Applicant Rebuttal Testimony 3 (Rebuttal to Testimony of Zeigler,Johnson & Cole Re Social Data Analysts,Inc Telephone Survey Conducted for Commonwealth of Ma.)* Witnesses: Bd Spencer & Ds MiletiML20148J040 |
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Seabrook |
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01/22/1988 |
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PUBLIC SERVICE CO. OF NEW HAMPSHIRE |
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ML20148H865 |
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OL, NUDOCS 8801270350 |
Download: ML20148J040 (28) |
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Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARML20217H9511999-10-21021 October 1999 Memorandum & Order.* Proceeding Re Nepco 990315 Application Seeking Commission Approval of Indirect License Transfers Consolidated,Petitioners Granted Standing & Two Issues Admitted.With Certificate of Svc.Served on 991021 ML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20211L5141999-09-0202 September 1999 Comment on Draft Reg Guide DG-4006, Demonstrating Compliance with Radiological Criteria for License Termination. Author Requests Info as to When Seabrook Station Will Be Shut Down ML20211J1451999-08-24024 August 1999 Comment Opposing NRC Consideration of Waiving Enforcement Action Against Plants That Operate Outside Terms of Licenses Due to Y2K Problems ML20210S5641999-08-13013 August 1999 Motion of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Strike Unauthorized Response of Nepco.* Unauthorized Response Fails to Comply with Commission Policy.With Certificate of Svc ML20210Q7531999-08-11011 August 1999 Order Approving Application Re Corporate Merger (Canal Electric Co). Canal Shall Provide Director of NRR Copy of Any Application,At Time Filed to Transfer Grants of Security Interests or Liens from Canal to Proposed Parent ML20210P6271999-08-10010 August 1999 Response of New England Power Company.* Nu Allegations Unsupported by Any Facts & No Genuine Issues of Matl Facts in Dispute.Commission Should Approve Application Without Hearing ML20210H8311999-08-0303 August 1999 Reply of Connecticut Light & Power Co,Western Massachusetts Electric Co & North Atlantic Energy Corp to Response of New England Power Co to Requests for Hearing.* Petitioners Request Hearing on Stated Issues.With Certificate of Svc ML20210J8501999-08-0303 August 1999 Order Approving Transfer of License & Conforming Amend.North Atlantic Energy Service Corp Authorized to Act as Agent for Joint Owners of Seabrook Unit 1 ML20211J1551999-07-30030 July 1999 Comment Opposing That NRC Allow Seabrook NPP to Operate Outside of Technical Specifications Due to Possible Y2K Problems ML20210E3011999-07-27027 July 1999 Response of New England Power Co to Requests for Hearing. Intervenors Have Presented No Justification for Oral Hearing in This Proceeding.Commission Should Reject Intervenors Request for Oral Hearing & Approve Application ML20209H9101999-07-20020 July 1999 Motion of Connecticut Light & Power Co & North Atlantic Energy Corp for Leave to Intervene & Petition for Hearing.* with Certificate of Svc & Notice of Appearance ML20195H1911999-06-15015 June 1999 Application of Montaup Electric Co & New England Power Co for Transfer of Licenses & Ownership Interests.Requests That Commission Consent to Two Indirect Transfers of Control & Direct Transfer ML20206A1611999-04-26026 April 1999 Memorandum & Order.* Informs That Montaup,Little Bay Power Corp & Nepco Settled Differences Re Transfer of Ownership of Seabrook Unit 1.Intervention Petition Withdrawn & Proceeding Terminated.With Certificate of Svc.Served on 990426 ML20205M7621999-04-15015 April 1999 Notice of Withdrawal of Intervention of New England Power Co.* New England Power Co Requests That Intervention in Proceeding Be Withdrawn & Hearing & Related Procedures Be Terminated.With Certificate of Svc CLI-99-06, Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 9904071999-04-0707 April 1999 Order.* Joint Request for ten-day Extension of Schedule Set Forth in CLI-99-06 in Order to Facilitate Parties Settlement Efforts Granted,With Exception of Date of Hearing. with Certificate of Svc.Served on 990407 ML20205G0921999-04-0505 April 1999 Joint Motion of All Active Participants for 10 Day Extension to Permit Continuation of Settlement Discussion.* Participants Request That Procedural Schedule Be Extended by 10 Days.With Certificate of Svc ML20205G3091999-03-31031 March 1999 Petition That Individuals Responsible for Discrimination Against Contract Electrician at Plant as Noted in OI Rept 1-98-005 Be Banned by NRC from Participation in Licensed Activities for at Least 5 Yrs ML20204E6401999-03-24024 March 1999 Protective Order.* Issues Protective Order to Govern Use of All Proprietary Data Contained in License Transfer Application or in Participants Written Submission & Oral Testimony.With Certificate of Svc.Served on 990324 ML20204G7671999-03-23023 March 1999 Comment Supporting Proposed Rule 10CFR50.54(a) Re Direct Final Rule,Changes to QA Programs ML20207K1941999-03-12012 March 1999 North Atlantic Energy Svc Corp Participation in Proceeding.* Naesco Wished to Remain on Svc List for All Filings.Option to Submit post-hearing Amicus Curiae Brief Will Be Retained by Naesco.With Certificate of Svc ML20207H4921999-02-12012 February 1999 Comment on Draft Contingency Plan for Year 2000 Issue in Nuclear Industry.Util Agrees to Approach Proposed by NEI ML20203F9471999-02-0909 February 1999 License Transfer Application Requesting NRC Consent to Indirect Transfer of Control of Interest in Operating License NPF-86 ML20199F7641999-01-21021 January 1999 Answer of Montaup Electric Co to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests Motion Be Denied on Basis of Late Filing.With Certificate of Svc ML20199H0451999-01-21021 January 1999 Answer of Little Bay Power Corp to Motion of Ui for Leave to Intervene & Petition to Allow Intervention out-of-time.* Requests That Ui Petition to Intervene & for Hearing Be Denied for Reasons Stated.With Certificate of Svc ML20199D2461999-01-19019 January 1999 Supplemental Affidavit of Js Robinson.* Affidavit of Js Robinson Providing Info Re Financial Results of Baycorp Holding Ltd & Baycorp Subsidiary,Great Bay Power Corp. with Certificate of Svc ML20199D2311999-01-19019 January 1999 Response of New England Power Co to Answers of Montaup Electric Co & Little Bay Power Corp.* Nep Requests That Nep Be Afforded Opportunity to File Appropriate Rule Challenge with Commission Pursuant to 10CFR2.1329 ML20206R1041999-01-13013 January 1999 Answer of Little Bay Power Corp to Motion of New England Power Co for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* with Certificate of Svc ML20206Q8451999-01-12012 January 1999 Written Comments of Massachusetts Municipal Wholesale Electric Co.* Requests That Commission Consider Potential Financial Risk to Other Joint Owners Associated with License Transfer.With Certificate of Svc.Served on 990114 ML20199A4741999-01-12012 January 1999 Answer of Montaup Electric Co to Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Nepco 990104 Motion Should Be Denied for Reasons Stated.With Certificate of Svc ML20206Q0151999-01-12012 January 1999 North Atlantic Energy Svc Corp Answer to Petition to Intervene of New England Power Co.* If Commission Deems It Appropriate to Explore Issues Further in Subpart M Hearing Context,Naesco Will Participate.With Certificate of Svc ML20199A4331999-01-11011 January 1999 Motion of United Illuminating Co for Leave to Intervene & Petition to Allow Intervention out-of-time.* Company Requests That Petition to Allow Intervention out-of-time Be Granted.With Certificate of Svc ML20198P7181998-12-31031 December 1998 Motion of Nepco for Leave to Intervene & Petition for Summary Relief Or,In Alternative,For Hearing.* Moves to Intervene in Transfer of Montaup Seabrook Ownership Interest & Petitions for Summary Relief or for Hearing ML20198P7551998-12-30030 December 1998 Affidavit of J Robinson.* Affidavit of J Robinson Describing Events to Date in New England Re Premature Retirement of Npps,Current Plans to Construct New Generation in Region & Impact on Seabrook Unit 1 Operation.With Certificate of Svc ML20195K4061998-11-24024 November 1998 Memorandum & Order.* North Atlantic Energy Services Corp Granted Motion to Withdraw Proposed Amends & Dismiss Related Adjudicatory Proceedings as Moot.Board Decision LBP-98-23 Vacated.With Certificate of Svc.Served on 981124 ML20155J1071998-11-0909 November 1998 NRC Staff Answer to North Atlantic Energy Svc Corp Motion for Leave to File Reply.