute. Where did the 1:30 8 come from?
9 MR. TRAFICONTE: Well, let's look at page 49. I'm 10 sorry. At the bottom of 48, I guess, is where you first set 11 forth when the general emergency was declared.
12 THE WITNESS: (Donovan) That's an initiating 13 event there. They were not notified until 1332, which is 14 two minutes later. It began and the notification process 15 extended out for some odd minutes.
16 BY MR. TRAFICONTE:
17 Q Well, when you say they were notified, who was 18 notified?
19 A (Donovan) Well, it says on the next page "GE 20 notification". That means at 1332 the onsite people 21 notified the onsite representatives a'c the EOF that there is 22 a general emergency.
23 0 Yes. The public is not notified, are they?
24 A (Donovan) They were notified with the EBS 25 messages that took place at approximately 1420 by both Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22539 1 offsite response organizations.
g
( ) 2 Q Yes. I'm going back to your counsel's helpful
%J 3 comment.
4 It's a fact that between 1239 and EBS Message No.
5 2 there was a general emergency declared, correct?
6 A (Donovan) That's correct.
7 Q The public didn't know that, did they?
8 A (Donovan) They knew that when they heard the EBS 9 messages and there was a concurrent news conference at the 10 same time.
11 Q They knew that when they heard EBS No. 2.
12 A (Donovan) That's correct.
13 Q Yes.
14 So the fact that that intervened is not going to n
15 help the public sort out where their school children are, is
(
16 it?
17 A (Donovan) First of all, there is no problem with 18 the school children. Schools haven't been dismissed yet.
19 Until you get to the time that schools are to be dismissed, 20 the public has no knowledge of whether the school day is 21 normal or not.
22 The only difference would be is, obviously, if you 23 are going to take actions that are going to preclude and 24 conflict with the parents' expectations of when they are 25 going to see their children. So school had not been Heritage. Reporting Corporation
,_s
-( (202) 628-4888
)
\_ /
E_______
DOMOVAN - CROSS 22540 1 dismissed at 12 -- whatever the time is -- that the news 2 conference was held, and the EBS messages, in the aosence of 3 information on the fact that there was going to be late 4 dismissal, did not impact upon the public because the public 5 was not being asked to take any actions with regard to their 6 children.
7 From that time frame, it has been pointed out, a 8 general emergency condition occurred, changing the state's 9 protective actions and the state took appropriate actions to 10 inform and instruct the public and inform and instruct the 11 schools of what actions to implement.
12 And so when the public was informed at 1420 that 13 these communities are being evacuated, the public equates 14 that that their schools are being evacuated. And they also 15 equate for the public that's in the sheltered communities I 16 that their schools are going to be sheltered and there is 17 not going to be dismissal of those schools. They are going 16 to be sheltered until the state arrives at a decision as to 19 what actions to take for the sheltered communities and the 20 sheltered schools.
21 Q So if I understand your answer, the fact is then 22 that the initial precautionary protective action decision 23 that there would be late dismissal of the schools, that 24 precautionary decision was never communicated to the public 25 through the EBS system.
l l
Heritage Reporting Corporation j (202) 628-4888 l
l
DONOVAN : CROSS - 22541
- t. . . 1 That's a more~ accurate statement then, isn't it?
f'( / 2 A ~(Donovan) At that time.
3 Q And then by the time the next message rolled 4 around --
5 A -(Donovan) Conditions have changed.
6 Q -- conditions had changed, and the actual L
7 protective action recommendation for the children had 8 changed.
9 A (Donovan) That's correct.
~10 Q All right, that's fine.- That's clarifying.
11 But then it's a fact,'isn't it, that'the initial 12 -precautionary de'ision c for the school children, which 13 apparently they struck at some time prior to 1239, that that 14 decision was never communicated to the public through an EBS 15 message, right?
16 A (Donovan) That's a fact, yes.
l' 17 MR. FLYNN: Which is exactly the issue that's 18 identified in the report.
19 BY MR. TRAFICONTE:
20 Q No, but in fact I think the record will be clear 21 that earlier this morning you told us that they supplemented l, .
l 22 the news conference and they communicated this information 23 in an EBS message. In fact, I think your words were "in the 24 next EBS message, they communicated this to the public".
25 A (Donovan) At that time it was communicated in the i-Heritage Reporting Corporation L (202) 628-4888 l
DONO3JAN - CROSS 22542 1 .ontext of protective actions, not precautionary protective 2 actions.
3 0 All right.
4 So to summarize, it's a fact that New Hampshire 5 notified the public of a precautionary protective action for J 6 the school children through a news release, and in no 7 fashion used the EBS system to communicate that protective 8 action, correct, that protective action?
9 MR. FLYNN: Precautionary action.
10 BY MR. TRAFICONTE:
11 Q That that precautionary protective action, 12 correct?
13 A (Donovan) That's correct.
14 Q All right.
15 Now is that a deficiency or an ARCA?
16 A (Donovan) We've identified it as an ARCA.
17 Q Do you think that's a close call?
18 A (Donovan) No, I do not.
19 Q You said before that there was a 15-minute timing 20 requirement, was there not, for the notification to the 21 public for protective actions?
22 A (Donovan) Yes.
23 Q You remember the.t was one of the standards used in 24 judging the Objective No. 137 25 A (Donovan) Well, it's actually used in judging Heritage Reporting Corporation (202) 628-4888 i
I
- _ _ _ - _ _ - _ _ _ i
H k
J DONOVAN - CROSS 22543 1- Objective.12.
. ;/
2 0 Well, okay, that's fine.
( f 3 And I think you said that the clock is started 4 .when the decision is made, and then the clock is stopped at 5 the point at which the EBS message is broadcast, correct? 'i 6 A (Donovan) That's correct.
7 Q An do I understand that precautionary protective 8 actions are not included in that timeliness --
9 A (Donovan) Depends on what the precautionary 10 protective action is.
11 Q Does FEMA have any guidance as to which 12 precautionary protective actions are included in the 15-13 minute requirement and which are not?
14 A (Donovan) Common sense and good judgment.
15 For example, if you are advocating to the public 16 that they do something, then you should instruct the public 17 of what you are to do.
18 In this case, the school organizations had been 19 notified not to dismiss children at their normal times.
20 Q How about the parents?
21 A (Donovan) At that time it wasn't critical to 22 notify the parents.
23 Q Well, why bother at all?
24 A (Donovan) Well, we thought it would have been 25 more effective to notify the parents. But it was not a Heritage Reporting Corporation (202) 628-4888 A
DONOVAN - CROSS 22544 1 critical issue that they failed to notify them in the 1239 2 EBS message.
3 Q Okay. So let me get it right. j 4 Now, FEMA thinks t aat they should have notified 5 the parents, that it was appropriate to notify the parents, 6 that it would have been better to notify them through an EDS 7 message, correct?
8 But that you would not have applied the 15-minute 9 timing requirement had they notified them through the EBS 10 message, because it's not one of the precautionary measures 11 that are subject to the 15 minutes based on your common 12 sense, right?
13 A (Donovan) Well, you are mixing apples and oranges 14 in your questions.
15 Q Well, where are the apples and where are the 16 oranges?
17 A (Donovan) First of all, our exercise report 18 identifies this as an issue.
19 0 Yes, I agree, and obviously most of my cross-l 20 examination has been probing whether it's an ARCA or a 21 deficiency.
22 A (Donovan) Secondly, we have said precautionary 23 protective actions that require the public to change their 24 lifestyle should be communicated in a timely fashion to the 25 public.
Heritage Reporting Corporation ,
(202) 628-4888 l l
l l >
)
DONOVAN - CROSS 22545 p_ 1 In this case, this protective action at the 1220
( h
(,v/ 2 time frame would not have required the parents to change 3 their lifestyle at that time.
4 Q Oh, is that a fact?
5 MR. DIGNAN: Could the witness be allowed to 6 finish these answers without counsel interrupting them?
7 MR. TRAFICONTE: Yes, I think that's fair.
8 MR. DIGNAN: It was a broad question given to him.
9 He's trying to answer it. He's been asked to justify a 10 decision he made. That's the kind of answer you don't 11 interfere with.
12 JUDGE SMITH: He's agreed.
13 THE WITNESS: (Donovan) The school organizations 14 were notified by the Board of Education from the state EOC
't v
i 15 their decision and requested to implement late dismissal.
16 And in the process of implementing actions at this time, my 17 judgment was that the public was appropriately informed, the 18 public was not requested to take actions. The school 19 organizations weie appropriately informed, and the public 20 was informed through a different mechanism. And as the 21 report said, we believe that the public should have also 22 been informed through the EB network at that time.
23 24 25 .
,s Heritage Reporting Corporation ;
/ \ (202) 628-4888 l N ,] l
DONOVAN - CROSS 22546 1 A (Donovan) That's correct.
2 Q And it requires that the response organization 3 demonstrate the ability and resources necessary to implement 4 appropriate protective actions for school children; correct?
5 A (Donovan) That's correct.
6 Q First of all, does that include precautionary 7 protective action?
8 Does the language of the objective also 9 incorporate precautionary protective actions?
10 A (Donovan) Yes, it does.
11 Q It does. All right.
12 Like the one we were just discussing? l 1
13 A (Donovan) That's correct. )
l 14 Q Is it a fair statement to say that once the 15 response organization has decided upon a particular )
16 precautionary action that they should be able to demonstrate 17 the capacity to communicate that to all of their component 18 parts and have all of their component parts follow the same 19 precautionary protective action?
i 20 MR. FLYNN: Are you asking whether the 21 communication of protective actions is evaluated under 22 objective 197 23 MR. TRAFICONTE: I think the question was pretty 24 clear.
25 Heritage Reporting Corporation (202) 628-4888 l
l l
l DONOVAN'- CROSS 22547 1
^
H 1 BY MR. TRAFICONTE:
/~i ;
! )
( ,f} ;2 Q. Did you understand my question, Mr. Donovan?
3 MR. FLYNN: Well, Mr. Traficonte, it.wasn't clear !
l I
4 to me. And I'm asking you the courtesy -- j 5 ER. TRAFICONTE: Well, you're not going to answer 6' it,. fortunately. )
J 7 MR. FLYNN: Your Honor, may I ask for 8 clarification.
9 JUDGE SMITH: I think that he has a role in i
10 understanding the question. He may want to pose an 11 objection or whatever. j 12 MR. TRAFICONTE: All right' 13 Let me put the question in a different way and l
14 perhaps it will be clear in a different way.
[
g 151 'BY MR. TRAFICONTE:
16 Q Part of objective 19, does it include a' review of ;
3 17 the capacity of the organization to, in the first case, l 18 reach an appropriate protective action, and then communicate j 19 it to its component parts and have the component parts l 20 follow it? ,
I 21 A (Donovan) No , it does not. l 22 Q That process is not incorporated in 19?
23 A (Donovan) Not all of it; no.
24 Q Because I want to direct your attention to the 25 bottom of 172 and then on to the top of 173.
Heritage Reporting Corporation 3 h -
(202) 628-4888 J
l DONOVAN - CROSS 22548 1 The bottom of 172 states: "That early dismissal 2 of school children in plume EPZ communities was considered 3 by the governor, and the decision was made not to recommend 4 early dismissal due to concern for the latchkey children."
5 Then the next sentence says: "A precautionary 6 protective action was made at site emergency to hold 7 children in school until 1700, i.e., late dismissal."
8 That's what we were just discussing; correct?
9 A (Donovan) That's correct.
10 Q That's that same decision we were just tracking; )
11 correct?
12 A (Donovan) That's correct.
13 Q "The Board of Education notified all appropriate 14 school districts of this precautionary protective action."
15 Now, there's an instance where the decision was 16 made, late dismissal, and it was communicated by the Board 17 of Education to all the school districts; right?
18 A (Donovan) That's correct.
19 Q So that aspect of the process is being reviewed 20 under objective 19; right?
21 A (Donovan) Not all of it.
22 Again, let me answer. The decision-making process 23 ia evaluated under objective 11. Objective 19 talks about 24 the communications of that decision to the parties that 25 would implement that decision.
1 Heritage Reporting Corporation j (202) 628-4888 ,
DONOVAN - CROSS 22549 1 Q It does. Yes. .I thought it'did.
L ry L 2 A '(Donovan) That isn't what you asked me.
f 3 You asked me if it evaluated both the decision 4 process --
5 Q. 'I see.
l 6 A (Donovan) -- and the implementation process.
7 Q No. I'm not interested in'this line on the 8 decision process, but the communication and let's call it 9 enforcement of the decision.
10 So.you are reviewing the way it's communicated?
11 And then are you also determining whether or not 12 the various school districts follow it?
13 MR. FLYNN: Excuse me. I need further 14 clarification.
The question is asking about communication. Now, 16 it's clear to me from the report that what is addressed under objective 19 is communication of the protective action 18 decision to the schools. To the responders who have to 19 carry it out.
20 It's not clear that it includes communication of 21 that to the public.
22- Are we still on the subject of the EBS messages?
23 MR. TRAFICONTE: We are no longer on the subject 24 of the EBS messages, Mr. Flynn. We are on the subject of 25 the implementation of the protective actions once decided Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22550 1 upon, the implemt.ntation of those protective actions by the 2 various school districts.
3 MR. FLYNN: Thank you.
4 BY MR. TRAFICONTE:
5 Q Now, it's a fact, is it not, that once the various 6 school districts learned of this precautionary protective 7 action some of them either disregarded it or simply did not 8 follow it; right?
9 A (Donovan) I don't know what you mean.
10 I don't believe that's the case.
11 Q Did all the school districts notified of this 12 precautionary protective action follow it?
13 A (Donovan) No, they did not.
14 But they were following their plans.
15 Q But they were still following their plans?
16 A (Donovan) Yes.
17 The school districts' plans and the school plans 18 state very clearly that they will implement protective 19 actions provided to them by three sources: the Board of 20 Education through the SAU, which is the school 21 superintendent or that school administrative unit.
22 Two, if they get a protective action from a local 23 government. One of these local EOCs.
24 Or three, if they hear it over the EBS message.
25 Whatever instruction they hear from either one of i
Heritage Reporting Corporation (202) 628-4888 1
i I
'l I DONOVAN - CROSS 22551 1 these three pathways they are to implement. And if one --
(
.s
- 2 if a protective action comes in on top of a precautionary 3 protective action, then the school is told not.to do 4 'anything but implement it.
5 What we have written on this exercise report under 6 objective 19 is that certain communities, so identified in-7 this report, and officials at those local EOCs gave 8 instructions to the schools that were different than what 9 the State Board of Education did from the state EOC.
10 So the school districts did not ignore it, they 11 were given a different set of instructions and they 12 implemented those instructions.
13- Q Oh, I see.
14 So'the local EOC officials told the local school
/ ..
i 15 districts to do something different than what the state, 16 through the Board of Education, was telling the school 17 districts to do.
18 Is that a fair statement?
19 A (Donovan) That's a fair statement.
l 20 Q That's a fair statement.
1 21 Now, is that or is that not in harmony with the 22 NHRERP?
23 A (Donovan) From whose perspective?
24 I don't understand your question.
- 25 Q Well, in what you just described, the fact that Heritage Reporting Corporation
[ (202) 628-4888
\
l
1 DOMOVAN - CROSS 22552 1 the local officials gave these school districts different ,
2 information with regard to protective actions for the 3 children. And then those two communities followed the local 4 officials and not the Board of Education.
5 Is that consistent with the NHRERP?
6 A (Donovan) Again, I don't understand your 7 question.
8 From whose perspective? Is it consistent from 9 schools --
10 Q From the perspective of the federal official 11 responsible for evaluating NHREBP?
12 A (Donovan) From the perspective that we looked at, 13 from the schools perspective, their actions were consistent.
14 JUDGE SMITH: With what? '
15 THE WITNESS: (Donovan) That the schools 16 implemented the protective action they were advised to 17 implement.
18 In this case they received one protective action 19 from the state, which was of a precautionary nature. And 20 they received a protective action from Portsmouth and 21 Brentwood EOCs that was different. And they chose as their 22 instructions tell them to do, to implement those protective 23 actions.
24 The actions of the two officials at the EOC were 25 recognized by the state. The state was eware of it and so Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22553 1- advised and compensated for it. And we felt they made, at
,, N .
t 2- that time, a correct decision that it's done, you don't try l(v) 3 to undo something that is already done. .
4 And in-this case there was no adverse 5 consequences.
6 BY MR. TRAFICONTE:
7 Q I'm not interested in the adverse consequences.
8 I'm interested in whether what they did was in 9 accordance and consistent with the plan or not?
10 A (Donovan) They identified --
11 O Is it your testimony that it was?
12 A (Donovan) From the perspective of the schools, 13 what the schools did was in accordance with their plans.
14 Q Okay, fine.
j,n 15 A (Donovan) From the perspective of the EOC 16 officials at the local EOCs, the local EOCs should have been 17 consistent with the state actions and we identified that as 18 an issue on page 181 of our exercise report.
19 Q We're going to turn to that in a minute.
20 Is this, perhaps, a flaw in the plan?
21 A (Donovan) No, I don't believe it's a flaw in the 22 plan.
23 Q If I understand what you're saying, the fact that 24 an individual school district is told that it is to follow 25 one of three inputs as to protective actions, and in an Heritage Reporting Corporation (202) 628-4888
- ______________m._
DONOVAN - CROSS 22554 1 instance where the inputs change, it's basically to choose 2 which one it decides to follow.
3 The fact that that's the way the NHRERP is 4 structured is not, in your view, a flaw in that plan?
5 MR. FLYNN: I object, I don't think that's a fair 6 characterization of Mr. Donovan's previous testimony.
7 He didn't say that they could choose whichever one 8 they wanted to.
9 BY MR. TRAFICONTE:
10 Q Mr. Donovan, is it a fair statement that an 11 individual school district in its plan is to receive or 12 could receive information from three different inputs as to 13 protective actionn?
14 A (Donovan) Yes.
15 Q How is the school district going to decide if 16 there are inconsistent protective actions, how is it to 17 decide what to do?
18 A (Donovan) They would communicate either to the 19 person to whom it received the instructions from or 20 communicate through its supervisory chain to its SAU.
21 Q It would communicate a request as to what they 1
22 were supposed to do? !
23 A (Donovan) If it perceived them to be 1
24 inconsistent, j 25 In this case, the schools do not receive Heritage Reporting Corporation j (202) 628-4888 ]
a
)
DONOVAN - CROSS 22555 1 inconsistent instructions. I have one SAU in Portsmouth
( ) 2 which covers a number of schools. They received the late j 3 dismissal and received latchkey children -- or early 4 dismissal.
5 The other case was not a school district; it's one 6 school, Swasey School which is different than a whole school 7 district.
8 0 Well, on page 173 what you describe happening here 9 seems to be that the Portsmouth officials for their schools 10 recommended early dismissal.
11 A (Donovan) With li cructions. You failed again to 12 read the complete text. "To hold the latchkey children."
13 Dismiss children who have parents at home to 14 receive those children. Children that do not have parents
() 15 at home you hold at the school. And therefore, they're 16 retained in a late dismissal mode.
17 Q Right.
18 So the Portsmouth officials made the exact 19 opposite decision the governor made, as you describe at the 20 bottom of 172 and the top of 173, where the governor 21 considered doing the same thing but he was concerned about 22 the latchkey children, so he instead ordered a " Hold the 23 Children Order," which you call late dismissal.
24 A (Donovan) They did not make the opposite 25 decision. The decision was consistent with the Board of
, ,- Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22556 1 Education's decision.
2 Q It was.
3 A (Donovan) Yes.
4 Q It was consistent.
5 It's consistent to order --
6 A (Donovan) No. If you would let me finish 7 talking, please.
8 It was consistent in that the Portsmouth officials 9 and the school district was concerned about the latchkey 10 children and recognized the governor's concern and rationale 11 for the late dismissal, precautionary protective action, and 12 took actions to implement protective actions in a 13 precautionary mode that were consistent with the governor's 14 and not inconsistent.
15 Q I see.
16 Do you think a plan would be appropriate if, for 17 example, with regard to precautionary actions for school l
18 children the plan said, notify.the various school districts {
19 in the EPZ that there is a general concern about school 20 children right now and there is a general concern about i
21 latchkey children. So as long as each one of the school 22 districts make a decision reflecting those concerns, they i
23 can dismiss the children early; they can hold the children 24 late. They can do any number of things, keep the children 25 for the normal school day.
Beritage Reporting Corporation (202) 628-4888 l
l i
DONOVAN - CROSS 22557 1 We don't care what you decide'to do, as long as f .
you express a concern and as long as you. consider the issue f( / 2 3 of-latchkey children.
4 Would that be a coherent way to have a plan for 5 precautionary actions for school children?
6 A (Donovan) That isn't what exists today, so I 7 don't know how to answer your question.
8 0 Well, I'm having problems sorting out how this can 9 both be -- you apparently believe that what Portsmouth did 10 is consistent with what the state recommended?
11- A (Donovan) I believe what Portsmouth did was 12 communicate its dec3sions before the state was able to
-13 communicate its decisions.
14 Q So there was a problem in the communication b 15 sequence?
16 A (Donovan) I didn't say that.
17 Q Well, then I must infer from that answer that each 18 of these school districts is free to take action as 19 individual school districts with regard to this emergency 20 prior to being communicated from the Board of Education?
21 A (Donovan) No.
4 22 Q No?
23 A (Donovan) I didn't say that either.
24 Q Okay.
25 A (Donovan) The plans again re,ad that the school Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22558 1 SAUs receive protective action or precautionary protective 2 action from one of three sources: the state; the 3 appropriate local government; or EBS., And depending on the 4 action that they receive they are to implement it. They are 5 not to go bach and requestion the philosophy behind it.
6 I believe what we said here in the exercise report 7 is that Portsmouth communicated one decision to the SAU.
8 The SAU implemented it. The decision was consistent with 9 the governor's decision with regard to his concern for 10 custody and accountability of the latchkey children. l 11 And we note on our log at 1240, when the School 12 Board of Education, its notification process was complete, 13 that they acknowledged by the time they got to the 14 Portsmouth SAU that the Portsmouth had implemented 15 precautionary protective actions based on the advice of the 16 Portsmouth EOC.
17 So they appropriately renotified all the other 18 schools to ensure that consistent and appropria'te 19 precautionary protective actions were taken at that time.
20 So again, from my perspective, the schools acted 21 accordingly. The state EOC acted accordingly. It would 22 have been nice if the local Portsmouth EOC communicated to 23 the state EOC before it took actions with regard to 24 notifying the SAU.
]
25 But I think the officials, in this case the Beritage Reporting Corporation (202) 628-4888 1
i l
_ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ __ - . _ _ _ J
DONOVAN - CROSS 22559
, : 1' selectmen and the school SAU representatives at the EOC,.
2 'showed ' equal -intelligence in good decision-making in l-l_ 3 arriving at a' decision that was consistent with the r
i 4 governor's and the state's decision.
5 Q You got a piece of information out of one of the 6 tables, did you not, in part of your response?
7' A (Donovan) I checked on table three to look at the-8 notification process. And on page 47 it'shows that the 9 Board of Education goes through a renotification process, 10 because as I said,'in their initial notification process 11 they discovered that that the Portsmouth EOC had gone to the 12 Portsmouth SAU with the precautionary protective action with 13 early dismissal.
. 14 Q I see.
-t 15 A (Donovan) With the exception of latchkey 16 children.
17 Q That's going to be.my next question, in fact.
18 At the bottom of page 47 there is at 1240 the 19 renotification entry that you just described; correct?
20 A (Donovan) Yes.
21 Q Before I proceed with that.
22 You mentioned that there were three sources that 23 the school district could receive the recommendation from:
24' Board of Education; local EOC official; and EBS;. correct?
25 A (Donovan) That's correct.
Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22560 1 Q EBS, now we're talking about the precautionary 2 recommendation for school children that we just discussed 3 that went out over a news release; right?
4 It's the same recommendation?
5 A (Donovan) They are different because the state's 6 plan calls for the implementation of protection actions to 7 be notified.
8 The only time EBS would be considered the primary 9 notification is in the hypothetical situation that you had a 10 fast-break emergency and you were unable to mobilize the 11 staff and the staff would be at the EOCs. And in which case 12 then the EBS message would be the primary driving force.
13 Q All right, 14 So let's just go back and you may want to correct 15 your testimony, as to the precautionary recommendations for 16 school children.
17 The individual school district is not -- one of 18 the three sources is not the EBS system?
19 A (Donovan) That isn't what I said.
20 Q Is it or isn't it the EBS system? !
21 A (Donovan) It's one of the three sources; yes.
22 Q All right.
23 But New Hampshire in this case didn't use the EBS 24 system to communicate the precautionary protective action 25 for school children?
Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22561 1 A (Donovan) Their plan does not call for them to 2 use that to implement precautionary protective action.
3 Q I'm just trying to track it through.
4 Then why are the schools and the school districts 5 assuming that one of the three sources for the information 6 is going to be an EBS message which the state would not use 7 to communicate the precautionary action?
8 A (Donovan) Because the plan appropriately 9 recognizes that we plan for a spectrum of accidents. Some 10 accidents in some scenario situations may not allow the 11 state to mobilize and staff its staff at the EOCs, in which 12 case then the EBS message would be the only means of 13 communicating.
14 And again, the state's plan calls for all schools, 15 all special facilities to receive a tone alert radio to be 16 installed at each special facility location.
17 Q Tone alert to hear the EBS message?
18 A (Donovan) Yes.
19 Q To hear the EBS message?
20 A (Donovan) That's correct.
21 Q Okay. Let me go back, we will leave that.
22 Look at the bottom of 47.
23 Well, let me just put the question to you.
24 When did Portsmouth decide on early dismissal?
25 A (Donovan) The evaluators didn't capture the time.
g Heritage Reporting Corporation
/ (202) 628-4888
DONOVAN - CROSS 22562 j 1 They notified us that it was before the SAU was notified of 2 the state's decision. I l
3 Q You say the evaluators didn't capture the time? '
4 A (Donovan) Didn't capture the specific time.
5 Q You mean it wasn't written down on one of those 6 EEM documents?
7 A (Donovan) It wouldn't have been written down on 8 the EEM document; it would have been written down on a log.
9 Q And it wasn't?
10 A (Donovan) No.
11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 l
Heritage Reporting Corporation (202) 628-4888
frONOVAN - CROSS- 22563 1- Q What time did the governor decide, as you
. !, 12' indicate at'the bottom of 172, what time did he decide to
- v 3- r(comnand late dismissal?
- 4 A- (Donovan) 1156.
5 Q And is that on page 45?
6 A (Donovan). It should be.
7 Q Yes, it is.
G On page 45, at 1156 there is a decision of late 9 dismissal. All right.
10 And we don't know what time Portsmouth made an u
11 early dismissal -- let's use the right language here. I'm 12, sorry..
13 .At 1156 the state decides on late dismissal. And-14 at-some intervening point after that Portsmouth decides on
- -- .15 -. early dismissal.
16 A (Donovan) That's correct.
17 And asLthe entry that you just mentioned 18 indicates, that the Board of Education staff, after 19 receiving the decision from the governor, began a 20 notification process. As our exercise report indicates, 1
21 under' Objective 16 --
22 Q Yes, I understand.
23 So the sequence was the governor made a decision.
24 The Board of Education began to communi'cate with the 25 appropriate school districts. And by the time they got to Heritage Reporting Corporation l
(202) 628-4888
\
f
DONOVAM - CROSS 22564 1 the Portsmouth area, Portsmouth officials at the EOC had 2 already decided on early dismissal.
3 Is that a fair statement?
4 A (Donovan) Yes.
5 Q All right.
6 A (Donovan) With the exception of the latchkey 7 children again.
8 Q Yes, yes. I understand that they were considering 9 the latchkey children.
10 A (Donovan) Well, they did more than consider.
11 They directed the schools to retain the latchkey children at 12 schools.
13 Q All right.
14 A (Donovan) Which in effect then becomes late 15 dismissal.
16 Q For them.
17 A (Donovan) Subset of school children --
18 Q Right.
IP A (Donovan) -- who could not have been delivered to 20 a home with a parent in it. ]
l 21 Q Right. And the governor had considered doing that j 22 and decided that that was not the best thing to do, right?
23 A (Donovan) That's correct.
24 Q That's why he ordered late dismissal.
25 Now, last question on this line.
Heritage Reporting Corporation (202) 628-4888
7 - -
DONOVAN - CROSS 22565 l
1 Are the Portsmouth officials acting appropriately-t s 2 in making"a decision for their own school-district prior to 3 hearing.anything from the state?
4 A (Donovan) Well, I think, as the report indicates, 5 that we felt that they should be trained to consult with the 6 state before reaching a decision.
7 O Right. And do you know'as you sit there today 8 whether in each of the 17 school districts, whether the 9 school plan or the local plan sets forth that requirement-10 that they wait until they get communications from the Board 11 of Education, or some central authority?
12 Is that in the plan?
13 A (Donovan) I have stated, and I will state again 14 that each of the SAU plans and each of the instructions 15 written for the individual schools say.they can receive 16 protective actions through one of three channels.
17 Q Local officials is one of them.
18 A- (Donovan) Local officials. Local officials' plans 19 say that they should implement actions taken by the state.
.20 Q Ah. So now we have found the culprit. The local 21 Portsmouth officials, who decided to recommend to the SAU-22 for Portsmouth that they take early dismissal, did not 23 follow the state plan?
24 A (Donovan) Exactly. And what do you think the 25 sentence says on page 185?
g Heritage Reporting Corporation
(
(202) 628-4888
DONOVAN - CROSS 22566 1 " Train staff on protective action implementation.
2 Additional training should be provided to the appropriate 3 staff to ensure that they understand the state's plan and 4 procedures for implementing protective actions for school 5 children."
6 Q What page is that on?
7 A (Donovan) Page 181, Issue No. 1.
8 Q Okay.
9 Brentwood did something else, right? They let 10 their kids go at the normal hours.
11 A (Donovan) Yes.
12 Q That's two.
13 MR. FLYNN: Excuse me. That's two what?
14 MR. TRAFICONTE: Two school districts.
15 MR. FLYNN: Oh.
16 THE WITNESS: (Donovan) No. Again, Swasey School 17 is not a school district where the Portsmouth SAU is a l 18 school district. I believe the Swasey School District is 19 one -- Swasey School is one school and not a school 20 district. There are 49 schools, I believe, in the New 21 Hampshire plume EPZ. The Portsmouth SAU, I believe, if my 22 memory is correct, is 10 or 11 schools. And the Swasey 23 School is one school.
24 The purpose of the -- I believe in reality the 25 school is even outside of the 10-mile EPZ, but inside the IIeritage Reporting Corporation (202) 628-4888
I f
DONOVAN - CROSS 22567
, ,_s 1 plume' planning zone. Then again, the bulk of the schools at
( \
2 Portsmouth, which is an ERFA G,'are also. technically outside A /
3 the 10-mile EPZ,: but they. are inside the identified planning f
l' l-4' zone.
5 BY MR. TRAFICONTE:
6 Q Now,.the statement that they are outside the 10-7 mile zone, do I understand that that would have weighed in 8 'in your judgment as'to whether the fact that this happened 9 was an ARCA or a deficiency?
10 A (Donovan) No. I was trying to --
11 Q That's irrelevant, isn't it?
12' bel. FLYNN: Excuse me. Will you let the witness 13 answer, explain his answer?
14 THE WITNESS: (Donovan) I'm trying to put the k 15 context --
16' MR. DIGNAN: This cross is getting close to 17 badgering, I respectfully submit.
18 MR. TRAFICONTE: 'This cross is not close to 19 badgering if Mr. Dignan's cross-in the past-in this 20 proceeding has set the standard of badgering.
21' JUDGE SMITH: That was relevant, I guess, but 22 nonresponsive to your question. So what do we do?
23 MR. TRAFICONTE: Well, I apologize.
24 JUDGE SMITH: You know, that's going to be one of 25 the problems that you are going to have with this type of Heritage Reporting Corporation (202) 628-4888
\
. _ _ _ - _ - ~
DONOVAN - CROSS 22568 )
1 extended cross-examination. You are going to get something 2 back that's not quite neat and to your liking.
3 MR. TRAFICONTE: I apologize. I have cut the ;
4 witness off in answering a couple of questions. I think the 5 reason is I'm concerned about time and I'm trying to move 6 forward. I will try to let the witness answer.
7 BY MR. TRAFICONTE:
8 Q So the fact that these particular schools where 9 this occurred are outside the 10-mile line, that's 10 irrelevant, right?
11 JUDGE SMITH: To the exercise.
12 THE WITNESS: (Donovan) To the exercise, yes.
13 BY MR. TRAFICONTE:
14 Q And your judgment about whether --
15 A (Donovan) To my judgment, yes.
16 O Just to probe a little bit further now.
17 This relationship between the central authority, 18 the local officials and the school district officials that 19 you've described, that relationship, is that the same 20 structure for day care centers, nursery schools and other 21 special facilities?
22 A (Donovan) In what regard?
23 Q Well, I'm sorry. That wasn't clear.
24 In this regard. That's to say, is local official 25 able to tell a day care center whether to shelter, evacuate, Heritage Reporting Corporation
)
(202) 628-4888 '
DONOVAN - CROSS 22569 1 et cetera?
(
%/
)' 2 A (Donovan) The local plans basically call for 3 local officials to determine the needs of special 4 facilities. And if needs are identified, then they make 5 those needs known to the IFO in terms of transportation 6 resources.
7 When the decision is made, they go back and verify 1
8 whether the affected special facilities need transportation I 9 implemented.
10 0 I was trying to really focus on day care centers, 11 for example.
12 Day care centers could dismiss early, could they 13 not?
14 A (Donovan) The state's plan does not call for
' f 15 precautionary protective actions for day care centers in the l(w 16 regard of early dismissal. It addresses specifically the 17 schools which are kindergarten through 12.
18 Q I see.
19 Is that an omission in the plan not to have a 20 procedure for day care centers that parallels the procedure, 21 precautionary procedures for schools?
22 A (Donovan) No, I do not believe it's an omission 23 in the plan. Because as you can appreciate the context, 24 most of the school children are piched up from residential 25 locations and taken by public transit means, a school bus,
,_s Heritage Reporting Corporation
/ (202) 628-4888
(
l l
l DONOVAN - CROSS 22570 l
1 through a contract from the school district to some resource 2 provider, collected and taken to the schools. And a return 3 to their homes by the same mechanism. l 4 In most cases, the day cares, the individual 5 parent or guardian, depending on the case, takes the 6 children to the day care location, and the hours for arrival 7 and departure are often skewed all over the place. They 8 place my child for three hours, they place my child for six 9 hours1.041667e-4 days <br />0.0025 hours <br />1.488095e-5 weeks <br />3.4245e-6 months <br />, they place my child for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />.
10 So the individual day care center knows its 11 arrangements with the people who are its clients. And it's 12 a completely different situation.
13 MR. TRAFICONTE: If I could just have a minute, 14 Your Honor.
15 (Pause.)
16 BY MR. TRAFICONTE:
17 G I would like to direct your attention, Mr.
18 Donovan, to page 216.
19 Now there was a prcblem, was there not, with the 20 way in which protective actions were communicated -- and we 21 are now in Massachusetts. We're dealing with the ORO.
22 There was a problem, was there not, in the way in 23 which protective actions were communicated to Newburyport?
l 24 Is that accurate? j 1
25 A (Donovan) No, that's not accurate. l 1
l I
1 Heritage Reporting Corporation I (202) 628-4888 1
DONOVAN - CROSS 22571 1 Q Well, what was the problem, as briefly as you can
/ \
. v)
.t 2 describe it? What was the problem with the Newburyport 3 schools?
4 A (Donovan) There was no problem with the 5 Newburyport schools.
6 0 There was no problem with the Newburyport schools.
7 JUDGE MCCOLLOM: May I ask a question just to 8 clarify it in my mind?
9 MR. TRAFICONTE: Yes, of course.
10 JUDGE MCCOLLOM: This goes back to the-sources of 11 information that the local schools have.
12 You say the Board of Education to local EOC and 13 EDS. If I am in that situation where I'm a school .
14 superintendent or whoever is going to make that action, what r~N
[/) w 15 instructions are to be he given as to how he would go, he 16 knows about all three of them, I presume.
17 How does he know what to do if he's uncertain? He 18 gets two mixed signals. What does he know? What does he 19 do?
20 THE WITNESS: (Donovan) His plan says that his 21 normal communications is from the Board of Education. So we 22 have these five SAUs that are out there?
23 JUDGE COLE: What's an SAU?
24 THE WITNESS: (Donovan) School administrative 25 unit.
,, -s Heritage Reporting Corporation '
j ) (202) 628-4888 l 'w 1
')
DONOVAN - CROSS 32572 1 JUDGE COLE: Okay. l 2 THE WITNESS: (Donovan) And they account for 85 3 to 90 percent of all the schools in the New Hampshire EPZ.
4 There are some private schools that are outside. But these 5 five SAUs account for all the public schools. So the only 6 thing that's missing from that equation is the private i 7 schools.
8 So the Board of Education calls these five SAUs.
9 Each of the SAUs has his own communication system to his 10 individual schools. And so there is a plan for the SAUs and !
11 there is a plan for the individual schools.
12 So the SAU's plan -- the normal path from the 13 planning perspective is that the Board of Education makes a 14 decision and the Board of Education coneuunicates that 15 decision, after the governor's approval, to the five SAUs.
16 They then, in turn, implement the protective actions as 17 called for.
18 And in implementing the protective actions, they 19 are to go to the local governments and give them their 20 transportation needs for that day The local governments go 21 back to the state with these transportation needs and 22 provide it. l l
23 If for some reason, a quick breaking emergency or 24 overlapping the notification to the SAUs, the EBS message or 25 local government message comes in with " implement this 1
Heritage Reporting Corporation (202) 628-4888 1
l i
1 ,
. DONOVAN - CROSS 22573 -1 1 protective act' ion", you would think, first of all, that the
- 2. state's EBS message and the state's Board of Education's 3 decision would be consistent. So the only possibility of an l 4 inconsistency would be between the local government and the !
5 state, because the local governments don't create EBS ;
6 messages. The state creates the EBS messages. ;
i 7 JUDGE MCCOLLOM: Okay. And what is'their !
8 direction there? Do they go --
9 THE WITNESS: (Donovan) Well, normally the local l 10 governments also go to the SAU. They go tc,the same top ;
11 official. !
12 JUDGE MCCOLLOM: Okay. i 13 THE WITNESS: (Donovan) The five SAUs would i 14 implement this. They don't go to the individual schools.
15 They have other persons in the local EOCs that go to l
16 individual schools, but that's again on this level: what 17 are your transportation needs today, what's your student 18 load vis-a-vis what we have as a plan default value.
19' So there are two pathways to the schools. The 20 hierarchical chain ideally is staked to the five SAUs, the 21 five SAUs then issuing and implementing instructions to all 22 public schools below them.
23 Another pathway can be from a local government to j 24 these five SAUs.
25 Now, the SAUs have, in some cases, schools that Heritage Reporting Corporation (202) 628-4888
DONUFM7 - CROSS 22574 1 are outside or beyond this one local community. So the 2 SAUs, however, only provide -- have a contact from the local 3 community in which the SAU is seated in. So an SAU would 4 not get multiple calls from local multiple communities. It 5 would get just a call from the local community that it's 1
6 physically located in.
7 JUDGE MCCOLLOM: Now the school itself knows to go j 8 back to the SAUs?
9 THE WITNESS: (Donovan) Yes.
10 JUDGE MCCOLLOM: But they also get the EBS --
11 THE WITNESS: (Donovan) They can get the EBS 12 message, yes.
13 And I think the plan is proper because, you know, 14 if you have a quick breaking emergency, the only thing that 15 may be able to be done is the EBS message, which would be 16 evacuate or shelter.
17 JUDGE MCCOLLOM: Is the EBS message then clear 18 that that is the only thing that can be done?
19 THE WITNESS: (Donovan) Well, it should be clear, 20 and when the -- in this case, again, the EBS message is 21 implementing protective actions. And the issue that I have 22 been examined on this morning was the implementation of 23 precautionary protective action. And that precautior.ary 24 protective action got overrun by a protective acticn.
25 JUDGE MCCOLLOM: All right. Thank you.
Heritage Reporting Corporation (202) 628-4888 ]
22575 DONOVAN - CROSS
. . l' RBY MR. TRAFICONTE:
O)
(x/ 2 Q At 1156 New Hampshire decides to recommend to its 3 school districts that'the children be held in school until 4 5:00, right?
5 A (Donovan) We're no longer on page 2167 6 Q I'm sorry. No, we are no longer on page 216. And 7 I was- asking a question about the timing again of the 8- precautionary re.: commendation to. hold the children in school 9 on the part ol dew Hampshire.
10 It was 1156, right?
11 A (Donovan) That was the decision and the 12 instructions were given to the notification staff 13 representing the Board of Education to begin the 14 notification call-out to the SAUs.
.15 Q All right.
16 A (Donovan) And they also call the private schools 17 that are not covered by the SAUs.
18 Q All right. Now, just so everyone is clear, I'm 19 going to ask you some questions about the-appropriateness of 20 that precautionary recommendation.
21 And would that be Exercise Objective No. 11, if I 22 ask you about the appropriateness of that protective action 23 recommendation?
24 A (Donovan) Yes.
25 Q It was appropriate, was it not, in your opinion, i
Heritage Reporting Corporation (202) 628-4888
(
- - - - _ _ - - _ - - _ - _ _ l
l DONOVAN - CROSS 22576 1 to recommend that? '
2 A (Donovan) Yes, it was.
3 Q Now did ORO recommend a similar protective action 4 for children? i 5 A (Donovan) No, because we wouldn't let them. '
6 Q Did they recommend in the sense of communicate to i
7 the FEMA control cell such a recommendation?
8 A (Donovan) Yes. I would like to take this 9 opportunity to go over these steps. I offered them 10 yesterday and you said you didn't want to hear them. So I 11 take your --
12 Q You think I am going to be in a different mood 13 today.
14 A (Donovan) At 1210, which is 14 minutes later than 15 when the State of New Hampshire came to the decision to !
16 implement precautionary protective actions of late 17 dismissal, the ORO went to the State of Massachusetts, which 18 is the FEMA control cell. And for purposes, I'll just call 19 it Massachusetts, with no offense to the State of 20 Massachusetts.
21 Q Commonwealth, by the way.
22 A (Donovan) Commonwealth, okay.
23 Q But if you are referring to a table, can you give 24 us the page?
25 A (Donovan) Well, this is on Table III, page 46.
Heritage Reporting Corporation (202) 628-4888
1 DONOVAN - CROSS 22577 1 .And this was following the discussion that the ORO staff had=
j 2' at 1202. I will.give you references of these_ discussions 3- 'and give you my content.
4 At the 1210 time,.they were told we will.only 5 implement protective actions on a case-by-case basic. So 6 .they were-told they would not implement precautionary 7 protective actions, only protective actions. That is, if S the conditions merit it, we will implement on a case-by-case 9 basis.
10 At 1245 --
11 Q- Does that mean recommendation by -- I'm not sure I 12 understand " case by case".
13- Do you mean they will take each one of the 14 requests for a protective action recommendation and the 15 Commonwealth would communicate for each one whether it's 16- okay or not?
17 A (Donovan) Yes.
18 Q I see.
19 A (Donovan) At 1245, there was an ORO briefing, and 20 they reported to the staff at that time -- that's Table III, 21 page 48 -- that protective actions would be made on a case-22 by-case basis, and that the schools will be evacuated if the 23 recommendation is made and if the decision is made.
24 And that normal closing of schools, as far as the 25 Massachusetts / FEMA control cell is concerned, would be the Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22578 1 case of the day. That that is, the control cell is telling 2 ORO no precautionary protective actions. And when the 3 normal school closing time comes, we will have normal school 4 closing.
5 At 1323, which is just before -- some nine minutes 6 before the general emergency notification was at the EOF, 7 again ORO was discussing protective actions for schools.
l l
8 And ORO went back to the FEMA control cell at 1330, two 9 minutes before the general emergency notification, and again 10 requested to the state, will you consider holding children 11 at school. In effect, late dismissal, a precautionary 12 protective action.
13 14 15 16 17 18 19 20 21
- l 22 23 24 25 1 Heritage Reporting Corporation (202) 628-4888
.,+
DONOVAN - CROSS 22579 i 1 A (Donovan) (Continues) They were again told by iw ,.
) 2'- the FEMA control cell that they would_not-allow 3 precautionary protective actions, and protective actions'
~4- .only would be made on a case-by-case basis.
L 5 Q What was that time?
6 A (Donovan) 1130 at this time.
7 Q' And is that on Table III?
8 A (Donovan) Table III, page 49. I 9 Q I see. The top entry, " Discuss holding school 10 children"?
11 A (Donovan) Right.
12 0 -So at 1330 there is a record here that ORO 4 -
13 discussed a late dismissal with the FEMA control cell?
14 A (Donovan) Right.
( 15 Q Okay.
16 A (Donovan) And the next step that occurred -- up 17 to.this time we are in site area emergency. The plant
'18 conditions wore trending down from the transient they had 19 earlier in the morning. .The wind was blowing out to the 20 ocean from the west to the east. .There was no release. And 21 the 1330 is the time, as Table III shows, we had an 22 initiating event happen within the plant, and causing --
23 another transient causing a pathway to occur to allow 24 release to begin.
1 25 At 1339, I'll call it the ERO but that's the Heritage Reporting Corporation
, (202) 628-4888 s
w-- _ - - - -
DONOVAN - CROSS 22580
% onsite organization, made a protective action 2 recommendation. This is on page 50, Table III, of a PAR, 3 protective action recommendation: Evacuate out the five 4 miles, shelter from five to 10 miles.
5 Two minutes later, 1341, this is on page 51, the 6 ORO went to Massachusetts, the FEMA control cell, with this 7 recommendation.
8 And in that case there is a correction I would 9 like you to note on page 51 in the text. It says from "two 10 to five miles in New Hampshire and Massachusetts." You 11 should strike out the "in New Hampshire and". The 12 recommendation was from two to miles in Massachusetts. So 13 the three words "in New Hampshire and" is deleted with this 14 recommendation.
15 At 1350 --
16 Q Should it be deleted in both instances? It says 17 it in the next line too.
18 A (Donovan) Well, no, just in that line, because in 19 New Hampshire they were recommending evacuation from zero to 20 five miles. But in this case, ORO is just talking to 21 Massachusetts.
22 Q I see.
23 A (Donovan) At 1352, which is page 52 of the 24 significant event log, the ORO faxes an EBS message to the 25 control cell for the control cell to review and approve.
l l
Beritage Reporting Corporation (202) 628-4888 1
mm ______ _ . _ . _ _ _ _ _ _ _ . _ . _ _ _ _ . . . _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ . _ - . _ _ - . . _ _ _ _ _ _ _ _ _ _ _ _ _
i' DONOVAN - CROSS 22581 1 .And again at 1358, also-on page 52, the ORO discusses the 2 PARS, draft EBS message. And in this time the context of
'3-
~
the discussion was we're going to evacuate the schools in 4 -the two communities of Amesbury and Salisbury which I call 5 -ERPA'B in our report. These are the two communities that 6 are affected by that zero to five miles, and to shelter the.
7 communities in ERPA'E, which is the areas from five to 10 8 miles.
9 At 1404, it's also on page 52, Massachusetts 10 authorized the protective action: Evacuate ERPA B and 11 shelter ERFA E. This was announced to the ORO staff at 12 1412. So the ORO staff at that time began to take actions =
13 to implement protective actions. This means that the 14 evacuation support coordinator went to the school 15 coordinator and said, we've decided to' evacuate the schools 16 in ERPA B and we have decided to shelter the schools in ERPA 17 E.
18 Between 1412 and 1415, the staff, who began the 19 phone calls out to the schools, quickly found out two 20 things, well, actually found out three things.
21 Number one, they found out the schools weren't 22 going to allow -- weren't going to commit their buses that 23 were sitting at the schools to evacuate the students. That 24 was number one problem.
25 Number two, they found that Merrimac, which is Heritage Reporting Corporation I \ (202) 628-4888
DONOVAN - CROSS 22582 1 outside ERPA E, had dismissed children, because by the time 2 the call got to Merrimac -- well, it's 2:15. We have 3 already dismissed our children. And they found out in 4 Newburyport likewise, that some of the schools had been ,
5 dismissed. Because by the time the call had been made, the 6 schools had already been dismissed.
7 The EBS message that had been discussed yesterday 8 and rediscussed at some point this morning had already been 9 prepared, had already been approved by the FEMA control cell 10 and was in the process of being faxed to the radio station, 11 and it was being faxed to the media center so that the media 12 center staff could go on out and brief the media while the 13 message was being broadcast.
14 And the sirens sounded at 1417, and the EBS 15 message was released at 1420. And we had, as we discussed 16 yesterday, the concurrent news broadcast.
17 The next thing, at 1510 -- excuse me. Or that's 18 the news conference which correctly states the school 19 status, and at - press release -- excuse me. Again, the 20 news conference, No. 6 at 1419, mentions that Merrimac 21 schools had been dismissed, and that at other schools the 22 dismissal had been delayed until they could be evacuated.
23 At 1445, the ORO director was given a br - ig by 24 his staff -- that's on page 55 -- that schools in Merrimac 25 had been dismissed. At Newburport, we had three schools Heritage Reporting Corporation (202) 628-4888 4
- __ ____ A
l' L
DONOVAN -. CROSS 22583 1- - sheltered: Brown, Bellsville and Immaculate Conception.
5 2 Four schools had been dismissed: Kelly, Ruppert A Nock, L/ .
3 - Newburyport High and Greater Newburyport. But the teachers 4 from the four schools where the students had been dismissed 5' were being sheltered.
6 We have an estimated time of arrival of buses to 7 the two school districts or schools represented in Amesbury.
8 and Salisbury of 1605 and 1645.
9 The evacuation support coordinator on his own 10 - initiative went back to the schools in these two communities 11 and said, what if I send you route guides. This at-1500, 12 page 55 of the significant event log. We will give you 13 route guides. So we will assist your buses in finding our 14 reception centers. That will expedite the evacuation of
.p 15 these students.
-(
16- Again, because of the instructions that we created 17 and as I discussed yesterday, the schools said "no". And 18 that was also summarized.as a discussion at 1508, again on 19 page 55. And they reported back at 1515 that the schools 20 will not commit any resources and that the ORO has to take 21 actions to implement all protective actions.
22 And I don't -- that's a description of all the 23 events that led to the issues that we discussed that we 24 discussed yesterday with the EBS messages.
25 Q Yes.
Heritage Reporting Corporation
[s s
(202) 628-4888 1
u- _._m______m_______..m. m .
DONOVAN - CROSS 22384 l 1 A (Donovan) But as I said, we tried, as a scenario 2 surprise and as a scenario condition, we tied ORO's hands.
3 They could not implement precautionary protective actions.
4 They could only implement protective actions. And when they 5 came to implement protective actions for the schools, we did 6 not let the schools commit their resources, because we 7 wanted to see the ORO's capability to provide compensating 8 actions, to provide transportation resources to these 9 schools.
10 JUDGE SMITH: Do you want to take a break at a 11 convenient time?
12 MR. TRAFICONTE: Yes. Can I just follow up and we 13 can take it maybe in three or four minutes?
14 BY MR. TRAFICONTE:
15 Q Mr. Donovan, I wanted to focus on the 16 precautionary protective action for the school children.
17 And I understand your response has taken us from that point 18 forward in time. Let's back up to the precautionary, the 19 precautionary protective action being, of course, either 20 early dismissal or late dismissal.
21 Look at page 49 at the top, the 1330 conference 22 call. Yes, page 49. It's in Table III.
23 Now I take it that that records that at that time 24 ORO discussed, perhaps recommended a protective action for 1
25 the children? l l
I Heritage Reporting Corporation ,
(202) 628-4888 l J
1 DONOVAN - CROSS A 22585 (Donovan) Yes.
2 Q Okay. Now, 3 is it your testimony that in a prior 4 time before 1330 there also had scussion been a di recommendation by ORO with the governor 5 ,
represented, of course, by the FEMA control cell, 6 concerning precautionary protective actions for children?
} 7 Is that your testimony?
8 A
(Donovan) Yes.
9 Q
10 Can you give us the entry on this table occurred? where that
\
11 A (Donovan) 12 At 1202 and 1210 on page 46.
Q All right.
13 Is the 1202 reference New Hampshire ORO to Mass governor?
14 A (Donovan) Yes.
15 Q
16 And is the 1210 reference the 1210 - 1214?
A (Donovan) Yes.
17 Q Of course, 18 neither one of the comment sections there makes any reference to precautio 19 nary actions for school children, right?
20 A (Donovan) No, it doesn't.
21 Q
Now here we have a problem --
22 A (Donovan) But in doing so 23 -
Q Let me ask the questions.
24 You can explain.
25 How do you know as you sit here that at th ose two times they also discussed recommended precautionary Heritage Reporting Corporation (202) 628-4888
22586 DONOVAN - CROSS 1
protective actions for school children?
Because I examined the players logs A (Donovan) 2 conversations and that were generated as a result of those 3 And I discussed with my 4
the notes that they wrote down.
As I said yesterday, my evaluation team 5 evaluation team. ints on this and to g
was not apprised of my scenario constra t d for the 6
7 that. So we communicated what conditions we crea e in cognizance as they wrote up their 8 ORO, and they took that 9 evaluations. tive, Our evaluation process focuses on the nega 10 Many times we don't write or 11 focuses on what went wrong.
What we focus on is what went 12 dialogue what went right. And there is a wrong.
And that's what our report writes.
13 14 reason for that. s with Of course, FEMA is in a collaborative proces 15 improved 16 the exercise participants to maintain an And so we not only look at the systematic 17 preparedness. ility to 18 implementation of plans, but we look at the ab And we 19 identify issues with the implementation of plans. to once we have identified an issue, 20 look at that point on, to improve plans or 21 working with the exercise participants 22 preparedness as the case may be.
All right.
We can break at this point.
23 Q Can you give me You say you reviewed player logs.
24 not the name, but the position of the players 25 the identity, Heritage Reporting Corporation (202) 628-4888
DONOVAN ' CROSS 22585 g_s 1 A '(Donovan) Yes.
q, .2 -Q Okay. Now, is it your testimony that in a prior 3' time before 1330 there.also had been a discussion 4 recommendation by ORO with the governor, represented, of 5 course, by the FEMA control cell, concerning precautionary 6- protective actions.for children?
7 Is that your testimony?
8 A- (Donovan) Yes.
9 Q Can you give us the entry on this table where that 10 occurred?
11 A (Donovan) At 1202 and 1210 on page 46.
12 Q' -All right. Is the 1202 reference New Hampshire 13 ORO to Mass governor?
14 A' (Donovan) Yes.
(3
(_,/ 15 Q And is the 1210 reference the 1210 - 1214?
16 A (Donovan) Yes.
17 Q Of course, neither one of the comment sections-18 there makes any reference to precautionary actions for l 19 school children, right?
l 20 A (Donovan) No, it doesn't.
21 Q Now here we have a problem --
22 A (Donovan) But in doing so --
23 Q Iet me ask the questions. You can explain.
24 How do you know as you sit here that at those two U 25 times they also discussed recommended precautionary Heritage Reporting Corporation 7-ws (202) 628-4888 l
I L-- _ a _
1 i
DONOVAN - CROSS 22586 j J'
1 protective actions for school children?
2 A (Donovan) Because I examined the players logs 3 that were generated as a result of those conversations and 4 the notes that they wrote down. And I discussed with my 5 evaluation team. As I said yesterday, my evaluation team 6 was not apprised of my scenario constraints on this and to 7 that. So we communicated what conditions we created for the 8 ORO, and they took that in cognizance as they wrote up their 9 evaluations. j 10 Our evaluation process focuses on the negative, 11 focuses on what went wrong. Many times we don't write or 12 dialogue what went right. What we focus on is what went 13 wrong. And that's what our report writes. And there is a 14 reason i'or that.
15 Of course, FEMA is in a collaborative process with 16 the exercice participants to maintain an improved 17 preparedness. And so we not only look at the systematic 18 implementation of plans, but we look at the ability to 19 identify issues with the implementation of plans. And we 20 look at that point on, once we have identified an issue, to 21 working with the exercise participants to improve plans or 22 preparedness as the case may be.
23 Q All right. We can break at this point.
24 You say you reviewed player logs. Can you give me 25 the identity, not the name, but the position of the players l
Heritage Reporting Corporation {
(202) 628-4888 )
1
DONOVAN - CROSS 22587
,_ 1 log?
L 2 A (Donovan) ~Public information advisor.
'3 Q Public information advisors,' players logs 4 reflecting communications between the public information 5 advisor and who?-
6 A . (Donovan) The public information advisor wrote 7 down the notes -- well, let me back up.
8 Q I'm. going to go to my office and pull the file. I 9 just want to'know what I'm supposed to look at.
10 A (Donovan) Let me back up. I want to give the 11 context.
12 Approximately every hour the ORO executive group 13 would have a meeting that they would discuss issues. And 14 depending on the responsibilities of each member, they would 15 write down their minutes of these meetings. I was also 16 there and observed'this.
17 Q Yes, I'm not talking about meetings. Understand 18 my question here.
19 A (Donovan) Okay, but that's where the source of 20 his logs is, I'm trying to point out.
y 21 Q- Yes. But maybe I want to go back and-repose the
\ -
22 question.
23 I'm focusing on the 1202 entry and the 1210 to 24 1214 entry where ORO is communicating with the governor.
25 A (Donovan) Well, at 1202 --
fg Heritage Reporting Corporation (202) 628-4888 1
pi i DONOVAlf - CROSS 22588
(
f 1
1 Q I'm not -- I'm sorry, go ahead.
l 2 A (Donovan) When he says, " regard legal authority 1
3 for sounding sirens and EBS messages", that's in the context 4 of implementing protective actions.
5 Q Yes, it's -- j
. 1 6 A (Donovan) And they were told, because my control !
7 cell was instructed to tell them that you can't implement 8 any precautionary protective actions.
9 MR. TRAFICONTE: Well, then why did they discuss 10 at 1330 the implementation of and recommendation of 11 precautionary?
12 A (Donovan) Because the ORO people were very 13 positive thinking people. They didn't want to accept that 14 "no". They kept coming back recommending again.
15 Q Good for them.
16 Did they make this recommendation regarding 17 precautionary protective acta.ons for school children?
18 Did they advise such a recommendation during the 19 1202 communication and during the 1210 to 1214 20 communication?
21 Specifically, Mr. Donovan, did they do at 1202 and 22 1210 to 1214 what your report says they did some hA r and a 23 half later, at 1330?
24 A (Donovan) They discussed the issue of a 25 precautionary protective rction. They were told "no". We Heritage Reparting Corporation (202) 628-4888
DONOVAN - CROSS 22589 1 will only implement protective actions and protective
. (O) 2 ' actions will be on a case-by-case basis.
3 Q All right. Now, your testimony that they did 4 discuss precautionary actions for the school children at L 5 1202 and 1210, is there documentary evidence of that fact?
6 A (Donovan) Just my interviewr with my control cell 7 and my witnessing the events.
8 Q I see. So the reference to the player log that 9 you made a few minutes-ago, that would not support as a 10 matter of documentary evidence that statement?
11 A (Donovan) It does support the statement that 12 protective actions will be on a case-by-case basis.
13 Q That I understand. But now that we are focusing-14 specifically on precautionary school protective actions, l d(O) 15 would those player logs, as far as you know, contain 16' evidence that they communicated that to the governor 17 specifically?
18 A (Donovan) I didn't look at all of them.- I looked 19 at several of them to reinforce.
20 Q Are there records of any type of the FEMA control 21 cell notes where they record what ORO had said to them at 22 1202 and 12107 23 Those are not available to use?
24- A (Donovan) No.
25 MR. TRAFICONTE: This would not be a bad time to Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22590 1 break for a few minutes.
2 JUDGE SMITH: When you were asking about player 3 logs, you meant in fact " player logs"?
4 MR. TRAFICONTE: Which we have, yes.
5 JUDGE SMITH: You have. All right.
6 MR. TRAFICONTE: The logs of the individual 7 players as they would record, yes.
8 JUDGE SMITH: Exactly. All right.
9 MR. TRAFICONTE: As opposed to evaluators.
10 JUDGE SMITH: Yes, right.
11 All right, 15 minutes.
12 (Whereupon, a recess was taken.)
13 14 15 16 17 18 19 20 !
21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 f _ - - -
DONOVAN - CROSS 22591
I 1 JUDGE SMITH- You may proceed.
[\..
f( ,/ 2 MR. TRAFICONTE: Thank you, Your Honor.
3 BY MR. TRAFICONTE:
4 Q I think this is the last question or last area on 5 schools, Mr. Donovan.
6 Did ORO go into this exercise assuming that in the
~7 event of an' emergency it was going to be able to make use of 8' the school buses in the towns?
9 A (Donovan) I don't understand your question.
10 Q Was it your impression, from observing the 11 exercise, that the ORO personnel had made certain 12 assumptions about the availability of school bus resources 13 in the six communities?
14 A (Donovan) In what context?
15 Q Well, I thought I understood your testimony this 16 morning to be that you put them -- I can't remember your 17 exact phrase -- but you made it more difficult for them by 18 having your FEMA control cell not permit the use of school 19 buses available to the six towns?
20 A (Donovan) Well,-that's partially correct. It was 21 the NHY control cell that did not permit the use of the 22 buses.
23 That ORO came back to the FEMA control cell and 24 asked the FEMA control cell, would you use your influence to 25' talk to these schools to see if they would commit their Heritage Reporting Corporation l
t-(202) 628-4888
DONOVAN - CROSS 22592 1 resources. And the control cell's answer was, no.
2 Q All right.
3 A (Donovan) But if I understand the context of your 4 question. We have decision-makers and you have 5 implementors. The decision-makers when they were told that 6 if a protective action to make a recommendation to evacuate 7 was concurred and became a protective action by the state, 8 the schools would evacuate.
9 I believe they made the assumption based on the 10 FEMA control cell statement that that would mean that the 11 schools would commit their resources.
12 Q All right.
13 A (Donovan) And when they came to implement that 14 decision they found out from the implementors, the schools 15 with the buses, that the schools would not implement their 16 resources. That the schools said, no, we will ignore the 17 fact that our buses and bus drivers are here; you provide 18 buses.
19 And so a decision was made, we will provide buses 20 and the instructions were issued to the bus dispatcher to 21 begin that action.
22 I pointed out that the school coordinator, the 23 evacuation support coordinator went back one more time to 24 the schools -- and the schools were played by the New 25 Hampshire Yankee control cell -- to ,"what if we give you Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22593 j_ 1 route guides? What if we assist you in moving these
/ T
( ). 2 children?", and they were told again, no.
3 So we stopped the implementation by allowing the 4 schools to commit their resources.
5 O I understand that.
6 A (Donovan) And like what I said earlier, I had 7 wanted to create the worst case. Conceivably at 1202 when I 8 was in the ORO EOC several rooms -- there's a large decision.
9 room and then there's a small room at the end where they 10 went in to make their calls to the FEMA control cell. I was 11 in that small room listening to the ORO director go over 12 these issues.
