ML19308C336
| ML19308C336 | |
| Person / Time | |
|---|---|
| Site: | Crane  |
| Issue date: | 07/28/1979 |
| From: | Harvey C NRC - NRC THREE MILE ISLAND TASK FORCE |
| To: | |
| References | |
| TASK-TF, TASK-TMR NUDOCS 8001220771 | |
| Download: ML19308C336 (90) | |
Text
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ERRATA IN THE JULY 28, 1979 nEPOSITION OF HAROLD COLLINS ASSISTANT DIRECTOR FOR EMERGENCY PREPAREDNESS OFFICE OF STATE PROGRAMS U.S. NUCLEAR REGULATORY COMMISSION BEFORE CHARLES A. HARVEY, ESQUIRE ASSOCIATE CHIEF COUNSEL 2100 M STREET, N.W.
WASHINGTON, D.C.
20037 ON BEHALF 0F THE PRESIDENT'S COMMISSION l
ON THE ACCIDENT AT THREE MILE ISLAND 80012207 7 /
. Page Line ERFATA 4
19 under vice " understood" 4
19 Delete "I"
4 22 at vice "of" 5
1 Delete "for energy" 5
18 emergency vice " energy" 8
12 Operational Safety Guides vice
" Operation and Safety Guides" 8
14 emergency vice " energy" 10 5
emergency vice " March" 10 5
or vice "in" 10 5
operators vice " operator" 12 1
emergency vice " energy" 13 7
between seven, now eight Federal agencies (since the old AEC was split into NRC and ERDA (now DOE))vice "between eight" 13 14 the AEC regulatory arm vice "AEC regulation" i
13 7
seven vice "eight" 13 21 seven vice "eight" 14 2
Federal Register Notice vice " Federal Register" 14 22 OEP vice " EPA" 17 18 and vice "between" 19 3
NUREG vice "Nu Reg" 19 7
.... Government Radiological Emergency Response Plans vice " Government Response Plans".
19 13 NUREG vice "Nu Reg" 19 16 NUREG vice "Nu Reg" 19 23 The vice "that" 1
i
. Page Line ERRATA 20 15 NUREG vice "Nu Reg" 21 8
that is vice "is" 29 2
in vice "of" 33 8
has sent people to the planning course vice "has only sent one person to that; the planning course,"
34 12 Siting vice " citing" 34 13 part vice " parts"
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36 8
Siting vice " citing" 36 8
plants vice " plans" 36 22 have vice "1.ck"/ sprays vice " space" 37 11 Eliminate comma after " design basis" 37 11 accidents, vice " accident" 37 12 accidents vice " accident" 37 12 insert comma after " consequences" 37 12 delete "in my case with respect and I say consequences,"
i 37 15 insert after doses "in excess of Enviranmental Protection Agency Protective Action Guides (PAGs),"
37 15 insert after "than" "the" 37 21 insert the word "and" between " preparedness" and "in".
38 16 insert the word "what" between "that"and "we" 38 16 insert the word"about" between " talking" and "here" 38 16 for vice "of" 38 18 js,vice"to" 38 18 EPZs vice "EPS's"
. Page Line ERRATA 39 2
establishment vice " establishments" 39 2
zones vice "shown" 40 13 within vice "with" 41 11 the vice "if" 41 12 insert before " lists" the word "which" 42 11 1979 vice "1978" 47 3
of vice "on" 49 9
our vice "your" 49 19 or_ vice "of" 50 7
insert...." ranging out" g "the..."
51 18 insert the word "not" before the word"certainly" jn_ vice "of" 51 19 n
51 25 was vice "were all" 53 15 that vice "what" 34 8
coolant vice " cooling" 54 10 situation vice " mixture" 54 24 per hour vice "over the year" 55 18 insert the words "within" between "was" and "a" 55 18 delete the words "given within" 57 25 that vice "there" 59 13 roentgens vice "milliroentgens" 60 18 coolant vice " cool" 60 20 Coolant vice " cooling" 62 11 didn't vice " don't" 64 8
hands vice " hand"
. Page Line ERRATA 64 12 hands vice " hand" 68 19 Hendrie vice_ "Hendry" 68 22 Hendrie vice_ "Hendry" 70 23 Oran vice "Rean" 71 5
the vice "a" 71 6
h vice "are" 71 7
insert the word "to" between "out" and "10" 71 22 insert the word "it" before "in" 74 10 Fouchard's vice "Fouchard" 74 18 Hendrie vice "Hendry" 75 15 those vice "thos" of vice "or" f
75 18 78 25 perceived vice " perceive" 80 18 insert the word "to" between " opposed" and "the" 81 3
a house vice "the house" 82 22 and vice "the" 85 13 choosed vice " chooses" Notes:
1.
I have not attempted to correct punctuation errors, which seem unimportant.
2.
I have not attempted to correct phrasing and punctuation errors in the questions of the interrogator.
Date: August 1, 1979 4A M eE 4 Harold E. Collins Assistant Director for Emergency Preparedness Office of State Programs 1
U.S. Nuclear Regulatory Commission i
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5-Errata witnessed by:
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//h /d Date: August 1,1979 Shirley p Welch Administrative Assistant for Einergency Preparedness
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Office of State Programs U.S. Nuclear Regulatory Connission a.
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U'iITED STATES OF Av. ERICA 1
2 PRESIDENT'S CO.v31ISSION ON THE ACCIDENT AT THREE MILE ISLA';D 3
4 5
6 7
DEPOSITION OF:
HAROLD COLLINS 8
9 10 Room 714 11 2100 M Street, N.W.
Washington, D.C.
12 July 28, 1979
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13 9:35,o' clock a.m.
14 15 16 1;
APPEARANCES:
is On Behalf of the Commiss.'.g :
19 CHARLES A. HARVEY, ESQUIRE Associate Chief Counsel 20 2100 M Street, N.W.
Washington, D.C.
20037 21 22 23 24 25 i
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_I _N _D _E X 2
WISESSES :
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Harold Collins 3
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PROCEEDINGS Ig 2
Whereupon,
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3 EAROLD COLLINS 4
having been first duly sworn, was called as a witness herein 5
and was examined and testified as follows:
6 BY MR. HARVEY:
Q Mr. Collins, this is a deposition being taken 8
preliminary to your appearance as a witness before the 9
Commission and I will be asking you a series of questions to to which you will be responding.
If you don't understand a question or if you would like it I phrased or repeated, just 11 ask me to do it and I will do that.
Do you understand?
12 b
13 A
Yes.
Q Perhaps you could give us a short resume of ycur 14 background, training and experience, how you happened to come 15 to the position you hold.
16 A
Well, I am a retired Naval officer with 25 years' t-service in the Navy, 7 of which were in the Nuclear Navy.
I 33 am a graduate of the Naval Academy, Naval Post-Graduate School, 19 and Navy's Nuclear Power Training School.
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about as compressed as I can make it.
31 I left the Navy in 1969.
I joined the Atomic 22 Energy Commission's regulatory arm and when the AEC was 23 abolished in early 1975, the AIC regulatory arm became the 3
Nuclear Regulatory Commission.
I first started out working 25 Acme Reporting Company
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for the Atomic Energy Commission in a Branch called the lg 2
Operational Safety Branch, which was in the Division of Reac c:
3 Licensing and the primary responsibilities I had in that 4
Branch were matters concerning emergency planning for licensed 5
nuclear facilities, operator training, industrial security, 6
pre-operational start-up and testing, and some other matters which I don't recall at this time.
8 Q
That was in 1969?
9 A
1969, right.
I was in that Branch through about to 19, I guess it was about 1973.
At that time I was transferred 11 to the then Office of Government Liaison-Regulation.
It 12 was a small office, about seven people and my function there I
13 was to work with the states with respect to radiological 14 emergency response planning.-
15 I was a party of one at that time in about a seven-16 person office.
The reason this assignment was made was because-1; early in the 1970's General Lincoln of the old office of 1s Emergency Preparedness which was an executive office of some 19 sort or another understood the Presideau -- I had a meeting k
Y 20 with the Chairman of the A,tomic Energy Commission, Glen 21 Seaborg -- and the early discussions centered around public n
concern for accidents of nuclear power facilities.
V 23 Those early meetings between General Lincoln and 24 Dr. Seaborg culminated in a Federal Register Notice which 1
25 was published, I believe January,:1973, which assigned to the Acme Reporting Company men........
tr-5 AEC lead agency responsibilities for energy among seven other A-1 2
Federal agencies to provide guidance and assistance to state 3
and local governments in developing emergency plans supportive 4
of nuclear facilities, specifically nuclear power plants.
5 Q
What positions did you hold after that?
6 A
When I first started out in Atomic Energy, I was a reactor safety engineer and I progressed up the grades to s
various levels in that until I became a senior reactor safety 9
engineer.
10 Q
How did you come to hold the present position you 11 hold now?
12 A
The office of Government Liaison-Regulation in the
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13 Atomic Energy Commission of course was abolished when the 14 Commission was abolished,.the AEC was abolishbd, and it 15 became the Office of International and State Programs in the 16 Nuclear Regulatory Commission.
17 When that happened, I was still a reactor safety is engineer charged with state and local government energy b-ig planning and preparedness.
That was in early, about when the m
NRC was formed, early 1975 or thereabouts.
It wasn't until 21 late 1976 after our current director, Mr. Robert G.
Ryan, came 22 aboard the summer of '76 that my title was changed from 23 senior reactor safety engineer to assistant director for i
24 emerp acy preparedness.
i 25 Q
So your official title at present is assistant 1
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director for emergency preparedness in the Office of State
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Programs.of the NRC?
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3 A
That is correct and I want to point out that the 4
Office of International and State Programs was divided into 5
the Office of International Programs and then another office, 6
the Office of State Programs, about the summer of '76.
7 Q
So then would it be fair to say that in your S
experience with the AEC and then with the NRC, your activities 9
and duties have been principally directed towards problems 10 of emergency preparedness and reactor safety?
11 A
That has been since I joined the AEC in 1969 and 12 this is now 1979.
I would say that over that decade about I
13 80 to 90 percent of my experience has been in this field.
14 0
I would like to go back to 1969, say, through 1970 15 and just move forward through the decade of the '70's and 16 try to get an understanding of the history of The Emergency 17 Preparedness Branch within the AEC and in the Nuclear Regulatory 18 Commission itself before 1970, say before recember of 1970, 19 what was the status of the Emergency Preparedness Branch in M
the AEC7 21 A
When I joined the AEC, I believe it was August 4 22 or thereabouts, 1969, the activities in the Emergency 23 Planning and Preparedness field were in two parts of the 24 Atomic Energy Commission.
The Atomic Energy Commission at i
25 that time consisted of a very large segment of, I. remember Acme Reporting Company
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something in the neighborhood of about 8,000 people and that lg 2
was called the AEC General Manager's Office.
That office
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3 primarily dealt with research and development and.the Nuclear 4
Navy, the promotion of nuclear power and things ndelear.
5 Within the AEC General Manager's side, there was 6
an Emergency Preparedness Branch but that Branch only dealt 7
with emergency preparedness activities for'the AEC's own 8
facilities.
.. ne, on the AEC regulatory side which was a much 9
smaller operation, I think in 1969 it was something in the 10 neighborhood of probably about 500 to 600 people when I joined 11 it.
There was no Emergency Planning or Preparedness Branch 12 in AEC Regulatory which dealt with commercial nuclear power
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13 stations but the emergency preparedness function was in a 14 Branch called the Operational Safety Branch which I was in in 15 the Division of Reactor Licensing.
16 There were at that time about seven people, as I 1;
recall, in the Branch including the Branch Chief.
I would 18 say that of the work produced by those seven people during 19 the years, say '69 through about '72, probably amounted to m
about in toto about one to two man years per year devoted to 21 emergency planning with the licensees.
22 0
So by that you mean even though there may have been 23 seven or eight people within that office or part of the AEC, 24 they didn't spend all of their time on emergency preparedness?
25 A
No they had other duties, training duties and many of Acme Reporting Company
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1 the things I went over in the first part of my testimony Ig 2
that was the function of that 3 ranch, but what I am trying go 3
get across here is that the emergency planning operation with 4
the licensed nuclear stations at that time was a very low 5
profile situation and in those days in '69 at least there 6
were no emergency planning regulations for licensees.
The regulations didn't come along until December 24, 8
I believe 1970.
The way we reviewed emergency planning such 9
minimal review that was being done in those days was that to since we don't have any regulations, we had a number of papers 11 that were generated within the Branch.
As I remember, they 12 were called Operation and Safety Guides.
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13 There were one or two operational safety guides to 14 guide the staff primarily in reviewing energy plans of b'
15 licensees which at that thm were in a very embryonic state.
