ML20248A549
| ML20248A549 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 06/05/1989 |
| From: | Atomic Safety and Licensing Board Panel |
| To: | |
| References | |
| CON-#289-8740 ASLBP, OL, NUDOCS 8906080151 | |
| Download: ML20248A549 (183) | |
Text
{{#Wiki_filter:- -- - - y UNITED STATES l k NUCLEAR REGULATORY COMMISSION i (
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g 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) ) PLA101ING EVIDENTIARY HEARING Pages: 23931 through 24101 Place: Boston, Massachusetts Date: June 5, 1989 a
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A [d p HERITAGE REPORTING CORPORATION OgleisfReportars
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s 23931 l ' .; - UNITED; STATES NUCLEAR REGULATORY COMMISSION
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ATOMIC SAFETY AND LICENSING BOARD
'In tha Matter of: ) . .
4 )' Docket Nos. l
.PUBLIC SERVICE COMPANY OF ) 50-443-OL -
T NEW HAMPSHIRE,.et'al., .) 50-444-OL' OFF-SITE EMERJENCY
)
(SEABROOK STATION,' UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING Monday, June 5, 1989 Auditorium Thomas.P. O'Neill, Jr. Federal Building
-, 10 Causeway Street Boston, Massachusetts
~
The above-entitled matter came on.for hearing,
'f pursuant to notice, at 1:02 p.'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 A'
! JUDGE RICHARD F. COLE, MEMBER Atomic Safety and Licensing Board
+ U.S. Nuclear Regulatory Commission Washington,~D.C. 20555
( Beritage Reporting Corporation (202) 628-4888
m . I 23932 APPEARANCES: For the Apolicants: O THOMAS G. DIGNAN, JR., ESQ. GEORGE H. LEWALD, ESQ. KATHRYN A. SELLECK, ESQ. JAY BRADFORD SMITH, ESQ. JEFFREY P. TROUT, ESQ. I 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 Manaaement Acency: H. JOSEPH FLYNN, ESQ. LINDA HUBER McPHETERS, ESQ. Federal Emergency Management Agency 500 C Street, S.W.
. Washington, D.C. 20472 For the Commonwealth of Massachusetts:
JAMES M. SHANNON, ATTY. GEN. JOHN C. TRAFICONTE, ASST. ATTY. GEN. ALLAN R. FIERCE, ASS'I . ATTY. GEN. PAMELA TALBOT, ASST. ATTY. GEN.
- MATTHEW BP.OCK, ESQ.
LESLIE B. GREER, ESQ. Commonwealth of Massachusetts + One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Heritage Reporting Corporation (202) 628-4888
-23933-U i _
fp-k; .? APPEARANCES: (Continued) U~ For the State of New Hamnahire:
.GEOFFREY.'M. HUNTINGTON, ASST. ATTY... GEN.
! - . State of New Hampshire-
-25 Capitol Street
, ' Concord, New Hampshire 03301 y
D For the ' Seacoast Anti-Pollution Leacrue: A ROBERT A. .BACKUS, ESQ. Backus, Meyer & Solomon 116 Lowell Street P.C.' Box 516' Manchester, New Hampshire 03105
~ JANE DOUGHTY, Director Seacoast Anti-Pollution League 5 Market Street
-portsmouth, New Hampshire 03801 For the' Town of Amesburv:
BARBARA'J. SAINT ANDRE, ESQ. -
-Kopelman and Paige, P.C. ,
; (- 77 Franklin Street B'oston', Massachusetts WILLIAM' LORD
~
Town Hall Amesbury, Massachusetts 10913 For the City of Haverhill and Town of Merrimac: ASHOD N. AMIRIAN, ESQ. P. O. Box 38 Bradford, Massachusetts 01835
..q :
For the City of Newburyport:
.: BARBARA J. SAINT ANDRE, ESQ.
JANE O'MALLEY, ESQ. Kopelman and Paige, P.C. 77 Franklin Street Boston, Massachusetts 02110 Heritage Reporting Corporation X (202) 628-4888
23934
. APPEARANCES: (Continued) .
For the Town of Newburv: O1 ) 1 R. SCOTT HILL-WHILTON, ESQ. Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street Newburyport, Massachusetts 01950 { I I l For the Town of Salisburv: 1 CHARLES P. GRAHAM, ESQ. i Murphy and Graham I 33 Low Street Newburyport, Massachusetts 01950 For the Town of West Newburv: JUDITH H. MIZNER, ESQ. Second Floor 79 State Street Newburyport, Massachusetts 01950 For the Atomic Safety and Licensina Board: ROBERT R. PIERCE, ESQUIRE , I Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l
~
Heritage Reporting Corporation (202) 628-4888
_*+ 23935
- g~ lHEEK
-I WITNESSES: DIRECT CROSS REDIRECT RECROSS-E M Panel No. 21:
- l Catherine M.' Frank Anthony M. Callendrello John G. Robinson Y by Mr. Fierce -23941 J
EXHIBITS: IDENT. REC. REJ. DESCRIPTION: . (No exhibits) 3 Heritage , Reporting Corporation ; (202) 628-4888 j
23936 I H P_ E K INSERTS: PAGE Joint Stipulation Regarding Testimony 23938 of Neil F. Morrissey Joint Stipulation Regarding City of 23938 Newburyport Emergency Planning P Massachusetts Attorney General's 24101 Cross-examination Plan for Applicants' No. 21 G
~
1 l l Heritage Reporting Corporation (202) 628-4888 t . 1
23937 7 -y 1 E E Q C E E p_ X H G E i \ (s / 2' JUDGE SMITE: Is there any preliminary business? 3 I know there is some. Ms. Saint Andre has a 4 request. 5 MS, SAINT ANDRE: I have two stipulations which I 6 would like to have entered into the record. They have 7 previously been filed and circulated to all the parties. S The first one is dated April 18, 1989, and it's entitled 9 " Joint Stipulation Regarding City of Newburyport Emergency 10 Planning". And I would like to have that entered into the 11 record. 12 The second one is dated May 25, 1989, and it's 13 entitled " Joint Stipulation Regarding Testimony of Neil F. 14 [] Morrissey". \' '/ 15 And if possible, I would like to have those 16 entered into the record and bound into the transcript, or 17 whatever the procedure is. 18 JUDGE SMITH: If there are no objections, both 19 stipulations will be bound into the transcript at this 20 point. 1 21 MS. SAINT ANDRE: Thank you, Mr. Chairman, and I 22 do have copies for the clerk. 23 24 25 m
, Heritage Reporting Corporation
(/x- (202) 628-4888
i O 23938 - 1 (The Joint Stipulation 2 Regarding Testimony of Neil l 3 F. Morrissey, and Joint 4 Stipulation Regarding City 5 of Newburyport-Emergency , t 6 Planning follows:) 7 8 9 10 11 12 13 14 15 16 17 18 , 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
l .' 4 L May 25,'1989 i i l I
'N UNITED STATES OF AMERICA NUCLEAR REGUIATORY COMMISSION ,
j
- before the ATOMIC SAFETY ~AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY OF ) Docket Nos. 50-443-OL' NEW HAMPSHIRE, et al. ) 50-444-OL
) Off-site Emergency (Seabrook Station, Units 1:and 2) ) Planning Issues
)
)
r N- JOINT STIPULATION REGARDING TESTIMONY OF NEIL F. MORRISSEY Pursuant to 10 C.F.R. 5 2.753, the Town of Amesbury (on behalf of itself and the other Interveners in these proceedings), the Nuclear Regulatory Commission Staff, and the Applicants hereby stipulate to the admission into 1 evidence, for all purposes, of the attached " Rebuttal 6 O JPDORRS.NB
Testimony of Chairman of Board of Selectmen Neil F. 1 Morrissey." i Respectfully submitted, ; i
~~ ~ TOWN OF AMESBURY NRC STAFF- l 1
fL s A& ,s
?_ ,
Elaine I. Chan 1
%_arbara St. Andre !
Kopelman & Paige, P.C. Office of General Counsel , 77Jranklin Street, U.S. Nuclear Regulatory Commission Suite 1000 Washington, D.C. 20555 Boston, MA 02110 (617) 451-0756 APPLICANTS
' &l N%\
f d Deffr'ey P. Trout Ropes & Gray One International Place Boston, MA 02110-2624 (617) 951-700C 9 w 9 p ,.
! . (
May-19, 1989 UNITED STATES OF AMERICA [~ NUCLEAR REGULATORY COMMISSION 4 ~ ~
' before the .s ATOMIC SAFETY AND LICENSING BOARD In the Matter of .
PUBLIC SERVICE COMPANY OF Docket Nos. 50-433-OL NEW HAMPSHIRE 50-444-OL
~
Off-site Emergency 4Seabrook Station, Units 1 and 1) Planning Issues a TOWN OF AMESBURY'S PRE-FILED TESTIMONY REBUTTAL TESTIMONY OF CHAIRMAN OF BOARD OF SELECTMEN NEIL F. MORRISSEY 1Q. Would you please state your name, position with the Town and official address? ( ,_, lA.' My name is Neil F. Morrissey. I am the Chairman of the Board of Selectmen of Amesbury. My official address is k Amesbury Town Hall, Friend Street, Amesbury, Massachusetts. 2Q. How long have you been a Selectmen? 2A. Since 1987. 3Q. Briefly describe the Selectmen's role in Amesbury? 3A. The Selectmen are the executive body of the Town which sets 3 policy, that is carried out by the Town manager and Town employees.
~
4Q. Have you previously testified before this Board? 4A. No. . 50 In your capacity as Selectman, are you involved in formulating Town policy regarding emergency planning? s
-5A. Yca. \
6Q. What is the present Town policy with regard to planning for emergencies? 6A. The Town recognizes its responsibility to.,grepare and plan - for local emergencies in order to protect the well being of
'~
its citizens. Town employees whose jobs are related to emergency plannihg, like the Police and Fire Chiefs and the - Civil Defense Director, are authorized and expected to prepare and plan for such emergencies. However, the Town of Amesbury has determined that no emergency plan can be formulated to safely evacuate the Town if the Seabrook nuclear power plant goes on line and a radiological accident occurs. In November, 1986, Town Meeting and the Selectmen voted not to pursue the futile course of planning for a Seabrook emergency. Therefore, because of its futility and the dangerous illusion it would create, and as a result of the 1986 town meeting action, town employees have been ordered not to participate in any emergency planning that concerns the Seabrook plant. 7Q. Are you familiar with a document entitled "Amesbury Comprehensive Emergency Management Plan?" 7A. No. , 8Q. Has the Board of Selectmen, either on its own, or through
~
the Town Manager ever prohibited, restricted or discouraged Town employees from engaging in any emergency planning activities? 1 1 O
8A. Purcuent to ths g norcl prohibition cgain3% plcnning for a , { scabroek roloted c2Orgency, the Selectman have, at least 1 once, prohibited the' Civil Defense Director from engaging in drill exercises which we felt were (irectly related to a Seabrook emergency. 9Q. Does the Civil Defense Director have to obtain the Board of
, Selectmen's permission to engage in any drill exercises?
9A. Yes. 10Q. Since 1985, has the Board granted the Civil Defense m Director permission to participate in any such exercises? 10A. Yes. In June of 1988 we authorized such participation and we authorized Mr. Clark to participate in more exercises in October of 1988 and during the first two weeks of April, 1989. (( 11Q. Are you aware of any other activities in which the Civil
/ \ Defense Director has participated with either the express tj or implied approval of the Selectmen?
11A. Yes. The Amesbury Civil Defense Department has assisted Amesbury police and fire departments and nearby communities during emergencies involving heavy rains and potential flooding. The Director and his volunteers also regularly participate in annual Amesbury Day activities by assisting with crowd and traffic control.
. 12Q. What support, if any, has the Town given to the Civil Defense Department since you took office in 19877 . 3 l'
(
, s 12A. Tho Bo2rd Cnd tho Tcwn hava cenciCtGntly CupportCd O Otrong civil Defense Department. 13Q. Are you aware of any complaints from any Town employees, including the Polide~and Firg Chiefs and the CiV11 Defense - Director, that_they are inhibited from adequately carrying 1 out their planning responsibilities? I 1
-l 13A. Yes. The Civil Defense Director and his volunteer staff were confused as to the policies on emergency planning, and ,
in the Spring of 1988 I met with them and the confusion was ironed out. 14Q. In your opinion, how well prepared is the Town of Amesbury for a non-Seabrook emergency? 14A. I believe the Town is well prepared. We have significantly increased our funding to the Civil Defense Department. We have authorized the Director to participate in drills and training sessions. We have aided nearby communities in emergencies. We have in place a permanent emergency operations center. 15Q. In your op' inion, has the Town's decision not to pursue what it considers futile planning for a Seabrook emergency, had a detrimental impact on planning for other emergencies? 15A. No. ' 16Q. Does this conclude your testimony? 16A. Yes. O
> t (, j
'* April 18, 1989 l fh) .
-(
UNITED STATES OF AMERICA' l NUCLEAR REGULATORY COMMISSION-before the - ATOMIC SAFETY AND LICENSING BOARD-In the Matter of
~
Docket Nos. 50-433-OL PUBLIC SERVICE COMPANY OF 50-444-OL l NEW HAMPSHIRE, et al. Off-site Emergency Planning Issues (Seabrook Station, Units 1 and 2) JOINT STIPULATION REGARDING CITY OF NEWBURYPORT EMERGENCY PLANNING Counsel for the City of Newburyport and the Applicants hereby submit the following Joint Stipulation, which is intended to obviate the need for testimony from the City of Newburyport City Clerk.
- 1. There is no copy of the Seabrook Plan for Massachusetts Communities ("SPMC") on file with the City of Newburyport City Clerk. The present City Clerk, Michael J. Sullivan, has served since March 30, 2987, and, to the best of his knowledge, no copy of the SPMc has been on file with his office cince at least that date. This stipulation should not be construed in any manner to indicate whether a copy or copies of the SPMC were offered to the City Clerk's office to be filed.
- 2. The document entitled " City of Newburyport - Emergency Planning Manual - SARA Title III", a copy of which has been
[ admitted as Applicants' Exhibit 48 in this proceeding, has never
'(
b3en submitted for approval by the City Council. There is no rGeord of the City Council ever accepting that document for review, or ever adopting or approving it. Applicants, by agreeing to this stipulation of facts, do not waive their right to contest the relevancy of the facts ctipulated herein.
*~
R3spectfully submitted, Public Service Company City of Newburyport of New Hampshire, et al. f __>_ __ J { ' J ff l [,. u lf.c:tA By: Barbgra J. Saint Andre By/,,deffrey Trout Kopelman and Paige, P.C., Ropes & Gray 77 Franklin Street One International Place Boston, MA 02110 Boston, MA 02110-2624 (617)451-0750 (617)951-7000 0 O
> 9
23939 1 MR. FIERCE: I have one small matter, too, Your
/7_ ')
(,./ 2 Honor. 3 JUDGE SMITH: Mr. Fierce. - 4 MR. FIERCE: We would like to announce that we are 5 distributing at this time the revised testimony of Sandra 6 Mitchell, which is all of the testimony that was in the
- 7 previously filed piece that contained her name, but deleting 8 those portions pertaining to Mr. Sikich.
9 So I would like to distribute copies of those at 10 this time. 11 (Document proffered to all parties.) 12 MR. COOK: Your Honor, at this time it would be 13 convenient for Applicants to state for the record also that
/~'s 14 we are today filing to the offsite service list, by regular I
'x /
)
15 mail five objections, in the nature of a motion in limine to 16 our objections to full pieces of testimony, and those are to 17 the testimony of Dr. Howard Harris, and Dr. Albert E. 18 Luloff. 19 And the remaining three are objections to portions 20 of the prefiled testimony and those include objections to 3- 21 Thomas J. Adler's testimony, the testimony of Carol Sneider, 22 and the testimony of T. Michael Carter. 23 And Applicants have distributed to the Board and 24 the parties in the courtroom the courtesy copies of those 25 motions.
,m Heritage Reporting Corporation
(\. _s) (202) 628-4888 l
23940 1 MR. FIERCE: Just one question to the Applicants. 2 I understand there is another one coming regarding
]
f 3 Dr. High's testimony, and that will be filed when? Tomorrow i 4 morning? 5 MR. DIGNAN: Who knows? p,. 6 MR. FIERCE: Who knows? 7 MR. COOK: Very shortly. - 8 MR. FIERCE: Very shortly. 9 MR. COOK: Yes. And the testimony, the objection 10 with regard to Mr. Adler is to Thomas J. Adler's testimony 11 on traffic guide training. 12 And the Applicants will be prepared to argue and 13 respond to any opposition at the Board's pleasure and the 14 pleasure of the parties. 15 JUDGE SMITH: Okay. 16 Anything further? 17 ('N o response.) 18 JUDGE SMITH: All right, Mr. Fierce. 13 MR. FIERCE: Thank you, Your Honor. : 20 Whereupon, 21 CATHERINE M. FRANK 22 ANTHONY M. CALLENDRELLO 23 JOHN G. ROBINSON 24 having been previously duly sworn, were recalled as 25 witnesses herein and were examined and testified further as Heritage Reporting Corporation (202) 628-4888
. REBUTTAL PANEL NO. 21 - CROSS 23941' ,
;, s . l' follows:
a' k j\- , 2 CROSS-EXAMINATION (Continued)
)
3 BY HR. FIERCE:. 4 Q. Good. afternoon, Panel. l 5 I would like to pick up with the cross-examination - 6 regarding that portion of your. testimony that begins on page < 7 23. It's under a large heading entitled "SPMC Response 8- Capabilities", and the first part of that dealing with the 9 SPMC's conceptual basis. 10 There is a reference immediately following.that to 11 the NUREG-0654,_Sup. 1 so-called assumptions. And your 12 testimony states that the SPMC incorporates these Sup. 1 13 assumptions. I wonder if you could tell me what you mean by 14 the word " incorporated"? D)
\- . 15 A (Callendrello) It is one of the planning bases 16 upon which the SPMC was developed.
17 Q That these three assumptions would in fact apply 18 during'a Seabrook emergency; is that ' correct? 13 A (Callandrello) Yes, that's correct. 20 Q As to the first one which is on your page 23, Sub. 3 21 1, Section,A, " Exercise their best efforts to protect the 22 health and safety of the public", you are assuming here that 23 the state in fact will act rather than sit on their hands. 1 24 , Is that correct? 25 A (Callendrello) Yes. We are assuming that the Herit age Reporting Corporation s- (202) 628-4888 l
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. REBUTTAL PANEL NO. 21 - CROSS 23942 1 governor and other organizations in the Commonwealth will do 2 whatever they can to protect the public health and safety 3 consistent with the position that has been expressed in the 4 response to interrogatories and also the admissions.
5 Q But I'm trying to get a little bit further than , 6 that and ask you whether you think that will in fact mean 7 acticn rather than complete deferral to the ORO. 8 A (Callendrello) It could mean action, and it could 9 mean deferral. It will mean whatever is in the best efforts 10 to protect the citizens of the Commonwealth. 11 Q What, in fact, does that mean operationally for 12 the state if they are to act in the best interest of the 13 citizens at the time? 14 In other words, how are they to know what it is 15 that is in the best interest of the citizens, given the 16 information that they have at hand at the time? 17 A (Callendrello) The governor has various technical 18 advisors. He has a radiological technical advisor. He also 19 has an operations technical advisor. The radiation advisor 20 is the person who comes out of the Department of Public 21 Health and provides input to the governor on what actions to 22 take regarding the minimization or reduction of risk due to 23 radiation.
, 24 There is also an operational arm or advisor to the i 25 governor which is the Department of Public Safety, through 1
Heritage Reporting Corporation (202) 628-4888 Gj) ' - -- _ _ .__-_-__ __- - _____-_ _ a
l I REBUTTAL PANEL NO. 21 - CROSS 2394? 1 its civil defense organization. Those two organizations 7_ l , 2 will provide input to the governor. 3 In addition, the SPMC provides for ORO liaisons to 1 4- be located at those locations at the Department of Public 5 Health headquarters and at the state EOC in Framingham to 6 provide input as well to the governor, and provide advice on l
- 7 the best actions to take and the best integration of 8 resources and plans to make to best protect public health 9 and safety. ,
10 There is no standard answer. It's going to be 11 whatever is best at the time of the emergency, given all of 12 the interactions that have been provided in both the SPMC 13 and in the Commonwealth's own plans. j l I j- 14 Q Whatever is best at the time of the emergency as
\
15 they perceive it, correct? , i 16 A (Callendrello) As they, being the Commonwealth, l 17 perceive it based on the information made available by their j 18 own advisors and by the utility's advisors. ; 19 Q It's not an objective standard of what's best. I 20 You are not assuming that they will, in fact, always come up 3 21 with the best response, but they will pursue what they l 22 believe and what they perceive to be the best response for 23 the Commonwealth; correct? q 24 A (Callendrello) They will do what they think is 25 best at the time. l 1 I Heritage Reporting Corporation fs (202) 628-4888 , - - _ _ _ _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ i
REGUTTAL PANEL NO. 21 - CROSS 23944 1 Q Now you are not here arguing that their judgment 2 is infallible, correct? 3 A (Callendrello) I'm sorry, I don't understand the 4 question. I'm not sure who you are referring to. 5 Q Well, in terms of making that subjective . 6 determination of what's best for the Co,mmonwealth, you are 7 not here arguing that that judgment from those officials is - 8 an infallible one. They could make mistakes, correct? 9 A (Ca11endre11o) I certainly suppose it's 10 conceivable that they could make mistakes in hindsight. But 11 I think they will make the best judgment they can make with 12 the information they have at hand. 13 Q Now as to the second assumption here, " Cooperate 14 with the utility and follow the utility offsite plan", now I 15 know we've had some discussion about this last week, and I 16 don't want to drive over that same path again. But I just 17 again want to make clear. 18 As I understood your testimony last week, it was 19 that the governments would not actually need to pick up and 20 hold in hand and look at the SPMC, correct? 21 A (Ca11endre11o) No. What I had said last week is - 22 maybe just slightly different from the way you characterized L 23 it. 1 l 24 There may be sections that they need to pick up 1 25 and hold in their hand. As we discussed last week, there Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23945 7-s 1 are appendices that have lists of food producers, food 2 processors that the user of that procedure may actually have t 3 to pick up and look at. l 4 What I said last week was, we are not expecting 5 somebody in the state to insert themselves into one of the 6 ORO positions. To pick up the plan and say, who am I in the 7 plan so I know exactly what procedure I need to implement. 8 But there are certainly aspects of the plan that 9 they may need to pick up and use. Prescripted EBS messages 10 are another piece that they might pick up and use. 11 Q All right. Now as to (C) which states, "Have the 12 resources sufficient to implement those portions of the 13 -utility offsite plan where state and local response is
's 14 necessary," how has that been incorporated into the SPMC?
15 A (Callendrello) That's incorporated in the c ncept 16 of operations of the SPMC that states that those, functions 17 normally performed by a local or state government will 18 continue to be performed by that local and state government. 19 Examples on the local level are snow plowing, law 20 enforcement and fire fighting. On the State level would be 5 21 the establishment of an emergency operations center. Those 22 are the types of functions we talk about. 23 Q Are there other portions of the utility offsite 24 plan where state or local response is necessary other than 25 the ones you have just mentioned? Heritage Reporting Corporation ( (202) 628-4888 -
REBUTTAL PANEL NO. 21 - CROSS 23946 1 A (Callendrello) If you would just give me a 2 moment, I'll check. 3 (Witnesses review document.) 4 THE WITNESS: (Callendrello) Without checking in 5 the SPMC where it does spell out what support the SPMC does - 6 rely on, those are the ones that come to mind. 7 I can't think offhand of any others. - 8 BY MR. FIERCE: 9 Q At the local level, I heard you say things like 10 local snow plowing capability. 11 Was that one of them? 12 A (Callendrello) Yes, it is. 13 Q Are there any particular resources that you are 14 assuming are in place at the local level that would enable 15 the local communities to accomplish that portion of the 16 emergency response? 17 A (Callendrello) We assume that the communities 18 would have available to them whatever resources they use for 19 snow plowing, whether it is a state function through the 20 Department of Public Works, or whether it's a local 21 contracted organization or whether it's a municipal 22 resource. 23 Q You are not assuming that they would have any 24 additional resources other than what is normally available 25 to them, correct? Heritage Reporting Corporation (202) 628-4888 - ) 1 i
REBUTTAL PANEL NO. 21 - CROSS 23947-
-s 1 A (Callendrello) That is correct. , \_,/ 2 Q With respect to the Commonwealth, do the 3 Applicants assume or contend that Massachusetts has more 4 resources available to it than were specified in the answers 5 to the interrogatories that were provided to you?
6 A ,(Callendrello) I have no reason to believe 7 otherwise.- The NRC Staff asked the question, what resources 8 would the Commonwealth utilize. And I assume that's a 9 complete answer. 10 Q In the last paragraph of the Sup. 1 section which 11 is quoted on page 23, the statement reads, "Although it is , 12 assumed that nonparticipating state and local organizations 13 will respond and follow the utility's offsite plan, it is
/ 14 not assumed that these organizations will be as familiar t
15 with the plan as if they had participated in the planning 16 process and exercised with the utility." 17 How much familiarity is assumed by the SPMC and 18 its operatives? 19 A (Callendrello) It is assumed that the 20 Commonwealth is familiar with their own internal procedures 3 21 for receiving the initial notification from the utility and 22 the subsequent notification of the Department of Public 23 Health and Civil Defense Agency. 24 Other than that, there is really no assumptign.