13 And if the ORO initiative had been accepted by the 14 state, for example, precautionary evacuation at this time,
,/,m
( ) 15 they could have evacuated all the schools at 1202. But that 16 isn't the conditions I wanted to create. I wanted to create 17 the ORO put in the mode of implementing a worst case 18 situation. That is, that they would not be able to 10 implement precautionary protective actions. That they would 20 be faced with a decision based on plant status which means 21 there is minimal time. You know, the general emergency EOF 22 recommendation was based on plant status, they had minimal 23 time to assess.
24 Basically, they're not the experts in plant 23 status, the onsite organ.ization is, so they take this
,-ss Heritage Reporting Corporation
[ ') (202) 628-4888 U
DONOVAN - CROSS 22594 1 recommendation and they go to the FEMA control cell. FEMA 2 control cell comes back with the concurrence.
3 And then in the middle of this, as they get ready 4 to implement, they get a second crisis tossed on top of 5 them: the schools won't commit their buses.
6 Like I said, I wanted to stress to the maximum 7 extent possible, from my perspective, their decision-makers 8 and their implementors to see if they fell apart or if they 9 continued on. And they continued on in an admirable 10 fashion. l 11 Q I would like to ask this question about the effect 12 of your decision to make it more difficult for them.
13 Mad ORO calculated the time it would take to 14 evacuate the schools based on the time necessary to mobilize 15 the buses available to the governments?
16 A (Donovan) That calculation is contained in the 17 evacuation time estimate for the ERPA.
18 Q I see.
19 There had been no particular determination of the 20 time necessary to mobilize sufficient buses to evacuate 21 school children. That timing sequence is contained within 22 the protective action calculation per ERPA?
23 A (Donovan) Yes, 24 I believe we v nver this the last time I was 25 here on this subject.
Heritage Reporting Corporation (202) 628-4888
i DONOVAN - CROSS 22595 .
Now, the fact'that you pressed them to come up
~
l Q
-2 with their bus resources themselves, a consequence of that
~
3 fact-is that it took them longer to mobilize the bus
, 4 resources than would have been necessary had the FEMA 5 control cell permitted them to'make use of local bus 6 resources; correct?
7 MR..DIGNAN: By local bus resources, you mean the 8 school's owned?
9 BY MR. TRAFICONTE:
10 Q By local bus resources I mean the non-ORO bus 11 resources, from whatever source?
12 A (Donovan) Well, if I understand --
13 MR. DIGNAN: Well, wait a minute.
14 I'm going to object on that basis, because I
/ O Q 15 understood the witness -- and he can correct me if xI'm wrong
-16 -- he testified quite precisely on this.
17 What hap,oened was, there was an attempt to get the 18 school's own buses and they were stopped in that effort.
19 There wasn't anything said yet, at least, about other local 20 buses that might --
21 MR. TRAFICONTE: Oh, all right.
22 MR. DIGNAN: -- it was the school owned.
23 MR. TRAFICONTE: That's my fault, I'm still being 24 unclear.
25 Heritage Reporting Corporation (202) 628-4888
(/
f m.__m. _.__ . _ . _ _ _ _ __________m___i___.______.____________________.__________________.____.______..________m______._._ ___.___ - _ _ _ _ _ _ _. ___ _ ___ _ _ _ -
DONOVAN - CROSS 22596 1 BY MR. TRAFICONTE:
2 Q I am referencing the schools owned. Some of those 3 are municipally owned, perhaps, some of those are private i
4 contractor. That isn't the relevant part. l 5 It's the school's own buses versus the ORO buses.
6 A (Donovan) Yes.
7 We precluded the use of the school's buses that 8 would have been at the schools at that time.
9 Q I understand.
10 Now, had they calculated the time it would take to 11 evacuate the schools based on the time it takes to mobilize 12 the school's own buses versus ORO buses?
13 A (Donovan) Well, I don't understand your question.
14 Are you asking about the difference between the 15 two?
16 Q Is there a planning defect here? Do we find here 17 that ORO is making a certain assumption about the time it 18 takes to mobilize buses? And it's making that assumption 19 note based on the time it takes to mobilize ORO buses?
20 A (Donovan) No , I don't think there's a planning 21 defect. The plan is calculated evacuation time estimates 22 for the two ERPAs, and that time calculation includes the 23 evacuation time estimates for the special facilities within 24 those two ERPAs.
25 And it is my understanding of that calculation 9
Heritage Reporting Corporation (202) 628-4888 )
l
' DONOVAN ' CROSS 22597 1 'that even.at worst case, and that's what we gave the ORO,
] worst case that if they had to mobilize and deploy their.
q ,
) 2 3' resources to provide compensating actions for the school 4 . districts, provide resources to the school, the worst case 5 is represented by that ETE.
6 Q In the normal course of conducting.an exercise 7 does FEMA interview the various school officials involved in 8 the exercise?
9 A (Donovan) I don't understand your question.
10 Q Well, if we looked at your report, I believe your 11 report in discussing the protective actions for -- the 12 exercise with regard to schools talks about interviews that 13 FEMA conducted with school officials, doesn't it?
14 A (Donovan) For ORO?
O
' ( ,) 15 -Q Yes. We're talking about Massachusetts now?
16 A (Donovan) Discusses that we interviewed three 17 schools; yes.
18 Q Yes.
19 And the question is: in the normal course is 20 interview of schools something that FEMA normally does?
21 A (Donovan) No.
22 O Why did you interview three schools in this case?
23 A (Donovan) Because in this particular case, this 24 was the only schools that had been indicated to us that had 25 resisted the pressure not to cooperate and had cooperated Heritage Reporting Corporation
[ (202) 628-4888
[L L__ _____ _ _ _ _ _ _ _ _ _ _ _ _ _ . ________ __
DONOVAN - CROSS 22598 1 with the ORO planning organization.
2 O I think I heard you say, the pressure not to 3 cooperate?
4 A (Donovan) Well, when local governments --
5 Q What are you referring to?
6 A (Donovan) -
pass ordinances and tell people that 7 they will be accused of violating certain ordinances if they 8 cooperate in the planning effort, I thought I was being 9 polite in putting that as pressure.
10 Q You can be impolite if you want to.
11 What local ordinances are you referencing?
12 JUDGE SMITH: Do you really want to go into this?
13 It you do, you're going to go?
14 MR. TRAFICONTE: I don't know of any local 15 ordinances. I just want to know what the witness is talking 16 about. He has referred to pressure from the --
17 THE WITNESS: (Donovan) I read it. I read a 18 document that you filed with this Board saying that a 19 certain member of the Amesbury School District refused to 20 talk to your people until he was convinced that he would not 21 be violating an ordinance. Now I don't know of any 22 ordinance. But I'm just going on the statement that your 23 organization filed with the Board.
24 JUDGE SMITH: Do you want to finish your answer?
l 25 MR. DIGNAN: You were describing why --
Heritage Reporting Corporation (202) 628-4888 i
_ _ _ - _ - .-- I
L DONOVAN - CROSS 22599' 1 THE WITNESS: (Donovan) Yes.
2 So we wanted to see and we -- two of the schools 3 organizations were within the plume EPZ and we went to them, 4 'and the report so acknowledges that they had implementation
^5 plans as to what they would do.
6 And one of the schools was outside the EPZ, as 7 found on page 225 of the exercise report. We acknowledged 8 there that they didn't have an evacuation plan. But the 9 purpose of their plan was that some of-their students'came 10 from within the EPZ. So here in effect you would have a !
11 late dismissal; they wouldn't let these students go back 12 into the EPZ if they were aware that there was protective
,13 actions being implemented in the EPZ, they would hold them 14 at that school until they could be picked up by their
,-~s 15 parents.
16 And the two day care centers that agreed to the 17 interview, as the report so acknowledges, said that.they had 18 written procedures and they had parental permission to 19 relocate the children in the event of an emergency.
20 And we just wanted to acknowledge it. That was 21 outside of our evaluation process, but we felt it was 22 something worthwhile to acknowledge and report.
23 BY MR. TRAFICONTE:
24 Q All right.
16 So normally FEHA does not - ,it's your testimony Heritage Reporting Corporation In ., (202) 620-4888
r-_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - . - - - - . - - - - - - -
DONOUAN - CROSS 22600 1 that FEMA does not conduct interviews like these?
2 A (Donovan) Like these; yes, normally we do not.
3 Q Do you have available to you, I believe it's 4 Exhibit -- well, let me check on the number.
5 Do you have available to you MAG Exhibit 91, which 6 is FEMA Guidance Memorandum EV-2?
7 A (Donovan) Yes, I do.
l 8 Q Could I ask you to turn to it. '
9 MR. TRAFICONTE: First of all, this I believe has 10 been admitted into evidence.
11 BY MR. TRAFICONTE:
l l 12 Q This document sets forth, does it not, FEMA 1
13 guidance as to how FEMA should review both the plan and 14 conduct and evaluate an exercise with regard to protective 15 actions for school children.
16 Is that a fair statement?
17 A (Donovan) No, it is not.
18 Q What part of that statement is incorrect?
19 A (Donovan) It does not describe exercise activity.
20 Exercise activity is described by the exercise evaluation 21 forms.
22 Q Could I direct you to pages 7 and 8 of this 23 document.
24 A (Donovan) I'm there. ;
1 25 Q Could you just review those two pages briefly. j Beritage Reporting Corporation (202) 628-4888
6 m 51 DONOVAN - CROSS 22601
'1' ~A (Donovan) It describes ~and discusses; exercise k ,)
m 2 requirements and evaluations.
.3 Q 'It-does?
4 A (Donovan) Yes.
5 Q It does, doesn't it?
6 A (Donovan) So this document was published and its 7 methodology _that's prescribed in this document was 8 superseded by the exercise evaluation methodology. ItLwas
- 9. published in June 20th, 1988.
'10 And another thing, if you recall our discussions 11' of this document, this document has to be interpreted in the 12- context that the planning organization has interpreted it, i 13 And in this case, schools are not_ identified as:
, 14- emergency response organizations. Schools are identified as 15 implementors of protective. action.
16 And here we are talking about the ORO. And in
~
17 this case, the schools are nonparticipating parties with the 18 exception of the three so noted.
-19 O By the way, on the front page of my copy of this 20 . document the-date is not set forth there. I have a November 21 13 without a year.
22 Does yours have a year?
23 A (Donovan) 1986.
24 Q So the fact that at page 8 of EV-2 at the bottom-25 third'where the document says: "With respect to simulating I
l l -
Heritage Reporting Corporation ]
L 3 (202) 628-4838 j Ns.' '
i l
L_-__---__ - _ - _ _ _
i DONOVAN - CROSS 22602 1 evacuation of school children in an exercise the following 2 guidelines are provided."
3 Those guidelines are not in effect, then, today?
4 A (Donovan) They're only in effect if the school in 5 question is doing these actions.
6 Q Oh, I see.
7 A (Donovan) And in this case, as we evaluated the 8 ORO exercise the ORO provided notification. We evaluated 9 the notification element. The ORO provided transportation, 10 and we evaluated the transportation.
11 Since the schools, vis-a-vis our scenario, didr't 12 commit resources, didn't participate in the exercise, that 13 type of interview that's described in these pages would only 14 be done if the schools received and implemented the 15 protective actions on their own. G, 16 In this case, the organization that was being 17 evaluated was ORO. The organization that was implementing 18 and deciding protective actions was ORO. And the actions so 19 taken are those that we evaluated.
20 Q Let me see if I understand.
21 These pages 7 and 8, and I take it, it goes on to 22 9, they're still in effect and they still provide guidance 23 for what FEMA does vis-a-vis contacts and interviews with ;
24 schools who participate in exercises?
25 A (L .ovan) The mechanistic process described in I
Heritage Reporting Corporation (202) 628-4888 j l,
1 l
. DONOVAN - CROSS 22603 g .. 1 this document has been superseded by the mechanistic process
\s 2 that is described in the EEM for objective 19.
3 : JUDGE SMITH: . Incidentally, what relevance does 4 this have?
5 MR..TRAFICONTE: The ultimate question here is, 6 the fact that the schools were not participating, I would-7 like to probe his judgment as to whether that impacts on the L
L 8 quality of his judgment'concerning preparedness for schools.
~
9 JUDGE SMITH: Well, I thought you were talking 10 about -- all right.
11 12 13 14
^m_) 15 16 17 18 19 20 22.
22 23 24-2E Heritage Reporting Corporation (202) 628-4888
- [k .
DONOVAN - CROSS 22604 1 Q So your testimony is that the relevant portions of 2 the EEM document have incorporated these pages, in essence?
l 3 A (Donovan) That isn't what I said. )
l 4 Q All right.
5 A (Donovan) I'm saying in 1986, this document came 6 out as a planning document. It came out with a statement 7 regarding protective actions, and it came out with a process 8 that describes things that should be addressed when one 9 exercises, school who are participating in the planning 10 process or participating in the implementation of protective 11 actions.
12 In 1988, we came out with a methodology for 13 evaluating exercises that replaced the earlier version of 14 methodology. And that described a process, and that process 15 is the one that we followed.
16 Q Does the fact that the schools in Massachusetts 17 were not participating and therefore not subject to the 18 inquiry that's described in the EEM procedures, does that 19 impact on the quality of the judgment FEMA makes about the 20 preparedness for schools?
21 A (Donovan) No, it does not.
22 Q There is no greater -- let me withdraw that.
23 Your judgment that there is adequate preparedness 24 for schools and school children is not more con 3ectural in 25 this case because the schools were not cooperating?
Beritage Reporting Corporation (202) 620-4E88
DONOVAN - CROSS 22605 r^s 1 A (Donovan) No. Again, FEMA has found, as many l \
\~ l 2 other governments has found, that special facility 3 organizations will act in their own interest to protect 4 those persons within their responsibilities.
5 The SPMC is a plan that provides the notification 6 process. It provides an education process. It provides 7 tools as public education documents and offers of assistance 8 to develop implementing plans if those schools choose to 9 participate in the exercise.
10 We will offer a tone alert radio which would 11 expedite if those schools chose not to have a radio, which I 12 assume most of them already have in their offices, but we 13 will give them a specific tone alert radio that would come fs 14 on if the EBS messages come on.
l \
5/ 15 The plan fully meets all of our planning 16 requirements. The exercise fully demonstrates that the ORO 17 response organization recognizes their responsibilities.
18 Despite all the handicaps that I created for them, they took 19 efforts to implement protective actions. They did so in a 20 proper and effective fashion.
21 And based on that, FEMA's finding that was given 22 to the Nuclear Regulatory Commission is the finding that we 23 stand behind: That appropriate protective measures can be 24 taken to protect the public's health and safety.
25 MR. TRAFICONTE: Your Honor, at this point I would a
l i
Heritage Reporting Corporation j jT
( __
) (202) 628-4898 )
1
DONOVAN - CROSS 22606 1 like to have a document marked, and I would like to offer it i 2 into evidence. The problem is I don't have the complete 3 document and I don't have xerox copies of it. But I will 4 provide those. This is something that I had promised to do 5 at several points during this cross-examination.
6 There was produced at Mr. Donovan's exercise 7 deposition and marked as Exhibit No. 5, a complete sample 8 blank set of evaluation forms which is the FEMA exercise 9 evaluation methodology. I have already marked and 10 identified, I believe at least one and perhaps two of these i 11 for at least one or two different objectives, 1
12 It's my intent to offer, and again obviously in 13 blank, but it's my intent to offer a complete set of these 14 objectives into evidence at this time. I would offer this 15 document and perhaps as a place holder, and then I would --
16 I have them in my office. I will xerox complete sets and 17 distribute them.
18 Before I get -- I'm not sure what we can number 19 that as.
20 JUDGE SMITH: You know, often we just number 21 things in sequence.
22 (Laughter)
I 23 MR. TRAFICONTE: Pardon me? l l
24 JUDGE SMITH: Well, like 100, 101, 102.
25 ER. TRAFICONTE: 101.
l l
Heritage Reporting Corporation l (202) 628-4888
i 4
1 i,
- O DONOVAN - CROSS 22607
' j) s( l' JUDGE SMITH: 101. You like that.
. ;2' .
~ MR. DIGNAN: What's the purpose of the offer?' To 4
-3 Eshow the existence' of the forms, because I will. stipulate' to
- .4' that?' I.mean.just before we get a one-inch exhibit in, 5 -what
- are you trying to establish with it?-
6 I'm. wondering if we could do it by stipulation.
7' BG1. 'TRAFICONTE: By stipulation?
8' I'm trying to establish each objective is 9' essentially glossed by FEMA.in a series of questions in 10 these' forms that indicates obviously --
11 MR. DIGNAN: Okay. So you want the-printed 12 material in. It's not just to establish that there was such
-13 forms.
f- 14 MR. TRAFICONTE: Oh, no, no. I want the questions
\ 15 set forth in this document to reflect the' nature of the FEMA 16 review process, yes. And it seems like the easiest and the' 17 quickest way to do it. It's all blank obviously.
18 JUDGE SMITH: Well, do you want to --
19 MR. TRAFICONTE: I would like to offer it.
20 JUDGE SMITH: -- number it?
21 MR. DIGNAN: You want to offer it for what it's 22 ' worth in light of the witness's testimony as to what it 23 means.
24 1s that what you are saying?
25 MR. TRAFICONTE: Y9s.
jg> Heritage Reporting Corporation (202) 628-4838
.t
}
i j
DONOVAN - CROSS 22608 1 MR. DIGNAN: Okay.
2 MR. TRAFICONTE: And if there is no objection -- 1 3 JUDGE SMITH: So are you looking to us for some 4 support or guidance?
5 MR. TRAFICONTE: Just to admit it. We will mark 6 it as 101. I would like to have it admitted into evidence 7 and then I will produce copies. It's a fairly lengthy 8 document. I will produce copies, distribute them and give 9 them to the reporter today or tomorrow.
10 JUDGE SMITH: We will receive it subject to you 11 providing the necessary copies, complete copies.
12 MR. TRAFICONTE: Yes.
13 JUDGE SMITH: It's a blank set of FEMA evaluation 14 forms.
15 MR. TRAFICONTE: With a cover sheet headed 16 " Exercise Evaluation Methodology".
17 (The document referred to was 18 marked for identification as 19 Mass AG's Exhibit No. 101 and 20 received in evidence.)
21 MR. TRAFICONTE: Your Honors, I am going to pass 22 on to, I believe it's 4 (c) , and ask the witness some 23 questions about adequate staffing and training.
24 BY MR. TRAFICONTE:
25 Q Mr. Donovan, it's a fact that the FPMC identifies I
Heritage RepGrting Corporation (202) 628-4888 1 1
DONOVAN - CROSS 22609
-~ . 1 certain positions and does not provide ORO personnel to
( ,) 2 staff those positions on a 24-hour basis, correct?
3 A (Donovan)- Are you referring to evacuation-
.4- specific positions?
5 Q Yes. The plan describes these positions as 6 evacuation-specific. .That's a fact, isn't it?
7 A (Donovan) It identifies certain positions, yes.
8 Route guides and dosimetry recordkeepers, which is-9 as of Amendment 6, Figure 2.10, I believe.
10 Q Now,-do you have the plan available to you?.
11 A (Donovan) I believe it's in this room.
12 Q Well --
13 A (Donovan). I don't have a copy in front of me,-no.
14 Q- We may not need to consult it. Let me just
~l', h _
(_,/ ' 15 represent to you that in the portion of the plan, Section 16 2.2.1 at page 2.1-1, there is a statement that -- in the 17 context of these evacuation-specific positions -- that an j 18 evacuation will occur "over a relatively short period of 19 time".
20 This statement is offered, I believe, in'the form 21 of an explanation for why 24-hour staffing for certain 22 evacuation-specific positions is not part of the ORO plan.
l
. 23 Is it a fact that an evacuation will occur over a )
24 relatively short period of time, Mr. Donovani j i
25 A (Donovan) I don't understand the constraints or f4 .
Heritage Reporting Corporation j
.{., (202) 628-4888 ;
l
r-~
DONOVAN - CROSS 22610 )
I conditions of your question.
2 Do you want to define "short"? {
i 3 Q Well, long enough to trigger the next shift. )
1 4 A (Donovan) The next shift of what? l 5 Which of these two categories are you referring 6 to?
7 Q Well, that's a fair statement. !
i 8 Let's take traffic guides. When are traffic l J
9 guides, according to the plan, to be posted at locations? l 1
10 A (Donovan) Traffic guides, there are two shifts of 11 traffic guides provided for in the plan.
12 Q How about reception center staff, when are they to 13 be posted?
14 A (Donovan) There are two shifts of reception 15 center staff provided for and identified in the plan.
16 Q Are you counting -- what are you counting as the 17 two shift?
18 A (Donovan) They have an agreement with the Yankee 19 Mutual -- I don't know the -- I'll have to look up the full 20 name. But the Yankee Atomic Organization and ORO has an 21 agreement which we discussed when we went over my testimony 22 on the plan. And it provides for persons to provide second 23 shifts for the two positions you have just asked me 24 questions about.
25 Q Oh, I see. Okay.
Heritage Reporting Corporation (202) 628-4888
n .-
, ;j DONOVAN - CROSS 22611' f 1 These individuals from Yankee Atomic-are'not'part 2- of the ORO organization, correct?
3 A (Donovan) They become part of the ORO' 4 organization.when they report to and assume an emergency
'S position with the ORO organization.
l 6' Q. All right.
L
[- ~7 Well, have they received'ORO training?
8 A (Donovan) No, they have not.
'9 .Q They have not.
10 So that the second shift traffic guide that comes 11 from' Yankee Atomic has.not received ORO training, correct?
12 MR. DIGNAN: Isn't this repetitious of cross-
'13 examination that took place in the plan' phase?
~
-14 MR. TRAFICONTE: Well, we are coming --
15 MR. DIGNAN: Didn't we go over it at length about, 16 your phrase is "on-the-job training", and we chased down 17 whether or not the Yankee people were health physicists who
~18 would take certain positions?
19 I have a distinct recollection of this.
20 JUDGE SMITH: That's right.
21 MR. TRAFICONTE: Yes. And the focus this go 22 around is I'm going to pursue traffic guides, and I'm going 23 to link it to the exercise to determine the performance and 24 .his evaluation of the performance of the second shift 25 personnel. It's going to link to the exercise, g Heritage Reporting Corporation
- t (202) 628-4888
DONOVAN - CROSS .
22612 1 There's no question that I asked him a series of l 2 questions last time concerning --
3 MR. DIGNAN: Can we do better than " link"? I mean 4 you found some centilla of evidence so that you can cross it i
l 5 again, or is it really relevant to the exercise?
I l 6 MR. TRAFICONTE: It's relevant to the exercise.
1 7 JUDGE SMITH: Of course, the issue that we are l
8 hearing, I believe, is what flaws were revealed in the plan 9 by the exercise.
10 MR. TRAFICONTE: All right.
11 BY MR. TRAFICONTE:
12 Q Let's take traffic guides. Now, traffic guides 13 have not been trained by ORO, correct?
14 MR. DIGNAN: Which ones?
15 THE WITNESS: (Donovan) Which ones?
16 BY MR. TRAFICONTE:
17 Q I'm sorry, I'm talking about the second shift, the 18 people who are going to come from Yankee Atomic.
19 A (Donovan) As we went over before, to say they are 20 not trained is not an accurate statement.
21 Q No. Trained by ORO.
22 A (Donovan) No, that's still not an accurate 23 statement.
24 Q All right. j 25 A l (Donovan) Before they assume their position, they i Heritage Reporting Corporation ]
(202) 628-4888
._m.__ - . _ _ _
o 1 .
?
DONOVAN - CROSS 22613
. )--( 1 receive training at the location or at the facility that a
c i\s 2 they are to execute their duties. And the' descriptions for 3 the first shift is to ensure that their replacements fully 4 understand their duties and responsibilities before the 5 first' shift leaves.
6 So the procedure calls for.on-the-job orientation L
R 7 and training. And again, the people were selected to form i 8 different resource pools and it's a determination by both' l
9 New Hampshire Yankee and the Yankee Atomic Organization that 10 the people who are identified and put in these pools have 11 skills, knowledge and aptitude to be able to receive this 12 on-the-job training and perform adequately.
- 13. Q All right. I want to focus on traffic guides.
14 First of all, in accordance with the plan, at what i
.(m,/ 15 ECL do the first shift traffic guides report to their posts?
16 A (Donovan) They mobilize at the site area 17 emergency, at the staging area.
18 Q They mobilize at the staging area.
19 When they mobilize at the staging area, does that 20- commence their shift?
21 A (Donovan) Yes. l 22 Q Now how many hours -- let's assume the accident.
- 23. just doesn't develop for a period of time.
24 How many hours could they wait at the staging area 1
25 before their shift, as defined by the plan, would end?
l Heritage Reporting Corporation )
( (202) 628-4888 -
Nm i
DONOVAN - CROSS 22614 1 A (Donovan) My interpretation would be 2 approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
3 Q Twelve hours.
4 At the point at which 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has passed, would 5 we then have the Yankee Atomic second shift group arrive to 6 constitute the second shift of traffic guides?
7 A (Donovan) It's conceivable, yes.
8 Q I mean that's what would happen if 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> --
9 A (Donovan) Well, it depends. I mean they may have 10 provided bunks and cots and said, we don't need you. Or 11 here, we've just rented this hotel. You guys go sleep over 12 here until we need you. I mean there are two options, but 13 one of the options is that they were there. They were all 14 wide awake. And they were there for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />.
15 Then I would assume that the staging area leader 16 would implement his plan and call for a full shift 17 change --
18 Q I see.
19 A (Donovan) -- to be brought in.
20 Q When do they leave the staging area and go to 21 their posts out in the field?
22 A (Donovan) It depends.
23 Q Well, when would be the earliest point?
24 A (Donovan) If they implement a precautionary 25 protective action for the beaches, they would go out at site Heritage Reporting Corporation (202) 628-4888 .
(
)
l
DONOVAN - CROSS 22615 1 area emergency.
7--
i \
\ ,/ 2 Q They could go out at site area emergency?
3 A (Donovan) A portion of them, yes.
4 Q A portion of them.
5 A (Donovan) Again, the traffic management manual is 6 defined to provide implementing, in this case, traffic 7 control and access control for both of the ERPAs and for the 8 Salisbury / Plum Island beaches. And so if precautionary 9 protective action or protective action was taken, the 10 implementation by mobilizing and deploying, or deploying 11 these people to the field, would be in consonance with 12 either the contemplation of or the actual actions.
13 Q Yes, it's the contemplation of that I'm focusing
,_ 14 on.
_, 15 In a site area emergency, some of the traffic 16 guides report to the field, do they not?
17 A (Donovan) It would depend on the season, the way 18 the plan is currently written.
19 Q All right. Let's talk about the summer.
20 In the summer, they could report to the field?
21 A (Donovan) Yes.
22 Q Now if they are out in the field and 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> has 23 gone by, that's the end of their shift, right?
24 A (Donovan) That's correct.
25 Q There is no relationship, is there, in terms of fN Heritage Reporting Corporation (202) 628-4888 (v)
t DONOVAN - CROSS 22616 1 timing between the site area emergency and a general 2 emergency?
3 A general emergency could follow upon a site area 4 emergency in any number of hours.
i 5 A (Donovan) That's correct.
6 Q So it's just as likely as not that the actual 7 performance of their duties as traffic guides could occur 8 much later in the sequence after a site area emergency as it 9 would occur within the 12-hour period?
10 A (Donovan) That's a possibility. Yes.
\
11 Q And isn't this why you need 24-hour staffing, 12 because you don't know when the actual performance of the 13 response task is going to be required?
14 A (Donovan) That's correct.
15 Q Now, therefore, it's just as likely as not that 16 the second shift from Yankee Atomic will turn out to be the 17 fir st traffic guides under this plan who will actually be 18 dir9cting any traffic.
19 A (Donovan) It's a possibility.
20 Q Well, it's more than a possibility.
21 It's just as likely as not, isn't'it?
22 A (Donovan) Well --
23 MR. DIGNAN: I'm interested in the change of the 24 Attorney General's views of probabilities in this line, 25 let's put it that way. I thought our big concern in life Heritage Reporting Corporation (202 628-4888
DONOVAN - CROSS 22617 i
, s; I was.the fast-breaking accident.
t 4 L 1 i ,/ 2 Now I've got 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from the site area -- ,
1 I
l 3 JUDGE SMITH: Well, not only that, but -- 1 4 MR. DIGNAN: -- to the general emergency. I would {l 5 imagine I'm going to have half the federal government here 6 by that time.
7 JUDGE SMITH: Well, you see, this is where --
8 MR. DIGNAN: Not at Fenway Park either.
9 JUDGE SMITH: -- the aspect of the case that --
10 (Laughter) 11 MR. TRAFICONTE: I was already thinking he's got 12 half the federal government here.
13 JUDGE SMITH: And it's not your birthday anymore.
p-s 14 (Laughter) x ,) 15 MR. DIGNAN: Yes, sir.
16 I'm going to beg the Board's indulgence. I mean, 17 we've chased the Seabrook evacuation planning process now 18 for many months. And the big issue has been the fast-19 breaking accident, how do you handle it.
20 Now, as I understand the hypothetical, we've hit 21 site area emergency and we hang there for 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> before a 22 general emergency.
23 JUDGE SMITH: I understand that.
24 MR. DIGNAN: And if there is anything to the 25 realism doctrine at all that the Commission has said, I f-'s Heritage Reporting Corporation
( ) (202) 628-4888
'u j 4
i.
I DONOVAN - CROSS 22618 1 would imagine by that time we've got state cops, federal 2 cops. We've got people flying in from all over the country 3 to help this situation out.
4 Do we really have to chase down whether or not --
1 5 JUDGE SMITH: Furthermore, it raises a question 6 that has never been fully answered by the Commonwealth. And 7 that is, when you first filed your contentions, you 8 explained to this Board and asked us to take into account 9 the fact that the governor of Massachusetts has determined 10 that in a fast-breaking accident in the summertime the 11 beaches cannot be evacuated within the time, or with the 12 consequences that he believes are essential for the health 13 and safety of the citizens of the Commonwealth. Therefore, 14 .there is no point in engaging in emergency planning.
15 However, now we are talking about the benefits of 16 emergency planning in the type of accidents where emergency 17 planning is possible, and you are pointing out that it is 16 possible.
19 Now what is the position of the Commonwealth with 20 respect to those types of accidents?
21 You are not alleging that no planning is helpful, 22 that there would be no dose savings. It's the opposite 23 thrust that you are making right there.
24 I mean, the Commonwealth can plan, if it elects 25 to, and it acknowledges benefits from planning on a slow-Heritage Reporting Corporation (202) 628-4888 l
l
DONOVAN - CROSS 22619
,-~s 1 breaking accident.
r 1
)
sm ,/ 2 MR. TRAFICONTE: Well, Your Honor, if we knew that 3 every accident was going to be a 12-hour lead time and if we 4 knew that --
5 JUDGE SMITH: No , you can plan for those and 6 without any harm.
7 MR. TRAFICOMTE: Pardon me?
8 JUDGE SMITH: And still maintain your position 9 that no planning for the fast-breaking accident is going to 10 be adequate. That avoids the question at all.
11 MR. TRAFICONTE: It doesn't avoid it.
12 JUDGE SMITH: It's a non sequitur to say if you 13 knew that all accidents were going to be slow breaking, you p-s 14 would plan. That is not the point.
I J
(_,/ 15 The point is you are now examining on the slow-16 breaking accident as to which you can plan.
17 MR. TRAFICONTE: Your Honor, if we took the 18 position that we can't plan for the fast-breaking accident, 19 but we can plan for the slow breaking, therefore here is our 20 plan, it omits any response for the fast breaking, but it 21 does have provision for the slow breaking.
22 Our position is that we would be aiding and 23 abetting the licensing process.
24 Q That's right.
25 MR. TRAFICONTE: So therefore --
Heritage Reporting Corporation i; Q ) (202) 628-4888
DONOVAN - CROSS 22620 1 JUDGE SMITH: So now your failure to plan is for 2 litigative purposes and not because of impossibility. And i 3 that's what I want you to say if that's the case, and we'll 4 get on with it.
5 MR. TRAFICONTE: Our failure --
6 JUDGE SMITH: Your failure to plan is to bolster 7 your position in litigation and not because it is i 8 impossible. That is the inference I draw from your 9 statement just now and from your line of questioning. And 10 that's what I want to know, is that the case.
11 MR. TRAFICONTE: Our failure to plan is, it. the i 12 first instance, because we don't believe we can effectively 13 plan for the fast-breaking accident. That's the reason why 14 we are not planning, i 15 JUDGE SMITH: No. That is not the reason why you 16 are not planning where there is a slow-breaking accident.
17 MR. TRAFICONTE: The reason why we're not planning 18 for the slow-breaking accident --
19 JUDGE SMITH: Is for purely litigative purposes; 20 is that true or not?
21 MR. TRAFICONTE: No. It is not for purely 22 litigative purposes, because the reason we are not planning 23 at all is the fast-breaking accident. If we participated in 24 planning for the slow-breaking accident but did not 25 participate in planning for the fast-breaking accident, and Heritage Reporting Corporation (202) 628-4888
7____
l-i I DONOVAN - CROSS 22621 i
1 we said that, we would see ourselves as aiding and abetting lif-c i'kj 2 the licensing process.
3 JUDGE SMITH: Right.
4 (Laughter) 5 JUDGE SMITH: So that is why you are not doing it.
6 You don't want to aid and abet by planning the licensing 7 process. That's all right. You've explained it.
8 MR. TRAFICONTE: Yes, I mean I don't think there 9 is an inconsistency there. I'm not sure of the consequences 10 of it.
11 JUDGE SMITH: No, I don't know if you have ever 12 really sat down and explained to the Board or to anybody 13 that you don't engage in planning where there would be 14 admitted benefits to your citizens in a slow-breaking
/
-s k ,)\ 15 accident, you don't do it because you don't want to hurt 16 your position before this Board and before the Commission.
17 Now we understand that. But I don't know if you 18 have ever said that before. You sure have said it now.
19 MR. TRAFICONTE: Well, just let me make sure 20 before I sign off on your characterization of our position.
21 We don't know what kind of an accident, if any, 22 Seabrook is going to have.
23 JUDGE SMITH: I know. I know you don't.
24 MR. TRAFICONTE: I mean if we knew --
25 JUDGE SMITH: But you know that it is possible to
,~' Heritage Reporting Corporation
( (202) 628-4888 x
I DONOVAN - CROSS 22622 1 plan for the slow breaking.
l 2 MR. TRAFICONTE: Yes. And we also know at the O, l 3 same time that we couldn't rely on there only being a slow 4 breaking.
5 JUDGE SMITH: A non sequitur.
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
e i
DONOVAN.- CROSS '22623 1 1 MR.-TRAFICONTE: I guess not in our view.
<; 3. ,
f( ,) 2 The disconnect here is that in your view that
- 3. might be a non sequitur. From our perspective that is part 14 and parcel of the decision not to --
5 JUDGE SMITH: Do you concede that there could be, 6 if Seabrook is permitted to operate, that there could be a-7 slow-breaking accident?
8 MR. TRAFICONTE: Yes.
9 JUDGE. SMITH: Do you concede that.there could be 10 dose savings achieved by planning for a slow-breaking 11 accident?
12 MR. TRAFICONTE: After the plant was licensed?
13' Yes.
,, 14 JUDGE SMITH: Before or after?
( ,) 15 You're alleging there is going to be a lack of 16 preparation because of no planning before.
17 MR. TRAFICONTE: And therefore no license would 18 issue.
19 JUDGE SMITH: I know. But assuming licensing?
20 Assuming that you can't be guaranteed of winning 21 in this forum?
22 MR. TRAFICONTE: I think I can make that 23 assumption.
24 (Laughter) 25 JUDGE SMITH: Assuming licensing, I think you Heritage Reporting Corporation (202) 628-4888
__--_-_- _ - _-_ _ _ u
DONOVAN - CROSS 22624 1 concede that there can be dose savings achieved by 2 relicensing planning for the slow-breaking accident.
3 MR. TRAFICONTE: Assuming licensing?
4 JUDGE SMITH: Yes.
5 MR. TRAFICONTE: Yes. Assuming licensing.
6 JUDGE SMITH: And yet, you fail to do it for 7 licensing purposes and not for public health and safety 8 purposes; is that correct?
9 MR. TRAFICONTE: No. That I obviously won't sign 10 off on, because there is a link in our view between the 11 failure to plan or the refusal to plan and public health and i
12 safety.
13 The Commonwealth has clearly taken the position 14 that public health and safety is promoted most by the 15 Commonwealth by attempting to prevent the licensing of 16 Seabrook.
17 JUDGE SMITH: Now the other point I would like to 18 raise is: what does this line of questioning have to do 19 about the exercise itself?
20 It seems to me that it is purely plan-specific.
21 You have yet to demonstrate, in effect, that anything 22 revealed by the exercise --
23 MR. TRAFICONTE: Because of the shortness of time 24 I will just tell you exactly what the relevance is.
25 They did do a second shift. They did have Yankee Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22625 s 1 ' Atomic come down and perform some traffic guide actions.
s_, 2 And in fact,~I was going to take the witness through'the 3 performance by the-Yankee Atomic traffic guide and his l
L 4 capacity to perform adequately because I' don't'believe the 1
Li 5 exercise indicates that the second shift Yankee Atomic 6 traffic guide knew what he-was doing.
7- JUDGE SMITH: All right.
8 MR. TRAFICONTE: I mean, that's the link..
9 JUDGE SMITH: Get on with it, we'll listen.
l 10 BY MR. TRAFICONTE:
11 Q Mr. Donovan, do you believe that the second shift 12 -Yankee Atomic traffic guide knew what he was duing?
l 13 A (Donovan) There was more than one. Yes, I do.
p_. 14 Q All right.
I
\ 15 MR. TRAFICONTE: _If I could have a minute, I will' 16 find the location of the Yankee Atomic traffic guide.
17 BY MR. TRAFICONTE:
18L Q There's an Extent of Play, is there not,' on 19 traffic guides for the ORO?
20 A (Donovan) Yes, there is.
21 Q What number is that?
22 A (Donovan) 328, starting on page 3.2.38, 23 Q And we're in Exhibit 61; correct?
24 Starting on page what?
25 A (Donovan) 3.2.38.
f-%g Heritage Reporting Corporation s (202) 628-4888
)
i
l I
DONOVAN - CROSS 22626 '
1 MR. FLYNN: No, it is not 61. 61 was rejected. ]
I 2 MR. TRAFICONTE: Applicants' 61. l I
3 Applicants' 61 is the Extent of Play but our copy 4 of this document is his Attachment A to his testimony.
5 MR. FLYNN: I see. 1 1
6 MR. TRAFICONTE: It's the same document.
7 BY MR. TRAFICONTE:
8 Q Now, Mr. Donovan, we will cut through this.
9 Isn't it a fact that the second string or the 10 second shift -- second shift not second string -- that the 11 second shift Yankee Atomic traffic guide was evaluated 12 during the exercise and had to respond to a mini-scenario 13 with regard to a traffic impediment?
14 A (Donovan) That's correct.
15 Q Now, where in your report do you refer to the '
16 response that that traffic guide made to that mini-scenario?
17 A (Donovan) We refer to both responses on page 227.
18 Q And at the top of 2277 19 A (Donovan) Yes.
20 JUDGE COLE: You' re in 43 (f) now?
21 MR. TRAFICONTE: Now I'm back to the report, yes.
22 THE WITNESS: (Donovan) Yes.
23 BY MR. TRAFICOMTE:
24 Q Which of these two simulated traffic accidents 25 that you are describing there, which of the two was the one Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22627 p;ss 1- in which the second shift Yankee Atomic traffic guide was k 2 responsible?
3 AL (Donovan)' As a traffic reroute mini-scenario,-
4 which would be found in volume 4, page 822-9 through 15.
5 Q Of the scenario document?
6 A- (Donovan) Yes.
7 And also the second shift changeover can be-found 8 in volume 1, page 72.18 through 20.
9 And also, there's two Extent of Plays.- There's 10 Extent of Play 3.28 that we're on; and there's also 3.2.24 11 which talks about shift changeover, using. personnel from 12 Yankee Atomic organization.
~13 Q And in your judgment, the reroute that -the second -
14 shift Yankee Atomic traffic guide performed was an adequate p-~
( ,/ 15 one?
16 A (Donovan) You have grossly mischaracterized his 17 duties. j 18 Q I thought you said the mini-scenario involved here 19 was a reroute?
20 A (Donovan) The traffic guide is not responsible 21 -for making reroute determinations. The traffic guide is 22 responsible -- in this case the scenario called for the 23 traffic guide to have witnessed an accident. His l 24 responsibility in witnessing an accident is to report it to l 1
,' 25 the system. He doesn't know the impact of that accident on Heritage Reporting Corporation
-( (202) 628-4888 l
1 L-__ .
( .
DONOVAN - CROSS 22628 1 the evacuation route network. He is not to take self-
'2 initiated events. He reports it to the system.
3 In this case the system goes all the way from the 4 traffic ~ guide via his communication network through a 5 dispatcher to the staging area leader at the staging area.
6 And in this case if it is a potential impediment, 7 the staging area leader is supposed to go to the ORO EOC to 8 determine and seek their advice and counsel, and perhaps, 9 directions on whether a traffic reroute is necessary.
10 So the traffic guides duties are: (a) to 11 acknowledge and report. First of all, let me step back. We 12 had too many scenarios. ORO's system calls for three means 13 to monitor traffic flow and traffic impediment. We tested 14 two of the three because the third one was very easy.
15 They have traffic guides at access control points 16 and traffic control points who have, depending on their 17 characterizations of where they are sitting, a visual sight 18 of either hundreds of yards or even in some cases half miles 19 or farther of road networks in each direction.
20 So like anyone else, if traffic is not moving they 21 can -- it's either not moving or I can see an accident.
22 We have the buses that are running routes. We 23 have multiple routes being run. We have buses that are l
24 running routes to special facilities. We have buses that 25 are running transit-dependent routes. They also have Heritage Reporting Corporation (202) 628-4888 1
_ __ I
p:
DONOVAN - CROSS 22629~
'1' instructions, if-you.see an accident you are to report in.
77--()
[I\m,/
2 The third means which we chose not to test because b
3 it.gives everything away is, ORO has a contract with a 4- -helicopter service to put planes in the' air. Up to five 5 ' helicopters. simultaneously. And these five~ helicopters
' 6 would be flying around just like they do over the' city.every 7 morning and afternoon and reporting. It's hard to go to a 8 major city where you don't see radio stations or some other 9 organization sponsoring a means to identify traffic 10 impediments.
11 And I don't know about this city, but in the city 12 I live in day-to-day -- but I'm not there day-to-day --
'13 ' Seattle, the' helicopters have a direct patchwork.right to g-4 14 the police. If they see an accident they are authorized to
-\s,/
15 go right on a channel, right to the police dispatch in 16 . Seattle. So the state patrol or the appropriate police 17 department and ambulance can roll right to the scene of the 18 accident. And they work in close collaboration.
19 The same planning has been thought of by the ORO. -
20 Now, obviously, if we let them fly helicopters, all five of 21 them which they were willing to do, they could have seen any ;
22 traffic impediment within a matter of minutes.
1 23 . We wanted to test the human network on the ground.
24 So we tested the human network on the ground. In each case,. j 25 not only for the ORO organization but for the New Hampshire, Heritage Reporting Corporation gO (202) 628-4888
DONOVM4 - CROSS 22630 1- State of New Hampshire, we gave them two mini-scenarios: one 2 to be seen by a traffic guide; and one to be seen by someone 3 who could report something else.
4 Casey's address is -- I read into the record that 5 mini-scenario for the traffic impediment, and the traffic 6 guides duties was to report. We waited for the shift 7 change. Our evaluators were there. In this case, the 8 controller, because we didn't create an accident, the 9 controller steps forth and says, if you turn in this 10 direction -- first of all, you hear a large bang, and if you 11 turn in this direction this is what you'll see. And then 12 the controller stops. And then it's up to the player in 13 this case to follow his procedure and report what he saw.
14 And we evaluated all aspects of that exercise 4 l
15 play. And it's our position, as stated here, that they 16 performed in a timely manner, consistent with the procedure, !
17 and all actions were appropriately taken.
18 MR. TRAFICONTE: Your Honor, I want to get done --
19 I want to do all this before lunch. Can we agree to 20 continue and keep going. I think I'm almost through. I 21 think I can be through in about 15 or 20 minutes.
22 I propose to then have what redirect there is and 23 recross all before lunch. I'm sure that amendable to Mr.
24 Donovan, I guess, 25 l Heritage Reporting Corporation l (202) 628-4888
_ _ - - _ _ _ _ - 1
DONOVAN - CROSS 22631
/
,x 1 BY MR. TRAFICONTE:
(,,) 2 Q- I would like to ask you a series of questions
.3 about the exercise, to the extent that it evaluated the 4 capacity at the monitoring station to monitor evacuees at 5 the rate necessary to ensure that the plan meets FEMA 6 guidance.
7 Do you recall testimony when you were here before 8 concerning the monitoring rate at the - your testimony 9 regarding the monitoring rate at the monitoring stations, do 10 you not?
11 A (Donovan) Yes. I recall our testimony was 12 discussing what the procedures called for. What other 13 correspondence called for, for througnput, I believe was the
,_ 14 term you used.
/s\
( ,/ 15 Q Yes.
16 A (Donovan) And, yes, we had extensive discussions 17 on that subject.
18 Q Now I would like to pick up the same line, but 19 this time focus on how and to what extent the exercise 20 tested and evaluated the throughput capacities at the 21 monitoring stations.
22 Could I direct your attention to page 226 and 227, 23 I'm sorry, I hope that's the right page.
24 A (Donovan) That's objective 29 which is the one we 25 were just discussing. 227.
l l
l fs Heritage Reporting Corporation (v ) (202) 628-4888
- l l
2-_______.
Yehs DONOVM1 - CROSS 22632 l 1 Q Yes, 227 is actually --
2 A (Donovan) Well, 227 and 228 talks about objective G,l 3 21.
4 Q Yes.
5 A (Donovan) Is that the objective you would like to l
l 6 talk about.
7 0 227, 228: the discussion of objective No. 21.
8 Now first of all, is there any discussion of the 9 evaluation that you did of the throughput capacities?
10 A (Donovan) Not in the context as it's stated in 11 the Extent of Play.
12 But again, I pointed out in my opening statements 13 that the evaluators had the Extent of Play and the 14 evaluators were to evaluate the objective in the context of 15 the Extent of Play.
16 For this exercise, for both offsite response 17 organizations we set up tests. And in this case we set up 18 tests to test their monitoring and throughput capabilities. j 19 In each case the test consisted of a number of 20 individuals who would be run through in a given time 21 sequence. And our evaluators in this write-up said that 22 they implemented their procedures in accordance with the 23 plan, and the implementation of the procedure in accordance 24 with the plan based on our previous testimony indicated that
)
25 approximately every 60 seconds a person was monitored at the '
Heritage Reporting Corporation (202) 628-4888 1
L f
DONOVAN - CROSS 22633
- ,-~ l' . monitoring stations.
k ,/ 2 The exact Extent of Play statements are found in 3 3.2.16 and 3.2.17 -- excuse me, 3.2.14. And in that regard 4 there was a 20 minute test. If you recall, there was 14 of 5 these monitoring stations and.we told our evaluators to pick 6 .five and pull the other nine players out.
7 One of Mass AG's testimonies says there was seven 8 monitors in the monitoring station, that's correct. But 9 only five of the monitors were engaged in the test. The 10 other two monitors were down at the decontamination station.
11 Because in addition to just running people through 12 .as part of this test we wanted, as the Extent of Play says, 13 one out of every fifth person to be found-to have a 14 contamination source.
7s k 15- So we are, you know, if we just had everyone walk
-16 through and there's no contamination source, they could go 17 pretty fast. So we wanted.to put enough persons in, one out 18 of five, which I think is a very high percentage, with spot' 19 contamination sources simulated through the use of Coleman 20 mantle lanterns to keep the monitoring rate honest, insofar 21 as the monitors were concerned because their objective was.
22 'not only to conduct the monitoring rate in accordance with.
23 their procedure, but obviously, part of our objective as 24 well is to see if they can detect contamination.
25 .
Heritage Reporting Corporation
( (202) 628-4888 I
DONOVAN - CROSS 22634 1 A The ORO demonstrated it and he hasn't asked me 2 questions, but New Hampshire demonstrated it as well. They 3 have a different rate, but they did demonstrate --
4 Q I understand they have a different rate.
5 I'm interested only in Massachusetts and the rate 6 at this point. )
7 Just on the Coleman mantle, and the mantle is part 8 of the -- the wick part, is that what we're talking about?
9 A (Donovan) It's like a wick, yes.
10 0 So you had some of these, and I take it they will 11 trigger a frisking device?
12 A (Donovan) They are a Beta admitter, thorium is 13 the nuclide material that is used, that the mantle lanterns 14 which normally are cotton, but there are some that are 15 synthetic. And they are impregnated with thorium. And if 16 you remove the plastic bag they will definitely give a high 17 alarm on most instruments that are so alarmed. If you leave 18 them in a plastic bag they still emit enough Be'ta radiation 19 that either the FEMA civil defense monitoring equipment or 20 the equipment used by the ORO will be able to detect.
21 Q All right.
22 You may have been in error when you said 3.2.14 as l
23 the Extent of Play on this portion of the exercise. It's 24 3.2.15, is it not? I 25 A (Donovan) You're right. I'm sorry.
Heritage Reporting Corporation (202) 628-4886
4 DONOVAN - CROSS 22635 7/'y 1 Q Just a quick question on the contamination aspect
)
(/ 2 of the test.
3 Did you have several of these Coleman mantles 4 available to you and then you distributed them to the people 5 that you were passing through?
6 A (Donovan) The controller organization was 7 responsible to ensure that approximately one out of five -- l 8 the Extent of Play describes that they should put them out 9 in a random fashion so that approximately one out of every 10 five persons entering the monitoring trailer would have a 11 source on them. I 12 Q I see.
13 They didn't give it to every fifth person, did
,m 14 they?
? \
c I
\. / 15 A (Donovan) I didn't monitor how they -- I believe 16 the Applicants' testimony contains documentation on how many 17 persons actually had mantle lanterns.
18 Q All right.
19 A (Donovan) Again, my evaluators were given the 20 Extent of Play. In most cases, if the procedures are 21 implemented properly, because we focus on the negative we 22 end up hardly seeing anything. And in this case, this 23 write-up says that they implemented their procedures in 24 accordance with what the procedures call for.
25 Q I'm just trying to get the details of the mantle l
[~'N Heritage Reporting Corporation (202) 628-4888 l
l
DONOVAN - CROSS 22636 1 exercise.
2 This was put on the person of these people, one of ,
3 these mantles?
4 A (Donovan) Yes.
- 5 Q Like in a coat pocket or something?
6 A (Donovan) Well, I'll have to check the Extent of 7 Play, if it gave a specific location. But normally it would 8 put it in a cuff, a sleeve cuff or a pant cuff.
9 Q You wouldn't put it in the same place for each of 10 the people who is carrying it, would you?
11 A (Donovan) Well, it would depend on how the 12 persons are clothed, I suppose. You may have only 13 limited --
14 JUDGE SMITH: What he is getting at is, do you do 15 it in such a way that is predictable which person and where 16 that person may have the source?
17 THE WITNESS: (Donovan) Well, the instructions --
18 JUDGE SMITH: Even if you don't have them, you can l
l 19 predict?
20 THE WITNESS: (Donovan) Well, normally they would 21 put them in several locations, I would expect.
22 JUDGE SMITH: Do you understand the direction of 23 the question?
24 THE WITNESS: (Donovan) Right, j I
25 I don't know exactly where they placed them.
l l
Heritage Reporting Corporation i (202) 628-4888
DONOVAN - CROSS '22637
<x 1 BY MR. TRAFICONTE:
l )
3%_s/ 2 Q You don't know, okay.
l 3 A (Donovan) It wasn't my job. It wasn't my people's I l
4 job to monitor --
5 Q It was the control organization that did that.
6 A (Donovan) We only have two evaluators: one inside 7 watching the monitoring function; and they had one outside 8 watching the monitoring of the vehicles.
9 O All right.
10 Now, the other aspect of the test was to test the 11 rate, the throughput rate; correct?
12 A (Donovan) That aspect of the test was to give 13 them a large number of people to be monitored in 20 minutes, 7s 14 and to see if the monitoring rate achieved what the
- V) 15 procedures called for.
16 Q Yes.
17 Because as you discussed last time you were here, 18 and as I obviously cross-examined you, they were looking for 19 a quicker or shorter per evacuee monitoring rate, were they 20 not?
21 They wanted to approve a faster rate?
i 22 A (Donovan) No.
23 We had already approved the instrumentation which 24 allowed them to specify a certain rate in their plan. We
]
1 25 were asking for the demonstration of their people's ability j l /N Heritage Reporting Corporation l (uJ ) (202) 628-4888 I
l u- . _ _ _
DONOVAN - CROSS 22638 1 to implement the procedures. And the procedures specify, I 2 believe, a time frame of approximately 60 seconds per person 3 at a monitoring station to be frisked.
4 0 Yes.
5 What I'm trying to determine, Mr. Donovan, was l
6 part of the exercise here was to demonstrate the throughput 7 capacity at the monitoring station; correct?
8 A (Donovan) By demonstrating it they could 9 implement their procedures, 10 Q Fine. That was the purpose.
11 Now, just so we are clear, I'm going to ask you 12 some questions to probe whether what you did could have )
13 demonstrated that.
14 First, I take it, it's your testimony that the 4
15 exercise did demonstrate that?
16 A (Donovan) Yes, it is.
17 Q Now, out of 14 monitors how many did you actually 18 use at this monitoring trailer? How many were actually 19 participating in the test?
20 A (Donovan) Five on each shift.
21 Q Five.
22 Why didn't you use 14?
23 You had 14 people there, did you not?
24 A (Donovan) Because that meant we would have had to 25 .
get a larger number of persons to play the public, I Heritage Reporting Corporation (202) 628-4888 i
l
9 DONOVAN - CROSS 22639 f s. 1 suppose. Plus we felt that a demonstration of approximately
/ \
- ( ,,/ 2 one-third of the staff there would give us a reasonable and 3 achievable demonstration of the rate.
4 Q I see.
5 A (Donovan) One of the issues was they demonstrated 6 that they could staff, so they provided staff to fulfill all
- 7. the positions called for in the plan. And then we took a 8 subset of that.
9 Q Yes.
10 A (Donovan) But in normal process, for example, in 11 watching the vehicles outside we wouldn't -- with only two 12 evaluators you wouldn't watch him for 14-hours monitor a 13 . vehicle, you would watch him on several occasions to see 14 that he is. implementing this plan and procedures. And then i
15' you would cease that aspect of your evaluation.
16 Q I understand that now.
17 To an extent, the throughput capacity of a 18 monitoring trailer has to do with the logistics of the
- 19. trailer, does it not?
20 A (Donovan) Yes, it does.
21 Q Do you remember some cross-examination, and Mr.
22 Dignan on redirect, we were asking you about the flow of the .
i 23 evacuee traffic through the trailer.
24 Your exercise test in no way' tested the capacity 25 of the monitoring trailer to handle the necessary ,
s Heritage Reporting Corporation (202) 628-4888
{
1
-l DONOVAN - CROSS 22640 1 throughput, did it?
2 A (Donovan) I don't understand your question.
3 0 What aspect is unclear?
4 The exercise test as you designed it or as it was i 5 designed did not test the capacity of the monitoring trailer 6 logistica11y to handle the necessary throughput, did it?
7 A (Donovan) For that portion that we asked them to 8 demonstrate; yes, it did.
9 Q But you only had five stations manned; correct?
10 A (Donovan) Well, in the context of our Extent of 11 Play we tested --
12 Q I understand that they did it in accordance with 13 the Extent of Play. I'm probing whether the Extent of Play 14 was an appropriate design to test the capacity at these two 15 centers. I understand it's in accordance with the Extent of 16 Play.
17 You had 14 monitors there. That tested their 18 staffing. And then you released nine of them. And you 19 tested throughput with only five; right?
20 A (Donovan) That's correct. I 21 Q The reason for that is you would have needed more
[
^
22 people to play the public to run through, if you were going 23 to actually do 14 stations; correct?
24 A (Donovan) That's correct.
25 Q So that's one constraint.
Heritage Reporting Corporation (202) 628-4888 i
DONOVAN - CROSS 22641 7- ~\ 1 Now, you only did it for 20 minutes, right?
/ A
\s/ 2 A (Donovan) That's correct.
3 Q And you could have done it for a longer period.
4 Why didn't you do it for a' longer period?
5 A (Donovan) Because I thought that was a reasonable 6 base to base our evaluation upon.
7 Q You thought that five individuals doing something 8 for 20 minutes was a reasonable basis to infer that they 9 could do that, that 14 people could do it for 10-hours?
10 A (Donovan) Yes.
11 Q None of this appears -- none of this, no reference 12 'to this aspect of the exercise appears in your report, can 13 you explain --
,-s 14 A (Donovan) Our report and the executive summary k -) .
m 15 says that one must confer with the Extent of Play to put the 16 evaluation of the objective in its proper context.
17 Q Okay, I'm not sure that's responsive.
18 A (Donovan) I didn't write the report for you. I 19 wrote the report for the exercise participants. The 20 exercise participants in this case knew the Extent of Plays 21 that we agreed upon.
22 FEMA headquarters knew the Extent of Plays that we 23 agreed upon. NRC knew the Extent of Plays that we agreed 24 upon.
25 We were all communicating on the same wave length Heritage Reporting Corporation l (/"~K) s _-
(202) 628-4888 l
l L - - - _ _ _ _ _ _ _ _ _ _ - - - _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _
DONOVAN - CROSS 22642 1 that when we said objective 21 was demonstrated, that it was 2 demonstrated in the context of the Extent of Play.
3 Q All right.
4 If I read to you objective No. 21 it says:
5 " Demonstrate the adequacy of procedures, facilities, j
6 equipment, and perconnel for the registration and 7 radiological monitor'ing and decontamination of evacuees."
8 Right?
9 A (Donovan) That's correct.
10 Q And we know, don't we, that FEMA has applied a 20 11 percent times the evacuee population over a 12-hour period 12 as essentially what adequate facilities and procedures and 13 equipment and personnel means, at least in part; correct?
14 I mean, that's what this standard means. This is 15 one of the few cases where we actually have FEMA on record 16 with a standard that's checkable; right?
17 MR. FLYNN: Objection.
18 MR. DIGNAN: Where are we going with this?
19 Is it the Commonwealth's position that we should 20 have had the equivalent of 20 percent of the EPZ out there 21 marching for 12-hours?
22 MR. TRAFICONTE: I think where we're going is so 23 transparent that the objection can be nothing other than 24 just an effort to run us out of time.
25 It's obvious what the objective is, where I'm Heritage Reporting Corporation (202) 628-4888
l i
DONOVAN - CROSS 22643 l 1
1 going. Where I'm going is --
7_
f \ k
( ,/ 2 MR. DIGNAN: Your point is --
3 JUDGE SMITH: It is an inadequate sampling.
4 MR. DIGNAM: It's an inadequate sample, in your 5 judgment. Isn't that the point?
6 JUDGE SMITH: But not you're going --
7 MR. TRAFICONTE: My personal judgment?
8 MR. DIGNAN: Yes.
9 Because in his judgment it was good enough. And 10 you are the only two talking. So in your judgment it is --
11 MR. TRAFICONTE: We are clearly not the only two 12 talking.
13 (Laughter) 14 MR. DIGNAN: In my judgment, it was an adequate A
() 15 sample. You're down two to one. Now, why don't you get 16 your colleagues to vote and we'll all split it up and the 17 Board will finally decide. But why do you beat it too death 18 for. That's what is wasting the time.
19 JUDGE SMITH: I know Mr. Traficonte wants to 20 finish and he is using his precious time.
21 All you have right now is an inference that you 22 disagree that the sample was adequate and that's all you 23 have. And the only testimony you have is that it's 24 adequate.
25 Now, the rest of the statement about the only Heritage Reporting Corporation
/s )
g (202) 628-4888 x_/
DONOVAN - CROSS 22644 1 opportunity where FEMA has declared a standard, I don't 2 think he means that as a part of his question.
3 Do you really mean that as part of the question?
4 MR. TRAFICONTE: I'll withdraw the last one.
5 JUDGE SMITH: Yes.
6 MR. TRAFICONTE: More of an editorial comment. j 7 MR. FLYNN: Your Honor, I suggest that this line 8 is not as clear as it could be. And we would move along 9 more expeditiously if it were.
10 JUDGE SMITH: It's his cross-examination.
11 MR. FLYNN: Well, I just want to make a suggestion 12 here. We're talking about several different things. We're 13 talking about demonstrating the rate of monitoring, and I 14 think that has been addressed ad nauseam, i
15 But the questions also suggest that maybe we 16 should have tested the stamina of the monitors to work for 17 10-hours in one shift.
18 JUDGE SMITH: He says it's sampling. It's a 19 sampling.
20 MR. FLYNN: Or he may be talking about whether 21 there was room enough in the trailer for all those people to 22 come through at one time.
23 JUDGE SMITH: Let him alone, if his cross-24 examination produoes an ambiguous results, that's his 25 responsibility.
Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22645 i x 1 MR. FLYNN: Very well.
) !
1
\_ / 2 BY MR. TRAFICONTE:
3 Q Mr. Donovan, the question on the table I think 4 when I editorialized is, this entire process of measuring j i
5 the rate and the throughput is not mentioned in your report, 6 is it? f 7 JUDGE SMITH: He said that and very, very clear.
8 MR. TRAFICONTE: Did he answer the question with 9 a, yes?
10 JUDGE SMITH: He said he didn't write it for you; 11 he wrote it for people who know what they're doing --
12 (Laughter) 13 MR. DIGNAN: Is that a finding?
,-s 14 I'm going to propose it.
U) 15 (Laughter) 16 JUDGE SMITH: Excuse me, you know quite a bit 17 about it, obviously. But it has to be read in the contexc 18 with the Extent of Play and scenarios.
19 MR. TRAFICONTE: This is a difficult area for me.
20 I reviewed the transcript on this and the last time we got 21 into this area Mr. Donovan told me that if I bsd arrived at 22 the center of the second shift I would have been told to go 23 out and handle the traffic. So I must have a weakness.
24 JUDGE SMITH: Wasn't it, play in the traffic?
25 MR. TRAFICONTE: It was play in the traffic.
/"'N Heritage Reporting Corporation t
y v) (202) 628-4888 l
f DONOVAN - CROSS 22646 1 JUDGE SMITH: Right.
2 (Laughter) 3 BY MN. TRAFICONTE:
4 Q Do you have any records or did you ever have any 3 records available for your revien that indicated exactly 6 what your evaluators saw when they witnessed a certain 7 number of people go in the door at one end and come out the 8 door at the other at the end of the 20 minutes?
9 A (Donovan) No , I do not.
10 Q At no time, before or after September 7 when you 11 discarded the documents, did you have any documentary 12 evidence of what the actual rate was; correct?
13 A (Donovan) That's incorrect.
14 Q What was the documentary evidence on the basis of 15 which you found that they met the throughput?
16 A (Donovan) Mr. Keller was the team leader for the 17 ORO evaluation effort. When he received it from the writer 18 for this objective, he brought it to my attenti'on that he 19 was sending it back to the writer because it didn't document 20 the numbers that Mr. Traficonte has pointed out the 21 documentation is missing.