16 I think that sums up the early part of the period.
i-0 All right.
About how many in 1969, about how many is commercial nuclear reactors were there operated in the United is States at that point?
Just a general figure.
33 A
I really don't know.
I can't recall, but I would 21 estimate based on what I can remember, it probably was some-e thing in tne neighborhood of 20 or so, perhaps 20 units.
23 Q
Now, in December, 197 0, the Atomic Energy Commission 23 issued requirements from Emergency Planning by licensees for the first time.
Is that correct?
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A It was about December 24, 1970, that is correct.
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0 Could you describe how that came to occur?
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Well,asImentionedbefore,wewereoperatingwit5 3
A various nonstatutory documents which dealt with a number of 4
5 matters in reviewing licensed applications, namely these 6
documents called Operational Safety Guides and various other 7
informal documents that had been developed in the various branches to guide the AEC Regulatory employees in reviewing 8
safety analysis reports submitted by the licensees and so 9
10 forth.
There was a move to convert the operational safety 11 12 guide in emergency planning, as I remember, into some type 13 of regulations con'cerning emergency planning.
I suppose that was done because there were people in the AEC at that 14 15 time that were getting a little bit concerned about accidents 16 at nuclear facilities and they were also being a little concerned about the effects of these accidents in the environs 1;
18 that maybe.they better codify into regulations, some minimal 19 emergency planning requirements on'these licensed nuclear facilities.. nSo it;wts something that just came along, I m
think, because there were people at that time that recognized 21 22 it probably was a thing that had to be done.
23 0
What?
24 A
As I mentioned also there was interest in the old office of Emergency Preparedness which I am sure helped that 25 Acme Reporting Company
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along somewhat.
2 Q
Now the requirements that were issued in December, 3
1970, or contained in the 10CFR part 50 Appendices, is that 4
correct?
5 A
That is correct.
Those are the March planning
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6 regulations now and they were in 1970.
7 Q
As of the December, 1970 emergency planning 8
regulations, what was the general thrust of those regulations?
9 What were they seeking to accomplish?
10 A
The regulations for emergency planning that were put 11 out by the Commission in 1970 sought to provide some minimal 12 standards, if you would, for nuclear facility emergency plans.
13 Those regulations are essentially divided into two basic 14 parts.
15 In the first part the regulations require that the 16 applicants in the nuclear facility operator at the construction 17 permit stage provide certain basic information concerning 13 emergency planning.
He does not have to provide the emergency 19 plan for his facility at that time, but he does have to 20 provide some information to the AEC -- the NRC as to how he is 21 going to put.his. emergency planning together and how this will 22 relate to off-site organizations and so forth.
23 The second part of the regulations pertain to the 24 operating licensing stage.
The first part was for construction 25 permit s'tage.
This second part requires that the applicant l
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for an operating license produce evidence that addresses the 2
requirements in the regulations, such as methods for norifying 3
off-site organizations in the event of a release of radioactive 4
material, a means for determining the magnitude of any radio-5 logical release, the licensee.'s arrangements with off-site 6
authorities whose assistance may be required in the event of 7
an emergency, the training of certain people in emergency 8
preparedness, a number of things like that. -
9 Since I don't have the regulations in front of me, 10 I can't go down the whole list, but those are examples of 11 things that are in there.
12 Q
So the first AEC requirement for emergency
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13 preparedness in regulation form emerged in December, 19707 14 A
That is correct.
15 Q
Between 1970 and 1972, what was happening in the 16 AEC with respect to emergency preparedness?
1 A
Between 1970 and 1972?
18 0
Yes.
19 A
Well, after the publication of the regulations in 20 December, 1970, the emergency plans of the licensees were 21 being reviewed in a more formal sense now that the AEC staff 22 had some legal basis to review these plans in a formal sense.
23 I would say that starting in 1971 there was a 24 general trend to upgrade the emergency plans of licensees.
15 I want to point out that before the publication of the.
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regulations there were energy plans in some sense or another P
2 in some of the nuclear facilities; whether they were in place 3
in all the nuclear facilities or not, I cannot say.
But I 4
want to point out those emergency plans that existed in those 5
early days were very rudimentary in nature.
6 So during the period
'70,
'72, we saw a gradual 7
increase in the quality of the emergency plans and a more 8
formal interest on the part of the AEC Regu2ata27, personnel, 9
particularly management in trying to get some kind of plans to in place.
But still in those years '71 and '72 emergency 11 planning was not a big piece of business in the AEC.
12 O
The emergency planning you have described goes 13 principally to plans developed by the licensee for on-site 14 consequenses of nuclear incidence during the period of 1970 15 and 1972, was there any growing appreciation of the need for 16 off-site planning as well?
17 A
Yes.
In the early part of my statement here I 18 mentioned a meeting or there were a couple of meetings between 19 General Lincoln of the old Office of Emergency Preparedness 3
and Dr. Glen T.
Seaborg, the Chairman of the Atomic Energy 21 Commission.
22 Those meetings occurred in the early 1970's prior to 23 1973 when the first Federal Register Notice came out.
As I 24 mentioned, the Office of Emergency Preparedness at that time 3
was receiving inquiries we had heard about from citizens from Acme Reporting Company
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time to time and public interest groups concerning "what if" ig 2
at a nuclear facility.
In other words, what if there was aq.
3 accident, what would people do off-site?
4 As a result of those meetings between Seaborg and 5
Lincoln, this Federal Register Notice came into being.
The 6
Federal Register Notice is non-statutory in nature and in essence what it is is a kind of an agreement between eight be" p'
8 Federal agencies that they will do certain things and have 9
accepted certain responsibilities to assist states and local 10 governments in radiological emergency response planning and
'11 preparedness.
12 0
What agencies are you thinking about?
13 A
In the '73 Notice the AEC was and of course this 14 was interpreted to be the AEC Regulatory, the AEC regulation
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15 was put in charge as lead agency among these other agencies.
16 The other agencies at that time were the Environmental 1;
Protection Agency, the Department of Health, Education and 19 Welfare, the Department of Transportation, the Federal 19 Disaster Assistance Administration, the Federal Preparedness m
Agency, let's see, how many -- oh, the Defense Civil Prepared-21 ness Agency.
I think that is eight.
I think I have covered p+
22 them all.
3 I want to point out scrething curious that happened 24 around this time.
I mentioned all of th3e started with the 25' old office of Emergency Preparedness.
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ar und the time this Notice was published, I.can't recall Ig k'
2 whether it was before the Federal P.egister was published in (
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'73 or afterwards, but it really doesn't make any difference.'
4 What I want to point out is the Old Office of
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5 Emergency Preparedness was abolished.
It was divided into two 6
parts, and one part became the agency that is today the 7
Federal Disaster Assistance Administration which is in the 8
Department of Housing and Urban Development.
9 The other part became what is today the Federal to Preparedness Agency in the General Services Administration.
11 Now, I have to correct that because both of those agencies 12 today no longer exist because about last week the Federal
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13 Preparedness Agency and the Federal Disaster Assistance 14 Administration and the Defense Civil Preparedness Agency were 15 all merged into the new Federal Emergency Management Agency, 16 FEMA, but anyway in those days those agencies that I mentioned 17 were essentially the agencies involved or their precursors or 18 their successors.
19 Well, the Notice was directed toward Emergency 20 Planning for fixed nuclear facilities and then in 1975,'.in i
21 December, 1975, the Notice was re-issued by the Federal 22 Preparedness Agency, which was a successor to the old EPA.
i 03 The Notice was updated to remove the name Atomic Energy 24 Commission from it and insert Nuclear Regulatory Co= mission i
25 as lead agency.
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1 The Notice was also expanded somewhat to cover not 1
2 only Emergency Planning for fixed nuclear facilities but fon(
3 transportation of radioactive' materials as well.
Still 4
assigning certain basic responsibilities to all of these 5
agencies and keeping the Nuclear Regulatory Commission in 6
charge of the cooperative program with the states.
That 7
occurred in~1 ate '75.
8 Q
So that as of 1973 with the publication of that 9
Federal Register notice there was an effort made to coordinate 10 the activities of certain Federal agencies in responding to 11 incidents at fixed nuclear facilities?
12 A
Mo, that is not exactly correct because the Notice 13 doesn't deal with the coordination of Federal agencies 14 themselves in response to accidents at nuclear facilities.
15 Both of these Notices, the 1973 Notice and the 1975~ Notice 16 are totally related to providing guidance, training, and 17 assistance to states and lochi governments in developing 18 their radiological emergency response plans and does not deal 19 with any operational matters concerning any Federal agencies.
20 That is covered under another document.
21 Q
Okay.
22 A
Under IRAP, it is the Inter-agency Radiological 23 Assistance Plan, which is managed by the United States Depart-24 ment of Energy.
25 Q
So that as of December, 1973, the efforts started Acme Reporting Company m........
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to provide Federal assistance to the states in developing
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plans to respond to nuclear emergencies.
What was happening; 3
within the AIC itself concerning its own licensees and 1
assisting the states during, let's say,the period of 1970 4
5 through 1974?
6 A
Well, first of all I would like to set something straight when we talk of assistance.
I want to make it quite a
clear this assistance was not financial assistance in any way.
9 There were no funds appropriated to assist states and local to governments in emergency planning for this specific kind of 11 planning.
12 There were some falds available for general emergency is planning that were controlled by the Federal Disaster 14 Assistance Administration.
But there wasn't anythi.ng specifica 11 15 earmarked for radiological emergency planning.
The assistance 16 was more handicidhg than anything else, meeting with state t-and local government people and trying to explain to them is guidelines for emergency planning and that kind of thing.
19 Now I must ask you to repeat that question.
You 20 wanted to know what was going on with respect to the licensee 21 emergency planning from '70 to '74?
22 O
Well, from '70 to '74 what was the AEC doing to 3
encourage states to come up with off-site emergency prepared-24 ness plans?
3 A
Well, the period '70 to '74 encompasses the first Acme Reporting Company m..s......
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Federal Register Notice.
Prior to the Federal Register Notice, low level activity with the states and local 2
we had a vc lg
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3 governments and prior to '73wehaddevelopedadraftguidelkne 4
for developing radiological emergency response plans for 5
states and local govr.rnments.
6 This draft guide'was circulating around the United States'and was in the hands of all of the states; I am.not 8
so sure about all the local governments but we were mainly 9
seeking comments on this draft guide that we were trying to 10 put together and we were getting the interest of some of the 11 states in it.
12 So up to 1973 we didn't really have any formal r
13 guidance or any formal piece of business with the states and 14 local governments.
The licensees were, I think some of them 15 at least being more interested in how their emergency 16 planning related to the emergency planning of off-site 17 authorities, but the activity, the overall activity between 18 licensee state and local governments between at that time the v'
19 Atomic Energy Commission was still a very low key operation.
m I think that is the way I can characterize it.
It 21 was like something was being formed but people didn't really 22 know what shape it ought to take yet.
And so there was a 23 lot of maneuvering around to try to figure out what form any 24 guidance ought to take and there were also factions within 25 the Atomic Energy Commission at that time which did not wish 1
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to see this carried to any upper level, or to any, shall we 19 2
say, prominence with more visibility.
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3 Q
Why was that?
4 A
We were operating in a very curious situation.
I 5
think the reason why is in the fact that the Atomic Energy 6
Commission was abolished.
There were vested interests within 7
the AEC that concerned the development and promotion of nuclea:
3 power.
This is why the Atomic Energy Commission was split in 9
half.. This is one of the reasons.
to Why it.was abolished, the regulatory arm at least 11 separated from the General Manager's side of the arm, I would 12 say the climate for emergency preparedness in the old AEC was
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13 a little bit healthier in the regulatory arm than it was in y
the General Manager's side of the house.
You asked why.
15 I tried to give at least part of an answer as to why.
16 There were people in the agency that were afraid that if t-emergency preparedness and planning became too big of an issue is that it may stymie che development of nuclear power.
I think 19 that is a fair statement.
2o Q
In other words, the more visibility emergency pre-gi paredness considerations had off-site and on-site, the more n
likely it would be that nuclear power might be stified in its 03 development?
24 A
Yes, I think that is a fair characterization of the situation at that time.
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Q Now, in 1974, December, 1974, the AEC published a 2
document entitled a Guide and Checklist for State Emergency,
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3 Plans which became ultimately NU Reg 75-1117 4
A Yes, you don't have the title quite correct, but 5
the title is, let me see if I can recall it, Guide and check-6 list for the Development and Evaluation of State and Local 7
Government Response Plans in Support of F'.xed Nuclear pr s
Facilities.