* Staff Does Not Object to North Atlantic Energy Svc Corp Motion.With Certificate of Svc ML20155D0041998-10-30030 October 1998 Motion for Leave to File Reply.* Licensee Requests Leave to Reply to Petitioner 981026 Response to Licensee 981015 Motion to Terminate Proceedings.Reply Necessary to Assure That Commission Is Fully Aware of Licensee Position ML20155D0121998-10-30030 October 1998 Reply to Petitioner Response to Motion to Terminate Proceedings.* Licensee Views Segmentation Issue as Moot & Requests Termination of Subj Proceedings.With Certificate of Svc ML20155B1641998-10-26026 October 1998 Response to Motion by Naesco to Withdraw Applications & to Terminate Proceedings.* If Commission Undertakes to Promptly Proceed on Issue on Generic Basis,Sapl & Necnp Will Have No Objection to Naesco Motion.With Certificate of Svc ML20154K8751998-10-15015 October 1998 Motion to Withdraw Applications & to Terminate Proceedings.* NRC Does Not Intend to Oppose Motion.With Certificate of Svc ML17265A8071998-10-0606 October 1998 Comment on Integrated Review of Assessment Process for Commercial Npps.Util Endorses Comments Being Provided by NEI on Behalf of Nuclear Industry ML20154C8171998-10-0606 October 1998 Notice of Appointment of Adjudicatory Employee.* Notice Given That W Reckley Appointed as Commission Adjudicatory Employee to Advise Commission on Issues Related to Review of LBP-98-23.With Certificate of Svc.Served on 981006 CLI-98-18, Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 9810061998-10-0505 October 1998 Order.* Grants Joint Motion Filed by Naesco,Sapl & Necnp for Two Week Deferral of Briefing Schedule Set by Commission in CLI-98-18.With Certificate of Svc.Served on 981006 ML20153H4471998-10-0101 October 1998 Joint Motion of Schedule Deferral.* Naesco,Sapl & Necnp Jointly Request Temporary Deferral of Briefing Schedule as Established by Commission Order of 980917 (CLI-98-18). with Certificate of Svc ML20154F9891998-09-29029 September 1998 License Transfer Application Requesting Consent for Transfer of Montaup Electric Co Interest in Operating License NPF-86 for Seabrook Station,Unit 1,to Little Bay Power Corp ML20154D7381998-09-21021 September 1998 Affidavit of FW Getman Requesting Exhibit 1 to License Transfer Application Be Withheld from Public Disclosure,Per 10CFR2.790 ML20153C7791998-09-18018 September 1998 Comment Supporting Proposed Rule 10CFR50 Re Reporting Requirements for Nuclear Power Reactors.Util Endorses NRC Staff Focus on Operability & Funtionality of Equipment & NEI Comments ML20151Z5611998-09-18018 September 1998 Order.* Pursuant to Commission Order CLI-98-18 Re Seabrook Unit 1 Proceeding,Schedule Described in Board 980904 Memorandum & Order Hereby Revoked Pending Further Action. with Certificate of Svc.Served on 980918 ML20151Y0331998-09-17017 September 1998 Order.* All Parties,Including Util,May File Brief No Later than 981007.Brief Shall Not Exceed 30 Pages.Commission May Schedule Oral Argument to Discuss Issues,After Receiving Responses.With Certificate of Svc.Served on 980917 ML20153E8771998-09-16016 September 1998 Comment Opposing Draft NUREG-1633, Assessment of Use of Potassium Iodide (Ki) as Protective Action During Severe Reactor Accidents. Recommends That NRC Reverse Decision to Revise Emergency Planning Regulation as Listed 1999-09-02
[Table view] Category:TRANSCRIPTS
MONTHYEARML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20236U5071998-07-20020 July 1998 Testimony of RA Backus on Behalf of Campaign for Ratepayer Rights ML20236T9111998-07-20020 July 1998 Testimony of Js Robinson Re Licensing of Facility ML20072V0131991-04-10010 April 1991 Transcript of 910410 Meeting in Rockville,Md Re Pullman- Higgins Field Weld Records Reverification Project.Pp 1-53. Supporting Documentation Encl ML20062B8601990-09-18018 September 1990 Transcript of 900918 Public Meeting W/Util in King of Prussia,Pa to Discuss Assessment of Power Ascension Test Program.Pp 1-100 ML20055D0961990-06-19019 June 1990 Transcript of 900619 Public Meeting in King of Prussia,Pa to Brief NRC on Assessment of Status & Results of Power Ascension Test Program.Pp 1-75.Supporting Info Encl ML20059F7101990-03-14014 March 1990 Transcript of Committee on Interior & Insular Affairs Subcommittee on General Oversight & Investigations 900314 Hearing on Licensing Procedures of NRC for Facility ML20245L5921989-08-17017 August 1989 Transcript of ACRS Subcommittee on Seabrook 890817 Meeting in Bethesda,Md.Pp 1-198.Related Info Encl ML20247M6371989-07-27027 July 1989 Transcript of Aslab 890727 Oral Argument in Bethesda,Md Re Offsite Emergency Planning.Pp 1-206.Supporting Info Encl ML20246F4441989-07-12012 July 1989 Transcript of 890712 Oral Argument in Bethesda,Md Re Offsite Emergency Planning Issues.Pp 1-103 ML20246A1481989-06-30030 June 1989 Transcript of ASLB 890630 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 28,185-28,296.Related Info Encl.Witness:Tj Adler ML20246N6791989-06-30030 June 1989 Rebuttal Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Interaction of Commuter Flow & Evacuation Traffic Flow within Seabrook Epz.* W/ Certificate of Svc.Related Correspondence ML20245K9531989-06-29029 June 1989 Transcript of ASLB 890629 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 28,051-28,184.Supporting Info Encl.Witnesses:O Renn,Am Callendrello & Eb Lieberman ML20245J7811989-06-28028 June 1989 Transcript of ASLB 890628 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,779-28,050.Supporting Info Encl.Witnesses:Am Callendrello,Ds Mileti,G Catapano & Cj High ML20245J7731989-06-27027 June 1989 Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re JI-56 (Monitoring Rate).* Evacuee Loads Could Possibly Be Higher than Estimates.W/ Certificate of Svc.Related Correspondence ML20245J4821989-06-27027 June 1989 Transcript of 890627 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,427-27,778.Supporting Info Encl.Witnesses:Sj Ellis,Am Callendrello,Cm Frank,Tf Grew & Tm Carter ML20245J7551989-06-27027 June 1989 Errata to Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Contention JI-56 (Monitoring Rate).* Related Correspondence ML20245J7421989-06-26026 June 1989 Testimony of O Renn on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Re JI-56 & Transit Time Through Reception Ctrs.* Using Estimated Stay Time/Carload of Under 25 Minutes Not Prudent.W/Certificate of Svc.Related Correspondence ML20245J5441989-06-26026 June 1989 Surrebuttal Testimony of Ba Burrows on Issues Re MS-1 Hosps, Reception/Decontamination Ctrs & FEMA (Gm) MS-1 Guidance.* Success in Monitoring Such Large Group within 12 H Unlikely. W/Certificate of Svc.Related Correspondence ML20245J2521989-06-26026 June 1989 Transcript of 890626 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,250-27,426.Supporting Info Encl.Witnesses:Am Callendrello,Wf Renz,G Catapano,Sj Ellis, Tf Grew & CM Frank ML20245G1641989-06-23023 June 1989 Transcript of 890623 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,131-27,249.Related Info Encl.Witnesses:T Urbanik,Wf Renz,Am Callendrello & G Catapano ML20245D5881989-06-22022 June 1989 Transcript of 890622 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,854-27,130.Witnesses: Am Callendrello & Eb Lieberman ML20245J4021989-06-21021 June 1989 Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Contention of JI-56 (Monitoring Rate).* Evacuee Load Estimates Will Likley Be Exceeded.W/Certificate of Svc.Related Correspondence ML20245C1231989-06-21021 June 1989 Transcript of 890621 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,586-26,853.Witnesses: Am Callendrello & Eb Lieberman.Supporting Info Encl ML20245B3761989-06-20020 June 1989 Transcript of ASLB 890620 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,282-26,585.Related Info Encl.Witnesses:Tj Adler & T Urbanik ML20245A2831989-06-19019 June 1989 Transcript of 890619 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,137-26,281.Related Info Encl.Witnesses:H Harris & Tj Adler ML20245D4671989-06-19019 June 1989 Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Re Contention JI-56, Reception Ctr Parking.* Estimates of Parking Capacity at Ctr Found Unreasonable.W/Certificate of Svc.Related Correspondence ML20245A4661989-06-16016 June 1989 Transcript of 890616 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,033-26,136.Supporting Info Encl.Witness:Si Cohn ML20244E1381989-06-15015 June 1989 Transcript of 890615 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,794-26,032.Witnesses: J Bisson,Am Callendrello,R Cotter & P Littlefield ML20244D6061989-06-14014 June 1989 Transcript of 890614 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,527-25,793.Related Info Encl.Witnesses:D Breton,J Van Gelder,R Cotter,J Bisson, Am Callendrello & P Littlefield ML20245A7061989-06-13013 June 1989 Suppl to Applicant Rebuttal Testimony 16 (Interaction of Commuter Traffic Flow & Evacuation Traffic Flow within Seabrook Epz).