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25 There are no further assumptions made with regard to how
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Heritage Reporting Corporation .(\ (202) 628-4888
l REBUTTAL PANEL NO. 21 - CROSS 23948 1 familiar the Commonwealth is with the SPMC. 2 Q So there is no assumption that at the time of an 3 emergency the governments will actually have the SPMC and be 4 familiar with its contents? 5 A (Callendrello) That's correct. That's why we , 6 send,the liaisons with copies of the plans. 7 8 9 10 11 . 12 13 14 15 16 17 18 19 20 21 22 23 24 . l 25 Heritage Reporting Corporation j (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23949
,- s 1 Q Can I state then that no familiarity whatsoever is
/
T l ' w,,) 2 assumed by the state or local responders in the SPMC, by the 3 SPMC7 4 A (Callendrello) It's a difficult question you are 5 asking me, because the concepts in the SPMC are in some 6 cases identical, or very similar to those that were used by 7 the Commonwealth while they were cooperating in planning, 8 and in fact are using to this day. 9 So they will have some familiarity, because they 10 are consistent concepts. So that's why I have a problem 11 with the spestion. 12 Q Okay. My only further question about the answer 13 you just gave is, are you assuming that they know that, that (~~$ 14 the state and local responders know what the SPMC contains, (' 15 at least insofar as knowing that the concepts are consistent 16 as you describe it? 17 A (Callendrello) No. We are not relying on that. 18 Q On page 24, after the section quoted again from 19 the NUREG-0654 supplemental document, there is a short 20 section that reads, "The position of the Commonwealth since 21 September 1986, has been that no state or local planning 22 will be undertaken for an emergency at Seabrook Station," 23 with a reference then to a Dukakis affidavit you have 24 attached at Attachment F. 25 Isn't it true, Panel, that that statement also G [d t Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL Hb. 21 - CROSS 23950 1 says, "Nor will the Commonwealth enter into any tests, 2 drills, exercises, training as well as planning", which you 3 have mentioned here? 4 A (Callendrello) Yes, it does. 5 Q Other than these Sup. 1 assumptions, are there any , 6 other assumptions about state or local response that 7 underlie the SPMC or your testimony here? , 8 A (Callendrello) One of the assumptions and it's 9 repeated in our testimony is that the SPMC has the resources 10 and the ability to fully compensate for the response in the 11 entire EPZ. 12 O Well, that sounds like an assumption about the 13 SPMC and the ORO rather than an assumption about the state 14 or local response capabilities, which is the focal point of 15 my question. 16 A (Callendrello) I can't think of any other 17 assumptions. 18 Q I'm going to jump ahead to page 27. 19 Excuse mra, I wanted to mention something on page 20 25. Up at the top of the page, the first full centence 21 says, "Thus, state and local officials have some familiarity
- 22 and understanding of Seabrook Station emergency response 23 needs."
24 That follows a discussion about the planning that 25 the state and local governments had engaged in prior to
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REBUTTAL PANEL NO. 21 - CROSS 23951
,-_ 1 1986. ,
l \ . (,,) 2 When you say "the state and local officials", you 3 are talking here about a fairly small group of people, 4 aren't you? 5 A (Callendrello) No. As I indicated, or as we 6 indicated in our testimony, over 500 local officials have
- 7 received or had received some training in radiological 8 emergency response. The state organization that staffs the 9 emergency operation center is a fairly large orgartization.
10 They have received training and exercised their radiological 11 emergency response plan. They have done so at least a dozen 12 times. 13 There are other members of state organizations r"'s 14 such as the Department of Public Health that periodically ('/ ) And I know that that 15 exercised their capabilities. 16 organization, at least the NIAT portion of that organization. 17 is roughly another dozen persons. 18 So there is a fairly large organization that has 19 received some training, or routinely demonstrates their 20 capabilities. 21 Q Well, you've mentioned all the organizations which 22 have certain generic responses to all the power plants in 23 the Commonwealth. 24 But with respect to Seabrook-specific planning 25 that was done prior to 1986, that group of officials that n
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f REBUTTAL PANEL NO. 21 - CROSS 23952 1 was involved in putting those plans together was a fairly 2 small group, correct? 3 A (Callendrello) No. No. It would have involved 4 representatives from at least five of the six EPZ 5 communities. It would have involved the state organization , 6 through both its headquarter's organizations and the area 7 organization. So it was a fairly large group of people that 8 were involved in the planning. 9 Q Do you know how many or what percentage of those 10 people are still in place at state and local governmental 11 positions? , 12 A (Ca11endre11o) I don't know what percentage. I 13 know some are still there. 14 Q Some are, but many are not, correct? 15 A (Callendrello) I don't know the numbers. I know 16 that, for example, the key positions, Director Boulay, Mr. 17 Hallissey, are still in position and they were the key 18 members of the planning development organization. 19 Q Further down that page there is a sentence about 20 eight lines from the bottom which begins with a quote. "To 21 ensure a smooth integration, this plan has been developed to 22 be consistent with the Commonwealth of Massachusetts . 23 Radiological Emergency Response Plan which is currently used 24 for operating nuclear power plants located within 10 miles 25 of the Commonwealth's boundaries." It's a quote from the Heritage Reporting Corporation (202) 628-4888
)
REBUTTAL PANEL NO. 21 - CROSS 23953
,-s s 1 SPMC. \;cf) 2 This alone, the fact that the plan has been 3 developed to be consistent with Commonwealth's own plans, )
4 that alone cannot " ensure" a smooth integration, can it? 5 A (Callendrello) I thinic it's one of the things 6 that assists achieving a smooth integration of the plans. j 7 Whether that alone can do it, I guess I would have to agree l 8 with that. That it alone cannot do it, but it certainly 9 goes a long way to achieving that. 10 Q Now, now I'm moving to page 27. The middle of the 11 page, it says the Commonwealth participated extensively in 12 preparedness to support other power plants as well as one in 13 vermont.
/s 14 The next sentence reads, "During a Seabrook i '-' ) 15 Station emergency, this preparation will provide the basis 16 of a planned Mode 1 response."
17 Wouldn't that sentence have been more accurat5 if 18 it had said " partially planned Mode 1 response"? 19 A (Callendrello) No. Mode 1 is one of the planned 20 modes of the SPMC. 21 Q It's one of the modes of the SPMC for the ORO, I l 22 correct?
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23 A (Callendrello) That's correct. 24 Q In a Mode 1 response, the state has assumed l L 25 authority over the emergency response and the ORO is
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REBUTTAL PANEL NO. 21 - CROSS 23954 1 providing any needed resources, correct? 2 A (Ca11endre11o) Yes, that's correct. 3 Q The state is following these other plans that you 4 have offered with your testimony, correct? 5 A (Callendrello) They are following whatever plans , 6 are the best plans. It may be their plans. It may be the 7 SPMC. 8 Q Those plans, as we've noted before, in some cases, 9 particularly with respect to the MCDA Area I plan, have not 10 been drilled, tested, updated or exercised since 1986, 11 correct? 12 A (Callendrello) That's correct. 13 Q And in the local communities, there are large-14 scale deficiencies with respect to staffing for their old 15 emergency plans. 16 Isn't that correct? 17 A (Callendrello) No , I don't think that's~the case. 18 Q Do you believe that every position that is 19 identified in say an old Newburyport or Amesbury plan or-20 Merrimac plan has been -- a person has been identified and 21 is known to be that responder for that position for 22 Seabrook? 23 A (Callendrello) No. I don't know. I don't know 24 what the staffing is of those plans. 25 0 At some point, isn't it true, Mr. Callendrello, i Heritage Reporting Corporation (202) 628-4888 l
'W REBUTTAL PANEL NO. 21'- CROSS 23955
-e s. .'1 that the planning has stopped for Seabrook, and there are
)s_, ' some gaps, and what we have is a' partially planned response,
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2 3 not a completely planned response in Mode 1, correct? i: 4 A (Callendrello) No,-I don't think that's correct. 5 As we went through last week, there are a number 6 of plans that=the Commonwealth will follow. And if we are
.7 in a Mode 1 response where we are providing resources.to-8 . supplement the Commonwealth's response, it is a fully 9 planned response. They are following some plan, one of the 10 myriad of plans that exist,'and we are providing resources 11 for them.to carry out their functions. So to that extent, 12 it is fully planned.
13 If there is some area that is unplanned, I don't f' 14 see how they would know to ask for the resources to respond
\'
15 to that. 16 Q On the next page, page 28, the Panel makes the 17 statement that it's expected that during an emergency 18 Massachusetts officials will be able to evaluate th,e 19 situation rapidly and implement those actions that are in 20 the best interest of their citizens.
'* Can you tell me how rapidly you think that 21 22 Massachusetts officials ought to be able to evaluate that 23 situation?
24 A (Callendrello) No, I can't tell you how rapidly
- 25 they ought to be able to.
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l REBUTTAL PANEL NO. 21 - CROSS 23956 j l 1 Q Ought they be able to do it fairly quickly? 2 A *(Callendrello) I think they can do it quickly. I l 3 don't know of any requirement other than a prompt , I 4 notification timing requirement for how quickly any 5 organization needs to be able to respond or make a decision. . 6 Q After an alert is declared, and the Commonwealth 7 is apprised of that, you would expect at that point they 8 would at least be making efforts to assess the situation, 9 correct? 10 A (Callendrello) Oh, I'm sure they would be. 11 Q And that they would be in that process well before 12 the liaisons arrive at their posts? 13 A (Callendrello) Again, I don't know "well" before. 14 I think it's likely that they would have begun to assemble 15 their organization, establish the emergency operations 16 center by the time the state liaison had arrived. 17 A (Robinson) Mr. Fierce, one other factor here is 18 that in the notification process when an unusua1 event or an 19 alert is -- the notice is given to the state, it goes to the 20 state police at 7. troop Headquarters. 21 They, in turn, call the Mass Department of Health 22 duty officer who, in turn, calls back to the plant to get 23 information on the conditions existing at the time. 24 So they would immediately start to assess the 25 plant conditions and gather information. Heritage Reporting Corporation (202) 628-4880
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. REBUTTAL PANEL NO. 21 - CROSS -
23957 1 Q Andisimultaneously at an alert, you, as the' state.
) 2 liaison to the Department of Public Health, would. at that
.3 point just'be directed to report to duty, correct?
4 A (Robinson) That is correct.
- 5 Q' And as we-have discussed last week, you would'have:
6' certain travel times.. You would travel to the ORO EOC and 7 'then from there~out to the Department of Public Health 8 location, correct? 9 A (Robinson) That's correct. 10 No, my position would be to go to the Mass 11 ' Department of.Public Health.
- 12. Q You would go directly there? -
13 A (Robinson) Right. j' 14 Q From Bolton?
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15 A (Robinson) From Bolton, yes. 16 Q But you are telling me now that there would be 17 information from the ' control room that they would have
- 18. already in order to begin assessing the situation?
19 A (Robinson) That's correct. 20 Q And likewise, they would be in that process of
^
21 assessing the situation before the ORO became operational. 22 Isn't that true, Mr. Callendrello and Mr. 23 Robinson? 24 A (Robinson) That's true. 25 Q The latter part of that sentence talks about I Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23958 1 implementing those actions. It is true, is it not, that the 2 Commonwealth could be in fact set on a course of action, 3 having assessed the situation, it could be set on a course 4 of action prior to the arrival of the liaisons or the 5 operational capability of the ORO,' correct? , 6 A (Callendrello) Yes, but that does not mean that 7 that is prior to any contact with the ORO. 8 The offsite response director, as one of his 9 initials actions, establishes contact with the control room 10 and finds out who the Department of Public Health duty l 11 officer is, and then contacts that individual and discusses 12 the implications of the emergency. . 13 Q And also perhaps explains a little bit about the 14 ORO and the SPMC, correct? 15 A (Callendrello) At least makes an offer as to what 16 types of capabilities exist and his understanding of the 17 response, or what ORO is doing to gear up. 18 Q And at that point if he were asked, is the ORO at 19 this point operational, the director would say, well, not 20 yet. We're mobilizing. 21 Correct? 22 A (Callendrello) That's correct. 23 If we are still at the alert, that is correct. 24 Q And that would be one of the pieces of information 25 that the state officials on the scene would be using to Heritage Reporting Corporation (202) 628-4888
l o ! REBUTTAL PANEL NO. 21 - CROSS 23959 1 " assess" the situation at that time, correct? The fact that 2 the ORO is not yet operational. 3 A (Callendrello) I don't understand the question. 4 I don't see how that follows. 5 Q Well, certainly, in assessing the situation, you 6 not only want to know what plant conditions are by calling - 7 the control room, but wouldn't the state want to know what 8 their own operational capabilities are at that point and be 9 assessing that? 10 And when the ORO calls up, they would want to know 11 what the operational capability at that point of the ORO 12 was, correct? 13 A (Callendrello) Yes, I think that would be 14 correct. And I think.that would be also something that the 9 15 offsite response director would offer. 16 Q And he would offer the information that the.ORO 17 was not yet operational, but was mobilizing at that point. 18 A (Callendrello) Again, we.are at the alert, that's 19 correct. 20 21 22 23 24 25 9 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23960 1 O At that point, let's assume there is an alert and 2 we've gone through that process we've just described, in 3 that conversation occurs, or those kinds of conversations 4 occur with the control room, with the ORO director. 5 How at that point will the Commonwealth know what , 6 actions are in the best interest of their citizens? 7 To look to its own plans, its generic plans, or to - 8 wait for the ORO to mobilize and delegate functions to the 9 ORO. 10 How will they know how to make that choice? 11 A (Callendrello) I would expect that they would be 12 themselves in a state of mobilization. It takes them some 13 time to activate their emergency operation center, for all 14 of the representatives from the Executive Order 144 agencies 15- to arrive, and themselves declare the emergency operat' ion 16 center operational. 17 Again, we're talking about the alert level. There 18 is no need to take protective. actions. That's one of the 19 definitions of the alert is to allow personnel to come to 20 some kind of a ready mode and begin to staff emergency 21 operations facilities. 22 Q If I understood you correctly, those state 23 officials are themselves mobilizing and their organization 24 may not yet be totally in place, and at the same time they 25 have now learned that the ORO is in a similar status, Heritage Reporting Corporation (202) 628-4888 i L - _ - - _ _ _ - - - - - - _ - - _ _ - - _ - - - - _ - - _ - - _ _
REBUTTAL PANEL NO. 21 - CROSS 23961 m s 1 mobilizing but without resources clearly in place. I \ (_/ 2 There is some uncertainties here then as to how 3 the state officials at that stage should go, correct? 4 A' (Callendrello) No. They would follow their own 5 internal activation procedures. 6 Remember, we are exchanging information between 7 the onsite organization and the technical advisor to the 8 governor, the Department of Public Health, regarding the 9 accident and its consequences. 10 Once the facilities -- the facilities being the 11 emergency operations center for the ORO -- and the state's 12 EOC become operational, those communications shift to the 13 communication between the offsite response organization and ,r^') 14 the state EOC. And that occurs through the many links that
'\ -) 15 exist: the offsite response director, the assistant offsite-16 response director and the state liaisons. ~
17 Q The situation is such that the state is at least 18 thinking about the possibility -- again, an alert stage -- 19 at least thinking about the possibility of an early beach 20 closing for which they believe some traffic control would be 21 needed. 22 And knowing that your organization is not yet in 23 place, that their civil defense EOC is still mobilizing, 24 that the state troopers are wherever they are in the field 25 in Massachusetts, how is it that state and local officials (n)
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I REBUTTAL PANEL NO. 21 - CROSS 23962 ) l 1 are to evaluate whether to engage in that precautionary 2 beach closing? 3 A (Callendrello) That would have to occur in a 4 discussion between the Department of Public Health and the - onsite organization, or upon the arrival of the offsite I 5 , 6 response director or the assistant offsite response director 7 at the ORO EOC. 8 Q The SPMC does not provide for a beach closing at 9 the alert stage, correct? 10 A (Callendrello) That's correcc. It's not part of 11 the SPMC. 12 Q At that point would the ORO director, or whoever 13 is on the phone with state officials, attempt to dissuade 14 them from considering a beach closing? 15 A (Callendrello) I wouldn't characterize it as 16 " attempt to dissuade." 17 I think the offsitti response director would give 18 the governor's representative the reasons why he felt a 19 beach closure was not necessary. But the governor is the 20 ultimate decisionmaking autho:rity in the Commonwealth. And
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21 if he feels it's in the best interest to protect the public 22 health and safety to close the beaches, then that's his 23 choice and I'm sure he will make it. 24 Q The ORO link here, who could be the liaison or the 25 director, would in fact advise the state leadership of the Heritage Reporting Corporation , (202) 628-4888
u REBUTTAL PANEL NO. 21 - CROSS 23963- . e
, .; 1 reasons why'the ORO-and the SPMC believes that an early
(_,) 2 beach-closing at the alert is not necessary for 3 Massachusetts. 4 A (Callendrello) That's correct. That's what was' 5 demonstrated during the exercise. 6 Q On page 28, there is a description of a standby 7 mode in which essentially what we have in the standby mode 8 is the ORO mobilizes and stands by ready. I guess that's
-9 it.
10 Is that right, Panel? . 11 A (Callendrello) Yes, that's correct. 12 Q The traffic guides do go out to their assigned 13 locations throughout the EPZ at that point in a standby ("' 4 14 mode, or not? 15 A (Callendrello) Could I just have a moment to 16 consult? 17 (Witnesses confer.) 18 . A (Ca'11endre11o) Yes. Ms. Frank is just refreshing 19 my memory on that. 20 I know they are deployed at the site area 21 emergency. They would be deployed regardless of whether we , 22 were in a standby mode or any one of the modes unless, for 23 example, the Commonwealth said don't send anybody out there. 24 Q That's the point I wanted to clarify, though. , 25 The traffic guides are deployed not according to Heritage Reporting Corporation Of (202) 628-4888
O REBUTTAL PANEL NO. 21 - CROSS 239.64 l 1 which mode the ORO is in, but according to what ECL has been , 2 attained. 3 If it's a site area, they are deployed; is that 4 correct? 1 I 5 - A (Callendrello) That's correct. , 6 Q For how long would the ORO maintain a standby i l 7 before declaring a shift change? 8 A (Callendrello) I think we say in the procedures, i 9 it's IP 1.1, the offsite response director's procedure. l l 10 Yes. It's IP 1.1, page 31, Step 7 under " Ongoing 11 activities for the New Hampshire Yankee offsite response 12 director". 11 3 It says, "If protective actions are not likely to 14 occur within the next six hours" -- oh, I'm sorry, did you 15 ask when we would consider a second shift? 16 Q Yes. You are in a standby mode. How long would 17 you have your people standing by, for how many hours before 18 you would engage in a shift change? 19 A (Callendrello) Well, what I was getting to is, if 20 it's going to be more than six hours before there is any 21 protective actions, there would be a reduction in staffing., 22 They would reduce the staffing to minimal levels, and that 23 was the step I was reading. 24 If you give me a moment, I'll get the staffing 25 procedure. Heritage Reporting Corporation (202) 628-4888 1 l
REBUTTAL PANEL NO. 21 - CROSS 23965
.,-- 1 (Pause to locate document. )
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l.(_,/ 2 THE WITNESS: (Callendrello) There is direction l 3 in IP 1.1, page 39. There is Step 11(a) . It says, "The 4 communication coordinator should be directed to commence 5 shift change call-outs at about nine hours into the site 6 area or general emergency, whichever emergency 7 classification occurs first." 8 BY MR. FIERCE:
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9 Q That's the call-out of the replacement staff. 10 A (Callendrello) Yes. 11 Q But that doesn't necessarily trigger a shift
- 12 change yet, does it?
13 A (Callendrello) No. That would trigger the shift (N 14 change.
'-- 15 0 That does?
16 A (Callendrello) Yes. The reason it's nine hours - 17 is to allow sufficient time so that we relieve people at 18 about 12 hours, because it takes time to report, get briefed 19 and deployed. 20 Q And that would, in fact, trigger the Yankee Atomic 21 mutual aid workers coming in for the evacuation-specific 22 positions? 23 A (Callendrello) That would be one of the groups. 24 There would be a full second shift for -- 25 Q Sure. Heritage Reporting Corporation ('N (202) 628-4888
l ( REBUTTAL PANEL NO. 21 - CROSS 23966 ) ! 1 A (Callendrello) -- all of the nonevacuation-2 specific positions. But the Yankee Atomic would be support 3 for the evacuation-specific positions. 4 Q Does the ORO at that point inform the Commonwealth 5 that the traffic guides who are standing by have not , I 6 received the regular ORO traffic guide training? . 7 A (Callendrello) No , that's not one of the pieces 8 of information that would be communicated; at least not by 9 procedure. 10 Q Assume in a standby mode an order to evacuate say 11 Salisbury is given by the state, do the ORO traffic guides 12 then stay on at their posts in Salisbury? 13 A (Callendrello) Now are we in Mode 1, Mode 2? 14 Q You're in a standby mode. 15 A (Callendrello) Standby mode. 16 Q Standby modes or standing by at their posts in 17 Salisbury and you've now heard the state is, at least for 18 Salisbury anyway, they are evacuating. 19 What do your traffic guides in Salisbury do? 20 A (Callendrello) They would wait to receive 21 directions to implement traffic control activities. 22 O But if the state or local police there said 23 evacuate the community and you, too. You ORO guys evacuate. 24 At that point they would leave?
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25 Would they take that direction from the state or Heritage Reporting Corporation (202) 628-4888 , - - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _ i
REBUTTAL PANEL.NO. 21 - CROSS 23967 l 1 , fw 1 local police? l
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- '(_)i - 2 A (Callendrello) I think they would inform the 3 officer what they were trying to achieve. They would
'I 4 . explain why they needed to be there. And if the officer 5 insisted, the ORO traffic guide would call.into the 6 evacuation support dispatcher, explain the situation to the 7 dispatcher, and then follow the direction of the local 8 officer.
9 Q The reception center staff and the monitoring and 10 decon workers are also Yankee Atomic replacements after the 11 shift change, correct? 12 A (Cellendrello) Some of the positions at the 13 reception center are Yankee Atomic. g' s 14 Q Some of them. 15 A (Callendrello) They are also Massachusetts 16 Electric people, or New England Power people that provide 17 'second shift staffing. But they are all -- we gain access 18 to all those individuals through Yankee Atomic. 19 Q Does the ORO inform the state again that after 20 that shift change has occurred in the standby mode, the 21 workers who are now standing by at the reception centers, or 22 at least some of them, have not received the formal ORO 23 training? 24 A (Callend,rello) I don't recall anything in a 25 procedure that tells the offsite response director to Heritage Reporting Corporation
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r i REBUTTAL. PANEL NO. 21 - CROSS 23968 1 f 1 transmit that information. 2 Q Down at the bottom of the page, the discussion of 9j 3 Mode 1 begins. In the last sentence there, there is a 4 reference to " resources", and I see this is cited, a 5 statement that is cited, I believe, to some Massachusetts , 6 Attorney General's answers to requests for admission. 7 Isn't it true, Panel, that in fact in that answer, - 8 which is in Attachment G to your testimony, the reference is 9 to every available resource, "With the stated position of 10 the Commonwealth that it will utilize every available 11 resource." 12 Isn't that correct? 13 Rather than the sentence says as you have it 14 written here, "will utilize whatever resources". 15 A (Callendrello) Yes. A direct quote would have 16 said "every available resource". 17 Q And in the -- 18 A (Callendrello) Although really that statement is 19 a blend of Mr. Agnes' memorandum and the admission. 20 Q Well, then, maybe we should short them out. Let's 21 just do it this way. , 22 Isn't it true, Panel, that your Applicants' 23 request to admit asked as follows: "Is it the policy and 24 position of the Commonwealth of Massaunusetts to utilize 25 fully every available resource, public and private, to the Heritage Reporting Corporation (202) 628-4888
REBUTTAL-PANEL NO. 21 - CROSS- 23969 f~s , 1 extent allowed by the laws of Massachusetts, and to the _, 2 extent necessary and/or appropriate to respond to a
'3 radiological emergency?"
I-
- l 4 - And the answer that was provided was, " Admit".
I S A (Callendrello) Yes, that's correct. l 6 Q Now with respect to the Agnes memo, which is 7 attached at your Attachment G just before that answer to the 8 requests for admissions, we are looking, are we not, Panel, 9 at a memo dated January 11, 1988, from Peter Agnes to Robert 10 Boulay? 11 .A (Callendrello) That's correct. 12 0 Isn't it a fact that this memo is written as a 13 recommendation, essentially a deliberative process memo to a
N 14 superior in a state agency by one of his juniors 15 recommending a certain course of action?