It is quite a mouthful.
9 Q
It certainly is.
10 A
But that document was developed over a period of 11 say about late middle 1973 to its final publication, I think 12 it was December 1, 1974.
At that time it was not known as
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13 NU Reg 75-111.
It was known as WASH 1293.
14 Q
What was the basic thrust of that document?
15 A
Basic thrust of that document and that document k'
16 still today re-issued as NU Reg 75-111 is our primary i;
emergency planning guidance document for states and local is governments.
That and supplement number 1 cf 1977 still 19 remains today ss our primary guidance document.
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The thrust of the document is to provide for 21 state and local governments a listing of essential elements 22 that should be in radiological emergency response plans 23 supporting nuclear facilities.
That plans for the states and pr 24 local governments not-for the licensees.
The document 25 discusses such things as. organization, responsibilities, Acme Reporting Company m. u......
20 Ig communications, notification in the event of an emergency, i
2 accident assessments, protective response, medical consideratic ns, s
3 training, tests and exercises, radiologicalexposurecontrolf 4
that is a fairly complete list.
5 It has got about 16 parts and there are 154 emergency 6
planning elements.
The document is divided into about 16 sections.
Each section gives the objective of what that a
section deals with, for example, communications.
It provides 9
a general objective for that element.
Then beneath it is a bunch of sub-elements, sort of to like a laundry list full of things that ought to be in place ti to address the primary objective in that section.
It-is a 12 fairly comprehensive document and I think it has withstood 13 the test of time.
34 15 0
It is in place and operating now as NU Reg 75-1117 k'
A That is correct, along with its supplement number 1.
16 3-0 Now, that document is not a regulation with the force of law but merely a guideline; is that correct?
gg A
Yes, it is a guidance document.
It has no statutory gg teeth behind it.
y) l Q
okay.
So that with the exception of the requiremento 21 for emergency plans by licensees in the licensing phase, there 22 1
is no regulation available to the NRC or a law having the 23 force of law to require emergency planning off-site.
Is that 24 a fair statement?
25 Acme Reporting Company
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A That is correct.
There is no such law or statute 13 2
that gives us a legal mandate or authority over emergency 3
planning on the part of states and local governments.
f 4
As a matter of fact, we have been unable to find 5
any law that is administered by any other Federal agency 6
which requires this kind of planning either, so it is the 7
entire program emergency planning program, with the states and a
local governments is based on voluntary and cooperative effortu.F 9
Q Since 1974 and until recently, let's say prior to 10 the Three Mile Island incident, could you describe how that 11 program has worked.
Has voluntary cooperation resulted in 12 good emergency planning by the states, generally speaking?
13 A
Generally speaking, prior to Three Mile Island 14 this voluntary program that NRC leads among these Federal 15 agencies has met with some success, but not 100 percent 16 success.
t-One of the reasons for this is some of the states and 18 local governments feel that they don't have the resources to 19 do this kind of planning.
And they are looking for financial 20 assistance and they don't have the proper staffs and this l
21 kind of thing.
That has been one excuse that has been trotted 22 out for not following the guidelines.
n I want to point out that I would say that between 24 the period of 1973 and the time of the accident at Three 25 Mile Island, we are in a heck of a lot better shape now and Acme Reporting Company
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even before Three Mile Island happened, say the month before, 2
than we were in 1970.
Many states have developed plans, e
3 these kinds of plans supportive of these kinds of facilities l 4
but one of the problems is that their quality varies.
5 It is not consistent from state to state.
Some 6
states have very good elaborate plans.
Others have just a 7
few pieces of paper thrown together.
So the: quality varies 8
all over the place.
But in general, I would say that the 9
voluntary program has worked reasonably well for what one can 10 expect from such a voluntary program.
11 Q
Under this program the states can submit their plans 12 to the NRC for review and concurrence by the NRC, what does 13
" concurrence" mean when a state has submitted its plan?
14 If NRC concurrence is obtained, what does that mean?
15 A
We went around and around on that word " concurrence" 16 when the Federal Register Notice was being developed by the 17 old Office of Emergency Preparedness and then later the i
19 Federal Preparedness Agency.
j l
19 There were some people who wanted the word " approval' 20 but the problem with that word was we don't really have any 21 authority to approve anything with respect to these kinds of r
plans so concurrence was selected because it is a softer word.
23 It means more, as I remember according to Webster, a meeting 24 of the minds to do good; in otner words, we concurred in the 25 plan's adequacy.
We did not approve it.
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It was chosen because the program was non-statutory 2
in nature.
That is basically why it was chosen.
What it 5
3 means to us is that if a state develops a radiological 4
emergency response plan that contains the essential elements 5
we consider to be minimal for a concurrence and the elements 6
are developed enough so that we are satisfied that they can be implemented in the event of an emergency, then we grant 8
the concurrence.
9 I think that is wha': concurrence means to us.
to O
So that in effect you are reviewing these plans it that are submitted against some of the guidelines that have 12 been developed by the NRC to determine whether or not the
(
basic components of an emergency plan are present in the 33 34 state plan; is that a fair summary?
15 A
Yes, I think that is essentially what I said.
We is are reviewing the plan against a set of guidelines, standards, 1-if you will, which are not enforceable and if we see that these things are in place and we are basically satisfied with them, 33 they may not be a r.undred percent in terms of quality, we gg 29 grant the concurrence.
Q Now, as of the Three Mile Island incident, how many 21 of fifty states had obtained NRC -- or let me put it this 22 way, how many of the fifty states, if you know, had submitted 23 plans for NRC concurrence?
24 A
.The total numbers that have been submitted to NRC 25 1
l l
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prior to Three Mile Island, I really don't know.
You see
,9 2
all the states that have nuclear power reactors have some kind
\\.
3 of an emergency plan out there.
We have seen a large portion 4
of these plans.
5 But exactly how many of them were submitted, I e
don't recall.
I don't have the records here, but it was, I 7
would say, it is less than,certainly it is less than the total 5
number of emergency plans that ought to be out there.
9 It is a lesser number than that.
Prior to Three 10 Mile Island w: had concurred in, I believe, 11 or 12 state 11 plans.
The reason I say 11 or 12 is I don't remember whether 12 the last state that we granted a concurrence to which was
/
13 Arkansas occurred prior to Three Mile Island or just after; it 14 was around that time.
So it was 11 or 12.
15 Q
Eloven or twelve out of how many states that have 16 operating nuclear reactors?
17 A
I believe it is right now about something in the is neighborhood of about 27 states that have operating nuclear 19 reactors, give or take a state or two.
Ultimately with all 20 the facilities under construction and planned and so forth, 21 I think we figured out that about 41 such states will need n
these plans and some of these states, of course, a small l
23 number of them will be states that don't have the reactor i
inside their boundary, but it sits on their boundary.
24 l
25 We call that a contiguous state and therefore they Acme Reporting Company
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-1 should have an emergency plan.
,g 2
O Had Pennsylvania obtained concurrence from the NRC(
3 for its plan prior to Three Mile Island?
4 A
No, it had not and it has not yet either.
5 Q
Have you had any contact with Pennsylvania 6
authorities concerning their emergency plan prior to Three Mile Island?
g A
Yes,..we did.
Now the exact dates of some of our g
formal centacts that is.. documented in writing, I am not to too sure of but I am going to try to estimate the dates.
I 11 believe it was in April 1975 we received a letter from the 12 Lieutenant Governor, -I think it was of the State of
(
13 Pennsylvania, which transmitted some draft emergency planning 14 documents to us for review.
15 This letter was a.e a result of letters that we have 16 sent out to the states r.nd local governments concerning g
emergency planning prior to that time.
We reviewed this 3g Pennsylvania emergency planning document within about a one-39 month period in May of that same year and I want to qualify 20 these dates because this is coming out of a fog here -- I 23 don't have these files here -- but in about May of '75 we sent g
back a letter to the Lieutenant Governor of the State who 23 had apparently been put in charge of emergency planning more 24 r less and we told him the documents that Pennsylvania had 3
sent to us were a nice start, but we didn't see a lot of the Acme Reporting Company
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27 1
planning elements in the guidance document addressed in them lg 2
and we encouraged them to further develop their plan in 3
accordance with our guidelines.
4 So it was a letter of encouragement more t).an 5
anything else, and thanking them for sending the docunents 6
but indicating to them that the documents fell short of the 7
mark that we had established.
After that time our contact with 8
Pennsylvania, the next contact was a year and a half or two 9
after that in which one of our 10 standard Federal Inter-agency 10 Regional Advisory Committee that we have set up around the 1
11 United States to assist states and the membership on these l
12 committees is composed of the agencies that are signatory 1.o
[
13 the Federal Register Notice.
14 The Regional Advisory Committee for that region, 15 the number, it may be 3, Region 3; anyway, the State of 16 Pennsylvania is in one of these regions.
That regional 17 committee did pay a call to the state.
There was-sort of 18 an informal discussion, a round table as I remember, about 19 emergency planning and to answer a lot of the states' questions 20 they had, I think they had questions of.the.Erice/ Anderson 21 Act and a lot of things which were of interest to them.
I don't thing a heck of a lot came out of that 23 meeting.
24 Q
co you recall approximately when the meetings teck 25 place?
Acme Reporting Company a n, n......
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1 A
No, it was after those letters in 1975.
I would 2
think it was around in '76 or '77 sometime, but I don't g
O recall precisely.
We really didn't hear much fron Pennsylvania 4
after that meeting and they submitted no further energency 5
planning documents to us.
6 So we had a very small staff and we deveted cur 7
our effort:. co states that were interested in following our 8
guidelines and wa ted to cooperate and develop plans.
9 Pennsylvania apparently had internal problems between its 10 Civil Defense Organization and its Bureau of Radiological 11 Health and for one reason or another there just didn't 12 seem to be much interest anymore up there in this kind of 13 activity.
14 So we took our business elsewhere because we couldn't 15 afford to sit around and work with people who at that time 16 didn't seem to be showing a great deal of interest.
We had I;
to go where the action was.
I think a lot of the problem is at that time was due to this internal problem between Civil 19 Defense in Pennsylvania and the Bureau of Radiological Health.
m We had also seen press clippings in newspapers from 21 Pennsylvania wherein the Director of the Bureau of 22 Radiological Health was complaining he couldn't get money 23 resources and so forth to do this kind of planning.
So there 24 was a financial planning problem, a financial problem as well 25 it. this area.
There seemed to be a lot of problems up there.
i l
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lg i Finances; bickering between agencies and things like that, k'
2 at least that was our perception of Washington.
s 3
Q Has it been your experience that as far as the voluntary cooperation with the NRC guidelines is 4
states' 5
concerned that sometimes there is foot-dragging for the purpose 6
of stimulating the legislature to provide funds?
7 A
Oh, indeed.
I have had state officials that s
confessed that to me, told me that outright the reason they 9
were doing nothing or proceedirg along at such a pace that to would barely keep them going in emergency planning in this 11 area was precisely that, that they were hoping against hope 12 that something would happen and they would get money or funds or stimulate their legislators to give them the wherewithall I
13 14 to do this kind of planning.
As a matter of fact, after Three Mile Island 15 occurred, I had one state director of Civil Defense call 16 i;
me on the phone and he said that he wished that he hrd moved 18 on emergency planning a little more rapidly but he said, "Of course, you recognize one of our problems is personnel and 19 finances and I frankly was hoping that the state or Federal m
Government would give us the wherewithall so we could do 21 22 this properly."
So that certainly is an aspect to this whole 23 business, finance s, indeed.
24 Q
Now,.the NRC conducts some training program state 25 Acme Reporting Company
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and local personnel in emergency planning and radiological y
2 response, as I understand it.
Would you describe that progq m 3
a little bit?
4 A
Yes.
That is probably one of the more successful 5
parts of our entire program and one in which we are quite 6
proud.
We have early in 1975, I believe it was March 16, 1975, 7
we commenced our training program with the states and local 8
governments.
At that time we put into place a radiological 9
emergency response planning course.
We did this with the help to of other Federal agencies and we conducted it at the Defense 11 Civil Preparedness Agency's staff college in Battle Creek, 12
- Michigan, l
the f..ve-day planning course.
13 We ran that course until late 1976 until we had 14 covered all 48 of the contiguous states and had sent well 15 over 300 people to that five-day course and it is a course 16 that teaches you how to put emerger.cy plans together using our 17 guidance documents and the guidance documents of other Federal 18 agencies.
19 That course is still in being but now we conduct m
our planning course on an as needed basis and at the request 21 of the states and local governments.
We have also carried 22 that course into the field where it is needed in regional 23 areas of states.
