ML20247G468
| ML20247G468 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 04/06/1989 |
| From: | AFFILIATION NOT ASSIGNED |
| To: | |
| References | |
| OL-I-MAG-058, OL-I-MAG-58, NUDOCS 8905300409 | |
| Download: ML20247G468 (5) | |
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1 Q.-
Taking c o m p e n s a t i ng/.'!..
measures.
For Y, l n :..
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2 example, think about this q u e s't i:o n in'the context vu r
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of schools, the utility'has taken compensatory y
'4 measures.
you have reviewed them.
-In fact, we 5
can stipulate'it's not clear there are any
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6 a d d i t. l o s a l compensatory measura' that coul* be 7
taken.
They have done all they can do in the way 8
of compensatory measures.
There seems to be no 9
other solution.
The schools are refusing to 10 participate.
11 I'm asking the question, is it an L12 intellectual possibility that your judgment as a 13 planner could be there still is not an adequate i
14 level of preparedness?
15 MR. FLyNN:
More information, is 16 part of your premise this is a planning question 17 or exercise question?
18 (Discussion off the record.)
. ;t 19 Q.
Nr. Donovan, we just had a fairly lengthy 34 w
20 dff the record discussion and I want to put one 21 question to you and it might still need to be 22 reformed and revised a little bit but, in effect, 23 to try to summarize the discussion we had, in r-24 reviewing a utility plan and in reviewing.the L_
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1 compensatory measures 1taken by the[ut111'ty
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compensate"for the nonparticipating governments, r.
making'a judgment on the effectiveness of.
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are.you 4
Ithe. compensatory measures in the event of an 5-actual' emergency?
6 A.
M *Jnt a ludgmentLon the corp nsatory g
7 measures against the criteria and the criteria is:
o 8
designedLto address a spectrum of emergencies..
9 MR. FLYNN:
Let me-suggest s.omething 10
'here.
InJone. sense, you are asking a legal 11 question and I's not bringing that up as an
- 12 objection but by way of.an offer to^ stipulate.
13 MR. TRAFICONTE:
That's what-I would
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14 love to-do.
'We've been around this bush'so many
'15 t i m e s '-
I think it's my own lack of art to be able 16 to nail this down.
17 MR. FLYNN.:
The other point I would 18 like to make is the sense of your' question is 1
wpether.11 is 19 part of FEMA's evaluation to judge 20 Shether some threshold of safety is accomplished 4
1 21 by the plans.
That's not the best way to phrase 1
22 it, perhaps, but you are asking the question from-(
E 23 the point of view of whether the plans are 24 evaluated to judge if there is some quantitative COPLEY COURT REPORTING
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1 measure, perhaps, of the. level of safety achieved 2
by the plans or if not a quantitat-Ive measure,
'3 then some subjective estimate of-the efficacy of 4
the plan in achieving a level of safety and my 5
offer to stipulate is that FEMA does not consider e
that to be part of i t s ' r e v i e..s p r o c a r-or pc.r*
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the judgment expressed as a result of the. review
'8 process.
9 MR. TRAFICONTE:
Would you enter 10 into a stipulation in that regard both to FEMA's 11 review process on the plan and the exercise in the 12 Seabrook instance?
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13 MR. FLYNN:
Yes.
l 14 MR. TRAFICONTE:
Can we enter into 15 that stipulation, as far as you are concerned, on 16 this record? //
17 MR. FLYNN:
I'm certainly happy to 18 do that.
The only condition that I would attach 19 is tha[ after the FEMA officials in Washington 20 kave reviewed the record, if they take exception, 21 I would' communicate that to you and the other 22 parties in this case.
l 23 MR. TRAFICONTE:
Fine.
But as the
- i 24 record stands now, subject to check, FEMA would L-COPLEY COURT REPORTING 1
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stipulate to.the characterization of its review 2
thatiyou just'gave.us?
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3 MR.~FLYNN:
Yes.
i 4
(Discussion off the record'.)
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5
- Q.
One last question on schools and our
.6 contention number 10, Mr. Donovan.
Would you turn-7 to page 1 7 3.-
You should learn by now, every time r
8 I say one last question, just completely disregard 9
that because I realize it's not the last 10 question.
.11 MR. FLYNN:
We'll stipulate to that, 12 John.
13 MR. TRAFICONTE:
All right.
14 Q.
Just to get something out of the way.
You 15 see on page 172-173 there is the narrative summary 16 for objective 19 as to New Hampshire.
Do you see 17 that?
18 A.
Yes.
19 N
'T'he bottom of 172, in the first or second
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20
.,g'ieragyaph there is a description of early 21 dismissal decision for the school children.
Do 22 you see that?
23 A.
Yes.
24 Q.
I had misread that, I think, in preparing COPLEY COURT REPORTING
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