16 A (Callendrello) *No, I wouldn't agree with that. 17 Mr. Agnes is Assistant Secretary of Public Safety. 18 Mr. Boulay works -- his agency would report to the office, 19 the Executive Office of Public Safety. 20 So my understanding of the hierarchy of state 21 government, Mr. Agnes would be above Mr. Boulay. 22 Q Mr. Agnes would be above Mr. Boulay. Okay, let's 23 assume that's correct. 24 Nevertheless, what we have here is Mr. Agnes, the 25 Assistant Secretary, looking to provide a recommendation of [r)
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REBUTTAL PANEL NO. 21 - CROSS 23970 1 a proposed policy to his superior, the Secretary of Public 2 Safety. And before making that recommendation to his 3 superior, he is seeking input from Mr. Boulay about a 4 proposal here. 5 Isn't that true? , 6 And specifically direct your attention to the last 7 sentence, and its Item No. 3 on the second page which reads, 8 "I would appreciate it if you would review the proposed 9 statement and give me your comments and those of your staff 10 before we make a recommendation to the Secretary." 11 Isn't that what it says, Mr. Callendrello? 12 A (Callendrello) Yes, it does. 13 Q' Do you know whether any formal policy statement 14 was ever issued by the Secretary of Public Safety himself? 15 A (Callendrello) I don't know. I know that Mr. 16 Trout did ask for any policy statements on discovery, and l 17 this is what we got. l ' 18 I presume if there was a final policy statement, 19 we would have gotten one. 20
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21 22 23 l 24 25 Heritage Reporting Corporation (202) 628-4888
. REBUTTAL PANEL NO. 21 - CROSS 23971 73 1 Q On page 29 --
i ,-) 2 A (Callendrello) (Continued) Again though, just to 3 revisit that, if you look on the first page of the Agnes 4 memo, the second numbered item, the sentence says, "In this 5 regard, I suggest that we consider the following statement 6 as an expression of the Commonwealth's policy and propose 7 that we include it in all emergency plans and guidance 8 material prepared or distributed by the Civil Defense 9 Agency." 10 So I guess to Mr. Agnes, he considered that 11 statement to be the Commonwealth's policy, and it looks like 12 he was asking Mr. Boulay to comment on how it affected 13 emergency plans.
/ 14 Q Well, he wanted his full comme,rts here, correct?
N 15 "I would appreciate it if you would review the 16 proposed statement and give me your comments and those of 17 your staff." 18 A (Callendrello) Yes, that's what it says. i 19 I don't know any more about the memo other than 20 what's in it. 21, Q On page 29, you make a statement after the quote 22 there to the Applicants' exhibit, that the " Commonwealth's 23 response and that of local communities is not ad hoc under 24 Mode 1 operation." 25 Wouldn't it again have been a more accurate
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. REBUTTAL PANEL No. 21 - CROSS 23972 1 statement to have presented that statement by saying that 2 it's not a completely ad hoc response?
3 A (Callendrello) No. 4 Q In your view, there is nothing about the response S under Mode 1 that would be ad hoc. . 6 Is that correct? 7 A (Callendrello) Under Mode 1, the ORO is supplying 8 resources for the Commonwealth to use. And it's the 9 expectation that they are using that in some planned manner 10 using the plans that exist. 11 Q In Mode 1, the state early on in an emergency 12 could be confronted with a situation where the ORO is not 13 yet ready to provide those resources, correct? 14 A (Callendrello) That's correct. While those 15 resources are being mobilized. 16 Q And in that situation, wouldn't it be fair to say, 17 Mr. Callendrello, that at least the state response would not 18 be completely planned? 19 A (Callendrello) No, that wouldn't be fair to say. 20 Q It would be completely planned at that stage 21 without the ORO yet fully mobilized in a fast-breaking 22 situation. Let's posit that. 23 How about then? The situation where the 24 Commonwealth at least perceives a need to act. l 25 A (Callendrello) Where I'm having trouble with the 1 ! Heritage Reporting Corporation I (202) 628-4888 -
REBUTTAL PANEL NO. 21 - CROSS 23973 questions is I don't see the linkage between degree of ( 1-8 4 2 . mobilization and planned response. J l 3 You are following a plan. Every plan has built 1 4' into it'some mobilization period.' And you, through good 5 planning concepts, account for.that mobilization period by 6 mobilizing at an early emergency classification level.-
# 7 _To say that because the plan has mobilization in 8 it that it's an unplanned. response, it just doesn't make any 9 sense. I can't agree with that statement.
10 ,Q You are suggesting, however, that there are 11 aspects of emergency response that the state may not yet bw
' 1:2 ready or able to conduct'because of the current state of
- L3 planning thatLthey have engaged in, and that is why the ORO-y 14 is standing by with certain resources, correct?~ ,
15 otherwise, why is the ORO here? 16 A (Callendrallo) Could you just repeat that? 17 I think.I agree with it, but I just would like you 18 to repeat it. 19 Q We are talking about a situation where the state 20 of emergency planning'in Massachusetts, because of its lack al of updating, planning, exercising, testing and drilling. 22 since 1986, has left certain deficiencies in the 23 Massachusetts emergency response capability for which the
'24' 'ORO is standing by saying, we're ready to provide personnel 25- or other services to fill those needs, correct?
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REBUTTAL PANEL NO. 21 - CROSS 23974 1 A (Callendrello) Yes. As a pre-planned measure, 2 compensatory measure. That's correct. 3 Q And in a fast-breaking emergency where those needs 4 for emergency response still' exists, when the ORO is still 5 mobilizing, the response that the state would come up with , 6 in those areas would be ad hoc, correct? 7 A (Callendrello) No. See, that's where I have a - 8 problem. 9 Q They would be following a plan? 10 A (Callendrello) If the state is applying its own 11 resources, I would presume that they are applying it in 12 accordance with some plan. 13 If they are utilizing,the ORO resources in Mode 1, 14 they are doing it in accordance with.some plan. 15 Q What is the plan for staffing of reception ' centers 16 in a fast-breaking accident for Seabrook that the state has 17 now? 18 Are you aware of a staffing plan? 19 A (Ca11endre11o) There were host plans developed up 20 until 1986. I know of no work on those host plans since
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21 then. I'm not aware of any staffing for the host 22 facilities. . 23 Q And what the state would do to quickly attempt to { 24 staff up a reception center would be basically ad hoc, , l 25 correct? Heritage Reporting Corporation (202) 628-4888 l \ _ _ _ __ . _ _ _ _ _ _ - -
REBUTTAL PANEL NO. 21 - CROSS 23975
,s 1 A (Callendrello) If they were taking responsibility
(,, 2 for staffing reception centers, it would be, again, in 3 accordance with some plan.- If they said, we need to staff a 4 reception center, what are we going to do, I would presume
- 5. that somebody would open up their Comprehensive Emergency 6- Response Plan ~and look under the section that says American
+ 7 Red Cross. Look down and say,.yes, American Red Cross 8 staffs reception centers. Therefore, somebody call the 9 American Red Cross representative and let's get these things 10 staffed. They would use some plan.
11 The fact that the resources may not be pre-12 identified as part of the Seabrook Station plan or the plan
.13 itself may be a comprehensive plan or a generic radiological 14 plan.does not mean it's ad hoc. There is some plan that O 15 somebody will look to to which planning ORO resources would 16 serve as a supplementary resource.
17 -Q The Massachusetts State Police are looking at one 18 plan. The Red Cross get notified; they are looking at 19 another. A host community pulls out its old plan for 20 staffing reception centers. 21 We could have three state agencies responding to 22 needs at a reception center in three different ways, 23 couldn't we? 24 A (Callendrello) Well, no. That's why you have a 25 command organization. That's why you have a civil defense 1 (N Heritage Reporting Corporation (202) 628-4888 I U--__-_____-_____-______-______-__-_-_______________________.._______.___________________
REBUTTAL PANEL NO. 21 - CROSS 23976 1 command organization to ensure that that doesn't happen. 2 Q If they decide to turn to the old host community 3 plan and they turn to the Town of Peabody, is it Peabody? 4 A (Callendrello) That's'one of the host 5 communities. , 6 Q Who in the Town of Peabody could be contacted to 7 staff up a reception center? 8 A (Ca11endre11o) I don't have the plan in front of 9 me, and I'm going by my recollection. But it would be the 10 civil defense director and the local American Red Cross is 11 what I recall. And they, in turn, would make additional 12 call-outs for personnel. 13 0 With respect to where a state police staging area 14 might be located, that would be an ad hoc decision made at 15 the time, correct? 16 A (Callendrello) There is one identified in the 17 1986 versions of the plan. And that's at the Topsfield Fair 18 Grounds. 19 Q Because there used to be a barracks adjacent 20 thereto, but there isn't any more, correct? 21 A (Callendrello) There are no barracks. That's one 22 of the considerations. 23 The other consideration is that it's a large area 24 controlled by the state. 25 Q At least' there would be a decision to make here, Beritage Reporting. Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23977 1 for now, correct? 7-. l \ (_,/ 2 A (Callendrello) I don't understand the qpestion. 3 Q The state responding, or particularly the state 4 ~ police in responding, would not feel compelled in any way, 5 would they, to set up their staging area at that location at 6 Topsfield just because that old 1986 plan said that's where 7 it should be? 8 Would they? 9 A (Callendrello) Where I'm having trouble is you've 10 given the NRC Staff an interrogatory response that said that 11 the Topsfield Fair Grounds would be used as a staging area. 12 Q No , I don't think that's correct. I think the 13 state police, they said what they said, and I don't want to (S/ i 14 get into an argument with you about that.
' 15 But I believe they did say, and you might agree 16 with me, that they would look to those plans. I think that 17 is the language they would use.
18 (Witness reviews document.) 19 BY MR. FIERCE: 20 Q Are you interpreting that language, Mr. 21 Callendrello, that they would look to those plans to mean 22 that they would follow them to the letter? 23 A (Callendrello) Again, we're in Mode 17 24 Q Yes. . 25 A (Callendrello) No , I don't think they necessarily l rN ( ) Heritage Reporting Corporation l \/ (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23978 1 would follow them to the letter. 2 Q Where the Department of Public Works will get 3 cones and barricades and who they would get to deliver them 4 would be an ad hoc response in a Seabrook emergency, 5 wouldn't it, Mr. Callendrello? , 6 They don't have staffing lists for those tasks for 7 Seabrook, do they? - 8 A (Callendrello) Not that I'm aware of. 9 Again, I just don't recall what was in the Area I 10 plan for DPW. But I just don't recall staffing lists there, 11 although they did list some resources. Staffing, as I 12 recall, was not one of them. 13 Q How they would handle all of the bus 14 transportation needs in the EPZ would be an ad hoc effort 15 for Seabrook, wouldn't it? 16 (Witnesses review document.) 17 A (Callendrello) As the interrogatory response 18 says, transportation resources would report to the Topsfield 19 staging area. And there is also an MBTA plan that was 20 provided. It was the plan that the MBTA would use for 21 providing transportation resources.
'22 Q Well, we had a little bit of confusion about that 23 one last week. And as I thought we left it, and maybe we 24 can clarify that, I thought it was,your view that, in 25 following the RERP, the state would use the more Heritage Reporting Corporation (202) 628-4888 l
REBUTTAL PANEL NO. 21 - CR.OSS 23979 1 contemporary notion of reliance on private bus companies 7-w) .
\ m- / 2 rather than on the MBTA.
3 A (Callendrello) That's correct, except that the 4 interrogatory response says that the MBTA thinks they are 5 providing bus resources. 6 Q That's right. 7 A (Callendrello) So it sounds like we are going to 6 have buses from both sources. 9 Q MBTA does think it will be providing bus 10 resources. 11 A (Callendrello) They will have buses from both 12 rources available. 13 Q So those state decisionmakers perhaps will have
,/T 14 some options.
( ) 15 But at least you can't deny that the decision on 16 how to respond with bus transportation resources to Seabrook 17 will be an ad hoc one. 18 A (Callendrello) Maybe I'm having trouble with your 19 definition of "ad hoc". Maybe I don't understand your 20 definition of "ad hoc".
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21 To me, if somebody is following a plan using 22 resources that have been pre-identified, that is not ad hoc. 23 And in Mode 1, the assumption is somebody is following a 24 plan and they are either using their own resources or 25 resources that the ORO makes available. Corporation (%)
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e REBUTTAL PANEL NO. 21 - CROSS 23980 1 So, in my mind, that is not ad hoc. 2 Q What are the private bus resources that have been 3 identified for Seabrook response in the state's own plans? 4 (Witnesses review document.) 5 A (Callendrello) Merrimac Valley Regional Transit , 6 Authority -- 7 Q What are you reading from, Mr. Callendrello?' 8 A (Caller.drello) I'm sorry. I'm reading from 9 Exhibit 55 (a) , page 136. Well, 136, I think, through 144. 10 Merrimac Valley Regional Transit Authority will 11 make available 40 buses. Travel Time will make available 30 . 12 full-sized buses, four motor coaches, 10 half-sized buses. 13 vermont Transit Company will make available 50 buses. 14 McGregor-Smith will make available, it looks like 55 school 15 buses, and I can't read the number of the motor coaches. 16 Michaud Bus would make available 28 school buses 17 and 15 intercity coach buses. Blanchard will make available 18 45 buses. Lowell Regional Transit Authority would make 19 available 33 buses. ABC Bus Company would make available 62 20 buses and Fiore Bus Service would make available 128 buses. 21 That's it. 22 Q The way you say this, "would make available X 23 number of buses" sounds like you believe that in fact these 24 agreements are still in effect. 25 Is that the case? Is that what you believe? Heritage Reporting Corporation (202) 628-4888
i REBUTTAL PANEL NO. 21 - CROSS 23981
-~ l A (Callendrello) I thought the question you asked k _,/
s 2 me is what bus resources are identifiedLin the area p1'an, 3' and that's what I read to you. 4 0 Well, I'm asking you what bus resources had been 5 pre-identified. And now you've pointed to those old letters. 6 of agreements. And I'm asking you whether, in fact, that 7 constitutes sufficient pre-identification for the state to 8 be able.to rely on their availability at the time. 9 A (Callendrello) I don't know if these lettprs of 10 agreement are still in force or not. 11 I know a number of these companies still exist. I 12 know that Merrimac Valley Regional Transit Authority still 13' exists. McGregor-Smith certainly still exists. Michaud
/N 14 exists. I don't know about Blanchard. Lowell Regional tU) 15 Transit Authority, I don't know about. ABC, I believe, 16 exists. And Fiore, I know, exists.
17 Q It's no secret to the public that the state has 18 stopped planning for Seabrook since 1986, correct? 19 A (Callendrollo) I presume not. 20 Q And for that reason alone wouldn't it be likely 21 that these bus companies are not feeling obligated under a 1986 agreement, letter of agreement with the Commonwealth of 22 23 Massachusetts? 24 4 (Callendrello) No , I don't know what obligation 25 they feel. These are general letters of agreement which r Heritage Reporting Corporation (
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REBUTTAL PANEL NO. 21 - CROSS 23982 1 say, "This letter confirms the willingness of the Merrimac 2 Valley Regional Transit Authority to provide buses and 3 drivers, to the maximum extent possible, to the 4 Massachusetts Civil Defense Agency for use in any 5 emergency." , 6 It's not specific to Seabrook. These letters may l 7 very well still be in force. Some of them call out 8 specifically Seabrook Station as one of the emergencies that 9 they would consider in an emergency. 10 I'm looking at every one of them. 11 (Witness reviews document.) 12 13 14 15 16 17 18 19 20 21 22 , 23 24 , 25 Heritage Reporting Corporation (202) 628-4888
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REBUTTAL PANEL NO. 21 - CROSS - 23983 ye s 1 THE WITNESS: (Callendrello) Again, some of them 1
) " Including an evacuation caused by an accident at L-
\_/s 2 say: .
3 Seabrook Station." 4 BY MR. FIERCE:
, 5 Q Do you think, Mr.'Callendrello, that it's anymore '
V 6 likely that a state official in calling these bus companies
*: 7 in the middle of a Seabrook emergency would be able to get 8 buses from them than it would be, say, if they picked up the 9 yellow pages.and called any other bus companies they can 10 find?
11 A (Callendrello) I think.so. 12 At least at one time this organization was working 13 with civil defense. Agreed to provide those resources. To 14 respond to any emergency. 15 As far as I know that is the most current area 16 plan. And I have no reason to believe that those resources
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17 would not still be available. 18 Q You would admit, though, that none of the bus 19 companies have engaged in a drill or exercise for Seabrook 20 with state or local officials; correct? 21 A (Callendrello) That's correct. 22 Q At least since 19867 23 A (Callendrello) That's correct. 24 Q In at least a number of the letters of agreement, 25 reference is made to the fact that training will be r% Heritage Reporting Corporation ( N- ') (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23984 1 provided; correct? 2 A (Callendrello) That's correct. . 3 Q And no training has been provided that you're
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4 aware of; true? 5 A (Ca11endre11o) I would have to go back and Iook , 6 at the training records. I don't recall any for bus 7 drivers, however. 8 Q What is it, if not an ad hoc effort, if the state 9 attempts to line up people to ride with these buses, to 10 guide them on routes through the EPZ and to schools and day 11 care centers and other special facilities and on routes 12 through the town to pick up those without transportation? 13 A (Callendrello) If you're saying the state would 14 attempt at the time to recruit individuals to act as guides, 15 I think that would be ad hoc. 16 But that's not what Mode 1 is; Mode 1 assumes that 17 the state would use the resources that it had preidentified; 18 and if those resources are not sufficient, it would call 19 upon the ORO to provide resources to compensate for any need 20 that the Commonwealth should have. 21 Q Again, I'm positing a situation where the ORO is 22 not yet fully mobilized and able to provide those resources. 1 23 In that situation there would be an emergency 24 response effort that would be ad hoc, because at the time 25 the Commonwealth and the localities would be in the process Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23985 1 _of trying to line up some people to guide those buses L s /_ 2 through the towns to the appropriate locations; correct? 3 A (Ca11endre11o) Again, just. underlying that 4 scenario you laid out for me is the assumption that we've 5 had an immediate declaration requiring a protective action 6 of evacuation. - 7 Q No. It's a fast-breaking accident, I would admit, 8 but we're talking about a situation where the state, 9 perhaps, might be interested in engaging in an early 10 protective action for the schools and needs to move before 11 general population PAR is issued? 12 A (Callendrello) So we've had a declaration of-emergency that would mobilize the ORO.
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13 _f 14 Q Right. T' 15 A (Callendrello) And mobilize Civil Defense and the 16 other state and local organizations. And while these 17 organizations are mobilizing they have decided to make a 18 protective action recommendation using resources that have 19 been preidentified through one of these early plans, 1986 . 20 plans. 21 Now that I understand the basis. ; 22 Q Or wherever? 23 A (callendrello) What was the question again? 24 Q They haved'one whatever they have done to line up 25 some buses but they need some help in guiding them through O Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23986 1 the towns to the proper locations because they're coming in 2 from other towns. 3 Wouldn't you have to admit that that effort to 4 line up those route guides would be an ad hoc one? 5 A (Callendrello) I would expect they would make a . 6 call to ORO and ask if any of our route guides.have been 7 mobilized. And as soon as they mobilize to send them to the - 8 Topsfield staging arsa. 9 In that instance, if you were trying to do 10 something ahead of what the plans call for, I would say 11 that's ad hoc. 12 Again, you' re operating outside of the plan, 13 though. 14 Q Your route guides are not even mobilized until a 15 site area emergency; correct? 16 A (Callendrello) Right. 17 And there's no need for protective action earlier 18 than site area emergency. 19 Q In turning to the Fed Cross just at the reception 20 centers, you would have to admit that the Red Cross, at this il point, has done no planning for Seabrook; correct? 22 A (Callendrello) That's correct. 23 With the exception of a few congregate care 24 centers that one Red Cross representative had visited. 25 Q And their efforts now to line up staff, volunteers Heritage Reporting Corporation (202) 628-4888 l J
REBUTTAL PANEL NO. 21 - CROSS 23987 1 for the reception centers, and also, for the congregate care 2 centers that might be identified,. that effort to line up 3 those peoplo now would be an ad hoc one, too; correct? 4 A (Callendrello) No. 5 There is a Red C'ross organization that exists 6 regardless of Seabrook Station planning. The Comprehensive 7 Emergency Response Plan identifies some 62 American Red 8 Cross Chapters. 9 And if you look at the staffing levels for those 10 chapters in terms of the general guidance that Red Cross 11 provides, they typically establish a shelter manager and a 12 couple of administrative staff positions for the shelters 13 that they would establish in their towns. 14 Remember, they don't respond solely to emergencies 15 at Seabrook; they respond to all types of emergencies that 16 may involve relocation of people. So the staffing would 17 exist through their normal chapter organizations. 18 Q But the number of people and the assignment of 19 those people to specific tasks in a reception center for 20 Seacrook evacuees would be part of the planning process that 21 has not been completed by the Red Cross; correct? 22 A (Callendrello) To the extent that any plans are 23 needed. They've got general training; they've got general 24 shelter manager instructions; they know how to take a 25 building and turn it into a congregate care facility. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23988 1 So I don't know how much else is needed in the way 2 of plans for them to do that. 3 Q A reception center is something different than a
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4 congregate care faci 1ity, though, correct? 5 A (Callendreilo) Yes, it is. , 6 In the Seabrook plan it is; yes. 7 Q And tasks that need to be performed there are 8 different than are performed in congregate care centers? 9 A (Callendrello) Yes, for the most part. 10 The radiological monitoring decontamination are 11 different. In fact, are tasks that Red Cross would not 12 normally perform. - 13 Q On page 30 there is a statement at the bottom of 14 the page, the last full sentence: "That the state and local 15 governments request for assistance can be directed to the 16 ORO counterpart or to the appropriate liaison."
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17 That process can only occur after -- let's talk 18 about, first, the ORO counterpart. 19 That can't take place, obviously, until the ORO l 20 counterpart is in place and operational; correct? i 21 A (Callendrello) That's correct. 22 Q And with respect to the liaisons --
- 23 A (Callendrello) With the exception of the offsite 24 response director, because he establishes contact from his 25 notification location -- wherever he is notified.
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REBUTTAL PANEL NO. 21 - CROSS 23989 fg 1 Q Or his cellular telephone in his car? ! )
'v / 2 A (Callendrello) Right.
3 Q But with respect to the others, they have to be in 4 place. And with respect to the liaisons, again, request for
, 5 assistance to be directed to them, the liaison has to be in 6 place at the agency; correct? ,
7 A (Callendrello) There can be a contact established 8 from the EOC, at least for the two state civil defense 9 liaisons, but those liaisons are intended to report to the 10 EOCs -- the Area 1 and the Framingham EOC 9- to fully 11 facilitate their operation. 12 However, there is an assistant offsite response 13 director for support liaison who does remain at the EOC and (T ( / 14 would contact the state organization to offer assictance and 15 provide the conduit through which the state organization 16 could request assistance. 17 Q At page 31 -- well, it's at the bottom of page 30 18 and carrying over to 31 there's a statement that comes from 19 the SPMC about the authorization that the ORO director has 20 been given by the president of New Hampshire Yankee. 21 My question is: is there any limit at all on that 22 authorization either with respect to the amount of money 23 that can be spent or in any other way? 24 A (Callendrello) Yes, there is. 25 Q What is that limit? n Heritage Reporting Corporation
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I REBUTTAL PANEL NO. 21 - CROSS 23990 1 A (Ca11endre11o) The limit is -- and I'm reading 2 from page C-1 of the SPMC, it's Appendix C. I'm trying to 3 find the beginning of the sentence, it's one long sentence. 4 But the clause that's relevant is: "To commit any 5 and all resources identified in said plan and funds up to , 6 his authorized signature level." 7 I don't know what the signature levels are. 8 Q That was going to be my next question. 9 Do you have any idea what the range is? 10 A (Callendrello) No, I don't recall offhand. 11 Q Is it in the range of thousands, tens of 12 thousands, hundreds of thousands? 13 You don't know? 14 A (Ca.lendrello) I don't know. 15 Q Does any p?ne'. member know that? 16 (No response) 17 BY MR. FIERCE: IB Q Now, at page 33 in the first full paragraph it 19 says: "The SPMC is intended to provide detailed guidance to 20 ORO members for implementation of an emergency response. As 21 such it is not intended that the state and local officials 22 will in all cases follow the specific mechanics of the SPMC 23 procedures." 24 Does that sentence imply that there are some cases 25 where actual mechanics of SPMC procedures would be followed? Heritage Reporting Corporation (202) 628-4888 l - - - - - - - -
I REBUTTAL PANEL NO. 21 - CROSS 23991
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s\ 1 A (Callendrello) Yes. k_, 2 . Q And which ones are those? 3 A (Ca11endre11o) I have named some of them already. 4 The traffic control point diagrams; access control p6 int 5 diagrams; the utilization of lists of ingestion pathway food 6 producers food processors; location of the reception 7 centers; the protective action recommendation process, and 8 that is the use of protective action guides; transportation 9 operations. 10 Q In any of these areas, Mr. Callendrello, are there 11 specific procedures in the SPMC that the state responders or 12 local responders would pick up and follow? 13 A (Ca11endre11o) There are parts of procedures that I (~'N1 14 they would pick up and follow. 15 Q Parts, okay. - 16 Let me take the traffic guides. You indicated the 17 diagrams. But with res'pect to the traffic guide procedures, 18 no they wouldn't follow those necessarily? 19 A (Callendrello) Not necessarily. 20 The traffic guides, of course, would continue to 21 follow them. But if a state or local police officer 22 arrived, what they would need to follow is contained on the 23 traffic control point diagram. 24 Q Just to be specific: on page J-1 of the Traffic 25 Management Manual, procedure number 1. (A)
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l l REBUTTAL PANEL NO. 21 - CROSS 23992 1 A (Callendrello) I'm sorry, I don't have a copy of
. 2 that. Just give me a moment.