22 The writer met with hie three members, because 23 there were two reception centers. And all four of them were 24 part of the evaluation of this obj+ctive. He came back and 25 said that we did not hold individual stop watches on Heritage Reporting Corporation (202) 628-4888
h~ ,
l DONOVAN - CROSS 22647 l ,-ss 1 individual persons, but they did demonstrate, in accordance
'(N ,-)
m 2 with the procedures, the throughput rate.
3 And by saying in our write-up that the plan was 4 implemented in accordance with what it is called for, that 5 they demonstrated the rate.
6 The fact that we sent it back and we asked for 7 reverification and it came back and said, we were more 8 interested in the quality of job that they were doing, 9 because we knew overall after a period of 20 minutes we 10 would be abic to assess on a basis, collectively, whether 11 they got the number through that they should have gotten 12 through or not.
13 And their answer was, they did a quality job. And
,-s 14 that the number that should have been passed through in 20 t i ks ,) 15 minutes passed through.
16 Q But when Mr. Keller went and talked with these 17 individual evaluators they didn't know what the numbers 18 were, did they?
19 A (Donovan) Well, you asked them, in so many 20 seconds per person and he said, no. Because again, the 21 evaluators were not interested in timing each individual 22 frisk for each of the five monitors. They were interested 23 in a 20 minute process did they do a quality job of 24 evaluation. That is, they were saying, if I put myself in 25 the hands of that frisker, all he knows, he's got to do is
/"Ng Heritage Reporting Corporation (202) 628-4888 (s_-) l
DONOVAN - CROSS 22648 1 get people through, he is going to wave his wand twice and 2 say step off the line, you're done.
3 And they were interested, knowing that the players knew that the -- the players didn't know it was a test. The 4
5 players just knew -- they asked nine people to leave and 6 five were left inside plus the two at the decontamination j 7 station. And then all of a sudden these people start coming 8 in. The players didn't know that it was going to last 20 9 minutes or 80 minutes. All they knew is people were going 10 to come in and this evaluator -- there was one evaluator in 11 the trailer and one evaluator outside, was watching them 12 monitor -- watching five of them monitor people passing 13 through at a fairly rapid rate.
14 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 ,
f
DONOVAN - CROSS 22649 1 JUDGE COLE: You are familiar with the monitoring i
! 2 trailers?
3 THE WITNESS: (Donovan) Yes.
4 JUDGE COLE: Are all of the stations located 5 within one trailer?
6 THE WITNESS: (Donovan) There is two separate, 7 one at each reception center. And there are 14 stations 8 for frisking within the trailer.
9 JUDGE COLE: Okay. So one individual trailer 10 contains all 14 monitoring stations at each of the reception 11 sites?
12 THE WITNESS: (Donovan) Right.
13 JUDGE COLE: All right.
14 THE WITNESS: (Donovan) And then, in addition, at 1
(u- ) 15 the end of the trailer there is a decontamination station 16 which is not a true frisking station. It's just an area. >
17 JUDGE COLE: Yes.
18 The reason why I ask is I remember reading in one 19 of the documents before us that when four monitoring 20 stations were added, a half trailer was added.
21 Was that physically hooked up and interconnected 22 directly with the other trailers or how was that?
23 THE WITNESS: (Donovan) That's proposed. I 24 believe that's proposed actions that the New Hampshire 1
25 Yankee organization says they are going to do. So the plan s Beritage Reporting Corporation
[
' ] (202) 628-4888 J
l
DONOVAN - CROSS 22650 1 of record, Amendment 6, says there is only 14 stations at 2 each monitoring trailer, and that's all we had to evaluate 3 was the 14 stations in the one trailer.
4 JUDGE COLE: Okay, thank you.
5 BY MR. TRAFICONTE:
6 Q FEMA's position is that they don't need any 7 additional trailers, isn't that right?
8 A (Donovan) I didn't say that.
9 Our plan evaluation says, based on the manner in 10 which the plan defines the population, permanent and 11 transient and the subsets therefore to be monitored,'that 12 the plan provides an adequate basis to perform the 13 monitoring in terms of the planning standard that FEMA uses.
14 Q Now FEMA has made a reasonable assurance finding.
15 A (Donovan) That is correct.
16 Q It's got a four-legged support, right?
17 A (Donovan) That's correct.
18 Q So that whole process vis-a-vis the adequacy of 19 the facilities for monitoring evacuees, FEMA is on record, 20 there's reasonable assurance right now, right?
21 A (Donovan) That's correct.
22 Q FEMA has decided that in its view, in its 23 judgment, that there need not be any additional trailers, 24 right?
25 A (Donovan) That's correct.
Heritage Reporting Corporation (202) 628-4888 I
4 DONOVAN - CROSS 22651
~s 1 MR.' TRAFICONTE: If I could just have a moment. I
/ i.
(s,/' 2 have only to request that documents I have marked be 3 admitted into evidence.- And I just want maybe a minute to 4 consult.
5 (Pause.)
6 JUDGE SMITH: Ms. Doughty, do you have 7 examination? Do you have any questions?-
8 MS. DOUGHTY: No. Mr. Backus handled that.
9 (Pause.)
10 MR. TRAFICONTE: I just want to ask a series of, I 1 11 hope, quick questions.
12 BY MR. TRAFICONTE:
13 0 -Tone alert radios, I take it when the tone sounds
~s 14 'the holder of the radio understands to turn to a normal
(, 15 radio for action?
16 A (Donovan) No. The traditional tone alert radio 17 that FEMA normally sees distributed is really composed of 18 three components. It is in some cases a standard radio. In 19 other cases it's a radio that's only preset to one 20 frequency.
21 It also usually has a battery inside the radio, 22 and it's usually one of these cadmium batteries that there 23 is a charger unit. So there is usually three components to 24 the tone alert radio: A charging unit'so that battery 25- within the radio is maintained at full charge, and that in !
i l
l e"Sg Heritage Reporting Corporation I
( ) (202) 628-4888
DONOVAN - CROSS 22652 l 1
1 the event, obviously, the power is lost. So there is still 2 then, therefore, a means for the radio to receive the 3 signal. j 4 When an EBS station activates its tone alert, the 5 tone alert signal does several things. But for the 6 recipient of a tone alert radio, it turns the radio on. And 7 it usually turns the radio on to a preset volume. So if the 8 radio is off, it comes on and a volume is set with the idea 9 that it's loud enough that it would gather one's attention.
10 And it comes on to the preset station.
11 Now, like I said, I have seen radios that are just 12 one station, and then there are radios that -- tone alert 13 radios that have multiple stations that a person could use 14 as a normal radio. But if the two-tone encryption tone came 15 on, it would automatically change the station and bring the 16 radio reception on to just the preset station.
17 Q Preset and therefore receives EBS messages, right ?
18 A (Donovan) That's correct.
19 And the radio won't turn off. It takes -- someone 20 has to go on over and turn it off. You know, it stays on.
21 It just doesn't come on and then fade down to nothing.
22 Q Do you know that what you just described as a tone 23 alert radio describes the tone alert radios mentioned in the 24 SPMC7 25 A (Donovan) The tone alert radios that I have seen Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22653 are the' tone alert radios that New Hampshire has but is in
'g-~ 1
\s '2 the process of distributing. As the SPMC plan review says, 3 that these radios would'be distributed after tbs -- so I'm 4 coming to the point I assume they will be the same radio, 5 only set to a different radio frequency. But I haven't 6 inquired as to their purchase process and whether it's 7 identical or is a different radio.
8 Q All right.
9 A (Donov .) Supplier, vendor, et cetera.
10 Q During your evaluation of the exercise, or while 11 you were writing your report, or at any other time, have you 12 reviewed-player logs?
13 A (Donovan) Yes. In fact, my evaluators reviewed r~s - 14 player logs. We gave each evaluation component the logs
\s_- 15 that were created at the work places that they evaluated.
16 So they were told, in fact, in all my evaluations we look at 17 the source material. And so they were all given 18 individually, depending on what their assignment was, the 19 player material that was generated at those locations.
20 Or conceivably, if they were part of a team out in 21 the field and they only saw the field component, and they were assisting with the other half of the evaluation, they 22 23 would have access to the player-generated material back at 24 the facility.
25 Q So player-generated materials were part of what
s Heritage Reporting Corporation I (202) 628-4888
DONOVAN - CROSS 22654 1 FEMA reviewed?
2 A (Donovan) Yes.
3 0 Were controller generated materials also part of 4 what FEMA reviewed?
A I never -- to my knowledge, I haven't .;
5 (Donovan)
I 6 received -- well, we received all the logs from the control j 7 cell, the New Hampshire Yankee control cell.
8 Q New Hampshire control cell, yes.
1 9 A (Donovan) But if New Hampshire Yankee controllers 10 generated other material, no, I didn't receive that.
11 Q And so those materials, other than this one 12 exception, those materials were not part of the basis for 13 your judgment?
14 A (Donovan) That's correct.
15 O I hope this is my last question.
16 The sirens in the areas of the beaches in 17 Massachusetts do not have voice mode, do they?
18 MR. DIGNAN: What airens in the areas of the 19 beaches of Massachusetts?
20 Did the Commonwealth put up a set of sirens for 21 me?
22 MR. TRAFICONTE: The siren system, the mobil siren l 23 system that is --
24 MR. DIGNAN: I'll stipulate it's not used under 25 the plan.
Heritage Reporting Corporation (202) 620-4888 l
I
' i
DONOVAN - CROSS 22655 1 MR. TRAFICONTE: All right.
2 BY MR. TRAFICONTE: j i
3 Q There is not going to be under'the plan a voice 4 mode for the sirens that broadcast tc the beaches in 5 Massachusetts. That's something you are aware of, is it 6 not?
7 A (Donovan) Yes, but I think that's different than 8 whether the sirens have a PA capability.
9 0 All right.
10 MR. DIGNAN: They have capability. They are not 11 to be used.
12 MR. TRAFICONTE: They are not to be used. Fine.
13 BY MR..TRAFICONTE:
14 Q In your view, is there going to be adequate 15 communication with the transient population in the 16 Massachusetts beach areas, in light of that fact?
17 A (Donovan) What do you mean by " adequate 18 communications"?
19 Q Well, in New Hampshire, the sirens are going to be 20 used in a voice mode to communicate to the beach 21 populations, correct?
22 A (Donovan) Only at the alert level. .j i
23 Q But they are going to be used, the voice modes are 24 going to be used.
- 25. A (Donovan) At the a]ert level.
Heritage Reporting Corporation j 3
(202) 628-4888
1 l
l DONOVAN - CROSS 22656 V 0 I
1 Well, again, what's the scenario?
2 If the scenario started off as site area 3 emergency, the plan calls for at this time to activate the 4 full component of 94 sirens, and they would, as I understand 5 the plan, they may or may not use the PA mode. But they 6 would basically activate the sirens and have an EBS message 7 that would be system-wide.
8 The State of New Hampshire has agreed, as part of 9 the public education program, that they are going to erect 10 signs at the various parks, beaches, parking areas so that a 11 transient arriving at the location would receive 12 notification that if he heard the sirens, whether it's in a 13 PA mode or in a siren noise mode, whatever you want to 14 describe what it is, or it's just being a siren, that he 15 would'have an opportunity to be informed as to what actions 16 to take if he heard that.
17 Q Well, you are talking now about New Hampshire.
18 Just so we are clear, in the voice mode what 10 people on the beaches are told in New Hampshire is turn on 20 your radio and listen for EBS messages essentially, isn't 21 it?
22 I mean, they are told other things, but that's a 23 part of what they are told.
24 A (Donovan) Well, I believe in the exercise report 25 the alert message that was used -- simulated since we didn't Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22657 1 actually broadcast -- advises people that the beaches are 2 being closed and that they should leave the beaches.
3 So I believe it's more than just turn on the I l
4 sirens.
5 0 All right.
6 The message to leave the beaches, the beaches are 7 being closed in New Hampshire was communicated via the voice 8 mode and the siren, correct?
9 A (Donovan) Well, yes, that was part of it. They 10 also -- these beaches are manned ---
11 MR. DIGNAN: How is this line related to the 12 exercise?
13 The sirens, keep in mind, have been litigated 14 before another Board. This is a plan issue, it seems to me, 15 you are bringing up. And the plan issue is part of the 16 sirens.
17 How is this related to the exercise?
18 There was no exercise of a voice mode, because we 19 don't use a voice mode.
20 MR. TRAFICONTE: There was no exercise in the 21 voice mode because you don't use the voice mode.
22 MR. DIGNAN: Yes. I mean this is supposed to be 23 the exercise we're talking about --
24 MR. TRAFICONTE: Yes, I am aware of that.
25 MR. DIGNAN: -- with Mr. Donovan. And I just Heritage Reporting Corporation G (202) 628-4888
r- <
l DONOVAN - CROSS 22658 1 don't understand what contention this is relevant to, an 2 exercise. l l
3 You are litigating in front of the other Board the j
)
4 issue, or you were litigating except you have lost it 5 already on summary disposition, before the other Board the 6 question of whether or not we should have a voice mode or 7 not have a voice mode or what we ought to do with the voice 8 mode. And I just don't see the relevance to anything before 9 this Board at this time of the voice mode or lack thereof in 10 Massachusetts, because that plan issue has been fought out 11 in the siren's case, and decided adversely to the 12 Commonwealth on summary disposition.
i 13 JUDGE SMITH: The longer you talk the more he's 14 thinking about it.
15 (Laughter) 16 MR. DIGNAN: Well, I like tc t ve him every 17 opportunity.
18 You know, there are times when you just like to 19 look at your craftsman work. Mr. Traficonte and his 20 colleagues' ability to search for a contention is something 21 I like to watch exercised every now and then.
22 (Laughter) 23 MR. DIGNAN: And I consider this a legitimate 24 sample.
25 (Laughter)
Heritage Reporting Corporation (202) 628-4888 i
l ',
rL DONOVAN - CROSS- 22659 y> 1 (Note passed to Mr.'Traficonte.)
' 2 .' lMR. TRAFICONTE: For the record,.I'm getting-
{
3 handed --
4- (Laughter) 5 'MR..TRAFICONTE: I'm getting handed all kinds of 6 proposals.
7 .(Laughter) 8 MR. TRAFICONTE: I'm not going to make_the 9- . argument that.I was thinking of making.
^
10 I think that Mr. Dignan may well be rigat. I 11 .think th'e narrow issue.of ---
12 MR. DIGNAN: That's enough.
13' (Laughter)
.14 MR. TRAFICONTE: He may be right, but.short 15
( sighted.
16- (Laughter) 17 MR. TRAFICONTE: I think I may have failed to 18 touch this particular base when Mr. Donovan was in here on 19 ' plan review. That is probably the case.
20 There is a contention -- I think it's JI-39 --
21 that involves or challenges the adequacy of the 22 . communication with the transients, and may have failed to 23 touch base when he was here before as to FEMA's evaluation 24 in that regard for the beach people in Massachusetts when
-25 the voice mode and the sirens are not planned on being used.
f Heritage Reporting Corporation y (202) 628-4888
\m
I DONOVAN - CROSS 22660 1 It's not a lengthy inquiry that I intended.
2 JUDGE SMITH: So you are seeking leave --
3 MR. TRAFICONTE: Yes.
4 JUDGE SMITH: Will you object?
5 MR. DIGNAN: I was just handed the latest effort 6 in the Court of Appeals.
7 I'm sorry, I wasn't listening, I confess.
8 MR. TRAFICONTE: I'm seeking leave to return to a 9 matter that I more appropriately should have addressed when 10 Mr. Donovan was here last month.
11 MR. DIGNAN: I don't think you should have, 12 because as I say, the planning question of the sirens is 13 being litigated in the other Board.
14 MR. TRAFICONTE: Oh, well, that's true, the 15 sirens. But I'm focusing on the communication with the 16 transients.
17 JUDGE SMITH: What the sirens or voice mode 18 alternative communicate.
19 MR. DIGNAN: But what I am saying has been decided 20 over on the other side is that the siren method, 21 methodology. The PANS, the Public Alert and Notification 22 System is or is not adequate is what's before the other 23 Board.
24 MR. TRAFICONTE: To communicate information to the 25 transients on the beaches?
Heritage Reporting Corporation (202) 628-4888 !
DONOVAN - CROSS 22661 1 MR. DIGNAN: No, because --
2 MR. TRAFICONTE: No, no, that's right. That's the 3 inquiry.
4 MR. DIGNAN: All right. So if we have an adequate 5 PANS --
6 MR. TRAFICONTE: Yes.
7 MR. DIGNAN: -- in the opinion of Judge Bloch's 8 Board -- i l
9 MR. TRAFICONTE: Yes. l 10 MR. DIGNAN: -- it is totally irrelevant to 11 anything, whether that PANS consists of sirens, talking 12 birds or whatever.
13 (Laughter) 14 MR. DIGNAN: Because that's Judge Bloch's call.
15 MR. TRAFICONTE: Was that one of the ideas you 16 guys --
17 (Laughter) 18 MR. TRAFICONTE: You tried a lot of different 19 things.
20 MR. DIGNAN: Well, they have about as much 21 relevance as some of the hypothetical I hear from your 22 office.
23 Now, that's my point, Your Honor. It's purely one 24 of jurisdiction. The adequacy of the Public Alert and 25 Notification System, which is what this is part of, is Heritage Reporting Corporation G (202) 628-4888
l DONOVAN - CROSS 22662 1 before the other Board. That's the only reason I broke in.
2 Maybe I shouldn't have done it. Maybe I'll let 3 Donovan explain why it isn't a problem and we'll all get out 4 of here.
5 All right, I'll withdraw the objection.
6 BY MR. TRAFICONTE:
7 Q Mr. Donovan, my question to you is, is it your 8 view that in the absence of planned use of the voice mode 9 that there is an adequate means to communicate necessary 10 information to the beach population in Massachusetts?
11 MR. FLYNN: Excuse me. I thought we went through 12 a long colloquy about it wasn't a planned use of the siren 13 system to use the voice mode in Massachusetts.
14 MR. TRAFICONTE: I think that's what I just said.
15 MR. FLYNN: Oh, without that.
16 MR. TRAFICONTE: Yes.
17 MR. FLYNN: Oh, very well.
18 THE WITNESS: (Donovan) Yes, it is FEMA's 19 position. I'll point out they have an acoustical system 20 that we have reviewed that provides the acoustical coverage 21 that our criteria calls for for the beach areas.
22 In addition, they have a redundant backup system 23 which, one, involves uses of these helicopters to spot 24 traffic impediments. One of the things the helicopters 25 would be directed to look at is, well, there is still lots Heritage Reporting Corporation :
(202) 628-4888
l DONOVAN - CROSS 22663 ~
es 1 of numbers of people on the beaches. They'also have a k, 2 backup, they have a contract, I should say. To me,.it's a 3 backup system for the helicopter that has acoustical 4 loudspeakers that could be used to target a portion of the 1 5 population on the beaches who may not appear to be taking 6 actions in response to messages or instructions, et cetera.
i 7 Again, the plan also calls for, assuming the 8 Commonwealth of Massachusetts would agree, that they have 9 proposed signs to be posted, to document and provide i 10 transients an opportunity to be informed at the parking area 11 and egresses to the beaches.
12 And lastly, I believe they are going to change 13 their cone:3pt to go to a beach closing year round, which 14 would reinforce the public education even stronger. That
( 15 if, (a) if I heard a siren, this means I leave the beach.
16 BY MR. TRAFICONTE:
17 Q So part of the reason why you believe the 18 transients will have appropriate information is that there 19 will be signs in the beach areas?
20 A (Donovan) Well, that's one of the -- no, I didn't 21 say that. That's one of the additional methods that the 22 plan offers to ensure that the public is informed, to give 23 the public an -- I won't say "to ensure". We don't ensure, 24 because we don't know whether they read them or not. But we 25 give the public an opportunity to be informed.
Heritage Reporting Corporation (s (202) 628-4888 ;
1 l
u_1___._____ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _.________________u
DONOVAN - CROSS 22664 1 Q That information is distributed within the EPZ, 2 though, isn't it?
3 A (Donovan) I didn't say that. That was the -- you l 4 asked me what was the purpose of the signs. The purpose of 5 the signs is to give the public --
6 Q I see, the signs. I'm sorry.
7 A (Donovan) -- who arrive at a beach an opportunity 8 to be informed.
9 10 11 12 l l
13 14 I
16 17 18 i 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 1
- _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ . l
l l
t DONOVAN - CROSS 22665
- ,._q. 1 . JUDGE SMITH
- Mr. Traficonte, if you' re going to l
2 take up much more time we'll have to make other-3 arrangements.
4 - MR . DIGNAN: Mr. Traficonte, incidentally, in'that 5 last line I don't know what the' thrust was but I'll 6 stipulate with you, we have no signs out there. Because the 7 Commonwealth refused to let us put them'out there. And I 8- assume continue to refuse to let us put them out.there until 9 the' plant gets turned on.
10 MR .' TRAFICONTE: I just want.to move for the 11 admission of several documents.
12 JUDGE SMITH: Your 15 minutes, incidentally, 13 turned,out to be, so far it's 40.
14 MR. TRAFICONTE: It turned out to be 40.
.f~ ( ,j) 15 JUDGE SMITH: So far.
16 Are you done examining?
17 MR. TRAFICONTE: I am.
18 I just want at this point move for the admission-19 of certain documents that I had marked.
20 I may not have moved the Barry report which is 21' marked as Exhibit No. 97. I may not have requested or moved 22 that that be admitted and I do so now.
23 JUDGE SMITH: Objections?
24 MR. DIGNAN: Didn't the Alban declaration with 25 this go in already.
Heritage Reporting Corporation (202) 628-4888
DONOVAN - CROSS 22666 1 MR. TRAFICONTE: The Adler declaration went in but I 2 it did not have reference to the Barry report.
3 MR. DIGNAN: What's the purpose of the offer?
I 4 If it's for the truth of the matters contained, I [
5 do object. If it's for some limited purpose, I don't.
6 MR. TRAFICONTE: I would like it in the record for 7 the fact that the statements were made in the Barry report.
8 I would like it in the record for the statements that are 9 contained in the Barry report. The fact that they were 10 communicated to FEMA sometime around 1985.
11 MR. DIGNAN: In other words, what you want it for 12 is to demonstrate that the report, in fact, was made and 13 made pursuant to a FEMA contract and received by FEMA.
14 MR. TRAFICONTE: And says what it says.
15 MR. DIGNAN: And says what it says.
16 MR. TRAFICONTE: Yes.
17 MR. DIGNAN: With that limitation I have no 18 objection.
19 MR. FLYNN: No objection.
20 JUDGE SMITH: Received.
21 (The document referred 22 to previously marked for 23 identification as 24 Mass AG Exhibit 97 was 25 received in evidence.)
Heritage Reporting Corporation (202) 628-4888 i
I l
_ _ _ _ _ ____________ . _ _ _ _ _ l
m,., - - -
DONOVAN - CROSS 22667 L.
~ sc 1- JUDGE SMITH: Incidentally, your Exhibit 95 which N )
,f . 2. I asbume.you're going to move into evidence, isn't that the L
same'as your 1017
~
3 4 MR. TRAFICONTE: Yes. That is what I had said 5- when I got to that. I'm not going to move that 95 be 6 admitted.
7 JUDGE SMITH: Oh, 95 --
8 MR. DIGNAN: It's going to remain for.
9 identification.
' 10 . MR. TRAFICONTE: It's a part of 101.
11 JUDGE SMITH: I got it, all right.
12 MR. DIGNAN: It goes in the sandbag file.
-13 (Laughter) 14 ' JUDGE SMITH: So this is withdrawn, 95 is
.(
(,,/ 15' withdrawn?
16 MR. TRAFICONTE: I never moved to have it 17 admitted. I just had it marked and used it for cross. And 18 at'the point, ILthink, in the record I noted I would 19 later -- that's all I have, Your Honor.
20 EXAMINATION BY JUDGE COLE 21 JUDGE COLE: Just really one question, Mr.
A 22 Donovan.
23 I note that the 1986 exercise, the scope of that 24' exercise was New Hampshire only. And in the B section of R25 Exhibit 43 (f) you have three columns: one listing the Heritage Reporting Corporation
(
(202) 628-4888
DONOVAN - CROSS 22668 1 deficiencies or ARCAs from the '86 exercise.
2 And then the next column, action proposed by or 3 (state response.)
4 Considering the definitions that you provided of a 5 deficiency versus an ARCA, my question has to do with what l 6 is in the second column, the action proposed, particularly 7 with respect to deficiencies considering your definition of l
8 a deficiency, which would then by your definition require a l 9 prompt remedial action. Was this handled shortly after l
l 10 19867 Or what is the timeliness of column two? How was l l
11 that contained? l l
12 THE WITNESS: (Donovan) My understanding that 13 most of the communications on the status of these corrective i 14 actions was offered to us in 1988. And some of the actions 15 had been implemented and some of the actions were in the 16 process of being implemented in 1988.
17 The prompt remedial action issue in our guidance l
18 memorandum EX-1, obviously, applies when we have a licensed 19 plant. And as a continuation of the license without 20 addressing an issue, we therefore want prompt action because 21 we have a licensed plant.
22 In this regard, because I wasn't responsible for 23 monitoring these issues between '86 and '88, I think the 24 absence of an operating license may have taken away some of 25 the timeliness in terms of implementing these actions.
Beritage Reporting Corporation ;
(202) 628-4888
DONOVAN - CROSS 22669 1 JUDGE COLE: So the response in column two wasn't i 2 necessarily taken out'of FEMA files after negotiation with Ls-3 an Applicant.
4 THE WITNESS: (Donovan) No.
5 JUDGE COLE: But it's timely information obtained
-6 for the '88 exercise?
7' THE WITNESS: (Donovan) Yes.
8 This is actually what the state did'in response to 9 the issue.
10 ~ JUDGE COLE: Okay, thank you.
11 That's all I have.
12 JUDGE SMITH: Do you have questions, Ms. Chan?
13 MS. CHAN: Yes, the' Staff has a couple of
,. 14 question.
Ll I\, % 15 JUDGE SMITH: You will follow-up.
16 Mr. Flynn, you'll have questions, too?
17 MR. FLYNN: I have a few.
18 MR. DIGNAN: 'I have a couple.
19 JUDGE SMITH: Ms. Chan?
20 CROSS-EXAMINATION 21 BY MS. CHAN:
22 Q Mr. Donovan, can you please explain how the 23 decisions regarding latchkey children were consistent?
24 A (Donovan) The state's perceived issue with school.
25 children on the exercise day was that if they had advocated Heritage Reporting Corporation
(' (202) 628-4888
. .. - __ - -_____ .-- ___ 1
DONOVAN - CROSS 22670 1 early dismissal, that a percentage of the students would be 2 returned to homes where there was no adult supervision or 3 guardian supervision present. And they did not want these 4 children to be put into an unsupervised mode when further 5 actions may be required to protect the public health and 6 safety.
7 So the state's concern was, we want to maintain 8 responsibility and control over the students locations until 9 we can decide. Again, they had no looking glass to know 10 whether the exercise was going to stop at site emergency or 11 go to general emergency and be a problem for New Hampshire 12 or not. So their concern was well based. And the decisions 13 were to be concerned about the latchkey children.
14 In Portsmouth, independently without consulting 15 with the state, the Portsmouth EOC came to the same 16 conclusion. And in that regard they -- in their 17 communication with the SAU said, dismiss all students who 18 can be returned to the custody of an adult and retain 19 custody over those students who cannot be returned to the 20 custody of an adult. So they retained custody of the 21 latchkey children.
22 In that regard FEMA believe the protective action 23 -- the implementation of protective actions were consistent 24 with the state's actions. It said, late dismissal for a 25 whole global community of schools. And Portsmouth in Heritage Reporting Corporation (202) 628-4888 i
1
:_--_--_ l
!.R DONOVAN - CROSS 22671
- . f-qf 1- consult'ation and in conveying their concern to the SAU. The.
? \~
\s_ ,/ 2 end-product was that the latchkey children -- their.
3 responsibility was maintained over the' latchkey children.
4 In that regard it's consistent; not inconsistent.
5 Q Thank you.
6 MS. CHAN: That's the only question the Staff had.
7 JUDGE SMITH: I don't know, between the two of you 8 who should be.the anchor. But let's go with'--
9 MR. DIGNAN: I'm a lot shorter I think than Mr.
10 Flynn.
11 MR. FLYNN: I would defer to Mr. Dignan at this 12 point, if that's all right.
13 JUDGE SMITH: All right.
14 CROSS-EXAMINATION 15: BY MR. DIGNAN:
- 16. Q Mr. Donovan,.I'm sure this may be reflected in 17 your qualification sheet and I just haven't got it in front 18 of me. But how many exercises have.you, for lack of a 19 better word, run as you.did the Seabrook exercise in your 20 career, for nuclear power. plants?
l 21 A (Donovan) I'm somewhere over 60 now.
22 O In any of.those cases did anyone get a perfect 23 score? And by perfect score I mean, not even so much as an l
24 issue?
25' A (Donovan) No.
f-sg. Heritage Reporting Corporation (202) 628-4888 (V)
l DONOVAN - CROSS 22672 f
1 Q I understand for your purposes you use such terms l 2 as " met the objective" or " adequate" or " inadequate," which 3 is sort of a pass / fail type thing.
4 But if you were to put Seabrook's exercise on a 5 scale of one to ten or a scale of excellent, good, fair, or 6 poor, in your experience --
7 MR. TRAFICONTE: Objection, Your Honor.
8 MR. DIGNAN: Can I finir,h the question. I know 9 you're upset.
10 MR. TRAFICONTE: I just want to make sure I do.
11 JUDGE SMITH: Go on with your question.
12 BY MR. DIGNAN:
13 0 -- in your experience, where does it come out?
14 MR. TRAFICONTE: Objection, Your Honor. We are 15 not permitted to compare plans. And we shouldn't be --
16 MR. DIGNAN: I'm not comparing plans. I'm not 17 comparing sites. I am ask!: ; this witness' experience of 18 exercises.
19 JUDGE SMITH: But didn't you repeatedly make the 20 objection that there was no contention which brought into 21 issue the overall finding? l 4
22 MR. DIGNAN: Yes.
23 JUDGE SMITH: Well, wvuldn't his -- do you want .
24 to open that up? l 25 MR. DIGNAN: No.
Heritage Reporting Corporation (202) 628-4888 ,
DONOVAN - CROSS 22673 1 (Laughter)
S i
'ws'
/) 2 MR. DIGNAN: Your point is well made, Judge.
1 MR. TRAFICONTE: I just thought of talking birds {
3 4 there for a minute.
5 MR. DIGNAN: I take it the objection is sustained.
6 JUDGE SMITH: No.
7 MR. TRAFICONTE: Objection is nicely withdrawn.
8 (Laughter) 9 JUDGE SMITH: It wasn't made on that basis.
10 There's no objection.
11 MR. DIGNAN: What?
12 JUDGE SMITH: The objection is withdrawn.
13 I'm just saying, you open that up and away we go.
, r~g 14 MR. DIGNAN: Well, he's going to examine him on ;
i >
his conclusion that it's a great exercise. I must just let
'\~ / 15 16 him go.
17 MR. FLYNN: No, it opens up the entire line of id questioning about 59 other exercises.
19 JUDGE SMITH: No, that's not the point.
20 The point is, on several objections and several l
21 lines of questiort Mr. Dignan raised the objection that 22 there is no contention in that alleges that the overall 23 quality of the exercise was bad. It was contention-by-24 contention-by-specifics. And we sustained those objections.
25 Now, apparently, Mr. Traficonte has no objection Heritage Reporting Corporation
,/;
) (202) 628-4888
(% y
DONOVAN - REDIRECT 22674 1 of you going into that, but if you go into that --
2 MR. DIGNAN: Actually, point of fact, Your Honor, 3 you sustained one. I made two and I lost the other one. I 4 didn't make as many as people think I made on that line. I 5 got the principle established that I used it fairly 6 sparingly after that.
7 But your point is well taken, I'll withdraw the 8 question.
9 MR. FLYNN: Thank you.
10 JUDGE SMITH: Any further questions?
11 MR. DIGNAN: That's it.
12 JUDGE SMI"H: Mr. Flynn?
13 MR. FLYNN: Yes.
14 REDIRECT EXAMINATION j 15 BY MR. FLYNN:
16 Q Mr. Donovan, I will ask you to recall a series of 17 questions that Mr. Traficonte asked you on Thursday of last 18 week, May 18th, and the subject was your evaluation of the 19 Trojan exercise.
20 Do you recall the discussion that you had with him 21 about the fact that certain emergency workers did not use 22 respirators?
23 A (Donovan) Yes, I do.
24 O And do you recall that at that time I interjected 25 a point about there being differences between that exercise Heritage Reporting Corporation (202) 628-4888 !
s DONOVAN - REDIRECT 22675
-s 1 and the Seabrook ' 88 exercise? .
(_,/ 2 A' (Donovan) Yes. ,
3 -Q My ; recollection is that Mr. Traficonte was pretty 4 emphatic about-not wanting to hear that. But hearing at 5 that time what those differences were, I'll put the. question 6 to you: why was the nonuse of respirators in the Trojan 7 exercise a sufficient magnitude to be considered a 8 deficiency, but the failure to wrap a patient in a blanket 9 in an ambulance at seabrook not a deficiency?
10 A (Donovan) I'll answer the latter part first.
11 The failure to wrap a blanket around the patient 12 for the ambulance transport did not result in him receiving 13 any more or less radiation. Did not result in the drivers 14 receiving any radiation. The only possibility it produced
'\ 15 was that the ambulance vehicle itself could have been 16 contaminated.
17 However, the hospital staff demonstrated that they 18 could survey the ambulance and would have taken actions to 19 clean the ambulance if it had been contaminated.
20 In the exercise so referenced to Trojan, the 21 people who were managing the dose commitment for the 4
22 emergency workers assumed that the players would have 23 implemented their plan and put on their respirators.
24 In this particular radiological monitoring team we 25 had for that scenario a high iodine release rate and they Heritage Reporting Corporation (202) 628-4888
\
i DONOVAN - REDIRECT 22676 J 1 were asked on two separate occasions to find the center line 2 and take a center line measurement of an air sample. Which 3 means they run a little machine that puts the air through a l 4 filter into a cartridge and it takes about 10 minutes for 5 that operation to take place.
6 The net result was that these emergency workers 7 exceeded 5 R committed dose. They exceeded the protective 8 action guide that they were not to exceed. And that's why 9 it was a deficiency.
10 If thay had implemented th3ir -- the people who 11 were controlling them assumed they were using the 12 respirators; therefore, they were not breathing in as much 13 iodine. From their calculations they didn't exceed. But 14 because they failed to verify that they were not using their 15 respirators or actions like that, that they did ceed their 16 dose and that was the issue.
17 Q Well, at Seabrook what potential was there for 18 avoidable dose as a result of the failure to wrap the 19 patient in a blanket?
20 A (Donovan) There was no potential for avoidable 21 dose at Seabrook.
22 O Going on to a different subject.
23 24 25 Heritage Reporting Corporation (202) 628-4888 l
l l
l
- _ _ .-___.__._____________________J
DONOVAN - REDIRECT 22677 i
s 1 Q Going onto a different subject, there was an
't
, ( ,/ 2 extended examination on the question of whether your 3 discussion with the Region 1 evaluators took place on August 4 30th or August 31st. Or in any event, in time for the 5 comments to be incorporated in the final report.
6 I would like you to tell us what efforts you made 7 to get -- before you finalized the report, before you sent 8 it to the printers -- to get comments from all of the people 9 who were reviewing the draft.
10 A (Donovan) Approximately 44 parties received our 11 draft exercise report. Three parties being the 12 participants, the State of Maine, State of New Hampshire and 13 New Hampshire Yankee. The other parties were FEMA Region 1
,-~ 14 Regional Assistance Committee, team leaders, group leaders,
(,)
I 15 deputy team leaders, et cetera.
16 Whea I mailed the report, I was on an exercise. I 17 had the report mailed to me in Richland, Washington. I was 18 conducting a two-day exercise for the State of Washington 19 and for local governments.
20 When I mailed it out, I was unaware, because I was 21 not in contact with my headquarters, that headquarters had 22 made a commitment the same day that I mailed the document to 23 this Board to produce a final report by September 1st.
24 When I got back to my office the following week 25 and became aware of that decision, I then took steps to f-~x Heritage Reporting Corporation
( '4 (202) 628-4888 LJ
f DONOVAN - REDIRECT 22678 l
1 ensure that all parties who received our initial mailing 2 were advised that they had to move up their commitment date 3 to get their comments back to me.
4 In every three work days, we called to remind 5 these people. We got comments, actual comments back from 43 6 of the 44 parties. The 44th party said he had no comments.
7 And a3.' comments were received and reviewed by me, and if 8 appropriate, were used to edit the report before we 9 published it.
10 Q Were you satisfied then that you had heard from 11 everyeno?
12 A (Donovan) Yes, I was.
13 Q On the first day of Mr. Traficonte's examination 14 he raised a question about verification of resources and 15 verification of training of personnel as a matter separate 16 from the exercise, 17 Is there anything you would like to add to that 18 discussion?
19 A (Donovan) Yes. We testified before how we went 20 through the training modules and we looked at the training 21 results. And that is a separate verification in addition to 22 the verification we do in the exercise.
I 23 And in this case we have looked at the training 24 modules and the training results for both the State of New l
25 Hampshire, New Hampshire Yankee ORO and the State of Maine.
Heritage Reporting Corporation (202) 628-4888
DONOVAN 1 REDIRECT 22679 1- .At a certain period in time we get into a
-4
\, '2 relationship with the offsite participants that they send us
- 3. a document called an Annual Letter of Certification, and.are 4 usually received on or about January 31st of each year. And 5 in this letter they outline to us their training activities 6 that have been conducted in the prior 12 months..
7 And it's my custom, upon receipt of such 8 documents, to some time in the year go on out and reverify 9 on an exception basis, to look at some of these results of 10 the training. And that is how we get into an operational 11 mode of monitoring their training program.
12 Q At a different point, but again early in the 13 cross-examination, yt were asked about whether you went to 14 Holy Cross College and looked at that facility; whether you q , 15 evaluated that facility for.use as a host center for the 16 evacuation of school children..
17 And I believe your answer to that specific 18 question was "no".
19 But I would like you to tell us what evaluation, 20 if any, you did make of the facilities at Holy Cross 21 College?
22 A (Donovan) This was in response, Your Honor, you 23 asked me a question Tuesday when I was sitting in the 24 audience. One of the Massachusetts attorneys was quizz!.ng a 25 panel that the Applicant had up here, g-y Heritage Reporting (202) 628-4888 Corporation
\
l DONOVAN - REDIRECT 22680 l
1 Objection 22 of this exercise report documents our 2 activities to the extent that it says that we went out and 3 we conducted verifications of the 26 congregate care centers 4 and one host center. And at that time the plan called for 5 one host center and 26 congregate care centers.
6 All of those facilities, there were letters of agreement in 7 the file.
8 We looked at Holy Cross, and as the Mass.
9 Electric, which is to be the backup facility to the Shriners 10 Auditorium as a host facility, we looked at all of those 11 facilities in the lines that they were congregate care 12 centers.
13 By definition, with the exception of a host 14 facility for special populations, a host facility for school 15 children, for example at Holy Cross College, contemplates 16 that you are going to hold custody of these children for a 17 period of hours,-and you are not contemplating bedding them 18 down and feeding them on a 24-hour basis, because the 19 concept is there that the public, the parents are going to !
20 arrive at these host facilities and pick up their children.
I 21 After we did that interview and following our 1
22 October issue of the plan review, we were advised by New ;
1 23 Hampshire Yankee that they were changing their concept of )
24 operation and they were now going to have two host !
l 25 facilities, Shriners and Holy Cross College.
l l
Heritage Reporting Corporation I (202) 628-4888 l
DONOVAN - REDIRECT 22681 1 In our view, the' inspections and the documentation i /~~N .
d,,)l 2' we did were sufficient for us to say, as we updated our 3 evaluation in December, that arrangements were adequate at 4 Holy Cross College to address hosting school children.
5 Q' Turning again to'a different subject. On Tuesday, 6 or yesterday, May 23rd, Mr. Traficonte examined you about 7 documentary evidence to support the' findings in the exercise 8 report.-
9 Now you have already testified at some length,'and 10 I won't ask you to go over it again, about the management 11 system that you devised or used for the-generation of the 12 exercise report.
13' But the question that I want to put to you is: In 14 .the documents that were given to you in this process, were 15 there any concerns, issues, deficiencies, ARCAs, however 16 described, that did not find their way into the final 17 exercise report?
18 A (Donovan) No.
19 Q And then the last subject that-I want to ask you 20 about is the protective action recommendations for New 21 Hampshire ERPA G.
22 You have already testified that those protective 23 action recommendations were adequate. I would like you to 24 explain what your reasons were for finding or determining 25 that those PARS were adequate.
Heritage Reporting Corporation 7-s t (202) 628-4888 lN u______________.___ _
l b
i '
l DONOVAN - REDIRECT 22682 1 .
I 1 A (Donovan) Yes, I would be happy to. I 2 I had several mini-scenarios. One of my mini-3 scenarios had to create conditions for the State of Maine to 4 play ingestion pathway issues which means I had to get the 5 plume to the State of Maine to create a deposition pattern, 6 not only based on plume deposition, but we have rain showers 7 brought in.
8 In my exercise report, in the time line, we did 9 not address specifically what we were doing. But I would 10 draw Your Honor's attention to two statements on page 36, 11 which is a narrative of the exercise scenario.
12 And on the first paragraph on page 36, we say, "In 13 order to allow adequate time for the formulation and 14 implementation of post-accident environmental sampling i 15 plans, the offsite radiological assessment personnel were 16 informed at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br />, or 6:00 in the evening, that the i 1
17 release was going to terminate at 1900. They were provided 18 plume history and monitoring information to be used in the 19 sample plan development."
20 In other words, what we did is we said the release 21 is over. We gave them a time jump. We said that here is 22 information that covers the next 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. This release 23 moved this way. Then it moved that way. And then it went 24 out to sea.
25 In effect, at this time we stopped the exercise ,
i Heritage Reporting Corporation (202) 628-4888 f
_7 gs DONOVAN - REDIRECT 22683 t
1 for PARS and protective actions for the plume pathway. At 7.s
, ) 2- 6:00 in the evening at all locations, in other words, anyone 3 who was involved with accident assessment was given a data 4 set from a controller that says the release is going to.
l 5 terminate in a hour, and you are no longer to play current-6 conditions. We want you to go through a time jump, a mental 7 set, look at this data and be prepared to be' engaged in a 8 session to start at 7:00 to deal with developing an 9 ingestion pathway sampling plan.
10 That was one of the things we wanted to see
- 11 demonstrated and one of the things we wanted to see 12 performed.
13 With the exception of the ORO response 14 organizations, most of the other organizations had been k) 15 given opportunities and had demonstrated exercise play for 16 the plume issues. They started shutting down. For example, 17 the New Hampshire State EOC shut down at 6:30. The. State of 18 Maine shut down.
19 Now, we didn't log those times in our significant 20 event log. The only time we log is when exercise play 21 stopped at the EOF, which is around 8:00 in the evening, 22 which is the second paragraph that says that 2,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br /> 23 drill activities were suspended.
24 I just wanted to draw your attention to the fact 25 that at 6:00 we stopped the exercise play with the exception
,-ss Heritage Reporting Corporation (202) 628-4888
DONOVAN - REDIRECT 22684 1 of the implementation actions that were going on in the 2 field. There were still some bus routes being drive. There 3 were -- we had traffic impediment situations unfolding in 4 the ORO's arena of activity, and we had other things.
5 But in terms of assessing the plume, making 6 further PARS, giving them the decisionmakers who make 7 protective actions, that all stopped at 6:00.
8 And at 7:15, by a term I will call " scenario 9 magic", I changed the plume direction radically. And I 10 would like to draw your attention to two things.
11 The scenario contains weather forecasts which were 12 given to the players at three different times. One, when 13 they arrived at their facility, they got a mid-morning 14 forecast and they got a mid-afternoon forecast. And I ;
15 initially said in the morning the wind was going to blow i 16 this way, and some time in the afternoon the wind was going 17 to shift and blow inland.
18 So when we had a release, it started out this way, l 19 it blew inland this way. When we stopped the play at 6:00 20 in the evening, the plume was still being pushed in this 21 direction. >
22 Q In a westerly direction?
23 A (Donovan) In a westerly direction.
24 At 7:15, in order to get the release to Maine, we 25 radically shifted the wind to come out of the south and blow Heritage Reporting Corporation (202) 628-4888
DONOVAN - REDIRECT 22685 the release this way. And at that time, yes, part of the 1
release crossed the area up here that's called ERPA G, which 2
is the community agreements with Portsmouth and Rye. And in 3
4 that regard, it crossed it. But any conclusions, et cetera, 5 about ERPA G that don't take the fact that we stopped the 6 release and we stopped exercise play at 6:00 in the evening 7 are not based on the accurate facts.
8 At 6:00 in the evening, when we stopped the play, 9 the plume was here, the State of New Hampshire. The onsite 10 field teams and the offsite field teams were all properly 11 monitoring and defining the location of the plume. They had 12 weather forecasts which were telling them that the wind was 13 going to continue to blow through the evening from the east 14 to the west, and they had no reason to suspect that the wind 15 was going to change and move radically to the north.
16 So when we stopped the exercise play at 6:00 that 17 evening, that's when any deliberations or conclusions about 18 protective action recommendations and protective actions 19 should be tabled. And that's how we evaluated it, because 20 obviously the only way we got the wind north -- we could have said, well, forget it. But we find if we tell players 21 22 to accept the impossible when they have to make a time jump, 23 that caused them problems.
24 So we said, well, despite the fact this rapid wind 25 shift wasn't forecast, it happened and it moved the plume Heritage Reporting Corporation (202) 628-4088
DONOVAN - RECROSS 22686 1 this way up north, and accept the fact that it happened.
2 Like I said, they were give this data at 6:00 in the evening ,
3 telling them that here is where the plume went for the next 4 seven hours, and here is the deposition patterns that are 5 created.
6 Q Thank you.
7 MR. TRAFICONTE: Thank you. I have no other 8 questions. L 9 JUDGE SMITH: Mr. Traficonte.
10 MR. TRAFICONTE: I just want to note for the l 11 record that I have been handed a note that says the Appeal 1
12 Board has reinstated MAG Exercise Contention 19 (d) as of 13 apparently a few minutes ago, is back before this Board in 14 this proceeding.
15 I would like to say I have some questions on 19 (d) ;
16 but I'm not going to say that.
17 RECROSS EXAMINATION 18 BY MR. TRAFICONTE:
19 Q I want to just ask you, Mr. Donovan, that last 20 discussion about ERFA G, I take it that this is in response 21 to testimony filed or contentions put forth by the 22 Interveners that there was an inappropriate or failure to 23 make appropriate protective action recommendations for that 24 ERPA by the State of New Hampshire, correct?
25 A (Donovan) No. I wanted to address our report Heritage Reporting Corporation (202) 628-4888
.I l
DONOVAN - RECROSS .22687 1- that we stopped -- pointed out to the Board that we stopped 7s 21 exercise play at 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> for accident assessment effort.
1 3- And when we did that, we stopped any play for protective j 4 action recommendations and protective action decisions.
i-
.5 Q That's what I'm trying to nail down.
6 Is it a fair summary of that testimony that the 7 plume moved and would have required perhaps a protective 8 action recommendation, but the State of New Hampshire had 9 been shut down and the exercise was over for the State of 10 New Hampshire.by the point at which that-occurred?
11 A (Donovan) No, that's not a fair statement.
12 The conditions and records and indications at that 13 time is that the plume was' moving in a westerly. direction.
14 Q Right.
15 A -(Donovan) And that the PARS and protective 16 actions were appropriate for the dose rates that were being 17 monitored and being projected.
18 The plume release started at 1345, and at about 19 1630 the release rate dropped.off significantly, and this is 20 4:30. So they knew, they being the accident assessment 21 staff, knew that they had a down trending release rate and 22 therefore the magnitude of the doses to be projected by that 23 plume were going to be'in a diminishing factor from that 24 point.on.
25 Q I'll try to get at it this way.
Heritage FWporting Corporation
! f-~) (202) 628-4888
. \,)
l
i DONOVAN - RECROSS 22688 1 When you changed the direction of the plume 2 because you wanted deposition in Maine, when you changed the 3 direction of the plume and pointed it northeast, was the J 1
4 exercise still going on for the decisionmakers at the New 5 Hampshire EOC7 6 A (Donovan) No.
7 Q Can you indicate in your report where it says what 8 time, if it says, what time you made the decision to move 9 the plume and what time the exercise had ended for the 10 decisionmakers in New Hampshire?
11 A (Donovan) I can answer the first. The report is 12 silent on the second.
13 Q Okay, answer the first.
14 A (Donovan) The statement on page 36 says that at 15 1800 hours0.0208 days <br />0.5 hours <br />0.00298 weeks <br />6.849e-4 months <br /> or 6:00 p.m., we told accident assessment staff 16 vho were located at the two state EOCs, the EOF -- I'm 17 getting tired -- and the NHY ORO EOC. So we told all 18 accident assessment staff.
19 And when we tell accident assessment staff, we in 20 effect are telling decisionmakers too. Time out. You guys I 21 are going to now jump time. We are moving the clock ahead.
22 In this case we're really moving the clock ahead. We didn't 23 move it until the following morning. But we said for the 24 purposes of the exercise now we want you to assess where the 25 plume went and develop an ingestion pathway sampling plan.
l l Heritage Reporting Corporation (202) 628-4888 i l
l l
1
DONOVAN - RECROSS 22689 1 And we gave them an hour to think about that. And 2 then at 1700 hours0.0197 days <br />0.472 hours <br />0.00281 weeks <br />6.4685e-4 months <br />, we said, okay, now you've had an hour to 3 look at the data. Now you develop the plan.
4 Those' elements that decided to be part of that 5 process ended up just those elements located at the EOF.
6 That whatever communications were communicated from the 7 state EOC, in this case the State of New Hampshire, where 8 you asked me where the decisionmakers were, were 9 communicated to their representatives at the EOF before 1700 10 hours. Because when we told them at 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br />, we say, 11 here's this data set, and this data set jumps 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. And 12 stop play on plume pathway. Now just concentrate, clear 13 your mind for a second. Concentrate on what this data is 14 telling you. If you need to get any instructions or 15 information or priorities from the state EOC, use this 16 window between 6:00 and 7:00 to get that information. And 17 at 7:00, we're going to ask you to demonstrate the formation 18 and construction of an ingestion pathway sampling plan.
19 Q So your testimony is that the EOC officials, 20 decisionmaking officials in New Hampshire knew at 6:00 that 21 they were not expected to make any further protective action 22 decisions and recommendations?
23 A (Donovan) That's correct.
24 Q All right, just so the record is absolutely clear.
25 When you time-jumped, were the people who were Heritage Reporting Corporation (202) 628-4888
'b LONOVAN - RECROSS 22690
];
1 told that to understand that the plume had moved northeast 1 2 and had already come and gone and made the -- 9d {
1 3 A (Donovan) Yes. It's completely gone. I 4 Q It's gone.. This is what happened in the 1
5 intervening time.
6 A (Donovan) When we gave them the time jump, I I
7 would have to look at the scenario to be specific, but all 8 of a sudden we're saying, hey, it's now 3:00 or 4:00 in the 9 morning, and you are sitting here with this data that was 10 constructed as your teams followed this plume as it 11 meandered through the land and passed out to the sea.
l 12 MR. TRAFICONTE: I don't have anything further, 13 Your Honor.
14 JUDGE SMITH: Anything further?
15 All right, you are excused. Thank you. j 16 THE WITNESS: (Donovan) Thank you.
17 (The witness was thereupon excused.)
18 MR. DIGNAN: Your Honor, before we break, I would 19 like to put something else in the record. ,
I 20 Yesterday I handed out a document which I advised 21 the Board had not been produced and in my judgment should 22 have been. And you will recall that document.
23 In addition, when that was done, I asked that a 24 search be done to be sure there were no drafts or other 25 versions of that document around. Another draft has emerged Heritage Reporting Corporation (202) 628-4888 l
l
_________A
_ ]
il 22691. ;
11- and I'm going-to give'it,to myl friends from the Commonwealth i
,kd 2 now,.' and1that completes that obligation I had'on discovery.
- 3 ' JUDGE SMITH
- All right, return at --
4 MR. TRAFICONTE:- Could I request an additional-10' minutes?
6- .I am, going t'o try to attend this afternoon,--and I '
7 want(to be'present, and I.just have.:a couple of matters that
'8 may take me an extra 10 minutes or so.
9 Could I.just ask for an additional-10 minutes 10 today?.
11- JUDGE SMITH: All right. Return at 1:15 -- 2:15'.
12 '(Whereupon, at 1:07 p.m., the hearing was 13 ' recessed, to reconvene at 2:15 p.m., this same day, 14 Wednesday, May 24, 1989.)'
'l 1
- 15 16 17 18' 19'
'20 21 22 23 24 25 l
Heritage Reporting Corporation
( (202) 628-4888
REBUTTAL PANEL NO. 23 - DIRECT 22692 1 AEIEBHQQH EEEE19H 2 (2:16 p.m.)
3 JUDGE SMITH: Mr. Lewald?
4 MR. LEWALD: Yes, Your Honor.
5 Your Honor, we have assembled the Applicants' 6 Rebuttal Testimony No. 23 Panel regarding the scope of the 7 graded exercise.
8 And the members of the panel are: John Baer; and 9 Anthony Ca11endre11o; and George R. Gram. Mr. Gram is the 10 only new member of the panel who hasn't been previously 11 sworn.
12 Whereupon, 13 JOIIN W. BAER 14 ANTHONY M. CALLENDRELLO 15 having been previously duly sworn, were recalled as 16 witnesses herein, and were examined and further testified as 17 follows:
18 Whereupon, 19 GEORGE R. GRAM 20 having been first duly sworn, was called as witness herein, 21 and was examined and testified as follows:
22 DIRECT EXAMINATION 23 BY MR. LEWALD:
24 Q Mr. Gram, I have placed before you a document of 25 some five pages, and I ask you -- some four pages -- and I Heritage Reporting Corporation (202) 628-4888
q
}
< REBUTTAL PANEL'NO. 23 - DIRECT 22693
,, 1- ask you if you can. identify that document?
7
/: '2 -A' (Gram) Yes.
3 Its a resume of.my experience and education.
4 Q Your experience, training, and education?
5 A (Gram) Yes, sir..
p 6 Q Are there any corrections that are to be made on 7 that?
8 A (Gram) Yes. I would like to make one correction.
9 On the first page under " professional," I am not 1
10 longer a member of-the American Association of Aeronautical ,
-11 Engineers. My membership lapsed at the end of December last 12 year.
13 .Q And other than that, is all the material contained 14 in the document true to the best of your knowledge and O
- j. . T 15 belief?
16 A (Gram) Yes, sir.
17 MR. LEWALD: Your Honor, I would ask permission to 18 either line out that item or' submit a fresh copy. It just 19 came to my attention a moment ago.
20 JUDGE SMITH: Where is it?
21 MR. LEWALD: It's on the face sheet of the 22 document.
23 JUDGE SMITH: It hasn't been provided to the Board 24 yet.
25 THE WITNESS: (Gram) I do not believe it was Heritage Reporting Corporation js (202) 628-4888
,(
L__----.---._---...--- -. - _ . . - - - - - - . . - . _ - _ - - -
REBUTTAL PANEL NO. 23 - DIRECT 22694 1 attached to the prefiled testimony.
l 2 ' JUDGE SMITH: No. !
3 MR. BROCK: Your Honor, it was prefiled with the j j
4 professional qualifications. l 5 JUDGE SMITH: All right. l l
6 BY MR. LEWALD: l 7 Q Mr. Gram, could you identify the line item again 8 for us, if you will?
9 A (Gram) Yes, sir.
10 On the first page under the heading 11 " professional," it's the third line item, American 12 Association of Aeronautical Engineers should be scratched j 13 out.
14 MR. LEWALD: With that deletion, Your Honor, I 15 would offer the document and ask that it be bound in the 16 transcript.
17 JUDGE SMITH: If there are no objections, the 18 resume of George R. Gram is received and is to be bound into 19 the transcript.
I 20 (The resume of George R. Gram 21 follows:)
22 23 24 25 Heritage Reporting Corporation (202) 628-4888
I l
.. d
-s e i
{ \ l
" \- / GEORGE R. GRAM II Work: New Hampshire Yankee Home: 1RFD3 #2 Indian Trail P. O. Box 700 Exeter, NH 03833 Seabrook, NH 03874 (603) 772-5699 (603) 474-9521, Ext. 4399
. SPECIALTIES:
- Utility. Executive Management
. Emergency Planning
. Community Relations and Public Affairs
. Project Management and Construction. Direction of large "Mega" (4 - to 5 Billion Dollar) . Projects
- Budget and Cost Control 4 - 5 Billion Dollar Projects
. Scheduling and Schedule Risk. Analysis
. . Turnaround Management of Critical Projects
. Outage Management and Control
. Contract Negotiations Labor Relations - N&tional and Local EDUCATION:
- M.B.A. - University of Miami, 1982 Miami, Florida
. B.S. - Aerospace Technology, 1970 Kent State University, Kent, Ohio PERSONAL:
- Married - 15 years; wife - Margaret; Daughter - Angela; Son - George PROFESSIONAL:
. American Nuclear Society
. American Society of Mechanical Engineers
. American Association of Aeronautical Engineers
. American Management Association
REFERENCES:
. See Attached EXPERIENCE
SUMMARY
-+s .
Approximately 22 years of experience in the fields of construction, outage management, backfit management,
}
l project management and utility executive management O
beginning in 1965 with line supervisory responsibilities of interstate highway construction, co-op student QC experience with Ford Motor Company; General Electric -
Large Steam Turbine Division turbine erection and field engineer experience; Florida Power & Light Company -
construction, outage, backfit and project management experience; New Hampshire Yankee - utility executive management.
WORK HISTORY:
- Currentiv Executive Director of Emeroency Preparedness and Community Relations for New Hampshire Yankee at the Seabrook Station. This sub-division head position is responsible for all emergency preparedness planning and implementation associated with the Seabrook Station, and all public affairs - community relations for New Hampshire Yankee Electric. This position requires daily, weekly and monthly interface with Local, State and Federal agencies including: 23 local communities and the individual sub-departments of these communities such as Town Selectmen, Town Managers, Fire, Police, Civil Defense, etc.; three States, Maine, New Hampshire and Massachusetts and the various State agencies involved with emergency planning such as State Civil Defense, Department of Public Health, etc.; Federal Agencies include Nuclear Regulatory Commission and the Federal Emergency Management Agency. This position requires weekly and monthly interface with Executive Management (C.O.B.'s, Presidents, C.E.O.'s and Vice Presidents) of the (12) twelve Seabrook Joint Owners.
Expenditure authorization limit for this position is
$500,000 for any single expenditure. This position reports directly to the President, and C.E.O. of New Hampshire Yankee Electric.
Recently Proiect Director of Massachusetts Emergency Planning for New Hampshire Yankee at the Seabrook Station. The Project entailed the development and implementation of a fully, utility run, emergency response organization and program for the Seabrook Nuclear Power Plant for that portion of the evacuation zone situated in Massachusetts. Successful completion of this Project was critical to the 5% and full power licensing of the Seabrook Plant. This position required weekly and monthly interface with Executive Management (Presidents, C.E.O.s, and Vice Presidents of the (12) f twelve Seabrook Joint Owners. Expenditure authorization 0
J 1
.. f
'~
limit for this position is $500,000 for any single expenditure. This position reported directly to the Senior Vice President - Nuclear for NHY.
- Director of Corporate Services for New Hampshire Yankee at the Seabrook Nuclear Power Plant This Subdivision Head position is responsible for all construction related activities at the Seabrook Project. All corporate scheduling, estimating, and project cost control also come under the responsibility of this position. In addition, the Corporate Project Management Department, responsible for all capital projects in-excess of $1,000,000, reports directly to the Director of Corporate Services. This position has direct
-responsibility and control of yearly O&M and capital expenditures in excess of $50,000,000/ year, expenditure authorization limit of $500,000 for any single expenditure and reports directly to the Senior Vice President - Nuclear of NHY.
Director of Construction for New Hampshire Yankee, Seabrook Station. This position from March, 1984, until fuel load on Unit I (October, 1986) at Seabrook, was responsible for all aspects of completing construction
\/~'} of the final 25% of Seabrook Unit I. Duties and responsibilities ranged from: local and national labor q '/
relations, NRC' licensing support, project completion, startup and turnover, Joint Owner financing support, prudency support, contract negotiations, investment recovery, contractor rampdown and demobilization, budget and cost control, scheduling control and direction, etc.
Peak manpower under this position reached 5200 manual and non-manual employees with budget responsibilities exceeding $400,000,000.
1973-3/1984 Florida Power and Licht Co.. Miami Florida Over a period of 11 years held the following positions and responsibilities:
Soecial Proiect Manaaer .with FP&L at their St. Lucie Unit 1 Generating Station, an 802 megawatt nuclear power plant, responsible for removal of the reactor thermal shield and repair of the reactor core barrel. This never before attempted project was conducted completely underwater due to the high radiation levels involved.
An unsuccessful project would have resulted in a long term shutdown of St. Lucie Unit 1. The project was C\
b t
7 l
i
)
completed successfully two (2) days ahead of schedule, O !
after almost one year of around-the-clock, seven days per week work. This position reported directly to the Executive Vice President of Power Production.
Assistant Proiect General Manaer/ Site Manaaer with FP&L !
at their Turkey Point Nuclear Generating Station, two 450 megawatt gas / oil fired units and two 760 megawatt ,
nuclear units, responsible for overall management of l backfit, construction, outage support and outage management on all four Turkey Point Units. This included replacement outages of Steam Generators on both Turkey Point Huclear Units. These replacement outages, which were completed in under six months, set an industry benchmark for correction of the generic industry problem. Average budget responsibilities ranged from $50 million/ year to as high as $200 million/ year during steam generator replacements.
Assistant Proiect General Manaaer under W. B. Derrickson (Engineering News Record's 1984 " Man of the Year") for FP&L on their St. Lucie Unit 2 Nuclear Project. St.
Lucie Unit 2, an 802 megawatt nuclear unit was completed on schedule in just over six years for a total cost of 1.4 Billion Dollars; again, setting an industry benchmark.
Construction Site Manacer for FP&L at their Turkey Point Generating Station, responsible for all major overhauls, modifications, construction, outage support and outage management.
Area Construction Supervisor for FP&L assigned to various sites and special projects, including complete overhaul of FP&L's Sanford Units 4 and 5, 400 megawatt oil fired units.
2/71 -7/73 General Electric Comoany. Cleveland, Ohio for their Large Steam Turbine Division, Installation and Field Engineering Department. Responsible for directing installation (Eastlake No. 5, a 600 megawatt coal fired unit for Cleveland Electric Illuminating) and maintenance overhauls of large steam and boiler feedpump turbines in Ohio, West Virginia, Indiana and Michigan, the majority of which were all coal fired units.
O
- - ----_ J
i i
REBUTTAL PANEL NO. 23 - DIRECT 22695 j
- - 1 MR. LEMALD
- Your Honor, I have copies of the.
t
)\s 2 resume of John W. Baer. For those members of the Board that.
~3 were not members in the New Hampshire proceeding.at'that 4 point time, I would be glad to distribute a copy.