* W/Supporting Info & Certificate of Svc. Related Correspondence ML20244D6131989-06-13013 June 1989 Transcript of 890613 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,227-25,526.Witnesses: J Bisson,Am Callendrello,R Cotter & P Littlefield ML20244E0281989-06-12012 June 1989 Transcript of ASLB 890612 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,065-25,226 ML20244C9661989-06-0909 June 1989 Transcript of 890609 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,965-25,064.Witness: CS Glick.Supporting Documentation Encl ML20244B7461989-06-0808 June 1989 Transcript of 890608 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,610-24,964.Witnesses: Ef Fox,Rj Bores ML20244A9041989-06-0707 June 1989 Transcript of 890607 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,363-24,609.Witness: Rl Goble ML20244A8961989-06-0606 June 1989 Transcript of 890606 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,102-24,362.Related Info Encl.Witness:Rl Goble ML20248A5491989-06-0505 June 1989 Transcript of 890605 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,931-24,101.Supporting Info Encl.Witnesses:Cm Frank,Am Callendrello & Jg Robinson ML20247Q5981989-06-0202 June 1989 Transcript of 890602 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,821-23,930.Witnesses: CM Frank,Am Callendrello & Jg Robinson ML20248B5421989-06-0101 June 1989 Suppl to Applicant Rebuttal Testimony 17 (Reception Ctr Parking).* Testimony Re Calculation of Parking Spaces Needed Per Facility to Maintain Flow of Evacuees Through Monitoring Trailers.W/Certificate of Svc.Related Correspondence ML20247N8031989-06-0101 June 1989 Transcript of 890601 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,547-23,820.Witnesses: Cm Frank,Am Callendrello,Jg Robinson ML20247M9471989-05-30030 May 1989 Transcript of 890530 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,148-23,290.W/supporting Info.Witnesses:Jw Baer,Am Callendrello,Gr Gram,H Saxner, G St Hilaire ML20247K0601989-05-26026 May 1989 Transcript of 890526 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,042-23,147.Witnesses: JW Baer,Am Callendrello,Gr Gram ML20247G1821989-05-25025 May 1989 Transcript of 890525 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,784-23,041.Witnesses: JW Baer,Am Callendrello,Gr Gram ML20244A8791989-05-24024 May 1989 Transcript of 890524 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-4 ML20247F7691989-05-24024 May 1989 Transcript of 890524 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,507-22,783.Supporting Documentation Encl ML20247E7311989-05-23023 May 1989 Transcript of 890523 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,264-22,506 ML20247D4451989-05-22022 May 1989 Transcript of 890522 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,171-22,263.Witness: RW Donovan ML20247E0081989-05-22022 May 1989 Errata Sheet to Corrected Testimony of Gw Sikich & J Paolillo on Behalf of Atty General Jm Shannon,Town of Hampton,Necnp & Seacoast Anti-Pollution League Re Toh/Necnp Ex 1(a) & (B).* ML20247A9771989-05-19019 May 1989 Transcript of 890519 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22.064-22,170.Witness: RW Donovan 1999-10-21
[Table view] Category:DEPOSITIONS
MONTHYEARML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20236U5071998-07-20020 July 1998 Testimony of RA Backus on Behalf of Campaign for Ratepayer Rights ML20236T9111998-07-20020 July 1998 Testimony of Js Robinson Re Licensing of Facility ML20072V0131991-04-10010 April 1991 Transcript of 910410 Meeting in Rockville,Md Re Pullman- Higgins Field Weld Records Reverification Project.Pp 1-53. Supporting Documentation Encl ML20062B8601990-09-18018 September 1990 Transcript of 900918 Public Meeting W/Util in King of Prussia,Pa to Discuss Assessment of Power Ascension Test Program.Pp 1-100 ML20055D0961990-06-19019 June 1990 Transcript of 900619 Public Meeting in King of Prussia,Pa to Brief NRC on Assessment of Status & Results of Power Ascension Test Program.Pp 1-75.Supporting Info Encl ML20059F7101990-03-14014 March 1990 Transcript of Committee on Interior & Insular Affairs Subcommittee on General Oversight & Investigations 900314 Hearing on Licensing Procedures of NRC for Facility ML20245L5921989-08-17017 August 1989 Transcript of ACRS Subcommittee on Seabrook 890817 Meeting in Bethesda,Md.Pp 1-198.Related Info Encl ML20247M6371989-07-27027 July 1989 Transcript of Aslab 890727 Oral Argument in Bethesda,Md Re Offsite Emergency Planning.Pp 1-206.Supporting Info Encl ML20246F4441989-07-12012 July 1989 Transcript of 890712 Oral Argument in Bethesda,Md Re Offsite Emergency Planning Issues.Pp 1-103 ML20246A1481989-06-30030 June 1989 Transcript of ASLB 890630 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 28,185-28,296.Related Info Encl.Witness:Tj Adler ML20246N6791989-06-30030 June 1989 Rebuttal Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Interaction of Commuter Flow & Evacuation Traffic Flow within Seabrook Epz.* W/ Certificate of Svc.Related Correspondence ML20245K9531989-06-29029 June 1989 Transcript of ASLB 890629 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 28,051-28,184.Supporting Info Encl.Witnesses:O Renn,Am Callendrello & Eb Lieberman ML20245J7811989-06-28028 June 1989 Transcript of ASLB 890628 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,779-28,050.Supporting Info Encl.Witnesses:Am Callendrello,Ds Mileti,G Catapano & Cj High ML20245J7731989-06-27027 June 1989 Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re JI-56 (Monitoring Rate).* Evacuee Loads Could Possibly Be Higher than Estimates.W/ Certificate of Svc.Related Correspondence ML20245J4821989-06-27027 June 1989 Transcript of 890627 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,427-27,778.Supporting Info Encl.Witnesses:Sj Ellis,Am Callendrello,Cm Frank,Tf Grew & Tm Carter ML20245J7551989-06-27027 June 1989 Errata to Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Contention JI-56 (Monitoring Rate).* Related Correspondence ML20245J7421989-06-26026 June 1989 Testimony of O Renn on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Re JI-56 & Transit Time Through Reception Ctrs.* Using Estimated Stay Time/Carload of Under 25 Minutes Not Prudent.W/Certificate of Svc.Related Correspondence ML20245J5441989-06-26026 June 1989 Surrebuttal Testimony of Ba Burrows on Issues Re MS-1 Hosps, Reception/Decontamination Ctrs & FEMA (Gm) MS-1 Guidance.* Success in Monitoring Such Large Group within 12 H Unlikely. W/Certificate of Svc.Related Correspondence ML20245J2521989-06-26026 June 1989 Transcript of 890626 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,250-27,426.Supporting Info Encl.Witnesses:Am Callendrello,Wf Renz,G Catapano,Sj Ellis, Tf Grew & CM Frank ML20245G1641989-06-23023 June 1989 Transcript of 890623 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,131-27,249.Related Info Encl.Witnesses:T Urbanik,Wf Renz,Am Callendrello & G Catapano ML20245D5881989-06-22022 June 1989 Transcript of 890622 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,854-27,130.Witnesses: Am Callendrello & Eb Lieberman ML20245J4021989-06-21021 June 1989 Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Contention of JI-56 (Monitoring Rate).* Evacuee Load Estimates Will Likley Be Exceeded.W/Certificate of Svc.Related Correspondence ML20245C1231989-06-21021 June 1989 Transcript of 890621 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,586-26,853.Witnesses: Am Callendrello & Eb Lieberman.Supporting Info Encl ML20245B3761989-06-20020 June 1989 Transcript of ASLB 890620 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,282-26,585.Related Info Encl.Witnesses:Tj Adler & T Urbanik ML20245A2831989-06-19019 June 1989 Transcript of 890619 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,137-26,281.Related Info Encl.Witnesses:H Harris & Tj Adler ML20245D4671989-06-19019 June 1989 Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Re Contention JI-56, Reception Ctr Parking.* Estimates of Parking Capacity at Ctr Found Unreasonable.W/Certificate of Svc.Related Correspondence ML20245A4661989-06-16016 June 1989 Transcript of 890616 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,033-26,136.Supporting Info Encl.Witness:Si Cohn ML20244E1381989-06-15015 June 1989 Transcript of 890615 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,794-26,032.Witnesses: J Bisson,Am Callendrello,R Cotter & P Littlefield ML20244D6061989-06-14014 June 1989 Transcript of 890614 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,527-25,793.Related Info Encl.Witnesses:D Breton,J Van Gelder,R Cotter,J Bisson, Am Callendrello & P Littlefield ML20245A7061989-06-13013 June 1989 Suppl to Applicant Rebuttal Testimony 16 (Interaction of Commuter Traffic Flow & Evacuation Traffic Flow within Seabrook Epz).