ML20247K060: Difference between revisions

From kanterella
Jump to navigation Jump to search
(StriderTol Bot change)
(StriderTol Bot change)
 
Line 17: Line 17:


=Text=
=Text=
{{#Wiki_filter:}}
{{#Wiki_filter:___--___-__-______ __________-_____
=
UNITED STATES k
NUCLEAR REGULATORY COMMISSION RG3 A'_
ATOMIC SAFETY AND LICENSING BOARD In the Matter of:
)
)
Docket Nos.
PUBLIC SERVICE COMPANY OF
)
50-443-OL NEW HAMPSHIRE, et al.,
)
50-444-OL
)
OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2)
)
PLANNING EVIDENTIARY HEARING O
Pages:
23042 through 23147 Place:
Boston, Massachusetts Date:
May 26, 1989
.....................................==================== ;
\\
L
/
o <'n i
HERITAGE REPORTING CORPORATION OBkWR m 1120 L Street, N.W., Sake 648 Mp:d# g goMyGEA Washington, D.C. 20005 N
#a (202) 628-4888 9906010197 8005I6
: F DR ADOCl:. 05000443 i
r s.
 
i I
i 23042 l
y UNITED STATES NUCLEAR REGULATORY COMMISSION l
'w h
ATOMIC SAFETY AND LICENSING BOARD 3
i In the Matter of:
)
)
Docket Nos.
PUBLIC SERVICE COMPANY OF
)
50-443-OL NEW HAMPSHIRE, et al.,
)
50-444-OL
)
OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2)
)
PLANNING EVIDENTIARY HEARING l
: Friday, May 26, 1989 Auditorium Thomas P.
O'Neill, Jr.
Federal Building 10 Causeway Street Boston, Massachusetts
[ml The above-entitled matter came on for hearing,
()
pursuant to notice, at 8:32 a.m.
BEFORE:
JUDGE IVAN W.
SMITH, CHAIRMAN Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 JUDGE KENNETH A.
McCOLLOM, Member Atomic Safety and Licensing Board U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 JUDGE RICHARD F.
COLE, MEMBER Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 l
7s Heritage Reporting Corporation
(
(202) 628-4888 m
 
23043 j-%..
APPEARANCES:
kw/
For the Applicant:
THOMAS G. DIGNAN, JR.,
ESQ.
GEORGE H.
LEWALD, ESQ.
KATHRYN A.
SELLECK, ESQ.
JAY BRADFORD SMITH,. ESQ.
JEFFREY P.
TROUT, ESQ.
GEOFFREY C.
COOK, ESQ.
Ropes & Gray.
One International Place Boston, Massachusetts 02110-2624 For the NRC Staff:
SHERWIN E.
TURK, ESQ.
ELAINE I.
CHAN, ESQ.
EDWIN J.
REIS, ESQ.
RICHARD BACHMANN, ESQ.
Office of General Counsel U.S. Nuclear Regulatory' Commission Washington, D.C.
20555 For the Federal Emeroency Manaaement Acency:
. /-m
(
H.
JOSEPH FLYNN, ESQ.
\\
LINDA HUBER McPHETERS, ESQ.
Federal Emergency Management Agency 500 C Street, S.W.
Washington, D.C.
20472 For the Commonwealth of Massachusetts:
JAMES M.
SHANNON, ATTY. GEN.
JOHN C.
TRAFICONTE, ASST. ATTY. GEN.
ALLAN R.
FIERCE, ASST. ATTY. GEN.
PAMELA TALBOT, ASST. ATTY. GEN.
MATTHEW BROCK, ESQ.
LESLIE B.
GREER, ESQ.
Commonwealth of Massachusetts One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Heritage Reporting Corporation (202) 628-4888 l
\\m-
)
___________________________________j
 
23044 APPEARANCES:
(Continued)
O For the State of New Hampshire:
GEOFFREY M. HUNTINGTON, ASST. ATTY. GEN.
State of New Hampshire 25 Capitol Street Concord, New Hampshire 03301 For the Seacoast Anti-Pollution Leacue:
ROBERT A.
BACKUS, ESQ.
Backus, Meyer & Solomon 116 Lowell Street P.O.
Box 516 Manchester, New Hampshire 03105 JANE DOUGHTY, Director Seacoast Anti-Pollution League 5 Market Street Portsmouth, New Hampshire 03801 For the Town of Amesburv:
BARBARA J.
SAINT ANDRE, ESQ.
Kopelman and Paige, P.C.
77 Franklin Street Boston, Massachusetts WILLIAM LORD Town Hall Amesbury, Massachusetts 10913 For the City of Haverhill and Town of Merrimac:
ASHOD N.
AMIRIAN, ESQ.
P.
O. Box 38 Bradford, Massachusetts 01835 For the City of Newburyport:
BARBARA J.
SAINT ANDRE, ESQ.
JANE O' MALLEY, ESQ.
Kopelman and Paige, P.C.
77 Franklin Street Boston, Massachusetts 02110 Heritage Reporting Corporation (202) 628-4888
 
r.
l I
o 23045 L-d I -
APPEARANCES:
(Continued) i-([m -}:
s;j.D -
For the Town of Newburv:
R.. SCOTT HILL-WHILTON, ESQ.
Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street-r.
Newburyport, Massachusetts 01950 For the Town of Salisburv:
CHARLES P.
GRAHAM,.ESQ.
Murphy and Graham
. 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 Licensine Board:
[
ROBERT R. PIERCE, ESQUIRE
' Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Heritage Reporting Corporation (202) 628-4888
' g N
 
23046 IHDEX WITNESSES _1.
DIRECT CROSS REDIRECT RECROSS EXAM Panel No. 23:
John W. Baer Anthony M.
Callendrello George R.
Gram by Mr. Brock 23049 by Ms. Doughty 23054 EXHIBITS:
IDENT.
REC.
P.E J.
DESCRIPTION:
Massachusetts Attorney General:
106 23053 23054 FEMA response to TOH's first set of interrogatories dated 2-21-89 Heritage Reporting Corporation (202) 628-4888 l
 
i
\\
23047 1 EDEX INSERTS:
PAGE (No inserts) i
(
Heritage Reporting Corporation (202) 628-4888
 
l1 23048 EB2EEEE1 HEE 1
JUDGE SMITH:
Good morning.
2 Is there any preliminary matters before we 3
proceed?
4 MR. LEWALD:
None that I'm aware of, Your Honor.
5 I did understand that there was a motion in limine 6
that was to be argued sometime this morning, if time 7
permitted, after the testimony of the panel.
8 JUDGE SMITH:
All right.
9 Mr. Brock?
10 MR. BROCK:
Your Honor, just on that point, I 11 think there was discussion about that.
I believe Mr.
12 Traficonte would be handling all that, although I don't know 13 if he was aware that he was to be here this morning for that 14 purpose.
15 (Counsel confers.)
16 MR. BROCK:
I'm corrected, Your Honor, I 17 understand he will be coming.
18 Whereupon, 19 JOHN W.
BAER 20 ANTHONY M.
CALLENDRELLO 21 GEORGE R.
GRAM, II 22 having been previously duly sworn, resumed the witness stand 23 herein, and was examined and further testified as follows:
24 Heritage Reporting Corporation (202) 628-4888
 
n-t REBUTTAL'NO. 23 PANEL - CROSS
.23049 1
CROSS-EXAMINATION (Continued)
~w -
<'.(
2 BY MR. BROCK:
l:
3 Q
Mr. Ca11endre11o, I would like to.just' follow-up 4
briefly on a couple points that.we touched on yesterday.
5
.Could you_ turn to page 51 of your testimony, 6
please.
.Callendrello)
I've got.that.
(
7.
A 8
Q And at page 51 of your' testimony, again, focusing 9
on that-sentence which begins in the middle of the page:
10
" Communication and coordination were demonstrated with at-11'
'leastLone administrative representative of each of the five
~
12 SAUs."
113 It is correct, is it not, that at least two of the 14 five administrative representatives were secretaries?
,,s
((
15 A
(Callendrello)
I believe we stated that we had no
' 16 indication in our records who had been contacted, although I 17 have no information to the contrary.
18 Q
All right.
19 So it could have been a secretary, but you don't 20 know who was contacted; is that fair to say?
21 A
(Ca11endre11o)
That's correct.
~
22 From the exercise records.
23 0
And you also stated, did you not, that you were 24 not aware of the content of the communications which are 25 referenced on page 51; correct?
Heritage Reporting Corporation (202) 628-4888
\\
 
REBUTTAL NO. 23 PANEL - CROSS 23050 1
A (Callendrello)
That's correct.
2 With the exception of the information that Mr.
3 Baer conveyed from the EOC player log.
I have no idea what 4
the content was.
5 Q
And you do not know, do you know, what response, 6
if any, the five SAUs did in response to the call?
7 A
(Callendrello)
No, I do not.
8 Although, maybe Mr. Baer can add something.
9 A
(Baer)
No, I don't.
10 Q
And it's correct, is it not, that FEMA did not 11 have any evaluators at any of the New Hampshire SAUs 12 offices; correct?
13 A
(Callendrello)
I can check the exercise report.
14 I don't believe they did.
But if you give me a 15 moment I will check the exercise report.
16 Q
Right.
17 I'm looking at page 3.3-5 of the Extent of Play, 18 number one under " methodology."
l 19 (Witness reviewing document.)
20 THE WITNESS:
(Callendrello)
In looking at the 21 FEMA exercise report on table 1 I do not see any evaluators 22 specifically assigned to an SAU, although there were five 23 evaluators assigned to evaluate the evacuation of schools.
24 BY MR. BROCK:
25 Q
But you see nothing there to indicate that FEMA Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23051
'I actually had evaluators at.the SAU offices; correct?
2 A
(Ca11endre11o)
That's correct.
3 Q
And it's also fair to say that FEMA did not have 4
any evaluators at any of the New Hampshire EPZ schools; 5
correct?
6 A
(Callendrello)
I don't think that's correct.
7 They did have evaluators who would have gone with 8'
buses:that were traveling routes, and some of those routes 9
included-transits to schools.
So that they would have had 10 evaluators who went with the buses or with the vehicles to 11 the schools.
12
-Q But those evaluators on the buses did not get out 13 and go into the facilities;.is that correct?.
14 A
(Callendrello)
I don't know what they did, but I 15 don't think that was the plan.
16 Q
And that was also true in Massachusetts, correct, 17 FEMA evaluators were not at Massachusetts schools?
18 A
(Callendrello)
That's correct.
19 0
And it's fair to say, is it not, that during the 20 exercise FEMA did not obseree or evaluate the performance of 21 school personnel in carrying out protective actions for 22 school children?
23 (Witnesses conferring.)
24 THE WITNESS:
(Baer)
In the FEMA exercise report 25 for objective 19, FEMA did note that the Department of Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23052 1
1 Education -- they termed it the Board of Education -- this 2
is on page 181 of 428:
"The Board of Education notified all 3
appropriate school districts of the precautionary protective 4
action."
5 So they did evaluate the performance of the 6
Department of Education representatives at the state EOC.
7 BY MR, BROCK:
8 Q
I was focusing upon school personnel, not DOE 9
personnel.
10 But with that clarification, Mr. Baer, you would 11 agree that FEMA did not observe or evaluate school personnel 12 during the exercise for protective actions for school 13 children?
14 A
(Baer)
Unless there were school personnel located 15 at the local EOCs where there were FEMA evaluators.
16 O
And you do not know that, do you, sir?
17 A
(Baer)
I know of one instance where that did 18 occur; yes.
19 Q
Where was that?
20 A
(Baer)
That was in Portsmouth.
21 Q
I would like to show you a document that --
22 MR. BROCK:
I apologize, Your Honor, I don't 23 believe we have complete copies, but they are on their way.
24 I have enough I think to make a limited distribution.
25 This would be Mass AG 106 for identification.
And Heritage Reportirg Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23053 1
it's entitled, " Federal Emergency Management Agency's
~~
\\s,/,
2
. response to Town of Hampton's first set of interrogatories
.3 and request for production of documents to FEMA on the 4
exercise."
I have paraphrased briefly.
Dated February 21, 5
1989.
6 (The document referred -
7 to was marked for 8
identification as 9
Mass AG Exhibit 106. )
10 (Documents proffered to all parties.)
11 BY MR. BROCK:
12
-Q Mr. Callendrello, you have before you what's been f
13 marked as Mass AG 106; correct?
14 A
(Callendrello)
Yes, I do.
[T(,)
15 Q
And referring you to FEMA response number two.
16 It references, does it not, its reasons explained 17 in response number one and then states: " FEMA did.not 18 observe or evaluate the performance of school administrators 19 or other school personnel.in carrying out protective actions 20 for school children."
21 That is what it says; correct?
22 A
(Callendrello)
That is correct.
23 MR. BROCK:
Your Honor, we would offer this.
24 MR. FLYNN:
No objection 25 MR. LEWALD:
I have no objection, Your Honor.
Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23054 l
1 I assume that the underscoring in the document is 9l 1
2 the Massachusetts Attorney General's and not FEMA.
3 MR. BROCK:
That is correct, Your Honor.
4 JUDGE SMITH:
All.right.
5 Attorney General Exhibit 106 is received.
6 MR. BROCK:
Thank you.
7 (The document referred 8
to previously marked for 9
identification as 10 Mass AG 106 was received 11 in evidence.)
12 MR. BROCK:
And with that, Your Honor, I have no 13 further questions of the panel.
14 J'JDGE SMITH:
Ms. Doughty?
15 MS. DOUGHTY:
I'll distribute my cross-examination 16 plan.
17 (Document proffered to the Board. )
18 CROSS-EXAMINATION 19 BY MS. DOUGHTY:
20 Q
Good morning, gentlemen.
21 A
(Callendrello)
Good morning.
~
22 Q
I would like to begin by discussing 23 interpretations of FEMA guidance as presented by the panel j
24 in this testimony.
25 And I guess I would begin by inquiring as to who Heritage Reporting Corporation (202) 628-4888 i
L
 
i l
l REEUTTAL'NO. 23 PANEL - CROSS 23055 1.
wrote the portion-of the testimony beginning at page 4 and
. 's_,/ !
2 concluding at'page 87 3
(Witnesses reviewing document.)
4 THE WITNESS:
(Callendrello)
The process for
-5 writing this piece of testimony -- this section of the-6 testimony as well as the other was the same as the process 7
we've used throughout this proceeding.
And that is, the 8
sections were originally drafted either directly by myself
.- 9 or Mr. Baer or other members of my staff.
10 They were reviewed many times by the panel 11 members, modified.
And then once we had reached agreement 12 that the testimony was accurate and complete,-we would give 13 it to Ropes and Gray and they would put it on their word 14 processing system and go through the mechanics of j_.,
k,)
15 reproducing it.
-16
-BY MS. DOUGHTY:
17 Q
Did you seek the advice of counsel as to whether 18 your discussion of the FEMA guidance on scope included all
.19 the relevant regulatory' guidance and pertinent decisions?
20 A
(Callendrello)
Counsel reviewed the testimony.
21 I don't recall a discussion on that specific 22 point, though.
23 Q
Okay.
24 Mr. Callendrello, are you familiar with ALAB-900?
25 A
(Callendrello)
Yes, I am.
1 Heritage Reporting Corporation
, (s (202) 628-4888 l
l
 
REBUTTAL NO. 23 PANEL - CROSS 23056 1
Q And that's not cited in this?
2 Specifically cited or perhaps I have missed it?
3 A
(Callendrello)
No, it is not cited.
4 Q
Do you have a copy of the Code of Federal 5
Regulations?
6 A
(Callendrello)
I have some sections or some 7
selected excerpts.
8 Q
Are you familiar with the Footnote IV in Appendix 9
E that refers to Section IV(f) (1) ?
10 A
(Callendrello)
Yes, I am.
11 O
You're aware that that footnote talks about the 12 integrated capability to adequately assess and respond to an 13 accident at a commercial nuclear power plant?
14 A
(Callendrello)
It talks about several subjects.
15 It has got two thoughts that talk about what full 16 participation means in terms of the regulation.
17 Q
How did you understand the concept " integrated 18 capability?"
19 A
(Callendrello)
My understanding of integrated 20 capability is in relation to the entities that are described I
21 earlier in that sentence.
And that is:
"The appropriate 22 offsite local and state authorities and licensing personnel l
23 physically and actively take part in testing their
~
24 integrated capability to adequately assess and respond to an 25 accident at a commercial nuclear power plant."
l Heritage Reporting Corporation (202) 628-4888
)
 
REBUTTAL NO. 23 PANEL - CROSS 23057 7y 1
So, in essence, the exercise should test the
(
)
/
\\_s' 2
capability of the organizations -- the integrated capability l
l i
3 of the organizations to respond.
4 Q
Okay.
5 Would you understand that to mean that things all 6
should be going on in an integrated flow contemporaneous 1y 7
with the scenario?
8 A
(Callendrello)
For some activities, yes, I do 9
believe that is what is meant by that.
10 Q
How did you determine which activities should be 11 integrated and those which you weren't obligated to 12 integrate with the actual timing of the scenario?
13 A
(Callendrello)
During the development of the 14 scenario, the crafters of the scenario worked with FEMA and
~s 15 NRC representatives and determined which activities needed 16 to be demonstrated.
I'll call it "in sequence" with the 17 scenario and which ones could be demonstrated out of 18 sequence because they involved verification, maybe some 19 mechanical aspect of the plan such as a map or a 20 transportation route, and were not required to be 21 demonstrated in sequence to show that integrated capability 22 to assess an accident, assess a situation, and respond in 23 the proper manner.
24 Let me add: one of the considerations for whether l
25 something was done in sequence or out of sequence, as we say 1
l 1
Heritage Reporting Corporation (f-w')
(202) 628-4888 wJ
 
REBUTTAL NO. 23 PANEL - CROSS 23058 1
in our testimony, was the availability of evaluators for a 2
particular function.
3 FEMA did put a large number of evaluators in the 4
field.
And even with that large number there were some 5
constraints as to how many activities could be observed at 6
the same time.
So it was necessary to move some activities 7
out of sequence to both fully demonstrate the Extent of Play 8
and allow observation of it in evaluation of it.
9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888
 
d 1
REBUTTAL NO. 23 PANEL - CROSS 23059
'l Q
Mr. Callendrello, wouldn't it have been possible t
a f-~
2 to run more buses.all at once even if the FEMA evaluators 3
couldn't evaluate every single.one?
And if they didn't want 4'
to. ride every bus route, they could have done that again 5
later the second day if they wanted to ride every single bus 6
route.
7 But couldn't you have tested the capability of 8
integrating the response of a number of bus companies all.at 9
once providing drivers within the timing of the exercise 10 scenario?
11 MR. LEWALD:
I'm going to object to the question, 12 Your Honor.
He's being asked as to what is possible with 13 the number of possibilities, and it borders on argument 14 really.
15.
MS. DOUGHTY:
Well, Mr. Lewald, the whole issue of 16 the scope of the exercise, the possibilities as to what was 17 reasonably achievable, had to be determined by the 18 participants and evaluators prior to the' exercise.
So they 19 must have considered questions of what was possible to do 20 and what was reasonably achievable.
21 MR. LEWALD:
I don't think the exercise is dealing 22 with a realm of possibilities.
23 JUDGE SMITH:
Can you'rephrare it?
Wouldn't it 24 have been reasonably achievable to acromrlish those 25 objectives.
Heritage Reporting Corporation O
(202) 628-4888
 
e REBUTTAL NO. 23 PANEL - CROSS 23060 1
MS. DOUGHTY:
A much better way of stating it, 2
Your Honor.
3 BY MS. DOUGHTY:
4 Q
I'll let you respond to that question then.
5 A
(Callendrello)
I'm sorry, c7uld you please just 6
repeat the question?
7 Q
Wouldn't it have been reasonably achievable to 8
mobilize a much larger number of buses on the first day of 9
the exercise to test the integrated capability to respond?
10 And then if FEMA evaluators wanted to riie every 11 single route, they could have been rerun at a later time to 12 make it possible for the FEMA evaluators to do that further 13 check.
14 MR. LEWALD:
This assumes, I assume, unlimited 15 resources by all of the players.
16 JUDGE SMITH:
The idea, as I understand from the 17 question, is that you are suggesting that more buses weren't 18 run because the FEMA evaluators were used.
And this is 19 where the logic of your question falls down, in my mind, 20 because the FEMA evaluators were used to run the routes.
21 And instead of what?
22 Just explain what you believe was the situation 23 and what, in your view, vould have been the better and more 24 reasonably achievable situation.
Then we will put that to 25 the panel.
Heritage Reporting Corporation (202) 628-4888
 
r REBUTTAL NO. 23 PANEL - CROSS 23061-L 1
MS. DOUGHTY:
Okay.
I believe Mr. Callendrello-4.i. \\
k,/
2 was stating that one of the' limitations to their testing the s
3 integrated capability of certain aspects of the plan was the 4
limitation posed by the fact that they had a limited number 5
of FEMA evaluators to observe everything.
6 JUDGE SMITH:
Right.
7 MS. DOUGHTY:
So now I am saying that, or rather, 8
inquiring whether or not it would have been reasonably 9
achievable.
10 JUDGE SMITH:
Couldn't they have used those FEMA 11 evaluators who ran the routes during the exercise, they 12 could run them anytime.
Is that your point?
13 MS. DOUGHTY:
No.
My point is that they could 14 have tested all the buses, more buses together on day one k
15 contemporaneously with the scenario.
And then if FEMA later 16 wanted to ride every single route, they could have done what 17 they~did in day two, which was have people traverse all the 18 routes out of the sequence of the exercise.
19 So I was inquiring as to whether it would not have 20 been reasonably achievable to mobilize more buses during the 21 actual exercise scenario to test the capab311ty to integrate l
22 all the --
23 JUDGE SMITH:
Of course, implicit in your b
24 question, too, and wouldn't that have been a better 25 demonstration, too.
Heritage Reporting Corporation (202) 628-4888 l
 
l l
REBUTTAL NO. 23 PANEL - CROSS 23062 1
MS. DOUGHTY:
Right.
2 JUDGE SMITH:
Can you answer that?
3 THE WITNESS:
(Callendrello)
That last phrase 4
clarifies it for me.
5 I can't just take that idea of reasonably 6
achievable in isolation.
I've got to look at all of the 7
reasons why you have an exercise.
And the exercise is to 8
test that integrated capability and evaluate the integrated 9
capability.
And without having an evaluator observe the 10 function, it doesn't really add much to the exercise.
11 Whether it's achievable or not, it's not prudent, in my 22 mind, to demonstrate a resource, tie up a resource if it's 13 not going to evaluated.
14 BY MS. DOUGHTY:
15 Q
Mr. Callendrello, couldn't that have been 16 evaluated from wherever FEMA, I assume at the EOC when the 17 state people, transportation coordinator made calls?
18 I'm talking about the New Hampshire portion of the 19 exercise at this point.
20 Couldn't that have been evaluated to see whether 21 indeed more bus companies could have been called and more 22 resources have been supplied?
23 It would have taken one FEMA evaluator to hear and 24 see the results of those calls.
25 A
(Callendrello)
Well, that's not the way I l
l Beritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23063 1
understood your previous question.
/
\\
' (,)
2 The way I understood your previous question is 3
wouldn't it'have been reasonably achievable to put more 4
buses on the road.
5 JUDGE SMITH:
But also part of that question was, 6
and evaluate them.
7 THE WITNESS:
(Callendrello)
Right.
8 No.
With that clarification, no, I don't believe 9
it was reasonably achievable.
10 MS. DOUGHTY:
Well, I think that there could have 11 been some limited evaluation.
If the bus companies had said 12 they had tried to mobi3ize more buses and the companies that 13 said, no, we can't provide them, that would have been 14 something that would have been evident to the FEMA evaluator p
c(
15 at the state EOC, would it not?
16 JUDGE SMITH:
Let's relax the method of asking 17 questions.
Let's put out on the table just what your 18 concept is and give them a chance to comment on it.
19 But wouldn't your approach have produced buses 20 pointlessly without evaluators?
21 MS. DOUGHTY:
Well, another way to evaluate it 22 would have been --
23 JUDGE SMITH:
Well, is that an aspect of your 24 question?
25 I mean, let's put the parameters around your Heritage Reporting Corporation
,_s
/
(202) 628-4888
\\
 
l-1 REBUTTAL NO. 23 PANEL - CROSS 23064 1
1 question and your concerns.
2 MS. DOUGHTY:
No.
I think there are ways that 3
they could have evaluated it.
They could have seen if the 4
bus companies could have run -- they also had FEMA 5
evaluators at the state transportation staging areas.
So if 1
)
6 the Applicants had made an effort to mobilize more buses and 7
get them to the state staging areas, it wouldn't have 8
required a FEMA evaluator to ride every single route to see 9
whether the buses could be mobilized.
10 They could have stood at the staging areas and 11 seen those buses arrive.
12 MR. FLYNN:
Your Honor, it sounds to me like the 13 same line of questioning that Mr. Brock was pursuing the 14 other day.
And that is, that the verification of the 15 resources or the availability of the resources of the bus 16 companies that were not actually planning the exercise was 17 done at a completely different time.
18 I don't see what this adds to that.
19 MS. DOUGHTY:
Well, Mr. Flynn, I'm just testing 20 whether it was reasonably achievable to better test the 21 integrated capability to respond.
22 MR. FLYNN:
It's a legitimate line of questioning.
23 My point is that it's already been covered.
24 MS. DOUGHTY:
I'm sorry.
I missed a word you 25 said.
Is it a what line of questioning?
Heritage Reporting Corporation (202) 628-4888
 
I REBUTTAL NO. 23 PANEL - CROSS 23065 l
l 1
MR. FLYNN:
It's a reasonable --
I
\\
, (,/
2 MS. DOUGHTY:
Reasonable.
3 JUDGE SMITH:
There's no objection.
4 MS. DOUGHTY:
All right.
5 BY MS. DOUGHTY:
6 Q
Mr. Callendrello, wouldn't it have been possible 7
to evaluate more busos by having the FEMA observers 8
determine whether bus companies were able to mobilize 9
additional buses to the state transportation staging areas?
10 A
(Callendrello)
It would have been possible to 11 evaluate that one isolated component.
12 I've got to keep going back to the Footnote 4 that 13 you directed me to earlier and read the second thought of 14 that, because that's important in my answers.
(
)
15 And the footnote says, "' Full participation' 16 includes testing the major observable portions of the onsite 17 and offsite emergency plans and mobilization of statt. local 18 and licensee personnel and other resources in sufficient 19 numbers to verify the capabi2ity to respond to the accident 20 scenario."
l 21 We had sufficient numbers to achieve tha+ goal, to 22 verify the capability to respond.
To take additional buses, 23 put them on the road unevaluated does not do anything to 24 verify the capability to respond.
25 Q
Well, again, how did FEMA evaluate the capability
)
Heritage Reporting Corporation f}
(202) 628-4888 l V
-________ _ _ _J
 
REBUTTAL NO. 23 PANEL - CROSS 23066 1
to get the buses to the state transportation staging area 2
from the bus companies?
3 A
(Callendrello)
Through the buses that were 4
provided.
5 Q
In other words, they stood at the state T
6 transportation staging areas and saw what arrived?
7 A
(Callendrello)
For that aspect of the objective, 8
yes.
9 O
So for at least that aspect of the objective many 10 more buses could have been mobilized and that could have 11 been evaluated; is that not true?
12 A
(Callendrello)
If you are saying couldn't more 13 buses have been mobilized, sent to the state transportation 14 staging area and then released, I suppose that's possible, 15 but I don't see how that adds anything to the demonstration 16 of the exercise.
And certainly that was not the Extent of 17 Play agreed upon by all of the exercise participants and 18 avaluators.
19 0
Was it 20 buses that were run contemporaneous 1y 20 with the scenario, Mr. Callendrello?
21 A
(Callendrello)
That's correct.
22 Q
Now could you refresh my recollection that 23 something in the nature of 533 buses were required for the 24 New Hampshire exercise?
j i
25 A
(Callendrello)
For simultaneous evacuation of all
)
k
\\
l l
i l
Heritage Reporting Corporation l
(202) 628-4888 l
1 1
 
REBUTTAL NO. 23~ PANEL - CROSS 23067 1
portions-of the New Hampshire'EPZ, that's my recollection of f--
N,,
2 the nusoer, or close to that.
s 3
O And you believe that 20 buses is a reasonable 4
demonstration of the capability to provide 533 buses?
l-5 A'
(Callendrello)
Yes, because that's one component.
6 Physically having a bus'show up at a staging area and-7 physically run a route is only one component of the function 8
that's being demonstrated.
There are other components:
the 9
assessment of!the need, assessment of the supply, assignment:
10 of the resources.
The actual field activities are only one 11 component of that.
12 And in my opinion, 20 buses is a sufficient-13 demonstration, and that was the agreed upon level o'f 14 performance that FEMA and the other participants needed to 15 provide to verify the capability to respond.
16 Q
Okay.
17 A'
(Callendrello)
I might add, though,'that there 18 were 20 buses provided, but there were many more routes run 19 than just 20 routes.
There were, I believe it was 118 20 routes run for schools, and 66 routes run for special 21 populations.
So it was a more extensive demonstration than 22 just the 20 routes.
23 Q
Okay.
But again, those additional routes were not 24 run contemporaneously with the scenario, and many of them 25 were run on the second day.
Heritage Reporting Corporation j--
(202) 628-4888 g
L
 
LEBUTTAL NOc 23 PANEL - CROSS 23068 1
Is that not true?
2 MR. FLYNN:
Excuse me.
I would like to ask for a 3
clarification.
4 Is the implication here that the scenario should 5
have been extensive enough to necessitate an evacuation of 6
the entire EPZ at one time?
7 JUDGE SMITH:
No.
She's suggesting -- well, you 8
answer it.
But she's suggesting something more than 20 9
buses should have been --
10 MR. FLYNN:
The problem lies in the extent of the 11 scenario.
Is that the implication of the question?
12 MS. DOUGHTY:
Did you say the extent of the 13 scenario, or did you mean the Extent of Play?
34 MR. FLYNN:
Yes.
Your line of questioning 15 suggests to me that what you are trying to establish is that 16 the scenario wasn't broad enough to require a response of 17 more than 20 buses.
And I'm just checking that out.
18 MS. DOUGHTY:
Well, I don't think that's a quite 19 proper interpretation.
The scenario was for a full 20 evacuation, so the scenario wasn't the limitation.
The 21 limitation was that someone along the line decided that 20 a
22 buses was a sufficient demonstration of the capability to 23 mobilize 533 buses.
24 MR. FLYNN:
Did I just hear you to say that the 25 scenario called for a full evacuation, an evacuation of the Heritage Reporting Corporation (202) 628-4888 l
 