5 JUDGE SMITH: I think it probably would be a good 6 idea since those transcripts may not be -- well, I know 7- they're not available to either member, so why don't you 8 also bind those, too, into the transcript.
9 MR. LEWALD: Yes, Your Honor.
10 JUDGE SMITH: I mean that one, so it will be newly 11 available and universally available.
12 Mr. Baer, is this a current and accurate resume 13 that Mr. Lewald has passed out?
14 THE WITNESS: (Baer) Yes, sir.
f-~
( 15' JUDGE SMITH: Have you seen it?
16 You better look at it?
17 THE WITNESS: (Baer) I should look at it.
18 MR. LEWALD: Our understanding, there was no 19 change from the prior resume that was submitted, Your Honor.
20 JUDGE SMITH: -Well, we'll have that bound in.
21 We will bind Mr. Baer's. Mr. Baer's resume, also,
- 22. will be bound in at this point.
23 THE WITNESS: (Baer) Yes, sir.
24 (The res6me of John W. Baer 25 follows:)
l Heritage Reporting Corporation (202) 628-4888 s_
JOHN W. BAER Experience March 1987 to Present Affiliated with Aidikoff Associa tes, Syosset, New York Present Assignments .New Hampshire Yankee, Seabrook Station. Responsibilities:
Participate in development of New Harpshire's radiological emergency response program for Seabrook Station and provide technical assistance related to licensing / hearing proceedings.
1981 te March 1987 Schneider/EC Planning & Management Services Harrisburg, Pennsylvania Senior Consultant. Responsible for providing program supervision and technical assistance to project staff.
Assigned responsibility for emergency preparedness planning, procedure preparation, personnel training, drill / exercise preparation, licensing support, and scheduling and coordinating project work with the client. Recent project assignments have included:
managing project team efforts in development of New Hampshire's radiological emergency response program in support of Seabrook Station and providing technical assistance in support of licensing proceedings.
managing Nes Hampshire RERP project team efforts in preparation for the 1986 Seabrook Station graded exercise:
managing the offsite radiological emergency preparedness programs for the Counties of Ashtabula, Geauga and Lake (Ohio) to support response to incidents at the Perry Nuclear Power Plant including establishing operational readiness of county emergency O
F -
tip g) . John W. Baer-f lk- / 'Page 2 operations centers, offsite drill and exercise preparation and'ASLB hearing support;
- managing the.offsite radiological emergency preparedness re-training program to, support response to incidents at the Waterford 3 Steam Electric Station;-
- coordinating the radiological emergency preparedness program to support.
response to incidents'at the Callaway Plant including direct responsibility for revision of'the Missouri State Nuclear Accident' Plan'and. associated local radiological emergency response plans, preparation of affidavits-to support motions for summary disposition of licensing contentions, development of local RERP implementing procedures, establishing operational readiness of 7,
local emergency operations centers,-
q development.of. emergency response
'A t.vaining programs for local EOC staff officers and emergency workers, and development / conduct of.the offsite drill and exercise program;
- evaluating and preparing revisions'to the station'and cffsite radiological
' emergency preparedness plans in support of the Palo Verde Nuclear Generating Station; development of the Louisiana Office of Emergency Preparedness' implementing procedures in support of the Waterford 3 Steam electric Station; and preparation of' lesson plans and conduct of training programs for state, county and local emergency response personnel in' support of the R.E. Ginna Nuclear Station.
R
John W. Baer Page 3 1973 to 1980 Southcentral Regional Planning Council Harrisburg, Pennsylvania Director. Responsible for administration of an eight-county planning and evaluation program for the Commonwealth of Pennsylvania. Assisted local governments in planning a development of criminal justice / emergency response communications and automated information systems.
Developed and revised training courses in data analysis for use by planning and operational personnel at the state and local government level. Assisted with delivery of six 35-hour training sessions fer criminal justice personnel within a ten-state region. Developed and conducted practical group exercises for course participants.
Planner (1973 to 1978). Assisted local governments in planning and development of a range of criminal justice programs, criminal justice system communications and automated information systems.
1971 to 1973 Lord Fairfax Planning District Commission Front Royal, Virginia Planner. Performed general planning tasks, including criminal justice and emergency response planning for a five-county region of Northern Virginia.
1966 to 1968 U.S. Department of Defense Fort Meade, Maryland Security Specialist. Evaluated security reasures for a federal security agency.
Provided recommendations for security requirements. Top secret /cr'pto
, security clearance.
Education 1970 Post Graduate Study - Public Administration American University Washington, D.C.
-3 -
O
John W. Baer Page 4 1966 B.A., Political Science Western Maryland College Westminster, Maryland i
i i
_4_
. i I
REBUTTAL PANEL NO. 23 - DIRECT 22696 1 BY MR. LEWALD: i 2 Q Gentleman, I have placed on the table before you a 3 document, the first sheet of which is dated April 18, 1989, 4 under the heading of the hearing matter and document 5 entitled " Applicants' Rebuttal Testimony No. 23 regarding 6 scope of graded exercise," and some 64 pages with j i
7 Attachments A through H.
8 And I ask you if each of you can recognize that 9 document?
10 First you, Mr. Baer?
11 A (Baer) Yes, I can.
l 12 Q Can you identify it as the document containing 13 your tretimony in this proceeding?
14 A (Baer) Yes, sir.
15 Q Mr. Callendrello, can I ask you if you can 16 identify the document entitled " Applicants' Rebuttal 17 Testimony No. 23 regarding scope of graded exercise," under 18 the date of April 18, 1989, as I have just described it to 19 Mr. Baer?
20 A (Ca11endre11o) Yes.
21 It's a document that incorporates my testimony 22 regarding the scope of the 1988 graded exerciae.
l 23 Q And, Mr. Gram?
24 A (Gram) Yes.
25 Q Yes, what?
Heritage Reporting Corporation (202) 628-4888 1
1
REBUTTAL PANEL NO. 23 -DIRECT. 22697
- 1. Does the. document incorporate your testimony?
,7, x_, ) 2 A (Gram) Yes, it does.
'3 Q On the subject matter?
4' A (Gram) For Applicants' Rebuttal Testimony No. 23 5 regarding scope of the graded exercise; yes, it does.
6 Q Can I ask each of you whether or not the matters 7 contained in your testimony as appearing in this document 8 true to the best of your knowledge and belief?
'9 Mr. Baer?
10 A (Baer) Yes.
11 A (Callendrello) Yes, they are.
12 .O Mr. Callendrello. 4 13' And, Mr. Gram?
14 A (Gram) Yes, they are. R
'! ,,,\
(/ 15 MR. LEWALD: Your Honor, I would offer Applicants' 16 Rebuttal No. 23 regarding scope of graded exercise and ask 17 'that it be bound.into the transcript as if read.
18 JUDGE SMITH: Mr. Brock?
19 MR. BROCK: No objection.
20 JUDGE SMITH: The testimony is received.
21 MS. DOUGHTY: Your Honor, I just wanted to raise a 22 point. There seems to be some portions of this testimony 23 that are more in the nature of legal argumentation at the 24 beginning.
25 I know Mr. Lewald has raised this as an objection 1
Heritage Reporting Corporation
, s (202) 628-4888 V
1 i .
. e Liz__ -- --_ _-_-------- I
REBUTTAL PANEL NO. 23 - DIRECT 22698 1 when people on our side of the case has offered what is ,
2 essentially -- through witnesses testimony --
3 JUDGE SMITH: Let's back up a little bit.
4 Are you raising an objection?
j 5 MS. DOUGHTY: Yes, essentially.
6 With respect to the -- beginning at page four, 7 subsection C, FEMA guidance on scope.
8 JUDGL SMITH: Page what? Would you slow down now.
9 MS. DOUGHTY: Page four.
10 Subsection C is essentially in the nature of an 11 interpretation of FEMA guidance, and I think it's more of a 12 legal document than actual testimony.
13 So I would move that that portton be stricken.
14 JUDGE SMITH: Mr. Lewald?
15 MR. LEWALD: Your Honor, this is a description of 16 the underlying -- the putting together, if you will, of the 17 graded exercise in terms of objectives and scope scenario 18 and evaluation under the guidance that FEMA has offered.
} 19 It's really descriptive background description as l
20 to what the testimony is working with, with respect to the 21 scope of the exercise.
l l 22 JUDGE SMITH: This is identical to the same type 23 of objection that has been repeatedly raised by both sides, 24 both sides throughout this litigation. And they raise the l 25 objection that a legal opinion cannot be expressed by lay-Heritage Reporting Corporation (202) 628-4888 ,
l
REBUTTAL PANEL NO. 23 - DIRECT 22699 73 I witnesses.
I i !
\ x ,,/ 2 And repeatedly we have ruled that: one, where the 3 lay-witnesses as a part of their work and their professional 4 lives use and rely upon regulations and guidance and even 5 statutes, as far as that's concerned, they may testify as to 6 how regulations and legal guidance are empicyed in their 7 work. And that's how they have done in here.
8 And in addition to that, many regulations and many 9 guidances, technical guidances of FEMA and the NRC are 10 really engineering guidances and not law guidances, and they l 11 are better understood, actually, by experts in the field 12 than lawyers. ,
13 In any event, the objection is overruled. We see
,s 14 it not as an effort to give legal advice or express a legal
/ s 15 opinion.
16 Judge Cole pointed out a relevant point. This 17 FEMA guidance and scope, do you witnesses understand this 18 and do you use it? And is it a part of your work as
- 19 emergency planners?
20 THE WITNESS: (Callendrello) Yes, sir, it is.
21 And it certainly formed the basis for at least part of the 22 Extent of Play, the exercise.
23 MS. DOUGHTY: Your Honor, for example, the 24 statement at the top of page five: " FEMA ha s equated the 25 major observable elements with the exercise objectives."
l l
/G Beritage Report sg Corporation i I (202) 628-4888
\m / l l
REBUTTAL PANEL NO. 23 - DIRECT 22700 1 That's an opinion and it's in the nature of a legal opinion.
2 JUDGE SMITH: Overruled.
3 It's not a legal opinion at all. It's 4 observation. In fact, they're quoting, so it's not even an 5 opinion. It's a quote.
6 Overruled.
7 We have been through this many times, Ms. Doughty.
8 You have been present when'we've argued this and discussed 9 this, isn't that true?
10 MS. DOUGHTY: Yes. If this is understood as just 11 their opinions, I suppose. But I have some argument with 12 some of the conclusions they reach, and I think they're in 13 the nature of legal conclusions.
14 JUDGE SMITH: Oh, then complete all of your 15 arguments, by all means.
16 MS. DOUGHTY: For example, they state here: " FEMA 17 guidance indicates that the one objective No. 36 that need 18 not be demonstrated is the ability to carry out emergency 19 response functions during an unannounced off-hours drill or 20 exercise."
21 JUDGE SMITH: That's not legal.
22 MS. DOUGHTY: Well it is because that's related to 23 a utility plan. So arguably the New Hampshire -- they are 24 applying that guidance --
25 JUDGE SMITH: Well, we just don't accept the fact Heritage Reporting Corporation (202) 628-4888
j.
REBUTTAL PANEL NO. 23 - DIRECT 22701
/" 'l that lawyers and only lawyers can work with FEMA guidance.
s_- '2 Elaergency workers, other people work with FEMA guidance, and 3' they develop'e2.pertise in it. And in.any event, it's 4 relevant to how they have used it even if they misinterpret.
5 Now, you can examine them if you think that they 6 have misinterpreted,- you will have that chance to examine 7 them.
8 MS DOUGHTY: All right.
9 JUDGE SMITH: But it is being offered as a m 10 background of how they have employed this guidance in their 11 work.
12 Is that correct, gentlemen?
13 THE WITNESS: (Callendrello) Yes, sir, it is.
14 MR. BROCK: Your Honor, at this time I distribute fs
\s- 15 the cross-examination plan of the Mass AG to the Board.
-16 MR. LEWALD: Did Your Honor accept the testimony 17 into the record?
18 JUDGE SMITH: The objection is overruled.
19 You've completed all of them now, Ms. Doughty?
20 MS. DOUGHTY: Yes.
21 JUDGE SMITH: The objection is overruled.
22 The testimony is received and shall be bound into 23 the transcript.
24 25
/N Heritage Reporting Corporation
() (202) 628-4888
REBUTTAL' PANEL NO. 23 - DIRECT 22702 1 (Applicants' Rebuttal i l
g 5
2 Testimony No. 23 regarding
- 3 scope of graded exercise 4 follows:)
5 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
_ _ _. _ _ _ _____.__m _ ___ ____ _ _ _________ _ _ _ _ _ _ _
!! ' i
]
LlD k .
April 18, 1989' l
i UNITED STATES OF' AMERICA NUCLEAR REGULATORY COMMISSION l
l before the ATOMIC SAFETY AND LICENSING BOARD 1
)'
EIn the Matter of )
)
PUBLIC SERVICE COMPANY OT ) Docket Nos. 50-443-OL NEW HAMPSHIRE, et al. ) 50-444-OL
)
(Seabrook Station,-Units 1 and 2)~ ) (Off-site Emergency
) Planning Issues)
)
{ APPLICANTS' REBUTTAL TESTIMONY NO. 23
-' REGARDING SCOPE OF GRADED EXERCISE Panel Members: John W. Baer, Emergency Planning Specialist, Aidikoff Associates Anthony M. Callendrello, Manager, Emergency Preparedness Licensing, New Hampshire Yankee George R. Gram, Executive Director of Emergency Preparedness and Community-Relations, New Hampshire Yankee 1
I
t O
. TABLE OF CONTENTS I. INTRODUCTION AND BACKGROUND . . . . . . . . . . . . 1 A. Purpose of Testimony . . . . . . . . . . . . . 1 B. Regulatory Requirements for Exercise Scope . . 3 C. FEMA Guidance on Scope . . . . . . . . . . . . 4 II. DETERMINATION OF SEABROOK EXERCISE SCOPE . . . . . 8 A. Overview . . . . . . . . . . . . . . . . . . . 8 B. Interactive Process to Determine Scope . . . . 9
- 1. Exercise Objectives . . . . . . . . . . . 9
- 2. Exercise Extent of Play . . . . . . . . . 12
- a. Demonstration of Plan Components . . 12
- b. Demonstration of Sufficient Numbers 15
- c. Demonstration of Reasonably Achievable . . . . . . . . . . . . . 16 e
- d. Influences on Scope . . . . . . . . 18 III. ISSUES RAISED IN CONTENTIONS . . . . . . . . . . . 22 i
l l A. Implementation of Protective Actions for L Impacted Populations . . . . . . . . . . . . . 22
- 1. FEMA Exercise Objective . . . . . . . . . 23
- 2. Influences . . . . . . . . . . . . . . . 24
- 3. Extent of Play . . . . . . . . . . . . . 25
- 4. Exercise Demonstration . . . . . . . . . 27
- a. Notification, Assignment, and Deployment of Resources . . . . . . 27 i
l l
l
-ii-
- _ . - _ _ _ _ _ _ _ - _ _ _ _ - .l
i s
I.
Y -
.,N
[ . .
, d b. Field Demonstration of Wheelchair Vans . . . . . . . . ... . . .J. . . -.- .28
- c. Field Demonstration of Ambulances . 28
- B . Transporting Contaminated Injured Individuals 29
- 1. . FEMA Exercise' Objective . . . . . . . . . 29
- 2. Influen~ces- ... . . . . . . . . . . .. 30 3.- Extent of Play' . .. . . . . . .. . . ., . 31' 4.: Exercise ~ Demonstration .. . . . . . . . 31' C. ' Environmental Sampling . . . . . . . . . . . . . 32
- 1. . FEMA Exercise' Objective . . . . . . . . .- 32
'J 2 . -- Influences . . . . . . . . . . . . . . . 32'
- 3. . Extent of Play . . . . . . . . . . . . . 331
- 4. Exercise Demonstration . . . . . . . . . 34 D. Implementation of Traffic control . .- . .. . .- 34 7
~f
'1. ' FEMA' Exercise Objective . . . . . . . . . 34-
- 2. Influences . . . . . . . . . . . . . . . 35
- 3. Extent of Play . . . . . . . . -. . . . . 35
- 4. Exercise Demonstrahlon . . . . . . . . . 36
- a. Notification and coordination'with Law Enforcement Organizations .. . . 36
- b. Assessment,. Assignment and Field Deployment of Police Resources . . 36
- c. Demonstration of Traffic Control in
-Hampton. . . . . . . . . . . . . . -. 39 E. Monitoring and Decontamination for Emergency Workers; Disposal of Decontamination Center Wastes . . . . . . . . . . . . . . . . . . . . 39
- 1. FEMA Exercise Objective . . .. . . . . . 40 I -iii-
.I L
l
l
- 2. Influences . . . . . . . . . . . . . . . 40
- 3. Extent of Play . . . . . . . . . . . . . 41
- 4. Exercise Demonstration . . . . . . . . . 42
- a. Demonstration of Monitoring and Decontamination Functions for Emergency Workers . . . . . . . . . 42
- b. Evaluation of the Emergency Worker Facility . . . . . . . . . . . . . . 42
- c. Disposal of Wastes Generated at Monitoring and Decontamination Facilities . . . . . . . . . . . . . 43 F. Staffing of Emergency Response Facilities . . 44
- 1. FEMA Exercise Objective . . . . . . . . . 44 !
- 2. Influences . . . . . . . . . . . . . . . 45 i
- 3. Extent of Play . . . . . . . . . . . . . 45
- 4. Exercise Demonstration . . . . . . . . . 46
- a. Facility Staffing . . . . . . . . . 46
- b. Second Shift Staffing . . . . . . . 48
- c. Representation of the Governor's Office . . . . . . . . . . . . . . . 49 G. Implementation of Protective Actions for School Populations . . . . . . . . . . . . . . 49
- 1. FEMA Exercise Objective . . . . . . . . . 50
- 2. Extent of Play . . . . . . . . . . . . . 50
- 3. Exercise Demonstration . . . . . . . . . 51
- a. 1 notification and Coordination of Emergency Information With Schools . 51
- b. Provision of Transportation '
Assistance to Schools . . . . . . . 51 1
-iv-L l.
.; l J
,f$
1 b i-
'Q) c. Teacher Participation . . . . . .. 52
.H. 1 Implementation of Protective Actions for
,l Impacted Populations in New Hampshire .
.z . . . 54
- 1. FEMA' Exercise' Objective . .. . . . .' . . ~ . 54
- 2. Influences . . . . . . _. . . . . . . . . 55 !
3.. Extent of Play . . . . . . . . . . :. . . 56
- 4. Exercise Demonstration . . . ... . . . . 58
- a. Transportation Resources.for Special E Populations . . . . .. . . . . . . . .58
- b. Ability of. Host Facilities to ,
Receive Special Facility Evacuees . 61
- c. Radiological Monitoring of Special
' Facility Evacuees . . . . . . . . . 61
- d. KI Decisionmaking . . . . . . . . . 61-
- j-w (1) Extent of Play . . .. . . . . 62'
\s / (2) Influences . . . . . . . . . . 62 (3) Exercise Demonstration . . . . 63 Attachment A: FEMA Memorandum From R.W. Krimm to F. Begley, Radiological Monitoring, Dated January 5, 1988 Attachment B: FEMA Memorandum from R.W. Krimm for NTH Division Chiefs, All FEMA Tagions, GM MS-1, Dated February 9, 1988 Attachment C: FEMA Memorandum From R.W. Kritm to E.A.
- Thomas, Guidance for the Qualifying,. Full-Participation Exercise at Seabrook Dated May 19, 1988 -
Attachment D: PSNH Letters from G.R. Gram to R. Boulay, Director of Mass. Civil Defense Agency, Dated January 15 and January 18, 1988; Records of Conversation - J.A. MacDonald, Dated January ;
27 and March 25, 1988 j
-v-1
Attachment E: Participation Matrix for ORO Exercise Attachment F: FEMA Memorandum From R.W. Krimm to F.J.
Congel, Objectives for the Seabrook Exercise, Dated June 22, 1988 Attachment G: NRC Memorandum From F.J. Congel to R.W. Krimm, Objectives for the Seabrook Exercise, Dated June 23, 1988 l Attachment H: FEMA Letter From R.W. Donovan, RAC Chairman to G.R. Gram, PSNH, Summary of Survey of Seabrook Facilities and Services, Dated October 21, 1988 i
1 O.
l
-vi-g 1
1
- 1 l
l
t-m I. INTRODUCTION AND BACKGROUND A. Purpose of Testimony The purpose of this testimony is to. respond to those admitted exercise contentions that concern the adequacy of the scope of the pre-license Saabrook Station 1988 FEMA
~
Graded Exercise of offsite emergency response organizations (the Exercise)l. Specifically, the interveners assert that the Exercise was too limited in scope because:
- ' The Massachusetts portion of the Exercise did not include' demonstration or evaluation of major portions.of'the Seabrook Plan for Massachusetts Communities (SPMC) in that there was no test of the Offsite Response. organization's j
s ( ORO,' s ) ability te muster the appropriate personnel and-vehicles in order to evacuate special facilities.in
" ~
Massachusetts. (MAG EX-2, Basis E)
- The Exercise failed to demonstrate that the ORO had adequate vehicles, e quipment , procedures, and personnel to
~
transport contaminated, injured individuals in that only one ambulance was tested. (MAG EX-21, Basis B)
. The Exercise failed to demonstrate sufficiently the ability of equipment and procedures in the State of New Hampshire to sample food and water appropriately by the testing of only two State Sample Collection Teams.
(SAPL EX-4).
- .1 -
f
l The Exercise failed to demonstrate that there would be sufficient numbers of personnel in New Hampshire to staff both the Traffic Control Posts and Access Control Posts because too few of these posts were adequately demonstrated.
(SAPL EX-6; TOH/NECNP EX-1, Basis d)
The Exercise failed to demonstrate the capability for decontaminating emergency workers in New Hampshire because a monitoring / decontamination facility (Hillside Junior High School) was not opened and, further, there was no provision for waste disposal. (SAPL EX-7)
The Exercise f ailed to demonstrate adequate staffing (24-hour and key positions) of Staging Areas, Reception Centers, local and host EOCs and the IFO in New Hampshire. (SAPL EX-8)
The Exercise did not demonstrate adequate protection in New Hampshire of persons in nursing homes, hospitals and other special facility institutions. The limited testing of special vehicles in the New Hampshire portion of the Exercise failed to demonstrate the ability to provide a sufficient number of buses and ambulances with properly trained drivers for transit-dependent persons, and that the buses would be properly routed. (SAPL EX-13; TOH/NECNP EX-1, Bases f and g)
The Exercise failed to demonstrate that protective actions for schools in New Hampshire can be implemented
~2-f
}
i 1
because teachers did not participate in the Exercise.
(TOH/NECNP EX-1, Bases a and b)
The following sections of this testimony discuss the regulatory requirements and Federal Emergency Management Agency (FEMA) guidance which pertain to the scope of a pre-license or qualifying exercise.Section II infra discusses the process by which the organizations involved in development of the Exercise applied the regulatory requirements and guidance and determined the scope and extent of play for the Exercise.Section III infra addresses each of the admitted contentions concerning scope of the Exercise in the following sequence:
Section III.A. - MAG EX-2, Basis E Section III.B. - MAG EX-21, Basis B Section III.C. - SAPL EX-4 Section III.D. -
SAPL EX-6 and TOH/NECNP EX-1, Basis d Section III.E. - SAPL EX-7 Section III.F. - SAPL EX-8 Section III.G. - TOH/NECNP EX-1, Bases a and b Section III.H. - SAPL EX-13 and TOH/NECNP EX-1, Bases f and g B. Regulatory Requirements for Exercise Scope The required scope of a pre-license or qualifying exercise finds its roots in 10 CFR Part 50, Appendix E,
l 1
1 6 IV.F.1 which requires "a full participation exercise which tests as much of the . . . emergency plans as is reasonably achievable without mandatory public participation." "' Full participation' includes testing the major observanle portions of the onsite and offsite emergency plans and mobilization of State, local and licensee personnel and other resources in sufficient numbers to verify the capability to respond to the accident scenario." Id., fn. 4.
C. FEMA Guidance on Scope With respect to the scope of pre-license or qualifying exercises necessary to meet the above regulatory criteria, FEMA, with the concurrence and approval of the NRC, developed a list of exercise objectives and capabilities that off-site radiological emergency response organizations must demonstrate. The objectives were developed from standards contained in 10 CFR 50.47(b), 44 CFR 5 350.5 and NUREG-0654, FEMA-REP-1, Rev. 1, Criteria for Preparation and Evaluation of Radiological Emergency Response Plans and Preparedness in Support of fluclear Power Plants (1980). FEMA Guidance Memorandum EX-3, Managing Pre-Exercise Activities and Post-Exercise Meeting (February 26, 1988), as supplemented by FEMA i
Guidance Memorandum (GM) EX-3 Amendment (March 7, 1988) sets forth the objective statements applied to the Seabrook Station Exercise. The FEMA exercise objectives functionally i
restate the intent of the evaluation criteria in I.TREG-i l
( 0654/ FEMA-REP-1, Rev. 1, as supplemented by NUREG-0654/ FEMA-REP-1, Rev. 1, Supp.'1, that can be observed and evaluated in exercises. FEMA has equated the " major observable elements" with the exercise objectives: "the major elements of plans and preparedness are incorporated in the . . . exercise objectives. . . .
" FEMA Guidance Memorandum PR-1, Policy on NUREG-0654/ FEMA-REP-1 and 44 CFR 350 Periodic Requirements (1985) at pg. 2.
Although the thirty-seven (37) offsi.te objective statements are grouped in three categories in GM EX-3 based on their need to be demonstrated in biennial exercises, FEMA has indicated in GM EX-3 that a pre-license exercise, such as that conducted at Seabrook, should demonstrate all but one of D the applicable objectives. FEMA guidance indicates that the one objective'(*36) that need not be demonstrated is the ability to carry out emergency response functions.during an unannounced off-hours drill or exercise. See GM EX-3 Amendment, page 2. Two other objectives were eliminated as inapplicable to the Seabrook Station Exercise. It is not the policy of either the State of New Hampshire or the Commonwealth of Massachusetts to recommend the use of KI for the general public. Therefore, KI for the general public is not a provision of either the SPMC or the:NHRERP.
Accordingly, the associated FEMA Exercise. Objective (No. 17) was not demonstrated. FEMA Exercise Objective No. 35, which g
\
l deals with the evacuation of onsite personnel, was demonstrated by the onsite emergency response organization, and evaluated by the NRC.
FEMA, therefore, has provided guidance as to which objectives are applicable and should be demonstrated during a qualifying exercise. The extent to which objectives or major portions of the plans should be demonstrated is a function of the specific characteristics of the plan and the site. As to 1
the extent of required demonstrations, which is referred to as the " extent of play," GM EX-3 Amendment provides the following guidance:
- The scope of the demonstration should include personnel, f acilities and resources required by the scenario and extent of play; The degree of demonstration of individual exercise objectives should test the workability of that aspect of the plan;
- The demonstration and evaluation of the objectives should follow the specific provisions of the plan being tested; and
- The demonstration of knowledge and liaison capabilities between response organization personnel will be evaluated based on the timeliness, completeness and effectiveness of interfaces.
O
'( The extent of play, as defined by FEMA guidance, relies on implementation of plans and procedures, including demonstrations of personnel, facilities and resources, as.
~
required by the exercise scenario. Verification of the workability of the demonstrated processes is based on the timeliness, completeness and effectiveness of the required responses. To this end, FEMA has developed an Exercise Evaluation Methodology (EEM) for use by FEMA exercise evaluators in evaluating exercises conducted pursuant.to 44 CFR 350, 10 CFR 50, and the NRC-TEMA Memorandum of Understanding (50 FR 15485). The EEM is utilized to ensure uniformity in the observation and evaluation of exercises.
For each exercise objective, the EEM identifies points of
/#'\ review which are derived from functional evaluation criteria of NUREG-0654/ FEMA-REP-1,-Rev. 1 and NUREG-0654/ FEMA-REP-1, Rev. 1, Supp. 1. These points of review direct the evaluators' attention to specific emergency response functions which fall within the purview of the applicable exercise objectives.
In addition to the guidance for extent of play in GM EX-3 Amendment, FEMA has provided supplemental guidance on the scope of demonstrations for (1) radiological monitoring capability (FEMA Memorandum from R. W. Krimm to F. Begley, dated January 5, 1988 (Attachment A hereto)), (2) medical services (MS-1) capability (FEMA Memorandum from R. W. Krimm 7
I I
I l
to NTH Division Chiefs, dated February 9, 1988 (Attachment B hereto)), (3) alert and notification capability (FEMA GM AN-1, dated April 21, 1987) and, (4) protective actions for school children (FEMA GM EV-2, dated November 13, 1986).
FEMA recognizes that site-specific factors of organizational planning and preparedness are further influences on extent of play. See FEMA Memorandum from R. W. Krimm to E. A. Thomas, dated May 19, 1988 (Attachment C hereto). With respect to the Seabrook Exercise extent of play, the various site-specific factors which were considered are discussed generally in Section II below and specifically concerning the contentions in Section III below.
II. DETERMINATION OF SEABROOK EXERCISE SCOPE A. Overview Determination of th: scope of the Exercise followed a sequential process. The process conformed to milestones established in FEMA GM EX-3 for completion of required actions preceding the conduct of the Exercise. The sequence of actions included generally:
- 1. Selection and development of Exercise objectives by New Hampshire Yankee (NHY) and participating state governments for submission to FEMA and NRC regional offices. The selection and development of objectives were determined primarily by the pre-
_g_
.t.
l!
\
p [( ) requisites for qualifying exercises of GM EX-3 and GM EX-3 Amendment.
- 2. Development and submission of an Exercise scenario which would be sufficient in scope to address the selected objectives and to prompt demonstration of the corresponding major observable portions of the plans.
- 3. Specification of an extent of play which defined' the actions to be taken and resources.to be employed ~ for demonstration of the major observable portions of the plans.
- 4. Contacts and meetings.among representatives of FEMA, NRC, NHY and the participating state f[( governments to discuss modifications to the extent of play and to complete the scenario.
B. Interactive Process to Determine Scope
- 1. Exercise Objectives The planning process to determine the proper scope of a qualifying exercise included the consideration of what major observable portions of the plan will be demonstrated and the
. extent of the demonstration. FEMA Exercise objectives, developed to meet regulatory requirements, provide the mechanism by which major observable portions of a plan are identified. The extent of play is derived from the specific provisions of the plans. Determination of the scope of the j f G[h
I exercise required an interactive process by the planning and evaluating organizations involved in the exercise.
New Hampshire Yankee (NHY), State of New Hampshire, State of Maine, FEMA and the NRC, each provided representatives who were involved in the planning of the Exercise and contributed to the defined scope of the Exercise. The Commonwealth of Massachusetts was invited to participate in the Exercise planning process but declined to do so. Egg Letters from G. Gram, NHY, to R. Boulay, MCDA, dated January 15, 1988 and January 28, 1988; Telephone conversation menos of J. A. MacDonald, NHY, dated January 27, 1988 and March 25, 1988. (Attachnent D hereto). In addition, all public school districts, and many private schools, special facilities, and governmental entities in Massachusetts would not participate in the Exercise planning process. Attachment E hereto is a matrix showing the facilities that were contacted prior to the Exercise to determine their willingness to participate in the Exercise and the responses received from each of them. This failure to participate influenced the definition of the boundaries of what was reasonably achievable to be demonstrated for many of the major observable portions of the plan. Other influences are discussed in Section II.B.2.d. infra.
l Using the applicable FEMA objectives as a guide in delineating major observable portions of the of f site plans, l
1 i
9
i' r
l:
i A-( I NHY drafted an Exercise scenario which set forth a logical
\m /-
sequence of events that might result from the postulated accident at Seabrook Station. The sequence of events prompted actions required by the emergency response organizations to demonstrate their integrated capability.to respond to the escalating Exercise scenario. Scenario events were designed to generate responses by personnel and resources which, if performed properly, would address and meet the stated Exercise objectives. The' objectives, in turn, were keyed to those major portions of the plan that could be reasonably observed, assessed and evaluated.
Representatives from the State of New Hampshire and the State of Maine reviewed the Exercise scenario and contributed to the determination of how the objectives would be O& demonstrated. The results are set forth in Section 2 of the Seabrook Station 1988 FEMA /NRC Graded Exercise Scenario.
(Applicants' Exhibit 61) For each Objective, the Exercise scenario generally indicates:
- 1. The exercise objective that is to be demonstrated.
i
- 2. The major portions of the plan that will be
]
observed.
- 3. The personnel who will be involved in the demonstration. 4
- 4. The actions that should be taken by Exercise i
participants.
\
- 5. The resources that will be used to respond to the event.
Th' saabrook Exercise Objectives were reviewed and accepted t y TE'e., . snd the NRC. geg FEMA Memorandum from R. W. Krimm to 1 J. rangel. NRC, dated June 22, 1988 (Attachment F hereto);
and NRC Memorandum for F. J. Congel to R. W. Krimm, FEMA, dated June 23, 1988 (Attachment G hereto).
- 2. Exercise Extent of Play
- a. Demonstration of Plan components Development of the extent of play for the Seabrook Exercise involved the design of exercise activities that would demonstrate, test, and verify the capability of particular effsite emergency response functions relied upon in the offsite response picns for Seabrook Station. The extent of play for the Exercise was designed to conform with FEMA guidcnce which states: "The degree of demonstration. of individual exercise objectives should test the workability of that aspect of the plan." (Emphasis added.) GM EX-3 Amendment, page 3. The scenario development process which determined the type and number of demonstrations (i.e., the extent of play), involved an extansive interactive process on the part of the representatives of the organizations involved in the Exercise.
NHY drafted a proposed extent of play. A systematic approach was undertaken by NHY for the selection and l
l v-
. .r evaluation of emergency. response functions which should'be
(
tested to verify the capability to respond to an actual emergency at Seabrook Station. This approach contemplated' )
l that all functional areas to meet an applicable objective ]
1 would be demonstrated. Federal guidance was used to j establish the basic framework of the functional ]
demonstration. Ege, pg. 5, supra.
The initial step in developing the extent of play was to identify the functional areas within the purview of the exercise' objective. For example, Exercise Objective 18 states:
" Demonstrate the ability and resources necessary to implement appropriate protective actions for the impacted permanent and transient plume EPZ population (including transit-dependent persons, special needs
. gO populations, handicapped persons and institutionalized
\j persons)."
A discrete observable element within. this objective would ?be a demonstration of the ability and resources to implement protective actions for transit-dependent persons.
The next step in developing the extent of play was to identify the processes, and their components, required to demonstrate the plan element during the Exercica. The same components are generally applicable to most plan elements and may be defined as follows:
+
decisionmaking conveyar.re of the decision
,O (
.l implementation of the decision by, among other thingF f determination of needed resources
- mobilization, allocation and deployment of needed resources verification of the deployment process.
Where the plan required responders to perform actions unique to a radiological emergency response, those actions were to be performed unless precluded by external influences.
The external influences, therefore, set the upper bound on what was rear 7nably achievable. In certain cases, however, the actual implementation in the field consists of responders performing actions which they are essentially trained to do or that they perform as part of their normal emt . .e n t (e.g., ambulance drivers, bus drivers, law enforcement personnel). Actual field deployment of resources in these cases could be litited to the extent necessary to:
demonstrate the extension of the decision process to the point of deployment in the field.
demonstrate procedures and communications for coordination of field resources and for their integration with the emergency response organization.
demonstrate the workability of field procedures.
i 1
l W) k_, ' -
demonstrate the effectiveness of training of field personnel'in'RERP specific actions.
Because the functions to be performed by these responders were similar'to their normal employment functions, an adequate demonstration of this particular functional area did not require extensive deployment of resources.
- b. Demonstration of Sufficient Numbers 10 C.F.R.'Part 50, App. E.IV.F.1 requires that the qualifying exercise scenario be designed to test sufficient numbers of plan components and processes, personnel, and other resources to ensure that the plan can be implemented and'that problem areas in the major portions of the plans and procedures, if present, would be' revealed. The Seabrook r
Exercise scenario was designed and developed to ensure that k m proper response implementation was the result of effective and workable plans and procedures:-- not.nere chance.
Representatives of the organizations involved in deve]cpment of the Exercise snenario considered a variety of factors and approaches in their determination of what constituted a sufficient demonstration to permit verification of the integrated response capability. NHY preliminarily considered a statistical approach. The use of a statistical application, for example, indicated that a certain sample size of Traffic Control Points (TCPs) in Massachusetts and
\% _/
t
I bus routes in New Hampshire could be demonstrated so that the results could be statistically interpreted.
J The statistical approach did not, however, control the level of demonstration. Rather, the level of demonstration was expanded to what was reasonably achievable or contracted '
based on constraints or external influences. The extent of play in any functional area was designed to test the workability of a plan process or resource -- a test that is 1
based largely on factors other than adherence to a statistical approach to determine the needed scope of the demonstration. With respect to the demonstrations noted above, for example, the Exercise extent of play was developed to:
demonstrate all TCPs and associated SPMC i traffic guide personnel in Massachusetts because this process is RERP specific and no constraints existed to reasonably limit the demonstration; and demonstrate virtually all New Hampshire bus routes, independent of the Protective Action Recommendations (PARS) resulting from the Exercise scenario, because FEMA requested a full demonstration in order to resolve FEMA findings from the previous 1986 exercise.
- c. Demonstration of Reasonably Achievable In the process of reaching consensus on the extent of play, representatives of the organizations participating in
/~x
(% ,r ) the Exercise met in a series of joint coordination meetings ,
I for the purpose of defining what was reasonably achievable and, therefore, establish the extent to which the demonstration of any functional area would be performed.
This. interactive process-resulted in a major coordination meeting of all the organizations on April 20, 1988 at which the Exercise objectives and the majority of the extent of play for all response organizations were determined. Those implementation aspects of the plans intended to meet an Exercise objective that were not affected by external influences were to-be' demonstrated in full as dictated by scenario events. An example of this would be the decisionmaking process associated with the formulation of i g protective action recommendations (PARS).
Those components of the major observable portions cf the plans found to be impacted by external influences were reviewed and discussed by the organizations' representatives to ensure that these components would be-demonstrated to the extent reasonably achievable or necessary to test their ability to be implemented. Scope expansions were evaluated l
to ensure that they would be useful. Scope contractions were evaluated to determine whether the remaining extent of play was sufficient to test what needed to be verified.
This deliberative process of defining the extent to which thase various conponents or functional areas would be gr s 17 t 1 l
w_-_---______-___________________________--
demonstrated resulted in an extent of play agreement which became Section 3 of the Seabrook Station 1988 FEMA /NRC Graded Exercise Scenario. (Applicants' Exhibit 61) The organizations' participants in the process agreed that the extent of play founded on the criteria discussed above, subject to the external influences discussed in section II.B.2.d. infra, was adequate to test the major observable portions ci the plans.
- d. Influencqs on Scope Representatives of the organizations involved in the development of the Exercise scenario considered a number of external influences affecting Lne extent of play. They considered whether demonstrations of certain activities associated with the plans were not required because they were normal day to day functions or were required because they were unique to a radiological emergency response plan. An activity would be unique to the response plan it the function perfczi.ed in a rac'iological energency at Seabrook Station would be different than a normal day-to-day function. If it i was not different, the demonstration of that function could logically be limited in th9 Exercise. The Exercise extent of i
play contempic ted that these activities would be performed in
{
their normal manner; therefore, demonstrations of these activities were not, in and by themselves, required to test l
I l
1 I i L______________ ___ J
w l
I
- -~s=
j j the workability of' major observable portions of the plans. a V The Exercise' extent of play relied on the. fact that:
+-
police'know how to perform traffic control,
~
special vehicle / ambulance crews know how to perform 1 functions pertaining to the transport of special population individuals, special care facility personnel know how to perform functions pertaining to the care of their wards, a
bus drivers know how to drive buses, and a
tow truck crews know how to locate and tow vehicles.
-The extent of play was further influenced by the fact that the Exercise was a simulation. The organizations'
-~g representatives assessed what was reasonably achievable in a-
\. / non-emergency situation. Among external influences which were assessed and factored into .the (xtent of plcy were:
- 1. The-need to reasonably limit the participation of public health and safety personnel (firemen, police, medical, and other emergency respondert.) so that they are not unduly away from normal public duties during a non-emergency situation.
- 2. The need to avoid impairing or closing down normal state and local agency operations in a non-emergency situation. J i
i
-l j; s '
l 1
l L -
- - - - - _ - - - _ _ - - - - - _ - - _ - - _ - - - - - - - -- --- -- 9
i l
- 3. The need to reasonably limit the participation of i all Exercise participants and evaluators so they do not have prolonged absences from normal duty stations during a non-emergency situation.
- 4. The need to reasonably limit the extent of use of public resources (e.a., buses, ambulances, schools, hospitals, etc.) so that their absence or use during the Exercise will not cause impacts to the public or unreasonably interfere with public use.
- 5. The need to otherwise minimize any impact to or inconvenience of the general public.
- 6. The inability to demonstrate during the Exercise certain aspects of the SPMC caused by the lack of participation by the Commonwealth of Massachusetts, state and i local authorities and other entities (e.g. school officials, special facility personnel). Certain facilities relied upon in the SPMC or NHRERP were not available during the Exercise.
The impact of unavailable facilities was assessed to determine whether compensating measures should be taken. For example, the ORO Staging Area contemplated in the SPMC, located on River Street in Haverhill, Massachusetts, was not available to demonstrate its functions. To compensate, NHY modified an existing facility located at the Salem Industrial Park, Salem, New Hampshire, to simulate the Haverhill facility. This simulated NHY ORO Staging Area was used 1
3
- .f" t
( during the Exercise to demonstrate functional areas associated with the deployment of emergency workers and the performance of the ORO local liaisons. The use of this-simulated facility allowed functions to be demonstrated as dictated by the Exercise scenario and, hence, is consistent with general FEMA guidance regarding the scope of demonstration of facility functions. Egg GM EX-3 Amendment, p.3.
- 7. The availability of FEMA and NRC. personnel'to physically observe and evaluate a large number of concurrent Exercise " events." FEMA, for example, required limitations or modifications to demonstration sequencing of.certain events in some functional areas so that its evaluators could
' observe and assess demonstrations of more than one event s_ .
This is common FEMA practice due.to resource limitations and evaluation priorities. But it is important to note that only certain field demonstrations were out-of-sequence.
Decisionmaking in support of these response functions was l done in sequence with the Exercise scenario to test the 4
integrated respense capability in these areas.
- These external influences were balanced with the competing goal of demonstrating " sufficient numbers" of personnel and resources to verify that the emergency plan processes are workable. This balance involved a collective judgment of what is reasonably achievable in an exercise and l
f'
what level of participation is necessary to test the workability of the plans. A significant factor in this collective judgment was FEMA's expertise and experience as to what and how elements should be tested, a professional opinion that was carefully considered by the other organizations' representatives in the development of the Exercise scenario.
1 Irrespective of the external influences on the extent of play, the Exercise was a large event. During the two days of 1
the Exercise, 1525 persons participated as players in the three offsite organizations, 338 persons simulated evacuees, and 274 NHY controllers, 151 FEMA evaluators, and 40 NRC observers participated. Notwithstanding the fact that FEMA put more evaluators in the field for the Seabrook Exercise than for any other previous exercise, the availability of evaluators did influence the number or sequencing of events that could reasonably be observed.
III. ISSUCS RAISED IN CONTENTIONS Each of the various issues addressed in this testimony tells within a specific FEMA Exercise Objective.
A. Implementation of Protective Actions for Impacted Populations l
MAG EX-2, Basis E alleges that the NHY Cffsite Response Organization (ORO) did not atterpt to demonstrate that it could muster the appropriate vehicles and personnel for the 1
~22-l l
3(/} j timely and proper evacuation of patients from EPZ hospitals, nursing homes, and other special facilities. It also alleges that the Exercise failed to test the preparedness of the bus, ambulance, and wheelchair van companies for the evacuation of patients.
- 1. FEMA Exercise Objective MAG-EX-2, Basis E alleges issues that pertain to TEMA Exercise Objective No. 18 which states:
" Demonstrate the ability and resources necessary to implement protective actions for the impacted permanent and transient plume EPZ population (including transit-dependent persons, special needs populations, handicapped persons and institutionalized persons.)"
Exercising the process of implementing protective actions for special populations for the SPMC is comprised of 1[~'h several components. There components include: i U a. Proper decisionmaking regarding the need for protective actions for special populations and conveying that decision.in a timely and effective manner to appropriate personnel;
- b. Demonstrating notification.of special facilities by /
either communications with actuel part.icipating facilities or with a NHY control cell simulating non-participating facilities;
- c. Notifying all transportation providers;
- d. Allocating, assigning, and deploying simulated l
l
/" -23 (s_-
t
transportation resources in accordance with the needs ,
determined by the scenario; and
- e. demonstrating this process in the field by the l
processing and dispatching of a number of actual vehicles to designated special facilities as dictated by the extent of play.
- 2. Influences The extent of play for this objective was influenced principally by FEFA guidance. The FEMA Memorandum, dated May 19, 1988 (Attachment C hereto) provided guidance with respect l to the proper evaluation of the availability and training of bus drivers and the availability of buses. The FEFA Memorandum noted that the focus of this issue is pre-exercise evaluation of the availability of buses and training of bus drivers. The Memorandum said further that such an evaluation can be accomplished by examining the training component of the organiza*. ion's emergency plent, examining lette:S of agreement (LOA) for buses and bus drivers and by making telephone calls to LOA providers to confirc capability to provide specified resources.
The extent of play was further influenced by tne fact that providing transportation is a routir e function of the c
resource providers. The purpose of the Exercise is to test portions of the plan that are specific to a radiological l
l )
i
3
',ll I
1 I
- )#
response, Land not to demonstrate repeatedly the normal
'(
functions of these supporting. companies'and organizations. l
}
The failure of many.special facilities in the Massachusetts EPZ communities to participate'in the Exercise 1
.)"
influenced the-degree to which actual notifications and' contacts with the facilities could be demonstrated and the extent to which reliance was placed'en the:NHY-Control Cell <
for simulation of this activity. The matrix at Attachment E hereto indicates that 1 of 37 special facilities contacted in the Massachusetts EPZ' communities agreed to participate.
- 3. Extent of Play Participants in the developnient of the extent of play for the Exercise detarrined that the ability to implement protective actions would be demonstrated by performing the
[/')
M.
'following functions:
- the protective action decisionmaking process;
- the initial notification of all companies providing special trans portation resources;
- notification of special facilities by contact with participating facilities or by simulated contact of
- non-participating facilities by calls to the NHY Control Cell;
- the assignment of transportation resources to meet the identified requirements; and
~25-l
. _ _ _ _ - - _ _ _ _ _ _ _ _ _ . .. l
+
the extension of that process into the field by the l
i deployment of a representation of resources.
As stated in Section II supra, the extension of this process into the field serves the purpose of testing the ability to implement the plans and procedures. Since the extension of this process into t"e field can be adequately demonstrated with a limited not r of public safety resources, NHY, with FEMA's concurrence, contracted for the services of four (4) special vehicles to be deployed by the ORO during the Exercise. These vehicles consisted of three (3) wheelchair vans and one (1) ambulance. One additional ambulance was contracted to demonstrate MS-1 capability on Day 2 of the Exercice.
The demonstration of transport capabilities by these resources was sufficient because (a) the use of more vans and ambulances.during the E.cercise would expand only marginally an. isolated component of a major observable element of the RERP, and (b) the addition to the number of FEMA evaluators to observe and further assess this function would have reduced the number of evaluators assigned elsewhere to evaluate other important functional areas of the Exercise.
In order to assess the preparedness of transportation resource providers relied upon for implementation of the SPMC, FEMA, during its evaluation of the SPMC, conducted an survey of transportation resource providers documented in L i e i-
.f%
letter from Richard W. Donovan, RAC Chairman for Seabrook Station, to George R. Gram of New Hampshire Yankee dated October 21, 1988. This letter, and attachDd survey, is-l Attachment H hereto. .The survey included information on' the type and quantity of manned vehicles, vehicle capacities, mobilization and dispatch information and estimated response times. Based ' on this survey, L FEMA determined that the transportation resources relied upon for implementation of=
the SPMC do exist and are adequate. Therefore, the survey results provided further information that FEMA considered in assessing the preparedness of these transportation resource-l
' providers in conjunction with the assessment of the adequacy of the SPMC.
- 4. Exercise Demonstration
- a. Notification, Assignment, and Deployment of Resources
-Dur.ing.the Exercise, the capability of the NHY ORO to coordinate.and integrate with the ambulance and van' functions-was demonstrated. As a result of the declaration of an l ALERT, ORO personnel initially contacted all bus, wheelchair van and ambulance companios under agreement with NHY for resource support during an emergency at Seabrook Station to determine available transportation resources. Concurrent with the notification process, Special Population Liaisons contacted participating special facilities or, in the l ,
J.
alternative, made simulated contact of non-participating l special facilities by calling the NHY Control Cell to determine their specific transportation requirements at the time of the event. Transportation resources were assigned accordingly. Special vehicle dispatch personnel at the ORO Staging Area filled out dispatch forms fer all of the assignments for special vehicles included in Appendix M of the SPMC for the entire Massachusetts portion of the 10-mile EPZ. Thus, the major functional elements af the plan pertaining to the notification, allocation and deployment of transportation resources for special needs populations were demonstrated, l
- b. Field Demonstration of Wheelchair Vans Three (3) wheelchair vans were mobilized to the ORO Staging Area. At the Staging Area, they received assignments (previously selected with FEMA) to evacuate patients from special care facilities (two nursing homes and one elderly housing unit). Upon completing the transport of simulated patients to Reception Centers for monitoring and subsequently to host facilities, the NHY Controller directed the drivers a of the vans to proceed back to the ORO Staging Area for l
further assignments,
- c. Field Demonstration of Ambulances The Exercise demonstrated one ambulance assignment to support evacuation for special populations in Massachusetts.
l )
L. {1
. /~'i
.i I The ambulance was dispatched to the ORO Staging Area V
where an assignment was received to evacuate a patient from Amesbury Hospital and transport that patient to the host facility, Deaconess Hospital. After completion of this assignment the ambulance was directed te return to the Salem ORO Staging Area where it was released from exercise participation.
B. Transporting Contaminated Injured Individuals MAG EX-21, Basis B alleges that the scope of the Exercise was insufficient because only one of the ambulances relied on by the NHY ORO to transport contaminated injured persons was tested.
- 1. FEMA Exercise Objective Contention MAG-EX-21, Basis B alleges issues that pertain to FEMA Exercise Objective No. 23 which states:
" Demonstrate the adequacy of vehicles, equipment, procedures and personnel for transporting contaminated, injured or exposee. individuals.."
Demonstration of this Exercise objective involved the process required for properly handling, transporting and treating a contaminated, injured individual. This process involves the following components:
- a. The participation of an ambula.nce crew to properly attend to the individual's injury and to. implement appropriate precautions for the control of the spread of contamination during transport.
[~N \~-]
.1 i
- b. The proper handling, monitoring, treating and decontaminating of the injured individual and the implementation of precautions to control contamination by the receiving hospital.
- 2. Influences The extent of play for this objective was influenced j i
principally by FEMA guidance. The FEMA guidance on this issue is provided in a February 9, 1988 memorandum regarding the " Clarification of Selected Provisions of Guidance Memorandum (GM) MS-1, Medical Services" from Richard Krimm, l
l Assistant Associate Director of FEMA's Office of Natural and l Technological Hazards, to the NTH Division Chiefs of all FEMA Regions (Attachment B hereto). The guidance states:
"A simulated contaminated individual, either from onsite or offsite areas, will be transported to each activated medical facility."
Or The transport of one simulated contaminated injured
)
individual is consistent with this clarification memorandum.
i The need to limit the involvement of public safety resources, such as additional ambulances, the abi:lty of the assigned FEMA evaluator to obseive each of the medical aspects of the !
Exercise, and the impact on the resources of the MS-1 hospital during a non-emergency situation were further i
influences. In addition, ambulance personnel of anbulance companies under contract to NHY receive the same training in
emergency medical care and handling individuals who are contaminated.
- 3. Extent of Play The purpose of the Exercise objective was to demonstrate that the training and processes employed for transporting and handling contaminated, injured individuals are correct and capable of being implemented. Extent of play negotiations determined that one ambulance and ambulance crew would be sufficient for this purpose and in accordance with FEMA guidance. The extent of play for this Exercise objective is provided in Section 3.2.14 of Applicants' Exhibit 61.
- 4. Exercise Demonstration Transport of a contaminated, injured individual was demonstrated by the ORO on the second day of the Exercise out-of-sequence with the scenario time line. To demonstrate this capability, an accident was simulated where a victim was injured and potentially contaminated. ORO ambulance personnel demonstrated precedures t o implement precautions for controlling the spread of contamination and to provide transport to an MS-1 hospital where the victim would te treated for injuries and decontaminated if necessary. The demonstration of this aspect of the plan included the proper handling of the individual simulated to be injured and contaminated and the use of the appropriate equipment by the ambulance and MS-1 hospital personnel.
C. Environmental Sampling i
! SAPL EX-4 alleges that only two (2) State of New Hampshire sampling teams were utilized during the Exercise and, therefore, sample collection and transport were not adequately demonstrated.
- 1. FEMA Exercise Objective SAPL EX-4 raises issues that pertain to FEMA Exercise Objective No. 27 which states:
" Demonstrate the appropriate use of equipment and procedures for collection and transport of samples of vegetation, food, crops, milk, meat, poultry, water and animal feeds (indigenous to the area and stored)."
Components associated with this objective include:
- a. Briefing and dispatching sampling teams to sampling locations with the appropriate equipment to collect samples;
- b. Demonstrating proper sampling techniques and logging of information; and
- c. Transporting collected samples to the proper locations for analysis.
- 2. Influences The NHREPP contemplates the use of up to three two-man environmental sampling teams to collect and transport various samples. All environmental sampling personnel receive identical training. During the development of the extent of play portion of the Exercise scenario, representatives of the >
New Hampshire Division of Public Health Services (NHDPHS) f
./ m
( ') requested the participation of two sampling teams on Day 2 of
\m./
the' Exercise in order to limit the impact on normal state agency operations. Further, NHDPHS had previously-demonstrated the deployment'of six environmental sampling teams for.a FEMA evaluated ingestion pathway exercise in December, 1987,-six months prior to the Seabrook Exercise.
FEMA agreed that two teams would be sufficient to demonstrate sampling on Day 2 of the Exercise.
- 3. Extent of Play The extent of play as provided in Section 3.3.20 of Applicants' Exhibit 61 reflects the proposed use of two environmental sampling teams to demonstrate sampling equipment and procedures as a result of the NHDPHS request
(N discussed above. The-purpose of the Exercise objective was to demonstrate that equipment and procedures are adequate'for the propor col?ection and transport of environmental samples and that the training provided to sample collection. teams is adequate to ensure proper utilization of equipnent and procedures. Two sample collection teams are sufficient for I
this purpose,-because equipment, procedures and training for i i
all sample collection teams designated in the NHRERP for Seabrook Station are the same. The NHDPHS sampling tears are experienced and trained in sampling equipment, techniques, and procedures.
/ !
1
-_-_L:__---_____---_-______--____.____.___-_--_ . _ _ - _ - _ __ - _ _ _ _ _ _ . _ _ _ _ _ _ _ _ - _ _ _ _ _ _______-_____-________-___3
l l
l I
- 4. Exercise Demonstration On Day 2 of the Exercise, two environmental sampling teams (four persons) were dispatched from Concord, N.H. to the NH IFO, co-located with the NHY EOF, in Newington, N.H.
i From there, the environmental sampling teams were dispatched !
to sampling locations in the field by NH accident assessment personnel. In the field, the two teams demonstrated the procedures for collecting environmental samples, collected i.
examples of environmental samples, and demonstrated l procedures for labeling, logging, and delivering the samples for analysis.
D. Implementation of Traffic Control SAPL EX-6 and TOH/NECNP EX-1, Basis d, allege that ,
Traffic Control Points and Access Control Points staffed by New Hampshire State Police and local law enforcement officers were too few in number to demonstrate adequately all that is i
necessary to provide traffic and access control functions in the New Hampshire portion of the 10-mile EPZ cr to support l I i FEMA's conclusion that the State and local police had i adequately shown the capability to deploy the required number 1 of officers.
1
- 1. FEMA Exercise Objective f l Contentions SAPL EX-6 and NECNP EX-1, Basis d raise l
issues pertaining to FEKA Exercise Objective No. 20 which states:
l l
d 1
m.
\L
.;-s
! h' _
f( ,/l " Demonstrate the organizational' ability and resources necessary to control evacuation traffic flow and to control access to evacuated and sheltered areas."
The process'of implementing traffic and access control' in New Hampshire is comprised of several components including proper notification, coordination, assessment, assignment and field deployment of personnel and resources.
- 2. Influences The process of directing traffic and controlling access is a normal day-to-day function of the law enforcement organizations involved in the Exercise. Similarly, the ability to use radio communications, dispatch personnel, locate various' intersections, and direct and control traffic are routine law enforcement activities that'these personnel p\ . are trained to perform on a regular basis,
[b Traffic control personnel in New Hampshire receive identical training. The extent of deployment of police personnel into the field during phe Exercise necessarily considered the irract on normal state and local law enforcement operations in a non-emergency situation.
- 3. Extent of Play
. The extent of play for this major observable portion of the NHRERP is provided in Section 3.3.9 of Applicants' Exhibit 61. The organizational ability an,d identification of resources necessary to implement traffic and access control !
functions were to be demonstrated. This d' demonstration was to l
l
\m
J 4 l
4 include notification, coordination, assessment, assignment and field deployment of personnel and resources. The influences discussed above resulted in the allocation of four New Hampshire State Police Troopers and one local police officer in each of the 11 participating New Hampshire EPZ communities having traffic control responsibilities to demonstrate traffic or access control functions in the field.
The purpose of the field deployment was to extend demonstration of organizational ability into the field and to demonstrate the adequacy of procedures and training for field personnel. As the procedures and training are the same for all field personnel, the number of officers to be deployed was sufficient to attain this objective.
- 4. Exercise Demonstration l
- a. Notification and Coordination with Law l Enforcement Organizations During the Exercise, notification and coordination l functions vere demonstrated. This demonstration showed that .
the various law enforcement organizations could properly notify, assess and assign resources in ruppcrt of protective action recommendations. NHRERP procedures lor this function were demonstrated.
- b. Assessment, Assignment and field Deployment of Police Resources The actual field implementation aspects of traffic and access control functions were demonstrated by at least one
( ,)
i I
police officer for each of the eleven participating New Hampshire communities with traffic control responsibilities and four State Troopers. (In several instances, local communities deployed more than one police officer into the field resulting in the field participation of a total of sixteen local officers.) The use of additional police personnel to test these functions was neither required nor appropriate. Consistent with the NHRERP, Volume 4B, State Police Communications section, a State Police EOC Liaison was notified to report to the NH Emergency Operations Center (EOC) . located in Concord at the ALERT emergency classification level. This State Police representative serves as the coordination point between the State of New (n\/
\m Hampshire emergency response organization and State Police operations. One of the actions the State Police EOC Liaison at the State EOC perforns is to establish communications with l State Police Headquarters in Concord.
l In order to assess State Police personnel resource availability, the State Police EOC Liaison requested State Police Headquarters to transmit a copy of the daily trooper
. roster. This roster included information regarding on-shift
)
police personnel duty locations throughout the State for that I specific day. Additionally, this roster included information with respect to off-duty personnel, e.g. State Troopers off-shift, on vacation, or on sick leave. j l
l (V
1
._..___,_._._.m. _ _ _ _ _ . _ . _ _ _ _ _ _ _ _ _
During the Exercise, the State Police Troop A IFO Representative at the New Hampshire Incident Field Office (IFO) utilized information in coordination with the State Police EOC Liaison to make priorities and assignments of actual personnel. In an actual emergency, these personnel would be dispatched to Troop A headquarters from various State Police barracks throughout the state. At Troop A headquarters, they would receive dosimetry and field assignments and be dispatched into the field. The actual assignment of available State Police personnel resources as they were on the day of the Exercise provided the basis for a determination that the New Hampshire State Police had demonstrated the capability to deploy sufficient State Police Troopers for implementation of access and traffic control functions. Exercise controller messages identified the specific Access Control and Traffic Control Point assignments to be demonstrated in the field and their respective activation times.
Similar actions were taken on the local level by personnel in participating municipalities which have the responsibility for traffic control functions. That is, local resources were determined and then at least one local officer from each of these municipalities demonstrated field implementation.
i I
__ I
1 1
( ) Provisions.for the distribution of traffic control equipnent were also demonstrated. During the Exercise, in 3 addition to the twenty (20) . State and local police officers demons'trating access ' and traf fic control, . four (4) State and seven (7) local support personnel were.also deployed to demonstrate distribution of equipment.
- c. Demonstration of Traffic Control in Hampton Intervenor's specific assertion that personnel from the Town of Hampton.did not staff any traffic control location is correct. 'As the Town of Hampton did not participate in the
-Exercise, traffic control responsibilities for the town fell
~ to the New Hampshire State Police. New Hampshire State Police, in conjunction with the State Department of
,f\
() Transportation, demonstrated traffic control at TCP D-HA-01, I located in the Town of Hampton at the intersection of High -
-Street and Lafayette Road (See Applicants' Exhibit 61 at Section 3.3.9).
E. Monitoring and Decontamination for Emergency Workers; Disposal of Decontamination Center Wastes SAPL EX-7 alleges that the exercise of the NHRERP failed to demonstrate the capability to provide for the decontamination of emergency workers, equipment and facilities because the Hillside Junior High School in Manchester was not opened and demonstrated during the Exercise. Furthermore, interveners assert that there was no
[ (
F
lL showing of adequate provisions for the disposal of contaminated wastes. I
- 1. - FEMA Exercise Objective SAPL Contention EX-7 raises issues that pertain to FEMA Exercise Objective No. 25 which states:
" Demonstrate the adequacy of the facilities, equipment, supplies, procedures and personnel for decontamination of emergency workers, equipment and vehicles and for waste disposal."
i The process of assessing the adequacy of the capability ;
to provide decontamination of emergency workers is comprised of several components. These include monitoring and decor.tamination processes, the identification and handling of contaminated materials and vehicles, and the adequacy of the facility layout, its operation and its equipment and supplies.
- 2. Influences The NHRERP contemplates the use of four host communities. Due to resource considerations and the j potential impact to the normal operations of the New Hampshire Department of Health and Human Services and the New Hampshire Division of Public Health Services, it was agreed that not all communities would activate and operate their respective reception / decontamination centers. This decision was influenced by the fact that the training and operating 1
1 i
i
) procedures of the NHRERP for all monitoring / decontamination
- s. -
- l activities are identical in technical content.
1 I
- 3. Extent of Play !
Monitoring and decontamination activities for emergency workers were to be demonstrated at activated Reception / l Decontamination Centers as discussed in Section 3.3.19 of Applicants' Exhibit 61. Emergency workers were to be directed to report to one of the activated Recop' ion / Decontamination facilities for evacuees to be monitored after the completion of their assignment. This demonstration was reasonable because the procedures for monitoring and decontaminating both members of the public and emergency workers are identical. Furthermore, identical
,/T training is provided to emergency response organization
\
] members who staff the monitoring and decontamination functions for Reception Centers and for the Emergency Worker Decontamination facility. The demonstration was to include monitoring and decontamination techniques, the identification, tagging and bagging of contaminated articles, and handling of contaminated vehicles.