* W/Supporting Info & Certificate of Svc. Related Correspondence ML20244D6131989-06-13013 June 1989 Transcript of 890613 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,227-25,526.Witnesses: J Bisson,Am Callendrello,R Cotter & P Littlefield ML20244E0281989-06-12012 June 1989 Transcript of ASLB 890612 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,065-25,226 ML20244C9661989-06-0909 June 1989 Transcript of 890609 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,965-25,064.Witness: CS Glick.Supporting Documentation Encl ML20244B7461989-06-0808 June 1989 Transcript of 890608 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,610-24,964.Witnesses: Ef Fox,Rj Bores ML20244A9041989-06-0707 June 1989 Transcript of 890607 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,363-24,609.Witness: Rl Goble ML20244A8961989-06-0606 June 1989 Transcript of 890606 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,102-24,362.Related Info Encl.Witness:Rl Goble ML20248A5491989-06-0505 June 1989 Transcript of 890605 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,931-24,101.Supporting Info Encl.Witnesses:Cm Frank,Am Callendrello & Jg Robinson ML20247Q5981989-06-0202 June 1989 Transcript of 890602 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,821-23,930.Witnesses: CM Frank,Am Callendrello & Jg Robinson ML20248B5421989-06-0101 June 1989 Suppl to Applicant Rebuttal Testimony 17 (Reception Ctr Parking).* Testimony Re Calculation of Parking Spaces Needed Per Facility to Maintain Flow of Evacuees Through Monitoring Trailers.W/Certificate of Svc.Related Correspondence ML20247N8031989-06-0101 June 1989 Transcript of 890601 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,547-23,820.Witnesses: Cm Frank,Am Callendrello,Jg Robinson ML20247M9471989-05-30030 May 1989 Transcript of 890530 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,148-23,290.W/supporting Info.Witnesses:Jw Baer,Am Callendrello,Gr Gram,H Saxner, G St Hilaire ML20247K0601989-05-26026 May 1989 Transcript of 890526 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,042-23,147.Witnesses: JW Baer,Am Callendrello,Gr Gram ML20247G1821989-05-25025 May 1989 Transcript of 890525 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,784-23,041.Witnesses: JW Baer,Am Callendrello,Gr Gram ML20244A8791989-05-24024 May 1989 Transcript of 890524 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-4 ML20247F7691989-05-24024 May 1989 Transcript of 890524 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,507-22,783.Supporting Documentation Encl ML20247E7311989-05-23023 May 1989 Transcript of 890523 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,264-22,506 ML20247D4451989-05-22022 May 1989 Transcript of 890522 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,171-22,263.Witness: RW Donovan ML20247E0081989-05-22022 May 1989 Errata Sheet to Corrected Testimony of Gw Sikich & J Paolillo on Behalf of Atty General Jm Shannon,Town of Hampton,Necnp & Seacoast Anti-Pollution League Re Toh/Necnp Ex 1(a) & (B).* ML20247A9771989-05-19019 May 1989 Transcript of 890519 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22.064-22,170.Witness: RW Donovan 1999-10-21
[Table view] Category:NARRATIVE TESTIMONY
MONTHYEARML20217N2561999-10-21021 October 1999 Transcript of Affirmation Session on 990121 in Rockville, Maryland Re Memorandum & Order Responding to Petitions to Intervene Filed by co-owners of Seabrook Station Unit 1 & Millstone Station Unit Three.Pp 1-3 ML20236U5071998-07-20020 July 1998 Testimony of RA Backus on Behalf of Campaign for Ratepayer Rights ML20236T9111998-07-20020 July 1998 Testimony of Js Robinson Re Licensing of Facility ML20072V0131991-04-10010 April 1991 Transcript of 910410 Meeting in Rockville,Md Re Pullman- Higgins Field Weld Records Reverification Project.Pp 1-53. Supporting Documentation Encl ML20062B8601990-09-18018 September 1990 Transcript of 900918 Public Meeting W/Util in King of Prussia,Pa to Discuss Assessment of Power Ascension Test Program.Pp 1-100 ML20055D0961990-06-19019 June 1990 Transcript of 900619 Public Meeting in King of Prussia,Pa to Brief NRC on Assessment of Status & Results of Power Ascension Test Program.Pp 1-75.Supporting Info Encl ML20059F7101990-03-14014 March 1990 Transcript of Committee on Interior & Insular Affairs Subcommittee on General Oversight & Investigations 900314 Hearing on Licensing Procedures of NRC for Facility ML20245L5921989-08-17017 August 1989 Transcript of ACRS Subcommittee on Seabrook 890817 Meeting in Bethesda,Md.Pp 1-198.Related Info Encl ML20247M6371989-07-27027 July 1989 Transcript of Aslab 890727 Oral Argument in Bethesda,Md Re Offsite Emergency Planning.Pp 1-206.Supporting Info Encl ML20246F4441989-07-12012 July 1989 Transcript of 890712 Oral Argument in Bethesda,Md Re Offsite Emergency Planning Issues.Pp 1-103 ML20246A1481989-06-30030 June 1989 Transcript of ASLB 890630 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 28,185-28,296.Related Info Encl.Witness:Tj Adler ML20246N6791989-06-30030 June 1989 Rebuttal Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Interaction of Commuter Flow & Evacuation Traffic Flow within Seabrook Epz.* W/ Certificate of Svc.Related Correspondence ML20245K9531989-06-29029 June 1989 Transcript of ASLB 890629 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 28,051-28,184.Supporting Info Encl.Witnesses:O Renn,Am Callendrello & Eb Lieberman ML20245J7811989-06-28028 June 1989 Transcript of ASLB 890628 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,779-28,050.Supporting Info Encl.Witnesses:Am Callendrello,Ds Mileti,G Catapano & Cj High ML20245J7731989-06-27027 June 1989 Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re JI-56 (Monitoring Rate).* Evacuee Loads Could Possibly Be Higher than Estimates.W/ Certificate of Svc.Related Correspondence ML20245J4821989-06-27027 June 1989 Transcript of 890627 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,427-27,778.Supporting Info Encl.Witnesses:Sj Ellis,Am Callendrello,Cm Frank,Tf Grew & Tm Carter ML20245J7551989-06-27027 June 1989 Errata to Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Contention JI-56 (Monitoring Rate).* Related Correspondence ML20245J7421989-06-26026 June 1989 Testimony of O Renn on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Re JI-56 & Transit Time Through Reception Ctrs.* Using Estimated Stay Time/Carload of Under 25 Minutes Not Prudent.W/Certificate of Svc.Related Correspondence ML20245J5441989-06-26026 June 1989 Surrebuttal Testimony of Ba Burrows on Issues Re MS-1 Hosps, Reception/Decontamination Ctrs & FEMA (Gm) MS-1 Guidance.* Success in Monitoring Such Large Group within 12 H Unlikely. W/Certificate of Svc.Related Correspondence ML20245J2521989-06-26026 June 1989 Transcript of 890626 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,250-27,426.Supporting Info Encl.Witnesses:Am Callendrello,Wf Renz,G Catapano,Sj Ellis, Tf Grew & CM Frank ML20245G1641989-06-23023 June 1989 Transcript of 890623 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 27,131-27,249.Related Info Encl.Witnesses:T Urbanik,Wf Renz,Am Callendrello & G Catapano ML20245D5881989-06-22022 June 1989 Transcript of 890622 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,854-27,130.Witnesses: Am Callendrello & Eb Lieberman ML20245J4021989-06-21021 June 1989 Revised Testimony of Cj High on Behalf of Jm Shannon,Atty General for Commonwealth of Ma Re Contention of JI-56 (Monitoring Rate).* Evacuee Load Estimates Will Likley Be Exceeded.W/Certificate of Svc.Related Correspondence ML20245C1231989-06-21021 June 1989 Transcript of 890621 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,586-26,853.Witnesses: Am Callendrello & Eb Lieberman.Supporting Info Encl ML20245B3761989-06-20020 June 1989 Transcript of ASLB 890620 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,282-26,585.Related Info Encl.Witnesses:Tj Adler & T Urbanik ML20245A2831989-06-19019 June 1989 Transcript of 890619 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,137-26,281.Related Info Encl.Witnesses:H Harris & Tj Adler ML20245D4671989-06-19019 June 1989 Testimony of Tj Adler on Behalf of Jm Shannon,Atty General for Commonwealth of Ma,Re Contention JI-56, Reception Ctr Parking.