3 0 It's a short one and I'll read it to you and see 4 if you can follow this. , 5 It reads: "At a site area emergency obtain , 6 dosimeters and a briefing from a dosimetry record keeper at 7 the staging area." 8 That's not a procedure you are intending the state 9 police to follow, is it? 10 A (Ca11endre11o) That's right; they would not need 11 to follow that. 12 Q Number two: dComplete emergency worker dose 13 record form, retain a copy of the completed form." 14 Again, that's a procedure for your ORO traffic 15 guides; correct? - 16 A (Callendrello) Right. 17 Now, those steps you've read, that is not to say 18 that a state policeman could not follow those. If, for 19 example, the state police rather than mustering at the 20 Topsfield staging area said, we've got 200 state police, 21 where do you want us to send them so they can get traffic 22 control instructions and dosimetry; it's quite possible we 23 would say, send them to the Haverhill staging area where 24 they could get dosimetry, they could get procedures, they 25 could get traffic cones. And they could follow those Heritage Reporting Corporation (202) 628-4888
l l 23993 I REBUTTAL PANEL NO. 21 - CROSS
,-- 1 portions of the procedure, although it's not necessary that I )
l- ( ,,- 2 they do. ) l 3 Q Well, I'm actually more interested in those areas 4 where you believe that it is necessary rather than possible 5 or optional, but it is necessary to follow specific SPMC 6 procedures. ,
- 7 Can you find for me some specific procedures you 8 think need to be followed?
9 A (Callendrello) Beyond those I've already 10 identified? 11 Q No. No, even within those you've identified. 12 I'm looking for -- if we can get an example. 13 Q On page 12 of the traffic guide procedure -- I'm yx 14 sorry, step 12, page J-2 which says: " Implement the traffic ( '
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N- 15 control strategy shown on the detailed sketch of your TCP." 16 And then it talks about people that should be 17 discouraged from passing. 18 Q So that section needs to be followed, but the 19 procedures above, 1 and 2, for example, and perhaps some of 20 the others need not be? , 21 A (Callendrello) Tnat's right. 22 The traffic guide who is either at the location or 23 will be at the location would provide that function for the 24 police officer at that location. , 25 Q What about the very next procedure, number 13: r% i Heritage Reporting Corporation (
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REBUTTAL PANEL NO. 21 - CROSS 23994 1 " Notify the evacuation support dispatcher if traffic is 2 blocked or if there is no evacuating traffic." 3 A (Callendrello) That would not be implemented by 4 the local policeman. That would need to be implemented by. S the traffic guide because that individual -- the traffic , 6 guide has the radio that can communicate with the evacuation 7 support dispatcher. 8 Q Number 15: " Place traffic control equipment in 9 vehicle and drive to the EWF trailer and notified by the 10 evacuation support dispatcher to terminate actions." .1 Is that one that the state and local police would , 12 need to follow and would be expected to follow? 13 A (Callendrello) I think portions of it. 14 We would expect state and local police to report 15 to the emergency worker facility to be monitored and 16 decontaminated, if necessary. 17 They wouldn't be notified by the evacuation 18 support dispatcher; I would expect that they would be 19 notified through their own command structure. 20 21 22 23 24 , 25 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23995
-~ 1 .Q How about in any other areas you mentioned?
x_,/ 2 A (Callendrello) The transit operations, we would 3 expect bus drivers to follow the routes laid out in the 4 SPMC. - 5 Q That's in the Traffic Management Manual, again; 6 correct? , a 7 A (Callendrello) Yes. 8 And also, in the packets that are provided to 9 route guides. 10 Q The procedures for providing transportation 11 resources, are there any specific implementing procedures 12 there that it is intended that state and local governments 13 will follow? The specific mechanics of those procedures?
,/'N 14 A (Ca11endre11o) No, t
\' 15 Q Are there any procedures in the procedures manual 16 themselves that it is expected that the state'and local 17 governments will-follow, mechanically follow?
18 A (Callendrello) I think I have laid out the 19 procedures that I'm aware of; that's a large volume. 20 I'm fairly familiar with the procedures and I just 21 can't offhand think of anything else that I would expect 22 them to follow. Maybe pieces of it and concepts such as 23 emergency workers reporting to the emergency worker facility 24 for monitoring and decontamination. 25 But again, that's not following the mechanica of a f Heritage Reporting Corporation (( L\ (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23996 1 procedure. 2 Q Let me just clarify. 3 There is nothing in this procedures volume, not a 4 page that provides a set of instructions or procedures that 5 state or local emergency responders are expected to follow? , 6 A (Callendrello) With the exceptions of the 7 procedures I've identified. . 8 O Maybe we need to go through those again. ; 9 Which ones are we identifying now? 10 A (Callendrello) Traffic control. 11 Q That was back in Appendix J. 12 I'm talking about the procedures volume? 13 A (Callendrello) Well, there is a traffic control 14 procedure as well; procedure IP 2.11. , 15 Q- 2.11? 16 A (Ca11endre11o) 2.11. - 17 Q Yes. 18 Which is labeled: " Traffic support and i 19 notification to the hearing impaired?" 20 A (Callendrello) Right. 21 Q Can we pull out that procedure as'well again and 22 have you show me which of these procedures needs to be 23 followed by the local or state responders? 24 A (Ca11endre11o) What would be followed is the 25 manning sequence for traffic control points, and the fact l 1
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l f L REBUTTAL PANEL NO. 21 - CROSS 23997
,, - ~ 1 that they are deployed at a site area, emergency or general 1
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,\_./ 2 emergency.
3 There is no specific step in this procedure that a 4 local or state responder would need to implement. In other 5 words, they would not need to substitute themselves for the 6 evacuation support dispatcher. 7 Q Or for the staging area leader 5.2? 8 A (Callendrello) That's right. 9 Q But they would instead follow, what is it now? 10 A (Callendrello) They would follow the general 11 instructions to deploy traffic guides or in this case state 12 and local police at the site area emergency or general 13 emergency. And to follow -- Step 5.1.3 of that says, in fN 14 essence, follow the traffic management manual which is where (
)
15 we were just before. That's Appendix J to the plan. 16 Q All right. 17 They don't need to look -- state or local 18 responders don't need to look at these procedures in order 19 to do that. They can pick up the Traffic Management Manual? 20 A (Ca11endre11o) In general, yes. 21 Some state police dispatcher or local police 22 dispatcher, more likely a state police dispatcher, would be a 23 performing these functions. But it's something that does 24 not need to be proceduralized ,for them necessarily. 25 A dispatcher would be told through his command
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L REBUTTAL PANEL NO. 21 - CROSS 23998 1 structure to mobilize state poli,ce when they arrive at the 2 staging area, tell them what location to report to. Tell 3 them what to do at that location and dispatch them. 4 Q What were the-other areas besides traffic cEntrol? 5 A (Ca11endre11o) Transportation operations. , 6 Q And are there specific procedures in this volume 7 that would be picked up and followed by specific state or 8 local emergency responders? 9 A (Callendrello) There's an attachment to procedure 10 2.10 which describes some of the bus needs for the 11 communities and provides a location for recording the 12 information regarding the other bus needs for the facilities 13 in the community. 14 Q Which attachment is that? 15 A (Callendrello) Attachment 1. 16 Q How about a specific procedure? Page or element 17 on a page? No? 18 A (Ca11endre11o) I'm looking. 19 (Witness reviewing document.) 20 THE WITNESS: (Callendrello) The direction to 21 fill out that attachment is on pages 8 and 9 of the 22 procedure under Step 5.2 for the bus dispatcher. 23 BY MR. FIERCE: 24 Q But that set of procedures under 5.2 was not meant 25 to be followed in a step-by-step fashion by a state or local Reporting Corporation Heritage (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 23999 1 responder; correct? 2 A (Callendrello) It's expected that the state or 3 local responder will assess the transportation need for the - 4 facilities in their community; include the transit-dependent 1 5 transportation need; and ensure that the buses are deployed 6 to fulfill those needs. 7 It's not necessary that they follow all of the 8 steps in this procedure because there are some positions 9 that are not reflective of a state or local organization. 10 But the concept of "when you're told that you 11 have resources, here is how you assign them" would 12 generally be followed by a state or local responder. 13 And as far as where those resources would be 14 deployed to, that would also be similar for a state and 15 local respond -- if a state and local responder was 16 implementing it or if the ORO was implementing. 17 Q If the state were implementing it, what would it 18 do here with respect to these procedures referring to route ' 19 guides? 20 A (Callendrello) It would utilize ORO route guides.
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21 In Mode 1? 22 Q Yes. 23 A (Callendrello) Use ORO route guides. 24 Q So you're admitting the state does not have route 25 guides? 9 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24000 1 A (Callendrello) The state plan has no provision 2 for route guides. It did talk about bus guides. I don't } 3 know what staffing was ever provided for them. 4 I mean, to the extent that they needed a route 5 guide, if they're using one of the bus companies that , 6 norma 11y services a school in the EPZ, they wouldn't need to 7 provide a route guide, obviously. - 8 Q Other than the -- well, we've talked about the 9 traffic guides and access. control function and now 10 transportation. 11 Is there any other procedures that would.need to 12 be followed by the state or local responders? 13 A (Callendrello) I don't know of any others. 14 Well, again, I indicated last week and again today 15 that Appendix L -- the information contained in Appendix L 16 would be utilized by state responders. 17 And some of the information in Appendix M could be 18 used by local responders in identifying those individuals 19 who are homebound to have special needs. 20 Q Just below the sentence we were just talking about 21 on page 31 there's a sentence which says: "What is intended 22 is if the Commonwealth and local communities wil'1 utilize 23 the provisions in the SPMC for determining and implementing 24 protective actions, implementing traffic and access control, 25 and use of reception and host facilities, monitoring Heritage Reporting Corporation . (202) 628-4888 l l L
, REBUTTAL PANEL NO. 21 - CROSS 24001 ,-s 1 decontamination facilities, transportation' operations in the 2 absence of any'other plan that tested response strategies."
3 Is there or isn't there an absence of other e 4 ' planned and tested strategies.at.the-state level? Strike. 5 _that andylet me put'it a di - ferent way. 6 Do we have a situation'in Massachusetts where
---- 7 there is'an absence of other planned and tested response 8 strategies, in any area, Mr. Callendrello?
9 A . (Callendrello) I think some of the specifica are 10 . missing from the plans.. And certainly, those plans have not 11 been tested in the Commonwealth as related to.a' response at
'12 Seabrook Station.
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- L3 So.for those functions that we have laid out in 14 the testimony, if there is no other planned or tested d 15 response strategy the Commonwealth will utilize, it'.s our 16 expectation that they will use the provisions of the SPMC.
17 Q Well, let me just take that for a minute. 18 Take that MCDA old plan, your Exhibit 55 (a) . We' 19 have already established-that that has not been' drilled, . 20 tested or exercised in the past three years and that nobody L 21 in the past three years has been trained regarding those 22 procedures. 23 Does that fall into that category, then, as an 24 area where.there is an absence of a planned and tested 25 response such that.the MCDA is now going to be expected, as Heritage Reporting Corporation '
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REBUTTAL PANEL NO. 21 - CROSS 24002 1- this sentence suggests, in utilizing the provisions of the
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2 SPMC instead? 3 A (Callendrello) The answer is, yes and no. 4 There are traffic control point strategies that 5 are in the SPMC that are also in Exhibit 55 (a) that are , 6 consistent. There's been some changes and we admit that 7 there's some changes to a few points, and there is one new - 8 additional point. 9 So I can't say unequivocally that everything that 10 is in this plan would be rejected and the SPMC followed. 11 What we'are saying is, the provisions exist in the SPMC in 12 those specific areas, on page 31 of the testimony, that 13 would allow the implementation of those functions,in the 14 absence of any other planned and tested response strategy. 15 Q I guess I'm still unclear. 16 ' What set of traffic management plans, diagrams, 17 will MCDA look to, in your view? 18 A (Callendrello) MCDA? 19 O And the state police? 20 A (Callendrello) Your interrogatory response says that they would look to the Appendix 3 to the Radiological 21 22 Emergency Response Plan, Section C-3. . 23 And what I'm saying is that the provision exists 24 for the state liaison to bring with him a set of the traffic 25 control point diagrams, as described in the SPMC, for Heritage Reporting Corporation (202) 628-4888 9!
r- - - -- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - --- q i l REBUTTAL PANEL NO. 21 - CROSS 24003 ? : p 1 utilization by state police.
\ 2 So to the ext'ent that state police, for any 3 reason, didn't want to use the diagrams that they said they-4 would use, then we have a full set of' diagrams that they can 5 use.
'6 -Q So they could use those old diagrams or they could:
7 use your diagrams? 8 A (Callendrello) That's right. 9 There's not very much difference between them. 10 Q Except.in a couple of significant aspec'cs as we 11 have already discussed such as at the I-95/ Route 110. 12 A- kCallendrello) As I said earlier, that does not 13 affect evacuation times. . 14 , s 15 16 17 18 . 19 20 21 22 23
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REBUTTAL PANEL NO. 21 - CROSS 24004 1, Q The final sentence in that paragraph 'is : "At 2 least in two of these functions, protective actions and 3 traffic and access control, the SPMC uses criteria and
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L 4 strategies nearly identical to those developed -- excuse me, 5 to those relied on by the Commonwealth." . l 6 Actually, that was maybe a Freudian slip there. 7 Isn't it, in fact, true that rather than using the - 8 language " relied on," that it would have been better to say 9 " developed and rejected by the Commonwealth?" 10 A (Callendrello) No. l 11 , In the areas of protective actions decision-making 12 in traffic and access control we were relying on the 13 interrogatory responses that the Commonwealth provided. 14 They indicated that for protective actions they would.look 15 to the protective action guidelines as used in the CERP 16 which are identical to the SPMC. 17 As far as traffic and access control points they 18 would use the points outlined in our Exhibit 55 (a) with the 19 four exceptions that we noted in our earlier piece of 20 testimony are identical. 21 Q Before I get into that, I don't want to talk to 22 you about protective action decisions. 23 I guess this sentence is suggesting that there 24 are, in fact, other areas where the SPM strategies are not 25 nearly identical to those relied on by the Commonwealth; Heritage Reporting Corporation (202) 628-4888
l. l h REBUTTAL PANEL NO. 21 - CROSS 24005
.p 1 correct?
_, 2 A (Ca11endre11o) That's correct. 3 0 What are some of those? l 1 4 A (Callendrello) The location of the reception 5 centers. j 6 Q What else? 7 A (Callendrello) The location of the local 8 transportation staging areas.
.9 Q Anything else you can think of?
10 A (Callendrello) Location of the -- well, the use 11 of a special facility, a special population host facility. 12 That's all I can think of offhand. 13 Q Let me talk about the protective action decisions 14 for a minute and ask you:.isn't it true that Massachusetts 15 had not/has not ruled out early beach clos'ing at an alert 16 for Seabrook? 17- A (Callendrello) The version of the plan that was 18 completed in 1986 did idelude evaluation of precautionary 19 beach closure at an alert level. 20 Q So there is a difference in strategy between the 21 SPMC's protective action strategies for the beach area and 22 what the old Massachusetts plans had; correct? , 23 A (Ca11endre11o) That's correct. 24 Q Massachusetts had not firmly adopted an ERPA ling 25 drawn the way the SPMC draws it with respect to the six Beritage Reporting Corporation
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REBUTTAL PANEL NO. 21 - CROSS 24006 l 1 towns; correct? l 2 A (Callendrello) No, that's not correct. 3 If you look at Exhibit 55, page 190 of 293 there 4 is a table that provides the evacuation time estimates and 5 the ERPAs, and those ERPAs are identical to the ERPAs in the , 6 SPMC. 7 JUDGE COLE: At page 1907 8 THE WITNESS: (Callendrello) Yes. 9 BY MR. FIERCE: 10 Q I understand these are certain evacuation time 11 estimates. 12 But is there anything in this whole plan that 1 13 would rule out calling for protective actions town-by-town, 14 separately, or using. groups of towns that are different than 15 the ERPAs that the SPMC utilizes? 16 A (Callendrello) There is nothing that would rule 17 that out. 18 Q But the $PMC has no provision for town-by-town 19 protective action decisions; correct? 20 A (Callendrello) That's correct. 21 Because one of the pieces of input data used when f i 22 you make a p'rotective action recommendation is an evacuation _ 23 time estimate. 24 And there are no town-by-town evacuation t4pe 25 estimates. As far as I know there have never been any town-Heritage Reporting Corporation (202) 628-4888 __ _ _ _ _ _ _ _ _ _ ..______-_______a
REBUTTAL PANEL NO.'21 - CROSS 24007
' j>~ 1. by-town' evacuation time estimates.
I o 2 Keep in mind, these ERPAs arrived at by KLD were 3 arrived at when KLD was under the direction of Massachusetts 4 Civil: Defense. 'So Mr. Lieberman did not dream these up.-
.- 5 These were agreed on and developed in concurrence with the 6 Commonwealth.
7 Q And after that the Commonwealth withdrew from 8 planning for Seabrook stating publicly that they did not 9 believe there was any set of plans that would adequately-10 protect their population; correct? 11 A. (Callendrello) I would have to look at Mr. 12 Dukakis' statement. 13 Q In essence, that's what it says, isn't it, Mr. t [ 14 Callendrello? - 1' . 15 A ' (Callendrello) Well, I think the document speaks 16 for itself in Attachment F. 17 He says: "I determine that no Radiological 18 Emergency Response Plan for the Seabrook Station emergency 19 planning zone can be devised which, 'and in the opinion of 20 the state is adequate to protect-the health and safety of-21 the citizens living within the emergency planning zone.'" 22 And then reference to 44 CFR 350. 23 Q Is there anything in those old planning documents 24 that indicates that Massachusetts has ruled out the use of 25 sheltering in the beach areas? [
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Q REBUTTAL PANEL NO, 21 - CROSS 24008 1 A (Callendrello) I don't know. 2 I don't recall whether they have or not. 3 (Witness reviewing document.) 4 THE WITNESS: (Callendrello) I'm looking at the 5 Exhibit 55, page 225 which is " warning and protective , 6 actions for Seabrook area beach populations." 7 As far as I can tell, and I'm iust reading this 8 quickly, I don't see any provisions for sneltering the beach 9 populations. There are no sheltering provisions in here. 10 BY MR. FIERCE: 11 Q In the document you have just referred me to I see 12 that the precautionary actions for the seasonal beach 13 population would include, and therein follows a list. 14 Do you read that language to preclude the use of 15 sheltering? 16 A (Callendrello) Those are precautionary actions. 17 Q Right. 18 A (Callendrello) If you look.at the protective 19 actions which are under the " general emergency" where they 20 talk about -- it's at page 237. Step 3, you have general
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21 emergency: "If the beaches are not yet cleared (fast-22 breaking situation) then evacuate the transient population 23 of Salisbury along with the transient population of the 24 Massachusetts EPZ seacoast areas." 25 That is somewhat of a mixture of protective l Heritage Reporting Corporation (202) 628-4888 i L___________--_______________________. __
REBUTTAL PANEL NO. 21 - CROSS 24009
,s 1 actions and precautionary actions. It's prot'ective action l (
k__/
) 2 for Salisbury; precautionary action for the other beaches.
3 Q As to traffic and access control the SPMC strategy 4 which relies on ununiformed nonprofessional traffic handlers 5 is hardly nearly identical to'the old state plan which 6 relies on state and local police; correct? 7 A (Callendrello) It's nearly identical in terms of 8 what control strategies are utilized at the traffic control 9 points. 10 Q In that sense. But in the strategy of personnel 11 use it's substantially different; correct? 12 A (Callendrello) It's different in that we are not 13 using state and local police to staff traffic control 14 points; that's. correct. [~~} 15 Q The Traffic management plan in the SPMC is one 16 which does not rely on the use of barricades at all; and 17 therefore, different in that respect from the old
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18 Massachusetts plans again; correct? Which do call for the 19 use of barricades? 20 A (Ca11endre11o) That's correct. 21 Q And the SPMC which takes that primary evacuation 22 traffic stream off of the Salisbury Beach and sends it out 23 through the intersection at I-95 in three different 24 directions, two of which,go on to I-95 and one of which goes 25 straight ahead, is not nearly identical to a strategy which f.~., Heritage Reporting Corporation (\ s- ) (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24010 (- 1 sends all the traffic going to I-95, is'it? l 2 A (Callendrello) The function is not identical. 3 But as I said, there is no impact on evacuation 4 time. 5 Q In your opinich? , 6 A (Callendrello) And Mr. Lieberman's opinion. 7 Q There's a statement down at the bottom of page 31 8 that says, in that first sentence of that last paragraph, 9 quote: " Mode 1 operation, use of ORO resources, expects 10 that the Commonwealth will respond in a planned manner 11 utilizing the plans procedures, personnel and equipment 12 identified in its 12-1988 responses to NRC Staff's first and 13 third set of interrogatories in conjunction with the site-14 specific response available only in the SPMC." 15 Is that the best phrasing of how a Mode 1 Partial 16 would work? Is that what we are referring to here? 17 A (Callendrello) I, quite frankly, never heard the 18 term " Mode 1 Partial" before. 19 'O Well, it's a Mode 1 but with the Commonwealth , 4 20 utilizing plans, procedures and personnel and equipment from i 1 21 the ORO in conjunction with site-specific response available j 22 onl'y in the SPMC7 23 They are using their own plans and procedures. 24 Let me start over. Try to understand that 25 section. We are in Mode 1 and I think it is saying -- Heritage Reporting Corporation (202) 628-4888 ) l l
REBUTTAL PANEL NO. 21 - CROSS 24011 1- correct me if I'm' wrong -- that the Commonwealth will use O- 2 its plans, procedures,. equipment, et cetera, identified in
-3 those interrogatory responses.
4 But if a resource for Seabrook or a response for
. 5 Seabrook is available only in the SPMC the Commonwealth, 6 state and local governments will utilir.e those resources or 7 responses available only in the SPMC.
'8 9
10 , 11 12 13 6 "5 1 16 - 17 18 19 20. 21 22 23 24 . 25 Heritage Reporting Corporation (202) 628-4888
i REBUTTAL PANEL NO. 21 - CROSS 24012 1 Q (Continues) Is that what that says? 2 A (Callendrello) Mode 1 is a mode of the SPMC. So 3 to that extent, it provides compensatory resources for any 4 deficiency thrit should arise in the Commonwealth's response. 5 - So to the extent that it's available in the SPMC, , i 6 I agree that the word "only" is unnecessary. But it's the 7 site-specific response that's available in the SPMC being
- 1 I
8 integrated with the resources that the Commonwealth has 9 identified and is utilizing in accordance with the planned , 10 actions they have identified in their interrogatory 11 responses. 12 Q Do you have something further? 1 (Callendrello) 13 A No. 14 0 Okay. So I'm still not sure I understand this. 15 If there is a site-specific response and it's 16 available only in the SPMC, the state would turn to it 17 rather than devising an ad hoc response of its own. 18 Is that what you are saying? 19 A (Callendrello) That's what Mode 1 assumes. Mode i 20 1 assumes that we've received the request for resources to 21 support and supplement the Commonwealth's existing ,' i 22 resources. " l 23 Q What if the response could be accomplished either 24 by looking to some old plans the Commonwealth had or its l 25 existing plans generically, or by reference to the SPMC? Heritage Reporting Corporation (202) 628-4888 __ _______-.__.m__________ _ ______ _ __ _ _ _
- -_ l REBUTTAL PANEL NO. 21 - CROSS 24013 7-3 1 is this saying that in that situation the ( ) .
\./ s 2 Commonwealth might follow the SPMC, but might not? It's up ;
l 3 to the state to make that election? 4 A (Callendrello) I think what's up to the state is 5 to make the choice on the use of resources that best achieve 6 the ultimate goal, and that is, protection of the health and 7 safety of the public. 8 If it means using SPMC resources, I am convinced 9 that the governor will use it. 10 Q Let me talk about a Mode 1, what I call a Mode 1 11 Full. No reference is made to the ORO four resources or 12 personnel. Maybe the ORO considers itself in a standby 13 mode.
N 14 Do you consider that such a response by the state
15 today would be adequate in view of the absence of such 16 things as sirens or the state's own lack of preparedness for 17 use of reception centers in its old plans, or any other 18 deficiency that you see the state has?
19 A (Callendrello) For some scenarios, yes. For some 20 scenarios that don't require protective actions, I think it 21 would be. 22 We're talking about a spectrum of responses. 23 Q Correct.
. 24 A (Callendrello) From least severe to most severe.
25 Q The kind of accident that would require a full Heritage Reporting Corporation j,N') (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24014 1 respo'nse, testing of all phases of emergency response 2 capability. 3 Isn't it true, Mr. Callendrello, that the state at 4 this point just could not implement an adequate full
- 5. response over the complete spectrum on its own? ,
6 A (Ca11endre11o) I think that their resources would . 7 need to be supplemented for every conceivable accident, 8 including a rapidly developing accident. 9 I think there are some accidents, as I said 10 earlier, some scenarios where their resources would be 11 ' capable of handling the response. But I think there are 12 cthers where their resources would need to be supplemented. 13 Q And they would need, in those circumstances, to 14 request assistance from the ORO.