Right now we conduct-it probably about two 24 times a year.
s The centerpiece of our radiological emergency Acme Reporting Company aca,.s......
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i 21 1
preparedness training program is the course that is called 2
Radiological Emergency Pesponse operations.
It is an 8 1/2(;
3 day course; let's say a hardware or general course.
In other words,.it. teaches people how to use 4
5 instruments and equipment and things like that, and it is 6
conducted at the Department of Energy's Nevada Test Site but
~
it is sponsored and paid for by the NRC.
8 We train state and local government people in that 9
course to be members of radiological emergency monitoring 10 teams.
The course is a very good program.
Our files are 11 full of letters that attest to its quality.and we are right 12 now pushing about 320 state and local government people a year 13 through that program, and about 80 Federal people a year through 14 that program.
15 It is an action oriented course that contains 16 simulated emergencies such as a power reactor accident, a 1~
transportation accident inv61ving radioactive materials and 18 industrial accidents involving radioactive materials and it 19 has been quite well received by state and local government M
people.
21 Another course that we have put into place which is conducted for us periodically by the Environmental Protectio ln 22 23 Agency is a radiological emergency response coordinators 24 course which is a' course for management personnel.
In other 25 words, decision makers that would have to make decisions based l
l Acme Reporting Company m..
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on evaluations of radiological accident assessment information, 2
We have conducted that course just about for all q.f 3
the states, I think, have sent soneone to it.
More than one-person from each state has attended that course.
That course 4
3 is '.ncomplete and we have only concluded one phase of it.
The 6
6ther phase still has to be developed.
That depends on work that has to be done by the Department of Health, Education 8
and Welfare.
9 That is essentially what our training program to consists of, courses in planning and operations.
Now we have it run the program since 1975.
I would like to point out when 12 we started out, this training program in '75, I had S20,000 13 for training so the training course cost us over the period
/
14 1975-1976 cost us about S80,000, and the other S60,000 15 we obtained " hat-in-hand" by going around to the other 16 involved Federal agencies, t-So the picture I am trying to paint h ere is we put 3g these training programs together with very little money in 19 the beginning.
Now our training budget for this fiscal year 3
is about $635,000.
The bulk of whicl. goes to the course that is conducted at the Nevada Test Site so there has been an increas-21 22 in funding for the program starting out at a very low level 23 within the NRC at about $20,000 a year to something in the 34 neighborhood of about $635,000 a year today.
23 0
Recognizing you don't have the files with you, but Acme Reporting Company
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do you recall what the participation of Pennsylvania authorities 2
has been in these kinds of trainir.g courses?
3 A
It has been very low, certainly not anything like 4
other states which have sent people to these training courses.
5 I think one person from Pennsylvania has attended our 6
radiological emergency response operations preparedness ccurse in Nevada which is an important course.
8 I think Pennsylvania has only sent one person to that 4, 9
the planning course, they did send people to that on a 10 periodic basis but the operations course, I think, only one 11 person has ever attended it.
12 We received a letter from Pennsylvania Bureau of Radiological Health after our director sent them his annual 13 ta letter with course offerings for courses conducted in Nevada.
15 The reply essentially was they couldn't afford to send people is to the course out of state for that length of period of time, i-even though the NRC was paying all the expenses except the 13 salary of the individual; we paid travel, per diam, costs 19 and also they were a little bit critical of the training pro-m gram out there, saying that although there might be some 21 parts that are useful to them, there were other parts which r
were not useful to them.
We have such a letter in our files.
3 34 Q
The statutory and regulatory scheme of the NRC is, 25 correct me if I am wrong, that a low population :ene is Acme Reporting Company
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34 1
established around a fixed nuclear facility and emergency 2
planning is done within that zone particularly evaculation (
3 planning, and that is a requirement of licensing.
But that ~
4 as far as outside the low population zone the LPZ is concerned 5
there are no regulatory requirements or any regulations 6
issued by the NRC that have the force of law to require emergancy planning outside that LPZ.
8 Is that a fair summary of the approach?
9 A
Well, in general that paints a reasonable picture.
10 Maybe I could elaborate on that a little bit.
11 The low population zone is an area that is defined in the NRC citing criteria Title 10 Code of Federal Regulation 3p/
12 13 parts 100.
And essentially what it says in there about the 14 low population zone is that an area established around a 15 facility in which there is reasonable likelihood that protective 16 measures such as evacuation can be taken on behalf of the i-residents of that low population zone.
is The low population zone itself, that portion of it 19 that is outside the exclusion radius which is the radius arounc 20 the facility in which the licensee has control of the property 21 and all the activities within it, the area between the n
exclusion radius and low population zone radius is an area that 23 really the licensee doesn't have any control over.
24 I think there was something in your question which 25 indicated maybe the licensee had scme kind of control in that Acme Reporting Company l
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ig 1
low population zone.
In fact, he does not have any control 2
whatsoever in that zone because that zone is generally.--
(
3 unless he owns the zone; in some cases he may own part of the 4
land in the zone, but in other cases he may not own the land 5
that is in that zone -- the residents in that zone if he does 6
not own the land are just like anybody else living anyplace in the United States, their protection is governed by the a
police and health authorities of that community.
9 The licensee really doesn't have any authority to do 10 anything in that low population zone if he doesn't own the 11 land.
At least that is my interpretation of it.
So the 12 thing I am trying to say here is that there are large portions 13 of low population zones in which the licensees have no authority 14 whatsoever.
15 Q
But in order to obtain a license there must be 16 emergency planning preparedness within the low population zones '
i 1-Is that correct?
18 A
The licensee must show the NRC and the old AEC that 19 there is a reasonable likelihood that appropriate protective 20 measures canibedtaken in the event of a radiological release 21 on behalf of the residents in that zone, but as I pointed out a
before, the implementation of those protective measures may 23 depend almost in all cases depends on activities carried out 24 by local and state authorities, not the licensee.
25 Now the licensee can send people o
- into the low Acme Reporting Company i
36 1
population zone to conduct accident assessments and give advice 2
to state and local gcVernment authorities but unless he owng 3
the land he has no police powers in it.
That is a prerogative of the state and local 4
5 government.
So it is a :rather peculiar situation and as a 6
matter of fact, I would like to say for the record in my opinion and in the opinion of other people,.the low population s
zone concept which is used for citing nuclear power plans y?
9 has gotten this Agency into a lot of difficulties on the to emergency planning front.
11 Q
How do you mean?
12 A
Well, one of the problems is that loa population
/
13 zones vary in radius all over the place.
They range all the 14 way from about 7/10 of a mile in radius to 10 miles for the 15 Fort Saint Vrain gas cool reactor in Colorado.
States and 16 local governments have never understood why low population i-zone radii vary all over the place or at least they have not is understood it very well.
ig In theory the reason they vary all over the place is 20 that the zone is established based on the kinds of engineered 21 safeguards that the plant has.
In other words, if you 22 lack safeguards on the plant such as additional space and f5 23 containment, a whole host of things, then you can theoretically 24 bring the radius of the low population zone in closer to the 25 site and establish that as the low population zone based on Acme Reporting Company a w.,.....
37 1
the engineered safeguards because in analysis of the design 2
basis accident used for siting purposes which are governed g 3
by the type of safeguards the plant has one can make the low population zone by calculation almost any radius one wants 4
5 to do.
6 It has been a very peculiar piece of business in 7
my opinion.
Now, how does that all relate to emergency 8
planning.
Well, it is difficult to base emergency planning 9
around a nuclear power facility on the low population zone 10 concept, because when you start looking at the off-site 11 cons =quences of certain design basis, accident and class 9 6
12 accident naturally the consequences in my case with respect
{
13 and I say consequences, I mean projected doses to the 14 population transcends the boundaries of the low population 15 zone and as a result in doses at distances greater than low 16 population zone boundary.
17 I guess what I am trying to say here is that for is years the low population zone boundary seemed to be in the 19 minds of many some kind of dagic line beyond which one didn't 20 really have to do a heck of a lot of emergency planning and 21 preparedness in practice in recent years in the licensing V
22 arm of this agency emergency planning was encouraged out to 23 a radius of about four or five miles.
24 This corresponds to an average low population zone 25 but the NRC-EPA Task Force which was formed in 1976 to look Acme Reporting Company
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38 1
into the question of how big of an accident should state and lg 2
local governments plan for at the request of the states; I (
3 think that report pretty well discredits the low population 4
zone as having any real meaning in emergency planning and 5
preparedness and that is why the NRC-EPA Task Force people 6
of which I was the co-chairman of that Ta sk Force came dcwn on the side of establishing emergency planning zones around a
these facilities rather than getting hung up on this problem 9
with the icw population zone which in my opinion has no real to relationship to emergency planning and preparedness.
11 0
Could you describe just briefly what the principal 12 recommendations of the Task Force were?
I 13 A
Yes.
The bottom line on the Task Force report 14 is,without going into a lot of detail, there shall be 15 established around every operating light water nuclear power 16 plant in this country that we are talking here of plants t?
v I-of several hundred megawatts electric all the way up to 11,
is 1,200 megawatts. alectric to emergency plan zones EPS's.
t$
19 The inner zone is for the plume exposure pathway of x
about 10 miles in radius and on the outer zone for the 21 ingestion exposure pathway of about 50 miles in radius.
That 22 is essentially what the Task Force recommendations are and 1
t 23 they arrived at that unanimously.
24 I might add the 11 person Task Force, 7 peopis frem 3
NRC and 4 from EPA, and they arrived at that recommendation Acme Reporting Company m.......
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after about 2 1/4 years of work, one of the reasons they gg E
2 recommended the establishments of emergency planning shown e 3
was because the Task Force was enable to identify any single' 4
accident for which one should plan because there is such a 5
whole host and spectrum of accidents that the Task Force 6
decided what needed to be done was to develop emergency plans 7
which were consequence-oriented and these zones were selected.
8 The size of these zones was selected as being 9
representative of the distances that ought to be in place to within which definitive amargency planning should take place 11 for the great bulk of possible power reactor accidents, 12 possible but not necessarily probable.
13 Q
Has the Task Force report been acted on yet?
14 A
The Task Force report was published December, 1978.
15 It went out for public comment with the Federal Register 16 Notice of December 15, 1978 for public comment until March 30, 17 1978.
18 Then as a result of the Three Mile Island accident 19 several people requested the comment period be extended 20 so a second Federal Register Notice went out in April 21 extending the comment period u ntil May 15, a total of five 22 months.
23 All the comments are in on the report from state and 24 local governments.
Utilities, private interest groups, 15 citizens groups, private individuals, everybody that -had Acme Reporting Company me....
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4 40 1
anything to say about it and the report -- not the report, Iamsorry--thecommentshavebeenanalyzedbytheNRC-EPg 2
3 Task Force and that analysis is complete.
4 The current status on that whole piece of business 5
is that Mr. Brian Grimes of the Office of Nuclear Reactor 6
Regulation and myself, who are the cc-chairmen of that Task Force sent forward to the Commission last week an action a
paper with a proposed policy statement relating to the 9
establishment of these zones around these nuclear facilities.
10 Our paper contains an analysis of all the comments 13 received and it was endorsed by all of the major office 12 directors and there is one dissenting view from a division l
13 with a major office that went along with that.
But the b'
14 endorsements of those zones is almost unanimous within the 15 Agency.
16 It is our understanding that EPA is sending forth 1-to its appropriate administrator a similar proposed policy te statement concerning the establishment of these zones around 19 these facilities.
What our Commission will do with that a
paper, I don't know, but obviously I am sure they will be 21 taking it under advisement and consideration and we should y.
know soon, I hope, what they will do with what the recom=enda-23 tions of the Task Force are.
24 Q
Most recently this year the NRC had issued a 3
Federal Register Notice requesting public comments on Acme Reparting Company m. n......
41 I
consideration of the adoption of additional regulations which 2
will establish as conditions of power reactor operation g
3 increased emergency readiness for public protection.
4 Can you describe the procese, that produced those 5
public comments?
6 A
This is the proposed Lule-making you are talking about, July 17 or something like that?
8 Q
Yes.
9 A
That proposed rule-making was a decision by the to Commission -- they decided they were going to do this.
And 11 if Federal Register Notice of that put out the proposed rule-V 12 making on emergency planning, lists a number of issues or
(
13 questions which were developed by a recently appointed Task 14 Force on Emergency Planning within the NRC.
The Task Force is not to be confused with the NRC-EPA 15 16 Task Force on Emergency Planning.
So the issues that appear g-in there were developed by this other Task Force on jg Emergency Planning.
One of those measures, I believe, gg concerns a question which says in effect, what should the 20 Commission do with the NRC-EPA Task Force report?
