ML20073G304
| ML20073G304 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 03/10/1983 |
| From: | Glass J PUBLIC INTEREST RESEARCH GROUP, NEW YORK, UNION OF CONCERNED SCIENTISTS |
| To: | |
| Shared Package | |
| ML20073G268 | List: |
| References | |
| NUDOCS 8304180246 | |
| Download: ML20073G304 (28) | |
Text
E F
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
x ATOMIC SAFETY AND LICENSING BOARD BEFORE ADMINISTRATIVE JUDGES:
I JAMES P. GLEASON, CHAIRMAN I
FREDERICK J. SHON DR. OSCAR H. PARIS In the Matter of:
CONSOLIDATED EDISON COMPANY OF NEW YORK, INC.
(Indian Point, Unit,No. 3)
POWER AUTHORITY OF THE STATE GF NEW YORK (Indian Point, Unit No. 3)
X l
Ossining Public Library Croton Avenue Ossining, N.Y.
March 10, 1983 6:00 p.m.
DEPOSITION OF JUDITH GLASS, taken pursuant to Stipulation by and between counsel for the respective parties herein.
IRVING WALDMAN Court & Freelance Reporting 380 Mc LaanAvenue Reporbr :
Leslie M.
Yonkers, N.Y.
10705 Arzoomanian Tel: (914) 476-7728 Service (212) 828-1400
/.
8304180246 830228 PDR ADOCK 05000247 G
1 2
APPEARANCES :
3 SHEA & GOULD, ESQS.
Attorneys for Consolidated Edison Company of New York, Inc.
5 330 Madison Avenue New York, New York 10017 6
BY:
DAVID H. PIKUS, ESQ.,
of Counsel 7
8 AMANDA POTTERFIELD, ESQ.
y Attorney for Intervenors Jointly, 9
NYPIRG/UCS New York Public Interest Rese_ arch Group, Inc.
9 Murray Street 33 New York, New York 10007 12 Also Present:
Pat Posner, PCAIP 33 Joan Holt, NYPIRG 14 o0o 15 16 MS. POTTERFIELD:
This deposition is 17 taken.by agreement of counsel for the Power Authority, 18 Con Edison and the Nuclear Regulatory Staff.
19 Th.'s deposition is taken on the condition 20 that the testimony that is given by Miss Glass during 21 this deposition will be stipulated into evidence as 22 testimony as though it were given before the Atomic 23 Safety and Licensing Board in this proceeding.
24 Otherwise, the deposition is taken for
/
25 the purpose of determining whether a stipulation can
1 3
2 be reached among the partfes to eliminate the 3
testimony of the following witnesses:
Loretta 4
Brundage, Lynn Gunzenhauser, Michael Robinson, 5
Joan Livingston, Phyllis Mendelsohn and Katherine 6
Feit, with the stipulation that the cross-examination 7
of these witnesses will be the same as the cross-8 examination of Miss Glass.
9 o0o 10 11 JUDITH
- GLASS, 44 Coachlight Square, 12 Montrose, New York, having been first duly sworn by Leslie M. Arzoomanian, a Notary Public of the 13 I
State of New York, was examined and testified as g4 15
- follows:
16 MS. POTTERFIELD:
You have been sworn 17 and you have given us your name and address?
18 THE WITNESS:
Yes.
19 MS. POTTERFIELD:
Do you have before you 20 the testimony that you wish to submit before the 21 Atomic Safety and Licensing Board in this proceeding?
22 THE WITNESS:
Yes.
23 MS. POTTERFIELD:
Did you prepare that 24 testimony yourself?
/
25 THE WITNESS:
Yes, I did.
L
I Judith Glass 4
MS. POTTERFIELD:
Do you have any additiong 3
or corrections to that testimony?
4 THE WITNESS:
No.
5 MS. POTTERFIELD:
Is it true and correct 6
to the best of your information and belief?
7 THE WITNESS:
Yes, it is.
8 MS. POTTERFIELD:
I move that this o
9 testimony be marked as an exhibit, Glass Exhibit 1, 10 for this de' position at this time.