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15 A (Callendrello) They would need to request 16 assistance, and I think that it would be likely they would 17 seek that assistance from the ORO. 18 Q It is conceivable that they could seek that 19 assistance from other sources, too, isn't it? 20 A (Callendrello) Yes. 1 21 Q Aren't there other ways, for example, that the ) 22 state could sound a public emergency warning? 23 A (Callendrello) Well, the state certainly could
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1 24 activate the emergency broadcast system, l 25 As far as fixed public alerting devices, as you l Heritage Reporting Corporation (202) 628-4888 j l 1 _ _ _ _ _ _ _ _____________________.____m
1 4 24015 REBUTTAL PANEL No. 21'.- CROSS 1 are well aware, the Commonwealth and the communities have 3 2' removed'the fixed. sirens that'were installed for.Seabrook 3 and.there are not very many fixed sirens that remain. 4 Q There are some, though, correct?
. 5 A (Callendrello) There are some. fire sirens that 6 remain. That is correct.
7' Q' And they could use-fire sirens?
. 8 A (Callendrello) That's correct. They would not
~9 have complete coverage of the EPZ, however.-
- 10. Q And they could do what rural communities do for 11 other kinds of emergencies using their police patrol cars 12 driving through the community with sirens blaring at a-13 particular tone, different tone.
14 A (Callendrello) They could. Certainly. 15 Q Are'there other organizations that you are aware 16 of, the National Guard perhaps, that might have sirens 17 mounted on trucks? 18 A- (Callendrello) I'm not aware of who else would 19 have1 sirens mounted on trucks. 20 Q What are some of the other areas in the broad 21 spectrum of emergency response that the state might feel 22 inadequate in dealing with and would need assistance from 23 some other outside source? 24 A (Callendrello) ,it would depend on the scenario, 25 the timing of the accident', the extent of the actions to be i Beritage Reporting Corporation i .. - (202) 628-4888
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REBUTTAL PANEL NO. 21 - CROSS 24016 1 taken. There is no simple answer to that. 2 Q Well, let me just take you back to reception 3 centers for a minute. I 1 4 The state could call on the Red Cross directly, 5 correct? . 6 A (Callendrello) Correct. 7 Q You indicated that they have certain emergency 8 shelters designated already for fires and floods and what 9 not, correct? 10 A (Callendrello) Correct. 11 Q The state doesn't necessarily need to go to the 12 ORO if it realizes it has needs in that area, correct? 13 A (Callendrello) If the state can establish a 14 reception center, again a reception center being more than 15 the Red Cross normally would staff, that is, providing the 16 monitoring, decontamination functions, it's conceivable the 17 state could establish a reception center on their own. 18 Q Are you aware that the Federal Emergency 19 Management Age'ncy might be developing certain resources to 20 come in and supplement the state and local governments which 21 haven't engaged in emergency planning? 22 A (Callendrello) I know that there is an executive . 23 order. I have no idea where FEMA stands in their 24 development of plans. 25 My understanding of that executive order is that Heritage Reporting Corporation (202) 628-4888
b... - I I 24017 REBUTTAL PANEL NO. 21 - CROSS L
- , x .1 there needs to be something that kicks that off, however.
I \
\- / 2. Q Wouldn't it be a request from the governor?
3 A (Callendrello) Well, you are mixing two different l' 4 concepts.
. 5 One is the Federal Radiological Emergency Response 1
6 Plan, which is a pre-planned arrangement where there are, I. 7 believe it's 10, John? 8 A (Robinson) Federal agencies. 9- A (Callendrello) Ten federal agencies that have 10 established roles in responding to radiological emergencies, 11 and can do so at the request of a number of organizations, 12 obviously including the governor. 13 What I thought you were talking about was some 14 kind of pre planned compensatory actions taken in 15 conjunction with the executive order. 16 I'm not aware of FEMA doing any of that. I know 17 that FEMA and the Department of Energy have a well 18 established capability in the Federal Radiological Emergency 19 Response Plan. 20 Q But the executive order does indicate that FEMA is 21 to develop certain response capability, correct? 22 MR. FLYNN: I object. This is legal 23 argumentation. We are essentially trying to establish what 24 the meaning of the executive order is. 25 Now in the past, the Board has routinely allowed Heritage Reporting Corporation (202) 628-4888
r ___ _ REBUTTAL PANEL NO. 21 - CROSS 24018 1 questions that go to the understanding of the Panel insofar l 2 as they actually use that understanding in their operations. 9; 3 But that predicate has not been established here. 4 JUDGE SMITH: Legal argumentation. 5 Read it back. , 6 (Accordingly, the pending question was played 7 back by the court reporter.) 8 MR. FIERCE: And I could add, "as you understand 9 it". I am not asking a legal question. 10 MR. LEMALD: Your Honor, I would like to inquire y 11 as t,o the relevancy of this aspect of the cross-examination, 12 either as to the contentions or the direct testimony. It 13 doesn't appear to reach any one of them as to what FEMA's 14 plans are. 15 MR. FIERCE: It certainly goes to the whole 16 collection of contentions that have to do with an 17 integrated, coordinated response to the extent that the 18 Commonwealth has other resources available to it from other 19 organizations that we just indicated. It may be from the 20 Red Cross directly. Obviously, then there is no need to 21 turn to the ORO, a private organization untested, in the 22 state's view, with respect to its performance and role. 23 Isn't another option out there at this point in 24 time, at least legally, some response capability pursuant to 25 an executive order from FEMA. Heritage Reporting Corporation (202) 628-4888
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. REBUTTAL PANEL NO. 21- . CROSS = 24019
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JUDGE SMITH: Let's assume that there are an ( l2 abundance of. resources readily available to the-
.3 Commonwealth.
4 What's the relevance of that?
. '5 MR. FIERCE: Then they.might well turn to a 6 federal.. agency for that assistance rather than a private, e
l 7 volunteer organization.
- 8 JUDGE SMITN: And that would be the best efforts 9 of the Commonwealth?
10 MR. FIERCE: Well, it might be. It depends on how 11 it was perceived. 12 JUDGE SMITH: So where does that take it? 13- MR. FIERCE: I_mean, we're testing whether this is
, 14 an organized, orchestrated plan meant to fit with-the 15 resources available to the Commonwealth.
16 JUDGE SMITH: Where do you go with the idea then?. 17 Assuming that you just struck gold here, and they 18 suddenly become aware that there is no problem at all. They 19 just turned to~ FEMA, and FEMA is really going to come 20 running in there.
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21 , MR. FIERCE: No, I'm not saying.they would. I'm 22 saying that's another option to them. 23~ JUDGE SMITH: Well, all right, assume --
- 24. MR. FIERCE: It adds to the unpredictability of 25 the Commonwealth's response because there are various
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. REBUTTAL PANEL NO. 21 - CROSS 24020 1 options.
2 JUDGE SMITH: That's the relevance, the 3 unpredictability? 4 MR. FIERCE: Correct. 5 JUDGE SMITH: They are going to stand around being , 6 confused as to which options they will select from among 7 many? 8 MR. FIERCE: Well, in terms of a coordinated, 9 orchestrated response, I think that poses problems, yes. 10 JUDGE SMITH: So it's just the shear availability 11 of options interferes with the coordination. 12 MR. FIERCE: Absolutely. 13 JUDGE SMITH: Let's let him make the argument. 14 It's relevant in his viewpoint. I can understand it. 15 MR. FLYNN: Well, Your Honor, the question assumes 16 that FEMA is doing certain things which Mr. Callendrello has 17 indicated he doesn't know whether FEMA is doing. And this 18 seems to me to be leading'us off in unknown directions. 19 I think if Mr. Callendrello indeed doesn't know 20 what FEMA is doing, that should be the end of that inquiry. 21 ,If we're trying to argue from the language of the executive 22 order itself, we -- 23 JUDGE SMITH: You started out objecting because it 24 was a legal -- 25 MR. FLYNN: Well, yes, that's my point. Heritage Reporting Corporation (202) 628-4888
f f v REBUTTAL PANEL NO. 21 - CROSS 24021 1 JUDGE SMITH: Do you know? b /' 2 MR..FLYNN: If the question is just -- 3 THE WITNESS: (Callendrello) I don't know. 4 JUDGE SMITH: He doesn't know. All right. 5 JBY MR. FIERCE: 6 - Q: And it's likely, Mr. Callendrello, that the state
- 7. officials also don't know to what extent FEMA might-have 8 actually taken steps pursuant to that executive order to 9 develop certain capacity?
10 JUDGE SMITH: Now you got that in because of your 11 theory that an abundance of options available to the 12 Commonwealth will interfere with a coordinated response. 13 But you are not going to go down that road very far. 14 MR. FIERCE: All right, let's drop it. 15 JUDGE' SMITH: Yes. 16 BY MR. FIERCE: 17 Q Mode 2 on the next page of your testimony, on page 18 32, it's a mode where the ORO is authorized to take certain 19 response functions and given responsibility for those, 20 either some or all.
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21 And on page 32 there is a certain -- in that first 22 sentence under Mode 2, there is a list of functions: 23 activation of public notification, recommending protective 24- actions. 25 These functions are just examples, correct? The 1 Heritage Reporting Corporation (202) 628-4888
1 REBUTTAL PANEL NO. 21 - CROSS 24022 1 Jist is really much longer? 2 A (Callendrello) That's a partial list. The full , 3 list is contained in IP 2.14, Attachment 7, and there are 4 seven activities for which legal authorization is sought 5 from the Commonwealth. . 6 MR. DIGNAN: Your Honor, may I make an inquiry 7 just for scheduling purposes. This may sound pejorative, 8 but it'isn't. 9 I notice we've covered what I understand to be 10 about nine pages more of the 30 that.were to be covered in 11 this cross-examination. And my simple inquiry is, is my 12 brother still assumed he will finish in time so that Dr. 13 Goble will get on today, because I am, frankly, waiting 14 around here to cross-examine Dr. Goble. And if he's not 15 going to make it on today, I would just as soon leave my 16 partner, Mr. Lewald, at the helm and accomplish some other 17 things that I might. 18 Could an inquiry of that nature be made, Your 19 Honor? 20 MR. FIERCE: I think that's an appropriate 21 inquiry, and I'm taking a look right now. 22 As I told a number of people before I started, I . 23 expected this was going to be in the two to three-hour 1 24 range. We've gone approximately two already. I do have at l l 25 least an hour more. It looks to me it could be an hour and Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24023
,-m 1 a half once I consider that we're probably going to take a ! l V 2 break.
3 MR. DIGNAN: I thought we would go straight 4 through.
. 5 MR. FIERCE: I'm willing to do that if you are.
6 But assuming there is a break -- 7 JUDGE SMITH: I didn't want to interfere with the 8 flow of your cross-examination. 9 MR. FIERCE: I appreciate that, Your Honor. But I 10 think it's going to be very close to the end of the day, 11 particularly if there is any redirect at all. 12 JUDGE SMITH: Where are you on your cross-13 examination plan?
/~N 14 MR. FIERCE: I'm on No. -- well, I'm talking about' i /
d" 15 Mode 2 which is in Item 5. 16 JUDGE COLE: Of 13 -- 17 MR. FIERCE: All I can tell you is that I tend to 18' look at my pages left in my notobook, and I'm clearly -- I 19 have clearly got a number of pages left here that are going 20 to take me, I would say, another hour and a half.
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21 JUDGE COLE: Sure. 22 With a break, we are approaching 5:00. And I 23 would like to be able to tell Mr. Dignan he does not need to 24 stick around, but would be hesitant to do so if for some 25 reason the Board would be displeased if I ended at a quarter ['N
\ I Heritage Reporting Corporation N' (202) 628-4888-
1 l REBUTTAL PANEL No. 21 - CROSS 24024 l 1 to five. 2 JUDGE SMITH: He's on No. 5 of a cross-examination i l 3 plan with 13 topics. 4 MR. FIERCE: There are a number of those topics 5 that are not of equal length, Your Honor. . 6' MR. DIGNAN: I guesa, Your Honor, I would like to 7 be excused with the understanding that I will, of course, 8 appear -- 9 JUDGE SMITH: Yes, I don't think there is the 10 remotest possibility that we are going to get to Dr. Goble, 11 not the slightest. 12 MR. DIGNAN: I'll take that as a finding. 13 ' JUDGE SMITH: Hope for tomorrow. Hope for 14 tomorrow. 15 (Laughter) 16 MR. DIGNAN: Your Honor, by the way, before I 17 leave, the other thing I did want to advise the Board is I 18 have been -- in the low power testing program, the advice I 19 was given this morning is that criticality again has 20 slipped. The best guess of the engineers now is Wednesday 21 night to Thursday morning is now the target. And I will 22 keep the Board advised, because I know that's a matter the 23 Board may be interested in. 24 JUDGE SMITH: Thank you. 25 Take a break until 3:30. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS L24025
'(Whereupon, a recess.was taken.)
O2 1 , 3 4-
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7 8 9 10 11
- 12 13 .
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21 22' 23 24 , 25 Heritage Reporting Corporation (202) 628-4888 i ____m_. ____m________________..___m__________. _ __. _ _ _ _ . _ .= _ _
i l REBUTTAL PANEL NO. 21 - CROSS 24026 ] 1 JUDGE SMITH: Before we resume the cross-1 2 examination. It is clear now that we will be able to have 3 this room for the third week in June. ) I 4 MR. FIERCE: Good. ] 1 5 JUDGE SMITH: And we will complete this month in . ] l 6 . Boston. We are making no effort because of the difficulty we j 1 I 7 had to extend hearing time in Boston beyond the end of June. 8 In fact, we expect the record to be closed by that time. 9 MR. FIERCE: Your Honor. 10 JUDGE SMITH: So anything after that will be in 11 Bethesda. , 12 MR. FIERCE: Maybe this is a good time to bring 13 this up. 14 I believe that having now read the supplemental 15 testimony to the Applicants' Testimony No. 17 -- is that the 16 one on monitoring and reception centers? 17 MR. LEWALD: Yes. 18 MR. FIERCE: I mean, the Mass AG can state right 19 now that we believe, even before doing the cross-20 examination, that we would have rebuttal testimony to that. l 21 That rebuttal testimony being items of information that we 22 cannot ascertain simply from cross-examination. . 23 And we would like to make the Board aware of that. 24 We're not exactly quite sure how to proceed, given the 25 Board's posture on that particular issue at this point. l Heritage Reporting Corporation (202) 628-4888 ______________._____.__u
REBUTTAL PANEL NO. 21 - CROSS 24027 1 But there is rebuttal testimony that we would like 1 2 to file that we believe would be relevant and would put in 3 issue a number of the statements made in that supplemental 4 testimony.
. 5 JUDGE SMITH: Well, your responsibility, of 6 course, is and has been to notify the parties of your need 7 for rebuttal testimony as soon as you become aware of it.
8 In this instance, since you now know that you 9 can't satisfy your requirements by cross-examination, it's 10 evident from the direct examination that you need it. 11 And it seems to me that is very late. 12 MR. FIERCE: What's very late? 13 JUDGE SMITH: When was the testimony -- 14 MR. FIERCE: It's supplemental testimony that 15 we -- 16 JUDGE SMITH: Oh, supplemental testimony. 17 MR. FIERCE: On the traffic and parking issues 18 that we just received last week. 19 JUDGE SMITH: I understand. 20 MR. FIERCE: And we're trying to make you aware at 21 the earliest. 22 JUDGE SMITH: I understand. 23 Go on with your cross-examination. 24 BY MR. FIERCE: 25 Q Panel, with respect to Mode 2, reference was made Heritage Reporting Corporation (202) 628-4888 -
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I REBUTTAL PANEL NO. 21 - CROSS 24028 j l 1 to implementing procedure 2.14. 2 Do you have that available? 3 A (Callendrello) Yes, I do. 4 Q Procedure 5.2.5 on page 5 has a subsection C which 5 says: "That if the Commonwealth of Massachusetts authorizes . 6 a response by New Hampshire Yankee offsite response 7 organization, implement Mode 2 activities, authorize 8 response, Attachment 4." 9 Do you see that? 10 A (Callendrello) Yes, I do. 11 Q When I go now to Attachment 4, page 2 of 12 Attachment 4 which is on page 13 of that section I see this: 13 I see a section there at the top on this table that says, 14 quote: " Complete appropriate column of Attachment 8, 15 emergency responsibility checklist with governor's 16 representative for each response action agreed upon between 17 state official and New Hampshire Yankee offsite response 18 organization." 19 Do you see that? , 20 A (Callendrello) Yes, I do. 21 Q And the responsible person is the ORO director and 22 the assistant director for support liaison and also the . 23 state liaison? 24 A (Callendrello) That's correct. 25 Q And below that, next to the column where it says: Heritage Reporting Corporation (202) 628-4880 l
REBUTTAL PANEL NO. 21 - CROSS 24029 f- 1 " Local EOC liaisono as responsible persons," a similar
- b. 2 statement: " Complete appropriate column of Attachment 8, 3 emergency response responsibility checklist with a local 4 municipality civil defense director / senior EOC official to.
.. 5 document level of responsibility for each response action 6 agreed upon between the local officials and New Hampshire 7 Yankee ORO."
8 Do you see that? 9 A (Callendrello) Yes, I do. 10 Q Now, I see from your testimony that you say: "No, 11 none of the local liaisons are going to be required to enter 12 this information on Attachment 8 for more than one 13 community." 14 It is clear, isn't it, Panel, here that a Mode 2 15 does contemplate a very diverse mix of entities responsible 16 for emergency response functions in the EPZ, doesn't it? 17 It permits the state, the local governments, and l 18 the ORO to handle any number of response functions. Now, I 19 understand that some of these are, obviously, only going to 20 be handled at the state level.
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21 But there is at least that possibility for a 22 variety of response functions to have any of those three 23 categories of entities responding: state, local, or ORO; 24 correct? . 25 A (Callendrello) That was a long question. Beritage Reporting Corporation (
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REBUTTAL PANEL NO. 21 - CROSS 24030 1 I assume you-just want the last part answered of - 2 that question? 3 0 Yes. 4 A (Callendrello) Yes. 5 The SPMC anticipates that one of three , 6 organizations could be providing the response: the state 7 organization; local organization; or the ORO. Although, 8 there are some functiona that reside solely with the state 9 organization such as decisions on protective action 10 recommendations. 11 Q So nhan.I look at Attachment 8 which runs from 12 pages 28 through 31, andblookatthismatrixandIseea 13 function such as on page 2, evacuation support function, 14 actually runs on to page 3, subparts A through M. 15 You could have a situation, then, Panel, where in 16 a.given town, let's say Salisbury, the state could be 17 responsible for what is listed here as evacuation 18 coordination for the general population. 19 And the local government could be responsible for 20 evacuatio,n coordination for the schools. 21 And the ORO could be responsible for evacuation 22 coordination for special facilities. 23 Is that correct? 24 A . (Callendrello) Could that happen? 25 Q Yes. l Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24031
,ew , 1 A (Callendrello) Yes, it could. %/ 2 Q And likewise pursuant to the SPMC, as this 3 document indicates, you could have a situation, say, for 4 traffic and access control which is listed down there as . 5 item K. '!
6 Do you'see that?
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7 A (Callendrello) Yes, I do. 8- Q Where the state was responsible in Salisbury, and 9 the local government police were responsible for traffic and 10 access control in Merrimac, and the ORO is handling traffic 11 and access control in Newbury; correct? 12 A (Callendrello) That could happen; yes. 13 Q I would like to explore the process briefly by (~' 14 which the ORO presents itself to the state at the time of an
'~'
15 emergency and then determines what mode to follow. 16 Is this best described in Implementing Procedure 17 2.14 as well? 18 A (Callendrello) The bulk of it is there. There 19 are'some steps, however, that are described in IP 1.1 and IP 20 1.11. 21 Q Well, as I see it here in 2.14 on page 4 it says: 22 " Notification of unusual event." These appear to be 23 procedures, I would guess, for the ORO director? 24 Is that correct? 25 A (Callendrello) Tnat's correct. /' is Beritage Reporting Corporation (202) 628-4888
i i i REBUTTAL PANEL NO. 21 - CROSS 24032 ! > 1 i' 1 Q And I see that he has in procedure 5.1.3 of an N
, 2 instruction to call the MDPH contact / duty officer. . j l
3 Do'you see that? l
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4 A (Callendrello) Yes. That's Step 5.1.3. 5 Q Right. . 6 Now, at the alert the director gets the same sort 7 of notification himself and again checke with the control l 8 room. 9 Ahd I see in procedure 5.2.3 again calls the MDPH 10 contact / duty officer. 11 Then reports to the ORO EOC, and upon arrival a l 12 calls the Massachusetts state EOC at Framingham. Provides 13 an accident assessment update and inquires who is now 14 directing the Commonwealth response. 15 Do you see that? 16 A (Callendrello) Yes, I do. 17 Q Now, in both instances, under the' unusual event 18 and under the alert, when the caller -- the director calls 19 the MDPH contact / duty officer there is a sentence which 20 reads: " Relay the emergency conditions and the capabilities l 21 of the New Hampshire Yankee ORO. Ask how the Commonwealth 22 of Massachusetts intends to respond." . 23 Do you see that? 24 A (Callendrello) Yes, I do. l 25 Q Now, is that the call then in which the mode Heritage Reporting Corporation (202) 628-4888 '
' REBUTTAL PANEL NO. 21 - CROSS 24033
- ~s 1 determination would be made by the ORO as to whether they're I
b . (_ / 2 going to be in standby Mode 1 or Mode 2, in these calls to 3 the MDPH contact / duty officer? 4 A (Callendrello) No.
. 5 Q No?
6 A (Callendrello) No. 7 Q Where does that occur? 8 A (Callendrello) Step 5.2.5. 9 Q All right. 10 Now, that is a procedure which -- you tell me, is
. 11 that a separate step or just a continuation of the procedure 12 for calling the Framingham Massachusetts state EOC?
13 A (Callendrello) That is part of --
/ '~'N 14 Q It's not a third calli that's part.of the second 15 call, correct?
16 A (Callendrello) That's correct. 17 That's part of the call to the Massachusetts state 16 emergency operation center. , 19 Q What kind of a response is it that the ORO is 20 looking for then in that first call to the MDPH contact / duty
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21 officer? 22 A (Callendrello) Maybe Mr. Robinson can best 23 describe how the Department of Public Health operates. 24 But just briefly, when the state police is 25 notified by the utility of an emergency at a nuclear power
,/ 3 i-i ' ) Heritage Reporting Corporation (202) 628-4888
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o REBUTTAL PANEL NO. 21 - CROSS 24034 1 plant the state police in ' turn makes several calls. One is 2 to civil defense so that their organization can begin the 3 activation process. 4 The other is to the Department of Public Health 5 who, for this type of emergency, is the principal technical - . 6 organization for the response. They in turn will call back 7 into the control room to assess with the control room people 8 what type of accident; the severity of the accident; the 9 prognosis for worsening; and any protective actions that 10 need to be taken, 11 At the point that the offsite response director 12 calls back it's likely that the Department of Public Health 13 call is the only one that the control room has received from 14 the Commonwealth. 15 So therefore, that is the logical person for the 16 offsite response director to talk to because as far as the 17 station is concerned that is the person who is charged with 18 protecting the public health. And that',s the contact that. 19 the station has had with the Commonwealth. 20 So the offsite response director will inquire: I 21 what's the Commonwealth doing to respond? And the 22 Department of Public Health contact can say, we're staffing . . 23 up; we're not staffing up, or if it's a situation that 24 requires immediate protective actions, we are beginning to ; i 25 implement protective actions. Heritage Reporting Corporation (202) 628-4888 l l l
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- REBUTTAL PANEL NO. 21 - CROSS 24035-1- Maybe Mr. Robinson can talk about what happens at;
'N_s/; 2: the'other sites.in'thiscregard. ..
3 Q Well, I'm concerned about the statement that is 4 .here'in,the procedures where in that phone call toLMDPH the
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.. 5 question is asked, how the Commonwealth intends.to. respond?
6 Generally, I guess, not so much specifically DPH, 7 Department of Public Health, because we have talked about 8 them. 9 But I'm asking: what is it you're looking for here 10 in response to that question?
~11 A (Callendrello) What Department of Public Health 12 is doing? -
13 Q No. L/ 14 A (Callendrello) What do they know the Commonwealth
-l 15 is doing to' respond to the notification that we-have made?
16 Q Other than what you said in response to that 17 question, how i~s the Commonwealth intending to respond? 18 other than having this response.come back, well, it appears 1 19 that they're staffing-up over at DPH, I can't tell you more 20 than that at this point. 21 What is it you expect to get from that person? 22 A (Callendrello) They may say, we're -- and it's 23 likely they would since this is what their plan asys -- 24 we're deploying somebody to the emergency operations 25 facility to go over with you the dose projections and the {. Beritage Reporting Corporation i (202) 628-4888 9
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REBUTTAL PANEL NO. 21 - CROSS 24036 l 1 recommended protective actions, if any. 2 We're activating the NIAT. team. We will have 3' field teams in your area within an hour or whatever the time 4 is that it will take those te'ams to mobilize, although an
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5 hour is about the right time frame. . 6 Again, DPH is the lead organization in the 7 Commonwealth when it comes to charting the Commonwealth's 8 course in response to a radiological emergency. So it's 9 appropriate to ask them how the Commonwealth intends to 10 respond. 11 - O So you believe, at this point, either at the 12 unusual event or at the alert, this particular contact can 13 actually speak for the Commonwealth and is knowledgeable 14 about the state of' affairs at various agencies throughout 15 the Commonwealth and their intended response? l l 16 A (Callendrello) No, that's not what I said. ' l 17 Q 'He can respond -- 18 A (Callendrello) Maybe Mr. Robinson can best 19 clarify by ta3 xing about what actually happens in the 20 Commonwealth. 1 21 A (Robinson) This situation or procedure that Mr. 1 22 Callendrello has just explained is not specific to Seabrook. . 23 It is the way that the Mass Department of Public Health is 24 outlined in the NIAT plans and the area plans, that the 25 utility will provide the information to the Department of I i Heritage Reporting Corporation l (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24037
.y 1 Health. That's through this call-back mechanism.