Subsequent to the Exercise, it was recognized that FEMA was unable to evaluate ".ne physical adequacy of the Hillside Junior High School to serve in this capacity. An inspection of the facility was conducted by TEMA on July 22, 1988 in r-'N _41-f
t l
order to assess the adequacy of the facility and its supplies, equipment and staffing arrangements.
- 4. Exercise Demonstration
- a. Demonstration of Monitoring and Decontamination Functions for Emergency Workers There is no requirement that each and every emergency response facility participate in an Exercise. On the day of the Exercise, the Hillside Junior High School, which serves as a secondary Reception / Decontamination facility for the i
host community of Manchester and as the Emergency Worker i Decontamination facility, was not demonstrated. Monitoring and docentamination activities for emergency workers were demonstrated at the activated Reception / Decontamination facilities in the host communities of Salem and Dover.
- b. Evaluation of the Emergency Worker
, Facility l
In order to assess the adequacy of the emergency worker facility and its associated supplies, equipment and staf fing, representatives of FEMA inspected the Hillside Junior High School. This inspection was conducted on July 22, 1988 and included observation by a representative of the Joint
~
- Inte rvenors . The facility, its operational layout, I
l procedures, staffing, equipment and supplies were assessed in conjunction witr FEMA's Exercise evaluation and found to be 1
j i i l l
, l
v > >
. /%
kj ~ adequate. (FEMA Exercise Report, Applicants Exhibit-43F,
.page 199 of 428).
- c. Disposal of Wastes Generated at Monitoring and Decontamination Facilities The'NHRERP contemplates the identification and decontamination or retention of. contaminated materials such as vehicles and other personal effects. During the Exercise,-
clothing and personal effects simulated to be. contaminated were removed, inventoried, bagged, tagged and stored in a secure place (see FEMA. Exercise Report, Applicants' Exhibit.43F, page 192 of 428). Parking areas for contaminated vehicles were also identified and utilized.
With respect to the ultimate disposal of contaminated f-4 wastes, the Exercise did not include a physical demonstration
\s_/ -of this isolated portion of those elements of the NHRERP-concerning radiological monitoring and decontamination. The ultimate disposition of contaminated wastes is considered to be a post-emergency response functioniwhich results from
. decontamination activities and, as such, is included as part of a recovery action plan developed at the later stages, or end, of an. actual emergency response pursuant to recovery procedures. Accordingly, at 1400 on Day 2 of the Exercise, NH State EOC officials discussed the matter of
' decontamination waste materials and contaminated vehicles. .j At 1452, they requested assistance from New Hampshire Yankee
-s i l
l i
t i
for removal of decontamination wastes in accordance with the existing agreement for this purpose. Subsequently on Day 2, NH State EOC officials developed a long-term sampling and recovery plan that included provisions for periodic monitoring of contaminated vehicles held in restricted areas and for disposal of decontamination waste materials by New Hampshire Yankee.
F. Staffing of Emergency Response Facilities SAPL EX-8 alleges that there was no demonstration of 24-hour continuous staffing of the New Hampshire Staging Areas and Reception Centers and that continuous staffing of local and host EOCs was not shown to be adequate. Furthermore, interveners assert that key positions in the NH IFO were not fully staffed, there were no provisions employed for filling vacant positions, and the Governor's office was not properly represented.
I
- 1. FEMA Exercise Objective !
SAPL Contention EX-8 raises issues that pertain to FEMA Exercise Objective Nos. 2 and 34 which respectively state:
" Demonstrate the ability to fully alert, mobilize and activate personnel for both facility and field-based emergency functions."
" Demonstrate the ability to maintain staffing on a continuous 24-hour basis by an actual shift change."
The demonstration of staffing levels at emergency response facilities and the demonstration of continuous
, I
>I r *
' p-4: \
s,, staf fing 'suf ficient to provide for an adequate emergency.
response'is comprised of the following components:
- a. The. notification and mobilization of emergency response organization members,
- b. The manning and activation of emergency response facilities,
- c. . The. demonstration of a continuous operation capability.
.d. The demonstration of.the briefing of incoming replacement staff.
- 2. Influences The ability to demonstrate staffing of emergency response organizations in the State of New Hampshire was r
i affected by the need to avoid impairing or closing down
\
normal l state and local agency operations in a non-emergency situation. It was further affected by limitations on individual participants imposed by their normal public duties and other pre-existing commitments.
- 3. Extent of play Staffing levels to be demonstrated at New Hampshire response facilities were established by the extent of play and were intended to demonstrate reasonable assurance that an adequate response capability would be provided in the event of a real emergency. Mobilization and staffing of emergency
l response facilities as contemplated in the NHRERP was demonstrated during the exercise. ,
The Exercise was to include a demonstration of an extended operations capability though a combination of the physical changeout of personnel and the presentation of personnel rosters for select emergency response facilities.
- 4. Exercise Demonstration
- a. Facility Staffing Approximately 575 responders in the New Hampshire organizations participated in the Exercise. This was a significant number of participants for a demonstration of an ir.tegrated emergency response capability during a non-emergency situation. Generally, full response facility activation was demonstrated within approximately one hour of the initial notification of an ALERT classification. See FEMA Exercise Report, Applicants' Exhibit 43F (hereinafter Exercise Report), page 146 of 428.
Due to the various pre-existing commitments and the non-emergency nature of the Exercise, several participants could )
J not or did not report to their emergency response facility i l
assignments. For example, the Town of Seabrook staffing of j i
the local EOC was observed to be not in accordance with the I Seabrook RERP (Volume 16 of the NHRERP) . FEMA noted in the Exercise Report that:
L -
'" Specific staff could not be present due to prior
'> engagements: The Fire Chief and school Principal' were out of town; the Health officer had a court appearance;.and other persons (Road Agent, Water Superintendent, and. Town. Clerk) could not leave their. offices. It was noted that the personnel-present'in the EOC assumed multiple duties.and that the telephone contact was maintained with those individuals who were at work. We also noted'that the Building / Health officers arrived.at the EOC-after his court duties." Exercise Report at page 148 of 428.
Response facilities and positions ~were, however, adequately staffed to demonstrate the appropriate response to events dictated by the Exercise scenario. While there may have been personnel shortages in isolated areas r" the overall response organization, these' absences did not impact the organizational ability to= implement the assigned response f-~ functions. Shift changes for key staff positions were k_ k . demonstrated in all but two of the eleven participating local thew Hampshire EOCs. In the NH State IFO, three of the nine Local Liaison Officers were not replaced on the second shift.
The Exercise Report, at page 207 of 428, indicates that the plan specifies a maximum of nine Local Liaison officers if all seventeen commur.aties do not participate. Eleven EPZ communities in New Hampshire participated in the Exercise..
The Exercise Report, at page 207 of 428, indicates that, on the second shift, the Local Liaison officer Functions were handled with six Local Liaison officers. Thus, the Exercise provided a test of the organizational ability to perform N'
l 1
l I
response functions, ensuring that the emergency plans and procedures are flexible and adaptable to meet both expected and unexpected circumstances.
Host facilities also were sufficiently staffed and operational in a timely manner. This includes demonstrated host community EOCs and Reception Centers. The Exercise demonstrated the ability to alert, mobilize and activate personnel necessary for facility functions. See Applicants' Rebuttal Testimony No. 25 (New Hampshire Exercise Performance) for a description of staffing represented at the demonstrated host community EOCs. On May 23c 1988, FEMA conducted an inspection and review of personnel rosters compiled in support of the NHRERP.
- b. Second Shift Staffing Although second shift staffing of transportation staging areas was not part of the extent of play, the State Transportation Staging Area Supervisor presented rosters to FEMA evaluators showing sufficient personnel for protracted staffing of positions and explained arrangements that would be made for protracted staffing. The same method was utilized to demonstrate protracted staffing capability at Reception Centers.
The Exercise of NHRERP included a demonstration of a second shift capability through a combination of the physical i
change out of personnel and the presentation of personnel
-4E-l E___ _ _ _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ - . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
i I
4.
. rosters.- In this way, FEMA Exercise Objective #34 was met.
See E<ercise Report at pages 206-208 of 428.
- c. Representation of the Governor's Office The Exercise Report at page 146 of 428 states that
"[t]he Governor's office was not represented according to the Plan'." This statement refers specifically to the provision of the NHRERP that briefing the press is a non-delegable duty for the Governor. During the Exercise, tn New Hampshire Public Information Officer provided briefings to the press.
The applicable language in the NHRERP was revised in the October 1988 amendment of the plan to make press briefings a delegable responsibility.
G. Implementation of Protective Actions for School ~
op-~ Populations 1
' \m. TOH/NECNP EX-1,- Bases a and b, allege that the June 28-29, 1988-Exercise of the New Hampshire Radiological Emergency Response Plan for Seabrook Station failed to meet a primary objective because the availability and participation of school teachers relied upon under the NHRERP was not demonstrated. It further asserts that this lack of participation by teachers resulted in FEMA's inability to observe an adequate demonstration of the organizational ability of resources necessary to effect an early dismissal, sheltering or evacuation of school children.
/'r %
]
cr~ , -
- 1. FEMA Exercise Objective TOH/NECNP Contention EX-1, Bases a and b, raises issues pertaining to FEMA Exercise Objective No. 19 which states:
" Demonstrate the ability and resources necessary to implement appropriate protective actions for school children within the plume EPZ."
The components associated with demonstration of this l objective are:
l l a. Notification of school administrative personnel of an emergency situation.
i
- b. Communication and coordination between the State of New Hampshire emergency response organization and school administrative personnel.
- c. Provision of transportation resources.
- 2. Extent of Play 1
The process of notification, communication and l
coordination between members of the New Hampshire emergency response organization (state and local) and school superintendents and administrators was to be conducted j l
according to the provisions of the NHRERP. The major i l
1 observable portion of the NHRERP to be demonstrated was the implementation of protective actions for school children. As
! contemplated in the NHRERP, the administrative responsibility I
i i for each s noc1 facility lies with the superintendent of the l
l public School Administrative Units (SAU's) and the administrator cf the individual private schools. The O'
l
. ___ _- O
LJ
.p 1, Superintendent / Administrator is part of the emergency response organization and provides coordination with state .
9 and local emergency response officials. The extent of-play-which governed the demonstration of this aspect of the NHRERP is included in Section 3.3.1 of Applicants' Exhibit 61.
- 3. -Exercise Demonstration
- a. Notification and Coordination of Emergency Information With Schools Notification of and coordination with the SAU's and private schools during the Exercise was provided by NH Department of Education representatives at the State EOC in Concord and by the participating towns and/or the local liaisons at the IFO in Newington. Communications and coordination were demonstrated with at least one O)
(, administrative representative of each of the five SAU's.
FEMA noted in the-Exercise Report that EPZ schools and potential host schools were promptly notified of changes in situation by New Hampshire Department of Education
! representatives. See Exercise Report, page 181 of 428.
- b. Provision of Transportation Assistance to Schools Transportation Requirements for schools were simulated by the Exercise scenario based on default values for schools contained in the NHRERP. These transportation requirements were provided by Exercise controller messages to the local EOC transportation coordinators or to the IFO Local Liaison
[ !
.j-I i
i Officers in the case of schools in non-participating communities. The transportation requirements were communicated to the IFO Resource Coordinator by these personnel in accordance with their procedures. The IFO Resource Coordinator then made assignments from the total vehicle pool indicated by the Exercise scenario to be available at the State Transportation Staging Areas at the Rockingham County Complex and at the Portsmouth Circle Business Center. The IFO Resource Coordinator communicated i these assignments to the State Transportation Staging Areas and directed the deployment of the required number of 1
l vehicles for schools to the local transportation staging areas. The vehicles were directed from the local staging areas to the schools. A representation of vehicles for schools was actually deployed from the transportation staging areas to the schools. These vehicles traversed the bus routes from the transportation staging areas to the schools and then to the appropriate host community reception centers.
l l See Applicants' Rebuttal Testimony No. 25 (New Hampshire Exercise Performance) for a description of the extent and results of the demonstration of transportation resources for schools.
- c. Teacher participation Within each SAU and private school, there is an internal emergency operations precedure. Under these procedures,
-u-g
.j --
Oj
\ superintendents / administrators receive notification and
. protective action. recommendations from state and/or local 'l emergency response officials and coordinate the implementation of the appropriate actions, including the provision of transportation resources, with the individual school facilities under their jurisdiction.
The administrative structure, therefore, provides that a decision regarding school protective actions is made by the superintendent or facility administrator,who, in turn, directs its implementation. In this context, the implementation of an administrator's decision by teachers does not require unusual or extraordinary skill. The actions required are consistent with those that would be taken, at
[ the direction of administrators, for other emergency related
'u) ' situations such as early dismissal during a winter storm, sheltering during a power outage, or evacuation demonstrated during a fire drill.
Teachers are " relied upon" in the NHRERP during implementation of school protective actions only to the extent that they are expected to carry out their professional
. responsibilities to supervise students under their jurisdiction during any type of emergency situation. As such, teachers are expected to take direction from their administrative supervisors and to provide. direction and control of their students. The purpose of the Exercise
objective was accomplished by the participation of 4 representatives of the New Hampshire Department of Education and of each of the affected School Administrative Units and by demonstration of transportation resources for schools.
H. Implementation of protective Actions for Impacted populations in New Hampshire SAPL EX-13 alleges that there was no test of the capability to transport hospital and nursing home patients to host facilities by ambulance and an insufficient test of evacuation bed bus capability in that only two mini-scenarios 1
were conducted for this purpose during the New Hampshire portion of the Exercise. It further alleges that there was no test of: (1) the ability to make decisions regarding the administration of KI to institutional populations; and (2) the capability of host facilities to receive, monitor and decontaminate patients. TOH/NECNP EX-1, Basis f asserts that insufficient regular buses (18 of 453), special ne'eds buses (2 of 71) and ambulances (1 of 48) were demonstrated; Basis g asserts there was no demonstration of actual availability of transportation resources.
- 1. FEMA Exercise Objective Contentions SAPL EX-13 and TOH/NECNP Ex-1, Bases f and g, allege issues that pertain to FEMA Exercise Objective No.
18 which states:
" Demonstrate the ability and resources necessary to implement protective actions for the impacted b permanent and transient plume EPZ population (including transit-dependent persons, special needs populations, handicapped persons and institutionalized persons.")
The exercise components associated with this objective are explained in Section III.A.l. supra.
SAPL Contention EX-13 also raises issues that pertain to FEMA Exercise Objective No. 16 which states:
" Demonstrate the ability to make the decision to recommend the use of KI to emergene' workers and institutionalized persons, based or predetermined criteria, as well as to distribute and administer it once the decision is made, if necessitated by radiciodine releases."
- 2. Influences The FEMA Memorandum, dated May 19, 1988 (Attachment C hereto) provided guidance with respect to the proper evaluation of the availability and training of bus drivers and the availability of buses. The FEMA Memorandum noted that the focus of this issue is pre-exercise evaluation of the availability of buses and training of bus drivers. The Memorandum said further that such an evaluation can be accomplished by examining the training component of the organization's emergency plans, examining letters of agreement (LOA) for buses and bus drivers and by making telephone calls to LOA providers to confirm capability to provide specified resources.
FEMA findings fro- the previou.3 1986 exercise further influence the extent cf play. Other external influences
I affecting the extent of play for Exercise Objective No. 18 are described in Section III.A.2. supra. None affected the demonstration of Exercise Objective No. 16.
e 3. Extent of Play The decisionmaking process associated with providing transportation resources for special populations was to be demonstrated by the State of New Hampshire emergency response organization. Notification of special facilities was to be I demonstrated with participating facilities and simulated for 1
non-participating facilities by Exercise participants calling into a NHY Control Cell. Vehicle providers were initially contacted, and transportation resources were assigned in accordance with the requirements determined by contact with special facilities. Field demonstrations of transportation resources were conducted to allow for the observation and evaluation of one or more events by any one FEMA evaluator.
For example, most of the actual buses run during the Exercise ran multiple routes, allowing the associated FEMA evaluators to observe more than one route.
It was determined by the organizational representatives
, during the development of the extent of play portion of the Exercise scenario that the simulated deployment and dispatch l
l of these evacuation vehicles would be sufficient to support the demonstration of the transport and evacuation capability i
7w 7% of special facility and special needs populations in New Hampshire for the following reasons:
(1) The primary objective of the Exercise scenario was to test the sufficiency of the coordination and integration of the various personnel (State and local) and resources needed to evacuate special populations pursuant to the NHRERP. A main focus.of this portion of the Exercise was to test information flows, decisionmaking functions and coordination aspects of the entire process and ascertain whether communications, maps, and other processes would be sufficient to implement protective actions. As indicated in the Exercise Report, page 173 of 428, these plan processes
'were sufficient to mobilize'more than enough transportation
[ \ . resources to meet demand.
(2) The actual process of transporting persons to and from hospitals, nursing homes, or other special care facilities is a normal day-to-day routine of the wheelchair van and ambulance company personnel who would report to the State TSAs. Accordingly, the ability to drive to various locations, to lead and unload patients, and to transport special care persons properly are functions that these companies and drivers demonstrate daily.
The extent of play for demonstrating the State of New Hampshire's ability to provide transportation resources to O N,,s
[
] evacuate special populations is described in Sections 3.3.7 and 3.3.8 of Applicants' Exhibit 61. i l
- 4. Exercise Demonstration
- a. Transportation Resources for Special Populations During the Exercise, the process of providing transportation assistance for special populations was demonstrated by a range of actions. They were:
(1) Procedures were implemented at the NH State EOC by the EOC Resources Coordinator, the Pupil Transportation Safety representative, and the Bureau of Emergency Medical Services to contact transportation resource providers.
(2) Special facilities (nursing homes and hospitals) were contacted at least once, in accordance with the extent of play, by either a Local Liaison Officer in the IFO or a local emergency response official in participating communities to demonstrate the ability to notify these facilities and to determine their transportation requirements .
(3) The results of the actions described in item (2) above were relayed to the IFO Resources Coordinator who assigned the appropriate transportation resources to the participating local communities or to the individual special facilities in non-participating connunities.
5c_
e (k) (4)' Buses for traversing bus routes for transit l: dependent persons were assigned to local communities in accordance with the numbers allocated in the NHRERP.
(5) Twenty buses, 1 wheelchair van, and 1 ambulance were deployed from transportation resource providers to State Transportation Staging Areas at the Rockingham County Complex-and the Portsmouth Circle Business Center according to the provisions of the NHRERP. This deployment occurred at the SITE AREA EMERGENCY classification in accordance with the
. plan.
Vehicles for special populations were dispatched from the State Transportation Staging Areas to the local communities and to.special facilities, and subsequently
~
proceeded to either host community reception centers or to q
host facilities.
After transportation resources were identified and mobilized, and assigned on the basis of identified requirements, the demonstration was extended to the field by the actual deployment of vehicles from the State Transportation Staging Areas for special populations and for i
traversing transit dependent bus routes in the local communities. This deployment included. eighteen buses for various bus routes, two buses for conversion to evacuation bed buses, one wheelchair van, and one ambulance.
The wheelchair van was dispatched to the Town of Seabrook local Staging Area. From there, the van simulated the pick-up of a handicapped person from the Pine Street Trailer Park and then continued on to the Salem Reception Center. The two conversion bed buses were dispatched to nursing homes for transport of evacuees to host health care facilities. These nursing homes (where conversion beds were installed on the bus) were the Eventide Nursing Home in Exeter and the Edgewood Center in Portsmouth (where patient loading was demonstrated by the use of a mannequin). Both conversion bed buses completed the routes from the nursing j homes to their respective host facilities. '
The one artulance and crew that was mobilized by the .
State EOC Resources Coordinator was directed to the State Transportation Staging Area at the Rockingham County Complex in Brentwood. There, the ambulance crew was issued dosimetry and instructions. The TSA Ambulance Coordinator assigned the arbulance to the Hampton Local Staging Area. Upon answering questions posed by FEMA evaluators, the ambulance crew was released from participation in the Exercise.
Sixty-six of the total of 77 bus routes (86 percent) for special populations in the New Hampshire portion of the EPZ were demonstrated. Applicants' Rebuttal Testimony No. 25 (New Hampshire Exercise Performance) explains the results of this demonstration.
l
i i
/"
/ i s
') b. Ability of Host Facilities to Receive Special Facility Evacuees Vehicles which demonstrated evacuation routes for i
special facilities on Day 1 and Day 2 of the Exercise
{
l completed the routes from the special facilities to the I designated host facilities. On Day 1 of the Exercise, two 1
evacuation bed buses traversed routes from two EPZ nursing homes to the host facilities of these nursing homes. The actual receipt of special facility evacuees by the host facilities was not demonstrated. These host facilities are hospitals and nursing homes which receive hospital patients and nursing home residents daily.
- c. Radiological Monitoring of Special Facility Evacuees
/m
( ') The personnel assigned this function under the NHRERP
'~'
are equipped and trained according to the procedures currently contained in the NHRERP for radiological monitoring at reception centers. The monitoring equipment and procedures were demonstrated at two reception centers during the Exercise. Applicants' Rebuttal Testimony No. 25 (New Hampshire Exercise Performance) describes the results of this demonstration.
- d. KI Decisionmaking With respect te the decisionmaking process associated l
with the adminstration of potassium iodide (KI) to institutionalized persens, as delineated in the NHRERP,
./~'N b L___--_-__--_-_-_--__---. _ - . - - - _ . _ - _ - - - - - --- - - - -_----- - -
l Volume 1, 9 2.7.3, Thyroid Protection, the Director of DPHS located at the State EOC in Concord is responsible for making recommendations on the use of KI as a thyroid blocking agent for the public and emergency workers pursuant to the nature of the emergency situation. I (1) Extent of. Play The Exercise scenario required demonstration of two functional areas regarding the administration of KI:
(a) That adequate and timely information regarding the emergency and the evacuation process is coordinated with and communicated to DPHS personnel responsible for making KI decisions.
(b) The DPHS Procedures for the authorization and administration of KI to affected persons in a specific area of concern can be properly implemented.
(2) Influences Affected persons who might be administered KI within a defined area of concern are emergency workers and institutionalized persons that cannot be evacuated for physical or medical reasons. The guidance and instructions
, for the State decisionmaking process for the administration of KI to these potentially affected persons are identical (Appendix K to the DPHS Procedures, NHRERP Vol. 4A). In either the case of emergency workers or institutionalized persons, the decision to administer KI is based on a I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ 1
/~N- i f}.s_ ).- calculation of the projected thyroid dose using the KI I l
Worksheet-in Appendix K. '
(3) Exercise Demonstration During the Exercise, DPHS personnel responsible for .
l recommending.the use of KI recommended its use for emergency.
workers in municipalities located within two (2) miles of the plant. As a result, the direction for emergency workers located.within this area to take KI was given at 1629. -At 1409, over two hours earlier, New Hampshire had recommended the evacuation of towns located within five (5) miles of the plant. The only health care. institution that could have potentially been affected by the KI directive, the Seacoast Health Center in Hampton, had already undertaken to evacuate.
The purpose of this Exercise scenario, in part, was to demonstrate the ability of DPHS personnel to make appropriate decisions for the administration of KI to potentially affected persons based on the available information and the DPHS Procedures in the NHRERP. The information available to the' State decisionmakers was that radiciodines were a concern in towns located within two (2) miles of the plant and that at the time of concern only emergency workers were present in this area due to the evacuation recommendation previously provided to the public. The appropriateness of the KI DPHS Procedures and the DPHS personnel to properly implement them was demonstrated by the decisionmaking process that resulted m
i
in the recommendation of the ingestion of KI to emergency workers within the identified specific area.of concern, see Exercise Report at pages 171, 172 of 428.
O
_ g
6 !
i 1
ATTACHMENT A
, (FEMA Memorandu:a From R.W. Krirm to F. Beglef, Radiological Monitoring, Dated January 5, 1988)
(
n -n
-- a
),a * "'* "* ' wa** 5"? "'*"*5c 8 8'c82 L ngency
~
Washmpan. D.C. 20472 gi . hd dA[.
>s m s 1988 g
r'
- i. 7 O
i MEMORANCUM TORd Trank Begley, chief Naturalagion FEMA and VI Technological Hazards Division FROM: 4Ritn
] ,
f as Assistant Associate Director ,
l -
Office of Natural and Technological !
Rasards Programs !
SUBJECT :
Radiological Monitoring
\
' -nonit=rin This memorandum provides guidance on the issue of rad ;
Shoreham .g. This issue is teing litigated as part of the
'tomic Saf ety and Licensing Board hearings. When Headquarters will ;rovide a statement promulg policy as impacted by these activities.
Current Guidance
- h The State and local radielegical emergency preparedness plansl shculd include previsions at relocation center (s) in the form of trained personnel and equipment 12-hou r to monitor within about a EP2 popu;lation to de evacuated.stiod a minimum of 20 percent' 4 Ter highly improbable radiological releases involving high levels of radiation ence= passing a relatively large area, it "
may be necessary 20 percent to moniter a greater nuater of evacuses beyon Of the population.
local governments would b :n auch a situation . Stats and s
ad hoc :esponse measures,e expected to develop and implement State, Federal and private sector supplemented, resources.if needed, by other The following guidance is provided in response to questions submatted in your memorandum seeking clarification of NUREG-1985, memorandum.0654/ FEMA-P2P-1 Evaluation Criterion J.12.li
- This policy was established in the memorandum f rom Mr. Krims to the NTE Division Chiefs dated December cencerning 'Cuidance on NOREG-0654/ FEMA-REP-1 Evaluation 24, 1985, Crite rion J.12.'
t
_ _ _ _ _ - - _ - - - - . - - - . --~
attachmsnt a (Page 8 og 3)
- 1. ggggg POPCTLATION @ RfBCE4tED.
The estimated population to be evacuated which will provide the basis for determining the' resources required for S, lume EP5 ulation ( ermanent
{ and trans ont monitorin populations).
. includes the total 5 is f rom a total t at the h 1 20 percent is applied to determine the amount of resources needed, i.e., trained personnel and equipment, to provide the monitoring within about a 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> period. The 20% of the i
I plume EPS population to be monitored in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is concidered to include evacuees from the CP! requesting sheltering ~at relocatien centers and those who desire monitoring only.
- 2. PLA)n(INo CONSIDERATIONS We have established that, for planning purposes, capability to moniter 20 percent of the plume EPI population in about 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> is adequate. Once this figure has been determined, the approximate number of monitors needed can be ascertained based on the f ollowing time-related f actors: 90 seconds (1.5 minutes) icr monitoring each evacuee and a 10-minute break for each monitor per hour, thus leaving 50 minutes f or monitoring. If it was determined that 20 percent of the total plume EPZ populat;tn was 6000 persons and 23 evacuees could be monitored per hour :50 minutas divided by 1.5) eacn moniter working s 6-hour Shif t, would monitor approximately 200 evacuees (6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> X 33 persons per hour). In this example, it would taxe 30 monitors to monitor the 6000 evacuees in about a 12-hour
.. pe riod, i.e., two shif ts of 15 monitors. This figure would be less conservative if a 10-minute break was not included
- n the calculations; thus, 40 evacuees could be monitored per hour by a single conitor and 240 in a 6-hour shift.
Using this example, if two shif ts were used 25 monitors would be ..eeded (6000 divided by 240).
- 3. MMOMsTRATicW CI '.An?0temen McNIMnfNc cipAntti-"r
.tadic1cgical monitoring capabilities should be tested at eacn tiennial arertise. A special scenarie to demonstrate radiological sonitoring is not nscessary. The scenario for the biennial exercise will normally incorporate a significant offsite release that necessitates the evacuation of portions or all of the EPI.
Activation of a reception center (s) with trained personnel and equipment sufficient to staf f the reception center and demonstrate this capability during an exercise is required. The location and number of reception center (s) to be activated and staffed is dependent upon the scenario, i.e., those reception centers which support the sectors of the EPs to be evacuated.
At least one monitor with a survey instrument should be present at each activated reception center to demonstrate his/her O
ettacEntnt T (Pagn 3 of 3) 0-
- J conitoring capability. '
roster of trained personnel and an inventory of availableTh p survey instruments that reflect the capabilit of the estimated population to te evacuated. y Once to monitor every 204
( )\ - :
6 years c shift change should be demonstrated by each offsite organization with radiological monitoring responsibilities.
4.-
1111a And 7dtsAl 212A3 i 1
State and local radiological emergency preparedness plans
'should include appropriate agreements per NUREG-0654/ FEMA-REP-1 eval'J4 tion criterion A.3. to incorporate arrangements for expanding radiological . monitoring capabilities if necessitated by accident consequences.- Federal assistance
' for expanding these capabilities is provided for in Part *:I
' Federal Radiological Monitoring and Assessment Plan (FRMAP)]
i
- of the rederal Radiological Emergency Response Plan (FRERP).
- 5. ucts?uMON i
Arrangements should be made to register all evacuses who arrateno While at time reception pe: 1cdconters f or radioicgical monitoring.
is set f orth f or the registration of
. tvacuses in NUREG-0654/ FEMA-REP-1, it is reasonable to expect 3 that this would radiological cecur simultaneously and continuo.aly with tne monittring.
both registration and monitoring of evacuees.Thus, the *.2-hour pericd snc If ycu have' any lurther questiens on this matter, please i
\ contact Bill McNutt at 546-2857.
b A,A,{ h CCi ,1) ?!MA Regicnal Offi:as (2) Frank J. Congel, Oirector Division of 3adiation Protection and I:ergency 7teparedness Muelear ?.eeulatory Ocemission
[
\
ATTACHMENT B (FEMA Memorandum from R.W. Krimm for NTH Division Chiefs, All TEPA Regions, GM MS-1, Dated February 9, 1988) i t
l
Attcchinnt B (Paga 1 of 4)
/
%3y ';- '* i i
Y'A7- # Federal Emergency Management Agency a.& . Washington D.C. 20472
[ *<a y '. . - -
7
. c . ..
pg 9y
- -8 ,*/ , "
C ! MEMORANDUM TOR:
NTH Division Chiefs All FEMA Regions .
- FROM:
, . 2 ,* .K
, Assistant Associate Director Office of Natural-and Technological Hazards
SUBJECT:
Clarification of Selected Provisions of Guidance Memorandum (GM) MS-1, Medical Services On November 13, 1986, Since that time, we issued GM MS-1, !!edical Services.
provisions. '
questions have arisen regarding some of its those provisions.f ollowing information is provided to clarify Primar_v And Eaevue Poseltals Gli 115-1 is silent on the issues of the location of primary and backup care for the medical facilities designated to provide medical offsite population.
Whi e it would be m preferable tnat both primary and backd; p medical f acilities be l I located outside of the plume EP2, this may not be feasible.
(,/ NUREG-0654/
that FEMA-REP-1 evaluation criterion J.10.h. provides relocation centers should be located "at least 5 miles, and preferably 10 miles, bevond the boundaries of the plume exposure emergency planning zone".
be located at least 15 miles f rom nuclear Relocation centers are to power plants to preclude or minimize f urther radiological exposure to evacuees and the need f or reevaluation.
should also be applied to medical f acilities.This rationale is TEMAmedical.
backup policy thatfacility, at least one, either the primary orTherefore, it outside the plume EPZ. should be located at least 5 miles This policy should be implemented notwithstanding those situations where the primary and/or backup medical hospitals. f acilities are the same as utility contract
- Medical Facilitv/Transeertation Resources Ris t s and Acreementr)
On page 3 of GM MS-1, esaluation criterion L.3. states that lists should be developed of the f acilities within the State or contiguous States considered capable of providing medical support f or any contaminated injured individual. The
" Areas for Review and Acceptance Criteria' for this section
' states that the lists should be annotated to indicate the ambulatory-nona .oulatcry capacities f or providing medical support for contaminated in]ured members of the general
/ni V
wwnuume t-> s truse o
- wv
~
[ .
1 C. 9 u ,'y;.
.nw <
~T?.l' A -
\
- $h],(( i public and any special radiological capabilities. Further, it states that this will enable State and local of ficials to direct members of the general public to those institutions capable of handling contaminated injured patients. The )
- " Areas for Review and Acceptance Criteria" for A.3. indicates that written agreements should be obtained for the designated !'
primary and backup medical f acilities and transportation providers.
Organizations that have responsibility for
- ~
transporting contaminated injured persons should specify the
... types and numbers of specialized and non-specialized vehicles necessary.
~
If additional vehicles and other. transportation resources are needed by an organization, they should be secured with letters of agreement.
Ambula terv/Non- Anbul a tory Cacacity The terms " ambulatory /non-ambulatory capacities", are explained as follows:
medical f acility's capacity to treat" Ambulatory capacity" means the
.' ' individuals on an outpatient basis and "non-ambulatory capacity
- means the facility's inpatient capacity. The outpatient capacity is the during day number anof individuals emergency that the facility can handle per without treatment of radiological contamination regard to hospitalization for inpatient or exposure. The
, facility withoutcapacity is the total number of available beds in a regard to treatment of radiological contamination or exposure.
Convevance EgI Contaminated Iniered Individuals.
Transporting contaminated injured persons is addressed in GM MS-1. It provides for specialized (e.g.,
ambulance) and non-specialized (e.g., auto, van or bus) transportation resources.
which type of vehicle is appropriate are the type andThe key factors in severity of the medical problems encountered and the need for trained emergehey medical services personnel. Members of the public who are physically injured or appear to be sick would be transported directly to medical f acilities medical treatment. Members of the public who are not for specialized physically injured or do not appear to be sick would proceed to relocation assumed that ifcenters for radiological monitoring. It is they are determined at relocation centers to be contaminated diagnosis and/or internally exposed and need further or treatment, facility (ies), they would be transported to a medical t Bvnarrine Relecation Centers As indicated above, relocation centers may be bypassed f or members be sick. of the public who are physically in]ured or appear to Suen persons should be transported directly to a medical facility unless the in3uries are minor in nature.
9
m eumauvuu e t-; wege e ens q I i
l
,~x[ l i
! 3 4 N '. y woi .
- g , '.. j
-M.* t This would cover those suf fering f rom en acute radiation gRr exposure syndrome and wob1d not require a trans c iv,.:. provider to assess radiological contamination. portation
,j Medical Perrennel
,. i '
'4 On page 4 of the GM, the ' Areas for Review and Acceptance
. . 3 '. Criteria
- states that each hospital listed under evaluation criteria L.L and L.1 shall have at least one doctor and one nurse whoinjured contaminated can supervise patients.theThe evaluation and treatment of
',- degree td which a
. medical facility has trained personnel beyond the minimum one doctor and one nurse is a matter between the State
. and local governments and that f acility's management. We
.- have not prescribed numbers beyond the stated minimum.
Medical Emercency Drills and Exercises a .
The demonst.stion of capability to provide medical services should be done in annual medical emergency drijls and biennial exercises.
An annual medical emergency drill involving a simulated
. contaminated injured individual (including one exposed to
,-~s dangerous levels of radiation) should be conducted and
( ) contain agencies provisions (i.e.,
for participation by locri services
\'~ '/ facility). ambulance and offsite medical treatment The simulated contaminated injured person should be transported directly to either a designated primary or backup medical facility for the public. If the medical facility is designated for both onsite and offsite use, then one drill can be used to test handle both onsite and offsite personnel.the f acility's capabilities to The drill should also include appropriate of f site emergency communications support.
Simulation of a relocation center (s) may be included required. althovgh the activation of relocation centers is not The offsite portions of the medical drill may be
. - perf ormed as part of the required biennial exercise.
When medical emergency services components are integrated into the biennial exercise, it is necessary to include the activation facilities.
of relocation centers and designated medical The scenario and exercise play will determine which relocation centers and hospitals should be activated.
This activation backup should include participation by primary and facilities, including appropriate support functions. A simulated contaminated injured individual, either f rom onsite or offsitefacility.
medical areas, will be transported to each activated
/N L,_,) -
i i
{ Attschmsnt B (Pngs 4 of 4) l
- . .u
'4
- g .,. . -
?C . ' -
a.
Regional staf f as required in CM EX-2, Annual medical em D.
,, g, jg'j - on page 2). Rev. 1 (Section A.3. i drills should be forwarded to FEMA Headquarters.The Region
. ::I.'
fmolementation
, ,,fN "
' T-The time frame for incorporating the provisions of GM MS-1
- into a biennial to reflect exercise the provisions of GMor EX-2 an annual (Augustdrill 11, has been revised 1987). All of GM MS-1 by Decemberplans 31, 1987. should have been revised to incorporate These medical service
, .' measures should be demonstrated either at the next annual medical emergency drill or biennial exercise held in calendar year 1988.
policy that If changes to REP plans are necessitated by the f rom the site, the plans should be revised to reflectat change by December 31, 1988. this least one The change should be demonstrated 1989. in a drill or exercise during calendar year This memorandum NRC staff. has been coordinated and concurred in by the If you have any questions please contact Bill McNutt at 646-2857.
. CC: Frank J. Congel 1 NRC 1
4
,r-
l l i l- if% !
i \ i i
l l
l l l
ATTACHMENT C ]
(FEMA Memorandum From R.W. Krimm to E.A. Thomas, .
Guidance for the Qualifying, Full-Participation Exercise at Seabrook Dated May 19, 1988) 8 i
i ks
Attachm3nt C (Pega 1 of 3)
[y n ) ...
Ib. _.iIl i
Federal Emergency Management Agency Wasnmpon. D.C. M+~;
MAY I 9 :9ES
, MEMORANDUM FOR: Edwarc A. Thomas, Chief Natural and Technological Hazards 1
FROM: Ricnarc W. Kr1.
l &J Assistant Associate Director Office of Natural and Technological Hazarcs Programs
SUBJECT:
Guidance for the Qualifying, Full ca rt :-1 p ati on Exercise at Seneroon (Also Addresses the Shorenam Exercise)
This .respones to yeur recuest of Maren 15, 1988, on guidance for use in the upcoming SeabrooK cualifying, full-participation exercise. This confirms the guicance provided to you in a conference call with Joan Hock, Marshall Sancers and Craig Wingo for the four issues raised.
,. Because of the relevance of tnis guidance te the Shoreham exercise, our
( ) response is appliec to both the SeabrooK and Shoreham exercises.
Issue 1. With resoect to the earticicatino State a'nd local eevernf ents (i.e., New namosntre ano Mainen, cutcance snouic ce oeveicoec aiono : e lines of tnat et str7cuteo cy memorancum cateo Maren 7,19E8, drem Grant Peterson to ne Regional Directors for evaluat1ng exercises wnere State ano/or local governments cecline to carticloate.
Resconse. The same scope of exercise objectives delineated for utility off site response organizations in the referenced Maren 7,1988, memorandum acolies to participating State and local governments. As set forth in this memorandum, 35 of the 36 exercise objectives of Guidance Memorandum (GM)
EX-3 apply, the only exception being objective 36. Of course, the new objective contained in the " Guidance Memorandum (GM) EX-3 Amendment" does not apply as it pertains only to utility o'fsite response organizations.
We understand that the State of New Hampshire has agreed to this extent of play in er:er to be consistent with the extent of play on the Massachusetts side. You should secure this understanding in writing, if you do not have it alrency. The specific oDjectives of the 35 that would need to be demonstrated by participating State and local governments are, of course, depenoent upon their emergency functions as documented in their emergency response plans anc crocedures for their respective plume and ingestion exposure patnway roles and responsibilities. The use of the exercise objectives in conjunction with the testing of plume and ingestion measures should be implementor in accordance with the guidance on pages la, 15 ano 16 of GM IN-1 for tne Seabrook and Shorenam exercises. ,
l\
\ i v
Attcchmant C (P:gs 2 of 3)
. I fif * '
1
!ssue 2. With res:ect to cualifyine exercises involvine eithea participating or non-particloating governments, guicance snoulo be cevelocea on now to orcoerly evaluate tne availaellity anc trainiac of cus crivers anc tne availao111ty of cuses.
Resconse. The focus of this issue is pre-exercise evaluation of the ava11ac111ty of buses and training of bus drivers. Suen an evaluatien can te ace:molisned by examining the training c:mponent of tne organi:stien's emergency plans, examining latters of agreements C. A) for buses and bus drivers and by making telaenone calls to LCA crevicers to c nfirm capacility to provice $;ecified resources. Guidance for determining tne extent of exercise demonstration and evalue:1:n f ar tus drivers and buses (and route guides) is proviced in the attachment.
Issue 3. With reseeet to the evaluation of decontamination and relocation facilities, we Delieve tnat erotecures for croceriy caoosine tne numoer of cecontaminat1on teams anc recistrars snouic ce ceveiocec.
Response. Functions associated with relocation f acilities incluce reception centers for registration and monitoring, decontamination centers and congregate care facilities. These functions may te integrated into the operations of a single f acility or may carriec out in pnysically separate f acilities and locations. Guidance for determining the extent of demonstration and evaluation of these functicns is provided in the attachment.
Issue 4 Finally, with resoect to the New Hamosnire cortion of the exercise, a cecis1on must ce mace as to wnetner correcticn of tne deficiencies anc ARCA's 1 cent 1ftec in tne Feeruary 1986 exercise sneuld be an oo?ective of the next Seacroom exercise.
Response. All icentified deficiencies from previous Seabrook and Snorenam exercises should have already been corrected prior to the upcoming exercises. If they have not, they should be demonstrated during these exercises. Likewise, any ARCA's from the 1986 exercises that have not been corrected should be redemonstrated, and if plan corrections are required, they too snould be demonstrated at the upcoming exercises.
Any cuestiens about this memorandum enould be referrec to Vern Wingert at 646-2872.
Attacnment cc: All Reg 1onal CNTH Chief s 9
i Attcchmsnt.C'(PIga 3 of.3) f5 ,
'W)
\
.h l Attacnment May 9, *.923 GUIDANCE FOR DETERMINING THE EXTENT OF DDIONSTRATION AND E'/ALUATION REQUIRED FOR QUALIFY 1M3, FULL-pARTICl?ATION EXERCISIS The following guidance is crovided for determining the extent of demonstrate:n and evaluation reouired for all organizations, f acilities anc . field activities in exercises. An objective of this guidance is to provice a frameworc f:r ascertaining the level od exercise demonstration that is dreasonaoly acnievaot e' in orcer to assure an aceouate demonstration of organizational clanning arc preparacness. This guidance is apolicaole to only qualifying,. full-partici:ation exercises. Suidelines are providec below for ma<ing tne determination of the exttnt of exercise demonstration anc evaluation.
- 1. Because of the site-specific nature of organizational planning anc preparedness, decisions on the extent of offsite demonstration ano evaluation of exercise functions and activities should be mace ey FEMA Regional staff in consultation with FEMA Headquarters.
(b 2. For exercise demonstration and evaluation purposes, the extent of activatien and staffing for all types of facilities, field teams (e.g., radiological monitoring) and field activities (e.g., t*affic control) should be determined on tne basis of a representative rumote c' facilities, staff and functions. A representative numoer may vary from 100t to a portion of trie total activity. The basis for determining a representative number is the documentation of organizational planning and preparedness, the type and level of participation recuired by scenario events and other relevant factors such as Federal evaluator resources.
- 3. The type and extent of additional documentation required to support limited demonstratieri of exercise activities and functions may be adcresseo througn such means as providing rosters of trained personnel and i9ventories of available equipment and instruments.
This guicance supersedes that contained in one part of section 3 of the attacnec January 5,1988, guidance on '" Radiological Monitoring" as follows: "At least one monitor with a survey instrument should be present at eacn activated reception center to demonstrate his/her monitoring capability."
O lO
i f, ~
9 I
ATTACHMENT D (PSNH Letters from G.R. Gram to R. Boulay, _
Director of Mass. Civil Defense Agency, Dated January 15 and January 18, 1988;
, Records of Conversation - J.A. MacDonald,
, Dated January 27 and March 25, 1988) l 1 G'U, I
l
\
l
_1 aswamanms a prege a ms, cy)
.9 .% // /
SEN S80003 P@6C Service of New MTWJie New Hampshire Yankee Division January 15, 1988 Director Robert Boulay Massachusetts Civil Defense Agency .
400 Worcester Road Framingham, Massachusetts 01701
Dear Director Boulay,
l New Hampshire Yankee is in the process of preparing for a Federally observed exercise of the emergency response organization which would rospond to a ;
radiological emergency at Seabrook Station. We have tentatively selected the week of 23 May, 1988 as a target date for this exercise.
To support an exercise in this time frame it will be necessary to submit to the cognizant Federal authorities proposed exercise objectives and a sus-mary of the extent of play for each participating emergency response orga-nization no later than 25 January, 1988. To facilitate the development of 3
the materials required for this submittal New Hampshire Yankee is
[
[^ = requesting you and the appropriate members of your staff to schedule and
(
% attend a coordination meeting with New Hampshire Yankee, prior to 23 January, 1988, at a place and time of your conv:aience.
j Upon completion of this meeting we expect to have finalized the proposed exercise objectives for the Massachusetts Emergency Response Organization and an outline of its extent of play. To assist you in preparing for this meeting and to serve as a starting point for discussions I have enclosed a draft of proposed exercise objectives for your state's response ornaniza-tion and a suggested meeting agenda.
If by January 23, no response to this request is received, New Hampshire j Yankee must assume continued non-participation in the radiological emergency response planning and exercise process by the Commonwealth of {
Massachusetts and will make alternate preparation for the exercise in i accorcance with recent Nuclear Regulatory Commission rule changes.
If you have any questions or if I can be of any assistance to you in this }
matter please contact me at (603) 474-9521, ext. 4399. '
Sincerely, 0 W G e R. Gram Executive Director Emergency Preparedness and Community Relations GRG/WO/cc
v usvavaanwans er s un;p amq
~5 /
SEP# 880047 I b' M Pubile Service of New HcrnpsNre e!
New Harnpshire Yankee Division January 28, 1988 Director Robert Boulay Massachusetts Civil Cefense Agency 400 Worcester Road Framingham, MA 01701
Dear Director Boulay,
I have received no resconse frem you to my letter of January 15, 1988 and acditienally you have indicated to Jim MacConald of my staff, in a telephone conversation of January 27th, that your intention is net to provice a response to the letter. With this in mind, New Hamesnire Yankee has initiated internal preparations to make alternate arrangements fer an exercise in accordance with recent Nuclear Regulatory Commission rule enanges. .
l As Mr. MacDonald related to you in the above referenced telephone '
conversation, New Hamesnire Yankee has delayed sutmissicn of exercise objectives to Feceral authorities until at least February 5, 1988.
If it is possible for you to recer.sicer your position in this matter within this time frame, New Hamesnire Yankee stancs reacy to meet with you or other representatives of the Commonwealth of Massachusetts, at a time and place of ycur convenience.
Sincerely, /
~O Ge 'e R. Gram utive Directer Emergency Preparedness and Community Relations i
L/EK3061 P.C. E:7 300. Seatreet NH 03874.Te!ecnene (603) 474-9574 l
f
awssc mene a wayJe a en e])
r i
,m '
I
/
) aaaaa..a.,.aaaa a aa...a..a.. aaa RECORD OF TELEPHONE CONVERSATION G 46444....*........a.. 44........
Standard Distribution Additional Distribution Georoe Gram Fatty Tore T. Haroster Jeff Crafts Debra Vanderbeek P. Stroup Mike Hawkins Tom Byrnes Cathy Franks Millie Munroe DATE: 1/27/8e CALL TO: Bob Boulav CALL FROM: J.A. MacDonald COMPANY: MA-CD PHONE NO: 617-875-1381
SUBJECT:
Si East Kinoston Siren Test and
- 2) Jan. 15, 1988 Exeac9se Participation Notice Letter, rw v- Summary of Conversation:
- 1) In accordance with our East Kingston siren test procedure, I called Bob to ,
alert him to the fact that a siren test is scheculed to be held this Saturcay, January 30th between 1000 and 1300 hours0.015 days <br />0.361 hours <br />0.00215 weeks <br />4.9465e-4 months <br />. He thanked me for the courtesy notice.
- 2) I informec Bcb that the response period mentioned.in our January 15th exer-cise participation letter (by Jan. 23) was being stretchec for an additional period, and that a becond letter was going to be sent to him to explain.
He said fine but that he could not respond to our inquiry under the non-participation stature that he is forced to De in. I l
He agreed with me that he hopec and expected that MA-CD would be working ,~
with NHY in emergency planning, like the situation used to be, but that for now that was not possible.
He told me to stop in and see him anytime I was in the neighborhood.
l $ \
1 l
f 4 V R/SS3051 t
1 Attachmsnt D (Page 4 of 4) l O
g "!!!"!.!!.!!!!!"?"!.!S"S!!!"
J standard ofstributien i Addftienal Distribution l
$ ksW '
b h/ 'O A SAw .
Z~ GElm x 4Ah m e; s-zr-ar -
e m 10:
ddd Bead cu:. raex: d./de-2pra //
eexwr Dr&&; slM enoue uo: e7 e.s' /rsY s m te:;
Am/ / /fff 4 / pre s s Summary of conversation: hsMsar O I de ee2rca a V x w as ea' <dd 0 fafv mAM'/Nf I%
4difAA/ ff S & / & "I I /f4
- Ms
~
pMor a rtw dae
/k 7$h sie67 owall 4 e dI+rN 4y dY #'9'"'N se r%f 4 am anArd' /**O '
1 e 44 ds sa"**kg lg/ dim& a Wh g /# " h f h/"" k Ua 6' s ,./ s a n .. sj A . s "'"o= -
1
t
\
i i
ATTACHMENT E (Participation Matrix for ORO Exercise) i
\
l O-I
1 . ., . tasme p- uvuzu c me uww , .;
'9 T, '
L-
!I PARTICIPATION MATRIX FOR ORO EXERCISE P hs._-[.I~ '
~
~
PUBLIC/ PRIVATE SCHOOLS .1 l
Amesbury Participated in Magg the Graded Exercise Source of Data
~
1:. .Amesbury"H.S. No .
- Letter SEP880174', .
3/14/88, from George:Ri Gram to Stephen J.
Gerber, Superintendent of Schools, Ameebury.
Public Schools, Amesbury, Massachusetts' .
No response for schools listed 1 5.
- 2. 'Amesbury Middle -No 1
- 3. Aresbury Elementary So 4 Cashman' School' -No 5; Horace Mann No 16, 7th Day Adventist No-l' Recori of. Conversation
' .\' ' - _ (R00) - 2/2 3/8 8, -- 3/2 9/8 8 '
(Training / Exercise Acceptance); Training done on'4/22/88 Merrinae f ~ 1. .Dr. F.'N Sweetsir. No' ** Letter - SEP880174, 3/14/88, from George R.
Gram to Thomas'F, Jenkins, Superintendent ~
of Pentucket Regional School District, k'est Newbury, Massachusetts.
Letter - 3/17/88, response from Thomas F.
Jenkins to George R.
Gram declining to participate for schools
. listed 1-2,
- 2. Donaghuc Schoci No l
ts l
- l.
- sussssamms te ytregg e. es _ aw v Newbury
- 1. Byfield School No
- Letter - SEP880174, 3/14/86, from George R.
Gram to Gerald W. Kohn, Superintendent of Schools, Triton Regional Union 68 School District, Byfield, Massachusetts. Letter -
3/21/88 response from Gerald W. Kohn to George R. Gram declining to participate for schools listed 1-4, 2, Newbury Elementary No
- 3. Woodbridge 5:hool No
! 4 Triton Reg. School No l
- 5. Gov. Dum=er Academy No ROC 5/2/88, between Chris Patrinos, ??HY, and 4 laurence Platelli, Asst. l Headmaster. (Limited !
participation in planning)
- - Signed Mail Receipt Received
- - Response Received
- Refused (Facili:s would not sign for it)
- ** Unclaiced (not delivered) )
1 - Did not partic' ete because school was not in session I
l l
I l
l __ _ _ _ _ _ _ _ _ _ _ _ _ _
PUBLIC/ PRIVATE SCHOOLS (continued)
Newburvrort Participated in l
Eggi the Graded Exercise Source of Data l 1. Brown School No Record of Cr ersation j
(ROC), 3/31/L between Chris Patrinos, NHY, and Joseph Donnelly, Asst.
Superintendent of Schools, Newburyport, Massachusetts informing NHY of decision not to participate in emergency planning for Seabrook for schools listed 1 5.
- 2. Belleville School No -
- 3. Kelly School No
- 4. Ruport A. Nock No S. Newburypert H.S. No
- 6. Greater Newburyport No Inactive during ARC Summer Spec. Ed. Exercise Planning (Su :er e ily)
' Greater Newbury;cr No Inactive during Educ. Coll. Sut:er Exercise Planning (Sumner Prograr) sucrer only)
- 8. I::aculate Conception No P.0C 3/18/88 (Training / Drills Participation)
ROC-4/25/86 (Planning Refusal)
Salisburv
- 1. Me orial Ele:entarv No
- Letter SEPS60174, 3/le/EE, free George R.
Gra: to Gerald W. Kohn, 3-
06eeueuauasuue e wwww w ou ewy Superintendent of l Schools, Triton Regional
(
Union 68 School Di s t ri.c t , Byfield, l Massachusetts. Letter -
3/21/88, response from Gerald W. Kohn to George R. Gram declining to participate for schools listed 1-2.
- 2. Plair, Schools No West Newburv
- 1. Pentucket Regional No ** Letter SEP880174, Sr/ H.S. 3/14/88, from George R.
Gram to Thomas P.
Jenkins. Superintendent of Pentucket Regional '
School District, West i Newbury, Massachusetts. l Letter - 3/17/88, response from Thomas P. j Jenkins to George R.
Gram declining to participate for schools l listed 1-3.
- 2. Pentucket Regional So Jr.H.S.
- 3. Dr John C. Fage So Schoci 4 Essex North Christian No ROC 4/7/88 (Participation pending; no further response)
- - Signed Mail Receipt Received
- - Response Received Refused (Facility would not sign for it)
- x* - Unclaimed (not delivered) 1 - Did not participate because school was not in session l
O
swwe3emsansm]w ts g veJgje w wu aw y l
/' ^ T .
i DAY CARES / NURSERIES
\s_ -) l Aresbury Participated in Sale the Graded Exercise Source pf.Date
- 1. Sheila Taylor No
- Letter SEP880174, 3/14/88
- 2. Vickie Cook No
- Letter SEP880174, 3/14/88
- 3. Sherrie Davey No
- Letter - SEP880174, 3/14/88 4 Stephanie Dragonas No ' ROC-3/8/88 (Exercise i
' Acceptance)
ROC 4/25/88 (Exercise Refusal)
- 5. Denise Toleos No
- Letter - SEP880174, 3/14/88
- 6. Elizabeth Hove No *** Letter SEPS60174, 3/14/88 7 ,s i
Kerry Muse SEP880174,
( ,
- 7. No
- Letter 3/14/88
- 8. Karen Tourr.ier So
- Letter - SEP880174 3/14/88
- 9. Donr.a Blades So ROC 2/25/88 (Exercise Acceptance)
ROC 4/28/88 (Training / Exercise Refusal)
- 10. Donna Perkins No
- Letter SEP880174, 3/14/88
- 11. Dianne Dore No
- Letter SEP880174, 3/14/88
- 12. Pan.ela Clark No +** Letter - SEP86017 ,
3/14/88 !
, 5-
! (
\s.
) I f
assesnmend a weawe w es avv I
- 13. June McIntire No
- Letter - SEP880174, i 3/14/88 14 Nancy Elander No
- Letter - SEP880174, 1 3/14/88
- 15. Denise M111ette No ***Le tte r - SEP880174, 3/14/88
- 16. Linda McDormand No
- Letter - SEP880202, 3/15/88; ROC 3/5/88 (Exercise Refusal)
- - Signed Mail Receipt Received
- - Response Received
- Refused (Fecility would not sign for it)
- - Unclaimed (not delivered)
O 6-f
_ __. - - ~
Attackmsnt @ (@cg2 7 o$ 24)
_rs i )- DAY CARES / NURSERIES x/ (continued) 1 Anesbury (cont'd) l Participated in Eatt the Graded Exercise Source of Data
- 17. Jane Tournier No
- Letter SEP880174, 3/14/88. . Returned letter 3/17/88, declining participation
- 18. Katherine Scott No
- Letter - SEP880174, 3/14/88
- 19. Karen Miele No ***Le tte r SEP880174, 3/14/88
- 20. Annalises Hutchinson No
- Letter SEP880174, 3/14/88 I
- 21. Katherine S. Ferru::a No *** Letter SEP881075, l 3/14/88
- 22. Evelyr. Fournier No
- Letter SEP880174,
()/
i 3/14/88
~' 23. Geralyn k'111ett No
- Letter SEP880174, 3/14/88 24 Debra Notargiacon.o No P.0C 3/10/88 (Exercise Acceptance)
ROC 4/25/88 (Exercise
- Refusal)
- 25. Ruth Terry No
- Letter SEP880174, 1 3/14/88 {
- 26. Deborah Tournier No
- Letter - SEP880174, I 3/14/88 27 Kathryn Marchitelli No *Lette r SEP880174, 3/14/88 !
- 28. Jeanne Yasi No ROC-3/8/88 (Exercise l Acceptance)
R00 4/25/88 (Exercist Refusal) i 7
fN I
?
t
\
l f
g g g gg -
(
l
- 29. Amesbury Country Day No
- Letter - SEP880176, 3/14/88 ROC 3/24/88 (Planning Refusal)
- 30. Windmill Country Day No
- Letter SEP880176, 3/14/88
- 31. Amesbury Headstart No
- Letter SEP880174, f 3/14/88
- - Signed Mail Receipt Received
- - Response Received
- - Refused (Facility would not sign for it)
- - Unclained (not delivered) 0
.E-t i
1
wsnesewaucuvun a u vwsp u wo awy f%
\%- ) DAY CARES /tiURSERIES (continued)
Merriese Participated in
.dggg
' the Graded Exercise Source of Data
- 1. Cayle Leblanc No
- Letter SEP880176, 3/14/88 ROC 4/6/88 (Plan Acceptance; Exercise Refusal)
- 2. Lillian Stuart No Letter SEP88020, 3/15/88 ROC-3/10/88 (Exercise Refusal)
- 3. Carol A. Goss No **** Letter SEP880174, 3/14/88 4 Eileen Lawler No
- Letter SEP880174, 3/14/88
- 5. Shirley Inr.is No
- Letter SEP680174,
,Q 3/14/88 Michelle Boye r No **** Letter SEP880174, 6.
3/14/88 7 .. Jean Gatchell No
- Letter SEP88020, 3/15/88 ROC 2/24/88 (Possible Participation)
ROC 3/7/88 (Exercise Refusal)
No
- Letter SEP880174,
- 8. Eileen Flynn 3/14/88 Newbury No
- Letter - SEP8E0174,
- 1. Maure e r. Hale :.
3/14/88 l
p 9-
[
t
Attachment E (Page 10 of 24)
- 2. Debra Dash Yes ROC 3/7/88, 5/17/88, 6/16/88 (Exercise Acceptance)
- 3. Mrs. A. Hilton No
- Letter SEP880174, 3/14/88 4 Creative Playhouse No **** Letter - SEP880302, 4/11/88
- - Signed Mail Receipt Received
- Response Received
- Refused (Facility would not sign for it) l **** - L'nclai=ed (not delivered)
O
- 5 f
ouwwusensus e ntresse eo ee awg ;
I.
i
./
A
)
j DAY CARES / NURSERIES (continued)
Newburvoort Participated in h the Craded Exercise Source of Data
- 1. Susan Bradford No
- Letter SEP880174, 3/14/88
- 2. Sue White No
- Letter - SEP880174, j 3/14/88
- 3. Elizabeth Cox No
- Letter - SEP881074,
,3/14/88 -
ROC-3/16/88 (Planning Refusal) 4 Maureen Albert No
- Letter SEP880174, 3/14/88
- 5. Laura Martel No
- Letter SEP880174, 3/1c/88 Letter SEP880202, 3/15/88
[s RC 3/77/88
( (!..ining/ Exercise Refusal)
- 6. Janet Cooke No *** Letter SEP8802C2, 3/15/88 7 Dianna Parkinson No
- Letter SEP880174, 3/14/88
- 8. Janet Meloon No *** Letter SEP880202, 3/15/88 ROC-3/7/88 (Training / Exercise Refusal)
- 9. Karen DeEcu No
- Letter SEP880174, j 3/14/88
- 10. Judy Lacroix No ** Letter SEP880174,
.3/14/88 l
t
Attachment E (Page 12 of 24)
- 11. Kathleen Charpentier No
- Letter SEP880174, 3/14/88
- 12. Nancy MacNeill Yes
- Letter - SEP880176, 3/14/88 ROC 5/19/88 (Planning, Training, Exercise Acceptance)
- 13. Newburyport No
- Letter SEP0174, Montessori 3//14/88 Letter-4/12/88, Maureen Daley, Director, to George R. Gram declining participation
- Signed Mail Receipt Received
- - Response Received
- - Refused (Facilit:, would not sign for it)
- - Unclaimed (not delivered)
O; l
l l '
l
Attachmsnt E.(Page 13 of 24) j 1
I l
'_,- \
i I k
~#
/' DAY CARFS/ NURSERIES l (continued)
Newburvrort (cont'd) l Participated in Name the Craded Exercise Source of Data 14 -. Kinder Care Learning No ROC 3/7/88.(Exercise Acceptance)
ROC-5/4/88 (Deferring participation)
- 15. Kroll Edge Nursery No **** Letter SEP88/0174, 3/14/88
- 16. Children's House No
- Letter SEP880174, 3/14/889
- 17. My Schoci Day Care So
- Letter - SEP880174, 3/14/88 1
- 18. Mrs. Murrays No
- Letter SEP880174, 3/14/88 i i
s 19. Circle of Triends No
- Letter SEP880174.,
/
} (Milk St.) 3/14/88
- 20. Circle of Friends No Sete as above (Federal St.)
- 21. Pa:ela Standle:. No
- Letter - SEP880174, 3/14/88 ROC 3/22/88, (no longer providing day care)
Salisburv
- 1. Alice Perry No
- Letter - SEP880174, 3/14/86
- 2. Margaret Allard So
- Letter SEP8F0174, 3/14/88
- 3. Susan Cuilbtrt No **** Letter - SE1880202, 3/15/88 ROC-3/5/88 !
(Training / Exercise l Refusal) rs .3-t
)
~~. /
i
_._-__m .__- __ _
i TAttachrnent~ 2 (@@@@ Wo2 if6) 4 Cynthia Lee No
- Letter - SEP880202, 3/15/88 ROC-3/5/88 (Training / Exercise Refusal)
- 5. Donna Spaneas Yes ROC-3/5/88 (Exercise Acceptance)
- - Signed Mail Receipt Received
- - Response Received
- - Refused (Facility would not sign for it)
- Unclaimed (not delivered) l 9
L 1;.