* Estimates of Parking Capacity at Ctr Found Unreasonable.W/Certificate of Svc.Related Correspondence ML20245A4661989-06-16016 June 1989 Transcript of 890616 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 26,033-26,136.Supporting Info Encl.Witness:Si Cohn ML20244E1381989-06-15015 June 1989 Transcript of 890615 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,794-26,032.Witnesses: J Bisson,Am Callendrello,R Cotter & P Littlefield ML20244D6061989-06-14014 June 1989 Transcript of 890614 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,527-25,793.Related Info Encl.Witnesses:D Breton,J Van Gelder,R Cotter,J Bisson, Am Callendrello & P Littlefield ML20245A7061989-06-13013 June 1989 Suppl to Applicant Rebuttal Testimony 16 (Interaction of Commuter Traffic Flow & Evacuation Traffic Flow within Seabrook Epz).* W/Supporting Info & Certificate of Svc. Related Correspondence ML20244D6131989-06-13013 June 1989 Transcript of 890613 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,227-25,526.Witnesses: J Bisson,Am Callendrello,R Cotter & P Littlefield ML20244E0281989-06-12012 June 1989 Transcript of ASLB 890612 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 25,065-25,226 ML20244C9661989-06-0909 June 1989 Transcript of 890609 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,965-25,064.Witness: CS Glick.Supporting Documentation Encl ML20244B7461989-06-0808 June 1989 Transcript of 890608 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,610-24,964.Witnesses: Ef Fox,Rj Bores ML20244A9041989-06-0707 June 1989 Transcript of 890607 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,363-24,609.Witness: Rl Goble ML20244A8961989-06-0606 June 1989 Transcript of 890606 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 24,102-24,362.Related Info Encl.Witness:Rl Goble ML20248A5491989-06-0505 June 1989 Transcript of 890605 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,931-24,101.Supporting Info Encl.Witnesses:Cm Frank,Am Callendrello & Jg Robinson ML20247Q5981989-06-0202 June 1989 Transcript of 890602 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,821-23,930.Witnesses: CM Frank,Am Callendrello & Jg Robinson ML20248B5421989-06-0101 June 1989 Suppl to Applicant Rebuttal Testimony 17 (Reception Ctr Parking).* Testimony Re Calculation of Parking Spaces Needed Per Facility to Maintain Flow of Evacuees Through Monitoring Trailers.W/Certificate of Svc.Related Correspondence ML20247N8031989-06-0101 June 1989 Transcript of 890601 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,547-23,820.Witnesses: Cm Frank,Am Callendrello,Jg Robinson ML20247M9471989-05-30030 May 1989 Transcript of 890530 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,148-23,290.W/supporting Info.Witnesses:Jw Baer,Am Callendrello,Gr Gram,H Saxner, G St Hilaire ML20247K0601989-05-26026 May 1989 Transcript of 890526 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 23,042-23,147.Witnesses: JW Baer,Am Callendrello,Gr Gram ML20247G1821989-05-25025 May 1989 Transcript of 890525 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,784-23,041.Witnesses: JW Baer,Am Callendrello,Gr Gram ML20244A8791989-05-24024 May 1989 Transcript of 890524 Affirmation/Discussion & Vote in Rockville,Md.Pp 1-4 ML20247F7691989-05-24024 May 1989 Transcript of 890524 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,507-22,783.Supporting Documentation Encl ML20247E7311989-05-23023 May 1989 Transcript of 890523 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,264-22,506 ML20247D4451989-05-22022 May 1989 Transcript of 890522 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22,171-22,263.Witness: RW Donovan ML20247E0081989-05-22022 May 1989 Errata Sheet to Corrected Testimony of Gw Sikich & J Paolillo on Behalf of Atty General Jm Shannon,Town of Hampton,Necnp & Seacoast Anti-Pollution League Re Toh/Necnp Ex 1(a) & (B).* ML20247A9771989-05-19019 May 1989 Transcript of 890519 Evidentiary Hearing in Boston,Ma Re Offsite Emergency Planning.Pp 22.064-22,170.Witness: RW Donovan 1999-10-21
[Table view] |
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9 DOLKETED U5Niit Dated: January 22, 1988 TB JMI 26 N1:45 UNITED STATES OF AMERICA 0FFlcF of Sy , y, ,
00CxEitm;3 stiq u3' NUCLEAR REGULATORY COMMISSION ORANCH before the ATOMIC SAFETY AND LICENSING BOARD
)
In the Matter of )
)
PUBLIC SERVICE COMPANY ) Docket Nos. 50-443-OL OF NEW HAMPSHIRE, et al. ) 50-444-OL
)
(Seabrook Station, Units 1 ) (Offsite Emergency and 2) ) Planning Issues)
)
APPLICANTS' REBUTTAL TESTIMONY NO. 3 (REBUTTAL TO THE TESTIMONY OF ZEIGLER, JOHNSON AND COLE REGARDING THE SDA TELEPHONE SURVEY CONDUCTED FOR THE COMMONWEALTH OF MASSACHUSETTS)
Witnesses: Bruce D. Spencer Dennis S. Mileti Applicants' rebuttal testimony regarding the Telephone Survey conducted by Social Data Analysts, Inc., ("SDA") at the request of the Attorney General for the Commonwealth of Massachusetts was developed from two viewpoints. First, a study was done with regard to external validity, or the ability of the Survey findings to be generalized to the general population which did not participate in the Survey.
The second area of review looked at internal validity or the examination of the questions within the questionnaire with I 8801270350 880122 PDR ADOCK 05000443 T PDR
- n
regard to the ability of those questions and answers, actually to measure what they purport to measure with associated freedom from systematic error or bias. These two viewpoints are presented below.
However, first, and perhaps of foremost importance, is the fact that the SDA Telephone Survey is a study of behavi7ral intentions. Pre-emergency intentions have little if anything to do with actual behaviqr. The lack of relationship between behavioral intentions and actual future behavior in a real emergency is as true for the public as for special sub-groups such as emergency workers. This basic and profoundly important point must hot be lost in the context of the critique of the technical aspects of SDA's poll which follows. Even a behavioral intentions poll that was not troubled by factore which would detract from its external and internal validity would not produce data indicative of actual public response to an actual future emergency which has not been experienced. Human response in an actual emergency is largely directed by factors which prevail during the emergency as it is being experienced. These factors, for example, would include the frequency with which emergency warnings are heard and confirmed, interaction with other persons as people engage in response decision-making, and other such factors which cannot be taken into account by a pre-emergency poll. Behavioral intentions regarding future emergency response by a segment of the public would not be 2
L
" . . . roughly representative of what the EPZ population would do in an accident at the Seabrook Station" (Testimony of Zeigler, Johnson and Cole, p. 18) again, even if the SDA poll were free of external and internal validity problems.
Such intentions, in other words, can be nothing more than what interviewees thought on the day that they were interviewed taking into account only what they may or may not have had in mind when they answered the Survey questions. In contrast, actual public behavior in an actual future emergency is the consequence of factors and relationships which cannot be simulated in pre-emergency polls or surveys.
These factors and how they affect behavior are well known from actual studies of actual behavior in actual emergencies.
These, not behavioral intention polls, should guide and determine emergency planning for actual emergencies at Seabrook.
I. Analysis of External Validity The sampling methodology employed in the Telephone Survey conducted by SDA described in Attachment 5 to the Testimony of Donald J. Zeigler, James H. Johnson, Jr. , and Stephen Cole on behalf of the Attorney General for the Commonwealth of Massachusetts, "Behavior During a Radiological Incident: Reactions of EPZ Residents to a Possible Accident at the Seabrook Nuclear Power Station",
cannot, in our opinion, ensure accurate descriptions and 3
b predictions for the population that the Survey purports to 4 describe. Claims that:
The results of the survey were generalizable to all households with telephones within the EPZ (Attachment 5,
- p. 3),
With the exception of the few households who do not have residential telephones, the sample is an accurate way to generalize to all households living in the EPZ" (Testimony of Zeigler, Johnson and Cole, p. 16), and we can be confident that the results we obtained are roughly representative of what the EPZ population would do in an accident at the Seabrook Station (Testimony of Zeigler, Johnson and Cole,
- p. 18) are unfounded. The problems with the design and execution of the sampling procedures are so serious that the Survey data and interpretations of that data should not be trusted.