I l'
' _-) 2 And that was specifically requested by the state a 3 number of years ago when they found,out that, ir itially, 4 when we provided this information to the state police there
. 5 was some confusion that took place there.
6 And so the procedure was finally set up so that 7 the Department of Health would call the control room 8 directly to get the information. 9 So that's why it's a generic plan for providing 10 the information to the state. 11 Q I understand this person at MDPH may have been in 12 direct contact with the control room. But now this is the 13 ORO director calling, it's a very early stage, either at the l f~'N 14 unusual event or alert stages here, and they are asking how IN, '- 15 the Commonwealth intends to respond. } 1 16 And other than what Mr. Callendrello just said 17 about, perhaps, looking for a response that says DPH is 18 invoking its NIAT procedures or DPH is sending a 19 representative to the EOF, is there a response from the 20 Commonwealth and about the Commonwealth that is anticipated 21 here from the ORO? 22 A (Robinson) My interpretation of that is that the 23 Department of Public Health would indicate at that point 24 whether or not they were going to send representatives to 25 the EOF or how they intended to respond. A 4 Scritage Reporting Corporation N- (202) 628-4888 l l _ _ _ _ _ _ _ - _ - _ _ _ _ _ _ ~ _ _ _ _ _ _ _ - - _ _ _ _ -
O REBUTTAL PANEL NO. 21 - CROSS 24038 1 And I assume they woul'd also, in passing on the 2 technical information to civil defense, they would indicate 3 that the ORO was requesting information on how the 4 Commonwealth would respond. 5 Certainly, the Department of Health is not going . , 6 to be able to respond for any of the other agencies. But 7 they will be able to say whether or not they were going to 8 dispatch somebody to the EOF or ORO. 9 (Witnesses conferring.) 10 11 12 13 15 16 17 18 , 19 20 21 22 , 23 24 25 Heritage Reporting Corporation (202) 628-4888 ,
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REBUTTAL PANEL NO. 21 - CROSS 24039
,s 1 Q Something else?
2 A. No. 3 Q Now you have said it's really in the second phone
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4 call.that goes to the person who is directing the
. 5 'Ccommonwealth's response at the state EOC in which the ORO's 6 appropriate mode is determined, correct?
7 A (Callendrello) Correct. 8 Q Now, it says here, " Provide a briefing" -- well, 9 let me just back up a second. 10 When this phone call is made, is there any 11 expectation about this particular person having knowledge or 12 familiarity with the ORO or with the SPMC? 13 A (Callendrello) No, there is no expectation that 14, they will have -- they will be knowledgeable about the 15 specific capabilities of the SPMC or ORO. 16 I think it's reasonable to expect that members of 17 the Massachusetts Civil Defense Agency know of the. existence 18 of the ORO and the response organization for Seabrook 19 station. 20 0 Let's assume it's an alert, a fast-breaking 21 situation that has a simultaneous unusual event. It goes to 22 an alert. So this is the first call that goes from the 23 director to this person directing the Commonwealth's 24 response. 25 Can you tell me how they begin that phone O Corporation
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REBUTTAL PANEL NO. 21 - CROSS 24040 1 conversation? 2 . What do they say? 3 A (Ca11endre11o) No. I've seen it during the 54 exercise. And I, quite honestly, just can't recall the 5 exact language that's used. But the essence of what is . 6 transmitted is contained in the procedure. And that is
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7 what's -- that is the information that's transmitted. 8 Q Provide a briefing on the emergency. 9 A (Callendrello) Yes. 10 Q Describe the capabilities of the New Hampshire 11 Yankee offsite response organization. 12 A (Callendrello) Yes. 13 Q Do you know how that description would be 14 provided? : 15 A (Callendrello) No, I don't. 16 I know what was done in drills and exercises. For 17 that specific aspect, I recall it was actually done by the 18 assistant offsite response director for support liaison in 19 the June '88 exercise. 20 I believe the language he used was something like, 21 "This is Jeffrey Crafts, Assistant Offsite Response 22 Director, support liaisons for the New Hampshire Yankee . 23 response organization. We are in tr.e process of staffing 24 our emergency operation center. I wanted to give you a j l 25 phone number where you can reach me and I'll be back in i Heritage Reporting Corporation , (202) 628-4888 I I
I REBUTTAL PANEL NO. 21 - CROSS- 24041 t ?
' contact with you as' things develop."
j ~x 1 k ) That's, in a nutshell, what the conversation was. l sm/ 2'
'3' Q Well, I'm trying to get a better sense of what the-4 -actual conversation was rather than a nutshell. .- 5* Do you --
6 A (Callendrello) I don't recall the exact language.
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7 MR. FIERCE: Your Honor, may I have a moment to 8 confer with counsel? 9 (Opposing counsel confer.) 10 MR. FIERCE: Your Honor, what I would like to do 11 at this time is offer into evidence a portion of a 12 deposition that was taken of Peter Stroup. 13 JUDGC SMITH: Who? f" 14 MR. FIERCE: Peter Stroup, S-T-R-O-U-P, wh6 is the ORO red team -- or first string team director. A deposition 15
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16 that was taken back in November, November 2. 17 And in that deposition, he was asked some 18 questions about his conversation in describing the ORO 19 capabilities to the person in charge.
-l 20 And I would like to offer into evidence the 21 following questions and answers which begin on page 76. Thp 22 first question, "Can you briefly, or can you tell me what 23 you would say if you had to give a presentation of the ORO's 24 capabilities to this person?" ,
25 Answer: "It would be specific to the event (\ Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS . 24042 1 classification that we were in. If it were a bomb threat, I !b 2 would not go into the detail of describing the entire ORO if 3 the person I was in discussion with didn't feel that was 4 necessary." 5 Question: "Let's assume it's not a bomb threat, . 6 but it's an accident. An emergency at the station. It's a 7 problem with a reactor or a worsening condition. You are at 8 the alert stage. What would you say about the ORO itself i 9 and its capabilities to this person?" 10 Answer: "At that point I would say that at the 11 alert stage many of our forces have been notified and have 12 been mobilized; that we have capabilities to analyze all the 13 information provided by the utility company as regards the 14 event. We are also dispatching personnel to Commonwealth 15 Civil Defense Agency, Department of Public Health, to assist 16 them in understanding what the ORO is. And that if they 17 felt there were any acti~ons necessary that we in fact do 18 have equipment resources to support that." 19 Question: "Is there anything else you would say?" 20 Answer: "I would probably call him back as soon 31 as I reported to the EOC and advise him that as to any 22 information that I would receive at that point." . 23 Question: "And you would ask them what their 24 intended response was?" , 25 Answer: "I've already stated before." Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21; . CROSS 24043; f" ' ') 1 JUDGE SMITH: Is that your offer?' A c 2 MR. FIERCE: , That's the' offer, yes.- 3 HR..LEMALD: No objection. 4- JUDGE' SMITH: 'No objection?
. 5 MR. LEMALD: No objection to it.
6 JUDGE. SMITH: Well, then that portion that he, read
" - shall: be deemed to be a stipulation that- that was the 7
8 portion of Mr. Stroup's deposition. 9 MR. FIERCE: Can I get the panel.to-confirm that 10 Mr. Stroup is,;in fact, the red team ORO director?
-11 MR. LEMALD: We would agree to that.
12 We can stipulate that he is the ORO director. 13 BY MR. FIERCE: 14- Q Going;back to our earlier discussion. 15' It's quite likely, is it not, Panel, that when the. 16 ORO director'first responds to the ORO EOC and makes this 17 call as one of his first actions -- 10 It is one of his first actions, isn't it, Panel? 19 A (Callendrello) Yes, it is.
' :20 Q That at that point in time the ORO is not yet 21 fully operational?
22 A (Callendrello) That's correct. 23 They would be in the process of mobilizing. If we 24 are talking about at the alert level. 25 Q So if the Mass Civil Defense Agency official in
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REBUTTAL PANEL NO. 21 - CROSS 24044 1 charge asked Mr. Stroup if the organization he headed was in 2 place, the director would have to say, not at this time but 3 we're mobilizing it; correct? 4 A (Callendrello) That's ccrrect. l 5 Q Has the ORO ever had an unannounced drill or . 6 exercise in order to test the time it would take to mobilize ! ~ 7 all ORO positions sufficiently to make the organization 1 8 operational? 9 (Witness confers.) 10 THE WITNESS: (Callendrello) I don't know of any 11 independently. I was just checking with the other panel 12 members. 13 (Witness confers.) 14 THE WITNESS: (Callendrello) It seems the 15 consensus of the panel that we have had an unannounced 16 notification drill. I don't' know of any unannounced 17 mobilization drills. 18 BY MR. FIERCE: 19 Q What's an unannounced notification drill? 20 A (Callendrello) Without any previous knowledge of 21 the ORO members, notification would be made to them in the 22 manner that would be done in an emergency. And they would a 23 need to acknowledge receipt of the notification. 24 Q So they've never had an unannounced mobilization 25 drill; that is, a drill that would requira people to, upon Heritage Reporting Corporation (202) 628-4888
REBUTTAL. PANEL NO. 21 - CROSS 240451
'.E 1 receipt of notification,1 report to duty?
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N 2 'A. (Callendrello) That's right. 3r The only -- that's right. 4 Q' Do you recall what the mobilization time was E. S' during the exercise to declare the organization, at least 6 the EOC,~ operational? l (Callendrello) 7 ~A I would have to check the FEMA - 8 exercise report. 9 HR. LEMALD: Your Honor --
.10 BY MR. FIERCE:
11 .Q From the alert? 12 MR.' LEMALD: -- I question the relevancy of this 13 line to' contention'or anything that the panel has said on. 14 direct. It seems as though we're getting into an offshoot 15 area here. 16: MR. FIERCE: Your. Honor.
'17 MR. LEMALD: 'Due to the extensiveness of the 18 cross-examination it's something I submit we don't heed.
19 MR. FIERCE: Obviously,'Your Honor, the 20 availability of the ORO'at these early stages is a relevant 21 factor for the state in making any of the decisions it's
- 22 going to have to make about how to respond.
23 And the questions about how long it will take that 24 organization,to organize itself and declare itself 25 operational are going to be very relevant,-certainly, for Heritage Reporting Corporation l+O (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24046 1 that state ORO interaction. 2 JUDGE SMITH: Overruled. 3 THE WITNESS: (Callendrello) From looking at the 4 FEMA exercise report which I think is Exhibit 43 (f) , that 5 shows the alert notification of the ORO began at 9:20. . 6 The director arrived at the EOC at 10:20. 7 And there's an entry ab 11:01 that shows New 8 Hampshire Yankee ORO EOC operational, although there were 9 contacts with -- there were briefings in the EOC and, also, 10 contacts with the Commonwealth of Massachusetts prior to 11 that. 12 JUDGE SMITH: You alluded to a notification drill 13 earlier. Did that notification drill require the ORO 14 personnel to, number one, not only note the time they 15 received it, but alsc, indicate how long it would have taken 16 them to respond? 17 THE WITNESS: (Callendrello) I don't know, Your 18 Honor. 19 I'm just not certain. I would have to check to 20 see what the scope of that was. 21 BY MR. FIERCE: 22 Q So for the exercise, Panel, I gather you're saying 23 from the alert at 9:20 the first indication, at lee.at in the 24 FEMA report of the ORO being operational, was 11:01; is that 25 correct? Heritage Reporting Corporation (202) 628-4888 I _ _ _ _ ___________________ _ _ _ A
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' REBUTTAL PANEL NO. 21 - CROSS. 24047
/-'g 1 A (Callendrello) That's when it'was indicated as
\-- 2 being operational. However, there were briefings and-3 contacts with the Commonwealth of Massachusetts that
*4 occurred prior to that.
L .- 5- The first EOC briefing was 10:01. Contact with 6 Massachusetts was at,10:02. 7 Q That was the assistant director; correct? 8 A (Callendrello) There was also notification of the 9 Massachusetts governor's -- it says, Massachusetts' 10 governor, but governor's representative by ORO at 9:47. 11 That 9:47 contact was the assistant director's contact. He 12 arrived at 9:39. 13 Q Obviously, you've got people arriving at different
/ \ 14 times after initial notification.
15 A' (Callendrello) Yes. 16 Q And that happened as well during the exercise; 17 correct? 18 'A (Callendrello) That's correct. 19 Q And the ORO was declared operational then after a 20 time span of, if my memory is right, from 9:20 to 11:01 21 would be about an hour and 41 minutes; correct? j 22 A (Callendrello) That's correct. 23 Oh, no, I'm sorry. 10:43 is the entry -- this is 24 table three of the-exercise report. New Hampshire Yankee 25 ORO EOC activated. So that would have been the activation a Beritage Reporting Corporation k- (202) 628-4888
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1 REBUTTAL PANEL NO. 21 - CROSS 24048 1 point in the exercise. So it's an hour and 20 minutes. 4 2 Q' Is there a distinction between activation and 3 having operational capacity?
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4 A (Callendrello) Yes. 5 Operational here is fully staffed is the common. . 6 Q And so you had activation after an hour and 20 7 minutes and were fully staffed after an hour and 40 minutes; 8 is that correct? 9 A (Ca11endre11o) That's correct. 10 Q Now, the exercise was a situation where it was an 11 announced drill. The responders knew that this was 12 happening; correct? They didn't know the time but they knew 13 it was happening that day; correct? 14 A (Callendrello) They knew there would be the 15 exercise that day. They had no idea what the time sequence 16 was. 17 Q Okay. 18 In this discussion between the director and the 19 person in charge at Mass civil defense, is there actually 20 discussion of Mode 1 versus Mode 2 using those words? ! I 21 A (Callendrello) I don't recall there being that 22 discussion. I would have to go back and look at the log of , 23 the assistant director. l l 24 Q How is the selection actually made then? ; 25 A (Callendrello) I don't understand the question. Heritage Reporting Corporation , (202) 628-4888 i
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. REBUTTAL PANEL NO. 21 - CROSS 24049
. ;,q 1 Selection of what?
\-s 2 Q Well, you told me before'it was in this phone call 3 through which the ORO determines which mode of operation 4 it's going to be in,. at least at this point in time;
.. 5 correct?
6 A (Callendrello) Correct.
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7 Q And so something happens.in this. phone call that 8 prompts the ORO to make this decision or in s:hich this 9 decision is discussed and made; correct? 10 A (Callendrello) That's correct. 11 Q Is it a response to what the Commonwealth says it 12 will be doing when asked? 13 A (Callendrello) That's correct.
/N 14 The director wouldn't say, do you want us to h 15 implement Mode 1 or Mode 2, but rather would say, here is 16 the status of our response capability. What's the status of-1~7 your response capability? What assistance do you need?
18 We'll tell you whether we can give you that assistance 19 because we're mobilizing. Again, using the hypothetical 20 that you raised. We're mobilizing or I'll tell you as soon
, 21 as we have the capability to supplement your need.
22 It's not necessary to talk about Mode 1 or Mode 2; 23 it's the concept that is important, whether it's resources 24 that are being supplied or whether a function is being 25 delegated to the ORO along with the requisite legal y-m . { } Heritage Reporting Corporation
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REBUTTAL PANEL NO. 21 - CROSS 24050 1 authority. 2 Q Now, at this point in time no one is communicating 3 yet with the local EPZ communities from the ORO; correct? 4 A (Callendrello) No, that's not true. 5 Q At this point? . 6 A (Callendrello) The EOC contact is part of -- his 7 procedure would proceed to make initial notification to the - 8 local contact points. In addition, we would expect that the 9 Commonwealth tPrough their normal call chain would call to 10 the local communities. 11 Q I understand what tho' Commonwealth might do. 12 But I'm asking with respect to the ORO, and you 13 mentioned the EOC contact person would be making 14 notification to the local community? 15 A (Callendrello) Yes. 16 Q In what form is that notification made? 17 A (Callendrello) Basically, reading the initial 18 notification fact sheet, which is the sheet that contains 19 the information transmitted by the control room to the ORO. 20 Q The transmission of that information is pretty 21 much of ORO function; correct? 22 If you would read that sheet? . 23 A (Callendrello) Basically, yes. 24 Q The EOC contact person is not in a position, by 25 virtue of experience or training with the ORO, to know how i Heritage Reporting Corporation (202) 628-4888 -
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l REBUTTAL PANEL NO. 21 - CROSS 24051
, -~s 1 to respond to a series of questions from a local responder I )
'N._ / 2 or to provide information or advice to that local responder; 3 correct?
4 A (Callendrello) Basically, no.
. 5 The EOC contacts function is to transmit the 6 initial notification. To ensure that the communities have
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7 received the initial notification of the accident. 8 Q In fact, isn't it true that the EOC contact person 9 is a security guard from Green Mountain Security who is 10 stationed at that facility in Newington? 11 A (Callendrello) Yes, that's correct. And performs 12 the notification functions for the ORO. 13 Q At this point, prior.to a declaration of an [} 14 emergency from the governor -- and that is a possibility at. i ' 15 an alert stage, correct, you could be " prior to" an 16 emergency declaration from the governor? 17 A (Callendrello) You could be. 18 I'm not certain when the' governor would declare a 19 state of emergency. 20 Q At that point, the towns themselves are each in charge of their own emergency response needs; correct? 21 22 A (Callendrello) They're in charge of their own 23 emergency response needs, but there are some functions 24 associated with the radiological emergency response that. j 25 rests with the state and not local governments.
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1 I REBUTTAL PANEL NO. 21 - CROSS 24052 i l 1 Q But, for example, with respect to their own 2 schools, at least prior to any decle.ation of an emergency, j
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3 they have got all the power they need to c3 ose their schools ! 4 early or do with their school children what they want; 5 correct? . 6 A (Ca11endre11o) That's my understanding, yes. '
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7 Q Just like they would if there was a snow storm or 8 tornado or hurricane? 9 A (Ca11endre11o) Correct. 10 Q They, in fact, could be implementing traffic 11 control on their own at that point? 12 A (Callendrello) Again, just remind me of where we 13 are in the scenario? 14 Q Well, this is at an early stage, an alert let's 15 say? 16 A (Callendrello) I don't see why they would be 17 implementing traffic control. 18 Q You don't see why. 19 But it's, in fact, the case that local towns have 20 the authority and the power to implement traffic control 21 measures, at least prior to a state of emergency by the 22 governor on their roads and their towns; correct? . 23 Nothing to stop them? 24 A. (Callendrello) Right. . 25 There is some jurisdictional separation between Heritage Reporting Corporation (202) 628-4888
l- .j REBUTTAL PANEL NO. 21 - CROSS 24053
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1 state and local' roadways. if
\ 2 Q Right. I understand that.
I 3 On page 36 of your testimony where we were 4 discussing the role of the liaisons, ] r 5 It says, in the first sentece: "The liaison 6 functions are specifically designed to establish and 7 maintain immediate communication with state and local 8 organizations;.thereby enhancing the coordination of 9 emergency response activities and compensating for the lack 10 of Seabrook Station's specific planning and training by 11 state and local responders." 12 Again, the liaisons do not arrive immediately 13 after an alert in the local communities; correct? ( 14 A (Callendrello) That's correct. 15 They don't arrive instantaneously. They arrive -- 16 as soon as they report to the staging area and are deployed. 17 Q They are notified at the alert stage? 18 A (Callendrello) That's correct. 19 A (Robinson) The unusual event. L 20 A (Callendrello) That's right. 1 .. l 21 They're notified at the unusual event. They 22 report at the alert. 23 O They don't report to duty until an alert stage is 24 declared. 25 And there are six of these local liaisons; j-f Heritage Reporting- Corporation (202) 628-4888 1
l RE3JTTAL PANEL No. 21 - CROSS 24054
)
1 correct? 2 A (Callendrello) Six local EOC liaisons. 3 0 One for each of the local EOCs who would report, 4 and then they would head out to the local EOCs, if granted 5 permission? . 6 A (Callendrello) That's correct. 7 Q The local EOCs could well be staffing up and 8 assessing the situation before any contact is received from 9 a local liaison; correct? - 10 A (Callendrello) When you say, assessing the 11 situation, I presume you mean assessing their own town 12 status, response organization status; not formalized 13 accident assessment because that's a state function. 14 Q I agree with that. 15 A (Callendrello) Yes, they would be staffing up, 26 assessing their personnel n ic' assessing their response 17 status. 18 Q You're familiar with -- we're talking about a 19 series of old town plans no'<, correct, emergency response 20 plans for nuclear incidents? 21 A (Callendrello) There are those plans, but there j l 22 are also the Comprehensive Emergency Response Plans that , 23 have been provided as well. 24 Q And under those old plans are you aware of what 25 alert -- whether at the alert or what other ECL is it that , 4 eritage Repding @ goration (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24055
,x 1 they activate their EOCs? \_- 2 A (Callendrello) I'm trying to recall.
3 (Witness reviewing document.) 4 THE WITNESS: (Callendrello) I believe it's an
, 5 option for them at the alert level', but they would 6 definitely activate their EOCs at the site area emergency. ~
7 BY MR. FIERCE: 8 Q What set of plans are you looking at there, Mr. 9 Callendrello? 10 A (Callendrello) I'm looking at the area plan, 11 Exhibit 55 (a) . 12 Q Now, that's a plan that the local communities 13 don't have; correct? ('~'N 14 A (Callendrello) .No. Unfortunately, I don't have t )
# 15- any local community plans here with me.
16 Q But just to confirm -- 17 A (Callendrello) I'm looking at the area plan,
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18 because it talks about notifications to the communities and 19 the actions that they would be expected to take. 20 I'm looking at page 45 of Exhibit 55 (a) . 47 when
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21 they talk about activation of EOCs. 22 (Pause) 23 THE WITNESS: (Callendrello) I'm sorry, 46 of 24 389. It appears that the local EOCs -- it says: " Instruct 25 operations officer to establish communications with each o Heritage Reporting Corporation -( -- (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24056 1 local EOC as it becomes operational." 2 And then the next step is -- oh, I'm sorry, I was 3 reading the host communities. 4 Evidently, they must be staffed at the alert 5 level. . 6 BY MR. FIERCE: 7 Q Well, the plan that you're looking at is not a l 8 plan that is available to the local communities now, is it? 9 Exhibit 55 (a) ? 10 A (Callendrello) I don't recall whether they have 11 the plan or not. 12 O What is the emergency response plan that each of 13 the communities has that you're referring to? 14 A (Callendrello) I don't know what plans they have 15 other than thIe ones that have been provided to us. 16 Q And the ones that are the exhibits to your 17 testimony that have been filed here; is that correct? l'8 A (Callendrello) I think the only local plan that 19 is an exhibit to our testimony is the West Newbury 20 Comprehensive Emergency Management Plan.
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21 Q Are you aware of any other local plans besides 22 that one? . 23 A (Callendrello) Well, there were local plans 24 prepared for each of the six communities. There were RERPs 25 prepared. Heritage Reporting Corporation (202) 628-4888
a f REBUTTAL PANEL NO. 21 - CROSS 24057
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1 .Since that time, evidently, there have been
\s 2 Comprehensive Emergency Management Plans prepared for, at 3 least, some of the communities. And evidently, some of the 4 others have severe storm plans or other types of plans.
. 5 And so those would not have the types of-emergency 6 classification levels that you have been asking me about, 7 although the RERPs would.
8 Q But the RERPs are specifically the documents that 9 the towns and the state, as well, havb ceased to use for 10 planning purposes for Seabrook; correct? 11 A (Callendrello) That's what the governor's 12 affidavit has indicated, yes. 13 Q Are you sware that the towns even have those plans 14 any longer, in any place or location that would be easy for 15 them to grab them in an emergency? 16 A (Callendrello) I don't know what the status of 17 those plans are in the towns. 18 Q It would be your view that they would staff up 19- their EOCs either at the unusual event or the alert?- 4 20 A (Callendrello) No. Not at the unusual event. 21 - Either the alert or the site area emergency. 22 Q Okay. 23 Mr. Robinson, you're the state liaison to the 24 Department of Public Health? 25 A (Robinson) Yes. Corporation ( - Heritage Reporting (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24058 1 Q In the ORO first shift? 2 A (Robinson) Yes. 3 Q The red team. 4 You have been provided training? 5 A (Robinson) Yes, I have. . 6 Q For that position. 7 And during the exercice -- where did you go during 8 the exercise?, 9 A (Robinson) During thd exercise I was at the FEMA 10 control cell at the site. 11 Q At the site. At Seabrook Station? - 12 A (Robinson) Yes. 13 Q So you didn't drive to the Department of Public 14 Health? 15 A (Robinson) No, I didn't 16 Q Upon your arrival there, did you simulate what
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17 your arrival would be like at the Department of Public 18 Health? 19 A (Robinson) Yes, we did. 20 Q What dad you say upon your arrival? 21 How did you present yourself? 22 A (Robinson) Well, what I would normally do is call . 23 the Department of Health and request permission to report to 24 either the Tremont Street office or find out if they were 25 going to move their operation to the EOC at Framingham. Heritage Reporting Corporat-ion (202.) 628-4888 _ - - . - - - , - - - - _ . - - _ - - - . _ _ _ - - _ _ - - _ - x- - _ _ - - - - - - - -----,-~._____--,---_m
REBUTTAL PANEL NO. 21 - CROSS' ~24059
; f-~s 1. Land when I ' arrived at the.--_beforefI arrived:
y
\ ,2 there,.I would call the ORO,. talk.to the assistant director 3 of offsite liaison andLget a briefing as far as the status 4 of'the plant and the emergency situation.