21 Mr. Grimes, I know, and myself are a little bit 22 disturbed that that question is going out since it seems to g3 us that the NRC -EPA Task Force report and its recommendations 23 have already been out for public comment for five months and 25 here we see it being. trotted out again in this proposed Acme Reporting Company an.........
42 lg rule-making so I am net quite sure in my own mind whar the i
2 intent is there.
l 3
It seems to be like doing the review of a review.
Q That comment period is over on August 317 4
5 A
I don't know when it expires; I don't recall the 6
date.
~
Q I would like to turn to the incident itself, the 8
Chree Mile Island incident in March, 1979, and get a picture 9
of what your involvement was with the NRC.
How did you first to hear there had been an incident at Three Mile Island?
11 A
On Wednesday morning the 28th of March, 1978, I V'
12 was in my office, the Office of State Programs which is
(
13 located in the Maryland National Bank Building in Bethesda.
14 I first heard about it from a colleague in the 15 office.
I believe it was Mr. Schwartz and also the Director 16 of our office, Mr. Robert G. Ryan.
They had received 1-information or someone in our office had received information 18 that something had happened at Three Mile Island.
19 As I recall,we found out about this somewhere between 20 8 o' clock and 9 o' clock on Wednesday morning in our office.
21 Q
During the day Wednesday, what was your principal 22 activity with respect to the incident?
23 A
Well, that first day we.sent over to the NRC's 24 operations Center in Eastwest Towers Building on East West 25 Highway in Bethesda a representative of our office, Mr. Harold Acme Reporting Company n s..,.....
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Gaut, was the man who went, cne of our emergency planning 2
people and Mr. Ryan, our Director, also went over there to (;
3 the Operations center to see whether our services were needed 4
in the Center and so forth and so on, since we are, part of 5
our office is part of the emergency response team in that 6
Center.
7 The rest of the state program staff throughu;. the 8
day mainly dealt with answering the numerous telephone calls 9
coming into the Office of State Programs from places all over 10 the United States, as far away as Washington State.
The 11 phones were ringing off the wall.
I think just about every 12 professional staff person in the office was answering I
13 inquiries from concerned state and local government people 14 who had heard that semething was amiss in Pennsylvania.
15 So I think that pretty well characterizes the 16 activities of the Office that first day except for the 17
" State program staff people that had gone over to the Operation 18 Center.
19 Q
Now you eventually went over to the Operation 00 Center later in that week, as I understand it?
21 A
Well, I went over to the Operations Center later e
that day.
23 O
That day?
24 A
Yes.
25 Q
Now, I would like to get a picture of just how the Acme Reporting Company j
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Operation Center was set up.
As I understand it, the 2
operation Center was the place where the senior management g 3
people for the NRC in Bethesda were making decisions and 4
getting information.
5 Is that correct?
6 A
That is correct.
O Could you describe physically how the operation 8
center was set up?
9 A
Yes.
It is a very large rcom.
I don't know the to dimensions of it but I would estimate that the total cubicle 11 the room is in is perhaps 40 feet by about 30 feet, something 12 in that nature, and subdivided into two rooms with a glass I
window between the two rooms.
13 14 One of the rooms has a table in it in a U-shape 15 configuration, a square U-shape conf.iguration with black-16 boards and clocks showing times all the way from San Francisco g
to New York City, a battery of telephcnes, chairs, desks, is and so forth.
ig This particu1Ar section was.the section where the 3
NRC senior management sat.
Then the room next door to that gi was where a lot of the NRC staff technical and support people 22 congregated and that consisted of a room with several desks 23 and was divided into 3 major areas.
There was one area that concerned itself with radiological surveillance activities.
24 Another area concerned itself with what was happening in the 3
Acme Reporting Company i m........
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plant, and another area which was essentialy equivalent to 2
the telephone switchboard area where there were ladies sitti g 3
at desks that could switch calls, inccming telephone calls, and switch them to the other people.
4 5
Theretwas a small anteroom off of that room which 6
our office used, the Office of State Programs, which contained 7
a couple of desks and two telephones.
8 That is generally what the room looked like.
In 9
the room that contained the staff people there was also a very 10 large dictagraph machine which was recording telephone calls 11 on some 20 channels of tape similar to the machines that 12 the FAA uses in control towers at airports.
[
13 Q
Let's say you got a call from someone in an adjacent 14 state wanting to know what the situation was at Three Mile 15 Island and if you had fielded the call in the Operations
~
16 Center, how could you get the information you needed to responct 1;
to the call?
18 A
Yes.
That was happening all the time over there.
19 Calls from states and especially the states around Pennsyl-m vania.
Depending on the questions the state official would i
21 ask us and these state officials that were calling us 22 generally were the state radiological health officers and/or 23 the state Civil Defense directors.
24 If they wanted to know what the status was within 25 the plant, we would obtain information on that from the desk Acme Reporting Company
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in the Center that dealt with the current status cf what 2
was going on in the reactor facility.
Scme of this infor=ation 3
was posted on blackboards in the room.
If they wanted to know information concerning the 4
5 radiological situation in the environs of the plant, then 6
we would obtain that information from the desk in the Center I
that dealt with the radiological matters so it was a matter of 8
either knowing what the answer to the question was or if we 9
didn't, going over and talking to someone who was working 1
1 10 in that area that could give us the information.
11 Sometimes we could get the information right away.
12 Sometimes we couldn't and we would have to tell the state i
- /
13 official, "We'will h ave to get back to you,".in. five minutes, 14 ten minutes, and call them back.
i 15 Q
So in effect you would come out of the anteroom is and walk over to the, let's say, the desk having to do with 1;
conditions at the plant and ask the person staffing that desk 18 what the situation was at the plant at the present?
l 19 A
or some specific question relating to the plant.
l l
20 Q
All right, and get that information and go back and l
l 21 report to the person who had called?
22 A
That is correct.
23 0
And the same would happen with respect to the 24 other desk concerning the radiological monitoring?
25 A
Right.
Then there were other offices up and down Acme Reporting Company
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hallways in that building.
Youseethisfloorisreallypartoftheheadquargern 2
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contingent of the Office on Inspection and Enforcement.
There are batteries of offices in the hallways on either
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4 5
side of the Operation Center that were offices of staff people 6
and many of these offices have been sort of temporaril.y converted into other action desks on other items and 8
sometimes we would have to go out there to get information 9
depending on what type of a question was being asked.
10 Also, other Federal Agencies, namely, HEW, EPA, 11 and FDAA, sent representatives to the Center who were in some 12 of these offices there, a sort of liaison representative.
13 Q
Okay.
Approximately how many people were in the 14 Operations Center as a rule as during the period of time 15 you were there?
16 A
Well, that varied all over the place depending..on 1;
what activity was going on and also, well, it mainly is fluctuated depending on what was happening in the plant, the 19 information that was coming in.
There were a lot of people 20 in the Center.
21 It got pretty grimy in there at times.
There was a lot of trash around and things like that.
Far more e
23 people in the thing than the thing was designed for.
I i
24 think that has been recognized now.
25 Oh, I would.say in the management portion of the Acme Reporting Company na.
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Center at any given time one would find perhaps anywhere from 2
8 to 12 people in there.
e s:
1 3
In the staff portion of the Center you would find 4
anywhere from 15 to 30 people at any given moment.
There were 5
a lot of people, so in total we are talking about something in 6
the neighborhood of maybe 30 people milling around in the placa.
Q And your desk, office of State Programs, in the a
anteroom was the principal conduit to the State of 9
10 A
It was and to the other states as well.
We had 11 during the crisis periods of the accident, the early days 12 through the weekend, we generally had two people from State l
13 Programs
.1 there and on occasion we would have one, but 14 generally there were two.
15 Q
During that first Wednesday was there any talk on 16 Wednesday or Thursday even about evacuation in the Operations Center?
g A
I don't recall any direct talk about evacuation in is the Operation. Center on Wednesday and Thursday.
Certainly 39 3
there was talk among some of the staff people there about it 21 from time to time, I am sure, especially by those that were 22 concerned about what protective measures might have to be taken i
l but the issue of evacuation b' dnesiby and Thursday, to the best e
.,3 1
24 of my knowledge, never really came up in any real d'edinitiva.
sense.
That didn't happen until Friday.
l 25 l
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O was anything said on Wednesday or Thursday, what lg 2
kind of evacuation plans dbes the state have or we ought to b 3
working on the state evacuation plans; was any of that 4
kind of talk going on?
5 A
Mo, we had the Pennsylvania emergency plan in the 6
Center.
We had two copies of it there.
One that we had gotten through the side door in December, 1978, some official in the state finally gave us a copy of the thing.
I believe s
k' there was a copy available to your inspection and enforcement 9
n) people who run the Centen who manage it.
I don't recall anybody saying that we ought to work 1:
with the State of Pennsylvania in preparing an evacuation 12 13 plan.
There were some people that might have asked the ques-tion as to whether there was an emergency plan and the answer 34 15 was, yes, the state did have one; was there an assignment of responsibility for evacuation, and yes is the answer and I ui believe it was the Pennsylvania Highway State Police.
g But there wasn't, I don't recall a great deal of pg activity concerning evacuation planning of anything like that v'
39 going on in the Center at that time.
Now, there may have been 3) some activity like.his going on in the state Pennsylvania gi 22 Emergency Managen.
! Agency itself.
As a ma' 3.r of fact I know there was.
Because we 23 found out that an Official from Washington of the Defense 24 Civil Preparednt is Agency had gone to Harrisburg and had 3
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established himself in the Pennsylvania Emergency Management 2
Agency Center to help with emergency planning matters and, as
\\
3 a matter of fact, this resulted in the State of Pennsylvania.*
over the period of, I don't know when they started, they 4
5 probably maybe started on Thursday or Friday or something 6
like that, starting to put together ad hoc evacuation plans 6
for the area around Three Mile Island ranging out the distances all the way to 20 miles but I have no personal s
detailed knowledge of those activities, only what I heard in 9
conversations with the Federal officials that knew about the to 11 activity up there in the State.
12 Q
So that principally on Thursday and on Wednesday
/
at least as far as your activities were concerned, it was 13 principally a process of gathering information and reporting 14 it to the various states who would be inquiring about what 15 was going on at Three Mile Island.
Is that correct?
16 A
That is correct, and obtaining information from 1
the state which would be useful to the Operations Center.
33 Q
Okay.
Now, what kind of information were you 19 obtaining that was needed in the Operations Center?
g A
Well, in those early days, Wednesday night, 21 Thursday, Friday, we were obtaining radiological surveillance 3
information from the State's Bureau of Radiological Health.
g We were getting this information on a rather sporadic basis..
l 3
l It wasn't coming in in any consistent manner.
We 3
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were getting some information.
We would transmit this lg information from the State Proc.rans Section of rhe Center to o
3 the Radiological Health desk in the Center.
Sothatfunctiod 4
was going on.
5 Q
Moving into Friday morning or Friday, when did you 6
first arrive at the Operation Center?
Well, before I go into that, I would like to ask 8
ene more question on Wednesday and Thursday.
What was your sense of who was managing the incidents on Wednesday and 9
10 Thursday?
Was it being managed from the Operatione Center as opposed to monitored by the Operations Center?
11 In other words, were the NRC region 1 people t'd 12 the utility managing the accident on Wednesday and Thurscuy
(
13 as a practical matter?
34 A
Well, of course, that has been the question all 15 al ng as to who was managing the incidents at the site.
16 Q
Yes.
g A
I don't '-rtthe NRC Operation Center was certainly p/
3g managing the incidents at the site.
They were more of an F
19 information gathering mode then.
I don't recall any orders 20 l
being issued out of the Operations Center directing any kind 21 of plant activities or anything like that.
gg Mainly they were just requests for information to 23 l
the NRC officials there, to the Metropolitan Edison people.
g I think all of the incident management at that time were all 25 Acme Reporting Company
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occurring at the site.
2 Who was running the show, I don't know.
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3 Q
When did you arrive at the Operations Center on 4
Friday?
5 A
I don't recall precisely when I arrived but I 6
think it was early in the morning.
I have no exact recol-lection.
I would have to go.back and look in the logs that we 8
kept for the Center.
I think it would have been about maybe 6 o' clock 9
to or 7 o' clock in the morning, something in that neighborhood.
It could have been before.that.
11 32 O
As you arrived, who was in the management portion 13 of the Operation Center that was called the bullpen?
A Well, that is what some of us called it, the bull-14 15 pen, yes.
In there at that time, I believe, was Mr. Gossick,,
the Executive Director for Operations; Mr. John Davis, the 16 Acting Director of the Office of Inspection and Enforcement; 3
I am saying this is early Friday morning.
We are talking 33 l
like maybe 6 o' clock or something like that, 7 o' clock on --
19 l
Mr. Ed Case, the Deputy Director of the Office of Nuclear 20 Reactor Regulations; Mr. Harold Denton, the Director of that 21 l
same office; Mr. Du'dley Thompson, Executive Officer of the 23 office of Inspection and Enforcement; Mr. Joe Fouchard of 23 our Office of Public Affairs; and a few other middle-management i
24 pe pie who were popping in and out of the place.
25 Acme Reporting Company
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3 But those are some of the principal people that 2
were in and around in there that morning.
3 Q
Now the people you have described, it it fair to 4
say generally they were senior management people, the heads of offices and divisions within the NRC?
5 A
Yes, they were at the top of the, Agency Directors 6
and Deputy Directors.of major program offices within the MRC, 7
and, of course, the Executive Director for Operations, g
Mr. Gossick, who is the Chief Executive Officer of the Agency 9
under the Commission.
10 Q
What did you do when you arrived in the opeEations 11 Agency Center as you recall?
37
/
A Well, there was somebody on watch there from State 13 Programs, one or two people, and like in the military we looked 34 ver the logs what had been written and brought ourselves k'
15 up to date on what was going on during the past night and 16 the other Office of State Programs person that was in there 3
with me coming in that morning was Mr. Robert DeFayette, so 18 we obtained information from the off-going watch and then gg 4
assumed our watch in the Center.
0 Q
When did the picture start to develop something 33 significant had happened at the plant?
g A
Friday morning.
23 Q
Yes?
3 A
I w uld say that it looked to me like it started to 25 Acme Reporting Company
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develop around 8 o' clock in the morning thereabouts.
We 2
started to hear about reports that there was on-going or thgre s
3 has been a radiological release from the Three Mile Island
~
4 facility which was a little bit different than other releases 5
that had been occurring on previous days.
6 These teletses were described as mainly due to the off gasing of noble gases from highly radi'oactive primary a
cooling water which had found its way out of the containment V'
building into the auxiliary building of the facility and 9
one can best characterize the mixture, I suppose, as being 4'
to that the plant had a water management problem and that this 11 water was radioactive and was releasing radioactive emissions 12 13 to the atmosphere.
We started to hear about different radiological 34 readings around the plant which were indicative that some 15 type of releases which were higher than what people had been 16 measuring on previous days were occurring.
i-Q Did there seem to be a lot of definitive hard-core ig information as to what the radiation leve*s were off-site?
19 t
A No.
I wouldn't say there was any definitive hard-3 core information coming in concerning what radiation levels gi were. The" information was very sporadic, such things as 3
25 =illircentgenc por hcur at the site boundary and 12 g
milliroentgens over the year and that one famous reading, p/
74 1,200 millircentgens per hour over the exhaust vent or stack 25 Acme Reporting Company
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of the plant.
^
2 O
These numbers would be coming on a sporadic basis e, i
3 without people being able to relate them to specific times a6d 4
levels?
5 A
That is correct.
It was very confusing from my 6
standpoint and from the standpoint of others.
There didn't seem to be any real handle on precisely a
where these releases wers being measured, only in the very 9
general sense and the tSma at which they were measured were to verying.
11 Q
So in some cases you wouldn't know where the 12 speci.fic measurement had come from and in other cases you I
13 wouldn't know when a particular reading had been obtained.
14 There just seemed to be no specifics about some of the 15 information you were getting?
16 A
Well, I would say in general any radiological t-surveillance information we were getting there generally is
'was a location given with in but it wasn't all that clear in
(
19 the minds of the people in the operations c' enter as to precise 2 y
20 exactly where that location was.
21 There was a lot of confusion there, I think.
I 22 think the times of releases, although we were getting some 23 times when measurements were taken and so forth and so on 24 in all cases we did not get good times as to when measurements 25 were being made.
1 Acme Reporting Compony
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Things would come in like it was measured an hour 9-9 I
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2 ago or it was measured about 30 minutes ago, things like e
N.
3 that, generalities.
4 Q
So that when somebody had some information from the 5
plant, what would that person do with it to 6
communicate it to the senior management people in the 7
bullpen?
8 A
Well, most of the information about the plant 9
itself was coming into the section of the Operations Center 10 that contained the staff, what could be called the staff as 11 opposed to management on the other side and the information 12 would come in there and then the individual that had the 13 information would go into the management center'part of tne
(
14 operation Center and he would make an announcement or he 15 would write something on a board or go over to one of the 16 management officials and give this information to him either 17 orally or on a piece of paper or sometimes if he was located is somewhere in the building and he found something out, he 19 might phone it in.
20 0
What would happen when that information was 21 transmitted?
How would the management communicate information 22 among themselves?
23 A
Well, they would discuss it and try to figure cut 24 what it meant.
It would be a lot of discussion on 25 individual pieces of information:
What does this mean? or A=e Reporting Company u,,.:......
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1 That's not good enouch.
Go back and get some more; or We 2
don't understand whar this means.
We don't know what to 3
make of this; or Yes, we understand this.
4 It was a whole variety of reactions to this 5
information, but I think the point here is that the 6
info::mation was coming in from a lot of different scurces 7
and via a lot of different tracks.
8 There wasn't really any good way to relate one 9
piece of information to another piece of information.
I to think this is what pahitad a great deal of the confusion which
. = --
11 seemed to rain from time to time over there.
12 Q
Confusion as to what was happening at the plant?
13 A
Yes, and a lot of people in the center felt 14 especially on Friday morning that they weren't really con-15 vinced that the people on-site had a handle on what was 16 going on and they didn't feel they in the Center had a handle t7 on what was going on.
is They didn't know how long these radiological 13 releases were or: curring, the length of time,there was very 3
poor informatiren on that.
They were finding out about gi things long after the fact, anywhere from many minutes to a
hours af ter t.he fact all kinds of things.
23 Time lags and just the general feeling of 24 uncertainty about who had a handle on the whole situation 25 up there.
I think there was a pervasive mood on Friday pr Acme Reporting Company
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morning.
ig 2
Q So that let =e see, if I can characterize it, g
3 su=marize it so that the senior management people in the 4
bullpen were getting readings that they didn't always know 5
where they were taken or when they were thken.
6 They were getting isolated bits of information and the pervasive moods as a result of getting these isolated 8
bits of information and not being able to relate them to the 9
big picture was that didn't know whether the people on-site, to the utility A.td the NRC people on-site,really had control 11 of what was happening inside the plant.
12 Is that a fair characterization?
l 13 A
In my mind that is a fair characterization.
14 Q
And as a result the people in the bullpen did not 15 really feel they had control of the situation either.
16 Is that fair;rtoo?
t --
A That is correct.
That is fair.
is Q
What happened when the 1,200 millirem reading 19 came in; do you recall how that, I take it -- let me back 3
up and ask you, I take it the 1,200 milliram reading from 21 the site was really what precipitated the evacuation 22 discussion or put the wheels in motion for the recommendation 23 that the NRC senior =anagement people ultimately made to the State for evacuation.
24 Is that correct?
25 Acme Reporting Company
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A Yes, that is correct as far as I can see it.
When 2
we first heard about that reading of 1,200 milliroentgens per N.
3 hour3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> measured at a stack or a vent above the plant; that 4
started to get people very concerned, that also they did not 5
know precisely when this release had started or whether it had 6
in fact terminated or what.
They had no information as to the length of time of a
the release, and that reading was an isclated reading.
It e
was that reading, to the best of my recollection, really to triggered off the discussion about evacuation as a protective it measure.
12 It was from that point on all discussions concerning
/
13 evacuation stemmed.
That I think was the highest reading 14 that -- well, I won't say it was the highest because there 15 were readings of something in the neighborhood of 20-to 30,000 16 milliroentgens per hour that had come into the Center before k'
but that these readings were at the top of the containment t-jg vessel itself, the concrete containment; oh, but with respect 19 to material going;off-site;0.I..think that was the highest 20 reading that I heard of between Wednesday and Friday morning, 21 at least in the net portion of the plant.
22 0
What was the understanding in the bullpen, as best 23 you can remember, of well, first of all, were you in with 24 the senior management at that point?
25 A
Ch, yes, I would walk in there because, you see, Acme Reporting Compony
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this little anteroom at that time the Office of State lg 2
Programs people were in was sert of straddled,is off to the 3
side, the area where management congregated and the area 4
where staff congregated, so we had a door from our little office that went both into the staff side and management side, 5
6 so we sort of straddled the thing, if you will, so myself and other program people had full access to the Center.
8 We would go in and listen to the discussions on both sidss.
9 10 Q
What was your sense of what people thought in the bullpen had caused this 1,200 millirem emission?
. ti A
Would you repeat that question again?
12 Q
When the 1,200 millirem reading came in, what did
['
13 you understand that the people in the bullpen thought had 34 caused that emission of that size?
15 A
Well, I don't know what some.of them thought: I 16 think some of them knew it was coming from or perceived it g
was coming from the off-gasing of primary cool plant water
/
33 in the manipulation of water around the plant.
19 They were letting primary cooling out of the primary v-3 system and this, of course, was going into containment and 21 then there was a path from containment to the auxiliary 3
building and the radioactive waste water tanks and so forth 23 and so on.
.,4 1
And I think that most people thought that these 25 Acme Reporting Company a n........
61 were inadvertent releases that water had to be released and Ig g
2 there was no way from keeping it from going out and the k
3 radioactive material in the water, the gases were coming out:
much like gas comes out of a bcttle of soda water; these 4
were inadvertent releases the plant operators couldn't control.
5 I think that is what some people certainly thought.
6 The situation was something over which they had no control or g
if th3y had control, it had to be done.
9 Q
Okay.
So there were two kinds of releases it seems to at that point.
The first was an emission that occurred when the 13 plant operators had no choice but to transfer water from one 33 place to another?
[
13 A
[ think there were some situations like that, yes.
34 0
And the second that occurred that was completely 15 unplanned and unprotected and uncontrollable, just as a
16 result of having transferred water.
g In other words, the release of gases?
3g A
Yes.
There is no way that they could prevent gg l
the gases from escaping from water which had spilled over 20 outside of its tanks, fin the tanks in which it was stored.
gg The gas just ecmes out of its cwn volition and escapes into g
l the atmosphere of the building and then out through filters g3 to the environs.
3, 0
"*f' Y " in.the Operations Center with the 1,200 25 Acme Reporting Company
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millirems emission was reported to the senior management 2
people?
\\:
3 A
Yes, I was.
4 Q
Could you tell us what happened just as best you 5
remember it, how, who said what, and what happened?
6 A
Well, there is no way I can say who said whrt.
I can sort of characterize a little bit about what went on.
There was a great deal of concern over this release.
a The principal concerns were that they didn't know how long 9
the release had been going on,when it might terminate and to they also don't know whether there would be more releases in b'
it the future of that magnitude or even higher.
12 I
There was some uncertainty based on the information 13 that was coming from the people at the plant that there may 14 be more such releases going to occur later on in the morning.
15 So with that in mind, I think, discussions shifted around is to posibbly evacuating people around the facility and it g-was with that line of thinking about uncertainty of the 18 existing releases, how long they had been going on, what 39 would happen in the future, that triggered off the discussion go of probably recommending evacuation around the facility.
gi Q
That was about 9 o' clock?
n A
Around 9 o' clock in the morning, thereabouts.
23 0
Do you recall who reported the 1,200 millirem 24 release?
23 Acme Reporting Company
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A I don't recall who did.
lg 2
O F: hare did you understand the release was coming from
\\.
3 when it was reported?
4 A
It was coming from an exhaust vent or a stack.
It 5
was described in various ways, some kind of a structure on 6
the plant.
0 Is it fair to say that -the report of the 1,200 milli-8 rem release triggered a state of alarm or excitement?
9 A
I wouldn't say it triggered a state of alarm.
That to is a pretty heavy state, a state of alarm.
That is when 11 people really start running around.
It triggered a state of 12 significant apprehension.
Let's say that, significant i
13 apprehension.
\\
14 That would be more characteristic of what -I 15 perceived to be the state of psychological affairs if you will, 16 in the Center, people had apprehension.
1-Q What were they saying, for example?
tg A
Well, they were discussing a lot of "what if's"?
What if this thing goes on all morning?
Nhat if this magni-19 1
00 tude of this release gets bigger?
What if the wind carries it gi off-site and it blows over some town?
What is going to be 1
l n
the exposure to people?
How much of a radiological dose are 23 they going to get?
What do you think we ought to do?
That 24 kind of a thing.
Those are some of the questions that were 25 being asked.
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Q Did all of the people in the emergency operations 2
Center have nuclear backgrounds?
g 3
A No, they did not.
A great many of them did.
But,*
4 of course, there were clerical people in there that had no 5
nuclear backgrounds and I guess it depends on your definition 6
of what a nuclear background is.
If you mean by that many years of experience with S
hand-on-operation of nuclear facilities and so forth, there k'
9 were a fair number of people that had that experience but to there were also other people who had no such practical.
11 experience but had educations in nuclear matters but had never 12 had any real hand-on experience.
V'
/
13 I say the persons ranged all over the place 14 typically of what you would find in almost any agency.
15 Q
When did the subject of evacuation come up?
16 A
It came up around 9 o' clock in the morning roughly.
l g
Q What was the substance of the discussions?
gg A
Well, it was kicked around the table and the management part of the Operations Center as to what should be 39 done.
29 Since the uncertainty factor raised its head 21 about these releases as I previously described the talk 22 centered to recommending a precautionary evacuation around the 43 i
i facility.
)
24 l
That all occurred around 9 o' clock in the morning 3
i Acme Reporting Company
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and pr ceeded until 9:15 or thereabouts, somet'.ing like t. hat lg 2
in any real sense and at that point in time certain people g 3
were saying in there, we think maybe we ought to recc= mend evacuation and people were nodding their heads.
It was 4
5 obvious to me that the senior management people in that Center 6
at that time were ccming to a meeting of the minds on recommending a precautionary evacuation and that led to my 8
inquiring of nem, do you want us to tell the State anything?
9 Whereupon, it was indicated to me by several of i
1 to them, yes, call the State and tell them that we recommend 11 evacuation.
12 O
Was there any attempt to confirm the 1.2 rem
/
13 figure at the site?
\\
14 A
I don't know if there was an attempt to confirm it is or not.
That measurement was made at the site so I don't know 16 who would be doing the confirming.
1; Do you mean people other than the ones who took the is reading?
i 19 Q
Was there any attempt to call the site and 20 determine where'.the emission was coming from or whether it 21 was planned or not?
22 A
Yes, indeed, there was an attempt to do that; 23 phone calls were being made.
Information was coming back.
24 Later we found out, I don't recall when, 9:30, 9:45, somewhere 25 around.10 o' clock that the reading was now 600 milliroentgens Acme Reporting Compony
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1 per hour. That it had changed or it was different, maybe the 9
2 original reading was wrong, I don't know, or the amount of 3
radioactive material that was escaping dropped off, but, yes; 4
there was an attempt to get more information on this reading.
5 Q
Did the attempts seem successful?
6 A
Not entirely.
Q Was dependable information coming back?
g A
No.
9 The situation with acquiring information didn't to seem to me to improve all that morning.
As a matter of fact, 11 it got worse.
It seemed'to degenerate.
12 Q
How do you mean?
13 A
Well, I saw no real improvement in the infobmation
(
14 acquisition and gathering system.
In other words, it would 15 seem to me that since more radiological things were happening 16 at the plant on Wednesday morning, more events were occuring.
1-Releases were going up, so forth and so on, that g
when compared to the activity of the day before when there 39 was some radioactive release but not of that order, it would seem that since more things were happening on g
31 Wednesday, more information ought to be coming in and yet 33 between the two days I didn't see any significant change in 23 the way information was coming in, so in that sense to my 34 mind one can say it got no better and may have deteriorated 73 slightly.
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This is ultimately what caused Mr. Harold Denton 2
to be sent up there about noon that day because information (
3 just wasn't coming out.
4 0
When they tried to call the site to acquire more 5
information about the 1.2 rem reading, just how would that 6
be done?
What would happen at the site?
How would that contact be made?
8 A
As I understand it, there was an NRC man in the 9
control room at least whose responsibility was to. stay.on 30 the phone or stay on a phone which had been established betweer the Center and the site, the Operation Center and the site.
11 12 A request would go from the Operation Center to i
the NRC man in the control room of the facility and then he 13 l
would have to ask someone,either a Metropolitan Edison person g4 or another NRC person or someone who was in the control room, 3
16 the Operation Center wants this or that, would they want to 3-know what we know about this or that, and sometimes it is my understanding, he would have to leave the telephone to go gg 39 find the information and then come back, find the individual, so I don't think it was the best of communications the way 3
3 it was set up.
That was my understanding of what was going on the 22 23 ther &nd of the line.
The person would get off the phone and come back on, 3
i 25 that bind of a thing.
So requests for information were funneled i
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that way.
2 Now, there were other links of communication.
Thj had a link of communication to the NRC's mobile van which is-3 a mobile radiological laboratory which was parked up near 4
the site.
They had communications with that facility.
There 5
6 were probably other communication links here and there.
Those were two of the main ones.
Q Harold Denton said at one point, " Sending people g
out to the site from the NRC was having them fall into a 9
morass.
You just never seem to hear from them again or 10 acquire reliable information from them."
11 Did that seem to be the sense on Friday morning?
12 A
Indeed, because that Friday morning is when
(
33 Mr. Denton made that statement.
I heard him say it with my 14 own ears.
15 Q
What was the circumstance on which he said it?
16 What were they tring to do at the time he said that?
g A
I think at that time he was talking to Chairman g
Hendry on the phone.
I think this is all recorded on tapes k'
19 f the telephone conversations in the Center.
20 This was a discussion between Mr. Denton and 33 Dr. Hendry, our Chairman, concerning what was going on in if the plant.
I don't recall precisely when that conversation, 23 that particular conversation, went on.
g It seems to me it was something in the neighborhood 25 Acme Reporting Company
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of about 11 o' clock in the morning, perhaps a little before.
2 3
Q As of Friday morning at the time the evacuation discussions were coming in and they were trying to confirm and 4
acquire more information about the 1.2 rem release, is it 5
fair to say that the NRC senior management people in the 6
Operation Center seemed to feel'that the people on the site.
really did not have a handle on what was going on inside the 8
reactor, Qhat the plant was doing -- the point that they were 9
n t completely in control of what was going on?
10 A
Yes, I think you asked me that question before, 33 maybe in a little different way.
12 I w uld say that das a fair characterization.
They
(
13 just weren't getting good information.
The management of 34 the NRC in that Center wasn't getting good information.
15 The more that situation persisted, the more nervous everybody 16 became about the thing.
g This is what ultimately led to Mr. Denton and jg Mr. Stello and a few other top technical people to be sent 39 to the site.
There were already people up there but as
.y Mr. Denton said, those we sent up there seemed to fall into
,3 this morass, and we never heard from them again.
3 I think that was probably a result of poor 23 communication.
It indicated to me the ccmmunication system 74 for the whole operation had essentially broken down.
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0 So that when the 1.2 ram reading came in at lg 2
9 o' clock there was that feeling in the operations Center e
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that maybe the right things weren't being done and there were
)
4 things occurring at the plant that were beyond the people's i
5 control and they had no way of ascertaining really what the 6
situation was at the plant?
A Yes, I could say that is a fair statement.
a Q
Could you describe the evacuation discussions?
9 As I understand it, you were involved in those discussions or to at least in the Operation Center at the time the discussion 11 took place between 9 o' clock and the time that you made the 12 call at 9:15.
/
13 Could you give us an idea of what those discussions 14 were?
15 A
Yes.
After I asked the NRC senior management in 16 there, what they wanted me to do with respect towthe State and I was informed to call the State and tell them that in g
ta the opinion of the people at that Center that evacuation was ig recommended around the facility.
There were some discussions as to distance, how 3
gi far out; numbers were kicked around, 5 miles, 10 miles, and so forth and so on.
I placed a call about 9:15, I think it gg 23 was, to Colonel Rehn Henderson who is the Director of the v'
24 Pennsylvania Emergency Management Agency in Harrisburg, 25 Pennsylvania.
I told Colonel Henderson.
I i
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71 I had asked him if he had heard about a 1,200 lg i
milliroentgen release and he said, yes, he had.
I said, 2
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"Had anyone told you to do anything," and he said, "No, not 3
yet."
And I said, "Well, in the opinion.of the NRC management 4
people that are in this Center right now, a recommendation of P'
5 k'
these people are that you should start evacuating people 6
around the facility."
I told him out 10 miles.
And he said p'.
he would start with 5 and I said, "That is fine.
That is your g
prerogative, but you should look to 10 miles as well," and 9
he accepted that recommendation.
to I told him that we.would get back to him with any 11 additional information and co forth.
That is the way that was 12 done.
So I transmitted the recommendation of the senior
[
13 management people to Colonel Henderson.
14 Q
Just prior to the senior management ask_ing you to 15 transmit the recommendation, who in the -- was it a general 16 consensus a precautionary evacuation or an evacuation of some 3
kind has to be taken of some kind undertaken or should be 3g recommended?
39 A
Yes.
A precautionary evacuation was what was 3
running through everybody's mind.
There was no question about 3
in my mind.
There was no question.
t/
Q The reason for that was the general uncertainty and 23 what was happening at the plant and the releases that were 3
taking place?
25 Acme Reporting Company
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A That is correct.
2 0
Werepeopleintheseniormanagementtalkingaboug 3
specific radii of evacuation?
Was there any discussion about that?
4 5
A Well, as I mentioned before, there were a lot of 6
numbers kicked around, 5 miles, 10 miles, and so forth and so on.
But there wasnt any really hard-core position on distances.
Just people mentioning numbers like 5 miles, 10 g
miles, that kind of thing.
g io Q
And the ultimate recommendation?
A It was 10.
Henderson said~he would start with 5.
g3 I think the reason he said he would start with 5 is he later 12 13 informed me he had evacuation plans prepared for 5 m,iles and he did not anticipate evacuations up to 10 miles when he 34 developed his emergency plan, but of course, later on he had 15 in place evacuation plans which were put together on an ad hoc 3g basis for 5, 10, 15, and 20 mile radii around the facility.
3 Q
Was there any discussion with Colonel Henderson 18 about the possibility of evacuating down the Plume or within 39 a particular quadrant?
g A
Yes, the recommendation that we gave him was in gg the direction of the Plume and I asked him if he knew where the y
Plume was going and he said he had been erroneously informed, l
23 as I recall, that the Plume was going down the Susquehanna 3
River.
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I He had since found out later that the plume was blowing in a ncrth to northeasterly direction and I remembenq 2
3 asking him, "Do you have any towns there?"
I said, "I think-4 you do."
He said, "Yes, we have a couple of towns," and he 5
named them:
Middletown, and some other place.
6 I said, "Well, that is where the plume is blowing.
Chen you say there are people in those towns?"
And he said, s
"Yes."
And they were within 5 miles.
9 Q
What did you do after you placed that call?
10 A
Well after I placed that call, later I got a call 11 from the Pennsylvania Bureau of Radiological Health.
Ms.
12 Margaret Riley and a nuclear engineer, a fellow by the name 13 of Dornsife, and they told me, they said they had heard about 14 this recommendation to the Pennsylvania Emergency Management 15 Agency and they wanted to know why it had been made and that 16 they had information that the release had stopped and that t-further the release level had dropped to 600 milliroentgens 18 per hour prior to stopping, and that there wasn't any need to 19 evacuate people at that time.
20 I told her that the conversation between myself and 21 Colonel Henderson was based on recommendations made by the 3
senior management people in the Center.
She became a little 23 bit upset with all of this, but I told her that was the way it was.
24 25 Q
Did anybody in the Operations Center talk about Acme Reporting Company e,,.,.a...
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i calling the overnor or calling the Co==issioners or anyone
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in particular when at that time the evacuation was decided 3
upon?
A Yes.
The business about calling the Governor and 4
calling the Commission, the NRC Commission, that all sort of 5
came after making the recommendations to the State of 6
Pennsylvania Emergency Management Agency.
There was some discussion about maybe we should 3
call the Commission and tell them now about this and there 9
was discussion, well, there was a phone call from Mr. Fouchard W" g
representative in Harrisburg, the NRC Office of Public Affairs u
representative in Harrisburg to his boss Mr. Fouchard in 33 the Center which indicated that the Governor was waiting for 33 the Chairman of the NRC to advise him as to what was going on g
and what should be done.
g And fouchard was pushing the Chairman on the phone t 16 to call the Governor and give him some information because the g
Governor was waiting to hear from Dr. Hendry.
Then there was g
a lot of discussion between Chairman Hendry and Mr. Denton and g
a 1 t of people on the phone and then ultimately a call was 20 placed to the Governor.
The way that call came out then the whole evacuation l recommendation got changed.
Henderson told me that he was still of a mind to evacuate people.
Of course, the Bureau of Radiological Health people didn't agree.
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The Governor who had to give the orders didn't 2
know what to do.