The Survey is described as a random sample of households with residential telephones, not a random sample of individuals (Attachment 5, p. 43). The sample was drawn with a "complex procedure" (Attachment 5, p. 40). A summary of the design of the sampling procedure is provided below.
Although the details of the design are technical, examination of those details will show four things.
First, the sample design systematically excluded some unknown proportion of EPZ households. Not only were households without a residential telephone excluded (Attachment 5, p. 40), but an unknown proportion of households with residential telephones who lived near the 4
e
boundary of the EPZ were systematically excluded from the Survey.
Second, the Survey did not seek a random sample of heads of households. The Survey is not representative even of the households that participated in the Survey because the responding heads of the participating households may differ from the other heads of those households.
Third, many households -- perhaps more than half of the households in the EPZ -- had no chanco of participating in the Survey. It is inappropriate to claim that the survey represents households that had no chance of participating in the Survey.
Fourth, the sampling errors appear to have been calculated as if the sampling design were a far less complicated one. The consequence of ignoring the complexity of the design is to understate the sampling errors, i.e., the sampling errors described in Attachment 5, pp. 52-53 and the Testimony of Zeigler, Johnson and Cole, pp. 16-17 are too small numerically and give a misleading impression of more reliability than was actually attained. (Sampling errors do not reflect validity.)
The first step in drawing the sample was an effort to list all telephone exchanges containing telephone numbers of l
residents of the EPZ. However, exchanges for which less than 15% of the numbers were determined to be within the EPZ were excluded from the list. Since those excluded exchanges were 5
l
"areas which straddle the boundaries of the EPZ" (Attachment 5, p. 41), the sampling procedure systematically excluded some proportion of the EPZ residents who lived near the boundary of the EPZ. The magnitude of the exclusion is not discussed in Attachment 5 or in the Testimony but simply opined on cross-examination to be a very small number.
(December 16, 1987, II. 7954)
Telephone numbers were selected from the listed exchanges "in such a way so that the proportion of numbers in the sample in a particular exchange would be the same as the proportion of numbers in the population in that exchange.
The sample utilized is a random digit dial sample in which the last two digits in the telephone number are selected at random by a computer from among all those working blocks in a particular exchange" (Attachment 5, p. 42).
Once a telephone number was selected and a "contact" was made, the interviewers were instructed to ask to speak to the male or female head of household (Attachment 5, p. 43).
Since sex quotas were employed (Attachment 5, p. 43), it is presumed that the interviewers were not seeking household heads of one sex or the other, but rather they would speak to a head of either sex up until that point in the Survey when they had met their quota of males (or females), after which point they would only speak to females (or males). Table A3, "Failure to Complete", Attachment 5, page 57, identifies 170 New Hampshire and 79 Massachusetts calls which were not 6
completed because callers "could not obtain correct sex". No random sampling was performed within the households (December 16, 1987, II, 7960), therefore the sample is not a random sample of heads of households.
The non-random selection of the respondent within the selected households is critical and extremely unfortunate because it means that of those households containing more than one head, the sample over-represents those heads who were home and willing to answer the phone. Beliefs, knowledge, and attitudes can vary markedly between different heads of the same household, and thus the typical attitudes of the responding heads would not be the same as typical attitudes within their households. Indeed, recognition of this variation between two heads of the same household appears to have led SDA to use sex quotas:
A sex quota was used to insure that the final sample would represent the population in terms of sex. It was important to make sure that women were not over represented as it is well-known from prior surveys that the attitudes of men and women toward issues like nuclear power generally differ. (Attachment 5,
- p. 43)
If the sample were truly a random sample of households and of their heads then no quota sampling would have been necessary. Not only do men and women have different attitudes, but so may heads of households who are home and willing to be interviewed and heads of households who are not home or not willing to be interviewed. The use of quotas by 7
4 sex certainly does not avoid this problem. Doctor Cole has remarked about quota samples:
In my opinion it is dangerous to generalize from this type of sa.sple (a quota sample) to a population.
Another flaw which might have created bias is the failure . . . to use a systematic procedure for selecting the member of the household to be interviewed.
(Testimony of Zeigler, Johnson and Cole, pp. 30-31).
Thus, the Survey is not representative even of the households that participated in the Survey because the responding heads of the participating households may differ from the other, non-responding heads of those same households.
A further problem with the use of quotas is that the quotas used by SDA were set according to estimates of the proportions of men and women in the population, and not according to the proportions of male or female heads of households in the various towns. To the extent that those proportions differ from each other, the use of quotas ensures a maldistribution of respondents by sex.
It is obvious that the sample could not represent those households in the EPZ lacking residential telephones. It is claimed that "data . . . indicate that more than 95% of the residents of the EPZ have telephones in their homes" (Testimony of Zeigler, Johnson and Cole, p. 14). However, no estimate of the proportion of households (as contrasted with persons) with telephones is offered in the Testimony, although Doctor Cole interpreted the "data" in cross-examination to the effect that "Somewhat less than 5 percent 8
of households do not have telephones." (December 16, 1987, II. 7948)
In addition to the problems of exclusion of households in the EPZ and non-random sampling previously noted, the Survey suffered yet another major problem -- nonresponse. As Doctor Cole has correctly pointed out: "There is no way to be certain that the people who refused to participate in the survey would have answered the questions in the same way as those who did participate", and later, "The lower the response rate the less confidence we could have in the Survey results." (Testimony of Zeigler, Johnson and Cole, p. 18)
In addition to people who directly refuse to participate in the Survey, we must also consider those who were denied the chance to participate because they were not at home, their line was busy, the interviewers had difficulty communicating with them (for example, persons who did not speak English well), or their telephone was out of order.
Therefore, the survey could only represent those households that had a chance of participation in an interview. Further, it is likely that less than half of the households in the EPZ had a chance of participating in the Telephone Survey. A total of 6,611 telephone numbers were selected for the Survey. These numbers are classified by SDA as follows (Attachment 5, pp. 47ff) :
1,055 = no answers after 3 callbacks 457 = continuously busy or head of household unreachable 9
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2,270 = not working residential numbers (and some businesses) 93 = communication too difficult ("language or psychological problem")
249 = interviews were not conducted because could not obtain correct sex (queta filled for available sex) 793 = refusals 100 = households outside EPZ 190 = interviews were not conducted because quota for town was filled 1,404 = interviews were conducted.
In order to calculate precisely the fraction of the households in the EPZ that had a chance of participating in the Telephone Survey, we need more information. How many of the 1,055 "no answers" were residential 9elephones? (Some undoubtedly were business phones.) How mcny of the "continuously busy" numbers were residential? How many of the 2,270 "not working" numbers were residential numbers?
Since this information was not available, we will consider a range of alternative assumptions. In the extreme case that all of these numbers were residential as the cross-examination testimony seems to imply (December 11, 1988, II.
7954-56), the fraction of households with telephones covered by the survey would be less than 30%. Even if none of the 2,270 "not working" numbers were residential, the fraction of households with telephones covered by the Survey would be less than 40%. Those assumptions are extreme, but they yield lower bounds on the coverage of the EPZ households with 10
residential telephones. If we assumed that half of the 1,055 "no answers" were really residential numbers, 75% of the 457 "continuously busy or head of household unreachable" were residential, and as stated by Doctor Cole in cross-examination (December 16, 1987, II. 7954-56) none of the 2,270 "not working" numbers were residential, the fraction of households with residential telephones covered by the Survey would still be less than 50%.
In the Testimony of Zeigler, Johnson and Cole (p. 18),
a "completion rate" of 64% is calculated as the ratio of the number of completed interviews to the sum of the completed interviews and the refusals. That rate ignores the 93 interviews that could not be completed because the respondent did not speak English or for some other communication or "psychological" problem. The rate also ignores residential phones that were not working or not answered or busy during the initial call and the three call-backs. Considering such cases suggests that the proportion of the households with residential telephones covered by the Survey is surely less than 60% and could well be less than 50%. Consideration of the additional households with no possibility of selection into the sample further diminishes the chances that as many as half of the households in the EPZ are represented by the survey.
Statistical theory provides no basis for generalizing results from the Survey to persons or households with no 11 -
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chance of participation into the Telephone Survey. One can try to make assumptions that those who were excluded from or refused to participate in the Survey are similar to those who did participate, but those a mrptions cannot be trusted unless they can be tested empirically. It is claimed by Doctor Cole that despite massive amounts of nonresponse,
" given past surveys we have conducted utilizing the same methods, we can be confident that the renults we obtained are roughly repres ntative of what tle EPZ population would do in an accident at the Seabrook Station" (Testimony of Zeigler, Johnson and Cole, p. 18) but no empirical evidence is provided to support that claim.