. 5 When I arrived at Public Health I,would inform 6 them that I was the liaison from the ORO. My responsibility 7 was to coordinate all the actions between the Department of-8- Public Health and the ORO.
9 .My first: action would be to brief them on the 10 plant conditions as far as the accident classification. 11 1 Whether or not'there was a release in' progress. ;What the' 12 offsite doses were, either measured doses or projected 13 doses.
' I would indicate whether or.not any protective 14
\- 15 actions had been recommended at that time. And then I would 16 'also give them whatever information I had regarding the
- 17. plant operational conditions, the technical information that 18 they might need to factor into their decision-making process
'19 regarding whether'or not the containment -- whether the 20 containment was in tact. The condition of the core. Any
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21 information regarding the radiation measurements in the 4 22 plan, in the containment or in the effluent pathways from 23 _the plant. 24 . Whether or not the plant had been shut down. When
-25 it would be shut down. When it would reach safe shut down
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l. l REBUTTAL PANEL NO. 21 - CROSS 24060 l
.1 conditions.
2 So this is the type of information I would give 3 them initially. 4 0 Can I stop you there and ask you some questions
'S ibout the " initial" part. .
6 How is it that you have all of these facts and all 7 of this information at your command to explain when you walk 8 in the door at the Department of Public Healtb ? 9 A (Robinson) I would have called the ORO before I 10 got there. Right after I started, as the Department of 11 Public Health -- I would make a call and let them know that 12 I was responding and get whatever information I had at the 13 time. 14 Now, I might not have all this information. It 15 might not be available. But this is the type of information 16 I would be trying to obtain so that I had it for the 17 Department of Health when I got there. 18 Q So you were on your car phone? 19 A (Robinson) I would have to call from a commercial 20 phone. 21 Q You don't have a car phone? 22 A (Robinson) No , I don't. . 23 24 25 Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24061 1 -Q So upon arrival -- let me back up. f.)-,D
\m ,/ 2 Where, in fact, is the office of the Department of .
3 Public Health that you would be heading for?
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4 A (Robinson) It's on Tremont Street.
, 5 Q Downtown Boston?
6 A (Robinson) Right. 7 Q What part of Tremont Street? 8 A (Robinson) I've been there dozens of times. 9 A (Callendrello) 150 Tremont Street. 10 A (Robinson) Yes. 150 Tremont. Right across from 11 the parking garage. . 12 Q So you would pull into the parking garage? 13 A (Robinson) Or wherever there was convenient ('~'g : 14 parking. ,
.d' j 15' Q And perhaps make a phone call at that point.
16 A (Robinson) If I hadn't made it earlier. 17 Q Well, you are going to have some driving time. 18 A (Robinson) The other thing that I would do when I 19 got there, too, as soon as I got to the Department of Public 20 Health, I would establish communications with the ORO at 21 that time anyway. 22 O It sounds to me like you-have the availability to 23 pass on a whole series of pieces of information that the 24 Department of Public Health ought to be able to get directly 25 from the horse's mouth by calling the control room. j q f Heritage Reporting Corporation
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REBUTTAL PANEL NO. 21 - CROSS 24062 1 A (Robinson) That's certainly the case. 2 Q Why would they want to talk to you then? . 3 A (Robinson) I believe that it would be 4 advantageous for them to talk to me to make sure that they 5 had full information from the ORO. . 6 If they are talking to the control room, they are 7 getting the information strictly from the control room. But 8 when I establish contact with the ORO in their office, then 9* I am able to get t::em information regarding locations of 10 offsite survey teams, the offsite measurements, any other 11 types of information that they would want to formulate their 12 own decision-making. 13 Q Now it's likely that they would go to the horse's 14 mouth for the plant technical information, but would go to 15 you for information about the ORO capabilities to do the 16 measurements, the dose assessments? 17 A (Robinson) That's t'he way the procedure is set 18 up. 19 A (Callendrello) It's not necessary, also, that 20 they would go to the control room. 21 At some point the emphasis of the onsite 22 organization shifts the offsite contact from the control . 23 room to the emergency operations facility. And it's 24 intended that the emergency operations facility, which is an 25 onsite organization facility, has the responsibility for Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24063 J-~x 1 dealing with the rest of the outside world, with the states
!s_- 2 that are involved in the response with the federal 3 government.
4 That's one of the reasons why Department of Public
. 5 Health sends a representative tc the EOF, at least for the 6 other sites and has indicated they would do so for Seabrook.
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7 So that they would be getting technical 8 information directly from the EOF. As Mr. Robinson 9 correctly states, he is there to supplement that information 10 as regards technical information, but also to provide that 11 information that exists within the control of the ORO field 12 monitoring teams, dose projections, protective action 13 recommendations, those kind of things.
/ 'N 14 Q Okay. But the point is he's not there to short 'N 15 circuit the communications that would occur with the onsite 16 organization, whether to the control room or to the EOF.
17 He's there to supplement and it would likely -- 18 A (Robinson) To facilitate the whole process. 19 Q And they would likely continue to make contact 20 with that onsite organization, correct? 21 A (Callendrello) I'm sure they would. 22 Again, as their plans say, the NIAT plans says, 23 they would dispatch a representative to the EOF. I 24 Q Now with respect to the supplemental information 25 you can provide, how would you explain the methodology used O
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REBUTTAL PANEL NO. 21 - CROSS 24064 1 by the ORO to project offsite radiological consequences? 2 A (Robinson) Well, I would have with me the full 3 set of the plans, and the maps of the area, charts of the 4 area and organizational chart. And after I had provided the 5' init.ial information to them, I would give them a briefing as . 6 far as the organization itself, the fact that it's made up. 7 of five key areas of response: the radiological response, 8 the offsite coordination, the implementation of -- the same ) 9 functions that the civil defense people would provide, the 10 alert notification, and the public information. 12 Then I would go back and focus on the area that 12 would be of interest to the Department of Public Health, 13 which would be the radiological response area, and indicate 14 that there were approximately 145 people assigned to that 15 function, and it was split up between the offsite dose 16 assessment, offsite field measurements. 17 The other function that would be of interest to 18 them was the dosimetry. That would be provided, dosimetry
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19 and recordkeeping would be provided to the local communities 20 and any state emergency responder. . 21 And the other main function would be the 22 monitoring and decontamination. 23 I would have with me, as I mentioned, a full set 24 of the procedures, as far as all the dose acsessment 25 procedures, the field monitoring procedures. If they had Heritage Reporting Corporation (202) 628-4888 l L
REBUTTAL PANEL NO. 21 - CROSS 24065 g 1- any questions regarding how that would be handled, I would i \
. 2- have them there. .
3 I would also point out to them that the entire 4- dose assessment proce'ss and decisionmaking is essentially
.. 5 the same as the state has adopted in the NIAT procedures and 6 the state radiological response procedures.
7 So there would be -- I don't believe there would 8 be any question in their mind as to how the radiological 9 response would occur. 10 Q Well, I think the specific question I asked you 11 was how you would describe it to them. 12 You are talking to technical people who understand 13 this stuff now. Mr. Robinson, tell us how the ORO goes 14 about projecting offsite radiological consequences. What's [ . V 15 the methodology they use? 16 A (Robinson) Okay, the ORO is equipped tith offsite 17 simpling equipment. The procedures and equipment are 18 essentially the same as that are used by the NIAT teams. 19 It's the same instrumentation, the same procedures. The 20 people would be dispatched to a downwind area. It would 21 depend, using the meteorological information from the plant. 22 The dose assessment coordinator would assign personnel to 23 monitoring teams to areas where you could expect to take 24 measurements of the plume center line. 25 And they would get out there. They would take the rs g Heritage Reporting Corporation
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i REBUTTAL PANEL NO. 21 - CROSS 24066 l l 1 measurements, both the gamma measurements and the air 2 samples; pass that information back to the dose assessment 1 l 3 coordinators, who would calculate the dose from that; and ! 4 then pass it on'to the rad health advisor who, using that 5 information as'far as the offsite dose information, the , 6 projected exposure periods based on that dose information. 7 And then taking the technical information that is 8 available to the rad health advisor, he would be making a 9 protective action recommendation based on the projected dose 10 to people in certain downwind areas. And that protective . 11 action recommendation would be based on the EPA protective 12 action guidance. - 13 Q During the exercise, did you have to do this? 14 (Witnesses confer.) 15 A (Robinson) I got sidetracked on the offsite dose 16 projections. 17 We would also be using, or the dose assessment 18 people would also have available the METPAC plume 19 projections from the onsite response organization. That 20 would be used also to factor into the process of projected 21 downwind doses. 22 I'm afraid I interrupted your question. 23 Q Well, I'm asking, did you have to do this during i 24 the exercise, explain this kind of thing? 25 A (Robinson) Yes, we did. Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24067 3v d 1 The control cell personnel would ask -- may ask ~ ' - -') d 2 many. questions during the day. They were looking for the -- 3 trying:to identify how the information flowed from the ORO. 4 They would ask specific questions about what was happening
. 5 at the' plant, what were the dose projections here or there.
6 The whole day was spent in very, you know, many,,many 7 questions. 8 Q Did you talk about METPAC?- 9 A (Robinson) We had the information from HETPAC. 10 They didn't, I don't -- 11 Q What's the information? 12 A (Robinson) Well, we had the METPAC plume
- 13. ' projections.
14 Q You'had the printouts? A (Robinson)' Yes. 15 16 Q Did you ever have to explain how HETPAC works? 17 JUDGE SMITH: Are you making this up as you go 18 along here? 19 MR. FIERCE: No , I've got it all the way down 20 here, Your Honor. I'll show you. 21 JUDGE SMITH: Where are you now? 22 You are still on No. 6 -- 23- MR. FIERCE: We're on liaison functions. 24- JUDGE SMITH: -- out of 13? . 25 MR. FIERCE: No, I'm on 7, liaison functions. t Heritage Reporting Corporation (202) 628-4888 1
1 REBUTTAL PANEL NO. 21 - CROSS 24060 ] 1 , JUDGE SMITH: You've completed 6. ; 2 MR. FIERCE: Yes. 3 JUDGE SMITH: So you are roughly half way through 4 with your cross-examination. j 5 MR. FIERCE: Nc, I'm roughly four-fiftha through . 6 my cross-examination, or more, based on thq number of pages 7 I have left. 8 JUDGE McCOLLOM: See what time it is.. 9 MR. FIERCE: 7 understand. 10 JUDGE SMITH: Has Mr. Fierce assisted you in your 11 mastery of the ORO responsibilities in his cross-12 examination? 13 THE WITNESS: (Robinson) I think so. 14 JUDGE SMITH: He's helping the capacity of ORO to 15 respond? 16 THE WITNESS: (Callendrello) I'm not sure if I 17 agree with Mr. Robinson. 18 (Laughter) 19 JUDGE SMITH: It seems to me he's reading you 20 through a review of ORO's responsibilities which would 21 follow, would in some way improve your capability of 22 renponding. . 23 All right, never mind. 24 BY MR. FIERCE: 25 Q Well, Mr. Robinson, do you know how METPAC works? Heritage Reporting Corporation (202) 628-4888 .
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REBUTTAL PANEL NO. 21 - CROSS 24069
.s 1 A (Robinson) Well, I think we have other experts on
\
N_,2 . 2 other panels that are going to be testifying to that. 3 Q If you were asked by state Department of Public
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4 Health officials how HETPAC works, you would have to refer
, 5 them somewhere else, wouldn't you?
6 A (Robinson) If it was the State of Massachusetts, 7 they have the general knowledge of METPAC. We use it at the 6 other plants. It's used at Yankee and Vermont Yankee. So 9 they normally are aware of the functions of METPAC and how 10 to use it. 11 Q Isn't there a site-specific Seabrook package 12 that's attached to METPAC at the EOF? 13 A (Robinson) Yes, there is.
/~^ 14 Q If they ask you what the default exposure periods d'- ') for METPAC for Seabrook were, what would -yea tell them?
15 16 A (Robinson) Two, four, six and eight hours. 17 Q Which periods are you referring them to on the 18 METPAC printouts when they go to look at them? 19 A (Robinson) Well, the METPAC prints out all the 20 default periods. It automatically calculates the default 21 periods for two, four, six and eight hcurs, and then the 22 dose assessment personnel would look at that to see, 23 depending on how long the release was expected to last, and 24 pick the appropriate default period. 25 Q At the bottom of the METPAC printout, there is a l js Heritage Reporting Corporation
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REBUTTAL PANEL NO. 21 - CROSS 24070 1 PAR recommendation, correct? >: 2 A (Robinson) I believe, yes. 3 Q And what default exposure period is that based on? 4 A (Robinson) I guess I can't answer that. 5 Q Are you familiar with the ETEs in the SPMC? , 6 A (Robinson) Yes. It's in the section -- is it . Section 2., in the ETEs and the dose assessment procedure? 7 8 Q Yes. 9 A (Robinson) Yes, I am. 10 Q You are familiar with that chart? 11 A (Robinson) Yes. 12 - Q Are you familiar with how they were derived, or by 13 whom, and when? 14 A (Robinson) No. But I understand that they are in 15 the process of being modified. 16 Q Now, are there ETEs as well in the NIAT handbook 17 for Seabrook? 18 A (Robinson) I don't believe so. 19 Q Are there other ETEs that the Department of Public 20 Health has available to it through its own plans and 21 procedures?
- 22 A (Robinson) For Seabrook?
23 Q Yes. 24 (Witnesses review document.) 25 A (Robinson) On Applicants' Exhibit 55, the . Heritage Reporting Corporation (202) 628-4888
l l REBUTTAL PANEL NO. 21 - CROSS 24071 S 1 radiological response plan, on page 190 they have the -- , i N- / 2 Q Evacuation clear time estimates. 3 A (Robinson) I'm corry? 4 Q They have evacuation clear time estimates there
. 5 for Seabrook, correct?
6 A (Rob $nson) Yes. 7 A (Callendrello) Yes, that's what those are. 8 Q If you were asked to explain the difference 9 between these ETEs and the ETEs in the SPMC, what would you 10 say other than that the numbers are different? 11 A (Robinson) I can't answer that question. 12 Q What would you say if you were asked, "Tell me, 13 what does the ORO know about the size of the beach f'~} 14 population as it exists right now at Salisbury Beach."
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15 Could you do that for them? 16 A (Robinson) I'm sure it could be done. I don't 17 know if they would have that information available at the 18 time. But certainly that info r~mation could be obtained. 19 Q You would tell them you would obtain the 20 information and get back to them en that? , 21 A (Robinson) Yes. l 22 Q How would you get that information? 23 A (Robinson) That would go back. It would be a 24 request back through the assistant director for offsite , 25 response to provide information on the beach population. i., ) Heritage Reporting Corporation N/ (202) 628-4888
l l REBUTTAL PANEL NO. 21 - CROSS 24072 l' 2 3 O A And how would he obtain that information? (Robinson) I would imagine he would coordinate with the local -- request information thrcugh the local 9l ( I
)
I 4 liaisons, talking to the police or the local officials in 5 those communities in the EOC. . ; 1 6 Q ,If you vere asked what size beach population a 7 particular ETE was based on, would you know? 8 A (Robinson) No, I'm afraid I'm not an expert in 9 ETEs. I think there are other people here that will be able 10 to answer specific questions on that. But I have not 11 personally spent any time going heavily into ETEs or the , 12 basis for them. 13 0 If the state says, gee, Robinson, what are the 14 other towns that are in the ERPA with Newburyport, can you 15 answer that without looking at the plans? 16 A (Robinson) That would be the other four towns: 17 Newbury and Salisbury, or Amesbury and Salisbury in ERPA B, 18 and the other four towns in the ERPA E. 19 Q And when the state says, why can't we evacuate 20 Newburyport and shelter in Merrimac, what do you say? 21 MR. LEWALD: I'm going to object to this line of 22 questioning. . 23 JUDGE SMITH: On what basis? 24 MR. LEWALD: This is not in the direct testimony 25 anywhere and it's really not in the contentions, the Heritage Reporting Corporation (202) 628-4888
1 REBUTTAL PANEL NO. 21 - CROSS 24073 1 question as to what Mr. Fierce thinks that the Department of 2 Public Health might be asking Mr. Robinson. 3 JUDGE SMITH: Where did you get that hypothetical? 4 MR. FIERCE: The hypothetical? 5 JUDGE SMITH: Yes, it was a hypothetical. What if 6 the state says, why can't we shelter one town and evacuate 7 another. 8 Where did you get that? 9 MR. FIERCE: Because the SPMC, using the ERPA 10 designations that it has, would preclude that. And they 11 might just ask, why can't we. 12 JUDGE SMITH: Sustained. 13 15 - 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporat . (202) 628-4888
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l REBUTTAL PANEL NO. 21 - CROSS 24074 1 BY MR. FIERCE: 2 O Is there a section of the plans that would explain 3 to the state why the ERPA lines were drawn the way they 4 were, Mr. Robinson? 5 A (Robinson) I think one of the reasons is that the , J 6 state has, not only at Seabrook but at the other facilities,
, J 7 asked for the ERPAs to be based by community so that it's a -
8 well defined' area. And ERPA B is within five miles of the 9 plant, up to five miles. And then the others are five to 10 10. 11 And the decisionmaking process is usually based on 12 taking protective actions out to five miles. For example, 13 evacuate to five miles and shelter downwind out to 10 miles. 14 So that's basically why they are split up in those two 15 ERPAs. 16 It's consistent with the' type of protective action 17 recommendations that are normally made. 18 MR. FIERCE: I'm going to try to jump ahead here, 19 Your Honor, some pages, if I can. 20 BY MR. FIERCE: 21 Q Directing your attention, Panel, at page 41 which 22 deals with routine governmental functions. 23 As I understand the Panel's testimony, both in 24 vriting and orally as we have discussed it, the Panel 25 expects that the traffic control points located on local Heritage Reporting Corporation l (202) 628-4888 l L-------_-.-_----_---
. REBUTTAL PANEL NO.'21'- CROSS 24075:
j-4 -1 roads will be staffed by the local police.
' \_ / 2' 'Is that correct?
3 A. (Callendrello) No. 4 Q. What is the expectation with respect to'-- r < 5 A- (Callendrello) Middle of page:41 talks about the 6 routine governmental functions that are' expected. It'says, 7 "On a local level, the SPMC expects the routine' governmental
. 8 functions of law enforcement, fire and rescue, snow' plowing,.
9 .public health and emergency medical services to continue 10 during a radiological emergency response. Traffic control 11' would be provided, or could be proyided solely by the ORO. 12 We do not rely on the local communities to provide traffic 13 control" 14 Q In'a Mode l' response, who would provide the 15 traffic control in the local communities on the local roads? 16 A (Callendrello) Either state, local or ORO 17 personnel. 18 Q And the old state plans, the traffic management 19 plans in Exhibit 55 (a), did I misunderstand you the other 20 days? I thought you indicated to me that the. local police, 21 in their old plans, have a responsibility to cover the local 22 traffic control points. 23 A (Callendrello) Yes, that's what the state police
-24 procedure says. ,
25 Q So in a response where the state and local Heritage Reporting Corporation (202) 628-4888
l REBUTTAL PANEL NO. 21 - CROSS 24076 1 governments wanted to handle traffic control, some state 2 police -- strike that -- some local police would be out 3 engaging in a traffic control or access control function, 4 correct? 5 A (Callendrello) For that situation, yes. . 6 Earlier you asked me about Mode 1. And Mode 1 is 7 the ORO supplying resources to implement the plan. 8 Q All right, let's talk about a standby mode. Maybe 9 that would have been more appropriate. ( 10 A (Callendrello) Okay. I 1 11 Q If the state and local governments are handling a l 12 response, the local governments are out handling traffic 13 control points identified in somebody's plan? 14 A (Callendrello) Correct. i 15 Q Has there been any assessment of the personnel 16 neede of these communities to engage in these routine 17 functions you have listed here as well as the traffic 18 control assignments they would have under these plans for 19 staffing traffic control points in their communities? ; 20 A (Ca11endre.llo) None beyond the staffing 21 requirements that were developed as part of the 1986 local j 22 plans. 1 23 Q The Applicants haven't engaged in any personnel 24 resources assessment of the type they did in the New 25 Hampshire litigation for the New Hampshire communities, Heritage Reporting Corporation (202) 628-4888 l
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l REBUTTAL PANEL NO. 21 - CROSS 24077 , k lL correct?' J f) (_f .2 A (Callendrello) Correct.
-f 3 Q Isn't it true that if the local communities, such 3 1
4 as Salisbury, were to engage in any amount of traffic f
. 5- control or access control in some other communities, they 1
6 would seriously jeopardize their ability to carry out i
+' 7 routine local law enforcement functions?
8 A (Callendrello) I don't think they-would do it if' 9 they seriously jeopardized their law enforcement functions. 10 That's why last week we talked about the mechanism that 11' exists for locals to request resources to supplement theirs 12 so that there is no function that goes uncompleted. 13 (Pause . )
/~ 14 Q Jumping further head to page 43 of your testimony. \- 15 At the bottom of the page, "The Commonwealth has 16 identi'fied a resource pool of 1320 state police personnel 17 who would be available to supplement local resources for 18 security functions."
19 Where is that from? 20 A (Callendrello) The number 1320 comes from the 21 interrogatory responses. 22 The concept that the state police would provide 23 security, and I don't think it's such a unique one, but it 24 comes from Exhibit 75, page 44 which says, "The most readily 25 available assistance to communities from state agencies
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REBUTTAL PANEL NO. 21 - CROSS 24078 1 prior to a major disaster declaration is described below. 2 State police and HDC, one of the functions", well, I'll read l 3 the functions. " Radio communications at the scene, control 4 of traffic, security." There are also others that are 5 indicated. , 6 , Q I'm just wondering if this number 1320 came from 7 one of the interrogatory answers. B A (Callendrello) Yes, it did, and I'm trying to 9 find the interrogatory. 10 It comes from Massachusetts Attorney General's 11 Second Supplemental Response to NRC Staff's First Set of 12 Interrogatories and First Request for Documents. Response 13 5 (a) under " State Police" says, "The numbar of. uniformed 14 state police is 1320." 15 MR. FIERCE: Your Honor, at this time I would like 16 to read into the record the rest of that response which is 17 not yet in the record, I believe. 18 JUDGE SMITH: Before you do that, were you aware 19 of the answer that Mr. Callendrello just provided? 20 MR. FIERCE: Was I aware of the answer? 21 JUDGE SMITH: Yes. 22 MR. FIERCE: Well, I was aware that it was in this 23 interrogatory, but it might have been somewhere else. And 24 he says it is from this interrogatory. 25 .JNDGE SMITH: You were wondering if there is an i Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24079
-~ 1 . alternate source for that information?
7 s _,) 2 MR. FIERCM: Yes. And if that's the source, I 3 would like to read the rest of the interrogatory answer. 4 Well, I think I'll start at the beginning. This
, 5 is a response labeled No. 5 (a) , State Police.
6 "The number of uniformed state police is 1320. Of 7 that number, 923 are assigned to field operations. The 8 remaining are assigned to the' Bureau of Investigative 9 Services and Support Services (i.e., photo bureau, training, 10 et cetera) . The geographic breakdown of personnel assigned 11 .to field operations is as follows: Troop A, headquarters 12 location Framingham. Personnel, 225. Geographical area, 13 Eastern Massachusetts including North Shore. Troop B, fN 14 headquarters location North Hampton, Massachusetts.
\ '- ) 15 Personnel, 163. Geographical area, Western Massachusetts."
16 JUDGE SMITH: Are you going to go through the 17 whole appointment of the Massachusetts State Police? 18 MR. FIERCE: There is only four more, Your Honor. 19 JUDGE SMITH: All right. 20 MR. FIERCE: Troop C, Holden, Mass. Personnel, 21 174. Central Massachusetts, geographic area. Troop D, 22 Middleboro. Personnel, 174. Geographic erea, Southeastern 23 Massachusetts, including Martha's Vineyard and Nantucket. E 24 Troop, Mass Turnpike at Weston. One hundred and five 25 personnel. Geographic area, Massachusetts Turnpike. 7-~~ i ( Heritage Reporting Corporation
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REBUTTAL PANEL NO. 21 - CROSS 24080 1 JUDGE SMITH: There are only four more troops. 2 MR. FIERCE: Four more troops. Now there is only Gj l J 3 one more troop. l 4 JUDGb SMITH: Go ahead. 5 MR. FIERCE: The last one, Turnpike, including the. ..) 6 Sumner and Callahan Tunnel. 7 Finally, F Troop, Logan International Airport. 8 Eight-two personnel. Mass Port Authority properties, . W 9 including Logan Intern'ational Airport. 10 But then contains the following sentences. "It 11 should be noted that the number of personnel listed above 12 for each troop represents the total of all shifts. For I 13 example, 225 personnel comprise Troop A. Yet, only 14 approximately 45 personnel would be on duty on a given 15 shift. That 45 to 225 ratio applies to other troops as 16 well." 17 MR. LEWALD: May I inquire who the author of that 18 document is? , 19 MR. FIERCE: It is the Mass Attorney General's 20 Second Supplement Response to NRC Staff's First Set of 21 Interrogatories. 22 MR. LEWALD: Is this something you wrote, Mr. . 23 Fierce? 24 MR. FIERCE: From the state police. 25 MR. LEWALD: It's something you wrote? Heritage Reporting Corporation (202) 628-4888 i
& '1 REBUTTAL PANEL NO. 21 - CROSS 24081
.ps
!1 MS '. TALBOT: The state police proffered'the 1
( 2' information, Mr. Lewald.