Attachment E (Page 15 of 24) l l
l
, s DAY CARES / NURSERIES (continued)
Salisburv (cont'd)
Participated in ligpqg the Graded Exercise Source of Data
- 6. Tracey Durkeee No
- Letter SEP880174, 3/14/88
- 7. Kiddie Corner No
- Letter - SEP680174, 3/14/88 ROC 3/7/88 (Training / Exercise Refusal)
L'e s t Newburv
- 1. Puddle Duck Place No Letter SEPE80174, 3/14/88
- 2. Madelyn Cirinna No *** Letter SEPS80202, 3/15/88. ROC 3/15/86 (Refused participation)
R l
/ \
- 3. . Lynn 'Jilson No
- Letter SEPS60174, '
3/14/68 i
4 Children's Castle No
- Letter - SEP880174, i 3/14/88
- 5. Kids 'Jorld Limited Se
- Letter SEP680174, 3/14/ES
- Signed Mail Receipt Received
- - Response Received
- - Refused (Facility would not sign for it)
- - Unclaitte d (not delivered)
+
O l _ _. _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ I
o , , , , , ,/rxoci 3 uEtet ,
e 5 4 5 5 4 4 h da 6 - 6 c 7 7 7 7 7 7 t ,r p 7 7 r r1 r1 r1 1 1 r1 roomi r1 r1 u e0 e0 e0 r0 r0 e0 rActac e0 e0 o t8 t8 t8 e8 e8 t8 e rcri t8 t8 S t8 t8 t8 t8 t8 t8t maeGt t8 t8 eP eP eP tP tP ePtoMr r eP eP LE LE LE eE eE LEerii .a LE LE
- S *S
- SLfDDRp
- S
- S ne is i
dc er t e ax pE i
cd o o o o o o o o ie N N N N N N N N td ra ar S PG E
I T
I L y y y I
t t t C i i i A e l l l F p e e e e i i i l,
y m m m m c c c T o o o o a a a A l f
i l
l I
l f F F F I
y l C t a g g g g l l l E i t n n n n a a a P l i i i i i i i i S i p s s s s c c c c s r r r r p
e e p
e p
a o u u u u F l l N N N N S S S
) )
r y y e t t t i i n r r e o o C e e h h l m m ) t t a g o o . u u t n l i i f
r d A A i i o R p s t t n l eg ag s r s s a oy l n l n o u e e M oe ai li l
l N R R hl Vs is d cl u Vu y y d e o Sa eo o e r r o d o V gli wl f m u u o i w r a o a b b w s e ot t y Wy yr N s e
s e
t s
l l
l p
bn ra ir ru wu r
u m m a i a as eb ob b A A E l I M l
I a I I s P s n e e e l m m e_
m . . . . . .P .A .A A_ 1 ? 3 4 5 6( 7( n(
rlI -
38 xOr
/ erg
, 8 , A 62 g ,) ()
7 / n gd e r13i ne8 s e0 nit 8i t8 - nnp/c t8 aie5r ePCl ac1 e LEOPrc/x
- SR( TA6E s
e Y
y t
i )
l t i i c
a r F o
- f
( l i
a n g
c i e s p d S e t v o i n) c d c de o l r R ue ov t wi p l idye eetd cvi eil t Reio ccn e l ea(
c iRF n a (d e Me e d sdm i dnoi s eosa e npul R gsf c ieen
. SRRU I
M 9 ****
o / i o 8 ) x 8 ) x 8
, 4 gt , ,
/ eE / eE /
e 61 na 5 6 e 9 ec( 9ec( 9 c 7 /i p 7 7 c /sn ) /sn ) /
r r1 3 ri r1 r1 r 3i a8l 3i a8l 3 u e0 rc e0 e0 u ct8 a ct8 a o t8 - ei t8 t8 o rp/s rp/s S t8 ft t8 t8 S ee0 u ee0u ePCer eP eP Cxc3f Cxc3f C LEODa LE LE OEc/e OEc/e O
- SR( p
- S
- S R( A3R R( A3R R ne ne is is i i dc dc er er t e te ax ax pE pE i i cd o o o cd o o ie N N N ie N N N td tt ra ra ar ar PG PG S
E
_ I T)
_ T. d I
e y y y y y I t t t t C u t t i i A n i i i i i e l l l e l l l F t p i i i p i i i y c c c y c c Lno T a a a T a a A c F F F F F I
y y C( t l l l t l l E i a a a i a a P l i i i l i i i S i c c c i c c c e e e c e e p
a p p p a p F S S S F S S
)
y t
i s r o
i s h y t l u A
a i
D g -
- n y i e g e s g n e
n s eu a i i d u go l s i o al l l u K l l i o e
f l y V l l
g c c i r e a a Vu e y yd
_ m mr m b m r l i a ie i i s a u rR i
c a
m N rt rn ee MC M r
r e
re rm eA M(
y r
u N b N
w e
dk e
l a EO r b
_ r w
_ e . . . e . .
_ M 1 2 3 N 1 2
!i
!!)llI - - .
, ' 3eteWOWUw3f
.t M m pQs HW OM M -
t t m
q , _ m p~ ,
u
-; 8 .8
~- e 8 8 g s~ ./ ./ n
(, . Ci
. Oc 4
1 4
1 gi nn Rr' ./ ./ in)
.e 3 3 ray
' ) x ull eE , ,
dPn ec( 4 - 4 .
o
. sn ) 7 7 ee i a8l
, ct8a r1 r1 e0 vsr iie e0
. rp/s t8 t8 tcm ee0u t8 t8 crm
. xc3f eP eP aeu Ec/e LE LE nxS (A3R *S *S IE(
o o o N N N
- y. y y t t t -
i i i )
t 9 l l l 1
i i i i c c c r
a a~ a F F F o y l a
l a
l a
f n
i i i g c c c i e' e e s p p p d S S S e t v o i n) e d c de e l r R ue ov t wi p l idye eetd t cvi a eilt e R ei o r ccn
. ) ) t l ea(
l e l e e iRF on on R a (d l oa oa Me e l hL hL d sdm i c c o dnei H Sf Sf o eosa l l r npul ro r ro n y
gsf c e oR oR ieen k b b l SRRU a t 4 r8 e u a2 a2 d - - -
Q H( H( A 4 5 6 ****
7
..!lll'
8 o , ,
/ c 5r ,
,/6 i
t ,/ei 6Rt 1 i
t ,/5 e 5 62 e - 5 61 .a 61( a /ea 61 c 7 7/x) 7 7 /d p 7/ p /l p 7/
r r1 r1 3El r1 r13 ei r138i 3bir13 u e0 e0 /a e0 e0 sc e0 8 c ice 0 o t8 t8 - ns t8 t8 - ui t8 - /i - sit 8 -
S t8 t8 au t8 t8 ft t8 4t stt8 eP ePCl f eP ePCer ePC2 r CorePC LE LEOPe LE LEORa LEO /a OPaLEO
- S *SR( R *S *SR( p *SR3 p R( p*SP ne is i
dc er te ax pE i
cd o o o o o o o ie N N N N N N N td ra ar S PG E
I T)
I L de y I t C u A in i
F t e e l
p e e e e i y m m m m m c Lno T o o lo o o a A c l I
l I I l
I l
I F I y l C( t a g g g g g l E i t n n n n n a P l i i i i i i i S i p s s s s s c c s r r r r r e a o u u u u u p F i l N N N N N S r r d o o e f f l l
y y i t t k e e S i i l c c d l o o nr i r r S S ae M o o t s n n t t .n m e a a r rn be a u M M o oe pm aC e q pn h t t e a m y ye yo eg S r m J a r rM rW Rn s
o a h t u u i p N a g n bd bd ts e y n i u we we rr m r n r o eg eg ou a u A D C NA NA PN J b
w .
e . . . . .
6
_ N 1 2 3 4 5 7
% i / i / i t 0 gt 0 gt i
ea 1 na 1 na l p /i p /i p bi 5 ri ri i c si - ei rc 5rc ei st ft ft or Cer Cer Pa ODa ODa
( p R( p R( p
- o o N .
N -
y y t t i i )
l 1 t i i i c c a a r F F o f
l l -
a a n i i g
- c c i e e s p p d
~
S S e t v o i n) e d c d' e e l r R ue ov t wi p l idye g . gn eetd nn nr cvi ia i o eil t sv st Reio ur ccn ui i
l ol l
loo iI l
l ea(
iRF u a ( d tS t - Me e
~ r- r sdm oy oy dnei pt pt eosa npul yi yi rr rr gsf c uo uo ieen bh bh SRRU wt wt .
eu eu - - - -
NA NA 8 9 ~****
i
1ll.
$e9n$nad e s _yd2D N o n u j; 8 e 8 8 8
_ a 8 i 8 8 8 t / l / / /
a 4 l 4 4 4 D i ) 1 1 ) 1 O
) 1 n n /8l /
o ,M 8 / m /
f 8 o 3 ,
o 3 38a 3 o / i rsoY t i
,/s 0 gt , f sti t ,
4u ,
e 1na 5 r,er i Nga np 5 61f 4 c /i p r1 7
e8Wo,ii r1 7
r13R 7/e r1 7
r 5ri u rc e0 t8 tesc e0 e0 n
e0 o ei t8 t/zcoui t8 t8 t8 S ft t8 e3terft t8 t8 a t8 Cer eP L1i rner eP ePCl eP ODa LE * / ri u r a LE LEOP LE R( p
- S
- 4FDM( p *S
- SR(
- S ne is i
dc er te ax pE i
cd o o o o o o ie N N N N N N td ra ar S PG E
I T -
I)
L de y y y y y y I t t t C u t t t -
)
A in i i i i i i 7^
e l l l l l l t 2 F t p i i i i i i i Lno y c c c c c c T a a a a a a r A F o O
F F F F F IC (c y i l l f
t l l l E i a a a n a a n P l i i i i i i g S i c c c c c c i c e e e a e e s a p p p p p p d F S S S S S S e t v o i n) e d s c de e e l r i R ue t ov t i t wi r r . v p p l ge oc i o idye nh pn t h eetd ii yI c s cvi sl r A k eilt
) ul u , r Reio d oe e bs y o ccn l
f K s we D a W t n
l ea(
iRF t u ec y a (d n t - o Ni i o e o r l l / v s t Me c oy l r ' i P sdm
( pt e l e l n dnei yi g iS u u g eosa t e rr a h a t n npul r m uo t rn P r i gsf c o a bh i ea o n ieen p N wt r vm . p r SRRI J y eu e t p u r NA l I
taul I I S O T - - -
u
- b . . . *
- w . . .
5 ***
e 0 1 2 3 4 1 1 1 * ***
N 1 1 1 O
l' t
o .
8 i aee
/ tl cR e 5 6gaPn c 7 /np ae r r1 4ii8ts S
u o
e0 t8 t8 eP Cl r2 ce ncB pi ni / e c at2 cr
- LE OPa/Ax
- S -
R( P4(E ne is i
dc
. er te ax n pE o i i cd o o s ie N N s td e ra s ar S PG n E i
I t I T) oL de n y I
C u s A n t
i )
a F i e l t w t p e i i
- Ln y m c l o T a r to N) o A I c 1 F o y f ho EC(
~ g t l
/ c P i n a n s l i i g S i s c i e c r e s s a u p d u F N S e t a v o c i n) e e .d b c de e l r y R ue l ov n e t p
wi o m l o e idye e l f
g eetd t a cvi a g l s seilt p n l e eReio i i i i i ccn c s V t tl ea(
i r i iiRF t u w l l a' (d r N o i iMe e a d c c sdm p f a a adnei a e y F Feosa t e e M r npul o m l u l l gsf c n y a n t b a ai e e n r N e a w i iSRRU d u e e e c c i b r r N e e-p D s G G p -
i t S S
- l s *
- a . . e o o * *
- 1 S 1 2 W N N* * *
- T)
Attachment E (Page 24 of 24) i 8
I l
l I
1.
FACILITIES IDENTIFIED POST EXERCISE G1 l
Amesburv j
- 1. Katheryn Cook 4. M.R. Residence (T.P.)
- 2. Patricia Younger Heritage Towers
- 3. Bonnie Noyes l
Merrimac
- 1. Janet Michaud Newbury
- 1. Salen Mauro ;
Newburvoort l
- 1. Marga:'.et Yuhasz Salisbury i
- 1. Diane Marie Champlin
- 2. Mary Sergi
- 3. Danielle Hajjar West Newbury
- 1. Mary Brown
- 2. Early Intervention j
__-- _ ___- _ ___ _ a
ATTACHMENT F (FEMA Memorandum From R.W. Krimm'to F.J. Congel, Objectives for the Seabrook Exercise, Dated June 22, 1988) l,
'I w
Attachment F (Page 1 of 2) im
\
(V -
O'.3
- 63.2 Federal Emergency Management Agency Washington, D.C. 20472 JUN 2 21988 MDiCRAN0tN FOR: Frant J. Congel Director, Division of Radiation Protection and Emergency Preparedness Office of Nuclear Reactor Regulation ,
Nuclear Regulatory Cornission 1 FRCN: r Assistant Associate Director Office of Natural and Technological Hazards Progress l SUBJEC T: Objectives For The Seabrook Exercise On April 22, 1988, the Nuclear Regulatory Commission (NRC) inquired whetner the Federal Emergency Management Agency (FEMA) could support a cnange in stheduling of the full-participation exercise of offsite preparedness plans' for the Seabroot and Shorehas nuclear power plants. As you know, the Shorenam exercise was conducted during the wek of June 6, 988.
The Seabroot exercise is seneduled for the week of June 27, 1988. It will involve the testing of offsite plans for the New Hampsnire, Psine 1 and Massachusetts portions of the Emergency Planning Zone. Since the Commonwealth of Massachusetts is not participating in the planning and l (\
l preparedness process for SeeDrook, the exercise will test the Seabrook j Plan for Massachusetts Comunities developed by the utility.
Attacned are the proposed objectives for the exercise. They have been reviewd by FEMA Region 1, the Regional Assistance Committee and FEMA Heaoouarters. We have also included the June 7,1988 matrix sumary, by jurisdiction and location, of the objectives to be demonstrated by the few Hampsnire f antee Of f site Response Organization, the State of New Hamosnire and the State of Maine. This updates the matrix in the oojectives/ extent of play document.
All objectives identified in FEMA Guidance Memorandum EX-3 and its March 7, 1988, Menment are proposed for demonstration, with the exception of:
Objective 17 - This is consistent with the policy of the Comonwalth of Massachusetts in that tne distribution and administration of potassius iodide to the general public is not a protective action option in the Commonwealth.
Objective 36 - This is consistent with the Mendment to Guidance Menorandu EX-3 which states that an of f hours, unannounced exercise is not a requirement for a qualifying exercise.
Althougr. it is FEMA's position that there are no impediments to the conduct ,
of the exercise, there does renain an open issue concerning Objective 34 l The issue concerns the demonstration of continuous 24-hour operations !
capacility by an actual snift change. Depending on the outcane of ongoing
,V discussions with the State of New Hampsnire, there is a possibility that an exercise deficiency could result in connection with this objective.
1 l
l I l L.-___-._____________-___. _ _ _ _ _ l
Attachment F (Page 2 of 2) l 0; <s 2-l It is our posit on that the proposed oojectives are suf ficient to demonstrate e capa0111 ties of toe aoove-mentioned of fsite organizations !
(
in a f ull-participation esercise. Please infom us as soon as poss1 Die wnether tnese oejectives are sufficient to constitute a qualifying exeacise j under NRC's regulations.
Since the attached documents also contain infomation on the extent of play, we est tnat you reep the coctznents confidential until af ter tne '
exercise. As you know, althougn certain aspects of extent of play are subject to modification right up to the time of the exerciss, it is important that any version ce kept secure in order to preserve the l Integrity of tne exercise play.
l If you have any questions or cpents, please feel f"ee to call me at 646-2871.
Attactynent As Stated .
O O
1 P
ca ATTACHMENT G (NRC Memorandum From R.W. 1988) F.J. Congel toKrirJn Exercise, Dated June 23, 4
i i
l
'(
k ATTACHMENT H Donovan, RAC Chairman (FEMA Letter From R.W.Surrary of Survey of Seabrook to G.R. Gram, PSNH, 1988)
Facilities and Services, Dated October 21, j-
{
Attachment H (Page 1 of 35)
.m w)'
i a
.r w ,, . m. e ns .c,
. r.
A
- t. < . . . - ph. .
L 1
! Y.. % Federal Emergencv .\1,an..agement Agency ll h'g[c
<ac'--hgrqn
. C,' , fecerQediqpa[NN : . . w- . Bothell.
Washington 980219796
, w' .-
l s.. _ _ . .. ... ' :. ~~-~~:~~~~~'
~
S , ,. , - ._ .,3 W ----- -
- ne tonar 21, 14AR
- . ~,. ..a 1 C"'
- ct i .os __.__ -; .
.f ,, <.. r a gg ---
up ..,> n
.C . h. s ,-
G,anraa a ne==i g ;, j ,
1 - c r n r :/
44 .. .it,i.vcD.D,c',q w Emervancy Peanarwunens 4rni roomnnity R Inrinns .
PSNH, ;W Yonn e.e Civiuson - Vall code 0J-44 P n. nou inn ...
Seahrnnw. Ww Hannanir. O'LR7 4 hat.WdCAUQM' Bene ua. ,,rn e - .
S!*R.IEf"* Annenry of Curvey of 44tsrnna r.<s7 : l i t in g and ServlCes As raquested'by ynor wiaff. ! as forwarding a copy nf t he summary .ind
.f ^ individual call < hen *< o< d in one rabruary 2.1-26, 19AA, orvey of
-(%- facilitles and servicaw in ynor Gabrnns' Plan.
Theme will annw ar tha iinlividual f acili t y rewponne-I lap sinestinn present.ed 4 in un.
Planne (**1 free in call 10 further infnrentinn i* rerluired. ,
Sincerely,
$_ _ $ 3_ D_ . -
t Richard W. Donovan j RAC Chaj reen (nr the Review and Evalitation nf the Sanbrook Of fsite Radiningjcal Faergency Plans and Preparedness r Ericl osuren (2) ,
i cc: Terry Harps ter, PSWH i k
George Thomas , PSNH Michael Lewis, PSNH (j
sk
]
l0f ^
l e
r% l i i l
\
v
l Attachment H (Page 2 of 35) l 1
O l 1
CFM& RV/NTil/RFP/*sr,A73/D2Q7/3-A-AA 1
1 St'W ARV of ti;RVFV nF gragRnnK F ar f f.T TT F9 ANO 4FRVirFA rw henney g3.gn, eogg RostTnwing F.ismitmeni a nel F.nr a
% 7 Ire La* Anhui .u * :. nn en e anaciev .. an6t f,na !ene
- t. Rinlk i ris hn e Anw O.evev. Ro m e w , Va riw ia Rogeu:(4"-JQ e4 I Ves V*8 2 Vanu - 311-14 ai l
- 2. ?.*
- Rum (nonnoy Runew 20 Schnni Rogew Ves Ws i43-J" Jitn l t
- 65 "I Ch 41:1. )
3 inz Ant C. ig n,* n y An=*w 13 iJA w 46=n Yom VM J 'da rn t tiviti Riew Annew 91 gneet nei 3A finw have 40 Van Veg (49 wa sajnri6y. r*=t have 20 me.nIw1 5, Parpnf Ron Ru m p w i VM ri m 9 Igtipel up 3A finw hMvp EO yen Y#9 30 luiupu (AS-71) 5 Vanu 1 Wh**i Chnir Yen Veg A. Paton Anw Run-w Signeel up for 16 hot wiuh Yes Yes in meet and sign op fnr A.
(AS tn 71 ment >i
- 7. Centwe f or- Aug In Romew 104 Romew (14 Arinits) Yen Yen 15 Whp.1 Cha i r- Va's (1A-22)
R. Wearl* Run Anumm/Vaetu (nam i t t ert 100 hot have 115 tn Yen yen
))A nnw wish to mign up.
(A5 bomen hold 44-4A en,
) Whwel Chair Van - holds R 2 Wheel chnle Vann inld 3 2 Hntr. hopes hnid 14-22 8 Mini-ennchen - 2b30 en.
10 Vann 14 each
- 9. Patrk TPMnapnetation Bunen/ Vans 170 Vehteles Yes Yes 25 Rosen 43-65 en ,
125 Vann 11-14 *n l 20 Wheel chnir V4ns 9 en.
- 10. Big W. Tranupneratinn Boneu,Vang An Bowew 4" Yam Ye 10 Vann 30
~ Attachment 11 '(Page 3 of 35)-
S
)V
- a. . w , .. . .e 4 .,.e........ nd ron.
% item u ., a m ba 1,.ns w ' a nn e,. . *
. , nn , . , 4 , .. .,a,e 't nA . r u e. t
- *nwww 110 Anu,. . 23.Ag ,, y,, , yn Wrriewyne,4mith Anw 12, *.u n tim e Aug I.i An=*w 1A Rowww - A5 e.a Vue Will i Van - 79 asinit u t '4 fintw Anw in Anup*,Veng 114 Anwww 4R wa Yom Nn .
~ ' M V,i n u -
- 2-15 6 WC Anwww A wa 14 W'Minn*y Anw rn Enuww Nonu
,, . y r w e.* n e m ea n n eael Yew Tn ons ;n w.ign A . a rn p i i ?. A
'% unluem Anw ca Anuww ?S howeau - 15- A3 ,e nt) Vree To wwvuoni ovwr=8hp t nwet
.lnat n w
'A : yviw e now in Anw w enem i s t art in 10% bowpu hnt Yam 8 Nm
. nn.-f l they nnnid one have =ign-o greamanf r=r 8s t e t
- Ar;hnn i Inns elem a ras i .
/% I f ul i f;w i .*
- e.e f t#lp i i i Hg i.O A -,
./
-_t
- 17. Durenw . Aelnii d en*** Ashn i a anf
- 3 Ambuleau ww (2-) Vee Vem M R*bnisil i t at inn V* h ir 1-9 f elop-eniing nn w ie.** i e;hn e r parlent= (2-3)
Vem Ypm
- 14. W elbnen Modenn Ashu larn se 10 Ambulaneww M W.C Vann 12 2 Crilital carea Vdnu - 1
- 14. bywinta Ashulence Anhulance Pene ws.il 20. now haw 22 Yem Yes Vanu 10 W C Vann P e ns i m esi nnu han 12 - A-A *4 to, rainliin Ashulnner Ambulance pene iund 2, #;nellel f urn isit YPR 40 up in A anre nahulances and up rn S W. Chair cars Rock]nghne Ambulance' AnhulnnCPn Peneippel 2, has 3 fne LOA Yes Yas 21.
and ownn 4.
Ashu ,ncen 2 Ashulancas. 1 Van .1 es. Yes Yer
- 22. Wedic Ashulenc* 2 Ashulance* A Ashulancem, 1 Wr. Van - 4 Y*n Ya4
- 23. RAI, Ashulnnce AshulencPm Prnei M#il 1 ham la avajl- Yes Yes
- 24. 9tavim Anhulaner able if neederi.
(G'
Attachment H (Page 4 of 35)
O I i<
E s ti s Taiw i tiir 8
- .imeaime.sii e sisi (' o r g .
umw anne n, en -4tm . m iin i ,. u w . , n ,. . . ; i y , , , , ,, i g yng i o n ,. ,
M- %riea e w i A mina l d ns ** Anbin i, ens w a Amhni,ern we V au Vow 2A. ? .I Oilurin A s hani,ene w w c,s i st h ea h,.nl 4_ ,ent w i l wil ( 04 Vase yn
, *
- sir ivprw wenilel init w e arn .
2" '.'ww e n e r v eni r i ".. wing Tow T r.or u s
- Triw T r in_ u w . 2 T r or pr ps Vem Ypp wi11 Inw 2 yeab le; lou w.
IA. Volgun.w ",,w i e. g T,.. T e n, = = < ,. i ii th y Ei.iv in .ane.pl v =* No
!.OA ,e w sie ivwe w usenlil nos l *ivo.
70 " idely ' s "owino "ow T, n, u_
% Tow 7. or u u - wnem e ,i n Ypg Veam i; .< r r y 2 vwhieiwu "O I aelw e*w e Arsi n N w rid i s- Tow T rier7 m g
- Tn. f r igy u g l
,7 4 p p i , g 2} y ,, ,g Ygg 9
l l
9
Attachment H (Page 5 of 35) d"P"'"E E a 0* f- 9n nnt rit, rping , nc cony c ,v i . ,, r i t. c .hrn ,n ot n i,, v,..rv ;4,. 11ti . w,ui C .* ev e r a w rahrien c y 23-24-25. QAA N _ gl f g g I
a l
1 v
1
t i
Attachment H (Page 6 of 35)
O FFMA R N /*cei ra w t lp-O-s.15ennrnnu / 2 '24 / AA Va= V**
NMV %,eyn linve f.nA (ntifract Helln. I'm F.lennnr ramtle a nni 1 .n rir for the F*<leral Emergancy Wnngement agency ment .* n re r.verwing the 4*ahrnnk Plan on nrenarrei by New Haapanire Wnure anni unhe t s t eri in the Nuclwar Reentatory Onesiuminn anel nur agency.
a few yorstions
- I woulel like in verif y ynor rarilitien and servicam. ,ind have that I wnn ial apprec ial
- y e u s t- anespr e rtg Date 2 / 2 d /10 A A ? lee ' S O%
1, Onenany+ Rncirinvhme An= 4*rvice 2 L ee vif insliv ishin n unpuu s ng i n f In#{w ti*his 1 E' an* A 1 * -Jd A AMT . _ _ inwn-wign o t*v#*e nr Agr .,ni .ish New h epunira V,i n k * * ) Va* !
A. nn you have a R Engriurrog-
'n'h m t r e w ou ri;* w h ,e v e yeui enmeisted for tiwe whno ist wn *mpegency rpepnner he respe a red f or A*nbronu? An=== 'J- *!ane 2 (Vehir1.e ..h netv cwi$
Avej]4hle- Sava r.il-w e of Sino r C. Capne t t y nf V*h ic l**? Rumpu 27 tn 40 Wn 11 rn 14 Ambulance Etc.
D. Mohillen t inn and Orpinyennt :
Are all ragnoream ilimpntched Crne nna wingle point? Va* f*tatinn avenu.
In cre. tan )
if at enre than noa i nc a t. i n n . name locatinns and how many ar. each Incatinne v/A Whnt is t he ynor normal lutninema une for these vehicles? nay Shift chart.c 5,evic, Off Hours or Night Shift E. Personnel:
Rnw enny tirivers (rtualif ted) iln ynn have? 15 full time drivar*>
F. Cosaunient. inns and/nr Call out Procedures:
How sin ynn enesuniente with Drivern during noren1 whif t*
%ev ..eindically call In (rndin/hepper/ phone p n r- radine How tn ynn enesuniente with nff-duty Driverg?
i Phnne enil aut Response time ghnold Aenbrnnk r erpie n t clispatch nf ynurOn bumem, etc..
sinnses nnw.
right nne? annenr Qn sinus =. nff-,luty poploy*pn? 1 2
}
! f
Attachment H-(Page 7 of 35) rN '
\
.. lV FFMA RX/recirantle-O-sahnornnus2/24/AA NMV ways have (OA V-e con t ra t:t Va*
Helln I 's F leannne cautle u nr1 i enra for the F.ad.arn i . Feargency %nngemen t Agency and we are review ing t he Senbrnnw Plan am p r o pss r eti tiy New Haapanire Yn n ir .a
- and u.neitted in,the Nnslpar Regulninry romaniew 'an and nur Agency.
I anuld like to verify ynor faci]Ilieg and =*rvicem. .unt h.e v e = f ew spient ionn thnt ! .nn bl a ppreat ix I
- yenir an==* ring.
- 1. cuennoy- ne An= fnonnnv Onier ; '7 4 /10 A A 7iset *Oa14
- 2. Nae of f neliv isinn i =p nuing in An ev e. noe
't . Phnnet 817 tAQ-Aa?1 Tnwn.
A. nn ynn hav wign d f ince- nf Agr ..ni .ith N w W.aspunica V.in k p* ? V.*9 R. R*=nore -
'n'hn t i a* *t an r r **
- indvw i nti enme e t f ail for own unnnld an **prg*.n'y regponme lip rwon a rwet for C anennai in Schnnn miew = i Vuh le i w .,nriv*ree A va i l .e h l .* * # wwu rvi 1 w w eif Mone F411 d
/
/$ g C. ca pac i t y n f V b i tt-wo Runen 41-4? A.in i t . nri As i childe.n
\
D. Wahillentinn nnel n ptnyment: ,
Are all resnorcem dispa t ched f rne one s ingle point? Nn unw many inentinnn? ? l If nt enre than nna Inention, name inent. inns and how enny at ench locatinn: A in A .e t one Incutinn a nel 12 In 14 at nther 1mentinn Wha t. is the ynnr nnrent hominent nap for theme vehicles?
Rnning nf s c h.in i % t nelen t e 08y Shlft was. Off Hnnrs ne Night Shift E. Personne1:
How anny drIvern (einnILfled) do you have? 25 rir Ivar*
F. Comennicatjnna and/or call not Procedurent Row dn you eneenniente with Drivers during nnraal whifts (radio /happer/ phone)? Radina nn ennt hou-a. fotherwise enll in)
Rnw do ynn ennennienf * =iIh nf f-dut y Drivers? Tal.anhnn. f. I g t Responme time whould Sentirnnk r ectua n t dispatch of your busen, etc.,
right now? *. einntwo en An s innt ee <t a na nel l n a nn tto, o f rin v u nL g
t i ne. . . . .,n .,<,.... nf,-,b,,, api.,,. ., ..e.
3
Attachment H (Page 8 of 35)
O ITMA R U wecirdwtlp-n-sVu.nnronn,2/24/AR NHV wayn have f.O A Vee fontract Va*
Wallo. I'm Flennor Castle arni ! *ner for the Freiern i Fmprgency Managemen t Agency ann we are r* viewing the A*nhennw plan nu prenared by Nee H.sappnire Yank ** and untie i e 6 *ei in ihe Nur1*=r R*gnineory rnesi=ainn and nur Agency.
t unn iel l ike i n veri f y yanic facilitinu and usarv i ram . dnr1 have a few #1uestions that i won ial apprec in t
- your answering.
1 roe rwe n y . Fne An= n t o. 2/24/toAR *lmetin*27.
- 2. L ow of ineli v ionn i Sp*nning in *rinn Fnv
- 1. Ahnn*- 417 "Q1-A10A Tnwn-A. P.o ynn h a v e. < i g n *,6 r ,. e t e r ni age .,n, ,irh g,w gs p.nge, vang,,3 ve, R R*wonry w-
'n'h u t "w eeni er w w h,e ve ytne enme s l i wei for ne, whnis iel an ***cgenry r*w pon es.
h* e-noir *d rne s ,.nenn.1 nn. *1 hn=*= - av rait et-we o netv* cal Avus*abl* fort Fay shifl9 Viuhl Chifl9 14 Hintr7 .**
- r. . repneity or V hiel O Rouw, enmeh*= - .1 A =*ae=
- 0. Vnhili7n t inn anet Npinye*nt :
Are all r==nure w dinpniche.d frne one wingle painto Va=
What is the your noreni hominess une rnr thane v*hicle=?
rhnre*, ?..or nner ine Day Shift
<me Off Hours or Night Shift E. Personnel:
How emny driverg (eguntirled) do yrns have? 2 5.n r o l l a nti nart eten.
F. Cneennien t ions and/or Cn } } out Pencedure=:
How dn yno ca.neunicate wiih Orivern riuring nnren1 shif ts (radio /h**per/ phone)? lelenhone Inn rudine)
How do ynn enesuniente with off-duty Drivers? Tulanhan*
Response tJoe shoulti Swahrook request djupatch nf your buses, etc. .
right now? i n i n 2n ein. nrf. duty employ **s? 20+ minutea. Have 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> anuw* ring =*cv6ew .ur nhnne and hawner O
4 k
{
1 1
I
Attachment H (Page 9 of 35)
- ,\
l V)
FFMA RV/*rei fen t lp-O-s3Mennenns / 2 /24 / AA
'[
VHY maya have f.0A We contract V**
%11n, t's Elannor c4=t) wnel T worir for the Feil
- ra l Emerg*ncy Management agency ants 9 a t-e reviewing the S*nbronn Pinn en preparen by New Hannanjre Yank *e a nsi uuhe i s l ead in ih* Nncienr R*guintney Onessmelon and nur ag*ncy.
f unuld lika in v*ri f y ynne f acilil len and nervicen . and have a few rtuestionn
~
lhnt f wnulil apprecini* ynor nnnwaring.
- 1. Fnenanyt vnenshnn A. . 0.1*: 2 '24 / S Q A A . Tien. t o . '4 a
- 1. Vaan nf tentiv islun i u ppn 'aing en m.ev c..n i r e* v
') . phnne A17 AT2.1?MM Townr
- a. Un ynn have eignimel f*tter nf agr**m ne .4 i h hw Hampenien Vank*** Va*
4 N *mnn r r w -
What ".*anure*= sie ve you i;neesir d for nup w hno lai dn rewrgancy camponne ha r arpl i rest for Ewahe netw1 Enw w. Way, w a g n *,, nn rne is nn, have en avn,1 ht- .. h nr.vnew : % in in*v .nn i,1 .**e en e n a n., * , nnt ent e t
/N Avn i 1,e h i 1 i I y - When* var nni air *=dv nne on enn
'f )
\d C. Capnell y nf Whiele=? Runen Jo nn en ior i e v -*.t have 20 **nte D. Wnbilizat ion anti Depinyment Are all r*=nureeg ilinpntched frne one wingle point? 3 How many locationn? L If at enre than un* Inentinn. name Inentiuna nnd hnw many at ench locationt 1/.4 of hn=*= de chevennt a nni 1'A at Reitan What la ynur nnreal busin*nn uem for then* vphiclen?
Reenlar ennen:*e finn Runu Day Shift and off Hours.
F. . Perennnett How many alrivpen (rlualified) do ynu have? A0 a t *med un ,
would have i n cher le on hnw anny have alrenrtv taken Cenbronn testnine Ir ; casennient.lons and/nr Call Out Pencedur*nt How do you communicate wj th Drjvers during nnrenI shif ts
( rad io/ heppe r / phnne )? R art l o u nn enen nthere en11 In na r i nrl f r8t l l V .
How tin you enesunica te with of f-duty nelvers? t al*nhnne R*npons* Ilaw whnoid S*nhrnnk resgur n t dinpnich of ynur husen. *fC.,
right now? los rtint*1y (Have Driv *r= available)
Off..htly *mninye**? a t o An m a nn a *. tanonit inir nn hne* Inentinna.
f
(' Note
- Cryut al Transport (Linda Carroll) 232-1375-7A now gernges with Mornthon and bne 60 hompn. Wou l el like to sept and sign op for t he Swabrnon Responen.
5
)
J
.__ l l
i Attachr.ent H (Page 10 of 35) ]
l l l i i 1
O l
l FF.WA R X /per i ra u f 1 -O-s.1Rean tirrinar / 2 /24 / AR VHV w,i y n h,e v e T.A A Va= r.nu t ra c t V**___
Hello l's Flednne ramt1* and i .ork (nr the F*elerm i Faser**ncy Manngement ;
Agency and we arp ** viewing t'1* Ceasbronn plan nu p r
- na r er1 by New Hdepsn s t e l Vankw* a nnt unne i i t *cantip-0-s1R*nurnnw<2/24/AA NMY ways hav* TOA We
,nntener V**
Wallo, i's F.lwannr castl* arut i anrw fnr the F elerni Feargency Manag* ment Agency ,,nri ww nre r* vie. wine the habenna plan ,* prepated by New Hnopunire Yank nnel eunmi t t <i en the Nuclear E*gitia t ory Ones t en ton anni nur Agency.
I would like en v*rify ynne racilitlen non wervice*, ,and have a few quentinna that ! .nutil appreciate your an=wering.
nate- 2*24/10AA Time; to+M7 1 (s: spa n y ? Dainn Ane A
- r n i e. Daton
- 2. Nnen of 1 rut iv ninn t unenw ing i n
.1. Ohnne! A17 M A 2 -QQd't Town; A. Un you have* a wigneal f It.ar of Agroament w i t h N*w nampanire V,tnk**? V*g R, Remnurt*u-Whal **=nner*w hav* ynn enemittwin for new abnn iil an *me rg*nt y ceampnnn*
h r*qu i t wii for Gabron=1 Anwww 'Srivendiiv wivnwn nn fna 'A hot
'I wish.aw to me
- s a ni t chMn** en A dw once rott f a ea l ha s 4n e-nme s e enree t Availabl* for: nay Shift' Might 9hift' 24 Hour?
7.w "*
I vaineltv =*we AM. **et e at C. Expncity nf V*hirl*=?
\ j _
0l Mnhil j /n t inn anal D.aninyment :
Are all reanurene slippat che 1 f rne nnea Mingle point? vue What Jw the ynite nnrea l lutninem8 uwe for these vehicles?
Schnni ch iIsle n Day ShI(t Off Hours or Night Shift F. . Permnnnel:
Hnw many etelv rm (egunlif teel) ein yuu have? All 11-14 are cart i f f eri rerular vi r i v* ru A e ( pn evi on f or Ferrennev R*unnnwp F. Communient inna and/or On11 Out Peneetlurent How dn ynu enamonicule with Drivers during nnreal shifts
( rarlin / hrepe ri phnne )? 2-wav rariina How dn ynu communicate with off-duty Drivern? T*1*nhnne
- te.,
Respons* ttop whnutel %nbrnnk rpepie n t ell epa t ch nf ynur hunem .
Off-iloty eeniny*en? At nicht e tus i d right now? M 10 nr is minnt*=
taka 1M sinen*= ti rne* e m 6v en el l e nn e ch
' \
7 1
Attachment H (Page 12 of 35) i trida E x/ece, ca = i 1 *-n-a.LSer nenna ,2 / 24 / A A i
NNY pyu h,s v e LOA Ww runtreet Va * . )
'.ip l i n . i's F1* anne ragtlea meni i .new for e .iw Fe.l r e i Faergwen;y Manngement.
Ayz.ncy ,enri =* are r* viewing the Membrnnec P l a ti nu pr epa rert by New ri,e e pun i r e Wnher a nei unho i t t *st to the Ninflen r Regula t ory r ,emimm inn anel nir Agency.
t wnn itt 1 ;'n e in verify ynor facilit-inu a nr1 m e rv t rl* n . ,s nr1 h a ve a f ew iluent ions shnt I wonist appr*r in s
- ynnr answer ing j 1 roep,iny: 9ent** t o r- IRnu I'nenanvi na t e : 2 /2 8 /10 AR . Time? 10'00.
2, Lee nf initiv isina l wpenning in tas 6r R-11'
't . Phnne- A 17 - M '4 5 - 2 0 A'l Town:
A. r.n yens have a u i gnen f .4 4 f e of Agreampnr wieh W w Flempentr* V,eniten ? Vea !
R. R emun re**s ?
Whms e*einarreau have ynn e nam e i l *.i for nup sn#ntial do em*rg ney rwepnnse
- in =
- w '94 how-w 'M Whe*h chair Vane he r*itu s ren for G nnrnomi Ava 6 lable* for- hay Rhifli Night Chiff7 2A Hour 2 V,e nia 1A *1 nr ? 't C, Enpnejiy of Vehis;)*u? A n u w ei ai Aeln) t s n, Mrhil 1 en t inn arul nepInym.ani -
Are 11 reunnre-w ilj mpa t chers f rom on* uing e j point? Va4 (P*mhnrfV1 hfhn t i< Ibn yenir ruiren t bus inega n=* (nr these veh{cles?
Mrhnni t'h l l r run Tennynnetutinn a n ti (norint Filier w e irin d nsy Shift off Hours or Night. shift F, Parannnel-t'n t n 150.
How many vir ivera (ynn i i f (**el) ein ynn have? Var (*=
F, r.namunientions antisar rall On. Procedurest 2-way rariina .
How inn you comanniente with Drivern iluring shif tm?
Hnw dn ynu comannjente with off-elisty Drivers? Whnne <vut*e Response tiep thnul:1 Senbronk requent <!!tpatch nf ynur huses, etc..
right now? F*tient* IM in in minuteu ri a v n r nicht O
A i
Attachment H (Page 13 of 35)
}
I I
~J l
FE14 A RV / *.:e r ra n t l *-0-s.1%.n ornner / 2 '24 / A A VMV wayu havn (OA '/ = . Enntrnet Ve W 11n .'s F1*mnne C,..stl* net i wnew for the F el.*rn i Fe*rgancy W nngement Agency ,.nn ** re r* viewing th* Cenbrnna Plan wm pr*pwr r1 by N*w ibi s pw n i r
- Y nmee anit anneist e4 en i h* Nuclear R*guin t nry enemism inn unit enir Agency ,
f wnn !<l 1 ;'m e i n verify ynne r,ic i l l t i nw and wervic*w. ann have n f ew % =nt inna that I wnu hl appr c ia s ytner anew
- ring i
- lmet 11 1A. 0
- 1. (napany- '4 myi Rne 0,e t e : 2/24/1CRA '
n,iwn anet Alan W*avia
- 2. Nas* of T rnt i v e rinn i unenming in
.t . Phon *: **i mas sti . nwn Y.a n A. % ynn hav* n e i n *,6 fwet*r nf agr**=*nr wiih N*w hopanir Vans *?
l R. R anner w.
^4hme :=wnnrews h ,. v e. ynn enmasat*d for nue ehtue lal an *mergency r*=pnnme ha r*quitro for 4 nbronw? 2..=*= . omm i l i wil in inn but nnw hava 119 in enom.tt n ill have 110 1, I'>M hv Anest 11A hnewe ihat en e b i Veh i . .= wiih n,ev rui7
,n 1 wh ee.1
) c. . rapac i t y of V h ici e ? non*n La as hoteling dJ in .! A'l m<lu lte 2 haif.hi_ p a l
(
"U/ thnIe van hnldInu a Iwn whwei ehair vwou honelina ennen . nn t il i ng 2% I hniding 74 hnliiino 1,1-?2 h ,. . s ..ni 1 hn ist i na 10 ann i h n l el i n e 21 ? V,i n q n n i ri i n g 14 ne w w *n ow rw .i n ri ,
A V n. ion id i ng is now. ny r.
D. Mohi l i /u t inn and fleploymen t .
Ar* all r enure 9 dimpat ch*vl f rna nn* s ingie point? One What is the ynnr normal housn*nm ove for these v*hicles? .nay Shift All vehnni chil.ir*n ivn..
Off Hours nr Night Shift E. Parannnel:
How many drivers (sluitilfled) do ynu havw? Over inn full anti nn e t-ttoo.
i A4 hMvp enna t hrnnah tembrnn6r Trainina F. Cnmounient inna and/nr Call (Nt Prneertureg:
Row do you communiente with Drivers during shifts: 2-wav rmdinn How do you enesunsenf* wiih nff-rloty Driv *ra? T*l*nhnna-Responww time =hnn]d *i*nbrook requrut dispatch of your hilsen,live etc..in right now? to di=6 in is e6e.ntee off-duty emplnyera? Waar
'
- tnwn wn c rui l :4 d i una t ch in 15 m i n n i .e j
x- y' A
Attachment M (Page 14 of 35)
O rEMA RXiecc Castle-0-83Seaoroox/2/24/88 NHY says have LOA Yes _ rontract ,Ve s,,
castle and I work for the Federal Emergency Management Hampsntre Helin, l's Eleanor Agency anc we are reviewing the Seaurook Plan au prepared by New Yankee and submitted to tne Nuclear Perulatory commissio that I would apprecsate your answering.
2'24/1988. *lse r jjjjjL.
Imuw) Date:
- 1. Company: co rk tranwoortatinn 2, Name of Individual speaking in Vine *nt Savill 411-240-1955 Tnwn:
- 3. Phone:
Hnspanire Yankee? Y*s, A, Dn ynu have a signeo Letter of Agreement with New B. Resources:
se What r= sources nave you committedsvehirle* for use abould an emergency with Driverw n respon mu new '-n be required for Seabroox?
Available for: Day Shift? _ Night Shift 9 _ 24 Houri _ , , , , , , , ,
'e d s two t vers _
C. Capacity of Vehicles? Buses di adultw and 65 children Statinn Wacons nold 4 iHe committed Vans. enee hnidine 12 nthers 15 '
for 25 buses and 125 Vann (Mnt 1: vested and %nt :9 seated 1 Whene rhntr Vanni D, Mobilization and Deployment:
No _ How sany Are all resources dispatched from one single point? _
locations? 2 ,,
locations and how many at each If at more than one lucation, name Avon location: 10 at Woowter end 1*9-1R0 mt What is the your normal business9pecial use for theseand Needs vehicles?
Aeoointment work for___
j School children transportation,sto snon, medical appointments and homettal runs __
Sr. Citi7 ens E. Personnel:
200 plus How many drivers (qualified) do you have?
F. Communications and/or call Out Procedures: 2-viv radios _
How do you consunicate with Drivers during shifts How do you communicate with eff-duty Drivers?_ telephone __
Response time should Seabrook request dispatch of your buses, etc.,
with 1-4 line managers and a right now? Have cellular phones Dispatch would coordinators enen with a 20 driver Off-dutynottffcation employees? list. _jame as above _
be assedtate after notification._
10 O
1
.1 r
Attachment H (Page 15'of 35) ]
1 i
. f%
-f )
v FFMA EVirreirant( -O-s35*nntnnk/2/24/AA VMV unyu have LOA '/.** runtract Va*
p Wiln. ;'s F1*unne f..atI* wini f .nra for the F elern! Fenrgency Manngement.
Aeenef y ann w a rea re v i*w ing t h* swahrnnw pinn nu preparert by New Lepunit e Vanupp nnet unnai s r esi in the Nnelwar Ragniatory (nesiuminn anel nur. Agency.
I would li'wp in ve.rify ynor facilllinn nort werviel*M, a nti have n (*w sjuestjonn that f wnnial apprecinte ynne unawareng 1 rnenany. *le W . - n = ne.re e i nn thw cien**6 %s t e ! 2/24/10AA 71eer
- 2. hem of T enliv e rinn t wpemming in K,.r n
- 3. Phon *? A11 RA1-dAP? Tnwn:
- a. On ynn have a wigne.el f tter of Agr* ment with Vew Waspnntre V.t nW o.*? Vee A R*unnecem-Whne rpenure u h ,. v ynn enaatitud for n= unno til .in *** rge.nry rwe pona a 2 0=== en '/-n= s-h* rpetu i e -el rne 9 aeunnao Ava il Asin for? 34y Shira? Vjght C h i f i ") 24 Hour 7
-n\
/
- c. rapac i t y of V h iel*=o anup. an.at vanut .n 7* . n in mini ho.
rn i
\
D, Wnhili/.nlinn and D pinym nl.
W Wow anny Ar* *11 re unnre:ww d i upu ch e.el f rne on*
- ing ]
- pn i n t ')
lenlnainnn? 1 Tf ni enr* than nn Inentinn, nne Inentinns anel how anny nt each 14 at a w h i n nei loentinnt 1A mi W: 1 f o rri . 20 ut l'ntown What is the ynne w remt huminees ump for thenn v h(cI*m?
.hnri #Ahnot "t 1 1/1 nere**nt enchi Ony Shift,,
Rehoni trunwil e-of f Fours or Night Shift E. Perunnnel:
How anny delvern (epin1(f teel) do you havn? ?O iWill ha ' em i n ari a' senhennk in sneine toma i F .- Onesunientions nnet/nr Call Out Pencedures:
How dn you communtente with Drivern during noren] shifts Telenhnn**-
2-way radine n nri (Rm How do ynn ennennicate with off-duty Dejvers? Tal*nhnn*_
Reapnnen iinn uhnolel Rembrnnk rentien t dimpntch of ynur husea, etc..
Of f-dnt y espinyaris? Waviene 19 minut*w tenut O right now? M. e6nnt*=
I elriv r= ltve eInew in farttt1v v
11
Attachment H (Page 16 of 35)
O' FTWA RY/*cer enue le n-835*nnrnna /2/24/ AA VWV ways have I.0a Va= Contrar't N' n I
1 Melin 's Fl*nnne rantle u nit i mo rir for shp F-ilerni Feargency W nnvenant '
Agency ants wea nr* reviewing the Ernbrnnw P1Mn nu prepar*<t Ity New O mpunire vank** anet unne il l wil in the Nue:lpu r R**u la t ory enem i nn inn anal nur Agency.
f wnulit like in verify your facilitipu nnd servicen, and have a f ew stuent ions 1hnt 1 woulet apprprinte ynur unawaring
- 1. rnspany? va c.rwenri te i t h nate: 2/25/1QRA. Timer 2 30 7, . Le* uf T ntiiv isinse l s pwn w i ng in 41 ". san c.d<hl
- 3. Phnnee t Ani-1R2 022M. Town:
A Gn you have = w igneel Le t t er nf Agen eeant with Vpw Hampanir* Ynnk p*? Ve*9 R 2*=nurcem- )
1 What --ennerpe have ynn romm i t t wel for uwe ahnulil an **prg*ncy responne he* r*quir-o for 4*nbrons7 hapw n TV h6c1*. .ith nesvarvin Avntiable fort hay Rhifti Niuht Rhtfl? 2d Knur?
('. . entun;i t y of V*h is;1 *gi Euu*w .ta adult and AM chililrpn
- n. Vnhi)i/*Iion anel Depinyment:
Are all runnureww diwpelci,ett frue one ning)* point? Vn Rnw sany inentinna? ?
Tf M. anr* than on. I nen t 11,n , name inentions and how many at ench J oep t lon e s-as ni We r e . mn ,- a r.d an-as ne concen t eiwn .
What la the your normal hunine== une for t hese vehicles?
tehnot chi).tran <nec w t. Tennenneg a t inn A chartae Day Shift 'j off Hours nr Night Shift F. . Personne):
Hns anny tirivera (sluallfled) ein ynu have? rorrentiv 40. With n*entive nnpeninvaant hard in lepen full utaff F. Communtestinns and/nr call Out Prncedurent How do ynu enmounicate with Drivers during normal shif ts: 252 hnve g
j 2-wny entli na . How do you caismuniente with nff-duty Drivers? Talenhnna Response time uhnald Senbrnnk requent dispatch nf your buses. etc., /
right now? n to an ein. Off-duty *=pinymes? snea. _
ff f und era t enet h i s enrrectiv Wer.r*ene-tellh iu in WA and Timberline
}
Tranennetatinn i= in N Hnenantre enannnv hun 500 humpe 9 t'h no l Roard in H j weid their enseite.nt wun en achnni rfryt. cnv. the innr**wton thev were l willine tn tnonernt, in nny wnv thov e rut l et w i t h VWV hut ellet have tn f airm intn l j
vnnuidwene1on ohlteneinn tn Schnni niutrtet l I
8 12
1 1
Attachment H (Page 17 of 35) l
,, 3 i /i i f.
\v/ ,
FFW A ES'/ *cci f an t lp-O-aMe na henow / 2 / 26 / RA VWY unyn have inA '/ = Contrnet E Hello. I'*e Fleanne r,.wr1* arid I work for the F* ele rn 't Fe*rg*ncy Manngweent Agency anni w* pr* r*vi* wing th* <*nbrook P t a ri ,iw preparert by N*w Hnspanire Vnnk** nnd muheettwel in t hea Nuralene W*guin t nry (nesimminn and nur Ageancy, i would li'n* tu verify ynnr rnc611tjen and wervicen, and have a few questsonn
~
thnt f would apprerent* ynnr answear ing .
nale. 2 /2 A /10 AR , fleet 10+0A
- 1. Cnennny- nun ha r anu en Vnew nf i nell v iehin i Spenn6ng en -hnews nonhwr 2.
S. Phone: A11 941 iadM Townt w i t h N'*w idaspan t r* Vank**?
I A. On ynn have d wigned feetter nf Agr*. ament Ven. anni mill vign a enntenes*
R. Reennetwe*
What reaanurewe have ytni enme s t r ead for nue uhnold an *mergency rempnner 1A R u w sa w 4 1 Van IV hie 1*w with helvveel he rer}ntrett for 4*nbrnme?
-Avnilable fnrt hay RhifI? Wh e.n n wel*.1 g
As vnn as &<ini t <
c: capacity or vehicie.1 k-f Anne.
Mnbl1 lent inn and ne.ptnymeans t 1 D.~
Vn Hnw many are all rennurewn dispnt ched f ene one wing!c point?
Inent innn? Tvnvahnrenuth f.nww ) 1 unel tirivwee Etne*e What 19 the ynne norent businetsu une for t heme vehiclen? 4 t*niv n r f.nws.41 i.
ist for .chnni hn. n ?st rne n,hels chee r t w e.
r l E. Permunnel:
Hnw enny drivern (spmlifl*d) do ynu have? 2 A firivers F. Cosennientions and/or Call out Prneedurent 1'
I Have nn Fne ein ynn enesuniente with Drivmen during normal Shif ts?
e n tii nu nn how,= *, rent s with p.w.y earlin nwed at t'n i v . nr towell T*1,nhnne en11-out Row do you consunicate with of f-duty Delvarm?
! Response time whould Seabrook request dispatch ofanoa. your buses, etc.,
right now? o in an ein off-duty papinymes?
l l
\
1,
\ \
s i l
1-I C--- __.~_.__._.L.____ _ _ _ _ _ _
Attachment H (Page 18 of 35)
.l.
\ O
- f TFWA R Y / *e rf i r,e n t 4 *-l')-4.1S*M hrnnk / 2 / 24 / AR NRY wayu hdvp ifia V*e Enntrnet Nn Welin ;= F 1 *n nn e r,. . t l .a neut i .nen rne i h.a F*d*rni Fenrg*nt;y Manag*mant
- ~
Agency ,nui we -r r* viewing ih* Spahrnon p l a n ,, w newnwrert by New Nepunire Yn n h w.* wnd annuitied in s h e. Nor:lene R*guininry (nonimminn anel nur Aguncy.
I would 'like i n weari f y your racil il len anit uprvie w. ,ind have a few questionn
~
Ihat f wnu nd apprear in t
- ynne answering 1 (nonanyt "Inre nn- nate- ?/2M/1QnR. ~ime: 11 10.
2 Nas* of fnrtivtitunt wpenning in Kathv Finr*
- 3. Dhnne A17-122-142A Tnwn-
{
'l A, Un you have M w i gn*e4 t t t
- r n f Agr*.am.an I wiih New Hampgnire Vankee? Va*
R. Ragnure*4!
l What e w e nu rrl p* have ynn enemirt*d for nup w hnu ld ee n *mprv*nc y r**ponme h* r*quiren ( n e- %*n br non ') :nwe= 114 V,e n e 1' Wr Row 1 w n r1 Wr Run 6 (Vehitiwa with nrivaresi A va i l,e h l ea fort n,,y shirt? Vight Shift? 24 Hnur?
J1-dA Van 12-1% WC. le hnlds A and C. Cupne i t y nf V*h ic l yg? Rouwm amml1*r wr holet a ...h /
l
- D. Wohil i n t inn nnd Depinym.an t A re a ll r*=nnre*= d i spa t ched rens nne mingle noint? Vn How enny I
Inensionu? 1 i
TC nt en raa than on* Incatinn, name locatinns and how enny at each g
loemtlon: tanunw nr**wn Wal, ri 1d a
Whnt is the ynne nerent huminema non for thas* vehicles?
cnshinneinn- tehnnIw S nwe. N.aert u . nnd chuet*r Day Shift nff Hoursi nr Night Shif t l l 1 l-E. Personnel:
Erne many drivers (quallfl*ri) rin you have? f ? O t a usru a . 40 Or**kn- 15-20 1
at Wakaff*1d 1
F. Communicatinna and/ sir Call Dot Procedurent I e How do you ennennicate with Drivers during normni chifts: Vans IPot i
radin unu in ne.i annrns 'n of humeam rariin *nuinned.
! f How dn you communient* with off-duty Drivern? **1*nhnn*
Response tim
- mhnuirl Seabrnow r ear]ue n t dispet.ch of ynur huses , etc. .
- right now? r,en enntntt at R mi. redluu with IM tn 80 min tima ;
fene* nf g.,het y *mp tnyren? tame l
I 14 n.
Attachment H-(Page 19 of 35)
)K l
\
N.
1 FFWA RY/*ctifant1*-O-dR*nrironn/2-26-AA WV un y u have Ina ' '- w * (*nntract i H*lln. I'm Fl*nnne Pnel le neul i ener fnr ih* Feelp rn i Fmpeg*ncy unnag* ment ARen"y neul w* new e*.ve*w.ng ih* <*nhennw si,qu mm pt *pu rwei by N*w h epunire Vunkww a nti u n he i l l e.rl in Ih* Muelwar R*gu la t ney (nam e nt inn anti nu r. Age.ncy ,
f unulil like in verify your facilitieg a nti wervicew, , inst have n.few questinou
~
lhnt t menital wpprectng* your unswersng.
nate: 2 '2 A /1 QR A " tee; 1 fospany Wearinne.v Rnu
- 2. N a se. nf infliv hinn I wp*nning an R obe r t McKinne.v
- 3. Phonet A17 AAA a117 Town:
A, nn ynn have n < ignevi t. wiser of Agr**a nl with W w Haapantre V,in ken?
- v. not orier winnen* ner *meni - ....I t .w uning in enik in nne h I n ww e., nes tw -nvi= o ne nnr ii**e invnivun :n t as enne*113na av awepunen, B, ***nurew=;
What rwenurepu have ynn enes e t 1 *ei for nem ehtuihi nn *mpevency rpmpnnse he rerluirect for 9enbronu? Enue* 10 IV blel*= with he lvarw M j9
\ 24 Hour?
Night ShlfI?
-- M, Avntinhl* fort n,,y thIft?
- r. . Capne,i t y nf V*h ie l*w? Buse* Van Mini-Bun Ashulance Ftc..
D. Wnhili/stion nrul Depinyment:
How enny Arp nll reannurcen st iepn t chwel r ene n n ea g(ngle pri t n t ? l Inenttonn?
Tf at enr* ionn on* Inentinn numa incntinnn anet how enny at. *nch - _ _
]peneinnt What 14 the ynur nnreal huntnean use for these ve*hiclas? Day Shjft r Off Hours or Night Shift j E. Parsonnel:
How anny driver = (e}unlifiert) In ynu hava?
l F. ComennientJonn and/or Call Out Prneeduren:
I How sin you commun tent
- with Drivars afuring norent shif ts 1 (rndin/berpar/ phone)?
/ Hnw sin you commun tent e wiih of f-eluty Deiv*rs?
/ }4
'k Response t lee should Senbrook requent dispatch of your humes, etc.,
g right now? nf f-ilut y employ **a?
35
[
Attachment H (Page 20 of 35)
I
- O i EFWA EX /*ref r in n t l *-O-s,3Sentirfinw / 2 / 24 /8A VWV wayw have LOA
-= rnntrnet Vn Wp11n I'm Flennne faulI arut I worm for the F dweni Fewegency u nngement n apency und w* new "*vi* wing the S e n b rt' im Plan n= prapnrad by New Hnapanjre Yn n k re. no unnai t i el in the Nnelwar R*girin t ory coesimm inti and nur Agency.
t wnnld lik* i n ver i f y your ine i l il l*= nnd werv it** . nnd have a few queurions
~
ihnt f would nppr*ciate your nnsweceng.
5fndunn Aou Iin** Date: 2-2 A-t C A A, *iset10'non e ;
- 1. roepnuyt l
- 2. Vnen nf indivistunt wpenking to Gnnui h trne s ann ce
- 3. Phnnet 411 1Q% AnR2 Town:
V**
A. Do you have. n e i gne.<6 Le t t e r eif Agr** ment with N w Haapanire. Vanken?
1 R. R *wnu rtf es I
Whnt apenurepa have ynn enmoitted frir new whinilil an em*rgency r*gpnnne e net w v* rue %*r '**-enad Roupu 79 he t'actu i r e.rt for Sentican.a7 ennche.e /V hielue wiih Oriveree9 Avnilable for' Ony Shift 9 Who.n ve opnu i s n l M -M )
C. capnei t y nf V*lt it lem? Busen _
- n. Mnhill/stion and Deployment!
Are all rumource.= dinpat ched f rne one eingle point? Yee. Vad f n eri WA lifhn t iw the your noren) business une for t heme vehicleM7 Day Shlft Rehnni Rue anel Rchnni acitvisi e un Ine nee unen rhneter Off Hours or Night Shift r.nonn i e Anm . ':en . rvice F. , Parannnel:
Hner enny drivera (qunlified) do yteu have? M innt vet tenined hv Sembrnnk Communtent.inna and/nr Call Out Proce<lurent How dn ynu enmanniente with Drivers during nnreal shiftM
( rarl t o / he*pe r / phone )? Talenhone How do you cosaunicate with off-duty Drivers? Telenhone en11-nut i
l 1 Response flea ahnuld hnbrnnk carguent dispatch nf ynur hunes, .!8ee etc., ,
right now? Varie= un en 20 'an minute *. off-duty espinyees?
j 1
911 e en n
- v nr *= =*el h i m enen1
- t e ennperatinn n varv willina attitude O
1 Note-l 16
{
. - - - --______-___m
i' l L- j Attachment H (Page 21 of 35) 1 i
I j, . f .j
'l l: fg -
.! ).
I
-I.V FOla RY /*, c , Ca nt l e-fi-sMennreiris / 2 /24 / A A -
Y*w font ese:1 Nn VHV wayn have f.OA Wallo. I'm Fl*=nne (n=t1* nnet i .nrw rne the F rel* rn i Feargency Manng* Gent agency nott ww-nr* enviewsng sh* Gahrosir Plan du prepared by New Haapanir*
Vankww n eut eniis il l
- i in the Nuciwne A*gnin nry Comm o us ion unti nur Agency.
I wnuld li'un in v*r i f y yr.ar f ac ii ll ieu avut wervicen, and have a l'ew rpsen t ionn
~
lhat I wenild apprec in t
- your nnew*reng
- 1. f. i n i (nonnny O vrip e 64 n u en Ont* 2/2A/AA Tient in.A7 in*w War ifnnn anonnt s anneforepell
- 2. Vuo* of imliv isinn i wreak ing t o .f ie tennele
- 3. Phon *: *01-1Ana Town:
A. Bei ynn hav* n uignesi felter of Agr****nt w (( h Gw Hnsport i re VMnkt-d i
)
v ..
- h. 'Remnurt'en ?
What ~enner*. nave ynn enester*,4 rne nun whnuld nn ***rgency r*=pnnne be required fnr b atiron=* Rn=*= 't n M Wfni-Bun p r. . rnpneiey nf vehi,;I*.? munem _ van
.A
- y 0. Wohlli ra t inn nnri Deninyern' -
C e V,e Are all regnurt** iliepnieba rne one single point?
Wbat 19 t he ynnr noran t Iniminwan unie for these vehic)en?
une,rhnetpe _nsy Shift.
unine n==
achnnt ane nnel Cchon a ar s t v il l*=
5' ,' Per.sunnei!
thew onny rir(vpre f ep n ii f tari) ein ynn h*v*1 F. C.neenn ien t inns and /or fall Out Proceduren:
Rar' i n How sin you ennennienie w4 8 h Drivera during .nnreal shif f n Kw 2-way
- ? frannene.v How sin you enesuni ante wit h of f-dut.y Drivern? Tel*nhnne Responn* tfee shoull Senbrook requent dispntch of your buses, etc..
right. now? 1/2 hr Off-duty employees? QRt drivern inented within rfty limitu
- 4n t * - h ow cannte env thev nre eneettted en schant avacontinn in cena af For_
1 weerFenet** n nfi wiun in take their evar'untion i nn t rut
- t i nn u fene the 9tnte I ptil l
- l e n i nuronnea envh* t hov stri nnt wish tn have e l emeri n ar ra s sen t ne
. ; enntenne
_tO I V 1 tv i
i-
-]
l '
- h _ _ _ _ . _ $
Attachment H (Pago 22 of 35) 4 i l
.f FFMA RX/*ccican t lp-n-43R*Hnennir / 2 /25/ AA NHY wayu have LOA S h Fontract _Va=
blin t's F lynnnr Fa n t l e* a nsi i work for ih* F elprul Fe*rg*ncy Management Agene y a ni we are r*vi*weng thw 4*mbrnon Plan ew preparait liy New Hampunire Yank *p neut enhei t t wil t o t h* Nor 1*n r Regn in t nry ("nes sma inn anel ruir Agency.