Indeed, Doctor Cole has admitted that ". . . important in assessing the adequacy of the survey results are the number of no answers, busy signals, or no eligible respondent at home. There can be no way of knowing whether these people would have answered differently than those interviewed."
(Testimony of Zeigler, Johnson and Cole, pp. 18-19). One possible way of trying to see whether those eligible to be interviewed would have answered in the same ways as those who actually were interviewed is to compare the Survey results with known statistics, such as census statistics. Not all of l
l the Survey statistics can be compared because not all o." the questions on the Survey are asked in the census or in another l
I high-quality data source. However, a demonstrated agreement l
! between some proportion of the questions on the Survey and 1 12 l
census (or other external criteria) would certainly lend more credibility to the Survey's results, even if it would not be proof that the Survey was representative with respect to the questions that could not be matched against census (or other) benchmarks.
The low coverage of the households (less than 60% or maybe less than 50% of those with phones and even less than that of all households) in the EPZ is so inadequate that the Survey cannot support statistical generalizations to all the households in the EPZ. The quality of the Survey is too low for the results to be trusted for use in important decision-making. The accuracy of the statistics based on the Survey is simply too suspect.
Sampling theory provides a means of estinating the variability in statistics that would occur from one sample to another as a result of the randomization that was used in the sampling. The term "sampling error" is used in Attachment 5, pp. 52-53, and the Testimony of Zeigler, Johnson and Cole, pp. 16-17, to describe the typical size of the variability.
Sampling error does not reflect the magnitude of other sources of error in the Survey, such as nonresponse, lack of randomized selection of head of household, response biases due to question wording and ordering, and so forth. The interpretation of sampling error in Attachment 5 , p. 53, suggests that it is computed as approximately twice the standard error. (The square of the standard error of a 13
l statistic equals the average squared difference between a statistic and its average value, where the average refers to the average over hypothetical independent repetitions of the sampling procedure under identical conditions. The standard error may also be interpreted as the typical size of the difference between a statistic and its average value.) To calculate standard errors applicable to complex sampling procedures is rather complicated. For certain kinds of ,
simple sampling procedures, however, the standard error of a percentage, say P, may be easily computed as the square root of the ratio of P times 100%-P to the number of interviews.
The standard error is largest when the percentage P is equal to 50%, in which case the standard error is equal to 50%
divided by the square root of the number of interviews. With 915 interviews (the number of completed New Hampshire interviews) the standard error would then be 1.65% and the l
sampling error would be 3.30%; with 489 interviews (the number of Massachusetts completed interviews) the sampling error would be 4.45%. In essence, this simple formula was used to calculate the sampling errors used in the Zeigler, Johnson and Cole Testimony. (December 16, 1987, Ir. 7990-92, 8021)
In order to estimate sampling errors correctly (i.e.,
accurately), one must take into consideraticn the exact manner in which the sample was selected. The sample is described as "a stratified random sample of households with l
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residential telephones" (Attachment 5, p. 40). Doctor Cole at (December 16, 1987 Tr. 7949) agreed that the sample was stratified in essence into 23 strata. In addition, the description of the sampling procedure suggests that multistage sampling was used. It is important to know that multistage sampling was used because, other things being equal, sampling errors for multistage samples tend to be larger than sampling errors for one stage samples. Lacking a more detailed account of how the sample was selected, we cannot say for certain that the sample was indeed a multistage sample, but we believe that it was. However, the Zeigler, Johnson and Cole Testimony does not address these matters and the sampling errors reported in the Zeigler, Johnson and Cole Testimony were calculated as if no multistage or stratified sampling were used.
Thus, the simple formula for calculating standard errors appears to be inappropriate for the Telephone Survey. The actual sampling errors quite possibly are considerably larger. Furthermore, certain statistics are calculated on small subgroups of the interviews, and the standard errors l
for those statistics are enormously larger.
1 l In particular, the sampling errors for the statistics on emergency workers in the New Hampshire EPZ are often far l greater than 3%, even with the simplified formula described earlier in this rebuttal. For example Table 2 in the Zeigler, Johnson and Cole Testimony , p. 51, estimates that 15 l
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19.4% of the emergency work roles are assigned to police, but the sampling error under the simplified formula is 14%, so the sampling variability is almost as large as the calculated statistic! If the complexity of the design were taken into account, the sampling error would probably be larger than 14%.
For the same reason, the statistics on the beha /ioral intentions of emergency workers are also extremely unreliable. Table 1 of the Zeigler, Johnson and Cole Testimony , p. 49, presents statistics for emergency personnel showing that 52% would perform emergency work, 39%
would check on their families, 3% would leave the area, 3%
would do something else, and 3% did not know what they would do in an evacuation advisory. However, those statistics are based on a sample of only 31 emergency workers and the sampling errors are large. Even using the simplified formula (which underestimates the sampling errors), the sampling error for the percentage saying they would check on their families is more than 17% and the sampling error for the i
percentage who would perform emergency work is more than 19%.
II. Analysis of Internal Validity 1
l A large amount of systematic error or bias exists in the 1
I questionnaire used in this Telephone Survey. In other words, the answers which survey respondents gave to the questions they were asked without doubt have been systematically colored or influenced by factors (for example, the wording l
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and ordering of questions) beyond their actual judgments.
Sufficient sources of systematic measurement error (bias) exist to such a degree that we must conclude that the results of this Survey lack a basis for internal validity; we do not trust, therefore, that survey findings represent a reasonably accurate representation of the actual views, judgments or opinions of persons interviewed. The many reasons why we have reached this conclusion follow.
Most of the bias (or sources of systematic measurement error) in the questionnaire are located in the first parts of the instrument. This is unfortunate because bias early in an instrument not only affects answers to the biased questions but can carry forward to subsequent questions which, taken alone, may not themselves be biasing.
The first topical question in the present Survey is numbered question 14. This question was worded as follows.
In general, how dangerous do you think it would be to live near a nuclear power plant?
The structured response categories read to the respondent were limited to the three which follow.
1 = very dangerous i 2 = dangerous l 3 = not dangerous at all The question, "In general, how dangerous do you think . . .
implies an answer to the respondent before the question is even finished being read by use of the word "dangerous". It thereforeleadstherespondenttoanopinionof"[angerous".
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In addition, the range of possible answers for this question also contains a source of bias particularly when one considers how the range of answers read to the respondent would interact with the biasing question wording. This entire question and its answers take only a few seconds to read to the respondent, yet before the respondent has a chance to offer his/her opinion they have heard the word "dangerous" four times. This is a source of systematic measurement error or bias since it would lead respondents to an opinion of "dangerous". This question and the answers read to respondents at the conclusion of the reading of the question more resemble a lecture on how dangerous nuclear power plants are than social science measurement relatively free of systematic error, or at least social science measurement which has made a reasonable attempt to minimize systematic error or bias.
The second question on the questionnaire and its answers as read to respondents forces the respondent to select a general value position on nuclear power:
- 15. Would you describe yourself as
- 1. = a supporter of nuclear power plants as a means of providing electricity.
- 2. = an opponent of nuclear power plants, or
- 3. = you haven't made up your mind yet on this issue?
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l The answers given to this question would contain bias since respondents heretofore have been instructed that nuclear power plants are dangerous due to bias introduced in the first (number 14) question. Respondents are here forced to become a "supporter" of nuclear power, and "opponent," or else claim that their minds are not yet made up. This dichotomization of opinion on an issue on which opinions range along a continuum is biasing, because whichever i
position is chosen, respondents will remember their selection and labor to be as consistent as possible with their choice in answering all subsequent questions.
The next question (number 16) was "Do you think that the Seabrook Nuclear Power Plant should be allowed to operate to generate electricity?" This question shows no major internal sources of systematic error. However, its position in the questionnaire is after questions 14 and 15 which do bias results. Interactive bias would operate from questions 14 and 15 on answers to question 16. For example, question 14 "teaches" people that nuclear power is dangerous and would serve to bias answers to question 16 toward "no" (the answer consistent with the bias introduced in question 14). A similar interactive bias on answers to question 16 would have l been operating from question 15.
Question 17 was "Given where you live, do you think you would be affected by a release of radiation if a serious problem developed at the Seabrook nuclear power station after l 19 1
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it started operating?". This question likely elicited measurement influenced by systematic error.because of its
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position in the questionnaire. For example,' question 14 biased persons'to say nuclear power was "dangerous"; once that position was adopted, it would bias persons away1from the answer "no" to question 17 (an admission that nuclear power is not dangerous, for all practical purposes)..