He wanted to hear from the Chairman and then
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the whole piece of business about the evacuation got changed 3
as a result of the Chairman's call to the Governor which I 4
understand was put in the vein of saying that if I had c preg-5 nant wife and children of pre-school age in that area of 6
5 miles, I think I would get them out of th,ere, And also I think there was a recommendation, I don't know who made that 8
recommendation, but there was a recommendation put out by 9
the Governor that everybody inside 10 miles stay inside in go shelter, stav ins :e their house, so I think it is important 13
~
that there never really was an order to evacuate anybody.
gg There were recommendations made from the NRC to
[.
13 the State and then the Governor making recommendations to 34 the people in the State in thos areas, the pregnant women g,5 and pre-school age children in 5 miles to recommend they get 16 out, and people inside of 10 miles take shelter.
3 These were always in the form or recommendations.
p/
ig As far as I know, there really were never any orders to this 39 effect.
20 Q
During the conversation with Margret Riley with 21 the State Bureau of Radiological Health, were she and Dornsife gg saying that there were no large releases off-site and that 23 there was no need for an evacuation during the phone call 34 with them?
25 l
Acme Reporting Company
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A I don't recall her saying that there weren't any 2
large releases off-site and to hear the term large is g
3 relativistic.
She was of the mind to say that the release 4
had stopped, that the 1,200 milliroentgens per hour reading 5
had turned into be a 600 mil 11 roentgen reading, half the 6
original value, but it was unclear to me whether that was because'the release was decaying off or whether someone had 8
misread an instrument and read it twice as high as what it 9
really was.
10 That is totally unclear and I don't know today 11 whether that has ever been straightened out.
12 Q
Was she saying no, evacuation wa:: necessary based
(
13 on the readings they had?
A That is what was indicated to me.
There was no 34 15 necessity to evacuate anybody around the facility.
16 Q
What did you do with that information after you 1;
hung up with her?
A I passed it onto the people in the operations ig Center.
I told them what she said and I think I got back to 19 20 her and essentially told her that that is the recommendation
)
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l 21 that was made to Henderson and his Agency was going to be the l
3 one to have to carry this thing out, and she would have to l
w rk her differences of opinion out with him.
23 Q
What Qas the reaction of the people in the operations 24 Center when you told them the persen frcm the Bureau of 25 Acme Repcrting Company
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78 1
Radiological Health had called and was opposed to the idea of lg 2
evacuation?
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3 A
I don't think there was any reaction.
I didn't detect any reaction.
It was just sort of a well, someone 4
5 called in and said we don't agree with that.
6 I don't think there was any reaction, much of a reaction at all.
It was just more people heard it and then 3
they went on to other things.
9 Q
After 10 o' clock, I take it that at 10 o' clock or shortly thereafter, it became clear in the Operation Center g
that the evacuation recommendation had been changed, that the 11 Governor had issued a take cover order or recommendation g
regarding evacuation?
(
g A
A selective evacuation.
9 Q
You are referring to the pregnant wcmen and 15 children?
16 A
- Yes, g
Q Okay.
When it became apparent the evacuation g
recommendation had been made. to the operation Center senior 39 management people had been changed at the Commission level, 20 what was the reaction in the operations Center?
21 Was it felt there had been a mistake made?
3 A
Well, to this day I think the recom=endation was a 23 sound recommendation at the time based on what was going on in 24 the Center and what we perceive to be and what little we 4i-d v'
3 Acme Reporting ~ Company
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know of what was going on at the plant.
I still think it lg 2
was a good recommendation.
g 3
O Let me follow thn; up.
During our interview you said this and let me read it to you.
You are summarizing 4
what you felt was the reason for the evacuation decision and 5
6 why you felt it was a' good decision both at the time and now and see if you agree with it today.
a You said, meaning the operation Center people, 9
"They were thinking this, and this tells me they were so uncertain in their minds as to what this really meant, and 30 the way things in general had been going up there for the 11 past two days, that they just felt that they would rather 12 recommend a protective meassure like evacuation than to sit
[
13
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around in the state in which they were sitting around, getting y
very poor information, and not knowing whether the people up 15 there at the site would do the right thing at the right time 16 and initiate evacuation on their own, or could even control what was happening at the plant at that point with respect to 18 radioactive releases.
General uncertainty caused them to 19 opt for recommending a precautionary evacuation."
20 Is that a fair summary of what led to that 2;
decision and the motivation behind reccmmending the 3
evacuation?
23 A
That is a fair summary and those are my own words.
34 0
When it became clear that that recommendation was 25 Acme Reporting Company
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changed the reaction in the Operation Center was what?
ig 2
A would you repeat that question again, please?
3 Q
When the evacuation recommendation that was made 4
to the State by the senior NRC management people was changed 5
at the Ccmmission level, could you describe what the reaction 6
was in the Operations Center?
A Well, I think the most significant reaction, as I 8
remember, came from Mr. Denton.
I remember Mr. Denton saying 9
to the Chaimnan that at that time that he made that recommenda-10 tion he was one of the management people that did make that 11 recommendation which led to the phone call that it seemed to b e
- 2 a good recommendation at the time based on the information
(
13 that he was privy to and that the rest of the people were 14 privy to.
15 Now what he thought later on in the morning as a 16 result of the Chairman's recommendation concerning what I t-call selective evacuation, that is pregnant women and pre-13 school children as opposed the evacuation of the entire 19 population, what he thought about that, I have no idea.
20 Q
That was not discussed in the Operations Center?
21 A
That was not discussed.
It just sort of all 22 happened.
In other words, the original recommendations all of a sudden turned into this selective evacuation routine 23 which incidentally Colonel Henderson of the Pennsylvania 24 Emergency Management Agency told me he didn't necessarily 25 Acme Reporting Company
81 ig 1
agree with that approach, because it is very difficult to 2
carry out a selective evacuation like that.
Knocking on e
9" 3
someone's door'in the house, there is a husband, a wife; the*
/
4 wife is pregnant; there are children ranging in ages from 5
pre-schoolers to teenagers; and like picture a policeman s
saying to the wife, "Are you pregnant?"
She says, "Yes."
"Well, you and the pre-school children leave the area," and 8
telling the husband and the other children to stay.
9 It is a little bit crazy in my mind.
I think to Henderson expressed that notion.
11 Q
After about 9:30 or 9:45 on Friday morning things 12 seemed to move up to the Commission level; is that a correct
(
13 understanding, at least ai far as the major decisions were concerned?
34 15 A
From about 10 o'clo'ck Friday morning around the is time of the whole evacuation scenario that was developing, 37 things did start to gravitate toward the Commission.
In is some sense in that the Chairman was now getting involved and ig the other Commissioners were getting involved and the thing 3
had escalated up to that level.
21 Q
Did this create any problems in your view?
22 A
In my view it did create a lot of problems because it is unclear to me how a collegial body of =en can effectively 23 24 act with respect to making recommendations concerning l
25 taking protective measures.
It is an unwieldy system.
That Acme Reporting Company
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is my view and I think that view is shared by many people in 2
the NRC now as a result of Three Mile Island.
('
3 I think it would have been far better to have one 4
officer of the Agency in high management position like 5
Mr. Gossick to be in charge of running those kinds of things.
6 It is difficult to manage an emergency with a hydra at the top.
8 It is far better if there is just one person i
l 9
=anaging the Agency.
That is my personal view.
I think it to is shared by other people.
I 11 0
So as of Friday morning the de' cision was made to 12 send Harold Denton to the site to centralize the information I
13 flow and to be sure that someone who knew what was going 14 on was'en-site and could report back to Bethesda?
15 And also whether or not it was a conscious is decision, a major decision-making processes began to shift t;
from the senior management Bethesda level to the Commission 18 level.
19 A
Yes.
Right.
m That is precisely what happened.
Everything just 21 sort of escalated up to the Commission level and Mr. Denton was sent there because communications were breaking down the k'
03 the information flow back to Bethesda was net good and they 24 wanted a very top senior competent technical person up there 25 that could ferret through the ma:e of information that was Acme Reporting Company
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i circulating around and lend so=e semblance of order to the 2
whole operation.
(
3 Q
So what you have been saying, as I understand it, 4
is that that process started even on Wednesday at the utility 5
level that when the accident started and began -- I guess 6
the point I am asking whether your making, is that the communications problem contributed to an escalation of the 6
management of the incident from the utility level to the g
Region 1 level'to the Bethesda level to the Commission 1evel 10 ultimately involving the President and the Governor of the State?
it A
Yes, that is precisely what happened.
And it all 12
(
stems fr'om the fact from the first day Metropolitan Edison, 33
\\
as far as I can see and as far as other people could see, 14 15 had totally lost its credibility by downplaying the 16 seriousness of the accident.
I think a lot of people in the g-public and in the NRC itself were confused.
16 It was that loss of credibility from Wednesday on 39 which kept deteriorating that gradually escalated the go management of the accident up higher and higher and higher until it inbolved the commission itself and sending Mr. Denton as gi the President's personal representative up to that place.
.;3 23 Q
But ecrly in the management of the incident "etropolitan Edison began to tell perhaps what it thought was 24 3
the real story but in any event a story that people didn't Acme Reporting Company aa,........
04 lg really believe and that lost its credibility over the period i
of time and that problem resulted in the NRC Region 1 people 2
\\
beginning to take a more active role in the management of 3
the incident because they were the only credibile source; 4
am I right?
5 A
Wil, I think that is a fair characterization that 6
naturally the Regional people were getting involved very 7
heavy right from the first day and I think their importance 8
increased as questions started to surface concerning the g
licensee's. ability to handle the thing on his own.
10 The involvement of the Region 1 people as can be 13 related and they were augmented by the staff in Bethesda 3;
and those people as Mr. Denton said " fell into the morass."
3,3 This thing was getting very big and a lot of people, communi-14 cations breaking down, and this ultimately led to him and a 15 staff of additional people going up there and taking command 16
'of the situation, so to speak, and at least being able to get 17 a good handle on what was going on up there and whether 33 the Metropolitan Edison people and tna other people involved 19 were doing the right things.
.,,0 Q
So that when the NRC Region 1 people.and the 3
staff augmenting Region 1 from Bethesda went out to the g
site and happened to fall into the morass as Mr. Denton descriced g
it, the feeling at the Operation Center was that the people 3
t in Bethesda had to somehow take control because of the 3
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19 uncertainty and they began to manage the accident as of 1
2 Friday morning?
(;
3 A
I think that is a fair characterization.
4 Q
Then once that happened it eventually got to the 5
point where the Commissioners themselves were involved in 6
the activity management of incidents?
A That is right.
You see, I think Governor Thornburg 8
could have acted on his own with respect to implementing g
protective measures.
to certainly, he had the authority.
He could have done 11 it on the advice of his Director in the Pennsylvania 12 Emergency Management Agency in almost any fashion he
/
33 chooses to do it, but for some reason or other he decided k'
that he wanted to hear from the Chairman of the NRC 14 15 personally as to what the Chairman thought should be done.
16 So in one sense the involvement of the Chairman t-and the other Commissioners in this thing was in part ig triggered off by Governor Thornburg wanting to hear from them.
At least, this is the way I saw it.
He wanted to 39 33 hear from the very top of the NRC, "What do you think we should do?"
gi 22 23 04 05
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1 I think that is the way the 5, hole thing went.
2 MR. HARVEY:
Thank you very much.
(;
3 (Whereupon at 12:35 o'cloc}. p.m.,
the deposition l
l 4
was concluded.)
l 1
5 l
1 6
I have read the foregoing I
r 7
pages 1 through 86, and they 8
are a true and accurate 9
record of my testimony therein to recorded.
M M M Y D W) 11
%cs'. trtMch 0-88 d w24. a. mm kaR v
_b4#
d 12 T
Harold Collins 13 14 Subscribed and sworn to before me 15 this day of 1979 16 17 Notary Public 18 My Commission Expires:_
j 19 20 21 22 23 24 25
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CERTIFICATE OF NOTARY PU3LIC I,
Linda Gumenick, th! CffiC!r D!for! Wh0C N!
3 i
foregoing deposition was takea, do herby certify tha: the witness whose testimony apnears in -he foregoing deposition 5
l was duly sworn by me; that the testimony of said witness was taken stenographically by me, and thereafter reduced j
to typewriting by me, or under my direction; that I am neither counsel for, related to, nor employed by any of 9
the parties to the action in which this deposition was taken; and further, that I am not a relative or employee of any attorney or counsel employed by the parties hereto; nor financially or'otherwise interestede in the outcome of the action.
14 15 16 W
%* t/
. v/n mu c u Mib 17 Notary Public 19 20 21 My Commission expires; July 1, 1982 l
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