I wnulit 1ike in varify ynor r,n'i l i t i em a nd w*cv i r** . and have a few ttueurinnn
~
that I wonial a pprec i>.i
- your unawer ing .
nxt*- 2/2M/10AR len; Q 42s m foenany, n r*ww Aeluilanc I
Len nr Tneliv ietun e =penntng in nwnnie Rnve.e 2
- 3. Phnn** A03- AS 4 -1414 Town: unen ne we-r- '.*H A. Un you have a vignpel f.*lter n f Agreeamean t with N*w Haapanire YankPP7 Va*
R 2 p u nu rtle u -
What rpenn erl e hav* yeut t'omm e t t wel f or q u es a hnu lsi an weergency r*gpnnne
- Aenblancpu ' huhi I ; i a( on 1,'* h ( e l ee w he rpelu a red for 4*nbronw?
(Vehic1*e wieh he 4 v*c i1 Avntidhl* for: nay Ahlft? Vfght Shjfti 24 Hour?
C. Capar:it y of V* hic le*? Van 2-1 *n Ashulence 2 If weretcher nattenta_
D. Vnhilitattnn anel n*pinympnt:
Are 411 r*mourc*w allupatched frne one single point? Ven.
What in the your nnremi inin inen s one (nr theme vehicles? Day Shif t Fearpanev a n ti t e ununnre u t inn of ee.hnbilitatinn nutientu one Off Hourn nr Night Shift F. Perunnnel:
How anny deIv*rm (igun I i f { pil) do yrus hatve? ?D-25 houinr i 2f1+ = 4 wri un for Sanhennit irnining F. Comenntentinna anri/or call out Pencerinren:
2-wny Ra tl i n e How dn ynn enesunicate with Drivern clurinE nnren) whifts i o efr r.n.n,*. nhnn.n.
How dn you consunicate with off-duty Drivers? Ca)) List j l etc.. j Responna tien shoul:1 R*nbronk rarguest ellspatch nf your husen e right onw? te== :nnn hr Off-duty espinyren? 9ame- )
h 9'
-l ta t
' - .__-______________O
1 Attachment H (Pago 2 3 of 3 5)-
4 }.
UMA R Y/*etl fn u t l e.-T)-a'lS*g n rnnn / 2 /24 /R8 WTY wayw have f.OA g Con t ract. Vea m Walin i'. F1 nnne casi(* . . . .
Apency neiti == nr*
reavi*w e ng t he.new for inPlan'nq
$*nbronu F d ral Fme.cguncy vanag* ment.
Va nir *
- nnd unhast(*d in th* Mnel*me or ana r.act hy N*w Wnannnire i would like in v.riry ynne rac i l i t ien anet w ev ic-% .Reagu ini nry (nomi mu ihat t woulel appre.eint*
ynor annwaring. nd b, eve 4 few rivestionn 1
2.
rnenany v ithnen u, Mndunn ambol nce L aw of 1.nl .v i elun t sp nueng an nnie. t/2%/ torr ? lear 4 1R
- g . Dhnnae A 17- 9 A S '"" A Q Arthur Ar*nn _
Townr 6 fin yene ha ve. a v ignevi f.* t t ea r of Agr****nt with N w H,empanira Vanke*? V*n R. Resenn er *w -
1 Whnt r*gtnereng hnvp ynta rummit1 d for nup whnu lil uti he r entu i ran for S ahrnnw$ Wnw A Wr *mpegancy r*9ponse.
__( Vah i e l u e with hviv*res7 reitsral car * '.s hn l a ns a=
(
1 in Avnilable f air i Ody RhIff7 __ Night Shift? \
24 Hour?
,Cg C. Capaci t y of V*bie len? W r. Vanu
/
I
'i 2 *meh if nn ele erhae vurv 4 on in 12. .everww. M ithaewn=* mur. Ashulnnr**
V'/ "a t t t en ) Enra - '
D. Mnhilj/atinn nnd D*pinyment:
Are nll reaanurern ellspatekast f eria nne 1
)nenfJnnu? 1 = ingle point? L Wow anny ff ni more than nna Incalinn, nnen loention: 1 clintnn toentions anel bnw many at each 1 w=rthnennah ihe r ** = t Hudunn I Whn t. is the your nurani humin *nn une for !
Fouronne'v nd nnn. =*reant v cont ract tennwn. these vehicles?
Day Shlft
_ Off }inurs or Night Shift T. Personn*J:
How many drivers (clunilflevi) rio you have?
! ff EM F.
Coseunications nnd/or Cal] Out Proceduren:
How slo ynn enamonicate with Drivers ciuring rinreal shif ts
( rad io /heepe r/ phone )?
radin und nneer=
How sin you enamunient
- with of f-eluty Drivers? Talenhnne Response tfee should Senbrook right. now? 1 immadtutaty and r==t rerluent distintch of your busen, etc.,
/
rc \
on tn 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />. Of f-clu t y same.
l 5 v. /
l 19
\
Attachment H (Pago 24 of 35)
O FFMA RX/*ce/Cani1*-n-835pahrrink/2/24/A8 MHV noyu have LdA van Contract Va.m_
Welin. f
- in Flannne Camil* nnel I work fitr the F elarn t Emergency Management Agencynnst vnnkp* enri mohmistest w* nr* r*vtawing in thet he. R*nbronk Plan un prep < reil by New Hampnhire i would like i n verif y your f Nucl*nr Regulainry C.nmalRRinn ant $ nHe Ag#nCyv ae'li j t ies and vervicen , and have a few questsonn thni i wnn ial apprera in t e yrine answering.
1 connnnv- Rayu t-e annue l n, -
nnte; 2/24/14AA.
- 2. Tien 2 4A ham of f ruli v islun i uppaning en inv Ev1 vain.
- 3. Phnn* 411-71A-0A00 Ynwn:
A. On you have n nignwei f.* t e ur eif Agr** man t wi t h New Hampnh ire Ynnken? VS R. R*nnore*w-What r*=nn er ** have yrm enesi s s *,1 for n=*
ha r*qu a reri f o r 0.n bronn ? Run*w uhnulit nn *mprgency responne hna 2 7 &mhn ) nt e nI 1 ') Wr Vann uvatinhien 20 Anholane*= n nri in W r Vann ( N.vw N*n t *
- f. ( r n e pet (nr MO.
Availabl* fne- All thift. i s
C. Capac i t y of Veh iclea? 'Van 6-A Walk : - , . .
r= (hna =1In-<inwn wanti Anhulence 2 N'- -
D. Mobilization and Depinyment: ' "
Are all resourepu dispatched frna nne ningir point? Nn How many loca t. i nne ? A If nt enra than nna inentinn, nam
- 1rientinnn nnvi hnw anny at each location: o at taw-runre/fnw 11 o-10 at Warrymar Vallev- o at Nnethahnre Olv 1A En Ghnem Div. A-7 nt F*ntral Mang Olv -
15 Wantern M=n* Oiv a nd .1 in sniew 0*nt E. Personnel Row many drivnrm ( ejun l i f i ert ) do yr>u hnve ? A l l R*w i n t e red ( FMT hu m i r ,
Pn em s. <i i n t n t ersp<t in t
- F7 Communientinna anti /or Call Out Pencedures:
Reve dn you enesunjente with Drivers during normal shifts Pnetnhler/ Ann Cnn. 9vatem- Pn em m*,i l e. ump Ahenroe. An-o t ruck avs t em , VWF avsten.
How do ynu enesuniente with off-duty Drivers? Fall-un
- Reapnnan timp ahentiel Sembrnnk rer}upat dispatch of your hunes, etc..
right now? 15-20 minut twith A nrann e nu l ti take 2 1/2 hnurnt Off-duty employe.em? enn.
I 20 L
k _ _ . _ _ _ - _ _ _ _ - - - _ - - - - - - - - - - - _ - _ - -
E J Attachment H (Page 25 of 35) . I x i
.'%./
FTNA R'G eceCnatl*-0-s.1S*nbenowr2/24/AA I
NWY wayn have f.n& Ypu .nntrnet Vn blin. t*e F1 nnne. rant 1* nsi f .nrn for t h e. F* ele ru i F.spegency Manngeannt Agency unit w n re r* viewing t h* 9 nbrnnn plan am p r *pa rert by New Haapanire Yank ** .e nel unhe i t I <l in t h* Nue1*n r Regu in t ury t'oma n us itui neut nu r Agency ,
I wonid 11'n a in w*rify your facilitlew net nerv6ceg, ,ind have'n fees questinnu that I wnnlel apprecinI* your answering,
- 1. (nepen y ; ra t a l ain A m bu l a n r** n,g t e ; 2/24/1QRR "jee; 1 ' fl.1
- 2. hem nf inellv ielun t wpenw ing i n .Inhn Wang r i let
- 1. Phnne: 41'r - A 2 M -ond ? Tsiwn !
A, no yno have a w i gnert f..a l t e r of Age **=ient w i t h New Haapanir Vnnkm*? Va4 R. R*gnuccew' What augnurra. have ynn enseest .I for u=* <hou isi nn *meergan y roeponne be r=qu i r*rt . f o r ;*nbrnnno ashnl=nca. 2 net con t ri rneniwh on in A enre nennlantwe meni nei to K chair care f C. Capnci ty nf Veh iclen? A m hn l a n c e. - O par h
! )
\,v1/ D. Mnhillynt. inn nnet ne.ployewns a Are all reunurceM ill u pa t cheri frne noe single point? Hnw anny j localinnn? J Tf et enr* than un* Inention, numa locattnna and how enny at'ench i Incntinnt 2 - Wtntbrein. I chelv n'. i Fvar*tt- R *n ese rv i l l e. n nri f 11 relttent r e lihe t. in tha ynur norent huntnpan use for t hese vwhicleg?
j' Reruine Fe.eennev u nti tennannrintinn nr Fielpr i v Day Shift l rnni erhnniet off Hourn or Night Shift F. , Personnel:
1-Rnw enny eleiv*rm (egunlifiml) ein ynn have?
', F. Communientionn and/or Cell out Procedur*we Now slo ynu enseun tent a wIth Detvaan sluring rinrent shif tn (redjo/ beeper /phnne)? 2-wav rneeuniratinna.
! i l NowIo you enesuniente with nff-eluty Drivers? Talanhnna Response tlea whould Senbrook request d ispatch of your busen , etc.,
- j. right now? toe.etime, nienntch, n n,i 24-hnur vnvarmen 1
f kj(l i
21 L
- m. ,
=
Attachment H (Page 26 of 35)
I l
@\ l I
UMA RX / *erl/ en e r l e-0-s3Sennrnnw / 2 / 24 / AR NMV ways have f.OA V u r.nn t ra ct We blin. t's F.lennne fant14 and i .orm for the Furleral Tapeg*ncy. Management Agency and we are r*v i ew i ng t h* diem brnnu plan nu prepa rwei by New Humpuntre Ynnk** and anhoitted in the Nairlwne Repila t ory Come t am inn anni nur Agency.
t would like in v*rify your racel; lien und wervie*=. .ind hav* a f*w riuestionn l thnt f unuld apprevainte your unaw* ring.
- 1. Cnennny' 'Jncit i nwh n e ashulun.* Da t e . 2 /24 /1 Q A A ?le*: 1 41 l
- 2. N*n em nf Inriiv idon i apenking in Chrie Stawne?
- 3. Phone An't- A A:>- mn Tnwn:
A. On you have n eign*d f ater nr Agr**=*ni w i t h Ww Humpgnir, Vankp*? Va=
R, R ouno rite n t ,
I d
iiiha t e * = nn r : .a n nave ynn commi e t wel rne owe shruilal an *=*ruancy raaipons*
rnne rne t ri r..e 2 Amhnlancow hau a rne he r*rtniren for O nbrnn'") u tatt-P nr Ave ** ment wnd n ne J Available (ne- Da y cib i r t ') Night Shift? 24 Hour?
C. rapneit y nf vehicle =? _Ashulance 2 in 3 natiente Mnhill?.ation and Deployment Are all r*=norcan dispat ched f rne one s ingle point ? Van.
What is the your norent huwinrun use for these vehicles?
E sp r*
- n r7 y Day Shift Off Hours or Night Shift F, . Personnel:
How many driverm (rlunlifl*d) do you have? 10-12 (*nnned 24 hnoral i
F. Cnoeunicarlona and/or Call Out Proceduren:
Row ein ynu ennenniente with Drivers during normal shif ts (radjo/breper/ phon *)? 2-wn v entiin .
l i
Enw rin you enesunient e with of f-duty Drivers? T*lanhnne Response tlee should Senbrook request dispntch of your buses, etc..
right now? Tesediate Off-duty empluvaen? 15 min. novenu.
l e
22 l
Attachm3nt H- (Paga 27 of 35) J
. 1 FFWA RY/*ers Cd a t ie-O-s35#.nnrnneri2 /24 / AA NWY wayn have IOA V** rnntract V.*
- Hello.-t's Fl*nnne raurl* nrui T oric rne the F e.<l* rn i Emergency Management Agency and.
- wr* r*v6 wing the A*nbronk Plan n < prepared by New Hampshire Yank ** and muheil t <l in the Nucl*nr R*gulninry Cneminainn nnel ruer Agency.
I would like in variry ynor facilillem and nervicen. nnd have a few rtuestionn Ihae i wou lel appr*r in 4
- your unawaring.
i 1, roepnnyt Wrt l e. Ambninne* fW. C i vn e.* n Date: 2/PA/10RR 7te*; 't . %7 .
l
- 2. We* nr instivistuni wpenning en nav* Enunlelinu !
- 3. Phone Pn7-MP-44MQ Town Pnetinnel unine A. Do yens huv* a w igneti feller of Agr**ernt with New Haapanfra Vankp*? V*n R. ;tenen:rew 3 Whnt r enurr**= have ynn enosill*el for nur ahnoisi nn *eprv ncy response he ruegu a re.n for %e,e n t nnw ") Vn 1 Amhninne = ? f Veh ie 1 *w winriverw Availdhle rnet Dny Shift 9 Night Shift? F*w evtra etnnt*=
F. , Cupne i t y or V*h ic l ew') Van a wh**l ehair'nennia Ambulance L A etc ech e 1 rn ld ing verptch e a net enantione i uten.
l I -
Vj D. Mnhil bution nnd Deployment ?
Are all rannurcre rilmpat cherl f rne one eingle point ? Van What is t he ynur normal busineux use for t hese vehicles?
Ee re.ncvt.* anet annoin. Tennafore Day Shift Off Hours or Night Shift E. Parennnel:
Hnw enny drivers (<tualifieel) do ynu have? *t nn enil F. Cnoeunientinnu nnd/or Cull Dut Proceduren: I
. Bnw rin ynu communiente with Drivern during nnreal shifts? Reente.
eultt-channel enriinw . nnet u hl en . enhlip en tii n u Hnw dn you enesunicate with off-duty Driverat talanhnna/naaara.
Respnnue tina nhould Senbrook requent dispetch of ynur huses, etc. ,
right nnw? *ne linie niennsch Off-duty rapinymen? 1/2 hr- for dIwonieh I
\
N 23 )
- -, -- - -g l
1 1
f .-
I g)
FEMA RX/*ecrCantle-D-s3Seabronk/2/24/AA KNV enyn have LOA Van Contract Yes Helin, i'm F.lennne Cant l* nnel I work rne t he i Federal Emergency Management Agencynnet Yank,* and we are reviewing nuhaittavi in the the Senbronk Plan en prepared by New Ham [ shire Nucl*ne Regulat iry Comminnion and nur Agency.
- I wnuld like in verify your facilities nud services, und have n few questions that I woulel apprecinte your annwnring. l
- 1. Company A ?. f. Amhnianca (N== Sienaal Date: 2/24/10AA.
- 2. Nan
- of Individua l apenk ing e n T.*n Rnnehned Timet at14
- 3. Phnn*: 200007-T?M-allA portland. vain- j A. On ynn have a n ign*d f,* e t er o f Agreemen t with N*w Hampnhire Ynnkaa? V*n B. Apunprewn:
What r*nnneren have ynn ef nem i i t *,1 he e-quared for S*nhenon? Vann 1 Wr for une ahnulti an emerg*ney renponse Amhnianr**= A with Orivaen Available for: Ony sh i f t.? Night Shif t ? 24 Hnur? l C.
Capacj t y of Vehicles? Van Q A mbu l e: nee p 2 ne a es. .- _ .-J. rse
- i '. ,e,. n .
D. Mobiltrat. inn and Deployment:
- .. A?.*qQ4~f #--f-7.*T";hl/rf
_pf Are all reunurere dispntehed frne one ulngle point? Ven
.;p *>Sa'ye ."* s What in the your normal huninean una for these vehiclen? ; widf.O:
~ ' "
Fuerpennten in Aren. Tennnnneratinn nf Flderiv. Ocy Shift Off Nours or Night Shift E. Personnel:
How many citiv*rn (qua l l fleel) clo ynu have? All Fmpreanev Mad .
Technirinna and critirm) Care T*ehnleinra Fl communications and/or Call Out Procedurent ~
How do you enesuniente with Drivers during noren) shifts (radio /heeper/phnne)? nore mble endina and endina in vahlrlan.
How pnear.do you ensuuniente with off-duty Drivers that are? Talenhnna and Responna time ahnolti Seahennk request tilspatch of your huses, etc.,
right now? Plene within 1/2 hnur could denlov nff duty within 1 hr.
24 O
- a. g. r - ?-
e
e Attachb.ent H (Page 29 of 35) r i
.I f~ '
f i k i i
)
FTWA RX/pec/Cantlp-D-s3Senbrnnk/2/?4/AA MMY unytt have IOA Va= Contrnet Y** __ .i k
bilo. t's Fl*nnne Centle nnr1 i work for the F *rie rn i Emergency Managreent l Agency nnd w* nre r* viewing the Senbrnnk Plan am prepared by New Heimpunire l Vankp* neul nubsisteri In the Nuclene Regulatnry Commission nnri nur Agency. f f wnuld like en verif y your f acilitlen and werviers, and have a f ew cluest J nns >
that i wnuld apprecinte ynur unawaeing. -
- 1. Cna pa n;8 : 8;l a v i e Astue lant
- 2/24/AR NI f*nilhack nn 2/2M Tleet O'An j
- 2. Nase of insilv teluni upunking en R* rn n eri f.*inviv
'3. Phnne: A17-212-1671 ,
Tnen: Bnntna A. No yno have n e ign* 1 isi ter eif Agreement with New Haapanire Vankee? Va*
R. Rennuccew.
Whnt ewanneepe haev* ynn enem i t t s.si for nur ahnulsi un emprepney rempnnne
'f n **d ed in h* restoired for 8ianbrnum 7 1 A s hn I w n e* *
- I u.e u 1A aVMiIdhl*
- emevens v n I V*h i ra l ee with neiveret7
-Available fort nn y Sh i f t ? Might 8;hift9 2A Hnur?
\
y/ i CJ Capneity of V ble1*s? Anhulenew 2
' O .1 Wntill/ntinu nnd Dep j nyment:
, i Are all rennurcen iltaparched f rne one ningle point ? Ven . Mennklina WA l
What is the your normal huulness use for these vehicles?
Foervantv Day Shift Off Hours nr Night Shift E. Perennnel:
'f I
Row many drivers (eguallfles!) do you have? mn.An with 30-4n trained hv Seabrnnk-F. Cuesunications and/or call Out Prncedurest How dn ynu enmouniente with Drivers during nnren) shifts
( rad in/heeper/phona )? 2-wava 2 hnma-Inne and f* Wad Rnd in Natwneer _
with Hnunitnin.
Row do you enesunicate with off-duty Drivers? Talenhnaa Response time whnuld Senbrnnk request dispatch nf your huses, etc.,
' right nnw? 24 hnure n dav s ta f f ael and mvn ilable .
nff-duty employees?
j 1 to 2 hnure rne ,n nlate rewnnrr**
I r
n/
1 as 1
a e Attachment H (Page 30 of 35)
O FF'WA RX/*cc/ Can t 19-D-43Senhrnnw/ 3-4 /88
% Y xxyx have LOA van Cnntract Y*w Mello, t 's El*nnor ra=t l anrt I worw ine t he F eleral Emergency Management Agency and we are rev6 ewing the Senbronk P1Hn nu prepared by New Hnopshire Yankee und subeltteri in the Nue; ear Regulatney Cneminstran and nur Agency.
I wnuld like in verify your (neilities and servieen, and have a few questions that I wnuld appreciat e yensr annwpring, l
- 1. rnepany: n neral Ashu l a nt . nate. callhar6r P'2M/AA ?!se: A 15
- 2. N=ne of Instiv ielun i ap*nking in e t cha rri R*.<l i va n
- 3. Phnner A17-440-A?n? Town:
A. On yrin have w e i gneef f.* t t ee r n f A g r * . n t with New H,.ep=~.ir- Ynnkee? V a R, ReunurcpM:
What rwenurepa h a ve, yriu einem i t t eri (nr um, uhnolrl an weergency rempnnse he rerluired for Spainona? A nho l nc ., J (v hiclwu with netv.ceni Avaiinhle for: 0,iy Shif1i Night thI(t? 24 Hriur?
C. Capaci ty of V*hiclem? Ashulnner 2
- 0. Mnhi1 izat inn anti D ploymen :
/.re all resnureen diupatched f rne one wingle point? Vew What is the ynur normal huniness une for these vehicles?
Peerv.ncv Day shift off Hnurs or Night Shift.
E. Personnel:
How anny ririvers (flualifled) do you have? Dava? O deivers plus part ttoers F. Communication anet/nr Call Out Peneetluren t l How do ynu enesunicate with Drivers durIng normal shifis l (rettin/ beeper /phnne)? 2-wav radina (40+ mil - unen hayand Enlee. NW1 !
f How do you communtente with of f-duty Drive,rs? Telenhnne l Responsa tlea abnuld Feahennk request dispatch of ynur humes, etc.,
right tiow? 7 .d ia t. orf-duty employecu? One r emed i a t e l v . **at on l 1
Call = 15-20 min !
1 G
l l :s r
.j Attachment 14.' (Page 31 of - 35)
_ ..:,s
- l J '*-
FEMA RX/*r:c/ Castle-0-83Spahronk/3-2-88
[
NNY.says have LOA 'Ves* Cnntract No Helin, I's Eleanor fant le and I work (nr ihn Federal Energency. Management Agency and we are reviewinE,the Senbrnok Plan as prepared by Nee Hampshire.
Yanken and nubelttert tn the Nuclear Regulatory Cnmetanion and our Agency.
I woul. like tn verify your facijftism and services, and have a few questions-that I enuld appreciate your answering. .
- 1. Company RJ ni107in Ashulence (Owns Puneral Parlor Alun)
Date 3/2/aA. Tleet n.e. e nl l ari rene Rnthall, WA
- 2. Nnee of Individual speaking tn R. 7 nt1orin owner 3 Phone: an3-MM2-na41-11nn Townr A,
On ynu have a signed Letter uf Agreement with New Hampshire Yankee? [,t,,,,
la nn inne.e in rr.et .anvn h. thinka h. nrtvinart N*w Hnennh i r. Yankee late in neraenar nr ==riv ranunev toma B. Feenureen What.rannurcan have ynn eneettted for une ahnuld an emergency responen he required fne Seabrnnk? Wad eneeltted, 4 f3 Ashulancen 4 1 Wheelchair Van.1 .
V .Available for: Day Ahlft? Might Shift? 24 Hour?
C; . Capacity of Vehicles? Ashulance Etc.:
D Mobilization and Oeploysant:
Are all resourceu dispatched free one ulngle paint? ves if at enre than nne lucation, naea'incations and hnw eeny at each location:
What is the ynur nntsal huninnen use for theen vehicles?
' Day Shift off Hours or Night Shift g .' Personnel:
Nou eeny deivers (qual 1 fled) do you hava?
F .* Communications and/or Call Out Procedures:
- Now do you cnsevnicate with Drivers during nnreal shifts?
h.- .
Now do you enseunicate with off-duty. Drivers? _ d.
Response tien ahnuld Seabrnnk request dispatch of your buses, etc...
right now? Off-duty employees?
Wat** Me. nilutin van v ev retenttiv, e tatert h im fire was willinr en ennperate in any wav nnestble but nnly I driver would virn un when they had staff emotint, en ha nold thov relt with nn rirtver conomention they could not sien enntract for nnn-penvidahle neevicec Pelt if mirned Contrnl/Arreement he would ne t'ovlti he euhipet in law entt wi t h ririver ennennnarat inn ..
l 27 -
(
__ .m_. ___a___ _ _ _ _ . . _ _ _ .
Attachment H (Pago 32 of 35)
O FEMA RX/ecc/ Castle-D-83Seabrnnk/3-4/88 NNY says have LOA Yes contract Yen Hello, i l's E1*anor Cast.le and I work fnr tha Federal Emergency Management i Agency and he are reviewing the Seabrnnk Plan as prepared by New Hampshire Yankee and nubettted tn the Nuclear Regulatney Cnsmission and our Agency.
~
I wnuld like in verify your facilities and services, and have a few questions that I would appreciat.m ynur answering.
- 1. Compa ny t Newburvnner Tnwine Service Date: 2/26/19Rs. Time Ar42s.
- 2. Nasa of Individual speaking in
- 3. Kleberiv Enwall Phone: A17-dA2-7100 Town:
A.
Do ynu hava a signed Letter of Agreement with New Hnopshire Yankee?
Yes. hut have nnt wirned enntreet B. R*nnurcent i What resnurces have you consitted for une should an emargency respanne he required for Seabrnnk? 7 Truckg Avnllable Vehiclen with Drivers)?
Available fort Ony Shift? Night. Shift? 24 Hour? - '*
C. , 4-. -
Capacity of Vehicles? can Tnw A vehicien nn 2 will carry 2 vehteles i D. Mohillt.ation and Depinyment:
Are all resources dispatched f rom one single pnint? central Loestion.
If at more than nne location, namn locations and how many at each Incation:
What is the your normal business una for these vehicles? Tovinr.
E. Personnel:
How many drivers (qualified) do you havn? Verf en. 5 full tima and 14 pa rt time.
F.
Communications and/or Call Out Procedures t Row do you conwunicate with Drivers during normal shif ts 2-way radion n erstinr on spaels) emarraney frenuency Ucc for emarr.)
How do you communicate with off-duty Drivers? Beepers and Telephones Response t ien should Seabrook request dispatch of your buses, etc.,
right now? wnxtsue 1/2 hour off-duty employees? Saee.
O 1 28
_m.__.________. _,_____ __
Attachmsnt H (Page 33 of 35)
[. <x V
FEMA RX/pec/Castl*-D-435eabrook/3-A-8A NNY mays have 1,0A Yes* Contract No l l
H*lln. I'm Eleannr Castle and I work for the Ferleral Esargency Management Agency and we are reviewing the Seshronk Plan as prepared by New Neopshire Yanker and submitted to the Nuclear Regulatory Cnesission'and nur Agency.
' _ I could like in verify your f acilities and services, and have a few questions '
that I wnulti appreciate ynur answering.
- 1. Company: Vninnne hwinP Date: 2/25/19RR. Timer 2.33 p.m.
- 2. Name of Inttivirtual speaking to " Jane" fnr Gernir! Vntonna 3 .- Phone: 61 'r-4 8 5-14 33 Town: .
A. Do ynu have a nigneri Letter of Agrnement with New Hampshire Yankee?
Yes, but says wants tn cancel und anys did not sign contract.
B. Rennurcen:
What resnurcen have you enestiteri for une shnuld an emergency response he requirect for Seshrnnk? Rnsen vann Ashuluneen Etc.
( Veh i c l e.= with Driveent?
~ ' ~
3 . , . , _ s -. . [
Available for: Day Shift? Right Shift? 24 Hour?
- l O C ." Capacity of Vehicles? Ruses __ Van ' Mini-Bus '
~ '
Ashulance . Etc.:
D. Mobilization and Deployment: ,,,,.
Are all reanurces dispatched from one ningle point? How eeny locations?
If at more than nne location, name locations anti how many at each location:
What is the your normal hutun.as use for t.heen vehicles?
Day Shift E .' Personnel
- i 1
Row many r!rivara (closlified) dn yo' u havn? \
l F. Coesunications and/or call Out Procedurest Row do you communicate eith Drivers during normal shifts ? j Mow do you communicate with off-duty Drivers?
Respnnan tien should Snahrnok request dispatch of ynar buses, etc.,
right now? Off-duty employees?
Nnte' Ondv en tri thev had nernaet tn 1,0A anti then en1ked tn thofe drivers and they enuld nnt cet drivern tn arren. j Without drivern thev esfiesot eneelt to f nerepeent to furnish regnurema without riri ve rs . Setri t hov should have telked to driverg first,
} 29
- ~ ., *;; .
l
Attachmant H (Pago 34 of 35) l O
FDIA RX/*cc/ Cast le-D-83Smahrnnk/2/26/A7 l NRY unys have LDA h Contract Yes Hello, I's Elannne Cantle and I work for the Federal Enargency Management Agency and we are reviewing the Seabrook Plan as prepared by New Hampshire Yankee end nubeltted in the Nuclear Regulatnry Cnseission and our Agency.
- I would like in verify your facilities and services, and have a few questions
- t. hat I would appreciate your answering.
I
- 1. Company: Cnady'* Tnwinr 2.
Date: 2/28/1984. Time: 9t26 e.a.
Name nf Individual speaking tne Sandy Rnochartt.
- 3. Phone 61'l-6 4 5-41 'LR . Town: Lawrence, MA .
A.
Do ynu hava a signed Letter nf Agreement with New Hampshire Yankee? Vy R. Resources:
What rasnurces have you enesitted for une should an emargency responen be required for Seshrnnk? 15 Tnu Trucka (Vehiclew with Driveral Available fort 24 Hour? Yem
- . .. ...- - . =
C .- Capacity of Vehiclem? 15 Tow Trucks. unee enn enerv 2 vehjeles.
D ." Mobillration and Deployment: ~..+ ~
Are all resources dispatched from one single point? Yes. hot Drivern do take hnea aveninsrs.
What is the your normai business use fnr thnen. vehicles? Routine Trnine E .- Personnel:
Row many drivers (qualified) do you have? 15 Fe Coenunications and/or Call Out Procedures Row do you enesunicate with Drivers during normal shifts: 2-way Radios How do you communicate with off-duty Drivers? Telephone and 2-wsy redins.
Response time should Seabronk request dispatch of your bosas, etc.,
right now? O to 20 minute everere. Off-duty esplayees? same.
O; 30 l r-
Attachm:nt H (Paga 35 of 35).
p 4 m,
/
)
FEMA RX/ecc/ Cantle-D-83Snabronk/2/26/AA NNY says have LOA Yes contract ,Y,gg,
. Ralln, l's Eleannr Castle and I work for the Federal Esargency Management AgenJy and we are reviewing the Seabrook Plan as prepared by New Hampshire Yankee and nubelttert in the Nuclear Regulatnry Commission and nur Agency.
- I would like to verify your. facilities and services, and have e few questions that I would appreciate your annmaring.
- 1. Company: Federal Auto Renair (Tnwing) Date: 2/26/1988. Time:9tSO a.m.
- 2. Nama of Individual apaaking in Alan Whittnett '
- 3. Phone 617-465-MR54 Toemt .
A. Do ynu have n-nigned t.etter of Agreement. with New Hampshire Yankaa?
Yes, with rnnernet R .' Rasnurcent t
What rennureen have you committed for use should an emergency responen ,
.be required for Seabronk? 2 Tow Trucka (Vehicles with Drivers)?
Avellsble fort Day Shift? All Night Shift? 24 Hour?
~~~
C- Capselty of vehicles? 2 Tnw Trucks and nne enn eserv 2 vehicles. .k. - v \
N
. ..~..
DJ Mobilirat inn and Dnployment:
... <.y-
. : d'. .i..
Are all resources dispatched from one single point? Yes. Drivers dn not take inn trucka hnen. *t,';- .
What la the your normal business use for these vehicles? Towint El Personnelt '
Row many drivers (atualifiert) do you have? 3 F: Communications and/or call Out Procedures How rio you communicate with Drivars during normal shif ts (radio / beeper / phone)? Telephone.
Row do you enesunicate with off-duty Drivers? Telephone Response time should Seabrook request dispatch of your buses, etc.,
right now? 10 to 15 einotes Of f-duty esphynes? h 31
e
~ REBUTTAL NO. 23 PANEL - CROSS 22703 1 JUDGE SMITH: Mr. Brock.
,3
._ ,/ 2 CROSS-EXAMINATION 3 BY MR. BROCK:
4 Q Good afternoon, gentlemen.
5 For the record, do I understand that each member 6 of the panel is prepared to defend the entire testimony; is 7 that correct?
8 Each member of the panel is sponsoring the entire 9 testimony and prepared to defend the entire testimony.
10 A (Callendrello) I prefer to say that this 11 testimony incorporates each panel member's testimony on the 12 subject. As is our usual practice, we collectively prepared 13 testimony, reviewed testimony, turned it over to Ropes &
<-~., 14 Gray for final editing, and it is presented in that manner.
\
(_,/ 15 Certainly each member of the panel has various 16 areas of expertise, and any one individual may be more 17 qualified or more prepared to answer a question than the 18 other. But this testimony does incorporate'all of our 19 testimony.
20 0 Well, let's take it one at a time then, so it's 21 clear.
22 Mr. Baer, is there any portion of Applicants' 23 23 that you are not prepared to support and defend, and any 24 portion you do not feel qualified to support or defend?
25 A (Baer) No, there's no part of the testimony that j Heritage Reporting Corporation fN g ). (202) 628-4888 l
1
REBUTTAL NO. 23 PANEL - CROSS 22704 1 I don't feel qualified to support and defend. However, 2 there may be other members of this panel who are more 3 knowledgeable on the events that are reflected in the 4 testimony, who could testify to certain things better than 5 I.
6 Q -Well, I'm really not asking for a comparison, Mr.
7 Baer. I'm simply asking are you familiar with the events, 8 with the testimony as presented, and are you individually 9 prepared to support and defend the testimony? Or if not, 10 please identify the portions you are not so prepared to 11 defend.
12 MR. LEWALD: Your Honor, I think he has answered 13 the question.
14 JUDGE SMITH: Yes, he did. He said, yes, he's 15 prepared.
16 MR. BROCK: Okay.
17 BY MR. BROCK:
18 Q And that is true for you, Mr. Callendrello?
19 A (Callendrello) Yes, sir.
20 Q Mr. Gram?
21 A (Gram) Yes, sir.
4 22 Q And for the record, am I correct that all three of 23 you gentlemen are presently employed or under contract to 24 New Hampshire Yankee?
25 A (Callendrello) That is correct.
Beritage Reporting Corporation (202) 628-4888
4 REBUTTAL NO. 23 PANEL - CROSS 22705 1 Q And that was true on the date of the emergency
/N >
5 )
2 ensrcise last June?
3 A (Callendrello) That is correct. .
4 Q All right, now, I don't see reference in the f 5 testimony to the personal involvement or roles of you 6 individuals in the development of the scenario, Extent of 7 Play and the exercise, so I.just would like to explore with l
8 each you your particular involvement in that area. l 9 Mr, Baer, could you tell me what role, if any, did 10 you have in the development of the scenario and the Extent 11 of Play?
12 I'm talking about prior to the exercise.
13 A (Baer) I had no involvement in the pre-exercise 14 activities, in the development of the scenario or in the
(}/
\
' ' ' 15 Extent of Play.
16 O All right. And with respect to the exercise, did 17 you have a role or an involvement in that event?
18 A (Baer) I was assigned as a controller during the 19 exercise to the Division of Public Health Services 20 activities in the New Hampshire incident field office in 21 Newington.
22 Q I'm sorry. Where were you stationed?
23 A (Baer) With the Division of Public Health j
24 Services at the New Hampshire incident field office in 25 Newington, New Hampshire, which is co-located with the l
I
'\ Heritage Reporting Corporation j
} (202) 628-4888 J
l
7----
1 l
1
)
REBUTTAL NO. 23 PANEL - CROSS 22706 J
1 emergency operatione facility.
2 Q And who assigned you that responsibility?
3 A (Baer) The organization in charge of the exercise 4 assigned me to that. I don't know who individually would 5 have dn-a that.
6 Q Can you tell me what was your function during the 7 exercise with respect to the IFO?
8 A (Baer) The function was to observe the activities 9 of the Divisien of Public Health services personnel there:
10 to interject exercise controller messages intended to prompt 11 certain actions on their part; to key the players from the 12 Division of Public Health Services on certain events that 13 they would not otherwise be aware of that would lead them to 14 take certain actions.
15 Q So you were a controller in the exercise, not a 16 player?
17 A (Baer) That's correct.
18 Q And am I correct that the entire duration of the 19 exercise, both days, on the 28th and 29th, you were 20 stationed at the IFO?
21 A (Baer) That's correct.
22 Q Who did you report to during the exercise with 23 respect to any information or observations that you had?
24 A (Baer) I reported to an exercise leader or 25 supervisor, who was in the emergency operations facility at Heritage Reporting Corporation (202) 628-4888
4 REBUTTAL NO. 23 PANEL - CROSS 22707 1 the time. His name was Patrick Casey.
[g I N _jl 2 Q And that was with respect to the public health !
3 issues that you were observing?
That's correct. f 4 A (Baer) l l
5 Q Did you maintain a log? l 6 A (Baer) Yes, I did.
7 Q And do you have a copy of that with you?
8 A (Baer) I don't have it with me here immediately. ]
And I 9 The log was, however, made available in discovery. !
10 can obtain a copy of it, yes, sir.
11 MR. BROCK: Mr. Lewald, could I obtain a copy?
But 12 I understand that it won't be this afternoon.
I would like a copy of that log. I, for the record, did 13 14 make a request to your office, I believe it was a weck ago
/
Y-)} 15 Friday, for the loge of the witnesses and I have not 16 received it.
17 MR. LEWALD: You were furnished with certain 18 materials. The log was not among them?
19 MR. BROCK: Not to my knowledge, Mr. Lewald.
20 BY MR. BROCK:
21' Q Mr. Baer, were you involved in the 1986 exercise 22 for Seabrook Station?
23 A (Baer) Yes, I was.
24 Q And what was your function at that time?
25 A (Baer) I again was involved as an exercise Heritage Reporting Corporation
( _,/ (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22708 1 controller at the time with the state emergency operation i 2 center in Concord, New Hampshire.
3 0 And again you were a controller and not a player?
4 A (Baer) Yes.
5 0 And your observations and activities took place 6 exclusively within the state ECO; is that right?
7 A (Baer) That's correct.
8 Q But if I understand your testimony, any pre-9 exercise activity along the line of scenario development, 10 5xtent of Play, you were not involved in that process?
11 A (Baer) In the case of the 1986 exercise, I was 12 involved in the pre-exercise meetings that led to 13 development of the objectives, and development of certain 14 aspects of the Extent of Play. I was not the exclusive 15 person involved, but I was involved in that process.
16 Q But you were not so involved in 19887 17 A (Baer) That's correct. ;
18 Q And am I also correct that other than the public 19 health information with respect to the 1988 exercise which 20 you were observing and focusing on and reporting about, that 21 was the extent of your focus with respect to the ' 88 22 exercise?
23 Those were the issues that you were concerned 24 about in 1988 exercise?
25 A (Baer) Directly. Yes.
I Heritage Reporting Corporation (202) 628-4888 l
i :
j I
i REBUTTAL NO. 23 PANEL - CROSS 22709
/'~h 1 Q All right, Mr. Callendrello, maybe we could move i
\
l- 2 to you at this point.
l 3 Now, did you have involvement in the pre-exercise 4 activities with respect to scenario development and Extent !
1 5 of Play?
6 A (Ca11endre11o) I was involved in the licensing 7 considerations of the development of the scenario.
8 Q When you say licensing considerations, what do you 9 mean?
10 A (Callendrello) We had every reason to believe 11 that the exercise would be litigated. And as such --
12 Q Why did you think that, Mr. Callendrello?
13 (Laughter)
/~'N 14 A (Callendrello) It came to me out of the blue. ;
\
'd
]' (Laughter.)
15 !
16 And as such, the organization that developed the 17 scenario or was developing the scenario sought the advice of I l
18 the licensing organization as to how to put ourselves in 19 the -- how to have the most complete exercise that would 20 withstand intense scrutiny in the hearing room.
21 Q All right. And would you be more specific then as 22 to what input or involvement you had, or what impact that 23 concern had with respect to developing the scenario and the 24 Extent of Play for 19887 25 MR. LEWALD: I think we've got at least two Heritage Reporting Corporation
[ (202) 628-4888
(
REBUTTAL NO. 23 PANEL - CROSS 22710 1 questions. What's the impact and what was his input.
2 MR. BROCK: Well, I will withdraw the question if 3 it wasn't clear for the witness.
4 BY MR. BROCK:
5 Q Mr. Callendrello, you have described certain pre-6 exercise activities which were focusing upon litigation 7 concerns of New Hampshire Yankee with respect to the 8 exercise, correct?
9 A (Callendrello) Yes.
10 Q And you were, do I understand it, an advisor in 11 some sense concerning development of exercise scenario and l 12 Extent of Play being mindful of these litigation concerns?
13 A (Ca11endre11o) In some areas, yes.
14 Q All right.
15 And what I am trying to do is just specifically 16 how did that role play out? How exactly did you carry out i
17 that role?
18 A (Callendrello) At around the time that the 19 scenario team began the development of the scenario --
20 Q And can I stop you there?
21 When was that?
22 A (Callendrello) As I recall, it was around 23 February, late February or early March.
24 0 19887 25 A (Callendrello) Yes.
Heritage Reporting Corporation (202) 628-4888 i
REBUTTAL NO. 23 PANEL - CROSS 22711 f-~s 1 I believe Mr. Gram can --
/ i k_, 2 A (Gram) If I could clarify.
3 The beginning of the development of the scenario 4 actually started in December of ' 87, and it started to take 5 a finh1 form towards the end of January of ' 88, and into l 6 February.
7 A (Callendrello) Around the time of the development 8 of the scenario the licensing board in the LILCO proceedings 9 had issued a decision that affected scope considerations of 10 exercises.
11 Q That was ALAB-900?
12 A (Callendrello) No, sir. That was the -- I'll 13 call it the Frye Board decision.
s 14 Q Oh, that was a licensing board decision which
\s _,-) 15 ultimately led to ALAB-9007 16 A (Callendrello) Yes, sir.
17 Q Okay.
18 A (Callendrello) And we received a copy of the 19 decision and cnalyzed it and provided advice to Mr. Gram's 20 organization as to what we thought what its impact should be 21 on the scenario.
22 Q And what specific recommendations did you make, or 23 how did you adjust the scenario based on the information you 24 then had at hand?
25 A (Callendrello) One of the areas that we addressed
(~s Heritage Reporting Corporation (x (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 32712 1 or suggested was the use of a statistical approach.
2 Q For what purpose?
3 A (callendrello) To determine sample sizes.
4 Q With respect to a full range, different kinds of 5 activities, the issue was the size of various samples?
6 A (Callendrello) That was an issue that had been 7 raised in the LILCO proceeding. They had taken the 8 testimony of an intervenor witness regarding statistical 9 sampling. That was one of the approaches that was looked at 10 in the development of the scenario.
11 Q And what was your recommendation with respect to 12 the statistical sampling?
13 A (Callendrello) That it be looked at as a method 14 for determining sample size.
15 Q Did you recommend that it be incorporated into the 16 exercise for determining sample size?
17 A (Ca11endre11o) No. The recommendation was that 18 statistical approach be evaluated for use in developing the 19 sample size for the Extent of Play.
20 Q And was it?
21 A (Callendrello) There was analysis, a statistical 22 analysis performed.
23 Q And when you say " statistical analysis", what is 24 your understanding of the factors, or how did that change 25 what New Hampshire Yankee was planning to do with respect to I
l Heritage Reporting Corporation (202) 628-4888 I s
REBUTTAL NO. 23 PANEL - CROSS 22713
/N 1 . sample sizes in the exercise?
- t N-
) 2 A (Callendrello) I don't understand the question.
3 Q All right, let me withdraw the question.
4 You said a statistical --
5 JUDGE SMITH: Well, you used the term " change" and 6 it may not have changed anything. But how did it influence.
7 MR. BROCK: Thank you, Your Honor.
8 BY MR. BROCK:
9 Q With that clarification --
10 A (Callendrello) I'm sorry, I --
11 JUDGE SMITH: Put the question again. t 12 BY MR. BROCK:
13 Q Did the statistical method which you recommended
/ 14 to New Hampshire Yankee to employ in the exercise scenario, k/ 15 as I understand it, you say they did accept your 16 recommendation, is that correct, and did employ it with 17 respect to developing the scenario?
18 A (Callendrello) I said an analysis was done for 19 some aspects of the scenario.
20 JUDGE SMITH: There is one thing I'm somewhat 21 confused about.
22 You indicated that you were going to evaluate the 23 possible use of statistical analysis. Now was statistical 24 analysis actually applied to some aspects of the scenario?
25 THE WITNESS: (Callendrello) There was an Reporting Corporation
[h Heritage (202) 628-4088 (v/
REBUTTAL NO. 23 PANEL - CROSS 22714 1 evaluation done of some components.
2 JUDGE SMITH: A statistical evaluation?
3 THE WITNESS: (Callendrello) Yes.
4 JUDGE COLE: Was it actually used to determine the 5 sample size?
I 6 THE WITNESS: (Callendrello) No. In some cases 7 we used less, and in some cases we used more.
8 JUDGE COLE: But a statistical approach was used 9 in making determinations?
10 THE WITNESS: (Gram) Maybe I can help to clarify.
11 We embarked on -- we went down a path of 12 evaluation on the use of statistical analysis to determine 13 the size of the demonstration, or the Extent of Play for 14 individual components such as the number of buses. If the 15 plan requires for the ORO 386 buses, you can come up with a 16 statistical representative sample that gives validity to the 17 actual test that's run.
18 After we collectively, the people that 19 participated in developing Extent of Play, we explored those 20 possibilities and came to the conclusion that statistical l
21 analysis just could not be used, because there were 22 situations where there were no constraints . running 100 23 percent such as traffic guides in Massachusetts for the ORO, 24 so that the statistical sample was not' applicable.
25 There were other instances such as running all the Heritage Reporting Corporation (202) 628-4888 1 1
l l
l REBUTTAL NO. 23 PANEL - CROSS 22715 l
L gs 1 bus routes in New Hampshire where FEMA wanted those run
! / 1
(,_) 2 because of issues that were raised in the '88 exercise. So )
3 it became very rapidly apparent that the statistical i
4 analysis approach just really could not be applied. 1 5 So it was not used, to my knowledge, in any one of 1
6 the instances where we exercised resources. i 7 JUDGE COLE: Okay. Thank you.
8 BY MR. BROCK:
9 Q Mr. Callendrello, just to follow along then.
10 Other than the statistical methods which were 11 initially discussed and developed as Mr. Gram has just 12 testified to, did you personally have involvement in the 13 development of the scenario or Extent of Play or any of p_ 14 those pre-exercise events with respect to the '88 exercise?
,) 15 A (Callendrello) No, sir.
16 Q Did you have a role in the exercise?
17 A (Callendrello) Yes, I did. I was a controller 18 for the New Hampshire Yankee ORO public notification 19 function and communication function at their emergency 20 operation center.
21 Q And whera is that EOC located?
22 A (Callendrello) It's located in Newington, New 23 Hampshire, co-located with the emergency operations facility 24 in the New Hampshire incident field office.
25 Q Am I correct that your personal focus in the Heritage Reporting Corporation
, (202) 628-4888 G
j 1
i l
. 1 1
REBUTTAL NO. 23 PANEL - CROSS 22716 l 1 exercise was on the performance of the ORO as distinguished 2 from the New Hampshire emergency management office? O)i 3 A (Callendrello) Yes, that's true.
4 Q And, I'm sorry, you said public information. The.t 5 was one aspect you focused on?
6 A (Cullendrello) No, public notification.
7 Q And in addition to public notification, were there 8 other areas of particular concern that you focused on during 9 the exercise?
10 A (Callendrello) I focused also on the l 11 communications function of the offsite response 12 organization. Those were my two assigned areas for 13 controlling in the exercise.
14 Q Who assigned you those areas?
15 A 'allendrello) The exercise director.
16 Q And who was that?
17 A (Callendrello) That was Diane Bovino.
18 Q Tell me this. Were you given materials in advance 19 by New Hampshire Yankee to study or to in some sense prep 20 for what you would be involved in in the exercise?
21 A (Callendrello) Yes, I was.
22 O And could you just briefly outline what that 23 process was and who provided materials for you?
24 A (Callendrello) It was a fairly lengthy process if 25 you consider the fact that there were full-scale drills that Heritage Reporting Corporation {'
(202) 628-4888 i
1 l
_ _ . J
i l
j REBUTTAL NO. 23 PANEL - CROSS 22717
[N - 1 were conducted prior to the exercise.
~
-) 2 One of the purposes of the drills is to train the 3 control organization as well as to train the player 4 organization.
5 We were provided copies of controller guidance, in t essence, controller training materials. We were provided 6
7 briefing sessions on how to observe and how to control the 8 exercise. We were provided copies of the procedures, copies 9 of relevant portions of the sceaario, the evaluation That's 10 materials which were also contained in the scenario.
11 about all I can recall offhand.
12 Q Okay, fine.
13 So you were provided the materials as you have 14 described them, end then for the two days of the exercise,
/}
N' ') 15 you were located at the EOC in Newington, focusing on ORO 16 performance in the two areas that you identified.
17 Is that a fair summary?
18 A (Callendrello) Yes, that's right.
19 Q During the exercise was there somebody that you 20 reported to periodically or during the course of events?
A (Callendrello) Similar to the organization that 21 22 Mr. Donovan described, New Hampshire Yankee had a 23 controlling organization established where we had an 24 exercise director who was responsible for making the 25 exercise flow, and then there were lead controllers for the Heritage Reporting Corporation
's_, (202) 628-4888 i
l
REBUTTAL NO. 23 PANEL - CROSS 22718 1 various organizations, and then below that lead controllers 2 for specific facilities.
3 In my case, I reported to the lead controller for 4 the ORO emergency operation center.
5 Q And I probably asked this, but I just want to be 6 clear then.
7 During the two-day period, you were exclusively at 8 the EOC that you've described? You weren't traveling 9 around; is that correct?
10 A (Callendrello) I did spend some time looking at 11 the joint telephone information center, but I was not 12 assigned there as a controller.
13 Q And where is the joint telephone center?
14 A (Callendrello) It's in a building adjacent to the 15 emergency operations center.
16 Q In Newington?
17 A (Callendrello) Yes, sir.
18 Q Now were you involved in the 1986 exercise?
19 A (Callendrello) Yes, I was.
20 Q And what was your function then? ]
21 A (Callendrello) I was the exercise director.
22 Q And this would have been just for the State of New l 23 Hampshire, correct?
24 A (Callendrello) The State of New Hampshire and the 25 onsite organization.
Heritage Reporting Corporation (202) 628-4888 l
REBUTTAL NO. 23 PANEL - CROSS 22719 fg 1 Q And were you located at the state EOC?
(N/ / 2 A (Callendrello) No, sir, I was not.
3 Q Where were you located?
4 A (Callendrello) I was at a number of facilities.
5 The exercise director is usually a person who spends a lot l
l 6 of time traveling between facilities to make sure that the 7 exercise is moving smoothly. I spent time it the media l 8 center, but principally my time was spent in the emergency 1
9 operations facility and incident field office.
i 10 Q All right. So in '86, then, you were on the go a l 11 bit more. You were moving around looking at various l 12 operations. And in ' 8 8, you were stationed, as you've 13 described it, focusing on those particular issues that you
/'~'N . 14 have already testified to, correct?
(\- ')- 15 A (Callendrello) Correct.
16 Q All right, Mr. Gram, just to complete this line.
17 Could you summarize for the Board what involvement 18 you had in the pre-exercise activities, including scenario 19 development and development of Extent of Play?
20 A (Gram) The organization that was set up to 21 develop the exercise, in other words, the Extent of Play, 22 scenario, reported directly to me. So I guess I could say I 23 had day-to-day involvement in the development of the 24 scenario and the Extent of Plays.
25 Q Well, this organization you've described, who
[}
( ,j Heritage Reporting Corporation (202) 628-4888
REBUTTAL No. 23 PANEL - CROSS 22720 )
I 1 comprised that organization?
2 A (Grara) It would have been made up of about, I 3 believe, 11 individuals at the time, at varying points 4 through the development process. So it could have been as 5 small as two or three people at one point, and as many as i
6 11.
7 It included people like Diane Bovino, Pat Casey.
8 Q These were all New Hampshire Yankee people?
9 A (Gram) Or contractors to New Hampshire Yankee.
10 Q And what was their mission or function?
11 Let me just withdraw that.
12 First of all, was there a chairperson for this 13 organization you have jus' identified?
14 A (Gram) If I can say there was a chairperson, I 15 would have to say it was myself.
16 Q So if I understand it, whenever this organization 17 would meet to discuss an area or pre-exercise events, you 18 personally were present for thosa meetings?
19 A (Gram) Not fer all of the meetings, but I would 20 say for a large majority, yes.
21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
REBUTTAL NO. 23 PALEL - CROSS '22721
,~s 1 Q And were you also present for pre-exercise
" \j 2. meetings involving FEMA?-
3 A (Gram) Excuse me,-could you repeat that.
4 Was I responsible or was I present?
5 Q Were you personally present for pre-exercise 6 meetings concerning scenario and Extent of Play development, 7 which included FEMA as well as New Hampshire Yankee people?
~8 A (Gram) I can't say that I was there for all of 9 them, but for the vast majority, yes.
10 Q Do I understand that you were the primary 11 negotiator for New Hampshire. Yankee in presenting the 12 scenario to FEMA and the give-and-take process which Mr.
13 Donovan defined? You were the principal person involved in 14 that for New Hampshire Yankee?
( 15 A (Gram) Yes.
16 Q I believe you testified earlier that tne scenario
- 17. and Extent of Play that that development began in December 18 of ' 877 19 A (Gram) The scenario would have begun development 20 in December of ' 87. To begin the framework of the scenario.
i- 21 Q And you were involved in that as of that time? i
~
22 A (Gram) I can't say I was personally involved in 23 the actual details of what was put to paper. I was aware l'
l 24 that that development was going on and I knew that it was 25 going to basically be the first cut, so to speak, or the l
l l q Heritage Reporting Corporation I (202) 628-4888
i REBUTTAL NO. 23 PANEL - CROSS 22722 l l
1 first draft.
2 Q Well, I guess what I'm trying to establish: did 3 your role throughout the scenario and Extent of Play l
)
4 development beginning in December of ' 87 up to the date of l 5 the exercise, was it your job to monitor for New Hampshire 6 Yankee and participate and present the scenario and
(
7 negotiate with FEMA? Was that your role consistently l 8 throughout the time frame? Or did it change?
9 A (Gram) That was one of my roles throughout that 10 time frame, yes.
11 Q Am I correct that New Hampshire Yankee, in the 12 first instance, developed a scenario document or a series of 13 documents and presented those to FEMA and NRC for comment?
14 A (Gram) New Hampshire Yankee developed a scenario 15 document that was reviewed and agreed to by the State of -
16 Maine and the State of New Hampshire. And it was co-17 submitted to FEMA as a proposed scenario for the 1988 graded 18 exercise.
19 Q So when you say, co presented, that would have 20 been Maine, the State of New Hampshire, and ORO?
21 A (Gram) Yes, sir.
I 22 Q But is it fair to say that New Hampshire Yankee j i
23 was the author, at least, of the initial document? l 24 A (Gram) Yes, sir.
25 Q And were you personally involved in drafting that Heritage Reporting Corporation (202) 628-4888 l
l
1 l
w REBUTTAL'NO. 23 PANEL - CROSS 22723 l 1
A' 1 scenario?
s- 2 A (Gram) You have to better define, personally 3 . involved in drafting.
4 Q Well, that's what I'm trying to establish, sir, is-5 the extent to which you had personal. involvement in terms of 6 attending meetings; negotiating personally with FEMA; ' or 7
7 were you at the top of authority structure that you'had 8 subordinates performing those roles and reporting back to 9 you? I mean, if that's a fair distinction.
10 Which was it?
11 A (Gram) I would believe the first characterization 12 would be proper. I was che primary interface for New 13 Hampshire Yankee and for the ORO with FEMA and with the NRC.
14 Q All right. Then I want to go back to my prior k 15 question.
16 .Were you then personally involved in drafting the 17 scenario document and the Extent of Play for initial i 18 submittal to FEMA 7 19 I mean, were you making the calls as to exactly 20 how those scenario events should occur during the exercise; 21 was that your role?
22 A (Gram) Yes.
23 Q And was it also your role to make an initial 24 proposal with respect to the Extent of Play for each of the .
I 25 different exercise objectives?
I Heritage Reporting Corporation
( (202) 628-4888 l
1
)
)
REBUTTAL NO. 23 PANEL - CROSS 22724 1 A (Gram) Yes.
2 Q And do I understand that the organization at New 3 Hampshire Yankee, the individuals that you previously 4 referred to, they assisted you in those endeavors?
5 A (Gram) Yes.
6 The process would be that individual extents of ,
7 play were assigned to individuals in the organization. They !
8 would develop a proposed Extent of Play. The exercise j 9 development organization would review it collectively. I 10 would buy off on it. And then it became a package that was l' submitted to FEMA.
12 Q So there were different people in the organization 13 who were assigned essentially different objectives, and 14 their assignment was to go out and prepare an Extent of 15 Play, for example, for whatever particular objective they 4 16 were assigned?
17 A (Gram) Yes.
18 Q And then they report back to you?
19 A (Gram) No.
20 They would bring that proposal to the group as a 21 whole. The group as a whole reviewed it, either accepted 22 it, rejected it, sent it back to be redeveloped. Once we 23 had the acceptance, then it became part of our pr.oposed )
24 submittal that we sent to the States of New Hampshire and 1
25 Maine for their buy off, prior to sending it collectively to Heritage Reporting Corporation (202) 628-4888 I l
J J
' REBUTTAL NO. 23 PANEL - CROSS 22725 1 FEMA.
2 0 .All right.
3 So in the first instance, New Hampshire Yankee, r-
.the people that you've described, put together a scenario L 4 5 document complete, sub'mitted that initially toLMaine and New 6 Hampshire before submitting to FEMA; correct?
7 A (Gram) Well, your use of the word " complete, " I 8 don't believe -it was intended to be a complete scope.
9 scenario. We knew that there were items that were going to 10 have to be' expanded on, small -- what are celled mini-11 scenarios. But I term it the core scenario document.
12 Q Tell.me this: did the State of New Hampshire have 13 changes that they proposed in the core scenario document f 14 prior to submission to FEMA?
15 A (Gram) I can't recall any, 16 Q Do you recall any changes that the State of Maine 17 proposed prior to submission to FEMA?
I don't recall a proposed change. I 18 A (Gram) 19 recall a couple of questions from the State of Maine on why 20 were they being asked or why would they want to propose to 21 do as an extensive amount'of participation as was being 22 proposed in the scenario.
23 O What was the response?
24 A (Gram) What'was the response from New Hampshire 25 Yankee?
Heritage Reporting Corporation (202) 628-4888 i
REBUTTAL NO. 23 PANEL - CROSS 22726 1 Q From New Hampshire Yankee, yes.
2 A (Gram) We sat down and went through an 3 explanation of the definition or at least our interpretation 4 of a definition of a full participation exercise, l
5 And that satisfied the State of Maine and they f 6 agreed to the proposed scenario.
l 7 Q Let me just push a little more on that.
8 When you say, you explained the definition of a 9 full participation exercise in response to some concern of 10 Maine of, you know, why do we have to be so involved in the 11 exercise, exactly what did you explain? What was your 12 understanding that you communicated to Maine about a full 13 participation exercise?
14 A (Gram) My specific recollection has to do with 15 the issue of developing a field sampling program and 16 actually going out to take field samples in an ingestion 17 pathway deposition scenario.
18 Q That was the context within which the issue came 19 up?
20 A (Gram) And I believe their argument was that they 21 did that on a regular basis. And I believe at the time, 22 relatively frequently in association with Maine Yankee 23 Nuclear Power Plant, and they were questioning as a state 24 why do they need to go ahead and demonstrate the same 25 situations.
Heritage Reporting Corporation (202) 628-4888
REBUTTAL-NO. 23 PANEL - CROSS 22727 y-4x 1- Q And so that satisfied Maine, and at that point the.
I _- 2 document was,co-submitted to FEMA and NRC7
( , 3 A (Gram) Yes, I'believe that's correct. Yes.
4 Q Just so that I'm clear.
5 When you talk about the core scenario document, is 6 that to include everything, at~least of the kind of document that's in the present scenario admitted into evidence except.
B for a number of mini-scenarios?
L 9 -Did it have, for. example, an Extent of Play 10 component for each objective?
11 A (Gram) No.
12 The original scenario submittal and objectives, I 13 don't believe, had all of the Extent of Play or maybe not 14 even any of the Extent of Play associated at that time, at 15' the initial submittal.
16 Q Would you please identify, as best you can, what l
l 17 did the core document include?
18 (Pause while witness searches for document.)
19 THE WITNESS: (Gram) I'm sorry, I don't have my 20 copy of the final scenario. But if someone has a copy of it l 21 I can show you the major portions that were the first 22 submittal.
23 Maybe just to save time, it was basically the
- 24 technical portions of the accident that were going to occur, 25 and the radiological depositions, wind directions, those fN Beritage Reporting Corporation V=)
(202) 628-4888
I 4 i
REBUTTAL NO. 23 PANEL - CROSS 22728 1 types of items.
2 BY MR. BROCK: O ll 3 Q Then do I understand it did not include the !
i I
4- components of the offsite response as the -- well, it did 5 not include Extent of Play; correct?
6 A (Gram) No.
l 7 It would have included objectives to be 8 demonstrated and the core -- when I say the core scenario 9 it's the core initiating events that happen at the plant and ;
10 the subsequent technical results of that. j 11 Q But it did not propose the Extent of Play or mini-1 12 scenarios as to how the responses to those events should 13 occur?
14 A (Gram) Not at that time, no.
15 Q When was that --
16 (Panel confers.)
17 BY MR. BROCK:
18 0 I'm sorry, do you have something to add? l l
19 A (Gram) No. !
20 Q When approximately was the submission of this core 21 document to FEMA and NRC7 i
22 A (Gram) Generally, I believe it was towards the --
23 about the third week in February of 1986.