I have no objection and would 12 stipulate to the admissibility of the exhibit marked 13 as Glass Exhibit 1 at the hearing, in the event that
~
14.
we are unable to agree on a stipulation that would 15 involve other witnesses, mid provided that the 16 deposition transcript could be read into the record 17 in lieu of cross-examination.
18 (Testimony of Judith Glass, dated June 1, 19 1982, consisting of two pages, with Judith Glass' 20 signature appearing thereon, received and marked i
21 as Glass Exhibit 1 for identification.)
22 EXAMINATION BY l
l 23 MR. PIKUS:
[
24 Q
Ms. Glass, turning your attention to what was 25 just marked-as Glass Exhibit 1.
Do you have any changes e
~
l Judith Glass 5
2 that you could make to the testimony as a result of the 3
interval of approximately eight months since the time 4
it was filed?
5 A
No.
Are you aware of any changes in the Emergency 6
Q 7
Planning for Westchester County that might make some of 8
the material contained in your testimony outmoded or 9
irrelevant?
10 A
Not to my knowledge.
11 0
Do you have any children of your own?
12 A
Yes; one daughter.
13 Q
How old is she?
14 A
Nine.
15 O
Where do you live?
16 A
I live in Montrose, New York.
17 Q
I take it your testimony is limited to the 18 students for whom you are responsible?
19 A
Well, it wrote it as a teacher.
However, a 20 lot of what I feel has to do with being a parent as well 21 in this given situation.
22 Q
Nothing in your testimony, marked as Glass 23 Exhibit 1, however directly addresses the problem that 24 your own child might face in an emergency; is that correct?
/
25 A
That's correct.
l m
I Judith Glass 6
2 O
Ms. Glass, I am going to show you a copy 3
of a document entitled " Indian Point, Emergency Planning, 4
And You."
5 MR. PIKUS:
I would ask the Reporter 6
to mark this as Glass Exhibit 2.
7 (Booklet entitled " Indian Point, 8
Emergency Planning And You," received and marked 9
Glass Exhibit 2 for identification.)
9 10 Q
Ms. Glass, have you ever seen the document 11 marked Glass Exhibit 2 before'this evening?
12 A
No.
13 Q
Do you recall ever having received an i
14 emergency planning brochure in the mail?
15 A
No.
16 Q
Have you ever discussed the subject of 17 emergency planning for Indian Point with your students?
18 A
No.
19 Q
Have any of your students ever expressed 20 concern to you about the operation of the Indian Point 21 Power Plants?
22 A
No.
They're very young.
They're in nursery 23 school.
They're three-year olds.
24 O
APproximately how many students are you
/
25 responsible.for?
I Judith Glass 7
2 A
Thirteen.
3 0
I take it that they all have parents?
4 A
Yes.
5 0
How do they generally arrive at school in 6
the morning?
7 A
Generally, by individual parents or car pool.
8 Q
I take it that the persons who drive in the 9
car pool are other parents?
10 A
Yes.'
11 Q
Are they picked up to leave school in the 12 same manner?
13 A
Not necessarily.
Sometimes they are picked up 14.
by babysitters.
15 0
These are all people who have automobiles?
16 A
Yes.
17 Q
Have you made any attempt to obtain any 18 information that you believe is necessary to be better 19 prepared to respond to a possible radiological emergency 20 at Indian Point?
21 A
Not outside of my testimony, which I hoped would be the source of my receiving some information.
23 0
I take it then by filing your testimony, you 24 believed somebody would read your testimony and then contact
/'
25 you in order to address your concerns?
nm-m
b I
Judith Glass 8
2 A
If not personally, then generally.
But, no, 3
I haven't otherwise.
4 0
Could you tell us what your understanding is 5
of the proceeding for which you filed this particular 6
piece of testimony, marked Glass Exhibit 17 7
A How it came about?
8 O
Yes; how you came to file this particular 9
piece of testimony and in what connection you believe 10 this testimony is going to be used.
11 Q
As a nursery school teacher, I was approached, 12 as were the other teachers in my school, and we were asked 13 to prepare testimonies.
First we were asked how we felt 34 about the drill last year and then we were asked to prepare 15 testimonies according to how we felt as teachers.
16 Q
Who asked you to prepare this testimony?
17 A
A woman from Croton who was a parent at the
(
l jg nursery school as well.
I l
l 19 Q
Would you be able to identify this woman?
20 A
Agata Craig.
21 Q
Did you know Ms. Craig before she approached 22 you in connection with the testimony?
23 A
Yes, because her son was one of my students.
24 Q
Did Ms. Craig indicate to you that she
/
25 represented any particular organization?
-d
1 Judith Glass 9
2 A
Parents Concerned About Indian Point.
3 Q
Did you understand at that time that they
'~
4 had a particular position on the operation of the Indian 5
Point Plant?
6 A
Yes.
7 Q
What did you understand that position to be?
8 A
A negative one.
9 Q
In fact, their position was that the Plant 10 should be shut down; is that correct?
11 A
Yes; I understood that.
12 Q
Did they make any effort to educate you as 13 to,what the content of the Emergency Planning for the IndiaE 14 Point area was?
15 A
Would you rephrase that?
16 Q
At the time that Ms. Craig approached you 17 to prepare..your. testimony, did she give you any information 4
18 concerning what was the content of the Emergency Planning 19 for the Indian Point area?
{
'O A
No, she didn't.
She gave me no other 21 information other than what I had read or been prepared 22 for by the Local.
i 23 Q
Did Ms. Craig advise you in any way as to e
24 the source of the risk posed by the Indian Point Power
/
Plants, more specifically, how a radiological emergency 25 l
c
l Judith Glass 10 2
might occur there?
3 A
No.
The conversation leading up to my 4
testimony only had to do with how I felt about the 5
evacuation.
6 Q
Do you recall exactly what Ms. Craig said 7
to you?
8 A
She was asking all the teachers to write 9
testimonies because all the general feelings seemed to 10 be the same, that we couldn't hear the sirens, first of 11 all, and second of all and more importantly, the fact 12 that it was so terribly confusing, as was stated. The 13 plans were confusing, both as a teacher and as a parent.
14.
Q I'm a little confused, Ms. Glass.
You have 15 indicated that you didn't know the content of the Plan,'
16 but you're telling me that the Plan was confusing.
Could 17 you explain that to me?
18 A
You mean did I know they were supposed to go 19 to specific areas in White Plains, to be at this particular l
20 school if you were from that district?
l 21 Q
Yes.
i 22 A
Yes; I had a vague idea.
That was the most I 23 had.
I knew that there was a lot of content, but I would 24 not be specific about it.
I didn't understand it.
/
Q
, From where did you get the information?
25
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3 Judith Glass 11 2
A I can't exactly remember.
I think there was 3
a leaflet or was it in the newspaper?
I don't know.
4 I know we had a meeting at the nursery school and we 5
were given material, the information, through this and 6
there was something printed, which I no longer have.
7 Q
Do you recall who met with you?
6 A
It was mostly teachers and parents in the 9
nursery school.
It was not any kind of group.
10 0
Who exP ained the content of the Plan to you?
l 11 A
The director of my nursery school at the time, 12 from what her understanding was.
13 Q
Would you tell us your best recollection of 14 what the director told you?
15 A
Just that these were the supposed plans.
16 This is what we were supposed to do in case of an accident, 17 and everybody was thoroughly confused.
18 0
What did she tell you to do?
19 A
We.:were supposed to go to some specific school 20 in White Plains.
21 Q
Do you recall what the name of the school was?
22 A
No; I really don't know.
23 0
Were you to accompany your children there?
24 A
This was a tremendous issue.
Nobody got that
/
/
25 far because we began discussing the fact that we had other
1 Judith Glass 12 2
children someplace else and were we really prepared to 3
take these tiny little children to a place so completely 4
unknown to them.
We didn't discuss it as if we were 5
really going to do it.
6 Q
Did you express your desire for further 7
information to the director?
8 A
Yes.
9 Q
What was the director's response?
10 A
She' agreed.
11 Q
Do you know whether the director attempted 12 to obtain further information?
13 A
I don't know exactly.
She was on the verge 14 of resigning.
She may be for her.own information at 15 that point; but I don't really know.
16 Q
Is she still the director?
i 17 A
No.
18 Q
You have a new director?
i9 A
Yes.
l 20 Q
Has the new director provided you with any
{
,i additional information about the Emergency Plan?
l A
She hasn't provided us with any further 22 23 information.
She has received some sort of radio.
t i
24 Q
If I called it a tone alert, would it be
/
accurate?
25
3 Judith Glass 13 2
A That name doesn't ring a bell.
It also gives 3
storm warnings.
4 0
Is it fair to say that it is a radio that 5
activates itself in the event that there is some sort 6
of emergency?
7 A
All I know is that when she knew that 8
yesterday there was going to be another--that the sirens 9
were going off, she did not plug it in because she said 10 that it was too loud.
So, I guess if it's not plugged 11 in, it's not self-activated.
I don't know.
I really 12 don't know.
13 0
Do you know whether it was the operators 14 of the Indian Point Power Plant who provided this device 15 for you?
16 A
As a matter of fact, I just want to say that 17 I'm not positive of this.
I think that an employee who' 18 might be a parent or a parent who might be an employee at 19 Con Edison gave the radio to the present director.
20 0
Do you know what the original source of your 21 former director's information concerning the Emergency 22 Plan was?
23 A
I guess the same as all of us; the news and 24 just what was made available to the public.
/
25 Q
It is your testimony that the director either
I Judith Glass 14 2
read about this in the newspaper or heard it on the radio 3
and then decided to hold a meeting with the teachers--
4 A
Yes.
5 0
--and then instructed you about the Plan?
6 A
Yes.
7 Q
Did the director tell you this or are you simply inferring that this is what happened?
8 9
A I'm inferring, only because I know she is 10 not associated with any particular group and she was 11 simply very concerned for the welfare of the people in 12 her school.
13 Q
Did the director tell you that she had met 34 with anyone from the firm Parsons, Brinckerhoft, Quade &
15 Douglas?
16 A
No.
17 Q
Did she indicate to you that there was a 18 consulting firm that was in the process of preparing 19 emergency plans for the four counties surrounding Indian I
I 20 Point?
21 A
It sounds familiar, but this is a year ago.
22 I knew that there were further investigations being made 23 to find out, but I'm not really thht-clear.
l i
24 Q
Did your former director ever mention anyone
/
25 by the name o f Harvey Harth?
r
1 Judith Glass 15 2
A No, not to my knowledge.
I've never heard 3
of him.
4 Q
Have you ever heard of any organization known 5
as the Four County Nuclear Safety Committee?
6 A
No.
7 Q
Have you ever heard of a consulting firm by 8
the name of E.D.S. Nuclear?
c 9
A No.
P 10 Q
Have'you ever heard of a gentleman by the 11 name of Dennis Behr?
12 A
No.
-13 Q
Have you ever heard of a woman by the name 14 of Peggy Rosenblatt?
15 A
No.
16 Q
Subsequent to your conversation with Ms. Craig, 17 did you make any further attempts to obtain information 18 about emergency planning for Indian Point?
19 A
No, I didn't.
20 Q
Are you aware that there is a toll-free 21 number for people who desire further information about 22 Indian Point to call in order to obtain further information?
l t
23 A
No.
24 Q
Did you ever learn that there were various
/
25 groups, such as Parents Concerned About Indian Point, who l
I I
Judith Glass 16 2
were conducting activities in the Indian Point area 3
concerning emergency planning for the Indian Point Plant?
4 A
Did I know that they were conducting activitiest 5
Q Yes.
6 A
No.
I know of the existence of the group, 7
but I don't keep up with what they're doing all the time.
8 Q
I take it then that you did not ask anyone
'l 9
associated with any of these groups that were supporting 10 the closing of Indian Point where you might be able to 11 obtain further information?
12 MS. POTTERFIELD:
I have to object to 13 the characterization of "these groups."
We have 14 only talked about Parents Concerned About Indian 15 Point. -
16 MR. PIKUS:
The. objection is well-taken.
17 Let me see if I can cure the objection.
18 Q
Are you aware that there are other groups 19 besides Parents Concerned About Indian Point who have 20 been conducting activities in the Indian Point area to 21 the end of obtaining the closing of the Indian Point 22 Plants?
23 A
Well, I know about it because it's always on e
24 the news, or at least often.
/
25 Q
Can you identify any other groups, other than m
1 Judith Glass 17 2'
Parents Concerned About Indian Point?
3 A
By name?
4 Q
Yes.
5 A
No.
6 Q
Have you made any attempt to obtain information 7
from Parents Concerned About Indian Point or anyone 8
associated with any of the other groups about the Emergency.
9 Plan for Indian Point?
10 A
N o t 'r e a l l y.
11 Q
Have you attempted to contact the Power 12 Authority of the State of New York for further information?
13 A
No, I haven't.
I suppose that I'm waiting 14,
to hear about what's going to happen after next week.
15 You know, everything is sort of on hold. So I haven't.
16 Q
Would it be fair to say that you filed your i
-test mony and are now waiting for the results of the 17 18 hearings being conducted by the Atomic Safety and Licensing 19 Board before further pursuing your quest for information?
20 A
I don't know if that would be a fair statement.
21 I'm not just waiting to see what the results will be.
It 22 is just that I'm not terribly active in the situation.
23 Yes, I want to know, but I guess like most people, my 24 daily life takes up the time and I haven't taken the time
/
25 to find out, which makes me feel guilty.
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1 Judith Glass 18 2
Q Ms. Glass, you referred a few minutes ago 3
to a parent of one of your students who was an employee 4
of Con Edison, did you not?
5 A
Yes.
6 Q
Have you attempted to obtain any information 7
about Indian Point or the emergency planning for Indian 8
Point from that particular parent?
9 A
No.
10 0
Very'early on in the deposition you' referred 11 to an emergency drill.
Were you referring to the 12 emergency exercise that was conducted in March of 1982?
13 A
Yes.
14 Q
Are you aware that there was another exercise
+
15 held on March 9th,1983, which would be yesterday, for -
16 the Indian Point Plants?
17 A
Yes.
18 Q
Did you hear the sirens at that time?
19 A
Yes, I did.
l 20 Q
Did your children hear the sirens?
21 A
They were too noisy to hear them.
They l
really didn't notice them.
22 23 Q
What type of information would you like to 24 have concerning the Emergency Plan for Indian Point?
/
A It's hard to say, because I feel very,'very.
25
1 Judith Glass 19 2
conflicted as far as my position as a teacher and a 3
parent is concerned.
Despite what they might say to do, 4
I'm not sure that I would, in all good faith, be able to 5
do-it.
6 Q
By "they," who are you referring to?
/
7 A
The people who make up the Plan.
8 Q
Are you aware that the Plan is now maintained 9
by the State of New York, the State Government?
10 A
Yes.'
j 11 Q
Have you made any attempt to contact the 12 State Government of New York concerning the Plan?
13 A
No, 14 Q
Have you made any attempt to contact anybody 15 working for Westchester Countir concerning the Plan?
16 A
No.
17 Q
Would you like information concerning the 18 operation of the Indian Point Plants, the actual manner 19 in which it produces electricity and the probability of l
l l
20 any kind of an accident occurring there?
21 A
Well, I get that included in my bill every 22 month, the little leaflet.
23 0
I take it there's nothing in the bill that 24 refers to the Emergency Plan?
/
25 A
. No.
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I Judith Glass 20 2
Q Is there any specific information that 3
would be helpful to you in terms of assisting yourself 4
and your students to respond in the event that there 5
were a radiological emergency, if you know?
6 A
It's very hard to say.
There are too many 7
elements involved.
8 Q
Do you believe that there are other types 9
of emergencias that would require you or your students 10 to make some sor't of response?
II A
Sure.
I2 Q
Could you tell us what types of emergencies I3 you might be referring to?
14 A
Fire.
That's the main one I can think of.
15 0
Does your school have a plan for responding' 16 to a fire?
17 A
Yes.
18 Q
Could you tell us briefly what that plan i
19 consists of?
20 A
We don't do fire drills in nursery school, 21 but we have a fire exit upstairs and three possible exits 22 downstairs.
So it's all taken care of.
The teachers 23 know what they would do.
/.
Q I take it that you would lead the students 24 7
25 out of the-building by predesignated fire axits, if
I Judith Glass 21 2
necessary?
3 A
Yes'.
4 Q
Is it your belief that the children would 5
respond to whatever instructions you would give them?
6 A
It's my hope.
I think they would respond 7
to what I tell them.
8 Q
Are you aware that a chemical spill would 9
also require the evacuation of an area that might include 10 your school?
11 A
Do you mean a chemical spill from a factory?
12 Q
Are you aware that there have been occasions 13 in the past in which large areas have been evacuated in 14 parts of the United States, Canada or elswhere because 15 of a spill involving toxic chemicals; for example, a 16 railroad car derailment that resulted in leaking gas?
17 A
Yes.
18 MS. POTTERFIELD:
I think I have to 19 note an objection to the extent that it assumed 20 that there were large areas evacuated.
I think it 21 is a little bit vague.
The witness has answered.
22 I will just note my objection.
23 Q
Let's say that the area might approximate 24 a square mile or so and would require the evacuation of
/
25 at least several hundred people.
1 Judith Glass 22 2
A Yes, I am aware that those possibilities 3
exist and I often wonder when I hear about them what the 4
people decided to do.
5 0
Your school has no plan other than for a 6
fire; is that correct?
That is in terms of responding 7
to emergencies.
8 A
I would have to say that's probably right.
9 Q
You are not aware of any plan other than 10 that for fire?
11 A
No.
12 Q
In the event that you were required to 13 evacuate your school and move you and your students out 14 of the distance of ten miles, how would you go about 15 doing it?
16 A
Well, I think.that the very first. thing we 17 would do would be to call the parents or the emergency 18 numbers because these are little people we are dealing 19 with and my first concern would be that their parents 20 would want to know where they are.
It would be basically 21 the same thing.
Q If you were given a set of instructions, either 22 23 by written or oral briefing, from government officials 24 or utility operators at Indian Point, would you attempt
/
25 to follow that plan in the event that there were a rad'io-
I Judith Glass 23 2
logical emergency?
3 A
Personally?
If I were one person alone, 4
not responsible for thirteen little people?
5 Q
Assuming that you are a teacher responsible 6
for your children.
7 A
I would try to follow the directions, assuming 8
that they would be with the ultimate safety in mind.
9 But if it meant taking all these people to different 10 places away from their parents and not being near my 11 daughter, I don't know how I could comfortably do it.
12 I don't think that I would be able to do it.
I would 13 have to follow my own instincts and those of the other 14-teachers with me.
15 Q
If the plan also included provisions for the 16 Safety of your own child, and I am speaking of your 17 daughter, would that affect your response?
18 A
I would like to'have her with me when I go 19 with these other children, as I'm sure their parents 20 would like to be with them.
21 Q
If there were a provision in the plan that 22 provided for some response that would assure the safety l
23 of your child and a response that would involve you t
24 leading your students to safety, would you follow that t
l 25 plan?
1
I Judith Glass 24 2
MS. POTTERFIELD:
I object.
That 3
question has been answered as best she can.
I 4
think it might be too vague for another answer, 5
since the hypothetical we are dealing with is an 6
assurance of safety.
I think it has to be more 7
specific.
8 A
I find that's what the problem is, because 9
yem sure ultimately we would all be safe, hopefully.
10 But there are too many sacrifices that the Plan involves Il as it presently stands.
12 Q
Is your daughter in school?
13 A
Yes.
14' Q
How old is she?
15 A
Nine.
16 Q
Is she in public school?
17 A
Yes.
l 18 0
Is it your belief that the public school that 19 she attends has a fire plan?
20 g
y,,,
21 Q
Along the lines of the plan that we discussed 22 for your own school?
l 23 A
- yes, 24 0
Do you believe that that plan adequately
\\
/
25 protects your daughter in the event that there would be a l
o
1 Judith Glass 25 2
fire at the school?
3 A
Yes.
4 MR. PIKUS:
I have no further questions.
5 MS. POTTERFIELD:
I have a few questions.
6 EXAMINATION BY 7
MS. POTTERFIELD:
8 Q
You were asked by Mr. Pikus about any changes 9
in the Plan that you had become aware of since you first 10 wrote your testimony.
Do you have any present knowledge 11 of any potential changes in the Plan?
12 A
About the possibility of a change?
13 Q
Yes.
14.
A I've heard, but I don't know what it is.
15 Q
Where did you hear of this?
16 A
I don't read the local newspaper.
I'm not 17 sure if I saw it.
Sometimes I see the articles..and 18 sometimes I hear.
I'm not that sure.
19 Q
You haven't received any_information about 20 the change, have you?
21 A
No, not to my mailbox.
22 Q
Have you received any information at school?
23 A
No.
24 Q
You were asked and you testified about your
/
25 inability to hear the sirens very well last year during
~,
1 Judith Glass 26 2
the drill.
Were you in the same location last year in 3
March during the drill as you were yesterday during 4
yesterday's drill?
5 A
No. But last year I was in a location that 6
was actually closer to the source of the siren.
7 Q
Where were you this year?
8 A
This year I was at Croton Community Nursery 9
School.
10 Q
Last' year where were you?
11 A
Holy Name of Mary in Croton.
12 Q
You testified that your director of the 13 Croton Community Nursery School was aware that a drill 14,
was to take place yesterday; is that right?
15 A
Yes.
16 Q
Did she instruct the teachers about that drill 17 or did she inform you that it would take place?
18 A
She informed us.
19 Q
Did she give you any instructions?
l 20 A
No.
21 Q
Do you know where she learned or how she 22 learned that a drill was to take place yesterday?
I 23 A
I don't know where she learned it.
I heard 24 it on the radio.
/
25 0
.You testified that you had not ever received
.w-m-
w
I Judith Glass 27 2
a booklet such as the one that was shown to you that 3
has been marked as Glass Exhibit 2; is that correct?
4 A
Yes.
5 Q
You never received that at home?
6 A
No.
7 Q
Your home address is where in relation to 8
your working address?
9 A
A few minutes north.
10 Q
Is it closer or farther away from the Indian II Point Nuclear Plant?
12 A
It?s much closer.
I3 MS. POTTERFIELD:
I have no further 14 questions.
15 (At which time the deposition of Judith 16 Glass was concluded.
Time noted:
7:00 p.m.)
17 18 tt 19 udith Glass 20 Sworn and subscribed to before e
21 this 2IE day of MohA
, 1983.
h,f) @ jo d 22 l
Notary Public I
_ yy,,,,,,
2<
w w a = w.,,
25 O
I 28 2
3 CERTIFICATION:
4 5
6 I, Leslie M. Arzoomanian, a Stenotype Reporter 7
and Notary Public within and for the State of 8
New York, do hereby certify that the witness whose 9
testimony is hereinbefore set forth is a true 10 record of 'the testimony given by that witness.
11 I further certify that I am not related to 12 any of the parties to this action by blood or 13 marriage and that I am in no way interested in the 14 outcome of this matter.
15 16 M. Anun,uirtsu 1,
Leslie M. Arzfomanian 18 19 20 Dated:
March 14, 1983 21 22 23 24 l
25
-,. -., _