REBUTTAL NO. 23 PANEL - CROSS 23069~
.,_z
'l entire EPZ?
2 MS. DOUGHTY:
No.
What I am trying to say is that 7
3 the guidance recommends, or rather, requires a testing of L
4 major observable portions'of the plan and.using resources in
~
5 sufficient numbers to verify the capability to respond to 6
.the accident scenario.
7 So I'm testing the ability that'20 buses is 8
- adequate verification of the ability' to respond.
9 MR. FLYNN:
Well, see, the problem that I'm having 10 is that'Mr. Callendrello made a point of saying that his 11 reading of the same~ regulation is that the demonstration has 12 to be in the context of the-scenario, and you are ignoring 13 that.
- 14 MR. BROCK:
'Well, is that an objection, Mr..Flynn?
r(
15 MR. FLYNN:
I asked for clarification.
I've 16 gotten the clarification.
17 Thank you.
18 BY MS. DOUGHTY:
19 Q
Mr. Callendrello, are you aware of the statement 20 in ALAB-905, and I'll quote the entire sentence just for 21 purposes of completeness?
22 "In summary, the adequacy of the scope of a pre-23 license emergency exercise must be judged against the NRC's 24 regulatory requirements, not the customary practice of FEMA 25 in designing and conducting such exercises."
ll-Heritage Reporting Corporation (202) 628-4888
\\
 
j REBUTTAL NO. 23 PANEL - CROSS 23070 1
JUDGE SMITH:
Where are you?
2 MS. DOUGHTY:
I only have a copy of the slip 3
opinion.
I was quoting from ALAB-900.
4 MR. LEWALD:
905 or 9037 5
JUDGE SMITH:
900.
6 MS. DOUGHTY:
: 900, 9-0-0.
7 MR. LEWALD:
900.
8 JUDGE SMITH:
Are you going to engage in a debate 9
with him on the law?
And I'm not saying that you can't, 10 because they do have in their testimony FEMA guidance and 11 scope.
12 MS. DOUGHTY:
I'm wondering how this impacted his 13 understanding as an individual --
14 JUDGE SMITH:
But that question is very, very 15 broad.
I don't know how he answers it.
I don't know how 16 it's going to be productive.
17 What was the question again?
18 MS. DOUGHTY:
Well, I just asked him if he was 19 aware of it, first of all.
20 JUDGE SMITH:
All right, if he's aware of it.
21 Are you aware of that?
22 THE WITNESS:
(Callendrello)
I've read ALAB-900.
23 What page are you on?
24 BY MS. DOUGHTY:
25 Q
Do you have the slip opinion, Mr. Callendrello?
Heritage Reporting Corporation (202) 628-4888 1
1
 
7______-______
l i
REBUTTAL NO. 23 PANEL - CROSS 23071 l
1 That's all I have with me, so I don't have the --
)
,_s s
i 1
(,)
2 A
(Callendrello)
I think that's what I've got.
j 3
Q Okay.
I'm at page 25 in the first full paragraph.
4 It starts about half way down the page.
5 (Witness reviews document.)
6 A
(Callendrello)
I see that statement.
7 Q
Did that influence your thinking in determining 8
how many resources you would --
9 A
(Callendrello)
No, it did not.
10 I might point out that the date of that decision, 11 at least on the copy I've got, is September 29, 1988; three 12 months after the exercise.
13 O
Okay.
So at the time of the exercise you clearly 14 couldn't have had the clarification of the regulatory
)
15 requirements provided in this Appeal Board decision?
'x J'
16 MR. LEWALD:
I think we can stipulate to that.
17 MS. DOUGHTY:
Okay.
18 BY MS. DOUGHTY:
19 Q
Now I would like to explore your reasons for not 20 testing Objective 36 in the New Hampshire portion of the 21 exercise, and that deals with the unannounced off-hours 22 test.
23 Was th+ basis of your understanding that Objective 24 36 -- well, you determined not to test Objective 36, and 25 indeed th.t was not tested.
1 Heritage Reporting Corporation 7-s\\
(202) 628-4888
}
s
_/
 
REBUTTAL NO. 23 PANEL - CROSS 23072 1
Is that correct?
2 A
(Callendrello)
There are two questions there.
3 Objective 36 was not tested, that's correct.
4 We did determine that in our discussions with 5
FEMA, because they had some specific guidance from Mr.
6 Peterson that indicated that Objective 36 did not apply to a 7
qualifying exercise.
8 And that's contained in Guidance Memorandum 9
EX-3 amendment dated March 7, 1988, which I think is MAG 10 Exhibit 93, at least that's what my notes indicate.
11 Q
Yes.
12 Now turning to page 2 of GM EX-3, there is a 13 number 3 and a paragraph that appears roughly in the middle 14 of the page, and then some subsections beneath it.
And one 15 of them states, " Objective 36, unannounced and off-hours 16 exercises and drills does not apply to a qualifying 17 exercise."
18 A
(Callendrello)
I see that.
19 Q
That's correct?
20 A
(Callendrello)
Yes.
21 Q
Now turning to the transmittal letter that 22 provided the memo to regional directors, it states at the 23 bottom of paragraph 1, "This guidance should be used in 24 conjunction with NUREG-0654, FEMA REP 1, Revision 1, 25 Supplement 1."
Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23073 1
Would you agree with that?
y-,-
A 2
A (Callendrello)
That's what it says.
f\\,-
3 Q
Now, did you interpret this memorandum as being 4<
applied to the utility plan demonstration?
5 A
(Callendrello)
NUREG-0654, Revision 1, Supplement 6
1, is the FEMA guidance that applies to the evaluation of 7
utility response, emergency response plans.
8 Q
Okay.
9-A (Callendrello)
So in that regard, yes.
10 Q
So do you understand this GM EX-3 to provide
~
11 guidance as to how to conduct utility plan exercises?
12 A
-(Callendrello)
Yes, I do.
13 On page 1 of the memo itself under " purpose", it 14 states, "This document amends the guidance in GM EX-3 to
(
15 accommodate the testing of-the utility offsite plans and 16 qualifying exercises."
17 Q
Now the plan for the State of New Hampshire is not 18 a utility plan, is it?
19 A
(Callendrello)
That's correct.
l 20 Q
Now, could you explain to me why Objective 36 1
L 21 wasn't tested for the New Hampshire portion of the EPZ?
l l
22 (Witness reviews document.)
1 23 24 25 Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23074 1
JUDGE SMITH:
I don't want to interfere, I know 2
you've got a rather busy morning ahead of you.
But he just 3
testified that he does not regard objective 36 as an 4
objective in a qualifying exercise.
5 MS. DOUGHTY:
For a utility plan.
6 JUDGE SMITH:
Well, how can you have -- excuse me.
7 (Pause) 8 JUDGE SMITH:
Go ahead.
9 THE WITNESS:
(Callendrello)
That's the point. I 10 can't point to any specific guidance right now.
But you 11 can't have announced on one side of the border and not 12 announced on the other.
13 I just don't see physically how that's going to 14 work.
15 JUDGE COLE:
Wasn't the FEMA guidance indicating 16 that it is not necessary to test objective 36 in a 17 qualifying exercise?
18 JUDGE SMITH:
It says by its very terms, objective 19 36: " Unannounced in off-hours exercises and drills does not 20 apply to a qualifying exercise."
21 MS. DOUGHTY:
Right.
4 22 But we already had the witness -- the witness has 23 already testified that his understanding is that this 24 applies to the test of the utility plan.
And the statement 25 here --
Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL;- CROSS'
-23075' f f-sqx 1
JUDGE' SMITH:
It may very well be that it applies
.(
s.
\\,,[.
2-
'to the test of the~ utility plan,-but he did not. testify, in 3
my hearing, that it does not apply to a test of a state 4-plan.
5 Or did you?
6 Is'it your -
go ahead.
7 MS. DOUGHTY:
It is.
I think.you're guessing, 8
probably.
9-JUDGE SMITH:
Well, go ahead with your cross-10 examination.
11 MS. DOUGHTY: 'Thank you, Your Honor.
' 12 BY MS. DOUGHTY:
13 Q
I guess'I would renew my question unless not 14 allowed.
(
15 A.
.(Callendrello)
I'm sorry, I forgot what the' 16 question was.
17 Q
Did you understand this guidance memorandum to 18 absolve' state plans from testing objective 36?
l 19 JUDGE SMITH:
In a qualifying exercise?
20 (Witness reviewing document.)
21 THE WITNESS:
(Callendrello)
I don't see this 22 9.idance memorandum specifically going to nonutility 23 sponsored emergency response plans.
l 24 I haven't had a chance to look at the other 25 guidance that exists, but this guidance appears to apply to Heritage Reporting Corporation (202) 628-4888
\\
 
r REBUTTAL NO. 23 PANEL - CROSS 23076 1
those plans that are developed in accordance with 2
NUREG-0654, Supplement 1.
3 I can't speak for FEMA on how they interpret it.
4 But I can't believe that they would mean in a situation 5
where, like we have got, where you have got one 6
participating organization, one participating state, and one 7
utility response organization that you would do something 8
differently.
9 Nor do I think could it physically occur that you 10 could have the exercise be announced on one side of the 11 border and unannounced on the other.
12 BY MS. DOUGHTY:
13 0
Could you have just notified the ORO workers 14 without having informed the State of New Hampshire?
15 A
(Gram)
You can't do that because of initiating 16 events of an unusual event require you to notify everyone 17 offsite.
So it begine the process.
18 Q
But we're talking about, at that point that's 19 during the actual exercise where you announced it, you have 20 to let everybody know offsite.
l 21 But I'm talking about prior to the exercise, not 22 letting anybody know at all when things are going to begin 23 to get going.
You might be able to inform the ORO workers, 24 but you wouldn't necessarily have to notify the governmental 25 entities of that, that could have been an unannounced test Heritage Reporting Corporation (202) 628-4888
 
l l
REBUTTAL NO. 23 PANEL - CROSS 23077 l
1 of their capability?
i
\\,/
2 JUDGE. SMITH:
Let's don't beat this to death.
3 The objective 36, whether it's a state plan or a 4
utility plan or whatever it is, does not apply to a 5
qualifying exercise.
6-And it just boggles my mind. I mean, it attacks my 7
imagination to understand how you suggest that in a 8
qualifying exercise it can be unannounced.
9 MS. DOUGHTY:
Well, Your Honor --
10 JUDGE SMITH:
So just move on.
11 MR. FLYNN:
For the record, Your Honor, it is 12 FEMA's position that, at least, that portion of the guidance 13 applies both to utility plans as well as to state sponsored 14 plans.
/
i
!,,v) 15 JUrGE SMITH:
It is just a simple clarifying 16 statement in that document.
17 As I understand that has also been the practice 18 throughout FEMA that they don't have an unannounced exercise 19 for qualifying, as I understand the testimony.
20 MR. FLYNN:
That's correct, Your Honor.
21 JUDGE SMITH:
Already adduced in this hearing.
~.
22 Ever.
23 MR. FLYNN:
Your Honor.
24 JUDGE SMITH:
Did you understand that to be the 25 case?
Heritage Reporting Corporation ps (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23078 1
MS. DOUGHTY:
Well, Your Honor, I understand that 2
ALAB-900 states explicitly at page 22 that to the extent 3
that NUREG-0654 and another FEMA guidance memo, FEMA PR-1 4
suggests such an interpretation.
And this is referring back 5
up to an interpretation that all the major elements don't 6
need to be tested in the qualifying exercise.
7 So those guidance documents conflict with the 8
language structure of the regulation, and thus, may not be 9
relied upon.
10 I think GM EX-3 --
11 JUDGE SMITH:
Show me the language that says that 12 you've got to have -- read the language you rely on here?
13 You're going to complete this cross-examination 14 this morning.
If you're going to spend time on this --
15 MR. FLYNN:
Your Honor, I think the point here is 16 that FEMA guidance can be legally incorrect.
But the point 17 has already been made; the rest is just legal argumentation.
18 JUDGE SMITH:
Well, that much is true.
19 MR. BROCK:
Do you want to stipulate it is 20 incorrect?
21 (Laughter) 22 JUDGE SMITH:
Just to follow your line.
Just read 23 the language that you think would control that.
24 MS. DOUGHTY:
This was in ALAB-900.
j 25 JUDGE SMITH:
Yes, I know.
Just go ahead and read Heritage Reporting Corporation l
(202) 628-4888 1
l l
______________J
 
L REBUTTAL NO. 23 PANEL - CROSS 23079
: i. -
I' 1-
' it.
You already' read it once.
Read it again..
)
2 MS. DOUGHTY:
I think I need the sentence-above it s
i.
3 just-to complete the thought.
L
.4 JUDGE < SMITH:
All right.
5 MS. DOUGHTY:
I was trying to paraphrase and maybe 6
if'I read the whole. thing it.will be clear.
7-
"We cannot agree, however, that insofar as the 8
initial prelicense exercise is concerned the major elements 9
of-the emergency plan can be tested in the aggregate over a 10 six year period beginning with the prelicense exercise and 11 extending to one or more post-license exercises.
12 To tho extent that NUREG-0654.and FEMA'PR-1 13 suggests such an interpretation, these guidance documents 14 conflict with the language and structure of the regulation, 15
'and thus, may not be relied upon."
16 This was the whole point of it.
17 JUDGE SMITH:
So you are arguing from that, that
~18 even if FEMA says, you don't need unannounced' drills and 19 exercises for a qualifying exercise, somehow they have to do 20 it anyway because of ALAB-900.
That is, indeed, a legal 21 argument and you can make it.
22 MS. DOUGHTY:
Okay.
23 THE WITNESS:
(Callendrello)
Your Honor, just for 24 completeness.
I knew it was in here, it just took me some 25 time to find it.
Heritage Reporting Corporation
('~'
(202) 628-4888 x
 
i REBUTTAL HO. 23 PANEL - CROSS 23080 1
In our Attachment C which is the memo from Richard 2
Krimm to Edward Thomas, on the first page in response to 3
issue 1 which Mr. Thomas raised the response was:
"The same 4
scope of exercise objectives delineated for utility offsite 5
response organizations in the referenced March 7th, 1988 6
memorandum applies to participating state and local 7
governments.
8 As set forth in this memorandum 35 of the 36 9
exercise objectives of guidance memorandum EX-3 apply.
The 10 only exception being objective 36, which is the off-hours 11 unannounced."
12 JUDGE SMITH:
Her point, as I understand it, you 13 foolishly and to your peril relied upon FEMA.
14 (Laughter) 15 JUDGE SMITH:
And NRC guidance tells you that it 16 was a mistake.
That's generally your point, isn't it?
17 MS. DOUGHTY:
Right.
18 JUDGE SMITH:
So move on to the next one.
I 19 MS. DOUGHTY:
Move on.
20 BY MS. DOUGHTY:
21 Q
While we are conveniently opened at Attachment C, 22 Mr. Callendrello, we were discussing yesterday, I think, in 23 response to Mr. Brock, you drew attention to issue 2 which 24 has to do with the test of bus drivers and availability of 25 buses; is that correct?
Heritage Reporting Corporation (202) 628-4888
 
.)
l REBUTTAL NO. 23 PANEL -TCROSS 23081.
1 This is Attachment C, page 2-of 3.
f 3-~).
:''(_,,/
2 A
(Callendrello)-
It addresses the issue of what the 3
extent of the demonstration for buses and bus drivers 4
involves.
5 Q
And if I understood your point or if I understood-6 the thrust of your testimony you were saying that the major-7.
emphasis should be on preexercise evaluation?.
8 A
(Callendrello)
I read a statement from the 9
response to the issue raised.
And the response said: "1'he 10 focus of this issue is preexercise evaluation of the 11
-availability of buses and training of bus drivers."
12 Q
But does not the last sentence of this section 13 state: " Guidance for determining the extent of exercise 14 demonstration and evaluation for bus drivers and buses (and
(
15 route guides) is provided in the attachment?"
16 A
(Callendrello)
Yes, it does.
L 17 Q
Now, looking at subsection 2, turning to the 18 attachment which is page 3, of Attachment C, and looking at 19.
subsection 2.
20 In that subsection is there not a statement that 21-says:
"A representative number may vary from 100 percent to 22 a portion of the total activity?"
23 A
(Callendrello)
Yes, there is.
24 Q
Wouldn't that apply to buses?
25 To test bus capability?
Heritage Reporting Corporation (202) 628-4888
 
1 EEBUTTAL NO. 23 PANEL - CROSS 23082 1
A (Callendrello)
Well, that statement and the 2
statement that follows it which says:
"The basis for 3
determining a representative number is the documentation of 4
organizational planning and preparedness," which is the 5
preexercise evaluation.
"The type and level of b
6 participation required by scenario events and other relevant 7
factors such as federal evaluator resources."
8 Q
I don't want to plow over old ground, but I think 9
we have dealt with it.
l 10 So, the basis for determining as you then look at 11 the documentation of how many buses there are; is that 12 correct?
13 A
(Callendrello)
That's one component.
14 In the discussions that arrive at the Extent of 15 Play for bus resources there are other activities -- there 16 are other considerations that are described in that 17 paragraph.
18 Q
Now, the scenario event in this exercise was a 19 scale evacuation of all the -- well, ultimately all the New 20 Hampshire communities were involved except for ERPA G, I
21 belicict is t%at not correct?
22 A
(Callendrello)
ERPA G was not evacuated.
So that 23 is correct.
24 The communities outside of ERPA G were evacuated.
i 25 O
So it was a pretty large evacuation, the scenario?
j
)
Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL-NO. 23 PANEL - CROSS 23083-p 1
A (Callendrello)
No, I have' trouble characterizing g,
3 il i
A,_ /
2 it as pretty large, because I don't know in what context you 3-want to talk about pretty large.
4 If it was on an area basis, it was the majority of 5
the EPZ on an area basis.
On a population basis I don't 6
recall the exact numbers.
-~
7
~But I do know that the City of Portsmouth which 8
was in ERPA G is a'large population center.
9 0
That's' correct.
10' I think we can agree that it was a large' area.
11 Now, on population it did include the Hampton 12 Beach area?
13 A
(Callendrello)
Hampton Beach area was -- the area 14 was closed as a precautionary action so that the population 15 was reduced prior to the evacuation order.
16 Q
Did you have an estimate of the population.that 17 needed to be evacuated relative to the whole population?
18 Was that considered at all in the determination of 19 sample size'for buses?
20 A
(Callendrello)
I don't know if that was 21 considered or not.
22 Maybe Mr. Gram can help on it.
23 A
(Gram)
You have to repeat the question.
I 24 believe there were two questions involved.
25 Were we or was the state aware of the populations Heritage Reporting Corporation (202) 628-4888
(
 
REBUTTAL NO. 23 PANEL - CROSS 23084 1
involved in the areas that were evacuated?
2 Yes, they were; that's part of their 3
considerations in protective action decisions.
4 So the answer to the first part of your question 5
is, yes.
l 6
Now, would you repeat the second part of your 7
question about buses.
8 Q
Let me break it up a little finer, then.
9 Do you recall the estimated population that was 10 evacuated from the New Hampshire portion of the zone or can 11 you give an estimate?
j 12 A
(Gram)
No.
13 We could get a copy of the plan and pull out the 14 populations by ERPA.
15 Q
Did you do that in determining what sample to 16 test?
17 Did you think about how much of tne population is 18 going to be evacuated and then think about how many buses 19 that would require?
20 A
(Gram)
No.
21 Q
So that didn't factor into your determination of 22 what sample size of buses to test?
23 MR. LEWALD:
Mr. Gram was not a participant in the 24 plan.
25 MS. DOUGHTY:
Well, he was a participant in the Heritage Reporting Corporation (202) 628-4888
 
4 REBUTTAL NO. 23 PANEL - CROSS 23005 1
development of the scenario and Extent of Play Agreements.
'l
(,/
2 MR. LEWALD:
If you want to ask about the 3
scenario, that's one thing.
But you are asking about the 4
exercise itself and he was not making protective action 5
recommendations nor wac he carrying them out.
6 MS. DOUGHTY:
Mr. Lewald, as head of the exercise 7
they considered an Extent of Play and how much -- I assume 8
they determined how widespread the accident would be and how 9
much of an area to involve and how many resources would be 10 involved in actually carrying out an emergency response.
11 And I'm just trying to probe with the witness, to 12 what extent, when they were thinking about the scenario, how 13 that impacted on their determination of what the Extent of 14 Play should be and how many actual real resources they
,n
(
15 should call into play.
w/
16 So, again, I just wanted to ask --
17 THE WITNESS:
(Gram)
Yes, I think I can respond.
18 The development of the Extent of Play and the 19 number of buses that were exercised was focused on 20 demonstrating the ability to run bus routes, not the ability l
l 21 to move people.
22 The total populations are considered during
)
23 protective action decisions.
And no one sits down and says, l
24 well, today is Thursday, how many people are going to be in 1
25 Hampton.
There's a default value that is always used.
l Heritage Reporting Corporation
[''N (202) 628-4888 l
l l
 
f REBUTTAL NO. 23 PANEL - CROSS 23086 1
So the total -- the ability to move all of the 2
people for a full evacuation is evaluated by FEMA in their 3
evaluation of total transportation resources.
I 1
4 5
6 1
7 l
8 9
'10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 i
l l
Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23087 1
Q Then when the default value was used, if you-
-~
\\s_
2 assumed the full need of resources in each of the facilities 3
that needed to be moved, did you total those up for the 4
communities that would be evacuated and determine from that 5
a sample size of buses to be tested?
6 A
(Gram)
No.
7 JUDGE COLE:
But that information is available.
8 THE WITNESS:
(Gram)
Yes, sir.
9 BY MS. DOUGHTY:
10 0
I would like to turn to page 14 of your testimony.
11 A
(Callendrello)
I've got that.
12 Q
Actually, we should probably start back on page 13 13, because the part I want to talk about follows from page 14 13.
,m 15 This was in the -- the next step, it states at the 16 final full paragraph on page 13, does it not, that, "The 17 next step in developing the Extent of Play was to identify 18 the processes and their components required to demonstrate 19 the plan element during the exercise."?
20 And then there is another sentence that follows 21 and then some subsections running on to page 147 22 A
(Callendrello)
Yes, there are.
23 Q
And the last one in that particular grouping is, 24
" verification of the deployment process"?
25 A
(Callendrello)
Yes.
Heritage Reporting Corporation 1
-[g (202) 628-4888
\\
 
I REBUTTAL NO. 23 PANEL - CROSS 23088 1
Q Do you believe that verification of a deployment 2
process is the same thing as verification of implementatica 3
capability?
4 A
(Callendrello)
No, I do not.
5 Q
So, in other words, if you can demonstration that 6
you have a process in place to call up buses, it doesn't 7
really demonstrate that you can get buses out on the road 8
and get them to where they need to go?
9 A
(Callendrello)
No, that's not the way I 10 understood your previous question.
11 You asked me is verification of the deployment 12 process equal to implementation of the action.
And I don't 13 believe -- well, my answer is, no, it is not, because that 14 is one component of the implementation process.
15 Q
Okay.
Isn't calling a bus company and just seeing 16 how many buses they have available and doing the phone 17 communications about where they need to go, isn't that just 18 a verification of the deployment process?
19 A
(Callend ello)
No, that's not what that testimony 20 is intended to say.
21 Verification of the deployment process is actually 22 putting a vehicle on the road in the field.
23 Q
Okay.
Now how would you understand verification 24 of implementation capability then?
25 Just so we are talking in the same terms, I want Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23089 1
to understand, g-
-k
,)
2 A
(Callendrello)
Verification of implementation 3
capability is the whole process.
It is the process from, 4
and depending on what particular function we're talking 5
about, the decisionmaking process.
6 If we're talking about transportation, which I 7
think we are talking about now, it's analysis of the need.
8 It's the contact of the supplier and analysis of the supply 9
of vehicles.
It's making the allocation and distribution of 10 those vehicles.
It's establishing the staging area 11 arrangement.
And the final part of that is the actual field 12 deployment of vehicles.
So that's one component of the 13 verification of implementation.
14 Q
Now is part of the deployment process -- well, p
15 maybe I should just be really clear about this.
( s) s.
16 The regulation at Appendix E, Section IV(f) 17 requires generally that emergency preparedness exercises, 18 and this is to quote a small portion of it, " tests the 19 adequacy of timing and content of implementing procedures 20 and methods".
21 And I'm wondering about how the actual timing of 22 deployment of buses was adequately tested.
23 I!ow did -- well, let me not clutter it up.
24 A
(Ca11endre11o)
I'm sorry.
Can you just give me 25 the question again?
Heritage Reporting Corporation
[''
(202) 628-4888 i
r
 
REBUTTAL NO. 23 PANEL - CROSS 23090 1
I know it was a long introduction to it.
2 Q
Okay.
3 A
(Callendrello)
I do have that section of the 4
regulation.
I was looking at it as you were talking, and I 5
just missed the question.
I'm sorry.
6 Q
Again, I'm interested in how the process of 7
deploying buses, as it was done in this exercise, tested the 8
adequacy of timing in content of implementing procedure and 9
methods.
10 A
(Ca11endre11o)
It tested the timing -- well, the 11 way I interpret that section of what you've just read is 12 adequacy of the timing, where there is timing that needs to 13 be evaluated, and I'm thinking along the lines of prompt 14 notification systems where there is a fixed time 15 requirement, or initial notification to offsite authorities, 16 this is for the onsite organization, where there is a fixed 17 timing requirement.
18 The timing requirements of the procedures, I know 19 of no other timing requirements, regulatory requirements or 20 guidance requirements.
I would interpret this to only apply 21 to those sections where there is a timing requirement.
22 Q
Wouldn't, in a real emergency response, the timing 23 aspect of deploying buses have an impact on the evacuation 24 time estimate?
25 A
(Ca11endre11o)
Well, no.
The evacuation time Heritage Reporting Corporation (202) 628-4888
 
l-REBUTTAL NO. 23 PANEL - CROSS 23091 1
estimate is the evacuation time estimate it.
-m i
(
/
2 O
But it's got certain assumptions about timing of v
3 deployment of resources.
4 A
(Callendrello)
Yes, it does.
5 Q
And did this exercise really test those 6
assumptions?
7 MR. FLYNN:
I object.
This is again legal 8
argumentation.
9 JUDGE SMITH:
No, it's not.
10 MR. FLYNN:
Well, but the --
11 JUDGE SMITH:
It's factual.
12 MR. FLYNN:
The whole point of the line is a 13 suggestion that there was not an adequate demonstration that 14 buses could be mobilized in a timely way.
But that issue
,/ m
(
).
15 goes to a threshold value or a minimum time for the
%d 16 mobilization of buses or other resources which is not part 17 of the standard that's applied.
18 JUDGE SMITH:
It's a standard which'is applied 19 where?
20 MR. FLYNN:
To the plan in general, or to this 21 aspect of this exercise.
It strikes me that this is the 22 Sho11y-Beyea --
23 JUDGE SMITH:
Are you suggesting there is no 24 element of timeliness in the deployment of buses that have 25 to be considered?
Heritage Reporting Corporation
(''}
(202) 628-4888
\\
)
 
REBUTTAL NO. 23 PANEL - CROSS 23092 1
MR. FLYNN:
There is no pass or fail value.
There 2
is no threshold value that has to be met.
3 MS. DOUGHTY:
There is no --
4 JUDGE SMITH:
There ar'e assumptions in the ETE as 5
to deployment.
And now she's asking simply how were those 6
assumptions, if tested, if they were.
7 MR. FLYNN:
Well, if that's how the question is 8
understood, then I will withdraw the objection.
9 JUDGE SMITH:
Was that it?
10 MS. DOUGHTY:
That's correct.
11 THE WITNESS:
(Callendrello)
The evacuation time 12 estimate was developed based upon the implementing 13 procedures contained in the plan.
And the exercise was a 14 test of those implementing procedures.
15 And FEMA's evaluation found that those 16 implementing procedures were adequately demonstrated.
17 Therefore, if you follow the chain backwards, I won't say 18 justified, but it has supported the timing sequence used in 19 the evacuation time estimate.
20 BY MS. DOUGHTY:
21 Q
Okay, that's a timing sequence as to reasonable 22 assurance that the ETEs are adequate in terms of providing a 23 basis for judgment of how much time it takes to deploy 24 resources.
25 JUDGE SMITH:
Something is wrong with that Heritage Reporting Corporation (202) 628-4888
 
F REBUTTAL NO.' 23 PANEL - CROSS' 23093 1
sentence.
L: f(
'2
.(Laughter)
- b j.
3 JUDGE SMITH:
Do you want it read back, or do you 4
-want to try again?
5 MS. DOUGHTY:
Maybe if I hear it, I will 6
understand what the problem is.
7 (Accordingly, the pending. question was played i
8 back by the court reporter.)
9
'MS. DOUGHTY:
I guess there was a problem with-10 that question.
Let me rephrase it.
11 BY MS.. DOUGHTY:
12 Q
Your response was in terms of the sequ'ence of 13 timing of-events.
'14 Now, I'm trying to inquire into whether or not the
]
15 exercise tested the assumptions in the ETE as to the general
-16 time frames in which resources could be deployed that are 17 assumed in the ETE.
18 JUDGE SMITH:
For buses?
For buses?
19 MS. DOUGHTY:
Yes.
Emergency response vehicles.
20' JUDGE SMITH:
Well, okay.
For all emergency 21 response vehicles?
22 MS. DOUGHTY:
Well, I think you are right.
We 23 should narrow it to buses.
24.
MR. LEWALD:
Is the question, "Was that a part of 25 the exercise"?
Heritage Reporting Corporation pf''
(202) 628-4888
(
 
REBUTTAL NO. 23 PANEL - CROSS 23094 1
JUDGE SMITH:
How did the exercise test the 2
timeliness of the deployment of buses, if it did.
3 MR. LEWALD:
It's assuming that it did.
4 JUDGE SMITH:
Yes, assuming that it did.
And if 5
it didn't, why didn't it.
6 MS. DOUGHTY:
He can answer that.
7 THE WITNESS:
(Callendrello)
It did test the 8
timeliness of response of those vehicles from the suppliers 9
that were involved -- the providers that were involved in 10 the exercise.
11 JUDGE SMITH:
How did it do it?
12 THE WITNESS:
(Callendrello)
FEMA actually --
13 JUDGE SMITH:
Just by timing it.
14 THE WITNESS:
(Callendrello)
Yes, they timed it.
15 v'UDGE SMIT 71:
Okay.
16 THE WITNESS:
(Callendrello)
They also timed the 17 routes that were run.
18 BY MS. DOUGHTY:
19 Q
Now, wouldn't you agree that if a company had been 20 called upon to supply more buses, it might have taken more 21 time to get those additional buses deployed?
22 A
(Callendrello)
I read the word "might" as is it 23 possible.
24 Sure, I think it's possible it could have taken 25 more time.
Heritage Reporting Corporation (202) 628-4888 I
i t
L
_______..______________________.J
 
'J REBUTTAL NO.'23 PANEL - CROSS 23095 l
Well,Ewould that be a likely result?
1 1JUDCE SMITH:
/''Ml
(
)
2 Her point is, here is a sample, if it is a sample, j
3 of.20 buses out of 500.
You can get those out rather 4
promptly.
Therefore, you did not test the capacity to l
5 deploy all of the buses in a real emergency is her idea, I-6:
believe, isn't it?
)
7 MS. DOUGHTY:
Yes.
8 THE WITNESS:
(Callendrello)
.It might take more 9
time to deploy them, but it may not have any impact --
l l
10 THE WITNESS:
(Gram)
On the ETEs.
I i
11 THE WITNESS:
(Callendrello)
-- on the ETEs.
1 12 Because the ETEs assume a range of reporting times.
And 13 these, in essence, would have been the first buses deployed' 14 from a particular yard.
If more buses are deployed, they
- [''N j
(
)
15 are further down the window of times that buses report on.
16 JUDGE COLE:
But that aspect was simply not I
17 testeo, the time for deployment of all buses?
18 THE WITNESS:
(Callendrello)
Of all buses.
i 19 No, that's correct.
i i
20 MS. DOUGHTY:
Thank you.
21 BY MS. DOUGHTY:
22 O
I would like to --
i i
23 JUDGE SMITH:
That's a considered answer now?
24 THE WITNESS:
(Callendrello)
We did not deploy 25 all buses.
Heritage Reporting Corporation
- ('~'
(202) 628-4888
 
k REBUTTAL NO. 23 PANEL - CROSS 23096 1
JUDGE SMITH:
Right, but did you test -- but was 2
the --
3 THE WITNESS:
(Callendrello)
Well, I'm sorry, 4
Your Honor.
5 JUDGE SMITH:
If I think about your answer, 6
because I don't understand that to be -- it could very well 7
be the case, but I don't think it's consistent with what I 8
understand the exercise to be.
9 THE WITNESS:
(Gram)
Yes.
I believe FEMA, in 10 their pre-evaluation of transportation resources, one of 11 their questions was, you know, at any given time how long 12 would it take you to respond and how many resources would 13 you normally do it.
14 So I believe that that the issue of testing in 15 that sense was done by FEMA in their pre-evaluation, the 16 timeliness of all the resources.
17 THE WITNESS:
(Callendrello)
In addition, as the 18 scenario progressed and the exercise progressed, additional 19 resources were made available to the participants in a time 20 sequence.
So that the availability of resources over a 21 staggered time or an extended time period was evaluated, was 22 demonstrated, although we didn't actually mobilize all buses 23 from the providers.
24 That type of information was provided on what 25 would be a reasonable time frame for the actual deployment Heritage Reporting Corporation (202) 628-4888
 
d j
i REBUTTAL NO. 23 PANEL - CROSS 23097 l
1-of those resources.
So that' aspect of it was tested.
]
4
)
2 I understood Judge Cole's question to be:
Did you x-3 test the actual' deployment of all vehicles from a single 4
provider.
5 JUDGE COLE:
My question was simply, in view of 6
the fact that you did not mobilize all the buses, the time 7
to do that was not determined in the exercise.
8 THE WITNESS:
(Callendrello)
That's correct.
We 9
did provide data, though, that indicated some deployment 10 time for-all of the resources needed.
'll BY MS. DOUGHTY:
12 Q
.And those are based on the assumptions of the 13 company-owners?
14 A
(Callendrello)
I'm not sure what went into that
/~
;(
15-deployment time sequence; whether it came from the A
16' assumptions of the owners or the evacuation time estimate 17 data.
It would have been one of those sources though.
18 Q
Okay.
I understood Mr. Gram's answer to be that 19 the bus company providers had provided to FEMA estimates of 20 the time to deploy resources.
21 So those are their assumptions as to estimates of
.~
22 time, are they not?
23 A
(Callendrello)
In what Mr. Gram was talking 24 about,.yes, that's correct.
25 I was talking about something a little bit Heritage Reporting Corporation (202) 628-4888 tO
--..-___----._______-_-__w
 
REBUTTAL NO. 23 PANEL - CROSS 23098 1
different.
And that is, during the exercise all resources 2
were not instantly made available to the exercise 3
participants.
They were made available to them on some 4
staggered basis and an evolving basis, a cumulative basis so 5
that it would approximate what would be the expected
~
6 deployment. time.
7 8
9 10 11 12 13 l
14 15 16 17 18 19 20 21
~
22
~3 24 25 Heritage Reporting Corporation l
(202) 628-4888 r
i
 
I 1
l l
REBUTTAL-NO. 23 PANEL - CROSS 23099 1
.O
" Expected?"
:[ m:5~,)
2 JL
,(Callendrello)' Right.
a 3
We tried to make it as real as we could for these 4
~ individuals by not instantly making all these vehicles 5
available to them.
6 Q'
Mr. Callendrello, I want to explore with'you'the
~7' statement in the testimony at page 15 about -- I believe 8
this.was. examined a.little bit yesterday but I want to go a 9
little bit further.
10 The statement appears -- the first full sentence 112-at the' top of page 15 is:
"Because the functions to be 12 performed by these responders were similar to their normal 13 employment functions, an adequate demonstration of this particular functional area did not require extensive 14 15 deployment of resources."
16:
And I believe this is in reference to the buses:
17
'is that correct?
Or is it in reference to more than just 18 the buses?
19 A
(Callendrello)
It's in reference to more than 20 just buses.
21 Q
Just for purposes of the record would you explain 22 which functions are being referred to in this sentence?
23 A
(Ca11endre11o)
I can explain -- I can describe-24' some of them; I may not hit them all.
25 One would be ambulance drivers.
Heritage Reporting Corporation r'
(202) 628-4888
^t a_______.
_ = _ - _ - _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _
 
REBUTTAL NO. 23 PANEL - CROSS 23100 1
: Wait, Mr.. Gram points out, on page 14 we do cite 2
some examples.
l 3
Q Okay.
4 A
(Callendrello)
In the middle of the page the 5
parenthetical says: " Ambulance drivers; bus drivers; law 6
enforcement personnel."
7 Q
Let's consider bus drivers and what they will be 8
expected to do during a radiological emergency.
9 Is it not true they will be expected to check 10 their dosimetry periodically?
11 A
(Callendrello)
Yes, that's correct.
12 O
Is it also not true that many of them won't be 13 driving in areas that they are familiar with, so they may 14 need to consult with maps?
15 A
(Callendrello)
I don't know the exact number; 16 the breakout of those vehicles that originate from companies 17 that normally service the EPZ versus those that don't; so 18 many qualify.
19 Certainly, some will be driving in areas that they 20 don't normally service and would be required to read a map.
21 Q
Other than the Barry Transportation Company, my 22 understanding is, that they all go to the state staging 23 areas and then are sort of deployed as they arrive there.
24 So even buses that are generally from the area 25 might not drive the particular routes they normally drive.
Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23101 1
Is that not. correct?
:/: (,,)'J 2
A
.(Callendrello)
That's correct.
3 They might not be driving -- might not normally 4
drive that_particular route.
5-Q Is it aisc not true that some bus drivers will be
'6 going to nursing homes and may have to deal with the 7
installation of beds on their vehicles?.
c.
8 A
(Callendrello)
No, that's not correct.
.9-We would only send buses to those facilities -- if 10 you' re talking about evacuation bed buses, those patients 11 would be loaded and the equipment would be installed by the 12 facilities on staff.
And they are, in fact,: trained to 13 perform that' function.
14 Q
Mr. Callendrello, do you recall the testimony of 15-Mr. Trahan on the New Hampshire side?
(
16 A,
(Callendrello)
I was not present for his 17 testimony.
18 Q
Do you recall the testimony of Commissioner 19 Maureen Barrows?
20 A
(Callendrello)
Vaguely; that was quite a while 21.
ago.
MS. CHAN:
Is there a particular part of the 22 23 testimony that, perhaps, you want to renew the witness' 24 recollection or are you going to pass on at this point?
-25 MS. DOUGHTY:
I'm trying to figure out what I Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23102 1
should at this point, to tell you the truth.
2 MS. CEAN:
If he can't remember you really can't 3
ask him anything else.
4 MS. DOUGHTY:
Right.
5 He doesn't have memory, so I'm trying to think 6
about how to approach this.
7 JUDGE SMITH:
Let's take a 10 minute break.
8 (Whereupon, a recess was taken.)
9 JUDGE SMITH:
On the record.
10 Ms. Doughty, Judge Cole poin.ted out to me that my 11 remark about you finishing this morning could be taken by 12 you as an order to finish this morning.
I didn't intend 13 that.
I thought that was your plan to finish this morning.
14 MS. DOUGHTY:
I had hoped to, but I'm not skilled 15 at estimating how much time it takes me to get through one 16 of these plans.
17 JUDGE SMITH:
Well, I was just reporting, somehow 18 you had conveyed the idea to us that you would finish this 19 morning, and I was pointing out that at that pace you're not 20 going to do it.
21 MS. DOUGHTY:
I think you may be right.
22 I'll press onward, however, and hope for the best.
23 BY MS. DOUGHTY:
24 Q
Mr. Callendrello, we were talking about other 25 functions that bus drivers may or may not be called upon to Heritage Reporting Corporation (202) 628-4888 r
:1 L
!",s REBUTTAL NO. 23 PANEL - CROSS 23103 l'
perform in the course of_a radiological emergency aside from
(-';
)t
'2 bus driving before we broke.
3-Just to start a new -- we agree that.they may need 4
to. read dosimetry -- check'their dosimetries, rather?
5 A
(Ca11endre11o)
That's' correct.
~
And they may be in unfamiliar areas and may be 6
Q 7
concentrating on finding their way including reading maps?
8 A
(Callendrello)
That's correct.
9 Q
Do you have Applicants' Exhibit 43 (f).available. to -
10 you at the table?
11-A
.(Callendrello)
Which is that?
12-Is that the exercise report?
13' Q
That's the exercise report?
14 A
(Callendrello)
Yes, I've got a copy of it.
)
15 Mine is not marked as an exhibit, so it has got 16 the other page numbering on it.
~
17 Q
0Aay.
18 JUDGE SMITH:
We're using the original page 19 numbers for this examination.
20 MS. DOUGHTY:
Okay.
21 BY MS. DOUGHTY:
22 Q
Those original page numbers would be 210 to 2117 23-A (Ca11endre11o)
I've got that.
24 O
Now, at page 210 there is issue number 1 25 identified and rated as an ARCA.
And this hco to do with Heritage Reporting Corporation g'~
(202) 628-4888
(
 
REBUTTAL NO. 23 PANEL - CROSS 23104 1
the reading of dosimeters at 15 minute intervals; does it.
2 not?
3 A
(Callendrello)
Just give me a moment to look at 4
that.
5 Yes, it does.
But this is an inadequacy as 6
regards to the offsite response organization and not the 7
State of New Hampshire.
8 Q
Well, at least for the offsite organization,.then 9
this was identified as a problem for the drivers of buses?
10 A
(Callendrello)
It was identified as an issue.
11 I can read the issue.
I wouldn't say identified 12 as a problem.
It was an issue that in a minority of cases 13 reading of dosimeters at 15 minute intervals was not 14 accomplished.
15 And it says:
"This was a more frequent problem 16 for the drivers of vehicles."
17 Q
Well, maybe I should be precise and call it an 18 area requiring corrective action, then?
19 A
(Callendrello)
Yes, it was.
20 Q
Now, on the New Hampshire side of the zone the 21 recommendation was that route guides -- this is at the top 22 of page 211 -- route guides should be trained to provide 23 assistance to bus drivers and reading and recording logging 24 dosimeter readings?
25 A
(Callendrello)
Again, that is for the offsite l~
l Heritage Reporting Corporation I
(202) 628-4888
(
 
L
[
REBUTTAL NO. 23 PANEL - CROSS 23105 1
response organization.
/''N 2
Q But we have agreed on the New Hampshire side bus
\\al 3
drivers will also have to check dosimetry?
4 A
(Callendrello)
Yes, they will.
5 Q
Now at page B-70 of the Applicants' Exhibit 43 (f) 6 there is a comment, " observation" column that states, among 7
other things, "That bus guides are no longer used."
And 8
that refers to the New Hampshire portion of the zone, is 9
that not true?
10 A
(Callendrello)
It does.
11 What you have pointed me to, though, is a specific 12 comment or comments specific to the Town of Kingston.
I 13 don't recall in 1986 whether bus guides were used in all.
14 communities or not.
,a 15 Q
Well, I guess we don't need to belabor that.
i (x_ l 16 But can we agree that bus guides are not 17 contemplated for the New Hampshire buses?
18 A
(Callendrello)
I'm sorry.
19 Q
The use of bus guides is not contemplated for the 20 New Hampshire buses?
21 A
(Callendrello)
That's correct.
22 Q
So the New Hampshire bus drivers will not, as 23 recommended for the ORO workers, have the assistance of bus 24 guides in reading their dosimetry and logging their 25 dosimeter readings, will they?
Heritage Reporting Corporation
[~^g (202) 628-4888
\\~ /
 
REBUTTAL NO. 23 PANEL - CROSS 23106 1
A (Callendrello)
If you're pointing me to the 2
language on 211, the recommendation is that route guides be 3
trained to provide assistance to bus drivers and reading and 4
recording dosimeter readings?
5 Q
Yes.
~
6 That will happen on the Massachusetts side of the but that won't be possible on the New Hampshire side 7
: zone, 8
of the zone, will it, because there will be no bus route 9
guides?
10 A
(Callendrello)
Well, it won't be possible.
11 But I think FEMA evaluated that capability.
12 If you just give me a moment I can look.
13 (Witness reviewing document.)
14 THE WITNESS:
(Callendrello)
FEMA did evaluate 15 the ability of the bus drivers or the monitoring of 16 dosimetry by bus drivers in the New Hampshire portion as 17 well.
18 BY MS. DOUGHTY:
19 Q
Yes.
20 That's at page 1547 21 A
(Callendrello)
Yes, it is.
22 Q
And that was issue number 1.
And 2 is an ARCA?
23 A
(Callendrello)
That's correct.
24 Q
And the evaluation was that most bus drivers, 25 ambulance drivers, town personnel, and a few local police Beritage Reporting Corporation (202) 628-4888 r
 
t
.h j
REBUTTAL No. 23 PANEL - CROSS 23107 l'
L 1
did not frequently monitor exposure?
1.; (-
(
/
2 A
(Callendrello).
That was the evaluation.
3 And then there were two recommendations to resolve
-4 that area requiring corrective actions.
5 Q
I guess the overall point I'm trying to make is, 6
there have.been identified difficulties with this procedure.
7 And this is different from what a bus driver would normally 8
be expected -- normal function-for a bus driver?
9 A
(Callendrello)
Again, you've got two pieces.
10 Yes, it is.
It was an identified area requiring 11 corrective action for the bus drivers that were 12 participants.
Actually, that comment includes more than 13 just bus drivers.
14 And it is something that they would not do in
}
15 their normal duties.
16 Q
So isn't the rationale for not requiring extensive 17 deployment of resources, as stated at page 15, not quite 18 accurate?
19 A
(Callendrello)
No.
20 You've got to look at the overall objective, and 21 the components of the overall objective.
22 What you are focusing on is one very small 23 component of that overall objective.
In this case it would
'24 be objective 18.
Maybe it's easier for me to read what 25 objective 18 is.
Heritage Reporting Corporation (202) 628-4888 C/
f
 
REBUTTAL NO. 23 PANEL - CROSS 23108 1
" Demonstrate the ability and resources necessary 2
to implement appropriate protective actions for the impacted 3
permanent and transient plume EPZ populations."
4 That's a very broad objective.
And you're talking 5
about one aspect of it.
One very small aspect of a 6
component of it.
7 And the important component of that is the ability 8
for a bus driver to drive a bus and reach a location.
And 9
those are duties that are performed by a bus driver on a 10 day-to-day basis, on a normal basis.
11 Q
But isn't the routine for a bus driver usually to 12 drive a familiar route and not have to check dosimetry?
13 A
(Callendrello)
Well, there is two parts to that.
14 I would grant that bus drivers -- at least I've 15 never seen a bus driver that normally has to check dosimetry 16 on their daily route.
But they do normally drive routes.
17 And they normally drive buses and follow maps.
This may be 18 a different map, but they are still following maps.
i 19 Q
Maybe on the first day of their employment they i
20 follow a map.
But wouldn't you agree that after having 21 driven the route two or three times that they have been 22 assigned for a school or unless it's a charter bus company 23 they normally don't need to follow route maps?
24 A
(Callendrello)
Well, school bus drivers that are 25 normally running their pickup routes I would agree wouldn't Heritage Reporting Corporation (202) 628-4888 i
 
Ly REBUTTAL NO.-23~ PANEL
. CROSS-2'3109 L
:1 need'a map.
But they do go outside of areas.
They go to
..,,q e/
\\
2 away.footb'all games.
And they go down to Boston to come to
\\s_,/ -
3' the various museums.
So they do follow maps as part of 4
their regular jobs.
5 Q
But you would agree that not all bus drivers do 6
those-extra. assignments?
7 So an assumption is being made, is:it not?
8
. You' re relying on an assumption that bus drivers 9
may take other. trips that require them to read maps?
10 A.
(Ca11endre11o)
We're relying on an assumption 11
'that a bus driver is able to read a map or is capable of.
12 being trained to read a map.
That is our assumption.
'13 Q
Now, I believe Mr. Brock elicited on examination 14 yesterday that there were 49 routes out of 66 routes, and-I 15 can't remember specific ally how you characterized those 16 routes that were successful?
17 (Witness reviewing document.)
18 19 20 21 22
[-
23 24 25 Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23110 1
THE WITNESS:
(Callendrello)
This was in New 2
Hampshire only?
3 MS. DOUGHTY:
Yes.
4 THE WITNESS:
(Callendrello)
There were 49 routes j
5 out of 66 routes, and I'll call those special needs routes.
6 MS. DOUGHTY:
Special needs routes.
7 THE WITNESS:
(Callendrello)
Those are hospital, 8
nursing home and transit-dependent routes.
9 BY MS. DOUGHTY:
10 Q
Now that would mean that 17 buses were not 11 successful in completing the routes, is that correct?
12 A
(Callendrello)
Seventeen routes were not 13 completed.
On the second day of the exercise, those routes 14 were being driven by private vehicles.
So it may not have 15 been a bus.
16 Q
Now at page 165 of the FEMA evaluation report, 17 there is a chart that appears in the middle of the page that 18 talks about the number of buses required and the time stated 19 is at 1420?
20 A
(Callendrello)
Yes, I see that.
21 Q
How was that number generated?
22 A
(Callendrello)
I don't know.
Evidently Mr.
23 Donovan put it in his exercise report from information that 24 he had available to either him or his observers or 25 evaluators.
Heritage Reporting Corporation (202) 628-4888 f
 
f REBUTTAL NO. 23 PANEL - CROSS
'23111 1
Q.
Okay.
;(G)
. 2.
A
-(Callendrello)
I don't know where that number 3
came from..
4 Q
Would you agree that roughly 25 to 26 percent of 5
'the -- I think this question may have been asked and I 6
apologize for asking it again, but I. don't quite remember-7 how you responded.
8 Would you agree that 25 to 26 percent'of the 9
special needs routes were not successfully completed based 10 on the numbers you just gave me?
~
11 A
(Callendrello)
Twenty-six percent were either not 12 completed or required controller intervention to complete.
13 So it was scored as a non completion.
14 Q
Now do you as an emergency planner. evaluate that n
15 as an adequate demonstration?
16 A
(Callendrello)
I would not rate it as an adequate 17 demonstration.
I think, in fact, FEMA has called that an 18 inadequacy that we need to improve the maps.
19 We have done some more analysis of what caused the 20 failures.
We looked at hospital routes and there were no 21 problems with the hospital routes.
All seven were run 22 successfully.
23 We looked at the nursing home routes, and eight 24 out of nine were run successfully.
25-We had a problem with the special needs -- with Heritage Reporting Corporation f''g (202) 628-4888 9
 
REBUTTAL NO. 23 PANEL - CROSS 23112 1
the transit-dependent routes.
And as a result, and we 2
analyzed that and found that the maps were the cause of the 3
problem.
And as a result, we have gone, and in our 4
enhancing the maps to improve their readability and the ease 5
of following.
So we think we understand the inadequacy or 6
what caused the inadequacy, and we are resolving the 7
problem.
8 O
So, I guess you did agree with me that having 26 9
percent of the routes not successfully run was not adequate 10 and it was not deemed adequate by FEMA?
11 A
(Callendrello)
It was an inadequacy or an issue 12 identified by FEMA.
I would agree with that, yes.
13 Q
So we are in the position of assuming that the 14 correction of the maps will correct the problem?
15 A
(Callendrello)
We are taking the action we think 16 will solve the problem.
17 You know, this has been an evolving process.
As 18 Mr. Brock pointed out yesterday, in 1986, the exercise was 19 run and there were problems with the maps.
And I can attest 20 that the maps were of very poor quality.
They were 21 photocopy street maps, and they were very difficult to 22 follow.
23 We improved those.
We obviously improved them 24 substantially.
We had a high success rate, 74 percent 25 completion rate on these, and even higher on the other types Heritage Reporting Corporation (202) 628-4888
 
7 REBUTTAL NO. 23 PANEL - CROSS 23113 1
.of routes.
,o -
T
/
2 We still identify that there were problems with w/
3 the maps and improvements we had to make to the maps.
And 4'
we are making those improvements.
5 Q
But the assumption that that's the problem has not
.6 yet been tested?
7 A
(Ca11endre11o)
I hesitate to say it's an 8
assumption.
We have evaluators and controllers on those 9
buses who observed firsthand what the problem was.-
If an 10 individual, a driver said, "I can't follow this map", we're 11 not making an assumption.
We know that there is a problem 12 with the map.
13-Q Okay.
Maybe I should say that the solution that' 14 you've implemented was not yet tested?
The solution to the
\\
15 perceived problem has not yet been tested?
'; w/
16 A
(Callendrello)
We are verifying and validating 17 that the maps are accurate, and that there were sufficient 18 landmarks.
We have not tested them, I believe, in any 19 exercise.
We certainly haven't had an exercise since then.
20 A
(Gram)
Yes, they have not been tested in a FEMA-21 evaluated exercise.
But the map upgrade program, that I 22 call it, is or does go through a testing problem.
23 We have evaluation teams that are giving copies of 24 the new maps and told to go out and run the routes.
We also 25 have a QC program where we have actual QC personnel from the Beritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23114 1
Seabrook site that do a follow-up verification for the whole 2
process.
And we've also used the upgraded maps for road 3
rallies for the Massachusetts ORO, in recent road rallies.
4 And the comments that come back are, you know, it 5
solved the problem.
6 Q
Have they been tested in the New Hampshire side?
7 A
(Gram)
I can't answer that question.
I don't 8
know.
9 Q
Okay.
10 JUDGE SMITH:
What's an ORO road rally?
11 (Laughter) 12 MS. DOUGHTY:
Sounds like fun.
13 THE WITNESS:
(Gram)
We run drills as part of 14 training sessions for the route guides for the ORO, the 15 Massachusetts response organization.
Where they are 16 actually mobilized and given a set of routes to run with the 17 new maps, and they actually go out and run a complete route 18 or several complete routes using the new maps.
And then we 19 verify that process through debriefings and actual 20 controllers participating in the process.
21 JUDGE COLE:
But you don't give prizes or anything
~
22 like some road rallies might?
23 (Laughter) 24 THE WITNESS:
(Gram)
No.
25 Heritage Reporting Corporation (202) 628-4888 f
 
(
~
l' REBUTTAL NO. 23 PANEL - CROSS 23115 I
1 BY MS. DOUGHTY:
s 2
Q I guess I would like to. move onto another line.
(v) 3 Turning to page 30 of your testimony.
4 1 guess I forgot one little question on the last 5
line.
Mr. Brock covered most of the area, but there are 6
really three aus. companies that actually provided buses on 7
the New Hampshire side of the exercise.
8 Is that not correct?
9 A
(Baer)
There were three bus companies that 10 provided buses.
There was another organization that 11 provided a wheelchair van, and a fifth organization provided 12 an ambulance.
13 Q
Now beyond those organizations, were calls 14 actually made to the other providers of service during the
;!(
)
15 actual exercise scenario, the other New Hampshire providers?
v 16 A
(Baer)
As I said yesterday that initially calls 17 were made to the providers according to the procedure that 18 the' persons with that responsibility had.
19 0
So every single bus company and ambulance company 20 and --
21 A
(Baer)
I can't say that every single one was 22 contacted.
But initially all of the companies in their 23 procedure were called, or attempts were made to call them.
24 1
25 Heritage Reporting Corporation
/''N (202) 628-4888 i
1 l
w-1 D
 
REBUTTAL NO. 23 PANEL - CROSS 23116 1
Q Was any documentation of how successful the 2
attempts were, kept?
3 A
(Baer)
Yes.
4 And I believe that was provided, but there was 5
some documentation to that effect.
6 Q
You appear to have it available there.
7 Maybe if you do we could get the definitive 8
answer.
9 A
(Baer)
I'm looking to see whether'I do have it.
10 (Witness reviewing document.)
I 11 THE WITNESS:
(Baer)
I think as I said, also, 12 they were called initially, according to an exercise 13 controller message.
And a prescribed message was read to 14 the bus companies that were contacted that asked them --
l 15 advised them of the exercise being conducted that day and 16 asked them if they wish to participate.
17 From the records I have, all of the companies that 18 are indicated in their procedure, but one, appear to have 19 been contacted.
20 BY MS. DOUGHTY:
21 Q
What was the name of that company, just for 22 purposes of the record?
23 A
(Baer)
The one organization that wasn't 24 contacted?
25 That appears was not contacted was actually the Heritage Reporting Corporation (202) 628-4888
 
. REBUTTAL NO. 23' PANEL - CROSS 23117
.l'.
Dover,.New Hampshire School District.
gg
~
-Q-
-Now, I can move on to the next'line, and this.has,
( f.
2 3
to>do.with-the ambulances.
'4
, Turning to your testimony.at'page.30'there is:a 5
citation to some FEMA guidance which I believe-is appended 6
as' Attachment B to your' testimony..
7 I'm asking, was it reliance on'this guidance that.
8
-- I guess your testimony says: "The Extent of Play for this 9
objective was implemented principally by FEMA guidance."
10-And.this is-the FEMA guidance that implements the 11 Extent of_ Play in regard to ambulance demonstration?
12 A
(Callendrello)
Yes. As regards to the number.of 13 individuals simulated contaminated injured individuals that' 14:
need to be handled by the exercise.
15 Q
.I'm just trying to relocate again where that 16 particular statement appears in Attachment B.
'It will take 17 me a' minute.
18 A
(Callendrello)
It's at the very bottom of page 3.
19 Q
I see.
20 It's in the next to the last paragraph on page 3 21 of 4.
~
22 A
(Callendrello)
No, it's not.
23 It's the very last sentence of page 3.
24 Q
Oh, I see.
Okay.
This is similar.
25 Now this guidance refers up above to an annual Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23118 1
medical emergency drill, does it not?
2 A
(Callendrello)
No, it does not.
3 The title of that is, " Medical emergency drills 4
and exercises." And the very first sentence under that 5
section which is at about the middle of page 3 talks about 6
the demonstration in annual emergency -- annual medical 7
emergency drills and biennial exercises.
8 O
I see.
9 Did you draw any distinction between the biennial 10 exercise and the qualifying exercise?
11 You assumed that this reference to biennial 12 exercise applies also to the qualifying exercise?
13 A
(Callendrello)
Yes.
As regards to the 14 demonstration of that objective.
15 Q
Could we refer to Applicants' Exhibit 43 (f), FEMA 16 exercise report.
I believe it's at page 186 for the 17 ambulance.
18 A
(Callendrello)
I've got that.
19 Q
Now, that objective was not met, is that correct?
20 A
(Callendrello)
Page 186, next to evaluation for 21 objective 23 it says, "not met."
22 Q
And there were two issues identified under that 23 objective?
24 A
(Callendrello)
That's correct.
25 Q
Now, ar page 187 the first full paragraph under Heritage Reporting Corporation (202) 628-4888
 
REEUTTAL NO. 23 PANEL - CROSS 23119 i
'l-
" procedures" the' statement appears: "The attendant was not i}
,1(
j L2 familiar with the procedure and did not have a copy in the-3' ambulance."
Is that --
4:
_A (Callendrello)- I'm sorry.
5 Oh, I see it.
6 Q
Yes.
o 7
"The attendant was not familiar with the procedure 8
and did not have a copy in the ambulance."
l 9
A (Ca11endre11o)' That's what it says, yes.
10' Q
That would suggest, would it not, that that was 11 not a routine procedure?
Was not a matter of the ambulance-12 driver's normal routine?
13 JUDGE. SMITH:
What procedure are you talking 14 about, covering the patient with a' blanket?
{
15 MS. DOUGHTY:
It's the whole procedure as
\\
16 described at page 187.
It's the first full paragraph.
17-JUDGE SMITH:
Okay.
18 MS. DOUGHTY:
And it starts out " procedures."
19 THE WITNESS:
(Callendrello)
As I understand'the 20 question, you are asking me if this indicates that the 21 transport of contaminated injured individuals is not part of 22 their normal day-to-day routine, I would say, yes.
23 I would say, the transportation of individuals is 24 part of their normal day-to-day routine.
25 But this is not one of those cases where that Heritage Reporting Corporation
['
(202) 628-4888
'(
r
 
REBUTTAL NO. 23 PANEL - CROSS 23120 1
other constraint entered into the consideration of the 2
Extent of Play.
3 As we said in our testimony on page 30, we went to 4
FEMA guidance to determine the Extent of Play for 5
contaminated injured individuals.
6 And then Attachment C, it clearly indicated that a 7
single individual is the Extent of Play for a biennial 8
exercise, and in this case, the qualifying exercise.
9 BY MS. DOUGHTY:
10 Q
Again, I would ask if you are aware of the 11 ALAB-900 discussion of the ambulance -- the extent of the 12 ambulance test in the Shoreham exercise?
)
13 A
(Callendrello)
What page is that on?
14 O
This would be page 42 of the slip opinion.
15 A
(Callendrello)
That was a different issue.
That 16 was not contaminated injured individuals, as I recall.
17 Q
Well, did you test ambulances -- how many 18 ambulances did you test other than for this contaminated 19 individual issue?
20 A
(Callendrello)
Just give me one moment.
21 (Mitness reviewing document.)
22 THE WITNESS:
(Callendrello)
On page 60 of our 23 testimony we indicated that one ambulance and crew was 24 mobilized in support of special population evacuation.
l 25 Heritage Reporting Corporation (202) 628-4888 l
t l
t
 
REBUTTAL NO. 23 PANEL - CROSS:
23121.
)
}
l BY-MS. DOUGHTY:
y
:(
j 2'
O.
And you' determined that that was an adequate-3 demonstration of that capability to test one ambulance?
4-A (Callendrello)
New Hampshire Yankee, State of New 5
Hempshire, and FEMA and NRC jointly determined that.that:was 6
an acceptable Extent of Play in light of the. constraints 7
that were discussed in the testimony.
8 Q
Would the -- strike that.
9 So overall there were two ambulances tested, then 10
.if I understand correctly, one for special needs 11
' individuals; and one to transport a contaminated injured 12 individual.
13 Is that a correct characterization?
14 A
(Callendrello)
Yes, that's correct.
O n(
15 Q
Now, are you aware that in ALAB-900, the Licensing
.\\
16 Board concluded that performance of only one ambulance and 17 one ambulette was' inadequate?
Is a test of sufficient-18 number of ambulances at Shoreham?
19 A
(Callendrello)
I'm aware as to what they 20 concluded, but it'was a different situation.
21 There, there had been no assessment of the 22 preparedness of the ambulance companies.
At the Seabrook
~
23 site, FEMA as Mr. Donovan described, did an evaluation of 24 the resources.
You will recall, that's one of the legs of 25 the four legs he said was part of his evaluation.
Heritage Reporting Corporation (202) 628-4888
-~
\\s /-
 
REBUTTAL NO 23 PANEL - CROSS 23122 valuation of the resources; therefore, 1
He did an t
2 he had performed the assessment of the preparedness of the 3
ambulance companies.
4 So the situations are totally different.
5 Q
But at least in terms of the one ambulance tested 6
for contaminated injured, the attendant was found not 7
prepared; wouldn't you agree with that?
8 A
(Callendrello)
It's not my understanding that 9
ALAB-900 nor the Frye Board decision went to contaminated 10 injured ambulances.
11 There, what drove the Extent of Play was the 12 guidance that FEMA provided on the scope of the biennial 13 exercise.
14 Q
So your decision to test one ambulance for 15 contaminated injured, I think I already have the answer to 16 this, but was that MS-1 at Attachment b7 17 A
(Callendrello)
Yes, that's correct.
18 Again, throughout this process FEMA and NRC were 19 involved in the discussions, and the states were involved in 20 the discussions in establishing the Extent of Play.
21 Q
And you said there were no other constraints to l
22 testing more, but it was just based on your understanding 23 that you figured this guidance memo, was all you needed to 24 do?
25 A
(Callendrello)
No, I didn't say there were no Heritage Reporting Corporation (202) 628-4888 f
 
REBUTTAL NO. 23 PANEL - CROSS 23123 1
other constraints.
.o
)
2-QL I thought you had said that.
I'm sorry.
3
.Would you care to clarify?
4 A
(Callendrello)
There are always other 5
constraints.
t..
6 In this case, ambulances in particular, there was 7
the constraint of taking ambulances ~off the road that would 8
normally be needed to provide public safety functions or 9
transportation for persons who are in need of medical 10 transportation in order to. enhance their public safety.
11 Q
If the ambulance that you had been using during 12 the exercise had been needed, you would have released it; 13 wouldn't you have?
14 A.
(Ca11endre11o)
I'm sure we would have.
I 15 Q
Are you saying --
(
16 A
(Ca11endre11o)
Depending on what the need is.
17 Obviously, not to go show up in-the.Old Home Day parade, but 18 if there was a medical emergency, obviously, we would 19-release that ambulance.
20-Q I would like to move on to your testimony about 21 the testing of the New Hampshire sampling teams.
22 I just simply want to, on this issue, ask you, 23 there's a sentence that begins at the bottom of page 32 that 24 says:
"During the development of the Extent of Play portion 25 of the exercise scenario representatives of the New Heritage Reporting Corporation (202) 628-4888
\\
f
___m_..m__
 
REBUTTAL NO. 23 PANEL - CROSS 23124 1
Hampshire Division of Public Health Services (NHDPHS) 2 requested the participation of two sampling teams on Day 2 3
of the exercise in order to limit the impact on normal state
)
i 4
agency operations."
q 5
And I would just like to know why was it less of a 6
limitation to have the teams on Day 2 than to have the teams
]
7 on Day 17 8
A (Gram)
I'm sorry, your question is not clear.
9 But what is meant to be said here in this 10 testimony is, this deals with ingestion pathway sampling 11 teams and they weren't dispatched until Day 2.
That's part 12 of the normal exercise scenario.
13 Q
There's no environmental sampling done during the 14 actual radiological emergency?
No collection --
15 A
(Gram)
There's plume tracking sampling.
16 Q
There's the monitoring function.
17 But there is also an environmental sampling 18 function which is separate.
So you're saying that none of 19 that is done on Day 17 20 A
(Baer)
Not for the purposes of ingestion pathway 21 actions.
The monitoring of sampling that is conducted on 22 Day 1 is for the purpose of formulating and confirming 23 protective action recommendations.
24 Q
Now, I'm not sure if you were there, but on the 25 New Hampshire portion of the litigation there was some Heritage Reporting Corporation (202) 628-4888
 
I REBUTTAL NO. 23 PANEL - CROSS 23125 ef-1--
testimony that DPHS field sampling teams could go out and 2
check the water that was coming out of the reception.
~3
' decontamination areas..
4 That would be this type of a team, would it not?
.5 A
(Callendrello)
I'm recalling back to that 6
testimony.
7 I don't believe that's the case.
'I think there is 8
another department within the State of New Hampshire.
And 9
maybe Mr. Baer can clarify.
That is responsible for 10 obtaining. water samples.
11' Q
So there is more than one environmental sampling?-
12 JUDGE SMITH:
Is this in contrast to. ingestion 13 sampling?
14 MS. DOUGHTY:
Yes.
f.
I
\\
15' There is environmental sampling that goes on, I
'(,)
16 believe, even during the plume. portion of the response.
17 JUDGE SMITH:
But what is the relationship between 18 that and the ingestion sampling?
19 MS. DOUGHTY:
Well, I'm not even trying to get 20 into the ingestion pathway at all.
I'm just trying to stay 21 with Day 1 response.
22 MR. LEWALD:
Is this waste water sampling?
23 MS. DOUGHTY:
Well, I was just using that as an 24 example.
But I'm talking about environmental sampling 25 generally.
Heritage Reporting Corporation
.f (202) 628-4888
[L L
 
l REBUTTAL NO. 23 PANEL - CROSS 23126 j
1 I'm wondering -- just trying to probe this 2
statement in the testimony that they seem to have some 3
limitation on normal state agency operation supplying the 4
two sampling teams on Day 1, so they supplied them on Day 2.
5 And I'm just wondering why that was.
6 THE WITNESS:
(Callendrello)
As Mr. Gram 7
explained, the concern the state had was on the number of 8
personnel.
They did not say, we want to demonstrate them on 9
Day 2.
10 The scenario -- during the scenario Day 2 events 11 were the ingestion pathway, ingestion sampling events.
The 12 Day 2 of the exercise clause in that testimony is just to 13 give clarification.
14 BY MS, DOUGHTY:
15 Q
Are these same personnel doing some other function 16 on Day 17 Were they doing some other function, these very 17 same personnel?
18 A
(Baer)
No, they weren't; they were different 19 personnel.
20 Q
On Day 2 do you know why the full complement of 21 teams, 100 percent of these teams couldn't be deployed?
22 JUDGE SMITH:
Day 27 23 MS. DOUGHTY:
Yes.
Now we're accepting --
24 THE WITNESS:
(Gram)
My recollection of the 25 limitation or the problem that the state had is, they didn't Heritage Reporting. Corporation (202) 628-4888
 
r.
.c REBUTTAL NO. 23' PANEL - CROSS 23127 E.s 1
want.to shut down their state lab for other. types of'
~
2'
. emergencies'that might happen.
They didn't want to-commit-
[
3 to that'for the' day of the drill.
~4 BY MS.-DOUGHTY:
l:
l 5
Q So supplying two more people would have required-6 them, perhaps, to have to shut down the state lab?
7 A
(Gram)
That's what they said.
8 Not to shut down the state lab, but to shut down 9
the ability to go out and take field samples for a hazardous 10 waste spill or an oil spill or something like that; that was 11 their concern.
12 Q
I have just one question about the establishment 13 of. access. control points and traffic control points.
14 To the extent that a local community was not
,_s 15 participating and established no points, there was-no test
(,
16 of the capability to go in and establish compensatory.
17 traffic control points, was there?
18 A
(Ca11endre11o)
That's not a true statement.
19 There was a demonstration.
In fact, I indicated 20 yesterday that one of the traffic control points that the 21 state police manned was Town of Hampton traffic control 22 point which would have been compensatory response.
23 Q
Was that the only compensatory response for a 24 nonparticipating community in this?
25 A
(Callendrello)
There was also a point manned in Heritage Reporting Corporation (202) 628-4888 x
1
_________-_____f
 
REBUTTAL NO. 23 PAEEL - CROSS 23128 1
Northampton which was compensatory.
2 Q
But there was only one manned in each of those 3
communities and there were four nonparticipating communities 4
for which there was no compensatory action taken; is that 5
correct?
6 A
(Callendrello)
There were no troopers who showed 7
up in those locations.
There was consideration of how those 8
points would be staffed through compensatory measures of the 9
state police; and that was handled at the incident field 10 office and Troop A.
11 But there were no troopers placed in the field for 12 those other communities in a compensatory fashion.
13 Q
Now, I believe you recall that there was some 14 controversy in the litigation on the New Hampshire side 15 about the adequacy of personnel to completely staff the 16 reception and decontamination functions.
17 Do you recall that, Mr. Callendrello?
18 A
(Callendrello)
That was an issue that was 19 certainly litigated.
We provided testimony on that.
But I 20 think the Board has issued a decision, so I guess in my mind 21 it's a resolved issue.
22 O
And insofar as there is a decision not to staff 23 all four of the host community reception centers, was that 24 decision in any way driven by shortages of DPHS personnel?
25 A
(Gram)
The answer to your question is, no.
It Heritage Reporting Corporation (202) 628-4888 i
 
- - - _=
-___7_
REBUTTAL NO. 23 PANEL CROSS 23129-gl-wasn't driven by any shortages in personnel.
It was, again, l
-2 driven by a concern on the state's part that they_did not 3
want to shut down all of their state functions in a 4.
.nonemergency situation.
5 Q
So can we-infer then, if they had-staffed all 6
_those functions it would require the shut down of normal 7
state functions in those areas?
8 A
(Gram)
I believe you have to ask all the 9
different state agencies that are involved.
10 But in'my mind that possibility could exist,-of 11 course, if there's an emergency.
12 Q
Now, the emergency worker facility at the Hillside 13 Junior High-School in Manchester was not tested 14 contemporaneously with the exercise scenario; is'that I(
15 correct?
16 A-(Callendrello)
That's correct.
17' Q
And your testimony presses the point that it's 11 6 similar enough to the normal reception center functions that 19 you didn't need to do a separate test of that facility; is 20 that correct?
21 A
(Callendrello)
The testimony is that the Extent 22' of Play took into account the fact that people are trained L
23 to provide monitoring and decontamination functions, whether-24 it's at the emergency worker monitoring decon facility or at 25 one of the other reception centers.
They receive the same Heritage Reporting Corporation (202) 628-4888
.\\
 
REBUTTAL NO. 23 PANEL - CROSS 23130 1
training.
Therefore, the capability to respond could be 2
demonstrated at one of the other reception-centers.
3 Q
Well, aren't there some respects in which the 4
emergency worker facility functions are going to be 5
different?
6 A
(Callendrello)
I'm sure there are.
There will 7
be a lot less people there, for one thing.
8 Q
Dut these are people who may have been exposed for 9
greater periods of time, since they were in the area of 10 carrying out the emergency response; is that not possibly 11 correct?
12 A
(Callendrello)
Well, there's a lot of assumptions 13 that go into that question.
Assuming they were in the plume 14 the entire duration of their assignment.
Assuming that they 15 were in the EPZ.
The potential exists for that, but I 16 wouldn't say that is by any means a certainty.
17 Q
Well, let's agree then that the potential exists 18 for that to be the case?
19 A
(Callendrello)
Okay.
The potential exists.
20 But I think it's a very -- I can't even put a 21 probability on it.
I'm not sure if it's great or small.
22 Q
No, I guess we can't do that.
We can't really 23 assign probabilities to various accident scenarios in 24 meteorological conditions.
25 A
(Callendrello)
In fact, it will be just as likely Heritage Reporting Corporation (202) 628-4888
 
l'l' REBUTTAL NO. 23 PANEL - CROSS 23131 1
that a member of the public would receive the same exposure.
g-Ik_
2 I can't make any assessment'of that likelihood.
3.-
Q All right.
4 But don't these individuals have dosimetry 5
equipment to check their overall exposure, and won't that
'6-need processing at the emergency worker facility?
7 A
(Callendrello)
Excuse me, I just want to check.
'8-(Witnesses conferring. )
9 THE WITNESS:
(Baer)
Would you repeat that again, 10 please.
11 BY MS. DOUGHTY:
12 Q
Well, the emergency workers are supposed to be 13 issued dosimetry so that-they have a cumulative record of 14 their overall exposure.
15 A.
(Baer)
Correct.
16 O
The general public evacuees don't have those.
17 A
(Baer)
Right.
'18 Q
Therefore they don't need to be processed at the 19 reception decontamination centers?
20 A
(Beer)
I'm not sure what you mean by " process."
21 The answer to the question is that, as I 22 understand it, is that the dosimetry is collected there and 23 it's processed elsewhere.
24 Q
So there's going to be no immediate feedback?
25 Assume for a moment that I was an emergency worker Heritage Reporting Corporation (202) 628-4888
\\
r X-_-_-__________-..
 
REBUTTAL NO. 23 PANEL - CROSS 23132 1
and I was at Hampton Beach for a number of hours and I 2
accumulated a dose above the recommended guidelines for an 3
emergency worker.
Nothing is going to be done to evaluate 4
that or to refer that person elsewhere at the emergency 5
worker facility?
6 A
(Baer)
Well, the reason the emergency workers are 7
provided with three different types of dosimetry, two of 8
which are self-reading dosimeters, so that exposure can be 9
monitored and recorded and recorded periodically so that 10 they don't exceed the exposure limits.
Or something can be 11 done before they exceed exposure limits.
12 So I'm not sure I understand --
13 JUDGE COLE:
Aren't they required to read their 14 dosimetry and record it at periodic intervals?
15 THE WITNESS:
(Baer)
Every 15 minutes.
16 BY MS. DOUGHTY:
17 Q
When they go to the emergency worker facility 18 they're supposed to turn that in --
19 (Witnesses conferring.)
20 THE WITNESS:
(Baer)
Just to complete my prior 21 answer.
They're also issued TLDs, which are thermal 22 luminescent dosimeters which are processed and read 23 subsequent to their assignments.
And the results of which 24 they would eventually see.
l 25 l
Heritage Reporting Corporation (202) 628-4888 l
l t
 
h
~
L REBUTTAL NO. 23 PANEL - CROSS' 23133.
'~
r.)
1 BY:MS. DOUGHTY:
D^
n 1,
i 2
Q So that's not processed?
3 A
(Baer)
No.
4
.Q
.Immediately after the exercise?
5 A-
.(Baer)
No.
6 O'
But someone does collect that. instrumentation and 7.
keeps some records with' regard to that worker's exposure, do 8
they not?
9 A-(Baer)
That's correct.
10 And that's the responsibility of the Division of 11 Public. Health Services.
12 Q
.But that was not tested during the exercise?
13 A
(Baer)
The process of collecting dosimetry from 14 emergency workers was demonstrated during the exercise.
(
15 For example, for field monitoring. teams at the
.16 incident ^ field office.
I believe, also --
17 (Witnesses conferring. )
18 19 20 21 4
~
22 23 24 25 Heritage Reporting Corporation
/~h (202) 628-4888
.lj
 
REBUTTAL NO. 23 PANEL - CROSS 23134 1
THE WITNESS:
(Gram)
Dosimetry from emergency 2
workers was collected during the exercise.
Emergency 3
workers were notified in the course of the exercise not to 4
deactivate to go to Hillside Junior High School.
They were 5
told to go to the Dover reception center which was, in 6
reality, a more complicated Extent of Play than they are 7
trained to do.
8 They are trained to go to Manchester.
They were 9
diverted in the middle of the exercise or at the tail-end of 10 the exercise and told to go to Dover.
They did go to Dover 11 and they did turn in their dosimetry.
It was collected by 12 DPHS.
13 MS. DOUGHTY:
Okay.
14 BY MS. DOUGHTY:
15 Q
How extensive was the test of their capability to 16 provide compensatory personnel to assist special needs 17 individuals in the nonparticipating communities?
18 (Pause.)
19 A
(Callendrello)
Can you just give us one moment?
20 Q
Yes.
21 (Witnesses confer. )
22 A
(Callendrello)
Mr. Baer has got the information.
23 A
(Baer)
I don't have the Extent of Play directly 24 in front of me for that.
But from my recollection, those 25 actions were demonstrated, one, by the sheriff's, Rockingham Heritage Reporting Corporation (202) 628-4888
 
f REBUTTAL NO. 23 PANEL - CROSS 23135 1
County Sheriff's Department providing personnel.to local pf L 1,s-j transportation staging areas in the six communities.
2 l
3 Of course, the incident field office was staffed 4
by personnel known as local liaison officers for the purpose 5'
of carrying out notifications to facilities in those a
6 communities, and was staffed fully on the first shift 7
specifically for that purpose with nine local liaison 8
officers.
9 Q
The liaison officers.were at the IFO?
10 A
(Baer)
Ye s, ma ' am.
11 Q
And the sheriff's deputies were at the local 12 staging area?
13-A (Baer)
That's correct.
14 Q
No sne simulated an ability to go out into a AQ) 15
' nonparticipating cos.mundty to provide compensatory special
-j 16 needs assistance, did they?
17 A
(Callendrello)
What Mr. Baer has described is 18 what the compensatory plan is.
19 As I understand your question, that's not what the
- 20 compensatory plan says.
The compensatory plan says we 21 establish the liaison officer.
You establish'the local 22 transportation staging area.
And at that point the 23 resources are deployed in the manner that would be deployed 24 if the community was participating.
25 Q
But nobody actually deployed a resource to test Heritage Reporting Corporation (202) 628-4888
..(
 
REBUTTAL NO. 23 PANEL - CROSS 23136 1
that function, did they?
2 A
(Callendrello)
Routes were run in many of the 3
communities, including those that were nonparticipating or 4
assumed to be nonparticipating on the day of the exercise.
5 Q
Right.
But had we talked about earlier the bus 6
drivers drive the bus, check their dosimetry and find their 7
way with the map.
They don't actually get out and provide 8
assistance to a special needs individual.
9 Nobody was sent out to assist a special needs 10 individual in the course of the bus running its route, did 11 they?
12 A
(Callendrello)
Where I'm having trouble with the 13 question is that's not part of the compensatory plan as I 14 understand it.
15 Q
Well --
16 A
(Callendrello)
What you are asking is -- if what 17 you're asking is did a vehicle go to a special needs 18 individual in a nonparticipating town, I would have to 19 check.
I know we did have wheelchair vans and an ambulance 20 participate in the exercise.
Whether they went to a 21 participating or nonparticipating town, I don't recall 22 offhand.
But I could check that.
23 Q
So you are saying it's not part of the plan for a 24 special needs individual to receive actual assistance 25 boarding a bus?
Heritage Reporting Corporation (202) 628-4889 i
f
 
l
[
REBUTTAL NO.-23 PANEL - CROSS 23137
)
~
i je~'
1; A-
'(Callendrello)
That is part'of.the plan.. That's Ji L
\\-
-2 not part of the compensatory. plan.
That action is the same
.whether.a'communityLis-participating or not' participating.
3' i
The compensatory plan provides personnel to notify' 4.
facilities, to staff the local transportation l staging area, 5
6'-
and from that point on the bus driver doesn't know whether It doesn't affect how he 7
it's a compensatory response.
8 responds.
It's only the small components that are part of 9
the compensatory plan.
10 Q
Maybe I can put it more simply.
If I were a special needs individual in one of the 11 nonparticipating: communities, how would the compensatory 12
, plan assist me:in getting transportation if.I could not make-13 f3 -
14 it out to the bus route by myself?
.15 A;
(Callendrello)
We're going of. going;back over
\\_,)
ground I think we plowed in the plan litigation.
16 But people who have special needs were afforded 17 the opportunity and are annually. afforded the opportunity.to 18' 19
-register:those needs with the state office ef emergency The state evaluates those needs and assigns the 20 management.
21 proper resources, transportation resources, to ensure that that person cets the assistance that they need.
22 23 So to that extent, you, as a special needs 24 individual, would have your needs taken care of in advance Whether a 25 through the state response organization.
Heritage Reporting Corporation
:O.
(202) 628-4888 I
 
REBUTTAL NO. 23 PANEL - CROSS 23138 1
community is participating or not participating on the day 2
of an emergency would not affect whether or not you were 3
provided those resources.
4 O
Okay.
I'm trying to determine how this capability 5
was tested during the exercise.
And if I were a special 6
needs person and I put in a call to the IFO and the special j
7 population liaison took my call, and then told the bus 8
drivers at the local transportation staging area that I was 9
along a bus route and needed a ride, who would help me get 10 to the bus route?
11 And was that tested during the exercise?
12 A
(Callendrello)
If you needed help getting to a 13 bus route, you would not be told to go to a bus route.
A 14 vehicle would be sent to your home to pick you up.
15 Q
I believe there was one ambulance in Seabrook.
16 Were any ambulances assigned to the nonparticipating 17 communities to test?
18 A
(Callendrello)
If you give me a moment, I'll have s.
19 to check that.
20 (Witness reviews document.)
21 JUDGE SMITH:
While he's checking, I understood 22 there was some urgency that we rule on the objections to Mr.
3 23 Jones' testimony.
I don't see what the urgency is.
24 MR. BROCK:
No, I don't think there is urgency, 25 Your Honor.
That was just if there was going to be Heritage Reporting Corporation (202) 628-4888 f
 
REBUTTAL NO. 23 PANEL - CROSS 23139
[.
.1 additional-time.this morning..
A-2
-JUDGE SMITH:
Okay.
3
_(Pause.)
4
-THE-WITNESS:
(Callendrello)
I don't find any --
}
5 in looking_at the exercise documentation'I have, it~ appears s.-
-6 that_the special needs vehicles'were not sent to any towns 7
for which a compensatory response is being provided.
8' MS. DOUGHTY:
Okay.
9-BY MS.-DOUGHTY:
10 Q
And'my recollection was that there were only'36 11 ambulances dedicated to the New' Hampshire response, and that-12-
,18 of those,were dedicated to hospitals.
13' Is that a correct recollection?
14 A
(Callendrello)
That's pretty close to my 15 recollection.
16
.And when you say " dedicated to the response", that 17 is the planning basis for establishing the transportation 18 need for ambulances.
19 Q
And are those ambulance personnel the only 20 personnel dedicated to going out to the nonparticipating 21 communities to provide compensatory-assistance to special 22 needs individuals needing transportation?
23 MR. LEWALD:
Your Honor, we are getting, I think, 24 or we have been, but we seem to continue be somewhat at 25 distance from the exercise or the scope of the exercise, and Heritage Reporting Corporation
('''
(202) 628-4888
 
l REBUTTAL NO. 23 PANEL - CROSS 23140 i
1 we're back to the plan actually, the New Hampshire emergency 2
plan.
3 MS. DOUGHTY: ~ Well, I thought I had understood the 4
plan before, and I obviously had a disconnect of 5
understanding with the Panel and I was just trying to get it 6
clear what the plan is and who the personnel are, so I would 7
know even which personnel should have been tested.
8 BY MS. DOUGHTY:
9 Q
Do you need that question again?
10 A
(Callendrello)
Yes.
I'm sorry.
I didn't hear 11 it.
12 O
Okay.
I was asking if, in the nonparticipating 13 communities, the only compensatory personnel for providing 14 transportation assistance to special needs individuals are 15 the drivers of those ambulances we just discussed.
16 A
(Caltendrello)
No, that's not a true statement.
17 Q
Maybe I should just say:
Who are the personnel 18 for the special needs individuals in New Hampshire, and how 19 were they tested?
20 A
(Callendrello)
Personnel, and I'm interpreting 21 this to mean personnel who provide transportation resources, 22 because obviously there are other personnel who provide 23 assistance of some fashion or another to individuals.
24 There are a number of -- there are bus drivers who 25 run transportation routes.
There are bus drivers who would Heritage Reporting Corporation (202) 628-4888
 
L pi
' REBUTTAL NO. 23 PANEL - CROSS 23141' 1'
be.providing-evacuation bed buses for special facilities-
't
/"
?.
-{
'2.
that-required them.
There would be ambulance'personneltwho' A
'3 would drive' ambulances into those communities that?would-q L
4' require compensatory aseistance.
And.all of those l
.5' individuals would serve as special needs individuals.
q 6
. Q This is not a routine function for a bus driver,'
7 is'it?
-1 8
A.
(Ca11endre11o)
"This" being driving a bus route.
9 I think it is a routine function for a. bus' driver to drive a.
L
' 10 bus route.
11 There is no difference -- and I guess msybe where 12.
I'm having the problem with the question is, as far as the 13 bus 1 driver knows, he doesn't know whether'it's a 14 compensatory. response or not a compensatory response.
The
,[
15 bus driver is told to report to a local transportation
- 16 staging area.
17 If-it's a participating community, that 18 transportation staging area will be staffed by local 19 personnel.
If it's a community that's unable to staff that 20 staging area, it's staffed by sheriff's deputies.
21 The bus driver reports there, receives sua 22 assignment and goes and performs that assignment.
23 Q
Okay.
24 A
(Callendrello)
As far as the bus driver is 25 concerned, whether it's a compensatory or response makes no Heritage Reporting Corporation (202) 628-4888
?
 
REBUTTAL NO. 23 PANEL - CROSS 23142 1
difference.
2 Q
Okay.
Who drives to the home of the special 3
needs individual in the nonparticipating community?
4 A
(Callendrello)
The same type of individual who 5
would drive to a home of a special needs individual in a 6
participating community.
It makes no difference as far as 7
the transportation resource is concerned.
8 Q
Who is that individual?
I mean what --
9 A
(Callendrello)
Either an ambulance driver, an 10 evacuation bed bus drive, bus driver, wheelchair van.
11 Q
Okay, so the bus driver drives to the home.
12 What then?
13 A
(Callendrello)
The person gets on the bus.
14 Q
What if the person requires special needs 15 assistance?
16 A
(Callendrello)
Then we don't send a bus driver.
17 We don't send a bus.
We send an ambulance or we send a 18 wheelchair van.
19 MS. DOUGHTY:
Excuse me just a moment.
20 (Counsel confers. )
21 BY MS. DOUGHTY:
22 Q
Mr. Callendrello, do you recall how many special 23 needs individuals have been identified in New Hampshire?
24 A
(Callendrello)
No, I don't know.
25 Q
But again, we agreed before there are 36 Heritage Reporting Corporation (202) 628-4888
 
REBUTTAL NO. 23 PANEL - CROSS 23143 1
ambulances dedicated, 18-of them are designated for
(
hospitals, and the others have to deal with all the nursing 2
3 homes and special needs individuals.
4 Is that correct?
5 A
(Callendrello)
The planning basis -- that's what 6
the planning basis is.
Based on the identified need, that 7
need for ambulances has been established.
That's not all 8
the ambulances that exist or are under letter of agreement.
9 But that is the planning basis.
10 A
(Gram)-
If I might add, I understood your question-11 to say that those ambulances are all the resources provided 12 for special needs.
13 That's not the case.
People respond to a special 14 needs survey and they identify what their need is.
If the
,-.(/f 15 survey card says, I'm bedridden and I cannot get out of my x.
16 house, then the special needs program dispatches an 17 ambulance to that house.
18 If the special needs card says, I'm in a 19 wheelchair and I can get to my front porch but I need 20 assistance getting into some kind of transportation, then 21 there is a wheelchair van that's dispatched at this part of 22 the program.
23 JUDGE SMITH:
Ms. Doughty, what is your problem 24 with this situation?
25 MS. DOUGHTY:
Well, my problem is that they tested Heritage Reporting Corporation
(''g (202) 628-4888
?
f 1
 
l' l
l REBUTTAL NO. 23 PANEL - CROSS 23144 1
no capability to provide this compen.atory assistance to 2
special needs individuals in the nonparticipating 3
communities.
And providing special needs assistance is one 4
of the objectives that's supposed to be tested.
5 JUDGE SMITH:
Yes, but this problem of getting the 6
special needs person into the conveyance seems to have 7
obsessed you for some time in this cross-examination.
8 MS. DOUGHTY:
Well, yes, it has.
And I think it's 9
because there is just no --
10 JUDGE SMITH:
Every time you ask a question, zap, 11 right comes back +.he answer.
I mean, what is it that you 12 still think you have to know?
13 Express your concern.
14 MS. DOUGHTY:
Well, my concern is that there 15 wasn't a very large test of this.
And I suspect that one of 16 the reasons for that is that they have very few resources 17 dedicated to this, and the ambulances --
18 JUDGE SMITH:
But that's not the line of questions 19 you are asking that I heard.
20 MS. DOUGHTY:
Well, I was trying to -- we had some 21 lack of clarity in terms of what the plan actually -- who is
~
22 actually to provide those services.
And I'm learning that 23 it's the ambulances and in some cases buses are dispatched 24 for special needs as well.
But they haven't dealt with the 25 problem of having somebody get the special needs person onto Heritage Reporting Corporation (202) 628-4888 r
 
REBUTTAL NO. 23 PANEL - CROSS 23145 1
the bus.
[
t 4
2 JUDGE SMITH:
At least'two times I've heard him x
1 3'
explain now that if they can't get on the bus, they don't-4 get'on the bus.
5-MS. DOUGHTY:
But that presumes that they have 6
enough ~ ambulances ar.d people to assist them, and that.wasn't 7
tested.
8 JUDGE SMITH:.But.then you don't follow through, 9
though.
You keep.asking what if they can't get.on the bus.
10.
And he says, if they can't get on the bus, we send ~somebody 11-else.
You-have to follow through, or whatever.
.12 MS. DOUGHTY:
Okay.
13 JUDGE SMITH:
Or abandon it or whatever.
You are 14 stuck on this one issue.
[
15 In any event, would you wind up your examination
's.
16 for today?
17 MS. DOUGHTY:
All right.
18 BY MS. DOUGHTY:
19 Q
Mr. Callendrello, there were no shift changes for 20
' sheriff's deputies --
21 JUDGE SMITH:
I didn't intend to direct you to 22 move on to the next line.
I'm just pointing out our time 23-for this morning is -- I mean, don't change your line of 24 questioning because of my remarks.
25 MS. DOUGHTY:
Okay.
All right.
Heritage Reporting Corporation (202) 628-4888 N
f
 
REBUTTAL NO. 23 PANEL - CROSS 23146 1
JUDGE SMITH:
You are certainly-free to do that.
2 MS. DOUGHTY:
Okay.
3 (Laughter) 4 MS. DOUGHTY:
Then I guess I'm in a quandary as to 5
which is the better tack to take at th a point.
6 JUDGE SMITH:
I just want you to pick a time 7
convenient to you to break until Tuesday.
8 MS. DOUGHTY:
All right.
9 BY MS. DOUGHTY:
10 Q
Mr. Callendrello, we can agreement then, I.think 11 to wrap up that particular portion, that no test was made 12 during the exercise of the capability to assist a special 13 needs person to evacuate from a nonparticipating community?
14 A
(Callendrello)
No, I can't agree to that.
15 JUDGE SMITH:
Okay, now, here is what you had 16 better do.
You had better take the weekend and think about 17 this problem.
18 MS. DOUGHTY:
Okay.
19 JUDGE SMITH:
And come in freshly armed with the 20 questions that you need.
21 MS. DOUGHTY:
All right.
22 23 24 25 Heritage Reporting Corporation (202) 628-4888
 
5,.
3%, -
L.
l >
23147 1:
: JUDGE' SMITH:. Anything further before we adjourn
.2.
on the record?
A 3'
'(No response.)
4 JUD'GE' SMITH:
If not, we will adjourn.
5 (Whereupon,.at 11:14 a.m.,
the. hearing was 6
-recessed, to resume at 1:00 p.m.,
Tuesday, May 30, 7
1988.).
8 9
.10 11 12 13
.14 15 W
16 17 18 19 20 21 22 23' 24 25 Heritage Reporting Corporation (202) 628-4888
>,a
 
4 CERTIFICATE e-A)
This is to certify that the attached proceedings before the-United States Nuclear Regulatory Commission in the matter a
of:
e Name:- Public Service Company of New' Hampshire, et al.
(Seabrook Station, Units 1 and 2)
Docket No:
50-443-OL 50-444-OL
.(Off-site Emergency Planning)
Place:
Boston, Massachusetts Date:
May.26, 1989 were held as herein appears, and that this is the original O
i 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.
jsj l
?
(Signature typed) :
Donna L.
Cook Official Reporter Heritage Reporting Corporation HERITAGE REPORTING CORPORATION (202)628-4888 L
- _ - _ _ _ -}}

Latest revision as of 15:28, 16 March 2025

Transcript of 890526 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,042-23,147.Witnesses: JW Baer,Am Callendrello,Gr Gram
ML20247K060
Person / Time
Site: Seabrook  NextEra Energy icon.png
Issue date: 05/26/1989
From:
Atomic Safety and Licensing Board Panel
To:
References
CON-#289-8709 ASLBP, OL, NUDOCS 8906010197
Download: ML20247K060 (108)
v • d • e


Text

{{#Wiki_filter:___--___-__-______ __________-_____ = UNITED STATES k NUCLEAR REGULATORY COMMISSION RG3 A'_ ATOMIC SAFETY AND LICENSING BOARD In the Matter of: ) ) Docket Nos. PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et al., ) 50-444-OL ) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING O Pages: 23042 through 23147 Place: Boston, Massachusetts Date: May 26, 1989 .....................................==================== ; \\ L / o <'n i HERITAGE REPORTING CORPORATION OBkWR m 1120 L Street, N.W., Sake 648 Mp:d# g goMyGEA Washington, D.C. 20005 N

  1. a (202) 628-4888 9906010197 8005I6
F DR ADOCl:. 05000443 i

r s.

i I i 23042 l y UNITED STATES NUCLEAR REGULATORY COMMISSION l 'w h ATOMIC SAFETY AND LICENSING BOARD 3 i In the Matter of: ) ) Docket Nos. PUBLIC SERVICE COMPANY OF ) 50-443-OL NEW HAMPSHIRE, et al., ) 50-444-OL ) OFF-SITE EMERGENCY (SEABROOK STATION, UNITS 1 AND 2) ) PLANNING EVIDENTIARY HEARING l

Friday, May 26, 1989 Auditorium Thomas P.

O'Neill, Jr. Federal Building 10 Causeway Street Boston, Massachusetts [ml The above-entitled matter came on for hearing, () pursuant to notice, at 8:32 a.m. BEFORE: JUDGE IVAN W. SMITH, CHAIRMAN Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JUDGE KENNETH A. McCOLLOM, Member Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 JUDGE RICHARD F. COLE, MEMBER Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 l 7s Heritage Reporting Corporation ( (202) 628-4888 m

23043 j-%.. APPEARANCES: kw/ For the Applicant: THOMAS G. DIGNAN, JR., ESQ. GEORGE H. LEWALD, ESQ. KATHRYN A. SELLECK, ESQ. JAY BRADFORD SMITH,. ESQ. JEFFREY P. TROUT, ESQ. GEOFFREY C. COOK, ESQ. Ropes & Gray. One International Place Boston, Massachusetts 02110-2624 For the NRC Staff: SHERWIN E. TURK, ESQ. ELAINE I. CHAN, ESQ. EDWIN J. REIS, ESQ. RICHARD BACHMANN, ESQ. Office of General Counsel U.S. Nuclear Regulatory' Commission Washington, D.C. 20555 For the Federal Emeroency Manaaement Acency: . /-m ( H. JOSEPH FLYNN, ESQ. \\ LINDA HUBER McPHETERS, ESQ. Federal Emergency Management Agency 500 C Street, S.W. Washington, D.C. 20472 For the Commonwealth of Massachusetts: JAMES M. SHANNON, ATTY. GEN. JOHN C. TRAFICONTE, ASST. ATTY. GEN. ALLAN R. FIERCE, ASST. ATTY. GEN. PAMELA TALBOT, ASST. ATTY. GEN. MATTHEW BROCK, ESQ. LESLIE B. GREER, ESQ. Commonwealth of Massachusetts One Ashburton Place, 19th Floor Boston, Massachusetts 02108 Heritage Reporting Corporation (202) 628-4888 l \\m- ) ___________________________________j

23044 APPEARANCES: (Continued) O For the State of New Hampshire: GEOFFREY M. HUNTINGTON, ASST. ATTY. GEN. State of New Hampshire 25 Capitol Street Concord, New Hampshire 03301 For the Seacoast Anti-Pollution Leacue: ROBERT A. BACKUS, ESQ. Backus, Meyer & Solomon 116 Lowell Street P.O. Box 516 Manchester, New Hampshire 03105 JANE DOUGHTY, Director Seacoast Anti-Pollution League 5 Market Street Portsmouth, New Hampshire 03801 For the Town of Amesburv: BARBARA J. SAINT ANDRE, ESQ. Kopelman and Paige, P.C. 77 Franklin Street Boston, Massachusetts WILLIAM LORD Town Hall Amesbury, Massachusetts 10913 For the City of Haverhill and Town of Merrimac: ASHOD N. AMIRIAN, ESQ. P. O. Box 38 Bradford, Massachusetts 01835 For the City of Newburyport: BARBARA J. SAINT ANDRE, ESQ. JANE O' MALLEY, ESQ. Kopelman and Paige, P.C. 77 Franklin Street Boston, Massachusetts 02110 Heritage Reporting Corporation (202) 628-4888

r. l I o 23045 L-d I - APPEARANCES: (Continued) i-([m -}: s;j.D - For the Town of Newburv: R.. SCOTT HILL-WHILTON, ESQ. Lagoulis, Clark, Hill-Whilton & McGuire 79 State Street-r. Newburyport, Massachusetts 01950 For the Town of Salisburv: CHARLES P. GRAHAM,.ESQ. Murphy and Graham . 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 Licensine Board: [ ROBERT R. PIERCE, ESQUIRE ' Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Heritage Reporting Corporation (202) 628-4888 ' g N

23046 IHDEX WITNESSES _1. DIRECT CROSS REDIRECT RECROSS EXAM Panel No. 23: John W. Baer Anthony M. Callendrello George R. Gram by Mr. Brock 23049 by Ms. Doughty 23054 EXHIBITS: IDENT. REC. P.E J. DESCRIPTION: Massachusetts Attorney General: 106 23053 23054 FEMA response to TOH's first set of interrogatories dated 2-21-89 Heritage Reporting Corporation (202) 628-4888 l

i \\ 23047 1 EDEX INSERTS: PAGE (No inserts) i ( Heritage Reporting Corporation (202) 628-4888

l1 23048 EB2EEEE1 HEE 1 JUDGE SMITH: Good morning. 2 Is there any preliminary matters before we 3 proceed? 4 MR. LEWALD: None that I'm aware of, Your Honor. 5 I did understand that there was a motion in limine 6 that was to be argued sometime this morning, if time 7 permitted, after the testimony of the panel. 8 JUDGE SMITH: All right. 9 Mr. Brock? 10 MR. BROCK: Your Honor, just on that point, I 11 think there was discussion about that. I believe Mr. 12 Traficonte would be handling all that, although I don't know 13 if he was aware that he was to be here this morning for that 14 purpose. 15 (Counsel confers.) 16 MR. BROCK: I'm corrected, Your Honor, I 17 understand he will be coming. 18 Whereupon, 19 JOHN W. BAER 20 ANTHONY M. CALLENDRELLO 21 GEORGE R. GRAM, II 22 having been previously duly sworn, resumed the witness stand 23 herein, and was examined and further testified as follows: 24 Heritage Reporting Corporation (202) 628-4888

n-t REBUTTAL'NO. 23 PANEL - CROSS .23049 1 CROSS-EXAMINATION (Continued) ~w - <'.( 2 BY MR. BROCK: l: 3 Q Mr. Ca11endre11o, I would like to.just' follow-up 4 briefly on a couple points that.we touched on yesterday. 5 .Could you_ turn to page 51 of your testimony, 6 please. .Callendrello) I've got.that. ( 7. A 8 Q And at page 51 of your' testimony, again, focusing 9 on that-sentence which begins in the middle of the page: 10 " Communication and coordination were demonstrated with at-11' 'leastLone administrative representative of each of the five ~ 12 SAUs." 113 It is correct, is it not, that at least two of the 14 five administrative representatives were secretaries? ,,s (( 15 A (Callendrello) I believe we stated that we had no ' 16 indication in our records who had been contacted, although I 17 have no information to the contrary. 18 Q All right. 19 So it could have been a secretary, but you don't 20 know who was contacted; is that fair to say? 21 A (Ca11endre11o) That's correct. ~ 22 From the exercise records. 23 0 And you also stated, did you not, that you were 24 not aware of the content of the communications which are 25 referenced on page 51; correct? Heritage Reporting Corporation (202) 628-4888 \\

REBUTTAL NO. 23 PANEL - CROSS 23050 1 A (Callendrello) That's correct. 2 With the exception of the information that Mr. 3 Baer conveyed from the EOC player log. I have no idea what 4 the content was. 5 Q And you do not know, do you know, what response, 6 if any, the five SAUs did in response to the call? 7 A (Callendrello) No, I do not. 8 Although, maybe Mr. Baer can add something. 9 A (Baer) No, I don't. 10 Q And it's correct, is it not, that FEMA did not 11 have any evaluators at any of the New Hampshire SAUs 12 offices; correct? 13 A (Callendrello) I can check the exercise report. 14 I don't believe they did. But if you give me a 15 moment I will check the exercise report. 16 Q Right. 17 I'm looking at page 3.3-5 of the Extent of Play, 18 number one under " methodology." l 19 (Witness reviewing document.) 20 THE WITNESS: (Callendrello) In looking at the 21 FEMA exercise report on table 1 I do not see any evaluators 22 specifically assigned to an SAU, although there were five 23 evaluators assigned to evaluate the evacuation of schools. 24 BY MR. BROCK: 25 Q But you see nothing there to indicate that FEMA Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23051 'I actually had evaluators at.the SAU offices; correct? 2 A (Ca11endre11o) That's correct. 3 Q And it's also fair to say that FEMA did not have 4 any evaluators at any of the New Hampshire EPZ schools; 5 correct? 6 A (Callendrello) I don't think that's correct. 7 They did have evaluators who would have gone with 8' buses:that were traveling routes, and some of those routes 9 included-transits to schools. So that they would have had 10 evaluators who went with the buses or with the vehicles to 11 the schools. 12 -Q But those evaluators on the buses did not get out 13 and go into the facilities;.is that correct?. 14 A (Callendrello) I don't know what they did, but I 15 don't think that was the plan. 16 Q And that was also true in Massachusetts, correct, 17 FEMA evaluators were not at Massachusetts schools? 18 A (Callendrello) That's correct. 19 0 And it's fair to say, is it not, that during the 20 exercise FEMA did not obseree or evaluate the performance of 21 school personnel in carrying out protective actions for 22 school children? 23 (Witnesses conferring.) 24 THE WITNESS: (Baer) In the FEMA exercise report 25 for objective 19, FEMA did note that the Department of Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23052 1 1 Education -- they termed it the Board of Education -- this 2 is on page 181 of 428: "The Board of Education notified all 3 appropriate school districts of the precautionary protective 4 action." 5 So they did evaluate the performance of the 6 Department of Education representatives at the state EOC. 7 BY MR, BROCK: 8 Q I was focusing upon school personnel, not DOE 9 personnel. 10 But with that clarification, Mr. Baer, you would 11 agree that FEMA did not observe or evaluate school personnel 12 during the exercise for protective actions for school 13 children? 14 A (Baer) Unless there were school personnel located 15 at the local EOCs where there were FEMA evaluators. 16 O And you do not know that, do you, sir? 17 A (Baer) I know of one instance where that did 18 occur; yes. 19 Q Where was that? 20 A (Baer) That was in Portsmouth. 21 Q I would like to show you a document that -- 22 MR. BROCK: I apologize, Your Honor, I don't 23 believe we have complete copies, but they are on their way. 24 I have enough I think to make a limited distribution. 25 This would be Mass AG 106 for identification. And Heritage Reportirg Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23053 1 it's entitled, " Federal Emergency Management Agency's ~~ \\s,/, 2 . response to Town of Hampton's first set of interrogatories .3 and request for production of documents to FEMA on the 4 exercise." I have paraphrased briefly. Dated February 21, 5 1989. 6 (The document referred - 7 to was marked for 8 identification as 9 Mass AG Exhibit 106. ) 10 (Documents proffered to all parties.) 11 BY MR. BROCK: 12 -Q Mr. Callendrello, you have before you what's been f 13 marked as Mass AG 106; correct? 14 A (Callendrello) Yes, I do. [T(,) 15 Q And referring you to FEMA response number two. 16 It references, does it not, its reasons explained 17 in response number one and then states: " FEMA did.not 18 observe or evaluate the performance of school administrators 19 or other school personnel.in carrying out protective actions 20 for school children." 21 That is what it says; correct? 22 A (Callendrello) That is correct. 23 MR. BROCK: Your Honor, we would offer this. 24 MR. FLYNN: No objection 25 MR. LEWALD: I have no objection, Your Honor. Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23054 l 1 I assume that the underscoring in the document is 9l 1 2 the Massachusetts Attorney General's and not FEMA. 3 MR. BROCK: That is correct, Your Honor. 4 JUDGE SMITH: All.right. 5 Attorney General Exhibit 106 is received. 6 MR. BROCK: Thank you. 7 (The document referred 8 to previously marked for 9 identification as 10 Mass AG 106 was received 11 in evidence.) 12 MR. BROCK: And with that, Your Honor, I have no 13 further questions of the panel. 14 J'JDGE SMITH: Ms. Doughty? 15 MS. DOUGHTY: I'll distribute my cross-examination 16 plan. 17 (Document proffered to the Board. ) 18 CROSS-EXAMINATION 19 BY MS. DOUGHTY: 20 Q Good morning, gentlemen. 21 A (Callendrello) Good morning. ~ 22 Q I would like to begin by discussing 23 interpretations of FEMA guidance as presented by the panel j 24 in this testimony. 25 And I guess I would begin by inquiring as to who Heritage Reporting Corporation (202) 628-4888 i L

i l l REEUTTAL'NO. 23 PANEL - CROSS 23055 1. wrote the portion-of the testimony beginning at page 4 and . 's_,/ ! 2 concluding at'page 87 3 (Witnesses reviewing document.) 4 THE WITNESS: (Callendrello) The process for -5 writing this piece of testimony -- this section of the-6 testimony as well as the other was the same as the process 7 we've used throughout this proceeding. And that is, the 8 sections were originally drafted either directly by myself .- 9 or Mr. Baer or other members of my staff. 10 They were reviewed many times by the panel 11 members, modified. And then once we had reached agreement 12 that the testimony was accurate and complete,-we would give 13 it to Ropes and Gray and they would put it on their word 14 processing system and go through the mechanics of j_., k,) 15 reproducing it. -16 -BY MS. DOUGHTY: 17 Q Did you seek the advice of counsel as to whether 18 your discussion of the FEMA guidance on scope included all .19 the relevant regulatory' guidance and pertinent decisions? 20 A (Callendrello) Counsel reviewed the testimony. 21 I don't recall a discussion on that specific 22 point, though. 23 Q Okay. 24 Mr. Callendrello, are you familiar with ALAB-900? 25 A (Callendrello) Yes, I am. 1 Heritage Reporting Corporation , (s (202) 628-4888 l l

REBUTTAL NO. 23 PANEL - CROSS 23056 1 Q And that's not cited in this? 2 Specifically cited or perhaps I have missed it? 3 A (Callendrello) No, it is not cited. 4 Q Do you have a copy of the Code of Federal 5 Regulations? 6 A (Callendrello) I have some sections or some 7 selected excerpts. 8 Q Are you familiar with the Footnote IV in Appendix 9 E that refers to Section IV(f) (1) ? 10 A (Callendrello) Yes, I am. 11 O You're aware that that footnote talks about the 12 integrated capability to adequately assess and respond to an 13 accident at a commercial nuclear power plant? 14 A (Callendrello) It talks about several subjects. 15 It has got two thoughts that talk about what full 16 participation means in terms of the regulation. 17 Q How did you understand the concept " integrated 18 capability?" 19 A (Callendrello) My understanding of integrated 20 capability is in relation to the entities that are described I 21 earlier in that sentence. And that is: "The appropriate 22 offsite local and state authorities and licensing personnel l 23 physically and actively take part in testing their ~ 24 integrated capability to adequately assess and respond to an 25 accident at a commercial nuclear power plant." l Heritage Reporting Corporation (202) 628-4888 )

REBUTTAL NO. 23 PANEL - CROSS 23057 7y 1 So, in essence, the exercise should test the ( ) / \\_s' 2 capability of the organizations -- the integrated capability l l i 3 of the organizations to respond. 4 Q Okay. 5 Would you understand that to mean that things all 6 should be going on in an integrated flow contemporaneous 1y 7 with the scenario? 8 A (Callendrello) For some activities, yes, I do 9 believe that is what is meant by that. 10 Q How did you determine which activities should be 11 integrated and those which you weren't obligated to 12 integrate with the actual timing of the scenario? 13 A (Callendrello) During the development of the 14 scenario, the crafters of the scenario worked with FEMA and ~s 15 NRC representatives and determined which activities needed 16 to be demonstrated. I'll call it "in sequence" with the 17 scenario and which ones could be demonstrated out of 18 sequence because they involved verification, maybe some 19 mechanical aspect of the plan such as a map or a 20 transportation route, and were not required to be 21 demonstrated in sequence to show that integrated capability 22 to assess an accident, assess a situation, and respond in 23 the proper manner. 24 Let me add: one of the considerations for whether l 25 something was done in sequence or out of sequence, as we say 1 l 1 Heritage Reporting Corporation (f-w') (202) 628-4888 wJ

REBUTTAL NO. 23 PANEL - CROSS 23058 1 in our testimony, was the availability of evaluators for a 2 particular function. 3 FEMA did put a large number of evaluators in the 4 field. And even with that large number there were some 5 constraints as to how many activities could be observed at 6 the same time. So it was necessary to move some activities 7 out of sequence to both fully demonstrate the Extent of Play 8 and allow observation of it in evaluation of it. 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Heritage Reporting Corporation (202) 628-4888

d 1 REBUTTAL NO. 23 PANEL - CROSS 23059 'l Q Mr. Callendrello, wouldn't it have been possible t a f-~ 2 to run more buses.all at once even if the FEMA evaluators 3 couldn't evaluate every single.one? And if they didn't want 4' to. ride every bus route, they could have done that again 5 later the second day if they wanted to ride every single bus 6 route. 7 But couldn't you have tested the capability of 8 integrating the response of a number of bus companies all.at 9 once providing drivers within the timing of the exercise 10 scenario? 11 MR. LEWALD: I'm going to object to the question, 12 Your Honor. He's being asked as to what is possible with 13 the number of possibilities, and it borders on argument 14 really. 15. MS. DOUGHTY: Well, Mr. Lewald, the whole issue of 16 the scope of the exercise, the possibilities as to what was 17 reasonably achievable, had to be determined by the 18 participants and evaluators prior to the' exercise. So they 19 must have considered questions of what was possible to do 20 and what was reasonably achievable. 21 MR. LEWALD: I don't think the exercise is dealing 22 with a realm of possibilities. 23 JUDGE SMITH: Can you'rephrare it? Wouldn't it 24 have been reasonably achievable to acromrlish those 25 objectives. Heritage Reporting Corporation O (202) 628-4888

e REBUTTAL NO. 23 PANEL - CROSS 23060 1 MS. DOUGHTY: A much better way of stating it, 2 Your Honor. 3 BY MS. DOUGHTY: 4 Q I'll let you respond to that question then. 5 A (Callendrello) I'm sorry, c7uld you please just 6 repeat the question? 7 Q Wouldn't it have been reasonably achievable to 8 mobilize a much larger number of buses on the first day of 9 the exercise to test the integrated capability to respond? 10 And then if FEMA evaluators wanted to riie every 11 single route, they could have been rerun at a later time to 12 make it possible for the FEMA evaluators to do that further 13 check. 14 MR. LEWALD: This assumes, I assume, unlimited 15 resources by all of the players. 16 JUDGE SMITH: The idea, as I understand from the 17 question, is that you are suggesting that more buses weren't 18 run because the FEMA evaluators were used. And this is 19 where the logic of your question falls down, in my mind, 20 because the FEMA evaluators were used to run the routes. 21 And instead of what? 22 Just explain what you believe was the situation 23 and what, in your view, vould have been the better and more 24 reasonably achievable situation. Then we will put that to 25 the panel. Heritage Reporting Corporation (202) 628-4888

r REBUTTAL NO. 23 PANEL - CROSS 23061-L 1 MS. DOUGHTY: Okay. I believe Mr. Callendrello-4.i. \\ k,/ 2 was stating that one of the' limitations to their testing the s 3 integrated capability of certain aspects of the plan was the 4 limitation posed by the fact that they had a limited number 5 of FEMA evaluators to observe everything. 6 JUDGE SMITH: Right. 7 MS. DOUGHTY: So now I am saying that, or rather, 8 inquiring whether or not it would have been reasonably 9 achievable. 10 JUDGE SMITH: Couldn't they have used those FEMA 11 evaluators who ran the routes during the exercise, they 12 could run them anytime. Is that your point? 13 MS. DOUGHTY: No. My point is that they could 14 have tested all the buses, more buses together on day one k 15 contemporaneously with the scenario. And then if FEMA later 16 wanted to ride every single route, they could have done what 17 they~did in day two, which was have people traverse all the 18 routes out of the sequence of the exercise. 19 So I was inquiring as to whether it would not have 20 been reasonably achievable to mobilize more buses during the 21 actual exercise scenario to test the capab311ty to integrate l 22 all the -- 23 JUDGE SMITH: Of course, implicit in your b 24 question, too, and wouldn't that have been a better 25 demonstration, too. Heritage Reporting Corporation (202) 628-4888 l

l l REBUTTAL NO. 23 PANEL - CROSS 23062 1 MS. DOUGHTY: Right. 2 JUDGE SMITH: Can you answer that? 3 THE WITNESS: (Callendrello) That last phrase 4 clarifies it for me. 5 I can't just take that idea of reasonably 6 achievable in isolation. I've got to look at all of the 7 reasons why you have an exercise. And the exercise is to 8 test that integrated capability and evaluate the integrated 9 capability. And without having an evaluator observe the 10 function, it doesn't really add much to the exercise. 11 Whether it's achievable or not, it's not prudent, in my 22 mind, to demonstrate a resource, tie up a resource if it's 13 not going to evaluated. 14 BY MS. DOUGHTY: 15 Q Mr. Callendrello, couldn't that have been 16 evaluated from wherever FEMA, I assume at the EOC when the 17 state people, transportation coordinator made calls? 18 I'm talking about the New Hampshire portion of the 19 exercise at this point. 20 Couldn't that have been evaluated to see whether 21 indeed more bus companies could have been called and more 22 resources have been supplied? 23 It would have taken one FEMA evaluator to hear and 24 see the results of those calls. 25 A (Callendrello) Well, that's not the way I l l Beritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23063 1 understood your previous question. / \\ ' (,) 2 The way I understood your previous question is 3 wouldn't it'have been reasonably achievable to put more 4 buses on the road. 5 JUDGE SMITH: But also part of that question was, 6 and evaluate them. 7 THE WITNESS: (Callendrello) Right. 8 No. With that clarification, no, I don't believe 9 it was reasonably achievable. 10 MS. DOUGHTY: Well, I think that there could have 11 been some limited evaluation. If the bus companies had said 12 they had tried to mobi3ize more buses and the companies that 13 said, no, we can't provide them, that would have been 14 something that would have been evident to the FEMA evaluator p c( 15 at the state EOC, would it not? 16 JUDGE SMITH: Let's relax the method of asking 17 questions. Let's put out on the table just what your 18 concept is and give them a chance to comment on it. 19 But wouldn't your approach have produced buses 20 pointlessly without evaluators? 21 MS. DOUGHTY: Well, another way to evaluate it 22 would have been -- 23 JUDGE SMITH: Well, is that an aspect of your 24 question? 25 I mean, let's put the parameters around your Heritage Reporting Corporation ,_s / (202) 628-4888 \\

l-1 REBUTTAL NO. 23 PANEL - CROSS 23064 1 1 question and your concerns. 2 MS. DOUGHTY: No. I think there are ways that 3 they could have evaluated it. They could have seen if the 4 bus companies could have run -- they also had FEMA 5 evaluators at the state transportation staging areas. So if 1 ) 6 the Applicants had made an effort to mobilize more buses and 7 get them to the state staging areas, it wouldn't have 8 required a FEMA evaluator to ride every single route to see 9 whether the buses could be mobilized. 10 They could have stood at the staging areas and 11 seen those buses arrive. 12 MR. FLYNN: Your Honor, it sounds to me like the 13 same line of questioning that Mr. Brock was pursuing the 14 other day. And that is, that the verification of the 15 resources or the availability of the resources of the bus 16 companies that were not actually planning the exercise was 17 done at a completely different time. 18 I don't see what this adds to that. 19 MS. DOUGHTY: Well, Mr. Flynn, I'm just testing 20 whether it was reasonably achievable to better test the 21 integrated capability to respond. 22 MR. FLYNN: It's a legitimate line of questioning. 23 My point is that it's already been covered. 24 MS. DOUGHTY: I'm sorry. I missed a word you 25 said. Is it a what line of questioning? Heritage Reporting Corporation (202) 628-4888

I REBUTTAL NO. 23 PANEL - CROSS 23065 l l 1 MR. FLYNN: It's a reasonable -- I \\ , (,/ 2 MS. DOUGHTY: Reasonable. 3 JUDGE SMITH: There's no objection. 4 MS. DOUGHTY: All right. 5 BY MS. DOUGHTY: 6 Q Mr. Callendrello, wouldn't it have been possible 7 to evaluate more busos by having the FEMA observers 8 determine whether bus companies were able to mobilize 9 additional buses to the state transportation staging areas? 10 A (Callendrello) It would have been possible to 11 evaluate that one isolated component. 12 I've got to keep going back to the Footnote 4 that 13 you directed me to earlier and read the second thought of 14 that, because that's important in my answers. ( ) 15 And the footnote says, "' Full participation' 16 includes testing the major observable portions of the onsite 17 and offsite emergency plans and mobilization of statt. local 18 and licensee personnel and other resources in sufficient 19 numbers to verify the capabi2ity to respond to the accident 20 scenario." l 21 We had sufficient numbers to achieve tha+ goal, to 22 verify the capability to respond. To take additional buses, 23 put them on the road unevaluated does not do anything to 24 verify the capability to respond. 25 Q Well, again, how did FEMA evaluate the capability ) Heritage Reporting Corporation f} (202) 628-4888 l V -________ _ _ _J

REBUTTAL NO. 23 PANEL - CROSS 23066 1 to get the buses to the state transportation staging area 2 from the bus companies? 3 A (Callendrello) Through the buses that were 4 provided. 5 Q In other words, they stood at the state T 6 transportation staging areas and saw what arrived? 7 A (Callendrello) For that aspect of the objective, 8 yes. 9 O So for at least that aspect of the objective many 10 more buses could have been mobilized and that could have 11 been evaluated; is that not true? 12 A (Callendrello) If you are saying couldn't more 13 buses have been mobilized, sent to the state transportation 14 staging area and then released, I suppose that's possible, 15 but I don't see how that adds anything to the demonstration 16 of the exercise. And certainly that was not the Extent of 17 Play agreed upon by all of the exercise participants and 18 avaluators. 19 0 Was it 20 buses that were run contemporaneous 1y 20 with the scenario, Mr. Callendrello? 21 A (Callendrello) That's correct. 22 Q Now could you refresh my recollection that 23 something in the nature of 533 buses were required for the 24 New Hampshire exercise? j i 25 A (Callendrello) For simultaneous evacuation of all ) k \\ l l i l Heritage Reporting Corporation l (202) 628-4888 l 1 1

REBUTTAL NO. 23~ PANEL - CROSS 23067 1 portions-of the New Hampshire'EPZ, that's my recollection of f-- N,, 2 the nusoer, or close to that. s 3 O And you believe that 20 buses is a reasonable 4 demonstration of the capability to provide 533 buses? l-5 A' (Callendrello) Yes, because that's one component. 6 Physically having a bus'show up at a staging area and-7 physically run a route is only one component of the function 8 that's being demonstrated. There are other components: the 9 assessment of!the need, assessment of the supply, assignment: 10 of the resources. The actual field activities are only one 11 component of that. 12 And in my opinion, 20 buses is a sufficient-13 demonstration, and that was the agreed upon level o'f 14 performance that FEMA and the other participants needed to 15 provide to verify the capability to respond. 16 Q Okay. 17 A' (Callendrello) I might add, though,'that there 18 were 20 buses provided, but there were many more routes run 19 than just 20 routes. There were, I believe it was 118 20 routes run for schools, and 66 routes run for special 21 populations. So it was a more extensive demonstration than 22 just the 20 routes. 23 Q Okay. But again, those additional routes were not 24 run contemporaneously with the scenario, and many of them 25 were run on the second day. Heritage Reporting Corporation j-- (202) 628-4888 g L

LEBUTTAL NOc 23 PANEL - CROSS 23068 1 Is that not true? 2 MR. FLYNN: Excuse me. I would like to ask for a 3 clarification. 4 Is the implication here that the scenario should 5 have been extensive enough to necessitate an evacuation of 6 the entire EPZ at one time? 7 JUDGE SMITH: No. She's suggesting -- well, you 8 answer it. But she's suggesting something more than 20 9 buses should have been -- 10 MR. FLYNN: The problem lies in the extent of the 11 scenario. Is that the implication of the question? 12 MS. DOUGHTY: Did you say the extent of the 13 scenario, or did you mean the Extent of Play? 34 MR. FLYNN: Yes. Your line of questioning 15 suggests to me that what you are trying to establish is that 16 the scenario wasn't broad enough to require a response of 17 more than 20 buses. And I'm just checking that out. 18 MS. DOUGHTY: Well, I don't think that's a quite 19 proper interpretation. The scenario was for a full 20 evacuation, so the scenario wasn't the limitation. The 21 limitation was that someone along the line decided that 20 a 22 buses was a sufficient demonstration of the capability to 23 mobilize 533 buses. 24 MR. FLYNN: Did I just hear you to say that the 25 scenario called for a full evacuation, an evacuation of the Heritage Reporting Corporation (202) 628-4888 l

REBUTTAL NO. 23 PANEL - CROSS 23069~ .,_z 'l entire EPZ? 2 MS. DOUGHTY: No. What I am trying to say is that 7 3 the guidance recommends, or rather, requires a testing of L 4 major observable portions'of the plan and.using resources in ~ 5 sufficient numbers to verify the capability to respond to 6 .the accident scenario. 7 So I'm testing the ability that'20 buses is 8 - adequate verification of the ability' to respond. 9 MR. FLYNN: Well, see, the problem that I'm having 10 is that'Mr. Callendrello made a point of saying that his 11 reading of the same~ regulation is that the demonstration has 12 to be in the context of the-scenario, and you are ignoring 13 that. - 14 MR. BROCK: 'Well, is that an objection, Mr..Flynn? r( 15 MR. FLYNN: I asked for clarification. I've 16 gotten the clarification. 17 Thank you. 18 BY MS. DOUGHTY: 19 Q Mr. Callendrello, are you aware of the statement 20 in ALAB-905, and I'll quote the entire sentence just for 21 purposes of completeness? 22 "In summary, the adequacy of the scope of a pre-23 license emergency exercise must be judged against the NRC's 24 regulatory requirements, not the customary practice of FEMA 25 in designing and conducting such exercises." ll-Heritage Reporting Corporation (202) 628-4888 \\

j REBUTTAL NO. 23 PANEL - CROSS 23070 1 JUDGE SMITH: Where are you? 2 MS. DOUGHTY: I only have a copy of the slip 3 opinion. I was quoting from ALAB-900. 4 MR. LEWALD: 905 or 9037 5 JUDGE SMITH: 900. 6 MS. DOUGHTY:

900, 9-0-0.

7 MR. LEWALD: 900. 8 JUDGE SMITH: Are you going to engage in a debate 9 with him on the law? And I'm not saying that you can't, 10 because they do have in their testimony FEMA guidance and 11 scope. 12 MS. DOUGHTY: I'm wondering how this impacted his 13 understanding as an individual -- 14 JUDGE SMITH: But that question is very, very 15 broad. I don't know how he answers it. I don't know how 16 it's going to be productive. 17 What was the question again? 18 MS. DOUGHTY: Well, I just asked him if he was 19 aware of it, first of all. 20 JUDGE SMITH: All right, if he's aware of it. 21 Are you aware of that? 22 THE WITNESS: (Callendrello) I've read ALAB-900. 23 What page are you on? 24 BY MS. DOUGHTY: 25 Q Do you have the slip opinion, Mr. Callendrello? Heritage Reporting Corporation (202) 628-4888 1 1

7______-______ l i REBUTTAL NO. 23 PANEL - CROSS 23071 l 1 That's all I have with me, so I don't have the -- ) ,_s s i 1 (,) 2 A (Callendrello) I think that's what I've got. j 3 Q Okay. I'm at page 25 in the first full paragraph. 4 It starts about half way down the page. 5 (Witness reviews document.) 6 A (Callendrello) I see that statement. 7 Q Did that influence your thinking in determining 8 how many resources you would -- 9 A (Callendrello) No, it did not. 10 I might point out that the date of that decision, 11 at least on the copy I've got, is September 29, 1988; three 12 months after the exercise. 13 O Okay. So at the time of the exercise you clearly 14 couldn't have had the clarification of the regulatory ) 15 requirements provided in this Appeal Board decision? 'x J' 16 MR. LEWALD: I think we can stipulate to that. 17 MS. DOUGHTY: Okay. 18 BY MS. DOUGHTY: 19 Q Now I would like to explore your reasons for not 20 testing Objective 36 in the New Hampshire portion of the 21 exercise, and that deals with the unannounced off-hours 22 test. 23 Was th+ basis of your understanding that Objective 24 36 -- well, you determined not to test Objective 36, and 25 indeed th.t was not tested. 1 Heritage Reporting Corporation 7-s\\ (202) 628-4888 } s _/

REBUTTAL NO. 23 PANEL - CROSS 23072 1 Is that correct? 2 A (Callendrello) There are two questions there. 3 Objective 36 was not tested, that's correct. 4 We did determine that in our discussions with 5 FEMA, because they had some specific guidance from Mr. 6 Peterson that indicated that Objective 36 did not apply to a 7 qualifying exercise. 8 And that's contained in Guidance Memorandum 9 EX-3 amendment dated March 7, 1988, which I think is MAG 10 Exhibit 93, at least that's what my notes indicate. 11 Q Yes. 12 Now turning to page 2 of GM EX-3, there is a 13 number 3 and a paragraph that appears roughly in the middle 14 of the page, and then some subsections beneath it. And one 15 of them states, " Objective 36, unannounced and off-hours 16 exercises and drills does not apply to a qualifying 17 exercise." 18 A (Callendrello) I see that. 19 Q That's correct? 20 A (Callendrello) Yes. 21 Q Now turning to the transmittal letter that 22 provided the memo to regional directors, it states at the 23 bottom of paragraph 1, "This guidance should be used in 24 conjunction with NUREG-0654, FEMA REP 1, Revision 1, 25 Supplement 1." Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23073 1 Would you agree with that? y-,- A 2 A (Callendrello) That's what it says. f\\,- 3 Q Now, did you interpret this memorandum as being 4< applied to the utility plan demonstration? 5 A (Callendrello) NUREG-0654, Revision 1, Supplement 6 1, is the FEMA guidance that applies to the evaluation of 7 utility response, emergency response plans. 8 Q Okay. 9-A (Callendrello) So in that regard, yes. 10 Q So do you understand this GM EX-3 to provide ~ 11 guidance as to how to conduct utility plan exercises? 12 A -(Callendrello) Yes, I do. 13 On page 1 of the memo itself under " purpose", it 14 states, "This document amends the guidance in GM EX-3 to ( 15 accommodate the testing of-the utility offsite plans and 16 qualifying exercises." 17 Q Now the plan for the State of New Hampshire is not 18 a utility plan, is it? 19 A (Callendrello) That's correct. l 20 Q Now, could you explain to me why Objective 36 1 L 21 wasn't tested for the New Hampshire portion of the EPZ? l l 22 (Witness reviews document.) 1 23 24 25 Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23074 1 JUDGE SMITH: I don't want to interfere, I know 2 you've got a rather busy morning ahead of you. But he just 3 testified that he does not regard objective 36 as an 4 objective in a qualifying exercise. 5 MS. DOUGHTY: For a utility plan. 6 JUDGE SMITH: Well, how can you have -- excuse me. 7 (Pause) 8 JUDGE SMITH: Go ahead. 9 THE WITNESS: (Callendrello) That's the point. I 10 can't point to any specific guidance right now. But you 11 can't have announced on one side of the border and not 12 announced on the other. 13 I just don't see physically how that's going to 14 work. 15 JUDGE COLE: Wasn't the FEMA guidance indicating 16 that it is not necessary to test objective 36 in a 17 qualifying exercise? 18 JUDGE SMITH: It says by its very terms, objective 19 36: " Unannounced in off-hours exercises and drills does not 20 apply to a qualifying exercise." 21 MS. DOUGHTY: Right. 4 22 But we already had the witness -- the witness has 23 already testified that his understanding is that this 24 applies to the test of the utility plan. And the statement 25 here -- Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL;- CROSS' -23075' f f-sqx 1 JUDGE' SMITH: It may very well be that it applies .( s. \\,,[. 2- 'to the test of the~ utility plan,-but he did not. testify, in 3 my hearing, that it does not apply to a test of a state 4-plan. 5 Or did you? 6 Is'it your - go ahead. 7 MS. DOUGHTY: It is. I think.you're guessing, 8 probably. 9-JUDGE SMITH: Well, go ahead with your cross-10 examination. 11 MS. DOUGHTY: 'Thank you, Your Honor. ' 12 BY MS. DOUGHTY: 13 Q I guess'I would renew my question unless not 14 allowed. ( 15 A. .(Callendrello) I'm sorry, I forgot what the' 16 question was. 17 Q Did you understand this guidance memorandum to 18 absolve' state plans from testing objective 36? l 19 JUDGE SMITH: In a qualifying exercise? 20 (Witness reviewing document.) 21 THE WITNESS: (Callendrello) I don't see this 22 9.idance memorandum specifically going to nonutility 23 sponsored emergency response plans. l 24 I haven't had a chance to look at the other 25 guidance that exists, but this guidance appears to apply to Heritage Reporting Corporation (202) 628-4888 \\

r REBUTTAL NO. 23 PANEL - CROSS 23076 1 those plans that are developed in accordance with 2 NUREG-0654, Supplement 1. 3 I can't speak for FEMA on how they interpret it. 4 But I can't believe that they would mean in a situation 5 where, like we have got, where you have got one 6 participating organization, one participating state, and one 7 utility response organization that you would do something 8 differently. 9 Nor do I think could it physically occur that you 10 could have the exercise be announced on one side of the 11 border and unannounced on the other. 12 BY MS. DOUGHTY: 13 0 Could you have just notified the ORO workers 14 without having informed the State of New Hampshire? 15 A (Gram) You can't do that because of initiating 16 events of an unusual event require you to notify everyone 17 offsite. So it begine the process. 18 Q But we're talking about, at that point that's 19 during the actual exercise where you announced it, you have 20 to let everybody know offsite. l 21 But I'm talking about prior to the exercise, not 22 letting anybody know at all when things are going to begin 23 to get going. You might be able to inform the ORO workers, 24 but you wouldn't necessarily have to notify the governmental 25 entities of that, that could have been an unannounced test Heritage Reporting Corporation (202) 628-4888

l l REBUTTAL NO. 23 PANEL - CROSS 23077 l 1 of their capability? i \\,/ 2 JUDGE. SMITH: Let's don't beat this to death. 3 The objective 36, whether it's a state plan or a 4 utility plan or whatever it is, does not apply to a 5 qualifying exercise. 6-And it just boggles my mind. I mean, it attacks my 7 imagination to understand how you suggest that in a 8 qualifying exercise it can be unannounced. 9 MS. DOUGHTY: Well, Your Honor -- 10 JUDGE SMITH: So just move on. 11 MR. FLYNN: For the record, Your Honor, it is 12 FEMA's position that, at least, that portion of the guidance 13 applies both to utility plans as well as to state sponsored 14 plans. / i !,,v) 15 JUrGE SMITH: It is just a simple clarifying 16 statement in that document. 17 As I understand that has also been the practice 18 throughout FEMA that they don't have an unannounced exercise 19 for qualifying, as I understand the testimony. 20 MR. FLYNN: That's correct, Your Honor. 21 JUDGE SMITH: Already adduced in this hearing. ~. 22 Ever. 23 MR. FLYNN: Your Honor. 24 JUDGE SMITH: Did you understand that to be the 25 case? Heritage Reporting Corporation ps (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23078 1 MS. DOUGHTY: Well, Your Honor, I understand that 2 ALAB-900 states explicitly at page 22 that to the extent 3 that NUREG-0654 and another FEMA guidance memo, FEMA PR-1 4 suggests such an interpretation. And this is referring back 5 up to an interpretation that all the major elements don't 6 need to be tested in the qualifying exercise. 7 So those guidance documents conflict with the 8 language structure of the regulation, and thus, may not be 9 relied upon. 10 I think GM EX-3 -- 11 JUDGE SMITH: Show me the language that says that 12 you've got to have -- read the language you rely on here? 13 You're going to complete this cross-examination 14 this morning. If you're going to spend time on this -- 15 MR. FLYNN: Your Honor, I think the point here is 16 that FEMA guidance can be legally incorrect. But the point 17 has already been made; the rest is just legal argumentation. 18 JUDGE SMITH: Well, that much is true. 19 MR. BROCK: Do you want to stipulate it is 20 incorrect? 21 (Laughter) 22 JUDGE SMITH: Just to follow your line. Just read 23 the language that you think would control that. 24 MS. DOUGHTY: This was in ALAB-900. j 25 JUDGE SMITH: Yes, I know. Just go ahead and read Heritage Reporting Corporation l (202) 628-4888 1 l l ______________J

L REBUTTAL NO. 23 PANEL - CROSS 23079

i. -

I' 1- ' it. You already' read it once. Read it again.. ) 2 MS. DOUGHTY: I think I need the sentence-above it s i. 3 just-to complete the thought. L .4 JUDGE < SMITH: All right. 5 MS. DOUGHTY: I was trying to paraphrase and maybe 6 if'I read the whole. thing it.will be clear. 7- "We cannot agree, however, that insofar as the 8 initial prelicense exercise is concerned the major elements 9 of-the emergency plan can be tested in the aggregate over a 10 six year period beginning with the prelicense exercise and 11 extending to one or more post-license exercises. 12 To tho extent that NUREG-0654.and FEMA'PR-1 13 suggests such an interpretation, these guidance documents 14 conflict with the language and structure of the regulation, 15 'and thus, may not be relied upon." 16 This was the whole point of it. 17 JUDGE SMITH: So you are arguing from that, that ~18 even if FEMA says, you don't need unannounced' drills and 19 exercises for a qualifying exercise, somehow they have to do 20 it anyway because of ALAB-900. That is, indeed, a legal 21 argument and you can make it. 22 MS. DOUGHTY: Okay. 23 THE WITNESS: (Callendrello) Your Honor, just for 24 completeness. I knew it was in here, it just took me some 25 time to find it. Heritage Reporting Corporation ('~' (202) 628-4888 x

i REBUTTAL HO. 23 PANEL - CROSS 23080 1 In our Attachment C which is the memo from Richard 2 Krimm to Edward Thomas, on the first page in response to 3 issue 1 which Mr. Thomas raised the response was: "The same 4 scope of exercise objectives delineated for utility offsite 5 response organizations in the referenced March 7th, 1988 6 memorandum applies to participating state and local 7 governments. 8 As set forth in this memorandum 35 of the 36 9 exercise objectives of guidance memorandum EX-3 apply. The 10 only exception being objective 36, which is the off-hours 11 unannounced." 12 JUDGE SMITH: Her point, as I understand it, you 13 foolishly and to your peril relied upon FEMA. 14 (Laughter) 15 JUDGE SMITH: And NRC guidance tells you that it 16 was a mistake. That's generally your point, isn't it? 17 MS. DOUGHTY: Right. 18 JUDGE SMITH: So move on to the next one. I 19 MS. DOUGHTY: Move on. 20 BY MS. DOUGHTY: 21 Q While we are conveniently opened at Attachment C, 22 Mr. Callendrello, we were discussing yesterday, I think, in 23 response to Mr. Brock, you drew attention to issue 2 which 24 has to do with the test of bus drivers and availability of 25 buses; is that correct? Heritage Reporting Corporation (202) 628-4888

.) l REBUTTAL NO. 23 PANEL -TCROSS 23081. 1 This is Attachment C, page 2-of 3. f 3-~).

(_,,/

2 A (Callendrello)- It addresses the issue of what the 3 extent of the demonstration for buses and bus drivers 4 involves. 5 Q And if I understood your point or if I understood-6 the thrust of your testimony you were saying that the major-7. emphasis should be on preexercise evaluation?. 8 A (Callendrello) I read a statement from the 9 response to the issue raised. And the response said: "1'he 10 focus of this issue is preexercise evaluation of the 11 -availability of buses and training of bus drivers." 12 Q But does not the last sentence of this section 13 state: " Guidance for determining the extent of exercise 14 demonstration and evaluation for bus drivers and buses (and ( 15 route guides) is provided in the attachment?" 16 A (Callendrello) Yes, it does. L 17 Q Now, looking at subsection 2, turning to the 18 attachment which is page 3, of Attachment C, and looking at 19. subsection 2. 20 In that subsection is there not a statement that 21-says: "A representative number may vary from 100 percent to 22 a portion of the total activity?" 23 A (Callendrello) Yes, there is. 24 Q Wouldn't that apply to buses? 25 To test bus capability? Heritage Reporting Corporation (202) 628-4888

1 EEBUTTAL NO. 23 PANEL - CROSS 23082 1 A (Callendrello) Well, that statement and the 2 statement that follows it which says: "The basis for 3 determining a representative number is the documentation of 4 organizational planning and preparedness," which is the 5 preexercise evaluation. "The type and level of b 6 participation required by scenario events and other relevant 7 factors such as federal evaluator resources." 8 Q I don't want to plow over old ground, but I think 9 we have dealt with it. l 10 So, the basis for determining as you then look at 11 the documentation of how many buses there are; is that 12 correct? 13 A (Callendrello) That's one component. 14 In the discussions that arrive at the Extent of 15 Play for bus resources there are other activities -- there 16 are other considerations that are described in that 17 paragraph. 18 Q Now, the scenario event in this exercise was a 19 scale evacuation of all the -- well, ultimately all the New 20 Hampshire communities were involved except for ERPA G, I 21 belicict is t%at not correct? 22 A (Callendrello) ERPA G was not evacuated. So that 23 is correct. 24 The communities outside of ERPA G were evacuated. i 25 O So it was a pretty large evacuation, the scenario? j ) Heritage Reporting Corporation (202) 628-4888

REBUTTAL-NO. 23 PANEL - CROSS 23083-p 1 A (Callendrello) No, I have' trouble characterizing g, 3 il i A,_ / 2 it as pretty large, because I don't know in what context you 3-want to talk about pretty large. 4 If it was on an area basis, it was the majority of 5 the EPZ on an area basis. On a population basis I don't 6 recall the exact numbers. -~ 7 ~But I do know that the City of Portsmouth which 8 was in ERPA G is a'large population center. 9 0 That's' correct. 10' I think we can agree that it was a large' area. 11 Now, on population it did include the Hampton 12 Beach area? 13 A (Callendrello) Hampton Beach area was -- the area 14 was closed as a precautionary action so that the population 15 was reduced prior to the evacuation order. 16 Q Did you have an estimate of the population.that 17 needed to be evacuated relative to the whole population? 18 Was that considered at all in the determination of 19 sample size'for buses? 20 A (Callendrello) I don't know if that was 21 considered or not. 22 Maybe Mr. Gram can help on it. 23 A (Gram) You have to repeat the question. I 24 believe there were two questions involved. 25 Were we or was the state aware of the populations Heritage Reporting Corporation (202) 628-4888 (

REBUTTAL NO. 23 PANEL - CROSS 23084 1 involved in the areas that were evacuated? 2 Yes, they were; that's part of their 3 considerations in protective action decisions. 4 So the answer to the first part of your question 5 is, yes. l 6 Now, would you repeat the second part of your 7 question about buses. 8 Q Let me break it up a little finer, then. 9 Do you recall the estimated population that was 10 evacuated from the New Hampshire portion of the zone or can 11 you give an estimate? j 12 A (Gram) No. 13 We could get a copy of the plan and pull out the 14 populations by ERPA. 15 Q Did you do that in determining what sample to 16 test? 17 Did you think about how much of tne population is 18 going to be evacuated and then think about how many buses 19 that would require? 20 A (Gram) No. 21 Q So that didn't factor into your determination of 22 what sample size of buses to test? 23 MR. LEWALD: Mr. Gram was not a participant in the 24 plan. 25 MS. DOUGHTY: Well, he was a participant in the Heritage Reporting Corporation (202) 628-4888

4 REBUTTAL NO. 23 PANEL - CROSS 23005 1 development of the scenario and Extent of Play Agreements. 'l (,/ 2 MR. LEWALD: If you want to ask about the 3 scenario, that's one thing. But you are asking about the 4 exercise itself and he was not making protective action 5 recommendations nor wac he carrying them out. 6 MS. DOUGHTY: Mr. Lewald, as head of the exercise 7 they considered an Extent of Play and how much -- I assume 8 they determined how widespread the accident would be and how 9 much of an area to involve and how many resources would be 10 involved in actually carrying out an emergency response. 11 And I'm just trying to probe with the witness, to 12 what extent, when they were thinking about the scenario, how 13 that impacted on their determination of what the Extent of 14 Play should be and how many actual real resources they ,n ( 15 should call into play. w/ 16 So, again, I just wanted to ask -- 17 THE WITNESS: (Gram) Yes, I think I can respond. 18 The development of the Extent of Play and the 19 number of buses that were exercised was focused on 20 demonstrating the ability to run bus routes, not the ability l l 21 to move people. 22 The total populations are considered during ) 23 protective action decisions. And no one sits down and says, l 24 well, today is Thursday, how many people are going to be in 1 25 Hampton. There's a default value that is always used. l Heritage Reporting Corporation [N (202) 628-4888 l l l

f REBUTTAL NO. 23 PANEL - CROSS 23086 1 So the total -- the ability to move all of the 2 people for a full evacuation is evaluated by FEMA in their 3 evaluation of total transportation resources. I 1 4 5 6 1 7 l 8 9 '10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 i l l Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23087 1 Q Then when the default value was used, if you- -~ \\s_ 2 assumed the full need of resources in each of the facilities 3 that needed to be moved, did you total those up for the 4 communities that would be evacuated and determine from that 5 a sample size of buses to be tested? 6 A (Gram) No. 7 JUDGE COLE: But that information is available. 8 THE WITNESS: (Gram) Yes, sir. 9 BY MS. DOUGHTY: 10 0 I would like to turn to page 14 of your testimony. 11 A (Callendrello) I've got that. 12 Q Actually, we should probably start back on page 13 13, because the part I want to talk about follows from page 14 13. ,m 15 This was in the -- the next step, it states at the 16 final full paragraph on page 13, does it not, that, "The 17 next step in developing the Extent of Play was to identify 18 the processes and their components required to demonstrate 19 the plan element during the exercise."? 20 And then there is another sentence that follows 21 and then some subsections running on to page 147 22 A (Callendrello) Yes, there are. 23 Q And the last one in that particular grouping is, 24 " verification of the deployment process"? 25 A (Callendrello) Yes. Heritage Reporting Corporation 1 -[g (202) 628-4888 \\

I REBUTTAL NO. 23 PANEL - CROSS 23088 1 Q Do you believe that verification of a deployment 2 process is the same thing as verification of implementatica 3 capability? 4 A (Callendrello) No, I do not. 5 Q So, in other words, if you can demonstration that 6 you have a process in place to call up buses, it doesn't 7 really demonstrate that you can get buses out on the road 8 and get them to where they need to go? 9 A (Callendrello) No, that's not the way I 10 understood your previous question. 11 You asked me is verification of the deployment 12 process equal to implementation of the action. And I don't 13 believe -- well, my answer is, no, it is not, because that 14 is one component of the implementation process. 15 Q Okay. Isn't calling a bus company and just seeing 16 how many buses they have available and doing the phone 17 communications about where they need to go, isn't that just 18 a verification of the deployment process? 19 A (Callend ello) No, that's not what that testimony 20 is intended to say. 21 Verification of the deployment process is actually 22 putting a vehicle on the road in the field. 23 Q Okay. Now how would you understand verification 24 of implementation capability then? 25 Just so we are talking in the same terms, I want Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23089 1 to understand, g- -k ,) 2 A (Callendrello) Verification of implementation 3 capability is the whole process. It is the process from, 4 and depending on what particular function we're talking 5 about, the decisionmaking process. 6 If we're talking about transportation, which I 7 think we are talking about now, it's analysis of the need. 8 It's the contact of the supplier and analysis of the supply 9 of vehicles. It's making the allocation and distribution of 10 those vehicles. It's establishing the staging area 11 arrangement. And the final part of that is the actual field 12 deployment of vehicles. So that's one component of the 13 verification of implementation. 14 Q Now is part of the deployment process -- well, p 15 maybe I should just be really clear about this. ( s) s. 16 The regulation at Appendix E, Section IV(f) 17 requires generally that emergency preparedness exercises, 18 and this is to quote a small portion of it, " tests the 19 adequacy of timing and content of implementing procedures 20 and methods". 21 And I'm wondering about how the actual timing of 22 deployment of buses was adequately tested. 23 I!ow did -- well, let me not clutter it up. 24 A (Ca11endre11o) I'm sorry. Can you just give me 25 the question again? Heritage Reporting Corporation [ (202) 628-4888 i r

REBUTTAL NO. 23 PANEL - CROSS 23090 1 I know it was a long introduction to it. 2 Q Okay. 3 A (Callendrello) I do have that section of the 4 regulation. I was looking at it as you were talking, and I 5 just missed the question. I'm sorry. 6 Q Again, I'm interested in how the process of 7 deploying buses, as it was done in this exercise, tested the 8 adequacy of timing in content of implementing procedure and 9 methods. 10 A (Ca11endre11o) It tested the timing -- well, the 11 way I interpret that section of what you've just read is 12 adequacy of the timing, where there is timing that needs to 13 be evaluated, and I'm thinking along the lines of prompt 14 notification systems where there is a fixed time 15 requirement, or initial notification to offsite authorities, 16 this is for the onsite organization, where there is a fixed 17 timing requirement. 18 The timing requirements of the procedures, I know 19 of no other timing requirements, regulatory requirements or 20 guidance requirements. I would interpret this to only apply 21 to those sections where there is a timing requirement. 22 Q Wouldn't, in a real emergency response, the timing 23 aspect of deploying buses have an impact on the evacuation 24 time estimate? 25 A (Ca11endre11o) Well, no. The evacuation time Heritage Reporting Corporation (202) 628-4888

l-REBUTTAL NO. 23 PANEL - CROSS 23091 1 estimate is the evacuation time estimate it. -m i ( / 2 O But it's got certain assumptions about timing of v 3 deployment of resources. 4 A (Callendrello) Yes, it does. 5 Q And did this exercise really test those 6 assumptions? 7 MR. FLYNN: I object. This is again legal 8 argumentation. 9 JUDGE SMITH: No, it's not. 10 MR. FLYNN: Well, but the -- 11 JUDGE SMITH: It's factual. 12 MR. FLYNN: The whole point of the line is a 13 suggestion that there was not an adequate demonstration that 14 buses could be mobilized in a timely way. But that issue ,/ m ( ). 15 goes to a threshold value or a minimum time for the %d 16 mobilization of buses or other resources which is not part 17 of the standard that's applied. 18 JUDGE SMITH: It's a standard which'is applied 19 where? 20 MR. FLYNN: To the plan in general, or to this 21 aspect of this exercise. It strikes me that this is the 22 Sho11y-Beyea -- 23 JUDGE SMITH: Are you suggesting there is no 24 element of timeliness in the deployment of buses that have 25 to be considered? Heritage Reporting Corporation (} (202) 628-4888 \\ )

REBUTTAL NO. 23 PANEL - CROSS 23092 1 MR. FLYNN: There is no pass or fail value. There 2 is no threshold value that has to be met. 3 MS. DOUGHTY: There is no -- 4 JUDGE SMITH: There ar'e assumptions in the ETE as 5 to deployment. And now she's asking simply how were those 6 assumptions, if tested, if they were. 7 MR. FLYNN: Well, if that's how the question is 8 understood, then I will withdraw the objection. 9 JUDGE SMITH: Was that it? 10 MS. DOUGHTY: That's correct. 11 THE WITNESS: (Callendrello) The evacuation time 12 estimate was developed based upon the implementing 13 procedures contained in the plan. And the exercise was a 14 test of those implementing procedures. 15 And FEMA's evaluation found that those 16 implementing procedures were adequately demonstrated. 17 Therefore, if you follow the chain backwards, I won't say 18 justified, but it has supported the timing sequence used in 19 the evacuation time estimate. 20 BY MS. DOUGHTY: 21 Q Okay, that's a timing sequence as to reasonable 22 assurance that the ETEs are adequate in terms of providing a 23 basis for judgment of how much time it takes to deploy 24 resources. 25 JUDGE SMITH: Something is wrong with that Heritage Reporting Corporation (202) 628-4888

F REBUTTAL NO.' 23 PANEL - CROSS' 23093 1 sentence. L: f( '2 .(Laughter) - b j. 3 JUDGE SMITH: Do you want it read back, or do you 4 -want to try again? 5 MS. DOUGHTY: Maybe if I hear it, I will 6 understand what the problem is. 7 (Accordingly, the pending. question was played i 8 back by the court reporter.) 9 'MS. DOUGHTY: I guess there was a problem with-10 that question. Let me rephrase it. 11 BY MS.. DOUGHTY: 12 Q Your response was in terms of the sequ'ence of 13 timing of-events. '14 Now, I'm trying to inquire into whether or not the ] 15 exercise tested the assumptions in the ETE as to the general -16 time frames in which resources could be deployed that are 17 assumed in the ETE. 18 JUDGE SMITH: For buses? For buses? 19 MS. DOUGHTY: Yes. Emergency response vehicles. 20' JUDGE SMITH: Well, okay. For all emergency 21 response vehicles? 22 MS. DOUGHTY: Well, I think you are right. We 23 should narrow it to buses. 24. MR. LEWALD: Is the question, "Was that a part of 25 the exercise"? Heritage Reporting Corporation pf (202) 628-4888 (

REBUTTAL NO. 23 PANEL - CROSS 23094 1 JUDGE SMITH: How did the exercise test the 2 timeliness of the deployment of buses, if it did. 3 MR. LEWALD: It's assuming that it did. 4 JUDGE SMITH: Yes, assuming that it did. And if 5 it didn't, why didn't it. 6 MS. DOUGHTY: He can answer that. 7 THE WITNESS: (Callendrello) It did test the 8 timeliness of response of those vehicles from the suppliers 9 that were involved -- the providers that were involved in 10 the exercise. 11 JUDGE SMITH: How did it do it? 12 THE WITNESS: (Callendrello) FEMA actually -- 13 JUDGE SMITH: Just by timing it. 14 THE WITNESS: (Callendrello) Yes, they timed it. 15 v'UDGE SMIT 71: Okay. 16 THE WITNESS: (Callendrello) They also timed the 17 routes that were run. 18 BY MS. DOUGHTY: 19 Q Now, wouldn't you agree that if a company had been 20 called upon to supply more buses, it might have taken more 21 time to get those additional buses deployed? 22 A (Callendrello) I read the word "might" as is it 23 possible. 24 Sure, I think it's possible it could have taken 25 more time. Heritage Reporting Corporation (202) 628-4888 I i t L _______..______________________.J

'J REBUTTAL NO.'23 PANEL - CROSS 23095 l Well,Ewould that be a likely result? 1 1JUDCE SMITH: /Ml ( ) 2 Her point is, here is a sample, if it is a sample, j 3 of.20 buses out of 500. You can get those out rather 4 promptly. Therefore, you did not test the capacity to l 5 deploy all of the buses in a real emergency is her idea, I-6: believe, isn't it? ) 7 MS. DOUGHTY: Yes. 8 THE WITNESS: (Callendrello) .It might take more 9 time to deploy them, but it may not have any impact -- l l 10 THE WITNESS: (Gram) On the ETEs. I i 11 THE WITNESS: (Callendrello) -- on the ETEs. 1 12 Because the ETEs assume a range of reporting times. And 13 these, in essence, would have been the first buses deployed' 14 from a particular yard. If more buses are deployed, they - [N j ( ) 15 are further down the window of times that buses report on. 16 JUDGE COLE: But that aspect was simply not I 17 testeo, the time for deployment of all buses? 18 THE WITNESS: (Callendrello) Of all buses. i 19 No, that's correct. i i 20 MS. DOUGHTY: Thank you. 21 BY MS. DOUGHTY: 22 O I would like to -- i i 23 JUDGE SMITH: That's a considered answer now? 24 THE WITNESS: (Callendrello) We did not deploy 25 all buses. Heritage Reporting Corporation - ('~' (202) 628-4888

k REBUTTAL NO. 23 PANEL - CROSS 23096 1 JUDGE SMITH: Right, but did you test -- but was 2 the -- 3 THE WITNESS: (Callendrello) Well, I'm sorry, 4 Your Honor. 5 JUDGE SMITH: If I think about your answer, 6 because I don't understand that to be -- it could very well 7 be the case, but I don't think it's consistent with what I 8 understand the exercise to be. 9 THE WITNESS: (Gram) Yes. I believe FEMA, in 10 their pre-evaluation of transportation resources, one of 11 their questions was, you know, at any given time how long 12 would it take you to respond and how many resources would 13 you normally do it. 14 So I believe that that the issue of testing in 15 that sense was done by FEMA in their pre-evaluation, the 16 timeliness of all the resources. 17 THE WITNESS: (Callendrello) In addition, as the 18 scenario progressed and the exercise progressed, additional 19 resources were made available to the participants in a time 20 sequence. So that the availability of resources over a 21 staggered time or an extended time period was evaluated, was 22 demonstrated, although we didn't actually mobilize all buses 23 from the providers. 24 That type of information was provided on what 25 would be a reasonable time frame for the actual deployment Heritage Reporting Corporation (202) 628-4888

d j i REBUTTAL NO. 23 PANEL - CROSS 23097 l 1-of those resources. So that' aspect of it was tested. ] 4 ) 2 I understood Judge Cole's question to be: Did you x-3 test the actual' deployment of all vehicles from a single 4 provider. 5 JUDGE COLE: My question was simply, in view of 6 the fact that you did not mobilize all the buses, the time 7 to do that was not determined in the exercise. 8 THE WITNESS: (Callendrello) That's correct. We 9 did provide data, though, that indicated some deployment 10 time for-all of the resources needed. 'll BY MS. DOUGHTY: 12 Q .And those are based on the assumptions of the 13 company-owners? 14 A (Callendrello) I'm not sure what went into that /~

(

15-deployment time sequence; whether it came from the A 16' assumptions of the owners or the evacuation time estimate 17 data. It would have been one of those sources though. 18 Q Okay. I understood Mr. Gram's answer to be that 19 the bus company providers had provided to FEMA estimates of 20 the time to deploy resources. 21 So those are their assumptions as to estimates of .~ 22 time, are they not? 23 A (Callendrello) In what Mr. Gram was talking 24 about,.yes, that's correct. 25 I was talking about something a little bit Heritage Reporting Corporation (202) 628-4888 tO --..-___----._______-_-__w

REBUTTAL NO. 23 PANEL - CROSS 23098 1 different. And that is, during the exercise all resources 2 were not instantly made available to the exercise 3 participants. They were made available to them on some 4 staggered basis and an evolving basis, a cumulative basis so 5 that it would approximate what would be the expected ~ 6 deployment. time. 7 8 9 10 11 12 13 l 14 15 16 17 18 19 20 21 ~ 22 ~3 24 25 Heritage Reporting Corporation l (202) 628-4888 r i

I 1 l l REBUTTAL-NO. 23 PANEL - CROSS 23099 1 .O " Expected?"

[ m:5~,)

2 JL ,(Callendrello)' Right. a 3 We tried to make it as real as we could for these 4 ~ individuals by not instantly making all these vehicles 5 available to them. 6 Q' Mr. Callendrello, I want to explore with'you'the ~7' statement in the testimony at page 15 about -- I believe 8 this.was. examined a.little bit yesterday but I want to go a 9 little bit further. 10 The statement appears -- the first full sentence 112-at the' top of page 15 is: "Because the functions to be 12 performed by these responders were similar to their normal 13 employment functions, an adequate demonstration of this particular functional area did not require extensive 14 15 deployment of resources." 16: And I believe this is in reference to the buses: 17 'is that correct? Or is it in reference to more than just 18 the buses? 19 A (Callendrello) It's in reference to more than 20 just buses. 21 Q Just for purposes of the record would you explain 22 which functions are being referred to in this sentence? 23 A (Ca11endre11o) I can explain -- I can describe-24' some of them; I may not hit them all. 25 One would be ambulance drivers. Heritage Reporting Corporation r' (202) 628-4888 ^t a_______. _ = _ - _ - _ _ _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _

REBUTTAL NO. 23 PANEL - CROSS 23100 1

Wait, Mr.. Gram points out, on page 14 we do cite 2

some examples. l 3 Q Okay. 4 A (Callendrello) In the middle of the page the 5 parenthetical says: " Ambulance drivers; bus drivers; law 6 enforcement personnel." 7 Q Let's consider bus drivers and what they will be 8 expected to do during a radiological emergency. 9 Is it not true they will be expected to check 10 their dosimetry periodically? 11 A (Callendrello) Yes, that's correct. 12 O Is it also not true that many of them won't be 13 driving in areas that they are familiar with, so they may 14 need to consult with maps? 15 A (Callendrello) I don't know the exact number; 16 the breakout of those vehicles that originate from companies 17 that normally service the EPZ versus those that don't; so 18 many qualify. 19 Certainly, some will be driving in areas that they 20 don't normally service and would be required to read a map. 21 Q Other than the Barry Transportation Company, my 22 understanding is, that they all go to the state staging 23 areas and then are sort of deployed as they arrive there. 24 So even buses that are generally from the area 25 might not drive the particular routes they normally drive. Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23101 1 Is that not. correct?

/: (,,)'J 2

A .(Callendrello) That's correct. 3 They might not be driving -- might not normally 4 drive that_particular route. 5-Q Is it aisc not true that some bus drivers will be '6 going to nursing homes and may have to deal with the 7 installation of beds on their vehicles?. c. 8 A (Callendrello) No, that's not correct. .9-We would only send buses to those facilities -- if 10 you' re talking about evacuation bed buses, those patients 11 would be loaded and the equipment would be installed by the 12 facilities on staff. And they are, in fact,: trained to 13 perform that' function. 14 Q Mr. Callendrello, do you recall the testimony of 15-Mr. Trahan on the New Hampshire side? ( 16 A, (Callendrello) I was not present for his 17 testimony. 18 Q Do you recall the testimony of Commissioner 19 Maureen Barrows? 20 A (Callendrello) Vaguely; that was quite a while 21. ago. MS. CHAN: Is there a particular part of the 22 23 testimony that, perhaps, you want to renew the witness' 24 recollection or are you going to pass on at this point? -25 MS. DOUGHTY: I'm trying to figure out what I Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23102 1 should at this point, to tell you the truth. 2 MS. CEAN: If he can't remember you really can't 3 ask him anything else. 4 MS. DOUGHTY: Right. 5 He doesn't have memory, so I'm trying to think 6 about how to approach this. 7 JUDGE SMITH: Let's take a 10 minute break. 8 (Whereupon, a recess was taken.) 9 JUDGE SMITH: On the record. 10 Ms. Doughty, Judge Cole poin.ted out to me that my 11 remark about you finishing this morning could be taken by 12 you as an order to finish this morning. I didn't intend 13 that. I thought that was your plan to finish this morning. 14 MS. DOUGHTY: I had hoped to, but I'm not skilled 15 at estimating how much time it takes me to get through one 16 of these plans. 17 JUDGE SMITH: Well, I was just reporting, somehow 18 you had conveyed the idea to us that you would finish this 19 morning, and I was pointing out that at that pace you're not 20 going to do it. 21 MS. DOUGHTY: I think you may be right. 22 I'll press onward, however, and hope for the best. 23 BY MS. DOUGHTY: 24 Q Mr. Callendrello, we were talking about other 25 functions that bus drivers may or may not be called upon to Heritage Reporting Corporation (202) 628-4888 r

1 L

!",s REBUTTAL NO. 23 PANEL - CROSS 23103 l' perform in the course of_a radiological emergency aside from (-'; )t '2 bus driving before we broke. 3-Just to start a new -- we agree that.they may need 4 to. read dosimetry -- check'their dosimetries, rather? 5 A (Ca11endre11o) That's' correct. ~ And they may be in unfamiliar areas and may be 6 Q 7 concentrating on finding their way including reading maps? 8 A (Callendrello) That's correct. 9 Q Do you have Applicants' Exhibit 43 (f).available. to - 10 you at the table? 11-A .(Callendrello) Which is that? 12-Is that the exercise report? 13' Q That's the exercise report? 14 A (Callendrello) Yes, I've got a copy of it. ) 15 Mine is not marked as an exhibit, so it has got 16 the other page numbering on it. ~ 17 Q 0Aay. 18 JUDGE SMITH: We're using the original page 19 numbers for this examination. 20 MS. DOUGHTY: Okay. 21 BY MS. DOUGHTY: 22 Q Those original page numbers would be 210 to 2117 23-A (Ca11endre11o) I've got that. 24 O Now, at page 210 there is issue number 1 25 identified and rated as an ARCA. And this hco to do with Heritage Reporting Corporation g'~ (202) 628-4888 (

REBUTTAL NO. 23 PANEL - CROSS 23104 1 the reading of dosimeters at 15 minute intervals; does it. 2 not? 3 A (Callendrello) Just give me a moment to look at 4 that. 5 Yes, it does. But this is an inadequacy as 6 regards to the offsite response organization and not the 7 State of New Hampshire. 8 Q Well, at least for the offsite organization,.then 9 this was identified as a problem for the drivers of buses? 10 A (Callendrello) It was identified as an issue. 11 I can read the issue. I wouldn't say identified 12 as a problem. It was an issue that in a minority of cases 13 reading of dosimeters at 15 minute intervals was not 14 accomplished. 15 And it says: "This was a more frequent problem 16 for the drivers of vehicles." 17 Q Well, maybe I should be precise and call it an 18 area requiring corrective action, then? 19 A (Callendrello) Yes, it was. 20 Q Now, on the New Hampshire side of the zone the 21 recommendation was that route guides -- this is at the top 22 of page 211 -- route guides should be trained to provide 23 assistance to bus drivers and reading and recording logging 24 dosimeter readings? 25 A (Callendrello) Again, that is for the offsite l~ l Heritage Reporting Corporation I (202) 628-4888 (

L [ REBUTTAL NO. 23 PANEL - CROSS 23105 1 response organization. /N 2 Q But we have agreed on the New Hampshire side bus \\al 3 drivers will also have to check dosimetry? 4 A (Callendrello) Yes, they will. 5 Q Now at page B-70 of the Applicants' Exhibit 43 (f) 6 there is a comment, " observation" column that states, among 7 other things, "That bus guides are no longer used." And 8 that refers to the New Hampshire portion of the zone, is 9 that not true? 10 A (Callendrello) It does. 11 What you have pointed me to, though, is a specific 12 comment or comments specific to the Town of Kingston. I 13 don't recall in 1986 whether bus guides were used in all. 14 communities or not. ,a 15 Q Well, I guess we don't need to belabor that. i (x_ l 16 But can we agree that bus guides are not 17 contemplated for the New Hampshire buses? 18 A (Callendrello) I'm sorry. 19 Q The use of bus guides is not contemplated for the 20 New Hampshire buses? 21 A (Callendrello) That's correct. 22 Q So the New Hampshire bus drivers will not, as 23 recommended for the ORO workers, have the assistance of bus 24 guides in reading their dosimetry and logging their 25 dosimeter readings, will they? Heritage Reporting Corporation [~^g (202) 628-4888 \\~ /

REBUTTAL NO. 23 PANEL - CROSS 23106 1 A (Callendrello) If you're pointing me to the 2 language on 211, the recommendation is that route guides be 3 trained to provide assistance to bus drivers and reading and 4 recording dosimeter readings? 5 Q Yes. ~ 6 That will happen on the Massachusetts side of the but that won't be possible on the New Hampshire side 7

zone, 8

of the zone, will it, because there will be no bus route 9 guides? 10 A (Callendrello) Well, it won't be possible. 11 But I think FEMA evaluated that capability. 12 If you just give me a moment I can look. 13 (Witness reviewing document.) 14 THE WITNESS: (Callendrello) FEMA did evaluate 15 the ability of the bus drivers or the monitoring of 16 dosimetry by bus drivers in the New Hampshire portion as 17 well. 18 BY MS. DOUGHTY: 19 Q Yes. 20 That's at page 1547 21 A (Callendrello) Yes, it is. 22 Q And that was issue number 1. And 2 is an ARCA? 23 A (Callendrello) That's correct. 24 Q And the evaluation was that most bus drivers, 25 ambulance drivers, town personnel, and a few local police Beritage Reporting Corporation (202) 628-4888 r

t .h j REBUTTAL No. 23 PANEL - CROSS 23107 l' L 1 did not frequently monitor exposure? 1.; (- ( / 2 A (Callendrello). That was the evaluation. 3 And then there were two recommendations to resolve -4 that area requiring corrective actions. 5 Q I guess the overall point I'm trying to make is, 6 there have.been identified difficulties with this procedure. 7 And this is different from what a bus driver would normally 8 be expected -- normal function-for a bus driver? 9 A (Callendrello) Again, you've got two pieces. 10 Yes, it is. It was an identified area requiring 11 corrective action for the bus drivers that were 12 participants. Actually, that comment includes more than 13 just bus drivers. 14 And it is something that they would not do in } 15 their normal duties. 16 Q So isn't the rationale for not requiring extensive 17 deployment of resources, as stated at page 15, not quite 18 accurate? 19 A (Callendrello) No. 20 You've got to look at the overall objective, and 21 the components of the overall objective. 22 What you are focusing on is one very small 23 component of that overall objective. In this case it would '24 be objective 18. Maybe it's easier for me to read what 25 objective 18 is. Heritage Reporting Corporation (202) 628-4888 C/ f

REBUTTAL NO. 23 PANEL - CROSS 23108 1 " Demonstrate the ability and resources necessary 2 to implement appropriate protective actions for the impacted 3 permanent and transient plume EPZ populations." 4 That's a very broad objective. And you're talking 5 about one aspect of it. One very small aspect of a 6 component of it. 7 And the important component of that is the ability 8 for a bus driver to drive a bus and reach a location. And 9 those are duties that are performed by a bus driver on a 10 day-to-day basis, on a normal basis. 11 Q But isn't the routine for a bus driver usually to 12 drive a familiar route and not have to check dosimetry? 13 A (Callendrello) Well, there is two parts to that. 14 I would grant that bus drivers -- at least I've 15 never seen a bus driver that normally has to check dosimetry 16 on their daily route. But they do normally drive routes. 17 And they normally drive buses and follow maps. This may be 18 a different map, but they are still following maps. i 19 Q Maybe on the first day of their employment they i 20 follow a map. But wouldn't you agree that after having 21 driven the route two or three times that they have been 22 assigned for a school or unless it's a charter bus company 23 they normally don't need to follow route maps? 24 A (Callendrello) Well, school bus drivers that are 25 normally running their pickup routes I would agree wouldn't Heritage Reporting Corporation (202) 628-4888 i

Ly REBUTTAL NO.-23~ PANEL . CROSS-2'3109 L

1 need'a map.

But they do go outside of areas. They go to ..,,q e/ \\ 2 away.footb'all games. And they go down to Boston to come to \\s_,/ - 3' the various museums. So they do follow maps as part of 4 their regular jobs. 5 Q But you would agree that not all bus drivers do 6 those-extra. assignments? 7 So an assumption is being made, is:it not? 8 . You' re relying on an assumption that bus drivers 9 may take other. trips that require them to read maps? 10 A. (Ca11endre11o) We're relying on an assumption 11 'that a bus driver is able to read a map or is capable of. 12 being trained to read a map. That is our assumption. '13 Q Now, I believe Mr. Brock elicited on examination 14 yesterday that there were 49 routes out of 66 routes, and-I 15 can't remember specific ally how you characterized those 16 routes that were successful? 17 (Witness reviewing document.) 18 19 20 21 22 [- 23 24 25 Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23110 1 THE WITNESS: (Callendrello) This was in New 2 Hampshire only? 3 MS. DOUGHTY: Yes. 4 THE WITNESS: (Callendrello) There were 49 routes j 5 out of 66 routes, and I'll call those special needs routes. 6 MS. DOUGHTY: Special needs routes. 7 THE WITNESS: (Callendrello) Those are hospital, 8 nursing home and transit-dependent routes. 9 BY MS. DOUGHTY: 10 Q Now that would mean that 17 buses were not 11 successful in completing the routes, is that correct? 12 A (Callendrello) Seventeen routes were not 13 completed. On the second day of the exercise, those routes 14 were being driven by private vehicles. So it may not have 15 been a bus. 16 Q Now at page 165 of the FEMA evaluation report, 17 there is a chart that appears in the middle of the page that 18 talks about the number of buses required and the time stated 19 is at 1420? 20 A (Callendrello) Yes, I see that. 21 Q How was that number generated? 22 A (Callendrello) I don't know. Evidently Mr. 23 Donovan put it in his exercise report from information that 24 he had available to either him or his observers or 25 evaluators. Heritage Reporting Corporation (202) 628-4888 f

f REBUTTAL NO. 23 PANEL - CROSS '23111 1 Q. Okay.

(G)

. 2. A -(Callendrello) I don't know where that number 3 came from.. 4 Q Would you agree that roughly 25 to 26 percent of 5 'the -- I think this question may have been asked and I 6 apologize for asking it again, but I. don't quite remember-7 how you responded. 8 Would you agree that 25 to 26 percent'of the 9 special needs routes were not successfully completed based 10 on the numbers you just gave me? ~ 11 A (Callendrello) Twenty-six percent were either not 12 completed or required controller intervention to complete. 13 So it was scored as a non completion. 14 Q Now do you as an emergency planner. evaluate that n 15 as an adequate demonstration? 16 A (Callendrello) I would not rate it as an adequate 17 demonstration. I think, in fact, FEMA has called that an 18 inadequacy that we need to improve the maps. 19 We have done some more analysis of what caused the 20 failures. We looked at hospital routes and there were no 21 problems with the hospital routes. All seven were run 22 successfully. 23 We looked at the nursing home routes, and eight 24 out of nine were run successfully. 25-We had a problem with the special needs -- with Heritage Reporting Corporation fg (202) 628-4888 9

REBUTTAL NO. 23 PANEL - CROSS 23112 1 the transit-dependent routes. And as a result, and we 2 analyzed that and found that the maps were the cause of the 3 problem. And as a result, we have gone, and in our 4 enhancing the maps to improve their readability and the ease 5 of following. So we think we understand the inadequacy or 6 what caused the inadequacy, and we are resolving the 7 problem. 8 O So, I guess you did agree with me that having 26 9 percent of the routes not successfully run was not adequate 10 and it was not deemed adequate by FEMA? 11 A (Callendrello) It was an inadequacy or an issue 12 identified by FEMA. I would agree with that, yes. 13 Q So we are in the position of assuming that the 14 correction of the maps will correct the problem? 15 A (Callendrello) We are taking the action we think 16 will solve the problem. 17 You know, this has been an evolving process. As 18 Mr. Brock pointed out yesterday, in 1986, the exercise was 19 run and there were problems with the maps. And I can attest 20 that the maps were of very poor quality. They were 21 photocopy street maps, and they were very difficult to 22 follow. 23 We improved those. We obviously improved them 24 substantially. We had a high success rate, 74 percent 25 completion rate on these, and even higher on the other types Heritage Reporting Corporation (202) 628-4888

7 REBUTTAL NO. 23 PANEL - CROSS 23113 1 .of routes. ,o - T / 2 We still identify that there were problems with w/ 3 the maps and improvements we had to make to the maps. And 4' we are making those improvements. 5 Q But the assumption that that's the problem has not .6 yet been tested? 7 A (Ca11endre11o) I hesitate to say it's an 8 assumption. We have evaluators and controllers on those 9 buses who observed firsthand what the problem was.- If an 10 individual, a driver said, "I can't follow this map", we're 11 not making an assumption. We know that there is a problem 12 with the map. 13-Q Okay. Maybe I should say that the solution that' 14 you've implemented was not yet tested? The solution to the \\ 15 perceived problem has not yet been tested? '; w/ 16 A (Callendrello) We are verifying and validating 17 that the maps are accurate, and that there were sufficient 18 landmarks. We have not tested them, I believe, in any 19 exercise. We certainly haven't had an exercise since then. 20 A (Gram) Yes, they have not been tested in a FEMA-21 evaluated exercise. But the map upgrade program, that I 22 call it, is or does go through a testing problem. 23 We have evaluation teams that are giving copies of 24 the new maps and told to go out and run the routes. We also 25 have a QC program where we have actual QC personnel from the Beritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23114 1 Seabrook site that do a follow-up verification for the whole 2 process. And we've also used the upgraded maps for road 3 rallies for the Massachusetts ORO, in recent road rallies. 4 And the comments that come back are, you know, it 5 solved the problem. 6 Q Have they been tested in the New Hampshire side? 7 A (Gram) I can't answer that question. I don't 8 know. 9 Q Okay. 10 JUDGE SMITH: What's an ORO road rally? 11 (Laughter) 12 MS. DOUGHTY: Sounds like fun. 13 THE WITNESS: (Gram) We run drills as part of 14 training sessions for the route guides for the ORO, the 15 Massachusetts response organization. Where they are 16 actually mobilized and given a set of routes to run with the 17 new maps, and they actually go out and run a complete route 18 or several complete routes using the new maps. And then we 19 verify that process through debriefings and actual 20 controllers participating in the process. 21 JUDGE COLE: But you don't give prizes or anything ~ 22 like some road rallies might? 23 (Laughter) 24 THE WITNESS: (Gram) No. 25 Heritage Reporting Corporation (202) 628-4888 f

( ~ l' REBUTTAL NO. 23 PANEL - CROSS 23115 I 1 BY MS. DOUGHTY: s 2 Q I guess I would like to. move onto another line. (v) 3 Turning to page 30 of your testimony. 4 1 guess I forgot one little question on the last 5 line. Mr. Brock covered most of the area, but there are 6 really three aus. companies that actually provided buses on 7 the New Hampshire side of the exercise. 8 Is that not correct? 9 A (Baer) There were three bus companies that 10 provided buses. There was another organization that 11 provided a wheelchair van, and a fifth organization provided 12 an ambulance. 13 Q Now beyond those organizations, were calls 14 actually made to the other providers of service during the

!(

) 15 actual exercise scenario, the other New Hampshire providers? v 16 A (Baer) As I said yesterday that initially calls 17 were made to the providers according to the procedure that 18 the' persons with that responsibility had. 19 0 So every single bus company and ambulance company 20 and -- 21 A (Baer) I can't say that every single one was 22 contacted. But initially all of the companies in their 23 procedure were called, or attempts were made to call them. 24 1 25 Heritage Reporting Corporation /N (202) 628-4888 i 1 l w-1 D

REBUTTAL NO. 23 PANEL - CROSS 23116 1 Q Was any documentation of how successful the 2 attempts were, kept? 3 A (Baer) Yes. 4 And I believe that was provided, but there was 5 some documentation to that effect. 6 Q You appear to have it available there. 7 Maybe if you do we could get the definitive 8 answer. 9 A (Baer) I'm looking to see whether'I do have it. 10 (Witness reviewing document.) I 11 THE WITNESS: (Baer) I think as I said, also, 12 they were called initially, according to an exercise 13 controller message. And a prescribed message was read to 14 the bus companies that were contacted that asked them -- l 15 advised them of the exercise being conducted that day and 16 asked them if they wish to participate. 17 From the records I have, all of the companies that 18 are indicated in their procedure, but one, appear to have 19 been contacted. 20 BY MS. DOUGHTY: 21 Q What was the name of that company, just for 22 purposes of the record? 23 A (Baer) The one organization that wasn't 24 contacted? 25 That appears was not contacted was actually the Heritage Reporting Corporation (202) 628-4888

. REBUTTAL NO. 23' PANEL - CROSS 23117 .l'. Dover,.New Hampshire School District. gg ~ -Q- -Now, I can move on to the next'line, and this.has, ( f. 2 3 to>do.with-the ambulances. '4 , Turning to your testimony.at'page.30'there is:a 5 citation to some FEMA guidance which I believe-is appended 6 as' Attachment B to your' testimony.. 7 I'm asking, was it reliance on'this guidance that. 8 -- I guess your testimony says: "The Extent of Play for this 9 objective was implemented principally by FEMA guidance." 10-And.this is-the FEMA guidance that implements the 11 Extent of_ Play in regard to ambulance demonstration? 12 A (Callendrello) Yes. As regards to the number.of 13 individuals simulated contaminated injured individuals that' 14: need to be handled by the exercise. 15 Q .I'm just trying to relocate again where that 16 particular statement appears in Attachment B. 'It will take 17 me a' minute. 18 A (Callendrello) It's at the very bottom of page 3. 19 Q I see. 20 It's in the next to the last paragraph on page 3 21 of 4. ~ 22 A (Callendrello) No, it's not. 23 It's the very last sentence of page 3. 24 Q Oh, I see. Okay. This is similar. 25 Now this guidance refers up above to an annual Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23118 1 medical emergency drill, does it not? 2 A (Callendrello) No, it does not. 3 The title of that is, " Medical emergency drills 4 and exercises." And the very first sentence under that 5 section which is at about the middle of page 3 talks about 6 the demonstration in annual emergency -- annual medical 7 emergency drills and biennial exercises. 8 O I see. 9 Did you draw any distinction between the biennial 10 exercise and the qualifying exercise? 11 You assumed that this reference to biennial 12 exercise applies also to the qualifying exercise? 13 A (Callendrello) Yes. As regards to the 14 demonstration of that objective. 15 Q Could we refer to Applicants' Exhibit 43 (f), FEMA 16 exercise report. I believe it's at page 186 for the 17 ambulance. 18 A (Callendrello) I've got that. 19 Q Now, that objective was not met, is that correct? 20 A (Callendrello) Page 186, next to evaluation for 21 objective 23 it says, "not met." 22 Q And there were two issues identified under that 23 objective? 24 A (Callendrello) That's correct. 25 Q Now, ar page 187 the first full paragraph under Heritage Reporting Corporation (202) 628-4888

REEUTTAL NO. 23 PANEL - CROSS 23119 i 'l- " procedures" the' statement appears: "The attendant was not i} ,1( j L2 familiar with the procedure and did not have a copy in the-3' ambulance." Is that -- 4: _A (Callendrello)- I'm sorry. 5 Oh, I see it. 6 Q Yes. o 7 "The attendant was not familiar with the procedure 8 and did not have a copy in the ambulance." l 9 A (Ca11endre11o)' That's what it says, yes. 10' Q That would suggest, would it not, that that was 11 not a routine procedure? Was not a matter of the ambulance-12 driver's normal routine? 13 JUDGE. SMITH: What procedure are you talking 14 about, covering the patient with a' blanket? { 15 MS. DOUGHTY: It's the whole procedure as \\ 16 described at page 187. It's the first full paragraph. 17-JUDGE SMITH: Okay. 18 MS. DOUGHTY: And it starts out " procedures." 19 THE WITNESS: (Callendrello) As I understand'the 20 question, you are asking me if this indicates that the 21 transport of contaminated injured individuals is not part of 22 their normal day-to-day routine, I would say, yes. 23 I would say, the transportation of individuals is 24 part of their normal day-to-day routine. 25 But this is not one of those cases where that Heritage Reporting Corporation [' (202) 628-4888 '( r

REBUTTAL NO. 23 PANEL - CROSS 23120 1 other constraint entered into the consideration of the 2 Extent of Play. 3 As we said in our testimony on page 30, we went to 4 FEMA guidance to determine the Extent of Play for 5 contaminated injured individuals. 6 And then Attachment C, it clearly indicated that a 7 single individual is the Extent of Play for a biennial 8 exercise, and in this case, the qualifying exercise. 9 BY MS. DOUGHTY: 10 Q Again, I would ask if you are aware of the 11 ALAB-900 discussion of the ambulance -- the extent of the 12 ambulance test in the Shoreham exercise? ) 13 A (Callendrello) What page is that on? 14 O This would be page 42 of the slip opinion. 15 A (Callendrello) That was a different issue. That 16 was not contaminated injured individuals, as I recall. 17 Q Well, did you test ambulances -- how many 18 ambulances did you test other than for this contaminated 19 individual issue? 20 A (Callendrello) Just give me one moment. 21 (Mitness reviewing document.) 22 THE WITNESS: (Callendrello) On page 60 of our 23 testimony we indicated that one ambulance and crew was 24 mobilized in support of special population evacuation. l 25 Heritage Reporting Corporation (202) 628-4888 l t l t

REBUTTAL NO. 23 PANEL - CROSS: 23121. ) } l BY-MS. DOUGHTY: y

(

j 2' O. And you' determined that that was an adequate-3 demonstration of that capability to test one ambulance? 4-A (Callendrello) New Hampshire Yankee, State of New 5 Hempshire, and FEMA and NRC jointly determined that.that:was 6 an acceptable Extent of Play in light of the. constraints 7 that were discussed in the testimony. 8 Q Would the -- strike that. 9 So overall there were two ambulances tested, then 10 .if I understand correctly, one for special needs 11 ' individuals; and one to transport a contaminated injured 12 individual. 13 Is that a correct characterization? 14 A (Callendrello) Yes, that's correct. O n( 15 Q Now, are you aware that in ALAB-900, the Licensing .\\ 16 Board concluded that performance of only one ambulance and 17 one ambulette was' inadequate? Is a test of sufficient-18 number of ambulances at Shoreham? 19 A (Callendrello) I'm aware as to what they 20 concluded, but it'was a different situation. 21 There, there had been no assessment of the 22 preparedness of the ambulance companies. At the Seabrook ~ 23 site, FEMA as Mr. Donovan described, did an evaluation of 24 the resources. You will recall, that's one of the legs of 25 the four legs he said was part of his evaluation. Heritage Reporting Corporation (202) 628-4888 -~ \\s /-