24 But if you give me a minute I might be able to 25 find the exact date. i I
Heritage Reporting Corporation (202) 628-4888 i
REBUTTAL NO. 23 PANEL - CROSS 22729 1 Q If you would, please, 2 (Long pause to peruse document.)
i I 4 5
! 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 1
REBUTTAL NO. 23 PANEL - CROSS 22730 1 THE WITNESS: (Gram) The date was February 12th, 2 1988.
t 3 BY MR. BROCK:
4 Q Thank you, I appreciate your research.
5 At what point did you receive a response from FEMA 6 on the submittal?
7 And just so I will let you know what's coming.
8 I'm trying to establish a chronology leading up to 9 the final product. So to the extent that you can identify 10 those documents, that's helpful.
11 (Long pause to peruse document.)
12 THE WITNESS: (Gram) The next step in the 13 progression that I can identify.
14 BY MR. BROCK:
15 Q Yes.
16 A (Gram) To the best of my recollection, is that 17 sometime between February the 12th '88 and mid-March the 18 exercise scenario went through a change to conform to FEMA 19 Guidance Memorandum GM EX-3 that was dated February the 20 26th.
21 Now I'm not sure whether or not -- I can't find a 22 formal letter from FEMA telling us that our scenario would 23 have to be revised. I believe that was just through ongoing 24 technical assistance between FEMA and New Hampshire Yankee 25 and the other participating organizations.
Heritage Reporting Corporation (202) 628-4888
]
REBUTTAL NO. 23 PANEL - CROSS 22731 1
So sometime during the time frame following your j'S 1 Q
\s / 2 2-26-88 submittal to mid-March based upon some input from 3 FEMA there was a change in the core document you've 4 described to conform with GM-3 amendment; correct?
5 A (Gram) Yes, sir.
6 Q First, do your records reflect, was that a comment 7 from FEMA or from NRC that led to that change?
8 MR. LEWALD: May I have a clarification.
9 Change in FEMA regulation or change in the core 10 document?
11 MR. BROCK: I apologize, Mr. Lewald.
12 BY MR. BROCK:
13 Q The change in the scenario or the core document
-~, 14 that you've identified, who requested, if you can tell, that 15 change be made?
16 A (Gram) I don't have any documentation to that 17 effect.
18 The best of my recollection is that it would have i
19 been FEMA.
20 Q What change was made as a result of that comment 21 from FEMA?
22 A (Gram) My memory is not that good. I would have 23 to go back and find a copy of the original scenario and look 24 at the subsequent scenario to tell you what those were.
25 O So sitting there you have no memory of how the Heritage Reporting Corporation f (202) 628-4888
\
w
__.__._____m _m____m.m___ __ ____.
l REBUTTAL NO. 23 PANEL - CROSS 22732 1 scenario changed, it's just your testimony did change?
2 A (Gram) Excuse me?
3 Q I say, sitting there today you have no memory as 4 to how the scenario document changed in response to the FEMA 5 comment, that it conformed to Guidance Memorandum EX-3 6 amendment?
7 A (Gram) That's correct.
8 Q How do you know there was a change?
9 A (Gram) I have a letter in front of me dated March 10 the 23rd 1988 to William J. Lazarus, Chief of the Emergency 11 Preparedness Section of the NRC, Region 1.
12 Q And how does that letter tell you there was a 13 change in the scenario document?
14 A (Grsm) "The exercise objectives have been revised 15 to conform to FEMA Guidance Memorandum GM EX-3 f,ated 16 February 26th and the March 7, 1988 amendment thereto. Two 17 copies of the revised exercise objectives for the above-18 named organizations are hereby submitted in accordance with 19 reference C," and that's a letter dated February the 3rd.
20 "The enclosure contains scenario related material 21 and is therefore considered confidential and should be 22 withheld from public disclosure until completion of the l 23 exercise."
24 Q You've just been quoting from the letter you 25 identified? .
l l
Heritage Reporting Corporation (202) 628-4888
( t
' REBUTTAL NO; 23 PANEL - CROSS 22733.
1 A. (Gram) Yes, sir.
/"'
~'N 2 Q Do you recall whether'you personally were involved 3 in conforming the core scenario document to the requirements
'4 of the guidance memo?
5 A (Gram) No, sir, I.do not recall.
6 Q.
You could have been involved,1but you don't recall 7 at this point?
8 A (Gram) 'Yes, sir.
9 Q' And as I understand it, you believe that that was 10 in' response to a FEMA comment, although it's possible it was 11 NRC?
12 A (Gram) I said, to the best of my recollection it 13 was FEMA.
, , 14 Q Do you recall NRC making any comments on the core 15 document that was originally submitted February 26?
16 A (Gram) Yes.
l 17 Q All right.
18 First of all, when did you receiv'e the comment l-19 from NRC on the document?
20 A (Callendrello) Just a correction on that last 21 question.
22 The core document was submitted February 12th was 23 our testimony. February 26 is the date of guidance memo 24 EX-3.
25 Q Thank you, Mr. Callendrello.
Heritage Reporting Corporation (202) 628-4888
l REBUTTAL NO. 23 PANEL - CROSS 22734 l
1 (Witness peruses document.)
2 THE WITNESS: (Gram) Yes. I believe it was in 3 the meeting that was held at the Seabrook site on April the 4 1st.
5 BY MR. BROCK:
6 Q That's when NRC made a comment on the core 7 document that you've identified?
L 8 A (Gram) The portions that related -- the NRC made 9 comments on the portions of the core document that were 10 related to the onsite exercise.
11 Q And you received or Yankee received those comments 12 at this April 1 meeting?
13 A (Gram) Yes, I believe that's correct.
14 Q So just to get the chrono 1cgy then.
15 If I understand it, the core document was amended 16 sometime prior to March 23 '88 in response to a FEMA 17 comment. And then on April 1 New Hampshire Yankee received 18 further comments from NRC on the document; correct?
19 A (Gram) Yes.
20 Q And what were NRC's comments on the core document?
21 (Witness peruses document.)
22 THE WITNESS: (Gram) I don't have any 23 documentation of what those comments were on the April 1st 24 meeting.
25 Heritage Reporting Corporation (202) 628-4888 l r
mm--_-_____ _ _ _
22735 REBUTTAL NO. 23 PANEL - CROSS BY MR. BROCK:
[' h! 1 '
f
2 Q Let me just clarify, I'm not sure whether you said l 3 or not, were you personally present at that April 1 meeting 4 onsite at Seabrook?
5 A (Gram) Yes, I was.
6 Q And who from NRC was there?
7 A (Gram) William Lazarus was one of the attendees.
8 Q Was Mr. Lazarus the contact person at NRC for the 9 scenario development?
10 A (Gram) Yes, I believe so.
So he was present and you were present. Who else 11 Q 12 was present at that meeting?
13 (Witness peruses document.)
14 JUDGE SMITH: I wonder if you could consult with
/N (J '
15 the panel and maybe let them have some of your needs known in advance. We can take a short break.
We can take an 16 17 afternoon break and it might save some of this time.
MR. BROCK: That's fine, Your Honor.
18 19 I thought I had flagged it for them a little bit 20 earlier. I'm trying to establish a chronology of the 21 development of the scenario document leading up to the final 22 product. And whatever inputs were involved in that and the 23 dates.
24 So that's where I'm going and I would be glad to 25 take a short break to let the panel review documents.
R Heritage Reporting Corporation
/
) (202) 628-4888
\s_f m___ _ _ _ - - _ _ i
REBUTTAL NO. 23 PANEL - CROSS 22736 1 JUDGE SMITH: Let's take our afternoon break.
2 (Whereupon, a recess was taken.)
3 JUDGE SMITH: Okay, do you want to start again, 4 we're on the record.
5 MR. TRAFICONTE: Yes.
6 Before we begin cross-examination, resume it, I 7 just would like to have the Board on the record reinstate 8 Basis D of MAG Exercise 19 pursuant to the May 24 Memorandum 9 and Order of the Appeal Board, which I have -- I think 10 everyone here has it.
11 MR. PIERCE: The Board does.
12 MR. TRAFICONTE: Yes.
13 I ask that only obviously as a formality in terms 14 of the record and the timing aspects involved.
15 JUDGE SMITH: The counterpart in this issue -- Mr.
16 Dignan isn't present.
17 Do you have an objection, Mr. Lewald, or anybody from the Applicants? !
18 l
19 MR. LEWALD: I'm really not in the position to j 1
i 20 speak to the matter except that I would think that the j
21 Appeal Board's action is subject -- itself is subject to an l 22 appeal. ll 23 JUDGE SMITH: I think, ju' as yesterday we said 24 our action expunging the contention was simply ministerial l l
2S in view of the remand. And the direction of the Appeal s l
Heritage Reporting Corporation ]
(202) 628-4888 j
)
1
r------__---_ ,
l REBUTTAL NO. 23 PANEL - CROSS 22737
, - ~3 1 Board, our action unexpunging it or reinstating it is also
( ) similarly ministerial and requires no analysis. It's just
\m / 2 3 the understanding of it. And it's pretty clear. l 4 (Laughter) 5 MR. TRAFICONTE: I think it is. I don't want to l
6 analyze it. I just really want you to do it.
7 MR. LEWALD: I'm just not up to the square one we 8 have apparently come back to.
9 JUDGE SMITH: Let's begin immediately with the 10 understanding that you can certainly anticipate in short 11 order the matter being reinstated. I just hesitate to do it 12 in the matter of hours without having the Applicants have an 13 opportunity -- it's reinstated by operation of order if 14 nothing else.
7-~(\
r
(_,/ 15 MR. TRAFICONTE: Fine.
16 JUDGE SMITH: The issue is going to have to be 17 litigated.
18 MR. TRAFICONTE: Your Honor, to be perfectly 1
19 candid, I just --
20 JUDGE SMITH: You need the words " reinstated."
21 MR. TRAFICONTE: Prior to 4:00 p.m. tomorrow I would very much like the words that the issue has been 22 23 reinstated in an open record.
24 JUDGE SMITH: All right.
25 The Appeal Board has acted with great dispatch.
Heritage Reporting Corporation .
I
((") (202) 628-4888 J
r REBUTTAL NO. 23 PANEL - CROSS 22738 1 And they obviously believe that it's a matter that has to be 2 acted upon promptly. Therefore we are obedient to that, 3 interpretation of it. We reinstate --
4 MR. LENALD: Could I ask that the Board hold that 5 order until tomorrow morning.
6 JUDGE SMITH: See, we wouldn't do it for you 7 yesterday. I get the feeling like we're sort of whipsawed 8 here a little bit.
9 MR. LEWALD: That's my great disadvantage, Your 10 Honor. I don't have any reason to believe that the Board's 11 action is going to be different except that I just don't 12 feel that I'm in a position to speak to the matter either 13 one way or the other.
14 JUDGE SMITH: I appreciate it, Mr. Lewald, but the 15 language of the Appeal Board is clear. And it's our 16 responsibility to be obedient to it as soon as we can.
17 There is no issue here, I'm sure, that can't be argued by 18 you.
19 I would like to give you the courtesy at least of 20 checking with Mr. Dignan who was the counsel for it.
21 MR. LEWALD: That was my purpose in asking that 22 the Board withhold.
23 JUDGE SMITH: Could somebody do that?
24 Did you say tomorrow morning?' I really would like 25 to get this done and get on with it.
Heritage Reporting Corporation (202) 628-4888 r
REBUTTAL NO. 23 PANEL - CROSS 22739 1 MR. TRAFICONTE: .Yes, as I would.
/}
-- 0 Again, to be candid, we have put a motion -- on 3 Monday we put a motion before the Commission that's 4 connected to this basis, as the Board knows. The Board is 5 perhaps or perhaps not aware of the fact that we have a stay 6- request in front of the D.C. Circuit as well.
7 I believe the Appeal Board' acted with the dispatch 8 that they did because they perceive some potential relevance 9 of this issue to the low-power license.
11 0 JUDGE SMITH: One way or the other we will' honor 11 the urgency that the Appeal Board saw, which I assume had 12 its genesis in your motion and the arguments before us.
13 MR. TRAFICONTE: Yes.
14 JUDGE SMITH: I just don't want to do it without
("'N,
'- 15 at least checking with your counterpart on the Applicants' 16 counsel, that's all.
17 MR. TRAFICONTE: That's fine.
-18 JUDGE SMITH: We will do it promp'tly.
19 MR. TRAFICONTE: All right.
20 JUDGE SMITH: As soon as we can. And if we can't 21 do that -- well, we'll do it promptly.
22 MR. TRAFICONTE: Okay.
23 MR. BROCK: Your Honor, one other preliminary 24 point Ms. Greer has raised as to the two outstanding motions 25 in limine filed by Applicants. I believe they run to the Heritage Reporting Corporation
's, (202) 628-4888 l l
l
REBUTTAL NO. 23 PANEL - CROSS 22740 1
1 Lonergan testimony and to bed bus testimony.
2 And we would just propose, if it's agreeable to 1
3 Applicants, to schedule those for argument tomorrow morning.
4 Would that be satisfactory?
5 MR. LEWALD: That would be agreeable.
t 6 BY MR. BROCK: ]
7 Q Now, Mr. Gram, you've had an opportunity to review 6 some documents during the break; is that correct?
9 A (Gram) Yes, sir.
10 Q And refresh your memory as to the course of events i
11 and the development of the exercise scenario?
12 A (Gram) Yes, sir.
13 0 I'm not trying to trap you, but my observation was 14 that you were consulting with a number of people other than 15 the people on the panel with you; is that correct?
16 There were other people here today during the 17 break that you consulted with on this issue other than the 18 people on the panel; is that correct?
19 A (Gram) Yes.
20 Q And the reason I point that out is simply that I 21 want to be sure that whatever testimony you are giving is 22 your own memory or as reflected in the documents before you, 23 and that's understood; correct?
24 A (Gram) Yes, sir.
25 Heritage Reporting Corporation (202) 628-4888 l
-_ --_.- - =-___ -
a REBUTTAL NO. 23 PANEL - CROSS 22741 1 Q- Now, I believe we had arrived at an April 1
['"N s/ 2 meeting at Seabrook Station with Mr. Lazarus of NRC and 3 yourself, and I think the question was, the pending 4 question, who else. atte nded that meeting. At least I don't 5 recall an answer to that.
6 Do you at this point know?
7 A (Gram) Well, I don't specifically have any 8 documentation on the actual attendees by name. FEMA was 9 represented, the State of New Hampshire, the State of Maine, 10 and New Hampshire Yankee.
11 Q Let me just stop you there.
12 Was there a particular person at FEMA that you 13 would have considered the contact person during the scenario
'g 14 development, or did you deal with a number of individuals at 15' FEMA?
16 A (Gram) I believe that during the exercise and 17 scenario development, there was one specific individual 18 designated by FEMA as their point of contact.
1 19 Q And who was that?
20 A (Gram) Joseph Hayes, I believe.
21 Q Do you know what his position is in FEMA?
22 A (Gram) Just a minute. I believe I have a letter 23 addressed to him.
24 (Witness reviews document.)
25 THE WITNESS: (Gram) The information I have is Heritage Reporting Corporation O (202) 628-4888 l
REBUTTAL NO. 23 PANEL - CROSS 22742 1 n sph E. Hayes, Chief, and then I don't know what the 2 initials stand for, EM & NPP. ;
3 BY MR. BROCK:
4 Q You are referring to what document, sir?
5 A (Gram) This is just a letter addressed to me from 6 the Federal Emergency Management Agency that was signed by 7 Mr. Hayes.
8 Q And it's your memory that Mr. Hayes was your.
9 contact person throughout the scenario development?
10 A (Gram) Yes, sir.
11 Q Was there a similar designated individual for the 12 State of New Hampshire?
13 A (Gram) Yes, sir.
14 Q And who was that?
15 A (Gram) Mr. Scott McCandless.
16 Q I'm sorry. That last name?
17 A (Gram) Scott McCandless.
18 MR. LEWALD: McCandless?
19 THE WITNESS: (Gram) McCandless, yes.
20 BY MR. BROCK:
21 Q Do you know what Mr. McCandless' position was with J l
22 the State of New Hampshire?
f 23 A (Gram) I believe he was a consultant to the State 24 of New Hampshire. )
25 O So to your knowledge, he was not a member of the i
i Heritage Reporting Corporation (202) 628-4888 l
l 1
( . } 'I REBUTTAL NO. 23 PANEL - CROSS 22743 1 State of New Hampshire emergency response organization?
/
5.
A 2 A (Gram) No.
3 Q And again, he was the regular contact-for New 4 Hampshire Yankee during the scenario development?
5 A (Gram) Yes.
6 Excuse me. Did you say State of New Hampshire or 7 New Har.) shire Yankee?
8 Q Mr. McCandless was the normal contact person for 9 the State of New Hampshire to New Hampshire Yankee.
10 A (Gram) Yes.
11 Q And just to round it out, for the State of Maine?
12 A . (Gram) I believe it was -- the State of Maine 13 representative that was present, and my recollection is not f-~g 14 100 percent on this, was Robert Malaney, Maine' Emergency i
%/
) 15 Management Agency.
16 O And are you referring to some document that 17 suggests that to you, or is that memory?
18 A (Gram) That's my memory.
19 Q And so is it fair to say that the individuals you 20 have identified throughout the spring of 1988, leading up to 21 .the exercise, those were your counterparts that you met with 22 in the scenario development?
23 A (Gram) Yes. There were more people present at 24 that meeting, but I just can't recall all their names.
25 Q And let me be sure I'm clear.
j
-/ Heritage Reporting Corporation
' (202) 628-4888 j I
=- - _ _ - - _ _ - - - _ _ _ _ _ _
REBUTTAL NO. 23 PANEL - CROSS 22744 1 Up until, prior to that April 1 meeting, do I 2 understand the only comment that you had received on the 3 core scenario document that you submitted on the 12th of 4 February was from FEMA and related to the GM-3 amendment?
5 A (Gram) No. The only comment that I could recall.
6 I don't really know if that was the only comment.
7 Q So you may have had comments from others, but you 8 don't recall sitting here today?
9 A (Gram) Yes, sir.
10 Q Who else got the core document that went out on 11 February 12th for comment?
12 (Witness reviews document.)
13 A (Gram) I'm sorry. I don't have that information 14 available.
15 Q Is it your memory that organizations or 16 individuals other than FEMA and NRC received the document, 17 the core scenario document for comment? .
18 A (Gram) No. My recollection would have been that 19 the service list would have been provided the cover letter.
20 The service list in this litigation would have been provided 21 the cover letter, but the scenario, the actual scenario and 22 the Extent of Play was very strictly controlled.
23 Q And strictly controlled in that your memory is 24 only New Hampshire Yankee, State of New Hampshire, State of 25 Maine, FEMA and NRC received copies of that document?
Heritage Reporting Corporation (202) 628-4888 ;
i i
REBUTTAL NO. 23 PANEL - CROSS 22745-p- q - 1 A (Gram) Yes.
\s. / 2- -Q Okay, now as I understand.it, your best memory.of 3 the.only specific proposal --
4' A (Gram) . Excuse me.
5 0 Yes.
6 A (Gram) I have to make a correction.
7 At that time.
8 Obviously, during the day of the exercise, the 9 controllers had to have access to the scenario.
10 Q That's fine. I-guess I was focusing'to the period' 11 up to April 1.
12 That would be correct then?
13 A (Gram) Yes.
14 Q And until that date your only memory of a specific f- s s, 15 comment on the document came from FEMA, and we've described 16 that. And that's the only specific comment you recall as of 17 that date?
18 A (Gram) Yes, sir.
19 Q All right.
I 20 Now, on April 1, there was a meeting with the l
organizations that you have described present at Seabrook 21 22 Station.
i 23 And what happened at that meeting?
24 And if you are refreshing your memory with a -
25 document, I would appreciate it if you would identify that.
Heritage Reporting Corporation
('~'N ' (202) 628-4888
( )
REBUTTAL NO. 23 PANEL - CROSS 22746 j i
1 A (Gram) I'll try. ;
2 (Witness reviews document.)
3 THE WITNESS: (Gram) I have a memo dated April 4 12, 1988, that has enclosed, or attached to it the meeting ;
5 minutes from the April let meeting.
6 BY MR. BROCK:
7 Q And how lengthy are those minutes?
8 I guess my question is running, is it lengthy or 9 is it something that you could summarize for the record?
10 A (Gram) It's lengthy. I'm up to seven pages, 11 including attachments.
12 MR. BROCK: Mr. Lewald, would it be agreeable for 13 you to provide a copy of those minutes to us?
i 14 THE WITNESS: (Gram) I believe these minutes were l 15 made available.
16 MR. LEWALD: I think you already have them.
17 MR. BROCK: I'm sorry, Mr. Gram?
18 THE WITNESS: (Gram) I believe these were 19 available for discovery.
20 NR. BROCK: Fine. Okay.
21 BY MR. BROCK:
22 Q Your memory is what, that they were included in 23 the documents at Seabrook Station?
24 A (Gram) Yes, sir.
25 Q Excuse me.
Heritage Reporting Corporation (202* 928-4888
, j u
I P.EBUTTAL NO.-23' PANEL - CROSS 22747 j f-( .1, MP. BROCK: I appreciate that, Mr. Lewald. With l
! l
- \s 2 that understanding, if I'could get a copy of that, it would 3 be helpful.
l 4 Could I get that after today's proceeding? ,
l 5 MR. LEWALD: We will copy them overnight, copy of j 6 the portion of that record and give it to you tomorrow.
l 7 . MR . BROCK: Thank you.
8 BY MR. BROCK: !
9 O All right, now, Mr. Gram, have you had an 10 . opportunity to review those minutes?
11 A (Gram) In part, yes.
12 Q And based upon'that review, can you summarize for 13 the Board what comments or proposals, if any, NRC had with-14 respect to the scenario document?
i 15 (Witness reviews document. )-
16 A (Gram) The only reference to the NRC in 17 relationship to the scenario document, and if you would 18 like, it's very short, I'll just read it.
19 Under exercise logistics, "NHY to submit the 20 exercise scenario outline to the NRC on April 10, 1988. l 21 (Later, NHY clarified that since the date coincides with a 22 Sunday, the submittal would be made on April 11, 1988).
23 Q Let's just follow that up a second. j 24 What is the scenario outline?
25 A (Gram) I guess just what it says. An outline of s Heritage Reporting Corporation (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22748 i l
1 the pertinent sections of the scenario. I 2 Q Well, if I understood you correctly, the core 3 document that was originally filed, for example, did not f I
4 include Extent of Play or mini-scenarios. I 5 Now, did the scenario outline you have just 6 described, was that to outline those kinds of parts of the 7 scenario, or do you know? '
8 (Witness reviews document.)
9 A (Gram) Maybe it would be easier if we went to the 10 actual submittal on April lith.
11 Q That's fine, Whatever is necessary to refresh 12 your memory.
13 (Witnesses searches for document.)
14 A (Gram) New Hampshire Yankee provided to Mr.
15 Lazarus on April lith, and I will just read here.
16 "This letter submits selected sections of the 1988 l
l 17 graded exercise scenario for your review, Enclosure 1, 18 These materials have been developed in accordance with FEMA 19 Guidance Memorandum EX-3 and the March 7, 1988 amendment 20 thereto. Submittal of these particular sections is also in 21 accordance with an agreement reached at the April 1st 22 meeting at Seabrook Station between representatives of the 23 Nuclear Regulatory Commission, Federal Emergency Management j 24 Agency, New Hampshire Yankee, The States of New Hampshire 25 and Maine. Concurrently, a request for a review of this Heritage Reporting Corporation l (202) 628-4888 l
1 l
t i L - _ -___--__ _
REBUTTAL NO. 23 PANEL - CROSS 22749
~s 1 scenario package are being submitted to Region 1 by the
! I
'N ,) 2 States of New Hampshire and Maine. l 3 "For your convenience, Enclosure 2, Seabrook i i
4 Station Emergency Exercise Scenario Status Sheets provides a 5 listing of all of the proposed scenario sections and the i
6 status of each section relative to this submittal." i 7 Q Do I understand from that that at least all of the 8 sections of the final scenario document were submitted at 9 least in outline form on April lith?
10 Meaning there was an outline form, including 11 Extent of Play,'an outline for mini-scenario; it was a 12 complete outline.
i 13 A (Gram) No.
14 Q All right.
p- ,
x, , 15 Did the outline include Extent of Play?
16 (Witness reviews document.)
17 A (Gram) No.
18 Q So that I'm clear then.
19 As of April 11, 1988, New Hampshire Yankee had not 20 generated any Extent of Play document?
)
21 A (Gram) No, that's not true. !
22 Q Okay, then how is that in error?
23 A (Gram) Extent of Play items were discussed in the j 24 April 1st meeting.
25 Q There was a discussion about Extent of Play?
I l
l e-wx Heritage Reporting Corporation j i I (202) 628-4888 ]
Ns/
t_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _;
REBUTTAL NO. 23 PANEL - CROSS 22750 1 A (Gram) Obviously, they had been forwarded at some 2 point in time to the major participants.
3 0 Well, all right. There was a discussion on April 4 1st concerning Extent of Play for various objectives.
5 Is that your testimony?
6 A (Gram) Yes.
7 Q And prior to that meeting, had Extent of Play for 8 any of the objectives been reduced to writing, to document 9 form?
10 A (Gram) Yes, I believe so.
11 Q Do you recall approximately when that was first i 12 accomplished?
13 A (Gram) No, I don't.
14 Q But your memory is that as of April 1st, there was 15 a -- at least certain objectives had an Extent of Play that 16 had been reduced to writing and circulated among the parties 17 thai you have identified?
18 A (Gram) Yes, sir.
19 Q Would that have included Extent of Play for all 20 objectives, or do you recall?
21 A (Gram) I do not recall.
22 Q Do you recall if anyone other than New Hampshire 23 Yankee had input into that Extent of Play, or those Extent 24 of Play documents prior to April 17 25 A (Gram) I can't specifically recall and give you Heritage Reporting Corporation
- (202) 628-4888 i
l l
REBUTTAL NO..23 PANEL - CROSS' 22751
-- 1: an affirmative answer. -
% ,) 2 The process would'have been -- my answer would'be 3 "yes", because the State of New Hampshire and the State of 4 Maine would have been involved in reviewing at that time 5 proposed Extent of Play before they were sent-out to FEMA 6 and the NRC.
7 -Q So it's your memory that some time subsequent to 8 preparation of the core scenario document there was a 9 -similar process for the Extent of Play portion which New 10 Hampshire Yankee generated and provided to both Maine and 11- Ne'. t Hampshire'for comments.
12 Is that how it happened?
13- A (Gram) Yes, to the exercise negotiating 14 participants for the State of Maine and State of New 15 Hampshire.
16 Q And then once there was agreement among New 17 Hampshire, Maine and New Hampshire Yankee, it was then 18 circulated to FEMA and NRC7 19 A (Gram) I can't characterize it as agreement,-
20 because I believe everybody knew that the process was going 21 to go through several evolutions. So I can't testify _to the 22 fact that there was agreement at that time.
23 There was agreement to submit the proposed Extent 24 of Play in that form.
25 Q All right.
Heritage Reporting Corporation (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22752 l 1 A (Gram) In its present form.
2 Q And just so I'm clear, do you recall approximately 3 when that document went to FEMA and NRC7 l I
4 A (Gram) No, I don't. !
5 Q It was some time prior to April let as best you 6 recall?
7 A (Gram) Yes.
8 Q Do you recall any specific input the State of New 9 Hampshire made to the scenario document before it was 10 submitted to FEMA and NRC, that original -- I'm sorry -- the 11 original Extent of Play document?
12 A (Gram) Prior to April 1st?
13 Q Prior to its submission to FEMA and NRC.
la A (Gram) Well, my problem with the question is that 15 there were several submittals of the Extent of Play to FEMA.
16 Q I appreciate that.
17 What I'm trying to do is isolate the initial 18 Extent of Play document. As I understand it, it was 19 generated by New Hampshire Yankee, and then circulated to 20 New Hampshire and Maine, correct?
21 A (Gram) Yes.
22 Q And do you recall what input or changes or 23 modifications the State of New Hampshire had in the initial 24 Extent of Play before it went to FEMA and NRC?
25 A (Gram) No.
Heritage Reporting Corporation (202) 628-4888 1
I
_ _-. _ _ _ _ _ __ __ __ _ __ D
REBUTTAL NO.'23 PANEL - CROSS 22753 i .- . 1. Q Do you know if they had any changes, or do you 2 recall?-
3' A (Gram) I do'not recall.
4' Q Do you recall any changes the State-of Maine may-5 have had?
6 A (Gram)- No, not -- in the initial submittal, no.
.7: Q At the April'~1 meeting, other than the comments by 8 NRC, do you recall' comments by FEMA, additional comments
- 9. beyond the GM Amendment 3 concern, propose'd changes to the 10 scenario document?
11 (Witness reviews document.)
12 13 14 3
Q 15 16 17 18 19 20 21-22 23 24 25 Heritage Reporting Corporation 4 (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22754 1 A (Gram) Excuse me, could you ask the question 2 again, please.
3 Q Yes.
4 I'm focusing on the April 1 meeting. You've 5 identified some NRC comments that resulted in an April 11 6 submittal.
7 What I'm trying to do is isolate other comments or 8 proposals for change to the scenario document by other 9 participants in the April 1 meeting. And right now I'm 10 focusing on FEMA.
11 In addition to the GM-3 amendment concern, did 12 FEMA at the April 1 neeting propose any change in the Extent 13 of Play or scenario document?
14 A (Gram) Yes.
15 I believe the meeting minutes from the April 1st 16 meeting reflect what ultimately resulted in a change to the 17 original scenario and Extent of Play.
18 O All right.
19 And what was that change or changes that FEMA 20 proposed?
21 A (Gram) Actually, there was a conflict within FEMA 22 between, at that time, with the FEMA RAC Chairman for New 23 Hampshire and the FEMA RAC Chairman in charge of the ORO.
24 And the issue had to do with the calculation of a total 25 population dose calculation.
Heritage Reporting Corporation (202) 628-4888 L _--_----- - - - _ _ - -
O '
~
I REBUTTAL NO. 23 PANEL - CROSS 22755 j- 1 The FEMA'RAC Chairman for New Hampshire'--
t i:. .
2 Q_ Let me stop_you there, I don't want to belabor the 3 point.
4 If I understand it, there was a technical issue 5 raised by FSMA in the April 1 meeting concerning dose 6 calculation, but FEMA was not in harmony at that point 7 exactly how it should be resolved?
8 A (Gram) Well, you have to understand that the two 9 participating organizations: the ORO and the-State of New
.10 Hampshire, at that point perceived that they'were going ~to 11 have to do two'different things to meet the same FEMA 12 objective based on the positions.of the RAC Chairmans.
13' So it was agreed in that meeting that it would go
,-s 14 up for FEMA headquarter direction on the' resolution.
lf'
,\ 15 Q And that occurred?
16 A (Gram) Yes.
17 Q All right.
18 And it was resolved at some point?
19 A (Gram) Yes.
20 Q Can you summarize what was the change to the 1
21 scenario document that FEMA finally came back with? l 22 A (Gram) Well, if I just might read it might help 23 explain.
24 .Q Fine.
25 A (Gram) "The New Hampshire and Maine RAC Chairmans .
1 I
i Heritage Reporting Corporation
( (202) 628-4888 ]
s 3
--- -__- __--_- 1
REBUTTAL NO. 23 PANEL - CROSS 22756 i 1 disagreed that the Extent of Play, i.e., performing the f 2 actual calculation for total population dose calculation was ;
3 required in order to satisfy the FEMA objective."
4 And he stated: "That this issue may require FEMA 5 headquarter's direction."
6 Q And that was the issue that was resolved?
7 A (Gram) That was the issue that was resolved.
l 8 Q Did FEMA propose any other changes to the scenario 9 document or Extent of Play at the April 1 meeting?
10 A (Gram) Yes.
11 Q And what change was that?
12 A (Gram) I believe the changes primarily revolved 13 around taking items out of sequence.
14 And again, if.I might just read the meeting 15 minutes: "The meeting participants agreed that MS-1 16 hospital and environmental lab analysis could be performed 17 separately from the major event time line used to conduct 18 the first day of exercise.
19 New Hampshire Yankee stated that it would consider 20 the options available."
21 Q So there was a concern about removing certain 22 exercise events out and putting them outside the time line; 23 is that correct?
24 A (Gram) Yes.
25 Q And was it ultimately approved that it was Heritage Reporting Corporation (202) 628-4888 1
1 I I a___-__-_______ . _ - _ _
REBUTTAL No. 23 PANEL - CROSS 22757
- >w 1 ' permissible to do that?
k ,) 2 A (Gram) Yes.
3 Q okay'.
4- Were there any further FEMA proposals at the April 5 1 meeting?
6 Let me-just back up one second.
7 Were there.any other exercise events which were 8 discussed to be taken out of sequence or out of the time 9 line at that April 1 meeting?
10 A (Gram) My memory is not good enough to remember 11 that. I'm relying on the notes of the meetings.
12 Q And with that assistance do you recall any?
13 A (Gram) No, I do not.
14 Q Do I understand that . with the exception. of the
\ ,/ 15 couple events which you've just identified, the remainder of 16 the exercise events at that point were to be conducted in 17 sequence consistent with the time line?
18 A (Gram) At that time, yes.
19 O And just so the record is clear when we say 20 " consistent with the tirae line", that is that the events 21 would unfold in the exercise as if it was an actual 22 emergency; correct?
23 A (Gram) Yes.
24 Q I can't recall if you answered this: does.that 25 exhaust the FEMA comments at the April 1 meeting?
Heritage Reporting Corporation
.-. (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22758 1 A (Gram) Well, there were a lot of other comments 2 that were related in the meeting minutes but none that have 3 to do -- none that actually relate to the actual scenario.
4 There is a comment at the very end of the meeting 5 minutes under the title, " Detailed Extent of Play."
6 And it says: " Notes of this section will only be 7 provided to the designated points of contact to ensure 8 confidentiality from playerc."
9 And these documents I don't have copies of what 10 those were.
11 Q That's fine.
12 MR. BROCK: Your Honcr, just for the record, given 13 that the witness has referred extensively to those minutes, 14 I would propose to mark those and offer them, but as I 15 understand it, I won't have the copies until tomorrow and I 16 will make the offer at that time. Just so the record is 17 complete on that.
18 BY MR. BROCK:
19 Q You have identified NRC and FEMA concerns or 20 proposals to amend the scenario document or Extent of Play 21 at the April 1 meeting.
e 22 Were there any further changes to the original 23 core document or original Extent of Play document proposed 24 by the State of New Hampshire; New Hampshire Yankee; or 25 Maine at that meeting?
Heritage Reporting Corporation (202) 628-4888
~
t REBUTTAL NO. 23 PANEL - CROSS 22759 i )
f] - 1 A (Gram) None that I can recall without the
'\ ~- ) 2 additional notes that deal with detailed Extent of Plays.
1 3 -Q That's fine.
4 Why don't we just leave it that way. I would ask j 5- that perhaps during the evening you could' refresh your 6 memory and I might return to that in the morning.
7 Thank you.
8 MR. LEWALD: Your Honor, I don't have the benefit 9 of the cross-examination outline, but to the extent that 10 it's material and relevant we certainly don't have any 1
11 objection to introducing or making available all these 12 meeting notes.
13 It's quite obvious that Mr. Gram is not a paper 14 shuffler. He didn't send out the notices; somebody else fx
(
L/ ) 15 did.
16 And to the extent that this is material we would 17 be glad to provide the document?. tion.
18 MR. BROCK: That's helpful, Mr. Lewald.
19 MR. LEWALD: Instead of going through a torturing 20 memory process which is ending up the same place anyway.
21 MR. BROCK: Well, Your Honor, these witnesses are 22 being offered to defend the scope of the exercise and I 23 don't think it should be any surprise.
24 JUDGE SMITH: He has r.ot made any objection.
25 MR. BROCK: Okay.
Heritage Reporting Corporation l
[}
y j/ (202) 628-4888
f: .
REh*!TTAL NO. 23 PANEL - CROSS 22760 1 I wasn't clear. If that's not an objection, then 2 T'11 let it stand. !
3 JUDGE SMITH: I think it's just a suggestion that 4 if you' re going to offer the minutes anyway why go through i
5 them so thoroughly, 6 Is that what your point is?
7 MR. LEWALD: It is, Your Honor.
8 To the extent that it's relevant to his line of ;
9 inquiry. We certainly don't have any objection. And it 10 would cut all this out.
11 It'c trying to put it in through Mr. Gram who, 12 obviously, does not have a present memory of all of the 13 detail that he is being asked.
14 MR. BROCK: Well, Your Honor, I agree that the 15 minutes --
16 MR. LEWALD: If it's for impeachment, I suppose 17 that's one thing. But I'm not sure that it is.
18 JUDGE SMITH: Well, you're not objecting, are you?
19 MR. LEWALD: No.
20 MR. BROCK: I'm not sure what it was, then, Your 21 Honor.
~
}
22 JUDGE SMITH: Well, I think his point is well 23 taken. You're not accomplishing much by examining -- well, 24 I think his point is well taken if you recall what he said.
25 MR. BROCK: I'm not trying to belabor the point, I
Heritage Reporting Corporation (202) 628-4888 l
l ___
REBUTTAL NO. 23 PANEL - CROSS 22761
,. - 1 Your Honor,'but the fact is that whether reflected in those
/
( ,,) - 2 minutes or by conversations, that this witness had through 3 other sources as of the time -- I'm trying to get this 4 witness who says he was the chief architect for New 5 Hampshire Yankee with various sources of information, you 6 know, what was the sequence.
7 JUDGE SMITH: There's no problem with that.
8 The problem that Mr. Lewald is alluding to, I 9 think, is don't run him through the minutes when you' re 10 going to put the minutes on anyway unless you're doing it 11 for another purpose.
12 MR. BROCK: Well, in part I'm trying to test his 13 memory. And also, see if there may be additional sources of
~. 14 information.
) 15 JUDGE SMITH: Fine. Great.
16 Mr. Brock, we have another concern or at least an 17 observation.
18 MR. BROCK: Yes, sir.
19 JUDGE SMITH: And that is, we wonder to what 20 extent you prepared for this cross-examination by discovery?
21 MR. BROCK: Well, Your Honor, frankly, the focus 22 as the outline shows is to the scenario -- I mean, to the 23 testimony. And that is the prinary focus of the cross, 24 although I don't know in time how lengthy that will be.
l 25 But the fact is, Your Honor, this testimony i l
, fg Heritage Reporting Corporation l l (202) 628-4888 l
REBUTTAL NO. 23 PANEL - CROSS 22762 1 doesn't -- at least I don't recall -- include a line as to 2 what the roles,of these individuals were.
3 I agree we received this on April 18th; that 4 there, you know, perhaps is some time for discovery at that 5 point.
6 JUDGE SMITH: No, earlier?
7 You don't think you could have had discovery 8 earlier on this issue?
9 MR. BROCK: Certainly, there could have been some 10 discovery on the issue, Your Honor.
11 JUDGE SMITH: But there wasn't.
12 MR. BROCK: But there wasn't.
13 And frankly, Your Honor, the panel is composed 14 exclusively of New Hampshire Yankee people, and we were 15 expecting perhaps the State of New Hampshire or there would 16 be some additional people from which we could get 17 information from.
18 MR. LEWALD: Your Honor, we have a book here full 19 of discovery production. There has been extensive discovery 20 in this matter.
21 JUDGE SMITH: Yes, I know that.
22 Maybe he has had the documents. Our observation 23 was, he seemed to be referring for th'e first time to 24 documents that we felt that normally he should have been on 25 top of or have had available for his cross-examination.
Heritage Reporting Corporation (202) 628-4888
q..
REBUTTAL NO. 23 PANEL - CROSS 22763 f 1. Let's just continue.
2- MR. LEWALD: That'siindeed the impression that is 3 conveyed.- That's.why_I_ thought we could cut it.short by.
'just producing ~the document.
~
p '4 l'
! 5 JUDGE SMITH: Let's go on.
! '6 BY MR. BROCK:
7 Q. Mr. Gram, I believe that you have identified the 8 changes to the scenario document and Extent of Play as of-9 April 1.
10 I would like to narrow the focus at this point to 11 the Extent of Play document and ask you, that subsequent to.
12 the April 1, '88 meeting, when were the next changes to.the 13 Extent of Play document or would you describe the process by
~~ 14 which that document involved?
(, '15 A- -(Gram) Maybe _: would be helpful if I went 16 through the whole chronology of the process to the point 17 where we ended up with the final scenario and the final 1 1
18 Extent of Play on the day of the graded exercise.
19' Q ?ine. Please, 20 A (Gram) As I stated, there are a set of meeting 21 minutes for the April let meeting that are dated April the
^
22 lith; 23 There was also a submittal to the NRC on April 24 lith.
25 Q That's the scenario outline at which you referred Heritage Reporting Corporation O (202) 628-4888
I -
l REBUTTAL NO. 23 PANEL - CROSS 22764
{
i i previously?
2 A (Gram) "This letter submits selected sections of 3 the 1988 graded exercise ccenario for you review, Enclosure 4 1."
5 Q That is the scanario outline?
6 A (dram) Yes.
7 There was then on April the 12th, I issued the 8 meeting minutes from the April 1st meeting. And in addition 9 to that set up another meeting for April the 12th. Excuse 10 me, April the 20th.
11 And the purpose of that meeting was to discuss the 12 exercise scenario and incorporate comments to the scenario 13 and detailed Extent of Play, i
14 Q All right.
15 And these were comments that you had received 16 prior to the meeting?
17 A (Gram) No.
18 The time frame was such that people brought their 19 comments to the meeting.
20 Q All right.
21 Would you describe what occurred at that meeting?
22 A (Gram) At the April 20th meeting?
23 Q Correct.
24 A (Gram) At the April 20th -- maybe I could just 25 read the agenda.
Heritage Reporting Corporation (202) 628-4888
{.
REBUTTAL NO. 23 PANEL - CROSS 22765.
L~ .
l' We talked about exercise logistics.in helping the
'2' NRC and FEMA find critique locations.
3 We talked about evaluator packets for FEMA.
I 4 We talked-about a backup second scenario in case
~
5 the first scenario and Extent of Play was made public.
l:
6 We talked about ground rules for Intervenor 7 observation.
8 Q Let me just stop you there.
9 What ground rules were discussed about Intervenor 10 observation?
11 A (Gram) I believe at that time we talked about the 12 need to setup a set of ground rules.
13 Q All right.
,, 14 So none were proposed at that meeting?
15 A (Gram) No.
16 We talked about exercise objectives and Extent of 17' Play.
.18 And specifically, issues to be resolved were total 19 population dose calcu3ations; positions requiring 24-hour 20 staffing for ORO. And we also talked about the 21 representative sample methodology.
22 Q Well, again, focusing on Extent of Play.
23 What was the form of the document at that point as 24 compared with the final Extent of Play document used in the 25 exercise?
Heritage Reporting Corporation (202) 628-4888 v
REBUTTAL NO. 23 PANEL - CROSS 22766 1 A (Gram) The best information I have on that is 2 Enclosure 2 to the April lith letter to the NRC, which I 3 mentioned before.
4' "This letter submits selected sections of the 1988 5 graded exercise."
6 Attachment 2 is: "Seabrook emergency exercise 7 scenario status." And it lists 12 categories with 8 subcategories, a total of 22 individual items. And there 9 are three categories for each item.
10 Q Well, let me just stop you there.
11 I'm not asking you to reconstruct verbally what 12 the document is. What I'm trying to get a sense of is, how 13 far along was the Extent of Play document? How far had it 14 evolved as of April 20th as compared with the final product?
15 A (Gram) I was just about to try and give you some 16 indication.
17 Q I'm sorry.
18 A (Gram) Enclosure 2 has, as I mentioned, the 21 or 19 so items listed and across the letter it has three separate 20 categories: provided in full; provided in part; and to be 21 provided at a later time.
22 Q Just so I'm clear, when you say "these items that l
l 23 were provided in part or in full," those were Extent of Play 24 for various objectives?
25 A (Gram) Well, maybe it would help if I read some Heritage Reporting Corporation (202) 628-4888
't_-
REBUTTAL:NO. 23 PANEL - CROSS 22767 b'
[% 11'. of'the. items.
' !S 2 ~ Item number.1 are planning elements.
3- LItem 2.are exercise' objectives.
4 Item 3 are exercise guidelines.
5' Item 4 are controller instructions.
6 ' Item 5 is a narrative summary.
7 ~Q Okay.
~8 A (Gram) Item 6.1 is a detailed scenario 19 -description.
10 0 Let me.stop.you there.
11 Now, I think one of the items you referred to are 12' the exercise objectives; correct?
13' A (Gram) Yes.
14 Q All'right.
' 15- And what I'm trying to pin down is: at that point 16 what did the Extent of Play document look like-with respect 17 to each of the exercise objectives?
18 A (Gram) Each of the exercise objectives had been 19 identified and provided in full.
20 Q All right.
21 So there was -- excuse me.
22 There was a complete Extent of Play, at least, for L 23 each exercise objective as of April 20?
L 24 A (Gram) No.
25 Heritage Reporting Corporation (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22768 .
1 Q They were not?
2 So there were certain objectives for which the 9l ]
I 3 Extent of Play -- I understand there were subsequent ;
)
4 modifications to the Extent of Play. ]
l 5 But at least was it a complete document at that 1 6 point?
7 A (Gram) No, I do not believe so.
8 Q Would it be fair to say that it was complete for 3 9 certain objectives and incomplete for others?
10 MR. LEWALD': I'm going to object to that. That's 11 a question that can't be understandable.
12 MR. BROCK: Well, if the witness understands it, i 13 he can answer it.
14 JUDGE SMITH: I thought it was understandable.
15 If you don't understand it, though, that's another 16 problem.
17 MR. LEWALD: The problem is if the witness says 18 "yes", then where are we?
19 JUDGE SMITH: Well, he shouldn't say -- well, I 20 don't know.
21 No, he can say "yes" or "no" or "I don't know".
22 THE WITNESS: (Gram) My lawyers taught me to say, 23 "Would you please repeat the question?".
24 BY MR. BROCK:
25 0 Well, let withdraw whatever was on the table and l
Heritage Reporting Corporation (202) 628-4888 l
iSi REBUTTAL NO. 23 PANEL - CROSS 22769 1 ask you: Do I understand then that as of April 20th.there S -
2 was an Extent _ of Play document which was complete for
~
3 certain exercise objectives, incomplete for others?
4 A (Gram) Yes.
5 Q Do you know which objectives it was still 6 incomplete?
7 A (Gram) Well, I can't state entirely for a certain 8 fact all of the items, but I can tell you in the April.20th 9 meeting part of the agenda that I read had to do with 10 exercise objectives and Extent of Play. And'one of the 11 items I read was total dose population calculations. .That 12 issue had not been resolved at that time, so the Extent of 13 Play had not'been finalized at that time.
14 Q And which objective does that run to?
f 15 Do you recall right now?
16 (Pause . )
17 You don't recall?
18 A (Grain) I'm going to say Objective 34.
19 Q All right, that's your best memory. Subject to 20 check, that's your teetimony" Just to save time, subject to 21 check, you believe it's Objective 34?
22 A (Callendrello) I don't believe that is the 23 correct objective.
24 Q Okay. Well, if you wish to assist his memory, go 25 ahead.
/~~ Heritage Reporting Corporation !
( (202) 628-4888 {
o '- ;
i E____-
REBUTTAL NO. 23 PANEL - CROSS 22770 1 A (Callendrello) I don't recall offhand what it is, 2 but 34, I think, is staff.
3 Q All right, let me move off that point.
4 Do you recall any other objectives for which there 5 was not a complete Extent of Play as of April 20th?
6 A (Gram) Again, the second item under that category 7 of exercise objectives and Extent of Play are positions 8 requiring 24-hour staffing for ORO.
9 Q Okay.
10 A (Gram) So the Extent of Play at that point on 11 that issue would not have been resolved either.
12 Q Further objectives that were still outstanding as 13 of April 20th for Extent of Play?
14 MR. LEWALD: Is that the whole -- are we talking 15 about objectives that are outstanding, or are we talking 16 about Extent of Play that's outstanding with respect to the 17 objectives.
18 MR. BROCK: If it wasn't clear, Mr. Lewald, I 19 believe we have been talking about this for several minutes i 20 now.
21 BY MR. BROCK:
22 Q Were there other objectives for which there was 23 not a complete Extent of Play other than the ones you have 24 identified, on April 20th? ,
25 A (Gram) I believe at the time there may have been Heritage Reporting Corporation l (202) 628-4888 l l
4
REBUTTAL NO. 23 PANEL - CROSS 22771 "aisimilar issue on 24-hour staffing in New Hampshire, and
~ 1-
\, -
2 that Extent of Play would'not have been resolved at the
-3 time.
- 4. Q And does that,'to the best of your knowledge, 5 ' summarize the outstanding objectives that--did not-have i
6 complete Extent of Play?
7 (Witness' reviews document.)
8 JUDGE SMITH: Let's go off the. record for a moment 9 while he is looking.
l 10 MR. BROCK: All right.
11 (Discussion off the record.)
l 12 BY MR. BROCK:
13 Q Mr. Gram, -just trying to move it along. !
14 At least based upon your memory and your review to
~
15 this. point of documents, that was the extent of the 16 outstanding objectives that still needed further Extent of 17 Play; is that correct?
18 A (Gram) No, I have a note that would indicate to 19 me that the issue of the Red Cross participation at 20 congregate care centers was not a resolved issue, and that 21 FEMA was going to try to pursue participation by the Red d
22 Cross for the graded exercise. And, therefore, the Extent 23 of Play through a congregate care center wss not closed at 24 that point in time.
25 0 And does that exhause it, at least, as you sit l
I N Heritage Reporting Corporation )
(202) 628-4888 i
)
REBUTTAL NO. 23 PANEL - CROSS 22772 1 there right now?
2 A (Gram) Well, the meeting minutes from the April 3 20th meeting have a very detailed section on the sections of 4 Section 2 of objectives and Section 3 of Extent of Play of 5 the overall scenario that reflect agreements reached between 6 all parties on items that have to be revised, and it's 7 rather extersive.
8 Q at me ask you this: Were there changes to --
9 let's focus for a minute on Objective 19, which is with 10 regard to protective actions for schools.
11 Now, can you tell me, on April 20th, was that 12 objective in the form in which we have it in the final 13 document?
14 MR. LEWALD: Is that a question?
15 MR. BROCK: That's correct.
16 MR. LEWALD: The final document being Exhibit 617 17 MR. B R O C F.: That is correct.
18 THE WITNESS: (Gram) Yes.
19 BY MR. BROCK:
20 Q All right. so as of April 20th the Extent of Play 21 for Objective 19 looked the same as it does --
22 A (Gram) That's not what you asked me.
23 Q Okay, I'm sorry.
24 A (Gram) The previous question only said 25 " objective".
Heritage Reporting Corporation (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22773-
/'~'N 1 Q Oh, the objective was the same?
-l }
\s/ 2 A (Gram) Yes.
3 Q Was the Extent of Play for that objective the same 4 on April 20th as it appears in final form?
5 A (Gram) The notes that I have in front of me would 6 lead-me to believe that the answer to that was "no".
7 There's a reference here specifically for the State of New 8 Hampshire to Objective 19, Reference EB-2 guidance, and then 9 there is a note that says, " Identify participating schools".
10 So I would assume during the process it was 11 identified that someone wanted, probably FEMA wanted the 12 participating schools detailed in the Extent of Play.
13 Q When you say " detailed in the Extent of Play".
14 A (Gram) Listed the actual schools listed by name g%
4 i
(/ 15 instead of probably just SAU.
16 Q So if I understand correctly then, your notes 17 reflect the concern by the State of New Hampshire concerning 18 Extent of Play for Objective 19 that had to do with 19 identifying participating schools?
20 A (Gram) No. My notes do not reflect who provided 21 the comment.
22 Q Do you know if any action was done with respect to i
23 that comment?
24 A (Gram) I would have to go back and look at the 25 form of the Extent of Play for that objective for that state Cj Heritage Reporting Corporation g
s / (202) 628-4888 v
l REBUTTAL NO. 23 PANEL - CROSS 22774 1 prior to the 20th, or at the 20th meeting, and then what the 2 subsequent result was. I just can't recall.
3 Q And so you can't presently state whether or not or 1
4 to what extent Extent of Play for Objective 19 was the s me l I
5 or was subsequently changed after April 20th? I 6 A (Gram) No, I cannot state specifically. But I l I
7 can state that all of these comments were addressed and 8 resolved with whoever the original provider of the comment I 9 was.
10 Q Is there any other comment with respect to 11 Objective 19 of which you were aware that had to be 12 addressed in the Extent of Play?
13 A (Gram) Yes. Under Massachusetts ORO for 14 Objective 19, there is a note or a comment that says, ,
15 " Identify number of schools to be exercised and how many 16 buses per school will be dispatched. (Check with Appendix 17 M) . "
18 Q All right, not to take time at this point, but I 19 would appreciate that before we resume in the morning if you 20 could -- my interests are really focusing on Objectives 18, 21 19 and 20 and the extent to which those objectives were in 22 final form or were not in final form as of April 20th, and 23 if there were changes subsequently, what were those changes.
24 MR. LEWALD: You mean Extent'of Play?
25 MR. BROCK: That is correct, Mr. Lewald. The Heritage Reporting Corporation (202) 628-4888
REBUTTAL NO. 23 PANEL - CROSS 22775
.1 Extent of Play for ' those objectives.
- (f 2- BY MR. BROCK:
3 Q Do you understand,' sir?
4 'A- f? ram)- Yes. Could you give me the objectives 5 again?
6 Q Yes.
7 A (Gram) Eighteen, 19 and --
8 0 Objectives 18, 19 and 20, and the question is:- To 9 what extent the Extent of Play for those objectives was in
-10 final form as of April 20th, or if there were' changes, what 11 were the changes and who proposed them.
12 Now can you tell me, at least generally, as a' - j 13 result of the April 20th meeting, and I believe'there is a 14 reference in your testimony to that being a significant 1
( ]/ 15 meeting in the formation of the scenario document and Extent 16 of Play; is that correct?
17 (P ause . )
18 BY MR. BROCK: .
19 Q First of all,.do you recall any reference in your 20 testimony to that?
21 I believe that -- let me look at page 17.
22 A (Gram) Yes, I do. I'll find the page in a 23 second.
24 Q Page 17 I'm look at, of your testimony. !
1 25 And do I read that correctly that that was, is it i Heritage Reporting Corporation j (202) 628-4888
\ l l
h REBUTTAL NO. 23 PANEL - CROSS 22776 !
1 fair to say, the watershed meeting in terms of firming up 2 the scenario document and Extent of Play?
3 Although there may have been specific changes, the 4 basic structure -- well, more than the basic structure --
5 the document was in fairly final form as a result of the 6 April 20 comments?
7 There was not a significant change following the 8 revisions as a result of April 20 and the document actually 9 used in the exercise?
10 A (Gram) Yes. I believe that's a fair 11 representation.
12 Q And just so that I'm clear, were there any other 13 meetings at which all the parties that were at the April 20 14 meeting reconvened or from April 20 on, was it a matter of 15 just firming up detail pretty much?
16 A (Gram) Yes, I believe there was one final 17 meeting. I believe it was May 20th.
18 Q May 20th?
19 A (Gram) Yes.
20 Q And was that at Seabrook Station?
21 Well, let me withdraw that.
22 Did it have the same participants who had been at 23 the April 20 meeting?
24 A (Gram) The same organizations would have.
25 0 All right.
Heritage Reporting Corporation (202) 628-4888 r
._____-_-_--____A
' /s ,
e REBUTTAL'NO. 23 PANEL CROSS 22777 i
. ' /] 'l A (Gram) I can"t testify to the actual 2 participants.
3 Q And what was the purpose-of the May;20' meeting?
4' Let'me ask you this. Was the purpose to finalize 5 the scenario document and the Extent of Play, finalize.those 6 details?
7 A (Gram) Yes. The purpose of the meeting was-to.
8 finalize as many things as possible in regards to.the Extent ~
9 of Play or how mini-scenarios were going to be played out, 10 those types of things.
11 .Q So it was really getting into the details:of 12 actually performing the exercise?
I' -13 A (Gram) Yes.
p 14 Q .Did you have a role in the Seabrook exercise last w/ 15 June?
16' A (Gram) No, I had no official role as a. controller
.17 - or'a player.
18 If I had any role, it was official worrier.
19 Q I'm sorry. Official?
20 A (Gram) Worrier.
21 Q Okay. Where did your worries take yo1, or what 22 were you doing during the two days of exercise?
23 A (Gram) I was observing at various of the 24 facilities: the EOF, the State of New Hampshire IFO, the i
25 ORO, EOC, the joint telephone media center, the joint media f-9s Heritage Reporting Corporation l (202) 628-4888
(
2
REBUTTAL NO. 23 PANEL - CROSS 22778 1 center in Newington, and the ORO alternate staging area in 2 Salem, New Hampshire. And I also visited the FEMA control 3 cell and the NHY control cell which were located at the 4 Seabrook site.
5 Q Of the places that you have identified, how many 6 of them did you travel to in day one of the exercise?
7 Were most of your travels on day one?
8 9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888 1
1 1 l i
I 1
1
- REBUTTAL NO.!23' PANEL - CROSS '22779
.,- 1 A (Gram) On Day 1:of the exercise I visited all of 2 .those places that I referenced.
L 3' On Day 2 of the' exercise I'would have been at the.
4 EOF to New Hampshi're; the OROs; EOC, I would have been at 5 the IFO, but.they were basically winding their operations 6 down. I would have been at the joint telephone center. And 7 I would have'heen.at the media center in Newington, 8 Q That was'on Day 27 9 A (Gram) That was Day 2.
10 Q All'right.
11 And Day 1, where were you? I'm sorry.
12 A (Gram) 'All of those same facilities.
- 13 In addition, the-Salem staging area and the FEMA 14 and NHY control cells which were onsite at Seabrook Station.
I5 15 Q All right.
16 Other than official worrier did you have a 17 specific mandate or responsibility or what did y a 18 understand your function to be?-
19 A (Gram) No role at all in the exercise. i 20 0 Were there particular --
21 A (Gram) Excuse me.
~
22 I did play, I would call it an, executive 23 management role. One of the instances, there wa. a problem i
24 with access for some of the Interveners to the EO -- excuse 25 me, to the EOC for ORO and I helped participate to resolve Heritage Reporting Corporation
~,7-~ (202) 628-4888
-A -__n-w---- -.-----.x
REBUTTAL NO. 23 PANEL - CROSS 22780 1 that, I believe.
2 Q Okay.
3 But as I understand, that was a fairly limited 4 issue. Basically, you were floating and observing.
S' Is that fair to say?
6 A (Gram) Yes, sir.
7 Q Did you maintain a log?
8 A (Gram) No, sir.
9 Q Did you travel with anyone else?
10 A (Gram) At one point in time.there was a visitor 11 from Long Island Lighting that traveled with me.
12 Q So that individual --
13 A (Gram) I just took him around the facility so he 14 wouldn't get lost.
15 Q You did not understand your function to be 16 observing or evaluating any particular events or functions 17 in the exercise?
18 A (Gram) No , sir.
19 Q Did you have a standard way of proceeding when you 20 would arrive at one of these facilities?
21 Was there a contact person you would approach?
22 Were there certain information you sought or did 23 you simply go around and have conversation just sort of 24 casually as it might occur?
25 A (Gram) Whenever I went into a facility the first Heritage Reporting Corporation ;
(202) 628-4888 i
REBUTTAL.NO. 23' PANEL - CROSS 22781 L ;fe3 1 thing I would do.would be status myself-from the information-
_s 2 available on the status boards in the facility, to find out 3 where the scenario or sequence of events happen to be 4 . playing ~out.
5 And then at some convenient time I might. talk to.
6 the facility lead controller, if he was not in the' middle of.
7 observing something or interjecting play, interjecting mini-8 scenarios or something for the players, I would just ask him 9 how things wero going.
10 Q .All right.
11 And so that was generally the way you proceeded to 12 the different areas?
13 A (Gram) Yes, sir.
14 Q Did you report during the exercise to anyone?
( 15 A (Gram) I don't understand your question.
s.
16 0 Well, as you went around and made various 17 observations, I understand at first, you did not maintain a 18 log; correct?
19 Is that correct?
20 A (Gram) Yes.
21 Q All right.
22 Did you contact any person or persons concerning 23 your observations during the course of the exercise?
24 A (Gram) During the course of the exercise I 25 believe I had discussions with other New Hampshire Yankee Heritage Reporting Corporation (202) 628-4888
1 1
REBUTTAL NO. 23 PANEL - CROSS 22782 1 executive management.
2 One, to keep my immediate superior informed of 3 where I was; and then, just relay to him how I perceived 4 things to be going.
5 Q And that is something that you did periodically 6 through the exercise?
7 A (Gram) Yes.
8 Q Subsequent to the exercise -- and let me just jump 9 to that.
10 First, did you generate your own report of your 11 observations?
12 A (Gram) No. '
13 Q Let me just ask you this.
14 Even though you didn't understand your role as 15 focusing on a particular function or event in the exercise, 16 were the circumstances such that there were particular 17 objectives that you did focus on or did you see your role 18 more as just overseeing the general flow of events?
19 A (Gram) My primary interest was in the overall 20 flow of the events through the two days of the exercise.
21 Actually, there were five days of exercise in the scenario.
1 22 But over the last year and a half, at that time --
23 excuse me, a year -- I had been involved in emergency !
24 planning. I knew just from my understanding of the scenario 25 and the events when significant items were going to happen.
Heritage Reporting Corporation (202) 628-4888
L. s
-l REBUTTAL NO. 23 PANEL'- CROSS 22783 I l
L( 1; So I might stage myself at a location just to ses-
-! 2 how- a particular organization handled that event. 'Just to 3 see'what happened.
4 Q Let me just close the point here. 1 5 were you involved in the 1986 exercise for-
- 6. Seabrook?
7 A- (Gram) No.
81 MR. BROCK: Your Honor, this might be a gos ime i
9 if it's convenient for the Board, I will be' moving into a 10 different line.
11 JUDGE SMITH: All right.
12 Anything further then on the record before we 13 adjourn?
g , 14 MR. LEWALD: No.
\s 15 JUDGE SMITH: We' re off the record.
16 We.will meet tomorrow at 9:00.
17 (Whereupon, at 5:00 p.m. the hearing was adjourned 18 to reconvene tomorrow morning at 9:00 a.m., Thursday, 19 May 25, 1989.)
20 21 22 23 24 25 Heritage Reporting Corporation
\g, (202) 628-4888
r -
'-L i
CERTIFICATE
-/ .
y l
-This is to certify that the attached proceedings.before the-ll United States. Nuclear Regulatory Commission in the matter l, 'of:
Name: Public Service Company of New. Hampshire, et al.
(Seabrook Station, Units l'and 2)
Docket No: 50-443-OL 50-444-OL (Off-site' Emergency Planning)
Place: . Boston, Massachusetts Date: 'May.24, 1989..
were held as herein appears, and that-this is-the original
%) transcript thereof-for the file of the-United States Nuclear Regulatory Commission taken stenographically by me and, thereafter reduced to typewriting by me or under the
-direction of the court reporting company, and that the transcript is a true and accurate record of the foregoing
. proceedings.
/S/ Yhk _ . f-(Signature typed): Donna L. Cook Official Reporter Heritage Reporting Corporation i
HERITAGE REPORTING CORPORATION (202)628-4888 I
- _ _ . - _ - _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _ _