ML20066H926
| ML20066H926 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/17/1982 |
| From: | Radford E PITTSBURGH, UNIV. OF, PITTSBURGH, PA, SUFFOLK COUNTY, NY |
| To: | |
| Shared Package | |
| ML20066H850 | List: |
| References | |
| ISSUANCES-OL, NUDOCS 8211230396 | |
| Download: ML20066H926 (35) | |
Text
d ATTACHMENT 3 e
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board I
In the Matter of
)
Docket No. 50-322-OL
}
LONG ISLAND LIGHTING COMPANY
}
(Emergency Planning -
I (Shoreham Nuclear Power Station, Phase I)
Unit 1)
AFFIDAVIT OF EDWARD P.
RADFORD, M.D.
)
State of New York I
)
to wit:
County of Suffolk My name is Edward P.
Radford.
I am a Professor of Environmental Epidemiology and Director of the Center for Environmental Epidemiology at the University of Pittsburgh.
As an M.D. and an expert on the human health effects of ionizing radiation, I am presently serving Suffolk County, New York, as a consultant in its ongoing emergency planning efforts connected with the Shoreham Nuclear Power Station.
It is my understanding that Mr. Andrew Kanen of PRC Voorhees of McLean, Virginia has testified that ambulance travel from the Shoreham site to Central Suffolk Hospital may be delayed by as much as one hour above the normal travel time for that trip.
It is my opinion that such a delay, in some cases, could have an adverse impact, upon a contaminated injured individual being transported from the Shoreham site to Central Suffolk Hospital.
The impact could be most extreme on those requiring immediate treatment for traumatic injuries which can be life-threatening
~ 8211230396 821119 PDR ADOCK 05000322 g
=
o o if not dealt with promptly.
In addition delay of decontamination of radioactive contamination could greatly increase the radiation exposure of such injured person, with the possibilities of immediate or delayed effects of radiation thereby greatly increased.
I%' 17,198v
]hrb) i
'u) rw
~
Date Nafne Subscribed and sworn to before me on the
/2 day of
/ffh i&
Notary Pg5ilic f
DOHOTHY MANNese NOTARY Pueuc, stees or newyet W"
i 52 4819712 0 E34*se March 30,18 l
I l
l
1 ATTACHMENT 4
UtilTED STATES OF AMERICA f4UCLEAR REGULATORY COMMISSION (ATOMIC SAFETY AND LICENSING BOARD)
BEFORE ADMINISTRATIVE JUDGES:
LAWRENCE BRENNER, CHAIRMAN DR. JAMES H.
CARPENTER DR. PETER A. tt0RRIS IN THE MATTER OF L0t4G ISLAND LIGHTING C0ttPANY
- DOCKET NO.e50-322-OL (SriCREHAtt NUCLEAR POWER S TATION
- (EMERGENCY PLANNING)
UNIT 1)
WASHINGTON, D.
C.,
FRIDAY, AUGUST 13, 1982.
DEPOSI TION OF NICHOLAS J.
DI MASCIO, A WITNESS, CALLED FOR EXAMINATION BY COUNSEL FOR THE INTERVENOR COUNTY OF SUFFOLK, AT THE OFFICES OF KIRKPATRICK, LOCKHART, HILL; CHRISTOPHER & PHILLIPS, 1900 M STREET, N. W.,
WASHINGTON, D.
C.,
BEGINNING AT 9:50 0' CLOCK A.M.,
BEFORE HILMAR K.
- KLAMANS, JR.,
A NOTARY PUBLIC IN AND FOR THE DISTRICT OF COLUMBIA, WHEN WERE PRESENT ON DEHALF OF THE RESPECTIVE PARTIES:
FRIEDLI, WOLFF & PASTORE, INC.
1735 EYE STREET. N.W. SUITE #811 f
WASHINGTON, D.C.
20006 PHONES: 331-1981 331 1982
93
)
1 MR. SEDKY:
SURE.
2 (BRIEP RECESS.)
3 BY MR. SEDKY:
~
4 Q
MR. DI MASCIO, WE WERE TALKING ABOUT YOUR COMMUNTCATIONE' 5
WITH MR. SEARS AFidR THE SUBMISSIO'1 OF REV 2.
DO YO'U RECALL 6
THAT?
7 A
YES.
8 y
THAT IS WHAT WE WERE TALKING ABOUT.
THERE WAS MORE I
THAN ONE BUT FEWER THAN TEN, I GATHER, OF THOSE COMMUNICATIONS; 10 IS THAT RIGHT?
..{.
II A.
THAT'S CORRECT.
I2 Q
WHAT SUBJECTS WERE DISCUSSED IN THOSE CONVERSATIONS I3 WITH MR. SEARS?
I4 A
WE DISCUSSED THE SER OPEN ITEMS.
15 Q
ALL 60'OF THEM?
16,
A NOT ALL 60 OF THEM, NO.
Q WHICH ONES DID YOU DISCUSS?
A WE HAVE DISCUSSED SEVERAL.
I DON'T REMEMBER ALL THE ONES THAT WE HAVE DISCUSSED.
Q TELL ME ABOUT THE ONES YOU DO REMEMBER.
A WE HAVE D'ISCUSSED TABLE B-1.
N Q
WHAT ELSE?
94 t
)
1 A
WE HAVE ALSO DISCUSSED SOME OF THE INITI ATING CONDITIC NS.
2 Q
ALL RIGHT.
WHAT ELSE?
3 A
'WE DISCUSSED THE SER OPEN ITEM ON -- I DON' T KNOW EXAC TLY 4
HOW IT IS WORDED, BUT IT DEALS WITH COMMUNICATION LINKS BETWEEN 5
AMBULANCE AND. UT ILITY..
6 Q
ANYTHING ELSE?
7 A
WE DISCUSSED MORE, BUT THAT IS ALL I CAN REMEMBER 8
RIGHT NOW.
9 Q
HAVE YOU EXHAUSTED YOUR PRESENT RECOLLECTION AS 10 TO THE SUBJECTS YOU DISCUSSED WITH MR. SEARS?
II A
GIVEN MORE TIME, I COULD PROBABLY THINK OF MORE.
12 Q
MAYBE WE WILL COME BACK TO THAT LATER THIS AFTERNOON 13 AND SEE IF OUR ONGOING EXAMINATION REFRESHES YOUR RECOLLECTION.
I ON TABLE B-1, WHAT WAS THE TOPIC UNDER DISCUSSION THERE?
15 MR. DI MASCIO, BEFORE YOU RESPOND TO THAT, I JUST WANT TO 16 ESTABLISH A COUPLE OF THINGS.
WERE THESE DISCUSSIONS BETWEEN I7 JUST YOU AND MR. SEARS OR WERE THERE OTHER PEOPLE INVOLVED 18 IN THESE CONVERSATIONS?
II A
IT WAS A TELEPHONE CALL BETWEEN MR. SEARS AND MYSELF.
O Q
WAS IT ONE TELEPHONE CALL YOU ARE RECALLI'NG RIGHT I
NOW?
22 A
SPECIFICALLY ON TABLE B-1 AS YOU ASKED ME?
- 95
)
1 Q
NO.
BEFORE WE GET TO THAT IN TERMS OF B-1,
' WANT 2
TO GET WHETHER IN YOUR EARLI R RESPONSE WHEN YOU SAID "WE" 3
DISCUSSED, "WE" DISCUSSED, "WE" DISCUSSED AND YOU IDENTIFIED 4
THREE AREAS,. THE "WE" YOU ARE REFERR'ING TO, WAS THAT YOU AND 5
MR. SEARS ONLY OR YOU ND MR. SEARS AND SOMEBODY ELSE ON THE 6
NRC STAFF?
7 A
MR. SEARS AND MYSELF.
8 Q
ALONE, CORRECT, ON THE TELEPHONE?
9 A
YES.
10 Q
ANYBODY ON YO,UR END, OTHER THAN YOU, ON A SPEAKERPHONE:
3,.
~k; 13 OR EXTENSION LINE?
I2 A
NO.
I3 Q
TO YOUR KNOWLEDGE, WAS ANYBODY ELSE ON HI'S END?
A NOT TO MY KNOWLEDGE.
15 Q
DID YOU TAKE NOTES OF THESE CONVERSATIONS?
16 A
SOME OF THEM I DID.
Q DO YOU STILL HAVE THOSE NOTES?
A I BELIEVE I DO.
Q ARE THEY IN THE PERSONAL FILE YOU REFERRED TO?
A THEY PROBABLY WOULD BE IN THERE.
~
Q LET'S GO BACK TO TABLE B-1.
WHAT WAS THE SUBSTANCE OF THE DISCUSSION CONCERNING THAT MATTER?
.96 I
A THE DISCUSSION CENTERED AROUND MORE OF A GENERIC
)
2 PHILOSOPHY ABOUT 30-MINUTE STAFFING REQUIREMENTS.
3 MR. SEDKY:
READ THE ANSWER BACK.
4 (THE ANSWER WAS READ BY THE REPORTER.)
5 BY MR. SEDKY:
6 Q
WHAT DO YOU MEAN BY THE PHRASE " GENERIC PHILOSOPHY"?
7 A
THERE ARE DIFFERENT INTERPRETATIONS THAT CAN BE 8
DERIVED FROM TABLE B-1 REQUIREMENTS AND OUR DISCUSSION CENTERED 9
ON TRYING TO CLARIFY AND GET NRC'S POSITION ON TABLE B-1.
10 Q
IN YOUR LAST ANSWER, ARE YOU INTENDING TO LIMIT
.. c 11 YOURSELF TO THE 30-MINUTE STAFFING REQUIREMENTS OR GENERALLY 12 B-1?
13 A
WE MAY HAVE MENTIONED THE ENTIRE B-1 BUT IT CENTERED 14 SPECIFICALL'Y, I WOULD SAY, ON 30 MINUTES.
15 Q
WHEN YOU ARE REFERRING TO TABLE B-1, MR. DI MASCIO, 16 YOU ARE TALKING ABOUT TABLE B-1 IN NUREG-0654; IS THAT CORRECT?
I7 A
THAT'S CORRECT.
Q THE TABLE IN THE PLAN IS TABLE 5-1; IS THAT CORRECT?'
18 19 A
I AM NOT SURE OF THE EXACT TABLE IN THE PLAN.
20 MR. SEDKY:
LET ME HAVE MARKED FOR IDENTIFICATION AS DI MASCIO EXHIBIT 2 A DOCUMENT ENTITLED " MINIMUM STAFFING 2I l(
REQUIREMENTS FOR NRC LICENSEES FOR NUCLEAR POWER PLANT 22
- 97 1
EMERGENCIES," A TWO-PAGE DOCUMENT.
)
2
'CTHE DOCUMENT REFERRED TO WAS MARKED DI MASCIO DEPOSITION EXHIB]T 3
NO. 2 FOR IDENTIFICATION AND IS ATTACHED TO THE COURT COPY OF THIE 4
DEPOSI' TION.}
5 BY MR. SEDKYi 6
Q ARE YOU ABLE TO IDENTIFY DI MASCIO EXHIBIT 2 FOR 7
IDENTIFICATION?
8 A
IT LOOKS LIKE THE TABLE FROM THE EMERGENCY PLAN, 9
YES.
10 Q
THIS IS THE TABLE, IS IT NOT, THAT IS SUPPOSED TO
(
Il CONFORM TO TABLE B-1 IN NUREG-0654?
IS THAT CORRECT?
12 A
YES.
13 Q
GET. TING BACK TO YOUR CONVERSATION WITH MR. SEARS I4 ON TABLE B-1, LET ME ASK YOU PRELIMINARILY WHO INITIATED THAT 15 CONVERSATION. DID YOU CALL HIM OR DID HE CALL YOU?
16 A
I BELIEVE THAT WAS WITH HIM, I7 i
Q WHAT DID HE SAY TO YOU IN THAT CONVERSATION?
18 A
I DON'T REMEMBER THE PRECISE CONVERSATION.
I' Q
WHAT INFORMATION DID HE CONVEY TO YOU IRRESPECTIVE OF EXACTLY WHAT HE SAID?
21 A
THE RESULT OF WHAT HE SAID WAS THAT OUR TABLE AS 22 PRESENTED DID NOT DIRECTLY MEET NUREG-0654 REQUIREMENTS.
Q DID HE INDICATE TO YOU IN WHAT MANNER IT DID NOT
{
98
(
)
1 MEET THE REQUIREMENTS?
2 A
THE FACT THAT THE 30-MINUTE REQUIREMENTS WERE NOT 3
MET.'
4 Q
BY LO,0 KING AT DI MASCIO EXHIBIT NO. 2 FOR IDENTIFI-5 CATION, ARE YOU ABLE TO IDENTIFY IN WHAT WAY THE 30-MINUTE 6
REQUIREMENTS WERE~NOT MET?
7 A
YES.
8 Q
WOULD YOU TELL US ABOUT THAT.
9 MR. RUDLIN:
WHAT IS THE QUESTION THAT YOU HAVE PENDING?
10 YOU ARE ASKING THE WITNESS TO COMPARE EXHIBIT 2 TO THE REQUIRE-
,k-Il MENTS CONTAINED IN TABLE B-1 IN NUREG-0654?
s.
12 MR. SEDKY:
AS I UNDERSTOOD HIS TESTIMONY, AND PERHAPS 13 I MISUNDERSTOOD HIM, HE WAS ADVISED BY MR. SEARS THAT DI MASCIO I4' EXHIBIT 2 DID NOT COMPLY WITH NUREG-0654 AND I ASKED HIM IN 15 WHAT FA'SHION AND HE SAID IT DID NOT MEET THE 30-MINUTE REQUIRE-16 MENTS AND I AM ASKING HIM TO EXPLAIN TO ME, IN EFFECT, HOW I7 IT FAILED TO COMPLY.
18 BY MR. SEDKY:
Q DO YOU UNDERSTAND THE QUESTION, MR. DI MASCIO?
A ARE YOU ASKING ME FOR MR. SEARS' INTERPRETATION 2I dF WHY IT DID NOT COMPLY?
22 Q
WHATEVER HE EXPLAINED TO YOU.
ARE YOU WAITING FOR
99
(
)
1 A QUESTION OR AM I WAITING FOR AN ANSWER?
2 A
I BELIEVE YOU ARE WAITING FOR AN ANSWER.
3 Q
OKAY.
4 A
I AM,STILL NOT CLEAR ON EXACTLY WHAT I AM ANSWERING.
5 Q
I BELIEVE WE'HAVE ESTABLISHED, AND I AM NOT TRYING 6
TO TESTIFY FOR YOU, THAT HE CALLED YOU AND TOLD YOU THAT IN 7
HIS VIEW DI MASCIO EXHIBIT NO. 2 FOR IDENTIFICATION DID NOT 8
COMPLY WITH THE REQUIREMENTS OF NUREG-0654; IS THAT CORRECT?
9 A
THAT WAS THE SUMMA.T. ION OF THE CONVERSATION, WHETHER 10 OR NOT THOSE WERE HIS EXACT WORDS.
(. ;
\\'.'
II Q
I UNDERSTAND THAT.
I AM NOT TRYING TO GET HIS EXACT 12 WORDS.
THE NEXT QUESTION TO YOU WAS IN WHAT WAY DID HE BELIEVE 13 THAT IT DID NOT COMPLY 'AND I BELIEVE YOUR ANSWER WAS THAT IT I4 DIDN'T COMPLY BECAUSE OF THE 30-MINUTE REQUIREMENTS OR WORDS 15 TO-THAT EFFECT; IS THAT CORRECT'?
I 16 A
WORDS TO THAT EFFECT, YES.
II Q
IN WHAT MANNER, TO YOUR UNDERSTANDING,_DOES DI MASCIO 18 EXHIBIT NO. 2 NOT COMPLY WITH THE 30-MINUTE REQUIREMENTS AS II PERCEIVED BY THE NRC STAFF?
MR. RUDLIN:
THE QU'ESTION AS YOU JUST PHRASED IT IS THE 21 l
ONE THAT I RESPONDED TO EARLIER BECAUSE I WAS NOT CLEAR WHAT 22 YOU WERE ASKING. LET ME EXPLAIN.
YOUR QUESTION AS JUST RECENTLY l
l
100
(
h 1
PHRASED SEEMS TO ASK THE WITNESS TO COMPARE EXHIBIT 2 TO 2
NUREG-0654 AND DETERMINE WHERE THERE MAY BE DEVIATIONS IN 3
THE REQUIREMENTS.
4 MR. SEDKY-THAT IS NOT MY QUESTION.
5 MR. RUDLIN:
THE QUESTION, I THINK, AND WHAT MA,Y BE CONFUSIbG 6
THE WITNESS, ASSUMES A PREMIGE, AND THAT IS THAT DURING THE 7
TELEPHONE CONVERSATION M'R.
SEARS EXPLAINED IN DETA'L WHERE 8
THERE WERE 30-MINUTE REQUIREMENTS.
9 MR. SEDKY:
THAT IS FINE.
I THINK YOUR OBSERVATION IS 10 WELL TAKEN.
s BY MR. SEDKY:
I Q
WAS THERE ANY DISCUSSION BETWEEN YOU AND MR. SEARS 13 AS TO IN WHAT MANNER DI MASCIO EXHIBIT NO. 2 FOR IDENTIFICATION FAILED TO COMPLY WITH THE 30 MINUTE REQUIREMENTS?
A DO YOU MEAN DID HE EXPLAIN TO ME THE SPECIFIC REASON 0
IS THAT WHAT YOU ARE ASKING?
Q i iM NOT SURE THAT I WANT TO BE SO SPECIFIC THAT 18 4FR THE QUEST ION.
I DON'T WANT YOU TO SAY "WELL, YOU (At
^
HE DIDN'T USE THOSE WORDS.'
WHAT I AM TRYING TO FIND OUT h
20 IS DID YOU HAVE AN UNDERSTANDING FROM WHATEVER HE TOLD YOU 21 l
AS TO IN WHAT WAY HE ME ANT YOU HAD FAILED TO MEET THE 30-l.4 b
22 MINUTE REQUIREMENTS.
MR. DI MASCIO, YOU SEEM TO BE HAVING l
a'
~
- 101 t
')
1 A HARD TIME ANSWERING MY QUESTION. YOU HAVE BEEN SITTING SILENTLY 2
FOR SEVERAL MINUTES.
DID YO HAVE ANY UNDERSTANDING AS TO 3
WHAT HE MEANT WHEN HE SAID YOU FAILED TO MEET THE 30-MINUTE 4
REQUIREMENTS?
5 A
I GUESS THE PROBLEM IS IT IS SIMPLE.
6 Q
IF IT IS SIMPLE, JUST TELL ME HOW IT IS SIMPLE AND 7
WHAT IS IT.
8 A
IT WAS MY UNDERSTANDING THAT TABLE B-1 REQUIRES 9
CERTAIN, INDIVIDUALS WITHIN 30 MINUTES AND THIS TABLE SHOWS 10 THOSE PERSONNEL WITHIN 60 MINUTES.
ij Q
BY REFERENCE TO DI MASCIO NO. 2 FOR IDENTIFICATION,
~'-
12 WHEN YOU TALKED ABOUT "SHOWS THOSE PERSONNEL WITHIN 60 MINUTES,
13 IS THERE A COLUMN THERE THAT YOU CAN REFER TO?
I#
A TABLE B-1 REQUIREMENTS WOULD BE THE THIRD COLUMN.
15 NOT THE THIRD.
THE ONE ENTITLED "30 MIN."
16 Q
WAS THE GIST OF MR. SEARS' COMMENT THAT THE PEOPLE UNDER "LILCO 60 MIN." SHOULD BE AVAILABLE WITHIN 30 MINUTES?
IS THAT THE GIST OF HIS COMMENT TO YOU?
19 A
MY UNDERSTANDING OF HIS CONCERN IS.THAT WE DID NOT h
20 SPECIFY SUFFICIENT PERSONNEL TO BE THERE WITHIN 30 MINUTES.
(
Q IF THAT IS AS COMPLETELY AS YOU CAN ANSWER, WE WILL JUST HAVE TO GO THROUGH THIS ITEM BY ITEM AND IT MAY TAKE A WHILE.
WHY DON'T WE TRY TO DO THAT.
LET'S LOOK NOW
.102
)
1 AT THE FIRST LINE.
'IT SAYS " PLANT OPERATIONS AND ASSESSMENT 2
OF OPERATIONAL ASPECTS."
00'YOU SEE THAT?
3 A
YES, I DO.
4 Q
THEN,THERE ARE A NUMBER OF DESCRIPTIONS OF INDIVIDUALS S
IN THE MAJOR COLUMN; IS THAT CORRECT?
6 A
THERE IS A LIST OF --
7 Q
DESCRIPTIONS OF POSITIONS.
DO YOU SEE THAT?
8 A
YES, I DO.
9 Q
DO YOU SEE " SHIFT SUPERVISOR (SRO)"?
10 A
I DO.
2T Il Q
THE NEXT COLUMN SAYS "ON SHIFT" WITH AN ASTERISK; 12 RIGHT?
13 A
YES, IT DOES.
I4 Q
WHAT DOES THAT COLUMN REPRESENT?
15 A'
THOSE WOULD BE THE PERSONNEL REQUIRED FOR TABLE 16 j
B-1 TO BE ON SHIFT.
I7 Q
THE NEXT COLUMN SAYS "LILCO ON SHIFT. ".WHAT DOES 18 THAT COLUMN REPRESENT?
II A
THOSE ARE THE PERSONNEL THAT LILCO HAS COMMITTED 20 TO BE ON SHIFT.
21 Q
THE NEXT COLUMN SAYS " 3 0 M I N. '.' ; CORRECT?
f.
22 A
CORRECT.
I
- 103 s.
)
1 Q
IS THAT A TABLE B-1 REQUIREMENT?
2 A
THAT IS A TABLE B-i REQUIREMENT.
3 Q
THE NEXT COLUMN IS "60 MIN."; CORRECT?
4 A
CORR EC T.
5 Q
IS THAT ALSO'A TABLE B-1 REQUIREMENT?
6 A
THAT IS A TABLE B-1 REQUIREMENT.
7 Q
THE FINAL COLUMN SAYS "LILCO 60 MIN."; CORRECT?
8 A
THAT IS CORRECT.
9 Q
THAT.IS THE NUMBER OF PERSONS THAT LILCO WOULD AUGMENT 10 WITHIN 60 MINUTES; IS THAT CORRECT?
(}'.
II A
THAT IS A COMMITMENT OF LILCO PERSONNEL WITHIN 60 12 MINUTES.
13 Q
SO AS I READ THIS TABLE, LOOKING ONLY AT THE LILCO I#
COMMITMENT, YOU COMMITTED TO HAVE -- LET'S TAKE ONE WHERE 15 THERE ARE SOME REAL NUMBERS.
DO YOU SEE ACROSS FROM THE TERM 16 "HP TECHNICIANS"? DO YOU SEE THAT?
II A
I SEE IT.
8 Q
LILCO COMMITS TO HAVE ONE LILCO PERSON ON SHIFT; IS THAT CORRECT?
0 A
THAT IS CORRECT.
I Q
THEN WITHIN 60 MINUTES LILCO COMMITS TO HAVE TWO 22 PERSONS; IS THAT CORRECT?
I
1,04 1
A THAT IS CORRECT.
)
2 Q
JUST FOR MY EDUCATION, IS THAT TWO ADDITIONAL PERSONS 3
OR ONE ADDITIONAL PERSON?
4 A
THAT,WOULD DE TWO ADDI TI ONAL PERSONNEL.
5 Q
IN ADDITION.TO THE ONE THAT IS ALREADY ON SHIFT; IS 6
THAT CORRECT?
7 A
THAT IS CORRECT.
8 Q
IS IT A' FAIR
SUMMARY
CF MR. SEARS' CONCERN THAT YOU 9
sit 1 PLY HAD NOTHING WITHIN 30 MINUTES?
IS THAT RIGHT?
10 A
I UNDERSTAND THAT TO BE HIS CONCERN.
'( :.
'*f 11 Q
THAT IS ALL I AM GETTING AT.
FOR EXAMPLE, AS HE 12 READS TABLE D-1, IF YOU LOOK AT "HP TECHNICI ANS" AT THE BOTTOM --
13 DO YOU SEE THAT ACROSS FROM " RADIATION PROTECTION"?
AS HE 14' READS'B-1, THERE HOULD BE TWO ON SHIFT AND THE CAPABILITY OF 15 ADDING TWO fiORE WITHIN 30 MINUTES; IS THAT CORRECT?
16 A
I DON'T KNOW HOW HE INTERPRETS B-1.
I7 Q
CONSISTENT WITH HIS COMt1ENT TO YOU, ISN'T IT FAIR TO 18 SAY THAT THAT IS HOW HE WOULD READ B-1?
19 A
NO, IT IS NOT.
20 Q
IT ISN'T.
ALL RIGHT, HOW DO YOU RE'AD B-l?
21 A
FOR THAT SPECIFIC EXAMPLE THAT YOU JUST GAVE ME?
22 Q
RIGHT.
A I READ TABLE B-1 FOR HP TECHNICIANS AT THE BOTTOft i
i i
.105
(
)
1 AS A 2 WITH A DOUBLE ASTERISK, INDICATING THAT THE FUNCTION 2
OF THOSE TWO INDIVIDUALS MAY ~ BE PERFORMED BY ANY TWO OTHER 3
INDIVIDUALS ON SHIFT.
4 Q
THAT,IS GOING TO ADD AN EL'EMENT OF CONFUSION.
LET'S S
TAKE A SIMPLER CASE.
LET'S TAKE THE SIMPLE CASE OF "OFFSITE 6
SURVEYS."
DO YOU SEE THAT?
7 A
YES.
8 Q
B-1 DOES NOT REQUIRE ANYBODY ON SHIFT; IS THAT CORRECT?
9 A
THAT IS CORRECT.
10 Q
AS MR. SEARS WOULD READ B-1, YOU WOULD BE REQUIRED II TO HAVE EITHER TWO PERSONS OR SURVEYS, DEPENDING UPON HOW 12 YOU READ IT, WITHIN 30 MINUTES; IS THAT CORRECT?
~
13 A
THAT IS MY UN.DERSTANDING OF HOW HE WOULD READ IT.
I4 Q
I UNDERSTAND THAT.
15 A
OKAY.
16 Q
I AM NOT TRYING TO GET YOU TO COMMIT THAT HE IS 17 READING IT CORRECTLY.
THE LILCO PLAN PROVIDES FOR EITHER 18 FOUR SURVEYS OR INDIVIDUALS WITHIN 60 MINUTES; IS THAT CORRECT?
I9 A
THAT IS CORRECT.
0
~NO PROVISION Q
IT CONTAINS, AT LEAST ON THE FACE OF I T, I
FOR OUTSIDE' SURVEYS WITHIN 30 MINUTES; IS THAT CORRECT?
22 A
IT DOES NOT CONTAIN A COMMITMENT WITHIN 30 MINUTES.
- 106 i
V 1
Q JUST IN
SUMMARY
THEN, IS IT FAIR TO SAY'THAT THE g
2 GIST OF MR. SEARS' COMMENT WAS THAT LILCO DIDN'T COMMIT TO 3
ANY AUGMENTATION WITHIN 30 MINUTES?
4 A
I BELIEVE THAT TO BE A CORRECT
SUMMARY
5 Q
DO YOU RECALL ANY OTHER DISCUSSION WITH MR. SEARS 6
ABOUT TABLE B-1?
7 A
NOT AT THIS TTME.
8 Q
STILL STICKING WITH B-1, WHAT DID YOU HAVE TO SAY 9
TO MR. SEARS ON THAT SUBJECT DURING THESE CONVERSATIONS OR 10 THAT CONVERSATION?
11 A
MY PROBLEM CAME WITH THE INTERPRETATION OF THE 30 12 MINUTES.
WHAT I WAS TRYING TO ASCERTAIN WAS WHEN THE 30 MINUTES 13 OR WHEN THE CLOCK STARTED AND WHAT SEQUENCE.
14 Q
WHAT DID HE SAY ABOUT THAT?
15 A'
I DO NOT RECOLLECT WHAT THE OUTCOME OF THAT WAS.
16 Q
WHAT DID YOU TELL HIM ABOUT THAT?
17 A
MY POINT OF CLARIFICATION WAS WHETHER OR NOT 30 18 MINUTES WAS AT THE DECLARATION OF THE EMERGENCY OR UPON ACTUAL'd I9 CALLING OF A PERSON.
20 Q
WAS THE POSITION YOU TOOK THAT IF IT'IS 30 MINUTES 2I FROM THE TIME YOU CALL THE INDIVIDUAL, THEN THE 60 MINUTES 22 AUGMENTATION YOU HAVE IS SUFFICIENT?
107
(
)
1 A
IF IT --
2 Q
THAT THE TIME BEGISS TO RUN FROM THE TIME YOU CALL 3
THE INDIVIUDAL.
WE ARE TALKING NOW ABOUT AUGMENTING ON SHIFT 4
PERSONNEL; ISN',T THAT CORRECT?
5 A
YES.
6 Q
WAS THE POINT YOU WERE TRYING TO MAKE THAT IF 30 7
MINUTES BEGINS TO RUN FROM THE TIME YOU CALL THE INDIVIDUAL 8
WHO IS TO AUGMENT THE SHIFT, THEN YOUR COLUMN LABELED "60 9
MIN.,"
I,N EFFECT, IS 30 MINUTES FROM WHEN THAT PERSON IS CALLED?
10 WAS THAT THE POINT YOU WERE TRYING TO MAKE?
77' b7:
11 A
I AM STILL CONFUSED WITH YOUR QUESTION.
12 Q
OKAY.
ASSUME THAT THE DECLARATION OF THE EMERGENCY.
13 IS TIME ZERO AND YOU CALL THE INDIVIDUAL'30 MINUTES THERAFTER.
14 ALL-RIGHT?
THEN THE PERSON REPORTS WITHIN 30 MINUTES OF YOUR 15 CALL.
WAS THAT THE POINT YOU WERE TRYING TO MAKE WITH HIM?
16 IN OTHER WORDS, IT WOULD BE A 30-MINUTE RESPONSE BUT WITHIN I7 60 MINUTES OF THE DECLARATION OF THE EMERGENCY?
18 A
NO.
I9 Q
HOW IN YOUR MIND DID THE QUESTION OF WHEN THE CLOCK 20 STARTED AFFECT WHETHER OR NOT YOU COMPLIED WITH TABLE B-l?
21 A
y WAS ONLY SEEKING FROM HIM AN INTERPRETATION AS
(
22 TO WHEN THE CLOCK STARTED.
THAT'S ALL.
1 I
i
108 i.
)
1 Q
BUT THE TEXT OF NUREG-0654 SAYS ON ITS FACE THAT 2
THE AUGMENTATION TIME IS FROM THE DECLARATION OF THE EMERGENCY; 3
ISN'T THAT RIGHT?
4 A
I WOULD HAVE TO READ THAT.
5 Q
LET ME SHOW IT TO YOU.
ON PAGE 35, I WILL JUST 6
QUOTE FROM IT AND SHOW IT TO YOU, IT SAYS "THE LICENSEE MUST 7
BE ABLE.TO AUGMENT ON SH'IFT CAPABILITIES WITHIN A SHORT PERIOD 8
AFTER DECLARATION OF AN EMERGENCY."
LATER ON IT SAYS "ANY 9
DEFICIENCIES IN THE OTHER STAFFING REQUIREMENTS OF TABLE B-1 10 MUST,BE CAPABLE OF AUGMENTATION WITHIN 30 MINUTES BY SEPTEMBER II 1,
1981."
LET ME SHOW YOU THAT LANGUAGE AND SEE IF THAT I2 HELPS YOU.
13 MR. DI MASC'IO, HAVE YOU HAD AN OPPORTUNITY TO READ THE N
PROVISION OF NUREG-0654 DEALING WITH THE AUGMENTATION WE WERE I
15 DISCUSSING?
16 A
YES, I HAVE.
I7 Q
IN LIGHT OF WHAT IT SAYS, DOES THAT ASS.IST YOU IN ANSWERING MY QUESTION, WHICH IS WHETHER OR NOT THE REGULATION IS FAIRLY CLEAR THAT IT IS THE DECLARATION OF AN EMERGENCY THAT STARTS THE CLOCK RUNNING?
21 A
I STILL SEE MY QUESTION OF AN INTERPRETATION AS 22 WHEN THE CLOCK STARTS TO BE ONE THAT IS VALID.
Q I GUESS WHAT IS BOTHERING ME A LITTLE BIT IS THAT
109
(
)
1 IF YOUR INTERPRETATION IS ACCURATE, ARE YOU SAYING THAT IN 2
YOUR TABLE 5-1, WHICH IS DI AASCIO EXHIBIT'NO. 2 FOR IDENTIFI.
3 CATION, THAT THE 60-MINUTE AUGMENTATION IS 60 MINUTES FROM 4
THE TIME THE. PERSON IS CALLED?
5 A
I AM TRYING TO SEEK INTERPRETATION.
6 Q
AS IT IS PRESENTLY SET FORTH, IN OTHER WORDS, WHEN 7
YOU SAY IN DI MASCIO NO. 2 THAT AN ADDITIONAL -- WHICH IS 8
THE ONE WE TALKED ABOUT BEFORE?
AN ADDITIONAL HP TECHNICIAN, 9
NOT THE ONE WITH THE ASTERISK'BUT THE OTHER ONE.
AN ADDITIONAL 10 TWO TECHNICIANS, ONE ON SHIFT AND AN ADDITIONAL TWO WITHIN
[;l.
11 60 MINUTES.
AS YOU UNDERSTAND IT, WHEN DOES THE CLOCK RUN 12 FOR THAT 60 MINUTES?
13 A
MY UNDERSTANDING AND MY INTERPRETATION OF THAT IS I4 THAT THE CLOCK WOULD START WHEN NOTIFIED.
15 Q
WHEN THE INDIVIDUALS ARE NOTIFIED?
16 A
YES.
I7 Q
I SEE.
SO YOU HAVE REALLY TWO KINDS OF -- I DON'T 18 WANT TO CALL THEM DISPUTES -- AREAS UNDER DISCUSSION NOW WITH THE NRC STAFF.
ONE HAS TO DO WITH 30 MINUTES AND, IN ADDITION, 20 WHEN DOES THE 30 MINUTES BEGIN TO RUN.
IS THAT FAIR?
21 A
NO.
I STILL SEE IT AS AN INTERPRETATION ON MY OWN 22 PART FROM THE NRC AS TO 0654 L
110
(
j Q
WAIT A SECOND.
AS I UNDERSTOOD MR. SEARS' CONCERN, r
IT WAS THAT YOU HAVE NO COMMITMENT TO AUGMENTATION WITHIN 2
30 MINUTES IRRESPECTIVE OF WHEN THE' CLOCK STARTS; IS THAT 3
CORRECT?
4 5
A THAT IS UNCLEAR TO ME BECAUSE I AM STILL TRYING 6
TO GET AN INTERPRETATION OF WHEN THE CLOCK STARTS.
7 Q
SUPPOSE THE INTERPRETATION CAME OUT YOUR WAY, JUST 8
FOR THE SAKE OF DISCUSSION, AND THAT MR. SEARS SAID "DESPITE 9.
WHATEVER THE NUREG SAYS, IT IS SUPPOSED TO BE AFTER THE DE-10 CLARATION OF AN EMERGENCY," THAT YOU PERSUADED HIM WHAT IT J. '
11 REALLY MEANS IS AFTER THE GUY WAS CALLED SO WE ARE NOW TALKING 12 30 MINUTES FROM THEN.
WOULD YOU THEN CHANGE THIS TABLE TO 13 SHOW LILCO 30 MINUTES OR WOULD YOU HAVE A DIFFERENT COLUMN 14 FOR LILCO 30 MINUTES OR WHAT?
15 A'
FIRST OF ALL, I DON'T THINK I PERSUADED THE NRC 16 IN THEIR INTERPRETATION.
I ONLY GET INTERPRETATIONS FROM 17 THEM.
18 Q
OKAY.
SECOND OF ALL WHAT?
19 A
WOULD YOU REASK THE QUESTION ON THE SECOND PART?
h 20 Q
ASSUMING YOU ARE CORRECT OR ASSUMING'THE NRC ADOPTS 21
'YOUR INTERPRETATION OR THAT IS ITS INTERPRETATION ALL ALONG I
22 THAT THE CLOCK STARTS WHEN THE INDIVIDUAL IS CALLED TO AUGMENT
- 111
)
I THE INDIVIDUAL -- DO YOU HAVE THAT IN MIND?
2 A
YES, I DO.
3 Q
THAT MEANS THAT THE CLOCK STARTS WHEN YOU CALL.
4 ISN'T IT A FACT THAT DI MASCIO EXHIB'IT NO. 2 STILL CONTAINS S
NO AUGMENTATION WITHIN 30 MINUTES?
6 A
IT DOES NOT HAVE A COMMITMENT WITHIN 30 MINUTES.
7 Q
SO LILCO HAS NO COMMITMENT TO AUGMENT WITHIN 30 8
MINUTES IRRESPECTIVE OF WHEN THE TIME STARTS; ISN'T THAT CORRECl?
9 ISN'T THAT WHAT WE JUST FINISHED SAYING?
10 A
RIGHT.
I Q
FURTHERMORE, THE QUESTION OF WHEN THE CLOCK STARTS IS STILL UP IN THE AIR EVIDENTLY; IS THAT CORRECT?
I A
WITH MYSELF, YES.
Q DO YOU HAVE AN OPINION AS,YOU SIT HERE TODAY AS TO'WHETHER OR NOT LILCO WOULD BE ABLE TO AUGMENT WITHIN 30 6
MINUTES IF THE CLOCK STARTED AT THE DECLARATION OF AN EMERGENCY 1 A
IF THE CLOCK STARTED AT THE DECLARATION OF AN EMERGENCY?
18 Q
CORRECT.
19 MR. RUDLIN:
ARE YOU ASKING GENERALLY OR WITH RESPECT h
20 TO ANY PARTICULAR POSITION?
MR. SEDKY:
GENERALLY.
IN OTHER WORDS, DOES HE HAVE A VIEW AS TO WHETHER OR NOT THEY COULD COMMIT TO AUGMENTING
112
\\
')
1 WITHIN 30 MINUTES ALL UP AND DOWN THE SCHEDULE.
IF HE SAYS 2
YES AS TO SOME AND NO AS TO OTHERS, I GUESS WE WILL PURSUE 3
THAT.
4 MR. RUDLIN:
I WILL OBJECT.
I THINK THAT CALLS ON THE 5
WITNESS TO SPECULATE.
6 MR. SEDKY:
SUBJECT TO THE OBJECTION.
7 THE WITNESS:
I THINK THAT CALLS FOR SPECULATION ON MY 8
PART THAT I AM NOT PREPARED TO MAKE.
9 BY MR. SEDKY:
10 Q
GIVE ME YOUR BEST JUDGMENT.
II A
I AM NOT SURE.
12 Q
THAT IS THE ANSWER TO THE QUESTION, RIGHT, THAT 13 YOU ARE NOT SURE?
I4 A
TO WHICH QUESTION?
15 MR. SEDKY:
LET'S READ IT BACK.
THE PENDING QUESTION 16 IS DO YOU HAVE AN OPINION.
(THE QUESTION WAS READ BY THE REPORTER.)
BY MR. SEDKY:
Q I AM JUST NOT SURE WHETHER YOU ANSWERED THE QUESTION OR WHETHER YOU WERE SAYING YOU WERE NOT SURE YOU UNDERSTOOD IT OR YOU WERE NOT SURE THAT YOU COULD ANSWER IT.
MY QUESTION IS ARE YOU NOT SURE THAT LILCO COULD AUGMENT ALL UP AND DOWN
113
)
1 THE SCHEDULE WITHIN 30 MINUTES?
2 A
NO, I WAS NOT ANSWERING THE QUESTION SAYING THAT 2
1 AM NOT SURE OF THAT.
4 Q
CAN Y,0U ANSWER THE QUESTIO'N?
5 A
I DON'T BELIEVE I CAN ANSWER THAT.
6 Q
WHY NOT?
7 A
THAT INVOLVES SPECULATION.
8 Q
WHY DOES IT INVOLVE SPECULATION?
9 A
THAT OPINION INVOLVES SPECULATION ON MY PART.
10 Q
YOU ARE THE ONSITE DIRECTOR OF EMERGENCY, PLANNING, 11 AREN'T YOU?
12 A
I AM.
13 Q
WE ARE TA'LKING ABOUT THE CAPABILITY OF LILCO TO I4 AUGMENT ITS ONSITE STAFF; ISN'T THAT CORRECT?
15 A
THAT IS CORRECT.
16 Q
ARE YOU SAYING THAT YOU HAVE NO OPINION AS TO WHETHER I7 OR NOT LILCO COULD COMMIT TO AUGMENT ITS ONSITE STAFF WITHIN 18 30 MINUTES OF THE DECLARATION OF AN EMERGENCY?
IN OTHER WORDS, I9 WITHIN 30 MINUTES OF THE DECLARATION OF AN' EMERGENCY.
20 A
IT WOULD BE MY OPINION THAT IT MIGHT BE AN UNREALISTIC 21 COMMITMENT TO MAKE.
(
22 Q
UNREALISTIC IN THE SENSE THAT IT MAY NOT BE CAPABLE O
114
(
)
1 OF BEING IMPLEMENTED?
2 A
IT WOULD BE MY OPINION THAT IT WOULD BE UNREALISTIC 3
TO COMMIT TO 30 MINUTES.
~
4 Q
00 YOU HAVE A VIEW AS TO WHY IT WOULD BE UNREALISTIC?
5 A
ONCE AGAIN, IT IS SPECULATION.
6 Q
DO YOU HAVE A VIEW OR NOT?
DO YOU HAVE A VIEW, 7
MR. DI MASCIO?
8 A
WOULD YdU REPHRASE A VIEW ON WHAT, PLEASE?
9 Q
ON WHY IT WOULD BE UNREALISTIC TO COMMIT TO AUGMENT-10 ING THE STAFF WITHIN 30 MINUTES OF THE DECLARATION OF AN EMERGENCY.
g 11 ARE YOU GOING TO ANSWER THE QUESTION, MR. DI MASCIO?
m, 12 A
YES, I AM.
IN MY VIEW, TO COMMIT TO THAT 30-MINUTE 13 AUGMENTATION AT THE DECLARATION OF AN EMERGENCY 365 DAYS A 14 YEAR, 24 HOURS A DAY WOULD BE UNREALISTIC.
15 Q
I STILL DON'T UNDERSTAND WHAT YOU MEAN BY "UNREALI STIC. "
16 YOU MEAN TOO EXPENSIVE? IS THAT WHAT YOU MEAN?
I7 A
NO, I DON'T.
18 Q
THEN WHY?
' I' A
WHEN YOU TAKE INTO ACCOUNT THE DISTANCE PERSONNEL 20 MAY LIVE.AWAY FROM HOME AND THE NORMAL TIME IT MAY TAKE TO 2I ARRIVE.
22 Q
WHAT YOU ARE SAYING IS YOU DON'T THINK I T C AN BE s_ -
G
115
(
)
I DONE?
2 A
I THINK IT WOULD BE UNREALISTIC TO COMMIT TO IT.
3 Q
GIVEN WHAT?
THE DISTANCES AND THE TIME AND TRAFFIC 4
AND THINGS LIKE THAT?
5 A
GIVEN THE DISTANCE.
6 Q
JUST GIVEN THE DISTANCE ALONE, YOU ARE SAYING THAT 7
THAT WOULD BE UNREALISTIC?
8 A
AND THE NORMAL TIME, YES.
9 Q
AND-THE NORMAL TIME THAT IT' TAKES TO GET TO THE 10 PLANT FROM THE HOME?
g-
_$Y 11 A
THAT IS CORRECT.
Q THAT IS UNCOMPLICATED BY UNUSUAL TRAFFIC CONGESTION, FOR EXAMPLE?
A AGAIN, I SAID IT IS UNREALISTIC TO COMMIT TO IT.
Q I UNDERSTAND WHAT YOU ARE SAYING.
I AM TRYING TO GET THE PARAMETERS, THE VARIABLES THAT GO INTO YOUR VIEW THAT 17 IT IS UNREALISTIC OR WOULD BE UNREALISTIC.
WE ARE TALKING 18 l
ABOUT DISTANCE AWAY FROM THE PLANT AND QUST NORMAL DRIVING i
19 TIME; IS THAT RIGHT?
'h 20 A
THAT IS RIGHT.
21 MR. RUDLIN:
I NEED TO MAKE A PHONE CALL WHEN YOU GET 22 TO A GOOD STAGE.
l
,116
(
)
1 MR. SEDKY:
THIS IS A GOOD TIME.
2 (BRIEF RECESS.)
3 BY MR. SEDKY:
4 Q
MR. DI MASCIO, JUST BEFORE THE BREAK, WE WERE TALKING S
ABOUT THE DISTANCES AND TIME INVOLVED IN GETTING FROM PEOPLE'S 6
HOMES TO THE PLANT; CORRECT?
7 A
YES.
8 Q
IT WAS THOSE FACTORS THAT LED YOU TO BELIEVE THAT 9
THE 30-MINUTE AUGMENTATION FROM THE DECLARATION OF THE EMERGENC1 10 WOULD BE UNREALISTIC; IS THAT RIGHT?
II A
AS A COMMITMENT, YES.
12 Q
IF IT IS THE DISTANCE AND COMMUTING TIME THAT 13 IS A PROBLEM IN YOUR EYES, THAT WOULD BE TRUE WHETHER THE I4 CLOCK BEGAN AT THE DECLARATION OR WHEN THEY WERE PHONED; ISN'T 15 THAT RI'GHT?
LET ME SEE IF I CAN MAKE IT CLEARER FOR YOU.
16 IF IT TAKES MORE THAN 30 MINUTES TO DRIVE FROM POINT X TO I7 THE PLANT, THEN IT TAKES MORE THAN 30 MINUTES TO DRIVE THAT DISTANCE AND THAT IS TRUE WHETHER YOU CALL THEM IMMEDIATELY UPON DECLARATION OR SOME POINT AFTER THAT; ISN'T THAT RIGHT?
O A
YES.
Q IS IT YOUR UNDERSTANDING THAT THERE WOULD BE A LAG 22 BETWEEN THE TIME AN EMERGENCY IS DECLARED AND THE AUGMENTATION STAFF IS CALLED?
117
)
1 A
THERE IS SOME TIME NECESSARY.
2 Q
SOME TIME NECESSARY TO CALL THE INDIVIDUALS; RIGHT?
3 A
RIGHT.
4 Q
IN.THE CASE OF A 30-MINUTE AUGMENTATION AS PER TABLE 5
B-1, WE ARE TALKING ABdUT ROUGHLY A DOZEN IND I VI DUAL,S ; ISN'T 6
THAT RIGHT?
7 A
WHICH TIME FRAME?
I AM SORRY.
8 Q
30 MINUTES.
9.
A YES.
10 Q
HAVE YOU ESTIMATED HOW LONG IT WOULD TAKE TO MAKE
'f '.
2R 11 THOSE CAELS?
12 A
I HAVE NOT.
13 Q
HAVE YOU IDENTIFIED THE INDIVIDUALS WHO WOULD BE I4 MAKING THE CALLS?
I 15 A
YES.
16 Q
IS I T' ONE PERSON OR MORE THAN ONE?
I7 A
DEPENDING ON THE LEVEL OF THE EMERGENCY. AND THE 18 TIME INTO THE EMERGENCY.
IT VARIES.
Q IN RESPECT OF THE 60-MINUTE AUGMENTATION AS TO WHICH 20 LILCO IS ABLE TO COMMIT AS SHOWN ON DI MASCIO EXHIBIT 2 FOR l
21 IDENTIFICATION, HOW MANY PEOPLE ARE CONTEMPLATED TO BE INVOLVED 22 IN CALLING THOSE INDIVIDUALS?
r l
l i
.118
)
1 A
PER THE PRESENT PROCEDURE ONE.
I WOULD LIKE TO 2
CLARIFY THAT.
FOR THE PRESENT PROCEDURE ONE, WHO IN TURN 3
WHEN HE MAKES A CALL THAT PERSON IN TURN WOULD MAKE OTHER 4
NOTIFICATIONS SO THAT IT WOULD CASCADE.
5 Q
I UNDERSTAND.
IS IT ALL MAPPED OUT ALREADY. IN THE 6
PROCEDURES?
IN OTHER WORDS, THE ONSITE PERSON WHO MAKES THE 7
FIRST TELEPHONE CALL IS GOING TO CALL MR. X, WHO IN ADDITION 8
TO ARRIVING WITHIN 60 MINUTES IS TO CALL MR. Y AND MR.
Z, 9
THAT KIND OF THING?
10 A
YES.
47g my Il Q
ARE THERE REDUNDANCIES BUILT INTO THAT?
IN OTHER 12 WORDS, 'IF SOMEBODY IS NOT AT HOME, DO YOU HAVE SOMEBODY ELSE 13 CALL?
I4 A
WE HAVE ALTERNATES.
15 Q
HAVE YOU IDENTIFIED THE INDIVIDUALS WHO ACTUALLY 16 WOULD BE RESPONDING WITHIN THE 60 MINUTES THAT YOU HAVE I7 ESTABLISHED SO FAR?
18 A
YES, WE HAVE.
I WOULD SAY WE HAVE EVEN IDENTIFIED THE POSITION.
0 Q
AS I UNDERSTAND THAT, ALL THOSE POSITIONS ARE PRESENTLY OCCUPIED BY INDIVIDUALS.
IN OTHER WORDS, IF YOU WERE TO MAKE 22 A CALL TODAY, HYPOTHETICALLY YOU WOULD KNOW WHO TO CALL?
9 e
119
~
a m
)
1 A
YES.
2 Q
ARE THERE ANY POSITIONS THAT ARE NOT YET FILLED THAT 3
WOULD BE AUGMENTED WITHIN 60 MINUTES?
4 A
NO.
5 Q
ON THE ASSCMPTION THAT THE PEOPLE WHO ARE. PRESENTLY 6
OCCUPYING TH3 POe TONS'THAT WOULD BE AUGMENTING THE ON SHIFT 7
PERSONNEL WITHIN 60 MINUTES, ARE YOU ABLE TO TELL US DISTANCES 8
AWAY FROM THE PLANT THESE INDIVIDUALS ARE, TAKING THE NEAREST 9
AND THE FURTHEST AS AN EXTREME?
10 A
NOT AT THIS TIME.
Il Q
HAVE YOU DONE THAT WORK BUT YOU JUST DON'T HAVE 12 IT IN YOUR MIND OR IT JUST HASN'T BEEN DONE YET?
13 A
IT IS IN THE PROCESS OF BEING DONE.
14 Q
IN OTHER WORDS, YOU ARE NOW IDENTIFYING WHO HOLDS 15 THOSE POSITIONS THAT WOULD BE RESPONDING AND WHERE THEY LIVE; 16 IS THAT RIGHT?
I7 A
THAT'S CORRECT.
18 Q
DO YOU HAVE AN ESTIMATE AS TO WHEN THAT EFFORT WILL I
I9 BE COMPLETED?
20 A
I l
Q WHEN YOU REFERRED IN YOUR VERY EARLY ANSWER TO GENERIC i('
22 PHILOSOPHY ABOUT 30 MINUTES, WAS THE PHILOSOPHY YOU ARE REFERRIb G l
TO THE ISSUE OF WHEN THE CALL WAS TO BE MADE OR WHAT?
I AM l
l 120
(
SORRY.
WAS THE PHILOSOPHY THE ISSUE OF WHEN THE CLOCK STARTED
)
1 TO RUN?
2 A
THAT WAS PART OF IT.
3 4
Q THAT WAS THE OTHER PART OF THE QUESTION OF HOW REALISTIC.
5 IT WAS TO AUGMENT WITHIN 30 MINUTES?
6 A
I BELIEVE SO.
7 Q
DO YOU RECALL ANYTHING ABOUT MR. SEARS' REACTION 8
TO THOSE TWO TOPICS, NAMELY, WHEN THE TIME STARTS AND HOW 9
REALISTIC IT WAS TO AGUMENT WITHIN 30 MINUTES?
10 A
BASICALLY, I HAD THE IMPRESSION THAT THAT IS THE 11 WAY IT IS WRITTEN.
12 Q
IN OTHER WORDS, IT IS 30 MINUTES AND IT IS FROM 13 THE DECLARATION OF THE EMERGENCY?
14 A
NO.
I DON'T REMEMBER THE SPECIFIC RESOLUTION ON 15 THE INTERPRETATION OF START OF THE CLOCK.
16 Q
THE WAY IT IS WRITTEN IS 30 MINUTES?
17 A
UNREALISTIC VERSUS REALISTIC.
18 Q
HIS CONCLUSION IS THAT IS THE WAY IT IS WRITTEN, 19 IN EFFECT?
h 20 A
YES.
21 Q
BY THAT, HE IS REFERRING TO THE 30-MINUTE REQUIREMENT 1 22 A
THAT'S CORRECT.
121 I
\\
)
1 Q
ANYTHING ELSE YOU RECALL ABOUT THE CONVERSATION WITH 2
MR. SEARS ON TABLE B-1 OTHER THAN WHAT YOU HAVE TESTIFIED 3
TO?
4 A
N O'.
5 Q
HAVE WE EXHAUSTED YOUR RECOLLECTION ON THAT TOPIC 6
OF THE CONVERSATION?
7 A
YES, WE HAVE.
8 Q
YOU ALSO SAID THAT YOU TALKED WITH MR. SEARS ABOUT 9
THE INITIATING CONDITIONS.
DO YOU RECALL THAT?
10 A
YES, I DO.
jg, 4:
II Q.
DO YOU REMEMBER WHETHER THIS WAS THE SAME CONVERSATIOt.
I2 WITH RESPECT TO WHICH YOU ALSO DISCUSSED TABLE B-1 OR WAS I.3 IT A DIFFERENT CONVERSATION?
I4 A
I DO NOT RECOLLECT.
15 Q
YOU DON'T RECALL. DO YOU RECALL WHO INITIATED THE 16 TOPIC?
"THE TOPIC" BEING THE INITIATING II CONDITIONS.
A I DON'T RECOLLECT THAT EITHER.
Q GIVE US YOUR BEST RECOLLECTION OF WHAT HE SAID TO YOU AND WHAT YOU SAID TO HIM ABOUT THE INITIATING CONDITIONS IN SUBSTANCE.
I KNOW YOU CAN'T REMEMBER EVERY WORD.
2 A
ACTUALLY, THIS ONE IS EASIER.
HE SAID TO ME THAT p
A
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board
)
In the Matter of
)
)
LONG ISLAND LIGHTING COMPANY
)
Docket No. 50-322 (OL)
)
(Emergency Planning (Shoreham Nuclear Power Station, )
Proceedings)
Unit 1)
)
)
CERTIFICATE OF SERVICE I hereby certify that copies of "Suffolk County's Response To LILCO's Motion For Summary Disposition Of EPs 2B, SB and 7B" were sent on November 19, 1982 by first class mail, except where otherwise noted, to the following:
- . = - ',
Lawrence Brenner, Esq.*
Mr. Brian McCaffrey
~." ; ta Administrative Judge Long Island Lighting Company 2,- u Atomic Safety and Licensing 175 East Old Country Road Hicksville, New York 11801 Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Ralph Shapiro, Esq.**
Cammer and Shapiro Dr. James L. Carpenter
- 9 East 40th Street Adminis.trative Judge New York, New York 10016 Atomic Safety and Licensing Howard L.
Blau, Esq.
Board U.S. Nuclear Regulatory Commission 217 Newbridge Road Washington, D.C.
20555 Hicksville, New York 11801 i
Dr. Peter A. Morris
- W. Taylor Reveley, III, Esq.**
Administrative Judge Hunton & Williams Atomic Safety and Licensing 707 East Main Street Richmond, Virginia 23212 Board U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Jay Dunkleberger New York State' Energy Office Edward M.
Barrett, Esq.
Agency Building 2 General Counsel Empire State Plaza Long Island Lighting Company Albany, New York 12223 250 Old Country Road Mineola, New York 11501 By Federal Express By Hand
.. C CV Stephen B.
- Lhtham, Esq.**
' Mr. Jeff Smith Twomey, Latham & Shea Shoreham Nuclear Power Station Attorneys at Law P.O.
Box 618 33 West Second Street North Country Road Riverhead, New York 11901 Wading River, New York 11792-Marc' W. Goldsmith MHB Technical Associates Energy Research Group, Inc.
1723 Hamilton Avenue 400-1 Totten Pond Road Suite K Waltham, Massachusetts 02154 San Jose, California 95125 Joel Blau, Esq.
Hon. Peter Cohalan New York Public Service Suffolk County Executive Commission County Executive / Legislative The Governor Nelson A.
Building Rockefeller Building Veterans Memorial Highway Empire State Plaza Hauppauge, New York 11788 Albany, New York 12223 Ezra I.
Bialik, Esq.
David H. Gilmartin, Esq.
Assistant Attorney General Suffolk County. Attorney Environmental Protection Bureau County Executive / Legislative New York State Department of Law Building 2 World Trade Center Veterans Memorial Highway New York, New York 10047 Hauppauge, New York 11788 Atomic Safety and Licensing Atomic Safety and Licensing Appeal Board Board Panel U.S.
Nuclear Regulatory Commission U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Matthew J.
Kelly, Esq.
Docketing and Service Section Staff Counsel, New York State l
Office of the Secretary Public Service Commission U.S.
Nuclear Regulatory Commission
'3 Rockefeller Plaza l
Washington, D.C.
20555 Albany, New York 12223 Bernard M.
Bordenick, Esq.*
Daniel F.
Brown, Esq.*
David A. Repka, Esq.
U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Washington, D.C.
20555 Stuart Diamond Environment / Energy Writer NEWSDAY Long. Island, New York 11747 7
~ i~stoph'er M.' McM6rray r
(
KIRKPATRICK, LOCKHART, HILL, CHRISTOPHER & PHILLIPS DATED:
November 19, 1982 1900 M Street, N.W.,
Suite 800 Washington, D.C.
Washington, D.C.
20036 t
__