However, the more important concern to be had with the first four questions (numbers 14, 15, 16 and 17) in the questionnaire is not that the answers given by respondents.to these questions were themselves subject to systematic error; the prime problem that questions 14, 15, 16 and 17 present to the internal validity of this questionnaire is the effect they have by introducing systematic error or bias into subsequent question answers in the remainder of the questionnaire. Taken together, the first four questions in the questionnaire serve to create unique subsets of study respondents, for example, respondents who voiced the following perceptions to their interviewer: nuclear power is dangerous (question 14); I am an opponent of nuclear power because it is dangerous (question 15); I am an opponent of nuclear power because it is dangerous and, therefore I do not l think Seabrook should be allowed to operate (question 16) ;
- and finally, I am an opponent of nuclear power because it is L dangerous, and therefore I do not think Seabrook should be j allowed to operate, therefore, of course I think I would be l
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i e- nene, --.--~,,,-a-,,.. ,,-n,.-- - - , , , - - - - ,1 - - - - ~ ~ , - - -
affected'if Seabrook had a serious problem after it began i
operating (question 17). After just four questions, this I
questionnaire has, created study respondents so boxed into a corner as to significantly guarantee that answers to subsequent questions would be influenced (colored, biased, and so on) by the box in which respondents must have found themselves. Interviewees desperately try to be consistent during interviews. How now, for example, can a person already committed to the above illustrative position select "go about your normal business" as an answer to a question about emergency response after reading a scenario in which a release of radiation were asked to be assumed (see, for example, question and answers number 274)? The answer is obviously that the respondent would have been biased toward another answer more consistent with the above illustrative position, for avespie, "leave your home and go somewhere else". Conversely, how could a respondent in the opposite polar box (nuclear power is not dangerous at all, I am a supporter of nuclear power, I think Seabrook should be allowed to operate, and given where I live I do not think I would be affected by a release of radiation if Seabrook had a serious problem) select "leave your home and go somewhere else" as an answer to, for example, question 274?
Questions 14, 15, 16 and 17, however, would have biased the sample of respondents in the direction of being in the former "box" and away from the latter; among other reasons 21
because of the directional bias contained in the first question. Once respondents had completed hearing and providing answers to the first four questions, enough systematic error would have been introduced into this study to lead to the clear cor.clusion that subsequent question answers (particularly those'on behavioral intentions) would lack internal validity and inflate intended evacuation estimates. This would be the case because of interactive bias introduced by the first four questions and answers, and the "box" into which they would have placed respondents.
Answers by respondents to protective action behavioral intention questions (numbers 20, 31, 274 and 312, for example) would have been subject to this interactive bias.
The answers read to respondents to these same protective action behavioral intention questions (numbers 20, 31, 274 and 312, for example) were as follows.
- 1. = go about your normal business, or
- 2. = stay inside your home (or where you are) or
- 3. = leave your home (the place where you are) and go somewhere else These response categories are neither mutually exclusive nor exhaustive -- it is possible to go about normal business by staying home or by leaving and going comewhere else.
A final problem exists in the questionnaire regarding internal validity in reference to protective action behavioral intentions questions numbered 20, 31, 274 and 312.
People were asked to speculate about their intended behavior 22
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in response to simulated emergency information. The l
information simulated for study respondents, however, does '
not Lirror the emergency information which the public would actually encounter in the event of an emergency at Seabrook.
As a consequence, therefore, as noted earlier, answers about behavioral intentions to the emergency information presented to study respondents in this Survey can shed n2 light on how people might behave in response to the actual form and type of emergency information that would characterize an actual emergency at Seabrook.
Other sources of systematic error or bias exist in the questionnaire. Question 42, for example, reads as follows.
When you heard this message on the radio how likely do you think it would be that you and your family would be exposed to a dangerous level of radiation?
The answers read to the respondents were: (1) very likely, (2) somewhat likely, and (3) very unlikely. Interactive bias from questions 14, 15, 16 and 17 would also direct answers to this perceived risk question. Interactive bias from the first four questions would also direct answers to question 311 which follows:
Suppose there was an accident at the Seabrook Station and the State Civil
. Defense officials said that everybody l living within ten miles of the plant I
should evacuate but that everybody who lived more than 10 miles away from the plant was safe. Would you believe the
- State Civil Defense officials that people l living more than 10 miles away were safe?
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Answers to this question would be colored by stated perceptions given as answers to questions 14 and 17, for example.
Questions 344, 345 and 346 in the questionnaire were directed only to respondents who admitted in the interview (see question 342) to having an assigned role in the Seabrook evacuation plan; and these questions were only asked on the New Hampshire portion of the sample. Question 344 reads as follows:
Suppose that the Seabrook Nuclear Power Station is licensed and begins to operate. If there were a problem at the plant and you heard that a ten-mile zone had to evacuate, what would you do first?
The answers read to the respondents for this question follow:
1= report to my assigned place to help the evacuation 2= make sure my family was safely out of the evacuation zone 3= leave the evacuation zone to make sure I was in a safe place 4= something else Question 345 is the next question asked of emergency workers and it reads as follows:
How would you make sure that your family I was safely out of the evacuation zone?
The answers read to the respondents so they could select one follows:
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. l 1= go home and drive your family to a safe place out of the evacuation zone ;
2= call home and tell your family to leave without you 3= some other way Question 346 is the next question asked of emergency workers and it reads as follows.
If there was a nuclear accident at Seabrook Station requiring the evacuation of people within a ten mile zone, how dangerous do you think it would be for you to spend several hours in your emergency assignment?
The answers read to the respondents follow.
1= so dangerous that it would be life threatening 2= very dangerous 3= somewhat dangerous 4= not dangerous The answers obtained to these questions would have been subject to bias for several reasons. In reference to question 344, for example, no choice is provided the respondent regarding what extensive emergency behavioral research illustrates as what most trained emergency workers actually do in the emergency mobilization period (for example, answers 1 and 2 are typically done at the same time). The do "something else" option in the ,nswers to questions 344 and 345 does not correct for this deficiency as interviewees typically select answers from the list they are provided. Answer to question 344 would be systematically 25
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directed toward unrealistic choices about behavioral intentions; answers to questions 344, 345 and 346 would also have been biased interactively because of the "dangerous" bias in question 14, for example. Additionally, questions 344 and 345 and their answers are constructed in such a way that respondents are forced to choose between work, family and personal safety. It overlooks that each can and typically is served at the same time in actual emergencies.
Questions 344 and 345 and their answers are more generic value measures of which object (job versus family) is, in general, of higher priority to the respondent. These answers lack internal validity as accurate behavioral intentions which, even if accurately measured, have little if anything to do with actual behavior in an actual emergency.
Question 348 reads as follows:
Currently plans are to have Civil Defense officials supervise an evacuation if this should become necessary. If as a result of an accident at Seabrook, you decide to leave the area and a Traffic Control official who was assigned to prevent traffic congestion told you not to drive on a road that you wanted to use, do you think you would:
1 = go where you wanted to go, or 2 = go where you were told to go This question is a text book example of how not to ask questions in questionnaires. It illustrates measurement without reliability (different answers would be obtained if measurement were reattempted). Answers would depend on what 26
people had in their minds when they heard the words "told you" (over radio?, personally, as they directed street traffic?), "official" (someone in a uniform?, someone else?),
"prevent traffic congestion" (for purposes of safety?, for convenience?), and so on. The question also presumes a conflict in the minds of evacuees (you want to go one way, and "they" want you to go another) which is a scenario which ignores actual human perception in actual emergencies as they are being experienced -- a "collective will" with "collective safety" as the prime motive for individual behavior.
Finally, this question would elicit biased answers from respondents by its questionnaire position; it comes directly after the "Chernobyl" question and some respondents would answer this question with that type emergency mind.
Finally, this Survey was performed over the telephone during which family "spokespersons" were interviewed. Family "srokespersons" were individuals who were not able to take into account in the interview the input from other family members, for example, the discussions between family members leading up to protective action decisions. The correct unit of analysis for the interview should have been the entire family and not just one self-selected "spokesperson", since in a real emergency protective action decisions would be made in the process of family interaction. Dr. Cole's colleagues Drs. Johnson and Zeigler well understand this family evacuation decision-making process; they have, in fact, even 27
diagrammed it (see Stanley D. Brunn, James H. Johnson, Jr. ,
and Donald J. Zeigler. 1979. Final Report on a Social Survey of Three Mile Island Area Residents, East Lansing: Michigan State University, Dept. of Geography, page 46.)
Interviewing individual "spokespersons" rather than the family unit, therefore, significantly deflates the internal validity of the study design. The Survey gathered behavioral intentions data from individuals, yet it is largely groups (for example, families) who respond to actual emergencies.
Family behavioral intentions and "spokesperson" behavioral intentions are not the same.
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