REBUTTAL NO 23 PANEL - CROSS 23122 valuation of the resources; therefore, 1 He did an t 2 he had performed the assessment of the preparedness of the 3 ambulance companies. 4 So the situations are totally different. 5 Q But at least in terms of the one ambulance tested 6 for contaminated injured, the attendant was found not 7 prepared; wouldn't you agree with that? 8 A (Callendrello) It's not my understanding that 9 ALAB-900 nor the Frye Board decision went to contaminated 10 injured ambulances. 11 There, what drove the Extent of Play was the 12 guidance that FEMA provided on the scope of the biennial 13 exercise. 14 Q So your decision to test one ambulance for 15 contaminated injured, I think I already have the answer to 16 this, but was that MS-1 at Attachment b7 17 A (Callendrello) Yes, that's correct. 18 Again, throughout this process FEMA and NRC were 19 involved in the discussions, and the states were involved in 20 the discussions in establishing the Extent of Play. 21 Q And you said there were no other constraints to l 22 testing more, but it was just based on your understanding 23 that you figured this guidance memo, was all you needed to 24 do? 25 A (Callendrello) No, I didn't say there were no Heritage Reporting Corporation (202) 628-4888 f

REBUTTAL NO. 23 PANEL - CROSS 23123 1 other constraints. .o ) 2-QL I thought you had said that. I'm sorry. 3 .Would you care to clarify? 4 A (Callendrello) There are always other 5 constraints. t.. 6 In this case, ambulances in particular, there was 7 the constraint of taking ambulances ~off the road that would 8 normally be needed to provide public safety functions or 9 transportation for persons who are in need of medical 10 transportation in order to. enhance their public safety. 11 Q If the ambulance that you had been using during 12 the exercise had been needed, you would have released it; 13 wouldn't you have? 14 A. (Ca11endre11o) I'm sure we would have. I 15 Q Are you saying -- ( 16 A (Ca11endre11o) Depending on what the need is. 17 Obviously, not to go show up in-the.Old Home Day parade, but 18 if there was a medical emergency, obviously, we would 19-release that ambulance. 20-Q I would like to move on to your testimony about 21 the testing of the New Hampshire sampling teams. 22 I just simply want to, on this issue, ask you, 23 there's a sentence that begins at the bottom of page 32 that 24 says: "During the development of the Extent of Play portion 25 of the exercise scenario representatives of the New Heritage Reporting Corporation (202) 628-4888 \\ f ___m_..m__

REBUTTAL NO. 23 PANEL - CROSS 23124 1 Hampshire Division of Public Health Services (NHDPHS) 2 requested the participation of two sampling teams on Day 2 3 of the exercise in order to limit the impact on normal state ) i 4 agency operations." q 5 And I would just like to know why was it less of a 6 limitation to have the teams on Day 2 than to have the teams ] 7 on Day 17 8 A (Gram) I'm sorry, your question is not clear. 9 But what is meant to be said here in this 10 testimony is, this deals with ingestion pathway sampling 11 teams and they weren't dispatched until Day 2. That's part 12 of the normal exercise scenario. 13 Q There's no environmental sampling done during the 14 actual radiological emergency? No collection -- 15 A (Gram) There's plume tracking sampling. 16 Q There's the monitoring function. 17 But there is also an environmental sampling 18 function which is separate. So you're saying that none of 19 that is done on Day 17 20 A (Baer) Not for the purposes of ingestion pathway 21 actions. The monitoring of sampling that is conducted on 22 Day 1 is for the purpose of formulating and confirming 23 protective action recommendations. 24 Q Now, I'm not sure if you were there, but on the 25 New Hampshire portion of the litigation there was some Heritage Reporting Corporation (202) 628-4888

I REBUTTAL NO. 23 PANEL - CROSS 23125 ef-1-- testimony that DPHS field sampling teams could go out and 2 check the water that was coming out of the reception. ~3 ' decontamination areas.. 4 That would be this type of a team, would it not? .5 A (Callendrello) I'm recalling back to that 6 testimony. 7 I don't believe that's the case. 'I think there is 8 another department within the State of New Hampshire. And 9 maybe Mr. Baer can clarify. That is responsible for 10 obtaining. water samples. 11' Q So there is more than one environmental sampling?- 12 JUDGE SMITH: Is this in contrast to. ingestion 13 sampling? 14 MS. DOUGHTY: Yes. f. I \\ 15' There is environmental sampling that goes on, I '(,) 16 believe, even during the plume. portion of the response. 17 JUDGE SMITH: But what is the relationship between 18 that and the ingestion sampling? 19 MS. DOUGHTY: Well, I'm not even trying to get 20 into the ingestion pathway at all. I'm just trying to stay 21 with Day 1 response. 22 MR. LEWALD: Is this waste water sampling? 23 MS. DOUGHTY: Well, I was just using that as an 24 example. But I'm talking about environmental sampling 25 generally. Heritage Reporting Corporation .f (202) 628-4888 [L L

l REBUTTAL NO. 23 PANEL - CROSS 23126 j 1 I'm wondering -- just trying to probe this 2 statement in the testimony that they seem to have some 3 limitation on normal state agency operation supplying the 4 two sampling teams on Day 1, so they supplied them on Day 2. 5 And I'm just wondering why that was. 6 THE WITNESS: (Callendrello) As Mr. Gram 7 explained, the concern the state had was on the number of 8 personnel. They did not say, we want to demonstrate them on 9 Day 2. 10 The scenario -- during the scenario Day 2 events 11 were the ingestion pathway, ingestion sampling events. The 12 Day 2 of the exercise clause in that testimony is just to 13 give clarification. 14 BY MS, DOUGHTY: 15 Q Are these same personnel doing some other function 16 on Day 17 Were they doing some other function, these very 17 same personnel? 18 A (Baer) No, they weren't; they were different 19 personnel. 20 Q On Day 2 do you know why the full complement of 21 teams, 100 percent of these teams couldn't be deployed? 22 JUDGE SMITH: Day 27 23 MS. DOUGHTY: Yes. Now we're accepting -- 24 THE WITNESS: (Gram) My recollection of the 25 limitation or the problem that the state had is, they didn't Heritage Reporting. Corporation (202) 628-4888

r. .c REBUTTAL NO. 23' PANEL - CROSS 23127 E.s 1 want.to shut down their state lab for other. types of' ~ 2' . emergencies'that might happen. They didn't want to-commit- [ 3 to that'for the' day of the drill. ~4 BY MS.-DOUGHTY: l: l 5 Q So supplying two more people would have required-6 them, perhaps, to have to shut down the state lab? 7 A (Gram) That's what they said. 8 Not to shut down the state lab, but to shut down 9 the ability to go out and take field samples for a hazardous 10 waste spill or an oil spill or something like that; that was 11 their concern. 12 Q I have just one question about the establishment 13 of. access. control points and traffic control points. 14 To the extent that a local community was not ,_s 15 participating and established no points, there was-no test (, 16 of the capability to go in and establish compensatory. 17 traffic control points, was there? 18 A (Ca11endre11o) That's not a true statement. 19 There was a demonstration. In fact, I indicated 20 yesterday that one of the traffic control points that the 21 state police manned was Town of Hampton traffic control 22 point which would have been compensatory response. 23 Q Was that the only compensatory response for a 24 nonparticipating community in this? 25 A (Callendrello) There was also a point manned in Heritage Reporting Corporation (202) 628-4888 x 1 _________-_____f

REBUTTAL NO. 23 PAEEL - CROSS 23128 1 Northampton which was compensatory. 2 Q But there was only one manned in each of those 3 communities and there were four nonparticipating communities 4 for which there was no compensatory action taken; is that 5 correct? 6 A (Callendrello) There were no troopers who showed 7 up in those locations. There was consideration of how those 8 points would be staffed through compensatory measures of the 9 state police; and that was handled at the incident field 10 office and Troop A. 11 But there were no troopers placed in the field for 12 those other communities in a compensatory fashion. 13 Q Now, I believe you recall that there was some 14 controversy in the litigation on the New Hampshire side 15 about the adequacy of personnel to completely staff the 16 reception and decontamination functions. 17 Do you recall that, Mr. Callendrello? 18 A (Callendrello) That was an issue that was 19 certainly litigated. We provided testimony on that. But I 20 think the Board has issued a decision, so I guess in my mind 21 it's a resolved issue. 22 O And insofar as there is a decision not to staff 23 all four of the host community reception centers, was that 24 decision in any way driven by shortages of DPHS personnel? 25 A (Gram) The answer to your question is, no. It Heritage Reporting Corporation (202) 628-4888 i

- - - _= -___7_ REBUTTAL NO. 23 PANEL CROSS 23129-gl-wasn't driven by any shortages in personnel. It was, again, l -2 driven by a concern on the state's part that they_did not 3 want to shut down all of their state functions in a 4. .nonemergency situation. 5 Q So can we-infer then, if they had-staffed all 6 _those functions it would require the shut down of normal 7 state functions in those areas? 8 A (Gram) I believe you have to ask all the 9 different state agencies that are involved. 10 But in'my mind that possibility could exist,-of 11 course, if there's an emergency. 12 Q Now, the emergency worker facility at the Hillside 13 Junior High-School in Manchester was not tested 14 contemporaneously with the exercise scenario; is'that I( 15 correct? 16 A-(Callendrello) That's correct. 17' Q And your testimony presses the point that it's 11 6 similar enough to the normal reception center functions that 19 you didn't need to do a separate test of that facility; is 20 that correct? 21 A (Callendrello) The testimony is that the Extent 22' of Play took into account the fact that people are trained L 23 to provide monitoring and decontamination functions, whether-24 it's at the emergency worker monitoring decon facility or at 25 one of the other reception centers. They receive the same Heritage Reporting Corporation (202) 628-4888 .\\

REBUTTAL NO. 23 PANEL - CROSS 23130 1 training. Therefore, the capability to respond could be 2 demonstrated at one of the other reception-centers. 3 Q Well, aren't there some respects in which the 4 emergency worker facility functions are going to be 5 different? 6 A (Callendrello) I'm sure there are. There will 7 be a lot less people there, for one thing. 8 Q Dut these are people who may have been exposed for 9 greater periods of time, since they were in the area of 10 carrying out the emergency response; is that not possibly 11 correct? 12 A (Callendrello) Well, there's a lot of assumptions 13 that go into that question. Assuming they were in the plume 14 the entire duration of their assignment. Assuming that they 15 were in the EPZ. The potential exists for that, but I 16 wouldn't say that is by any means a certainty. 17 Q Well, let's agree then that the potential exists 18 for that to be the case? 19 A (Callendrello) Okay. The potential exists. 20 But I think it's a very -- I can't even put a 21 probability on it. I'm not sure if it's great or small. 22 Q No, I guess we can't do that. We can't really 23 assign probabilities to various accident scenarios in 24 meteorological conditions. 25 A (Callendrello) In fact, it will be just as likely Heritage Reporting Corporation (202) 628-4888

l'l' REBUTTAL NO. 23 PANEL - CROSS 23131 1 that a member of the public would receive the same exposure. g-Ik_ 2 I can't make any assessment'of that likelihood. 3.- Q All right. 4 But don't these individuals have dosimetry 5 equipment to check their overall exposure, and won't that '6-need processing at the emergency worker facility? 7 A (Callendrello) Excuse me, I just want to check. '8-(Witnesses conferring. ) 9 THE WITNESS: (Baer) Would you repeat that again, 10 please. 11 BY MS. DOUGHTY: 12 Q Well, the emergency workers are supposed to be 13 issued dosimetry so that-they have a cumulative record of 14 their overall exposure. 15 A. (Baer) Correct. 16 O The general public evacuees don't have those. 17 A (Baer) Right. '18 Q Therefore they don't need to be processed at the 19 reception decontamination centers? 20 A (Beer) I'm not sure what you mean by " process." 21 The answer to the question is that, as I 22 understand it, is that the dosimetry is collected there and 23 it's processed elsewhere. 24 Q So there's going to be no immediate feedback? 25 Assume for a moment that I was an emergency worker Heritage Reporting Corporation (202) 628-4888 \\ r X-_-_-__________-..

REBUTTAL NO. 23 PANEL - CROSS 23132 1 and I was at Hampton Beach for a number of hours and I 2 accumulated a dose above the recommended guidelines for an 3 emergency worker. Nothing is going to be done to evaluate 4 that or to refer that person elsewhere at the emergency 5 worker facility? 6 A (Baer) Well, the reason the emergency workers are 7 provided with three different types of dosimetry, two of 8 which are self-reading dosimeters, so that exposure can be 9 monitored and recorded and recorded periodically so that 10 they don't exceed the exposure limits. Or something can be 11 done before they exceed exposure limits. 12 So I'm not sure I understand -- 13 JUDGE COLE: Aren't they required to read their 14 dosimetry and record it at periodic intervals? 15 THE WITNESS: (Baer) Every 15 minutes. 16 BY MS. DOUGHTY: 17 Q When they go to the emergency worker facility 18 they're supposed to turn that in -- 19 (Witnesses conferring.) 20 THE WITNESS: (Baer) Just to complete my prior 21 answer. They're also issued TLDs, which are thermal 22 luminescent dosimeters which are processed and read 23 subsequent to their assignments. And the results of which 24 they would eventually see. l 25 l Heritage Reporting Corporation (202) 628-4888 l l t

h ~ L REBUTTAL NO. 23 PANEL - CROSS' 23133. '~ r.) 1 BY:MS. DOUGHTY: D^ n 1, i 2 Q So that's not processed? 3 A (Baer) No. 4 .Q .Immediately after the exercise? 5 A- .(Baer) No. 6 O' But someone does collect that. instrumentation and 7. keeps some records with' regard to that worker's exposure, do 8 they not? 9 A-(Baer) That's correct. 10 And that's the responsibility of the Division of 11 Public. Health Services. 12 Q .But that was not tested during the exercise? 13 A (Baer) The process of collecting dosimetry from 14 emergency workers was demonstrated during the exercise. ( 15 For example, for field monitoring. teams at the .16 incident ^ field office. I believe, also -- 17 (Witnesses conferring. ) 18 19 20 21 4 ~ 22 23 24 25 Heritage Reporting Corporation /~h (202) 628-4888 .lj

REBUTTAL NO. 23 PANEL - CROSS 23134 1 THE WITNESS: (Gram) Dosimetry from emergency 2 workers was collected during the exercise. Emergency 3 workers were notified in the course of the exercise not to 4 deactivate to go to Hillside Junior High School. They were 5 told to go to the Dover reception center which was, in 6 reality, a more complicated Extent of Play than they are 7 trained to do. 8 They are trained to go to Manchester. They were 9 diverted in the middle of the exercise or at the tail-end of 10 the exercise and told to go to Dover. They did go to Dover 11 and they did turn in their dosimetry. It was collected by 12 DPHS. 13 MS. DOUGHTY: Okay. 14 BY MS. DOUGHTY: 15 Q How extensive was the test of their capability to 16 provide compensatory personnel to assist special needs 17 individuals in the nonparticipating communities? 18 (Pause.) 19 A (Callendrello) Can you just give us one moment? 20 Q Yes. 21 (Witnesses confer. ) 22 A (Callendrello) Mr. Baer has got the information. 23 A (Baer) I don't have the Extent of Play directly 24 in front of me for that. But from my recollection, those 25 actions were demonstrated, one, by the sheriff's, Rockingham Heritage Reporting Corporation (202) 628-4888

f REBUTTAL NO. 23 PANEL - CROSS 23135 1 County Sheriff's Department providing personnel.to local pf L 1,s-j transportation staging areas in the six communities. 2 l 3 Of course, the incident field office was staffed 4 by personnel known as local liaison officers for the purpose 5' of carrying out notifications to facilities in those a 6 communities, and was staffed fully on the first shift 7 specifically for that purpose with nine local liaison 8 officers. 9 Q The liaison officers.were at the IFO? 10 A (Baer) Ye s, ma ' am. 11 Q And the sheriff's deputies were at the local 12 staging area? 13-A (Baer) That's correct. 14 Q No sne simulated an ability to go out into a AQ) 15 ' nonparticipating cos.mundty to provide compensatory special -j 16 needs assistance, did they? 17 A (Callendrello) What Mr. Baer has described is 18 what the compensatory plan is. 19 As I understand your question, that's not what the - 20 compensatory plan says. The compensatory plan says we 21 establish the liaison officer. You establish'the local 22 transportation staging area. And at that point the 23 resources are deployed in the manner that would be deployed 24 if the community was participating. 25 Q But nobody actually deployed a resource to test Heritage Reporting Corporation (202) 628-4888 ..(

REBUTTAL NO. 23 PANEL - CROSS 23136 1 that function, did they? 2 A (Callendrello) Routes were run in many of the 3 communities, including those that were nonparticipating or 4 assumed to be nonparticipating on the day of the exercise. 5 Q Right. But had we talked about earlier the bus 6 drivers drive the bus, check their dosimetry and find their 7 way with the map. They don't actually get out and provide 8 assistance to a special needs individual. 9 Nobody was sent out to assist a special needs 10 individual in the course of the bus running its route, did 11 they? 12 A (Callendrello) Where I'm having trouble with the 13 question is that's not part of the compensatory plan as I 14 understand it. 15 Q Well -- 16 A (Callendrello) What you are asking is -- if what 17 you're asking is did a vehicle go to a special needs 18 individual in a nonparticipating town, I would have to 19 check. I know we did have wheelchair vans and an ambulance 20 participate in the exercise. Whether they went to a 21 participating or nonparticipating town, I don't recall 22 offhand. But I could check that. 23 Q So you are saying it's not part of the plan for a 24 special needs individual to receive actual assistance 25 boarding a bus? Heritage Reporting Corporation (202) 628-4889 i f

l [ REBUTTAL NO.-23 PANEL - CROSS 23137 ) ~ i je~' 1; A- '(Callendrello) That is part'of.the plan.. That's Ji L \\- -2 not part of the compensatory. plan. That action is the same .whether.a'communityLis-participating or not' participating. 3' i The compensatory plan provides personnel to notify' 4. facilities, to staff the local transportation l staging area, 5 6'- and from that point on the bus driver doesn't know whether It doesn't affect how he 7 it's a compensatory response. 8 responds. It's only the small components that are part of 9 the compensatory plan. 10 Q Maybe I can put it more simply. If I were a special needs individual in one of the 11 nonparticipating: communities, how would the compensatory 12 , plan assist me:in getting transportation if.I could not make-13 f3 - 14 it out to the bus route by myself? .15 A; (Callendrello) We're going of. going;back over \\_,) ground I think we plowed in the plan litigation. 16 But people who have special needs were afforded 17 the opportunity and are annually. afforded the opportunity.to 18' 19 -register:those needs with the state office ef emergency The state evaluates those needs and assigns the 20 management. 21 proper resources, transportation resources, to ensure that that person cets the assistance that they need. 22 23 So to that extent, you, as a special needs 24 individual, would have your needs taken care of in advance Whether a 25 through the state response organization. Heritage Reporting Corporation

O.

(202) 628-4888 I

REBUTTAL NO. 23 PANEL - CROSS 23138 1 community is participating or not participating on the day 2 of an emergency would not affect whether or not you were 3 provided those resources. 4 O Okay. I'm trying to determine how this capability 5 was tested during the exercise. And if I were a special 6 needs person and I put in a call to the IFO and the special j 7 population liaison took my call, and then told the bus 8 drivers at the local transportation staging area that I was 9 along a bus route and needed a ride, who would help me get 10 to the bus route? 11 And was that tested during the exercise? 12 A (Callendrello) If you needed help getting to a 13 bus route, you would not be told to go to a bus route. A 14 vehicle would be sent to your home to pick you up. 15 Q I believe there was one ambulance in Seabrook. 16 Were any ambulances assigned to the nonparticipating 17 communities to test? 18 A (Callendrello) If you give me a moment, I'll have s. 19 to check that. 20 (Witness reviews document.) 21 JUDGE SMITH: While he's checking, I understood 22 there was some urgency that we rule on the objections to Mr. 3 23 Jones' testimony. I don't see what the urgency is. 24 MR. BROCK: No, I don't think there is urgency, 25 Your Honor. That was just if there was going to be Heritage Reporting Corporation (202) 628-4888 f

REBUTTAL NO. 23 PANEL - CROSS 23139 [. .1 additional-time.this morning.. A-2 -JUDGE SMITH: Okay. 3 _(Pause.) 4 -THE-WITNESS: (Callendrello) I don't find any -- } 5 in looking_at the exercise documentation'I have, it~ appears s.- -6 that_the special needs vehicles'were not sent to any towns 7 for which a compensatory response is being provided. 8' MS. DOUGHTY: Okay. 9-BY MS.-DOUGHTY: 10 Q And'my recollection was that there were only'36 11 ambulances dedicated to the New' Hampshire response, and that-12- ,18 of those,were dedicated to hospitals. 13' Is that a correct recollection? 14 A (Callendrello) That's pretty close to my 15 recollection. 16 .And when you say " dedicated to the response", that 17 is the planning basis for establishing the transportation 18 need for ambulances. 19 Q And are those ambulance personnel the only 20 personnel dedicated to going out to the nonparticipating 21 communities to provide compensatory-assistance to special 22 needs individuals needing transportation? 23 MR. LEWALD: Your Honor, we are getting, I think, 24 or we have been, but we seem to continue be somewhat at 25 distance from the exercise or the scope of the exercise, and Heritage Reporting Corporation ( (202) 628-4888

l REBUTTAL NO. 23 PANEL - CROSS 23140 i 1 we're back to the plan actually, the New Hampshire emergency 2 plan. 3 MS. DOUGHTY: ~ Well, I thought I had understood the 4 plan before, and I obviously had a disconnect of 5 understanding with the Panel and I was just trying to get it 6 clear what the plan is and who the personnel are, so I would 7 know even which personnel should have been tested. 8 BY MS. DOUGHTY: 9 Q Do you need that question again? 10 A (Callendrello) Yes. I'm sorry. I didn't hear 11 it. 12 O Okay. I was asking if, in the nonparticipating 13 communities, the only compensatory personnel for providing 14 transportation assistance to special needs individuals are 15 the drivers of those ambulances we just discussed. 16 A (Caltendrello) No, that's not a true statement. 17 Q Maybe I should just say: Who are the personnel 18 for the special needs individuals in New Hampshire, and how 19 were they tested? 20 A (Callendrello) Personnel, and I'm interpreting 21 this to mean personnel who provide transportation resources, 22 because obviously there are other personnel who provide 23 assistance of some fashion or another to individuals. 24 There are a number of -- there are bus drivers who 25 run transportation routes. There are bus drivers who would Heritage Reporting Corporation (202) 628-4888

L pi ' REBUTTAL NO. 23 PANEL - CROSS 23141' 1' be.providing-evacuation bed buses for special facilities- 't /" ?. -{ '2. that-required them. There would be ambulance'personneltwho' A '3 would drive' ambulances into those communities that?would-q L 4' require compensatory aseistance. And.all of those l .5' individuals would serve as special needs individuals. q 6 . Q This is not a routine function for a bus driver,' 7 is'it? -1 8 A. (Ca11endre11o) "This" being driving a bus route. 9 I think it is a routine function for a. bus' driver to drive a. L ' 10 bus route. 11 There is no difference -- and I guess msybe where 12. I'm having the problem with the question is, as far as the 13 bus 1 driver knows, he doesn't know whether'it's a 14 compensatory. response or not a compensatory response. The ,[ 15 bus driver is told to report to a local transportation - 16 staging area. 17 If-it's a participating community, that 18 transportation staging area will be staffed by local 19 personnel. If it's a community that's unable to staff that 20 staging area, it's staffed by sheriff's deputies. 21 The bus driver reports there, receives sua 22 assignment and goes and performs that assignment. 23 Q Okay. 24 A (Callendrello) As far as the bus driver is 25 concerned, whether it's a compensatory or response makes no Heritage Reporting Corporation (202) 628-4888 ?

REBUTTAL NO. 23 PANEL - CROSS 23142 1 difference. 2 Q Okay. Who drives to the home of the special 3 needs individual in the nonparticipating community? 4 A (Callendrello) The same type of individual who 5 would drive to a home of a special needs individual in a 6 participating community. It makes no difference as far as 7 the transportation resource is concerned. 8 Q Who is that individual? I mean what -- 9 A (Callendrello) Either an ambulance driver, an 10 evacuation bed bus drive, bus driver, wheelchair van. 11 Q Okay, so the bus driver drives to the home. 12 What then? 13 A (Callendrello) The person gets on the bus. 14 Q What if the person requires special needs 15 assistance? 16 A (Callendrello) Then we don't send a bus driver. 17 We don't send a bus. We send an ambulance or we send a 18 wheelchair van. 19 MS. DOUGHTY: Excuse me just a moment. 20 (Counsel confers. ) 21 BY MS. DOUGHTY: 22 Q Mr. Callendrello, do you recall how many special 23 needs individuals have been identified in New Hampshire? 24 A (Callendrello) No, I don't know. 25 Q But again, we agreed before there are 36 Heritage Reporting Corporation (202) 628-4888

REBUTTAL NO. 23 PANEL - CROSS 23143 1 ambulances dedicated, 18-of them are designated for ( hospitals, and the others have to deal with all the nursing 2 3 homes and special needs individuals. 4 Is that correct? 5 A (Callendrello) The planning basis -- that's what 6 the planning basis is. Based on the identified need, that 7 need for ambulances has been established. That's not all 8 the ambulances that exist or are under letter of agreement. 9 But that is the planning basis. 10 A (Gram)- If I might add, I understood your question-11 to say that those ambulances are all the resources provided 12 for special needs. 13 That's not the case. People respond to a special 14 needs survey and they identify what their need is. If the ,-.(/f 15 survey card says, I'm bedridden and I cannot get out of my x. 16 house, then the special needs program dispatches an 17 ambulance to that house. 18 If the special needs card says, I'm in a 19 wheelchair and I can get to my front porch but I need 20 assistance getting into some kind of transportation, then 21 there is a wheelchair van that's dispatched at this part of 22 the program. 23 JUDGE SMITH: Ms. Doughty, what is your problem 24 with this situation? 25 MS. DOUGHTY: Well, my problem is that they tested Heritage Reporting Corporation (g (202) 628-4888 ? f 1

l' l l REBUTTAL NO. 23 PANEL - CROSS 23144 1 no capability to provide this compen.atory assistance to 2 special needs individuals in the nonparticipating 3 communities. And providing special needs assistance is one 4 of the objectives that's supposed to be tested. 5 JUDGE SMITH: Yes, but this problem of getting the 6 special needs person into the conveyance seems to have 7 obsessed you for some time in this cross-examination. 8 MS. DOUGHTY: Well, yes, it has. And I think it's 9 because there is just no -- 10 JUDGE SMITH: Every time you ask a question, zap, 11 right comes back +.he answer. I mean, what is it that you 12 still think you have to know? 13 Express your concern. 14 MS. DOUGHTY: Well, my concern is that there 15 wasn't a very large test of this. And I suspect that one of 16 the reasons for that is that they have very few resources 17 dedicated to this, and the ambulances -- 18 JUDGE SMITH: But that's not the line of questions 19 you are asking that I heard. 20 MS. DOUGHTY: Well, I was trying to -- we had some 21 lack of clarity in terms of what the plan actually -- who is ~ 22 actually to provide those services. And I'm learning that 23 it's the ambulances and in some cases buses are dispatched 24 for special needs as well. But they haven't dealt with the 25 problem of having somebody get the special needs person onto Heritage Reporting Corporation (202) 628-4888 r

REBUTTAL NO. 23 PANEL - CROSS 23145 1 the bus. [ t 4 2 JUDGE SMITH: At least'two times I've heard him x 1 3' explain now that if they can't get on the bus, they don't-4 get'on the bus. 5-MS. DOUGHTY: But that presumes that they have 6 enough ~ ambulances ar.d people to assist them, and that.wasn't 7 tested. 8 JUDGE SMITH:.But.then you don't follow through, 9 though. You keep.asking what if they can't get.on the bus. 10. And he says, if they can't get on the bus, we send ~somebody 11-else. You-have to follow through, or whatever. .12 MS. DOUGHTY: Okay. 13 JUDGE SMITH: Or abandon it or whatever. You are 14 stuck on this one issue. [ 15 In any event, would you wind up your examination 's. 16 for today? 17 MS. DOUGHTY: All right. 18 BY MS. DOUGHTY: 19 Q Mr. Callendrello, there were no shift changes for 20 ' sheriff's deputies -- 21 JUDGE SMITH: I didn't intend to direct you to 22 move on to the next line. I'm just pointing out our time 23-for this morning is -- I mean, don't change your line of 24 questioning because of my remarks. 25 MS. DOUGHTY: Okay. All right. Heritage Reporting Corporation (202) 628-4888 N f

REBUTTAL NO. 23 PANEL - CROSS 23146 1 JUDGE SMITH: You are certainly-free to do that. 2 MS. DOUGHTY: Okay. 3 (Laughter) 4 MS. DOUGHTY: Then I guess I'm in a quandary as to 5 which is the better tack to take at th a point. 6 JUDGE SMITH: I just want you to pick a time 7 convenient to you to break until Tuesday. 8 MS. DOUGHTY: All right. 9 BY MS. DOUGHTY: 10 Q Mr. Callendrello, we can agreement then, I.think 11 to wrap up that particular portion, that no test was made 12 during the exercise of the capability to assist a special 13 needs person to evacuate from a nonparticipating community? 14 A (Callendrello) No, I can't agree to that. 15 JUDGE SMITH: Okay, now, here is what you had 16 better do. You had better take the weekend and think about 17 this problem. 18 MS. DOUGHTY: Okay. 19 JUDGE SMITH: And come in freshly armed with the 20 questions that you need. 21 MS. DOUGHTY: All right. 22 23 24 25 Heritage Reporting Corporation (202) 628-4888

5,. 3%, - L. l > 23147 1:

JUDGE' SMITH:. Anything further before we adjourn

.2. on the record? A 3' '(No response.) 4 JUD'GE' SMITH: If not, we will adjourn. 5 (Whereupon,.at 11:14 a.m., the. hearing was 6 -recessed, to resume at 1:00 p.m., Tuesday, May 30, 7 1988.). 8 9 .10 11 12 13 .14 15 W 16 17 18 19 20 21 22 23' 24 25 Heritage Reporting Corporation (202) 628-4888 >,a

4 CERTIFICATE e-A) This is to certify that the attached proceedings before the-United States Nuclear Regulatory Commission in the matter a of: e Name:- Public Service Company of New' Hampshire, et al. (Seabrook Station, Units 1 and 2) Docket No: 50-443-OL 50-444-OL .(Off-site Emergency Planning) Place: Boston, Massachusetts Date: May.26, 1989 were held as herein appears, and that this is the original O i 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. jsj l ? (Signature typed) : Donna L. Cook Official Reporter Heritage Reporting Corporation HERITAGE REPORTING CORPORATION (202)628-4888 L - _ - _ _ _ -}}

Retrieved from "https://kanterella.com/w/index.php?title=ML20247K060&oldid=5462008"