.3 MR. FIERCE:. They provided this~information. ;
4- MR.fLEWALD: And you just took they informatio'n-
.. 5 .they provided and -- . 6 N$. TALBOT: Am I being cross-examined now?.
7 MR. LEMALD: -- inserted-it verbatim into thip 8 answer? 9 MS. TALBOT: Am I being cross-examined? 10L MR. FIERCE: Well, this is the answer provided by 11 the state police. 12 JUDGE SMITH: Who signed the interrogatory? 13- MR. FIERCE: Pamela Talbot. 14 .MS. TALBOT: .Your Honor, I thought we had been
' Q 15; through this' discovery business ad nauseam. I mean, I'll be 16 glad to recap the process.
17 MR.' FIERCE: I don't.think there is any doubt that
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18 it was prepared with the agency and our attorneys together. 19 MS. TALBOT: Our only concern is -- 20 JUDGE SMITH: All right. What's your concern, Mr.
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21 Lewald? 22- MR. 'LEMALD: I was just wanting the source of it 23 as to the self-serving additions to the statistical,. 24 factual response. . 25 MR. FIERCE: It is part of the answer that's
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REBUTTAL PANEL NO.'21 - CROSS 24082 )
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1 provided here, Your Honor. I'm almost done. I have one 2 more sentence to read which is only that, " Personnel 3 assigned to the Bureau of Investigative Services and Support 4 Services'could be activated to augment field operations in 5 the event of a large-scale emergency." , i 6 That's the end of the answer. 7 JUDGE SMITH: All right, that's fine. And I 8 understand the relevance. But what I don't understand is 9 why, when you are sitting there with that information, why 10 did you put this Panel and everybody in this room through 11 that painfully, slow, tortuous process of getting them to 12 identify where they got that information? 13 It's just like you have no regard whatever for the 14 other people in this room. I mean, you don't care how long 15 it takes. 16 MR. FIERCE: Your Honor, I apologize for that one. 17 I should have had copies of that dacument available to just 18 hand out, and I'didn't. 19 JUDGE SMITH: I think you owe some apology to the 20 other people in this room when you underestimated by a 21 factor of perhaps four or three the amount of time that you 22 spent on your cross-examination, when you have had fully . 23 responsive answers from this panel, and you have had 24 virtually no objections. . 25 MR. FIERCE: I'll take responsibility, Your Honor. Heritage Reporting Corporation (202) 628-4888
L L. REBUTTAL PANEL NO. 21 - CROSS 24083
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1 l s 1 I mean, I do have to note-that there were -- ',[ )
* \_ / 2 JUDGE SMITH: It's a gyestion'of professional 3 courtesy to your colleagues in the litigation.
4 MR. FIERCE: As you know, I got approximately 50
, 5 minutes of cross-examination on Friday because of the 6 argument on the motion.
~*
7 JUDGE SMITH: All right. So you are not to 8 apologize. Move along. 9 MR. FIERCE: No, I am apologizing for this one. I 10 should have had that document, and I didn't. 11 JUDGE SMITH: But I don't believe that you have 12 treated your colleagues with professional respect. You have 13 grossly without cause overstated the cross-examination that 14 you'have had, that you were going to undertake. 15 MR. FIERCE: I think I grossly understated it, 16- Your Honor. . 17 JUDGE' SMITH: Mr. Fierce. 18 MR. FIERCE: , I anticipated it.would be shorter. 19 And you are saying that I should have told people that it 20 was going to be longer than it turned out.
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21 JUDGE SMITH: You understated it. You are 22 correct. Thank you for that. 23 And I don't know why. Why did you? 24 MR. FIERCE: Pardon? 25 JUDGE SMITH: Why did you do that? ( Heritage Reporting Corporation (202) 628-4888
O REBUTTAL PANEL NO. 21 - CROSS 24084 1 MR. FIERCE: I made only the fairest estimate that 2 I -- 3 JUDGE SMITH: You gave us a cross-examination plan 4 which on the face of it would have taken at least the time 5 that you estimated, but that wasn't really your cross- . 6 examination plan. Your cross-examination plan was a very, 7 very, very large set of notes. 8 MR. FIERCE: Well, I gave you an outline, I admit. 9 JUDGE SMITH: Other lawyers in this proceeding 10 have given you the courtesy of much more accurate cross-11 examination estimates. 12 BY MR. FIERCE: 13 Q Panel, could I jump to page 50? 14 In this section of your testimony talking about 15 mutual aid agreements, the Panel has reviewed these mutual 16 aid agreements; is that your testimony? i 17 A (Callendrello) No. The testimony is that these 18 communities rely,on mutual aid agreements as part of other 19 emergency plans. It's part of their normal course of 20 business in responding to public safety events, fires. 21 Q Those mutur" aid agreements don't say anything 22 specifically about nuclear incidents, do they? , l 23 A (Callendrello) I'm not aware of the language of 24 the mutual aid agreements. 25 Q Many of the communities in the EPZ in the past l Heritage Reporting Corporation (202) 628-4888 I
REBUTTAL PANEL NO. 21 - CROSS 24085 I have looked to other. EPZ communities for niutual aid,
- 2. correct?
3 A (caliendrello) There are mutual aid agreements 4 that involve communities within the EPZ. But in addition,
. 5 and we say that on page 49,' there are other communities that ,
6 are part of that same mutual aid agreement. And those
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7 communities are outside of the EPZ. 8 9 10 11 12 13 14 - b 15 16 17
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REBUTTAL PANEL NO. 21 - CROSS 24086 1 Q It's not anticipated by the panel, is it, that 2 during a Seabrook emergency any of the EPZ communities would 3 likely be providing mutual aid to any other EPZ communities? 4 A (Callendrello) It's possible, if you had a 5 partial protective action, for example, involving only , 6 ERPA B. 7 Is it likely? 8 Again, what we're relying on mutual aid for is to 9 supplement those normal public safety functions that those 10 communities would provide: fire; rescue; law enforcement 11 activities. To that extent, if'there's a fire in Amesbury 12 and West Newbury has got not incidence and they can supply 13 mutual aid fire support; sure, I think they will supply it. 14 If it means a potential loss of life. 15 Q But as far as you know there have been no drills, 16 exercises, or training with respect to those mutual aid 17 agreements and a Seabrook emergency; correct? 18 A (Callendrello) No, but that's not what we're 19 relying on mutual aid for or expecting the communities to 20 rely on mutual aid for. 21 We're expecting them to rely on mutual aid in 22 their traditional role. And that is, supplementing the . 23 public safety resources of other communities within the 24 mutual aid district. 25 And so to that extent, they have exercised mutual Heritage Reporting Corporation f (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24087 < 1 aid and use it on a normal basis.
/f-~(T
/
\~ / 2 Q Jump ahead to page 59, if you would, Fanel.
3 In the middle of the page it says: "Should a Mode 4 1 response be implemented command and control of the support
. 5 organizations remain with ORO management, and there's no 6 need to discuss a mix of authorization. Allocation and 7 requests for resources are relayed from state or local 8 officials to the ORO -state and local EOC liaisons support 9 resources under contact to the ORO will be mobilized in 10 accordance with the SPMC."
11 A (Callendrello) That's contract. 12 Q Excuse me. " Contract, under contract to the ORO 13 will be mobilized in accordance with the SPMC." [~'N 14 I'm still a little unclear on this distinction you
\ -
15 have here and on the next page as well between operational 16 control and direction of emergency forces. 17 Let me give you an example and'see if you can sort 18 this out for me. 19 Let's assume we've got a Mode 1 response where 20 this ORO is offering some assistance, and they're providing,
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21 say, buses to Newburyport. 22 And upon their arrival in Newburyport state police 23 meet the convoy and attempt to divert it to Salisbury, which 24 for some reason they, perhaps, are concerned it's closer to 25 the plant and they want to do Salisbury first. A Heritage Reporting Corporation ( ) (202) 628-4888 l 1 - _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ -
4 REBUTTAL PANEL NO. 21 - CROSS 24088 . 1 If the state police do stop that convoy and seek 2 to direct 10 buses to Salisbury, what will those drivers and 3 route guides do? 4 A (Callendrello) Well, the hypothetical -- I need 5 to add some things to the hypothetical. . 6 I'm going to assume that the route guides have 7 been told to report to a specific location and that there
'8 they will be met by somebody, whoever the state has 9 determined will apply those resources or who will exert 10 operational control over those resources.
11 If they are diverted, I would expect them to call 12 into the staging area and say, we have been diverted, are 13 you aware of this. And I would expect the staging area to 14 either say, yes, we are or, no, we aren't. Let me talk to' 15 the person in charge there. 16 But in the Mode 1 response ORO is providing 17 resources. We are directing those resources to report to a 18 location. Report to the command structure that the 19 Comrconwealth will be implementing, where that command 20 structure will exert operational control over those I l 21 resources to perform whatever function they need them to . 22 perform. . 23 Q So you're saying they would allow themselves to be 24 diverted, those buses, drivers, and guides? , 25 A (Ca11endre11o) No. L Heritage Reporting Corporation (202) 628-4888 u __ ____ _ _ _ _ _ _ _.________________________ _ _ ___ _ _
REBUTTAL PANEL NO. 21 - CROSS 24089 f- 1 .I think whatLI said was, they would attempt to l
\s
_s' 2 sort the situation out because they left'with one set of 3 instructions and are now getting another set. 4 But I would expect that would happen quickly and
;_ 5 they would continue on with whatever is the appropriate --
6 to whatever the appropriate function is. . 7 0 I guess we have to go sort it out. 8 They call back to the ORO. Would they wait for an 9 instruction for the ORO before being diverted to Salisbury. 10 or would they take the direction from the state police and' 11 say, well,.they have directed us to Salisbury, we're just 12 letting you know that? 13 A (Callendrello) I don't know which way it would
/' N 14 go.
\ '15 I would think that it would be the former. That 16 is, they would call back to the staging area and say, gee, 17 we know when we left we were supposed to go here. This 18 state police trooper is telling'us that the new information 19 is that we're to be directed here; is that right?
20 I imagine it would be done very quickly. I can't
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21 imagine it taking a long time where they would sit and the 22 response would die. 23 Q All right.
. 24 What if they were actually - your ORO responders 25 were directed to engage in a function that was sort of m
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REBUTTAL PANEL No. 21 - CROSS 24090 1 outside their realm. 2 For example, traffic guides were directed by some 3 local police to go do something else because the local 4 police were going to take over the traffic control. And the 5 local police suggested they go assist with an evacuation of . 6 a town hospital. 7 Would your responders allow themselves to be 8 diverted in that way or, again, wait for an instruction from 9 the ORO before taking that reassignment? 10 A (Callendrello) It would totally depend on the 11 situation. If all of the traffic control functions as 12 called for in the SPMC were being accommodated, I would 13 think that those traffic guides would be available as a 14 resource pool to do whatever the governor wanted them to do. 15 JUDGE SMITH: You can make up an' infinite number. 16 MR. FIERCE: I could. I'm asking -- 17 JUDGE SMITH: Absolute infinite number. 18 MR. FIERCE: I'm just trying to get to the essence 19 of this operational control versus direction' control, and I 20 just wanted a couple of examples to see how it worked, Your 21 Honor, that's all. 22 THE WITNESS: (Callendrello) The ORO might - 23 suggest to the governor that we have other people available. 24 The traffic guides receive some specialized training and 25 they're best suited for traffic. l Heritage Reporting Corporation (202) 628-4888
REBUTTAL PANEL NO. 21 - CROSS 24091'
)
- g. 1 JUDGE SMITH: That's right.
f s_, 2 In response to your infinite number of many j i 3 scenarios he has an infinite number of responses to them, 4 too. So where do we go? ]
, 5 DY MR. FIERCE:7 j
6 Q Well, isn't it true that the traffic guide 7 training doesn't instruct the guides exactly what to do in i 8 such a situation as that or in any situation where there is 9 a conflict between command and control and direction? 10 A (Callendrello) The traffic guides are trained as 11 to what the command structure is. 12 The hypothetical you have given me where they have 13 .been directed to perform some'other function is not part of 14 their training. They are trained to follow the command
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15 structure, however. 16 They-are also trained to communicate any problems 17 that should arise. 18 19 20 21 , 22 23 l 2A . 25
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REBUTTAL PANEL NO. 21 - CROSS 24092 1 (The Board confers.) 2 -JUDGE SMITH: Proceed. 3 BY MR. . RCE: 4 Q Panel, I want to clarify something. 5 I believe earlier in the cross-examination the , 6 panel informed me that the Tewksbury liaison is the liaison 7 to the state police; is that correct? 8 A (Callendrello) I said that's one of the functions 9 that that liaison could perform. That liaison is titled a 10 state civil defense liaison, because that is the location of 11 the Area 1 emergency operation center. , 12 What I said was, there is a state police
,13 representative who reports to that location. And that same 14 liaison could act as a liaison with the state police and 15 would act as a liaison with the state police representative 16 who reported there.
17 Q I just wondered if that stands, in any way, in 18 conflict with what the panel has on page 62 at the top where 19 the panel appears to state, it's the liaison in Framingham 20 who functions no the liaison with the state police? 21 A (Callendrello) That,'s also true. 22 There is also a state police representative at the , 23 state emergency operation center. So the state liaison who 24 reports to Framingham would act as a liaison with the state 25 police representative who reported there. Heritage Reporting Corporation (202) 628-4888 1
l L REBUTTAL PANEL NO. 21 - CROSS 24093 l
,- 1 Q So they're both acting in some. ways as liaisons?
i
"\ 2 A (Callendrello) Yes.
3 Q To the state police. 4 On page 62 at the bottom of the middle paragraph
., 5 the panel indicates that, MCDA has indicated it will send a 6 representative to the utilities EOC?
7 A (Callendrello) Yes, that's correct. 8 Q By that we're clear, are we not, we're talking 9 here about the Seabrook Station ERO team and their EOF 10 facility; correct? 11 A (Callendrello) I don't know; that came directly 12 out of the interrogatory response. 13 Q Okay.
/ 14 A' (Callendrello) I assume that meant the ORO EOC.
\ 15 Why'do you assume that when the word " utility EOC" Q
16 is here? 17 A (Callendrello) Because it's a utility sponsored 18 offsite response plan. 19 Typically that's -- because it's a utility 20 sponsored offsite response plan.
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21 Q You don't think that they might be referring to 22 the EOF and the onsite emergency response EOC? 23 A (Callendrello) Well, I suppest,it's possible. 24 They're physically located in the same building. 25 Their rooms are right next to each other.
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0 REBUTTAL PANEL NO. 21 - CROSS 24094 1 Q Is there room in the EOF for state officials? 2 A (Callendrello) Yes. 3 Q The coordination that's described here with the 4 State of New Hampshire -- between the State of New Hampshire 5 and the ORO -- has been developed through a series of , 6 written agreements, joint coordination sessions, drills ar,d , i 7 exercises; correct? 8 A (Callendrello) Correct. 9 As well as their procedural steps in the New 10 Hampshire plan and the SPMC. 11 Q Right. 12 None of that exists between Massachusetts and the 13 State of New Hampshire for Seabrock; correct? 14 No written agreements, joint coordination 15 sessions, drills, and exercises? 16 A (Callendrello) There were a few full scale drills 17 in late 1965, early 1986 time frame where some 18 representatives of the Commonwealth did report to EOF to 19 demonstrat'e the coordination aspects. 20 But since 1986 the Commonwealth refused to sign
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21 the letter of agreement and has not sent any representatives 22 to the EOC EOF with the exception of the observers during 23 the exercise, the observers being from the Attorney l 24 General's office. 25 MR. FIERCE: I did have just a couple questions I Heritage Reporting Corporation (202) 628-4888 1
l
. REBUTTAL PANEL NO. 21 - CROSS 24095 e x. 1 and I'll be throug's, Your Honor. !
I i l x/ 2 BY MR. FIERCE. ; i 3 Q About two or three of your exhibits attached to a 4 the testimony, Panel.
, 5 First was Attachment M?
6 A (Callendrello) "M?" 7 Q "M" which is the Town of Salisbury emergency 8 response. A section labeled " Town of Salisbury emergency 9 response plan SARA Title III," page 6. 10 It indicates that: "The on-scene 11 coordinator / incident commander will appoint a news media 12 spokesperson who will handle total onsite dissemination of 13 information." I) 14 Do you see that?
\ )
15 A (Callendrello) Yes, I do. 16 O This is a plan for Salisbury that you are 17 asserting is currently in effect; is that correct? 18 A (Callendrello) Well, the reason this is in here 19 is to show the mutual aid response capability. 20 Q I understand the reference to that.
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21 , A (Callendrello) I believe that SARA Title III plan 22 is currently in effect, although I can't recall whether 23 there was any testimony regarding the Salisbury plan. 24 Q Are there other plans that look like this for the 25 other towns?
,a
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. REBUTTAL PANEL NO. 21 - CROSS 24096 1 A (Callendrello) There are other local plans. Some 2 of them are Comprehensive Emergency Management Plans. Some 3 are Severe Storm Plans. 4 Q You're.not asserting that every other town has a 5 SARA Title III plan that looks something like this or th'is , 6 section, are you? 7 A (Callendrello) I don't think they all have SARA 8 Title III plans, as my recollection of the testimony given 9 earlier. 10 Q Now, with respect to the Salisbury plan here, if 11 they were to look this plan they would be appointing a media 12 spokesperson; correct? To handle -- 13 A (Callendrello) For a SARA Title III response; 14 that's correct. 15 Q And do you say a SARA Title III response has 16 anything to do with the kind of response they will be L 17 engaging in for Seabrook? 18 A (Callendrello) Some aspects of it does. i 19 Q Is this an aspect? 20 A (callendrello) I think it's something that they )
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21 may do. They may appoint a spokesman to talk about the 22 local response. But I would need to check the state RERP. . 23 I believe the provision of public information is a i I
- 2. state responsibility.
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. REBUTTAL PANEL NO. 21 . CROSS 24097 1 THE WITNESS: (Callendrello)' It may_take me a few 2- minutes to find it.
(Witness searches for document.)' , 3 L 4
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1 l REBUTTAL PANEL NO. 21 - CROSS 24098 l 1 THE WITNESS: (Callendrello) Ms. Frank's been 2 nice enough to find this reference for me. 3 It's Exhibit 55, page 147. It says under " State 4 Responsibilities", "The governor's press secretary is 5 responsible for the release of information on behalf of the , 6 Commonwealth." . 7 I don't believe the local governments have 8 responsibility for describing the overall activities of the 9 Commonwealth, although they are, it's my understanding, 10 responsible, or could be responsible for describing the 11 response of their own local organization. 12 BY MR. FIERCE: 13 Q So they could have a local spokesperson dealing 14 with the media on those issues? 15 A (Callendrello) As far as regards to the local 16 response. 17 Ah, it's on the same page right above it, " Local 18 Government Responsibilities". It says that their local 19 government responsibilities for public information are 20 described in local radiological emergency response plans.
. i 21 That's not very helpful, I guess.
22 That's one of the reasons for establishing the . 23 media center, is to coordinate the provision of response -- 24 of information to the media. Generally, it's desirable to 25 have the information provided to the media for any single Heritage Reporting Corporation (202) 628-4888
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l REBUTTAL PANEL NO. 21 - CROSS 24099
,s 1 organization funneled through a single individual or a few
( \ lj 2 individuals at a single location to ensure a coordinated 3 provision of that information. 4 I could expect that the state would exert their 5 responsibilities under the 'ERP R and be the source of 6 information regarding the Commonwealth's response and to a d 7 great deal of the local response. But there is nothing that 8 I can see that precludes. local communities from providing 9 the information to the media. 10 Q I wanted to ask you, finally, about Attachment P, 11 which is a portion of something labeled Merrimac Emergency 12' Operat ions Plan, pages 11 and 12. And on the first page of 13 that,-I see a section under " Command and control of ("] 14 operations" that indicates that the civil defense director
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/l 15 is subject to the direction and control of the Board of 16 Selectmen, and in that vein, will coordinate all emergency i 17 operations in accordance with mission agreements contained
'18 in this plan.
19 But that after the emergency, as this section 20 reads, it appears that the command and control of disaster
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21 recovery operations shifts to the governor. 22 Do you see that, Panel? 23 A (Callendrello) Yes. There is a phrase, though, 24 that follows that, "in a declared state of emergency". 25 Q "In a declared state of emergency," correct.
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REBUTTAL PANEL NO. 21 - CROSS 24100 1 This plan suggests that Merrimac will be doing its 2 own thing in an emergency at Seabrook, correct? 3 A (Callendrello) To.the extent that their resources 4 permit it, yes. That's the whole foundation upon which the 5 Comprehensive Emergency Response Plan is based. . 6 Q And it's up to the Board of Selectmen in Merrimac 7 to give the ultimate command and control direction to the 8 civil defense director, correct? 9 A (Callendrello) For that community, ycs. 10 Q And that board has not engaged in any nuclear 11 incident training, drills, or exercises, correct? 12 A (Callendrello) That's correct. 13 MR. FIERCE: Your Honor, that's all I have. 14 JUDGE SMITH: Anything further before we adjourn 15 this evening? 16 (No response.) 17 JUDGE SMITH: Is there any possibility we could 18 complete this Panel tonight? 19 How about you, Ms. Chan, or Mr. Bachmann? 20 MS. CHAN: The Staff doesn't have any cross of ! 21 this Panel. 22 JUDGE SMITH: How much redirect do you have? . 23 MR. LEMALD: Just had a very short bit, Your 24 Honor, but I would like a chance to regroup. 25 JUDGE SMITH: All right. s Heritage Reporting Corporation (202) 628-4888
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y y 3., . , REBUTTAL PANEL NO. 21:-' CROSS' 24101 1 MR. LEWALD: It's a local panel and we're not _'- 2 - talking about out-of-state witnesses. 3 JUDGE SMITH:- Okay. So we'will adjourn until 4 _- tomorrow at nine.
# 5 (Whereupon, at 5:20 p.m., the hearing was 6 r,ecessed, to resume at 9:00 a.m., Tuesday, 7 June 6, 1989.)
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4 4 MASE AG's CROSS EXAMINATION PLAN FOR [~'N APPLICANTS' NO. 21
.I (Coordination of Governmental Resources and Response) -O)
I. Identify the expertise or knowledge each member of the panel brings to this testimony. II. History Mass. planning for Seabrook (Part II.A. of 9 testimony) -- Questions directed at specific statements made in testimony to set the record straight.
. Also, offer all of MAG's answers to Interrogatory 2 of NRC Staff's 3rd set.
III. Existing Commonwealth Capabilities (Part II.B. of testimony) .
- 1. Clarifying questions about State Police to establish:
- Plans are not current, not available No training or exercising Traffic Mgt. plan is outdated
- Response times unknown What Applicants contend the State Police will do, i.e., follow SPMC or old State Police plan A
l 2. Clarifying. questions about expected response by
\s-} Dept. of Public Works to establish:
No real plan exists; response would be a TMI-type response.
- 3. National Guard - Clarifying questions
- 4. MBTA - Clarifying questions
- 5. MDPH - Clarifying questions
- 6. MCDA - Clarifying questions
- 7. MDFA - Clarifying questions
. 8. Governor's office - Clarifying questions
- 9. Exec. Office of PubJic Safety - Clarifying questions
- 10. MDFW - Clarifying questions
- 11. MDEQE - Clarifying questfors l (D l () _- .
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O IV. Identify and clarify the assumptions about state / local response that underlie the SPMC and/or this testimony. (Part III. A. of
- testimony) ,
V. Explore the " Modes" and how the ORO will present them to the govts. (Part III. B. of the testimony) VI. Explore how Mass. is expected to follow the utility plan or coordinate with the ORO. VII. Clarifying questions about the Liaisons. VIII. Question about the basis for Applicants' assumptions about the performance of routine . governmental functions. (Part III. D.l. of testimony) IX. Clarifying question about Mutual Aid Agreements. (Part III. D.2. of testimony) X. Clarifying questions about state / local facilities, resources, and communications and noting the lack of training or exercising of a ' coordinated Seabrook response. (Part III. D. 3. of testimony) XI. Integration / Coordination with the local response is given short shrift in the SPMC. (Part III. E. of testimony) XII. Integration / Coordination with the state cannot be reasonably assured, as the working relationships have not been established through training, " drills and exercises. (Part III. F. 2. of testimony) XIII. Coordination with New Hampshire officials with . Mass. officials are not assured by NHY's Letters of Agreement alone. 1503n o
l l 1 CERTIFICATE I
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This is to certify that the attached proceedings before the United States Nuclear Regulatory Commission in the matter l of: Name: Public Service Company of New Hampshire, et al. (Seabrook Station, Units 1 and 2) Docket No: 50-443-OL 50-444-OL (Off-site Emergency Planning) Place: Boston, Massa'chusetts Date: June 5, 1989 jN 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.
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(Signature typed) : Donna L. Cook Official Peporter Heritage Reporting Corporation r"~ k HERITAGE REPORTING CORPORATION (202)628-4888
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