ML20126F217
| ML20126F217 | |
| Person / Time | |
|---|---|
| Site: | Waterford |
| Issue date: | 02/28/1981 |
| From: | Tedesco R Office of Nuclear Reactor Regulation |
| To: | Aswell D LOUISIANA POWER & LIGHT CO. |
| References | |
| NUDOCS 8103110239 | |
| Download: ML20126F217 (14) | |
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h UNITED STATES 8 7 j
NUCLEAR REGULATORY COMMISSION 5.*f
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a Docket No. 50-382 FEB 2 31981 Mr. D. L. Aswell Vice President, Power Production Louisiana Power & Light Coinpany 142 Delaronde Street New Orleans, Louisiana 70174
Dear Mr. Aswell:
SUBJECT:
REQUEST FOR ADDITIONAL INFORMATION We have determined that certain additional information is required in order to permit us to complete our review of your application for an operating license for Waterford Steam Electric Station, Unit 3.
The enclosed round two requests for additional infomation w<a prepared by the Instrumentation and Control Systems Branch and are numbereo U30.9 thru 030.43.
Please advise us of the date you expect to provide responses to the enclosed request.
If you require any clarification, please contact the staff's assigned project manager.
a Sincerely,[
RobertL.g k
i vMcAo Assistant Directo for Licensing h
Division of Licensing k
Enclosure:
Request for Additional Information cc w/ enclosure:
See raxt page 81031103 57 g
s.
Mr. D. L. Aswell Vice President, Power Production Louisiana Power &' Light Company FEB 2 S 1981 142 Delaronde Street New Orleans, Louisiana 70174 cc:
.W. Malcolm Stevenson, Esq.
Monroe & Lemann 1424 Whitney Building i
New Orleans, Louisiana 70130 Mr. E. Blake Shaw, Pittman, Potts and Trowbridge 1800 M Street, N. W.
Washington, D. C.
20036 Mr.'0. B. Lester Production Engineer Louisiana. Power'& Light Company 142 Delaronde Street New Orleans, Louisiana 70174 Lynian L. Jones, Jr., Esq.
Gillespie & Jones P. O. Box 9216 Metairie, Louisiana 70005 2
Luke Fontana, Esq.
Gillespie & Jones 824 Esplanade Avenue New Orleans, Louisiana 70116 Stephen M. Irving, Esq.
One American Place, Suite 1601 Baton Rouge, Louisiana 70825 Louisiana Office of Conservation ATTN: Administrator Nuclear Energy Division P. O. Box 14690 Baton Rouge, Louisiana 70808 President, Police Jury St. Charles Parrish l
, Hahnville, Louisiana 70057
'[
U. S. Environmental Protection Agency
'1 ATTN: EIS Coordinator Region VI Office 1201 Elm Street First International Building Dallas, Texas 75270 i
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ENCLOSURE REQUEST FOR ADDITIONAL INFORMATION 030.9 Regulatory Guide 1.70 Revision 3, Standard Fomat and Content of Safety Analysis Reports For Nuclear Power Plants, Section 7.1.1, Identification of Safety-Related Systems states " Identify the systems that"are identical to those of a nuclear power' plant of similar design that has recently re-ceived a construction permit or an opnrating license; identify those that are different and discuss the differences and their effects on safety-related systems." In conformance with Regulatory Guide 1.70, Section 7.1.1, provide a comparative discussion of the instrumentation and con-trol systems for Waterford with that of San Onofre Units 2 and 3 or a similar facility.
030.10 The statement in Section 7.1.2.2 that " Redundant channels of Class IE indicators are either isolated from the measurement loops, separated in accordance with IEEE 279-1971 or both," is not clear.
If this statement actually applies to redundant indicator channels that are classified Class IE, then the separation in accordance with the IEEE 279 requirements is com-pulsory and not a matter of choice. Clarify this apparent discrepancy.
030.11 As shown in Figure 5.1-3, the signals of four hot-leg temperature channels and four cold-leg temperature channels in each of the two loops are connect-ed to the Core Protection Calculators (CPCs). Presumably each of the four CPCs receives signals from one hot-leg and one. cold-leg temperature measure-ment channels in each of the two loops. Discuss how these signals are pro-cessed in the CPCs for measurement of AT power. Also, in Figure 5.1-3 the signal from " TIC" in the cold leg of loop 2B goes to CPC. This appears to be a control channel as shown in other cold legs; if so, it should be re-noved from CPC.
030.12 rour rasr.once to nuestien 030.5 st:t.,s hat the ine.r :3,tt e-i tion for the pressocias: 1 rni utilizes an ope c.3'.
a referenca leg systen. A con.:ern has been esisad by
.v;h e r
.J FWR canufneturer that in such a systaa, an c a ? i rt depressuriza.. ion a:cilaat rapid effervescer. e el >!.talvti hydrogen accuz.ulated in the upper p:rt of the ::n'!:s404 jt could blow water cut of the referance leg cni es'ne a~ 1ar;e IcVel error. To eliminate the possibility of such effact, bellows are used at the tap of the reference leg to pr: rete an interface seal. Discuss if this possible problem h.s 5 n considered in the selection of the level transuittera for Uaterford-3.
030.13 As shown in Table 7.2-1, the high tog power-level ; ip typass can be initiated by a =ccual switch. Key-operate;! : itches however are spec-ified for the bypassing of the T.hs and the local power density, ind the 2?S/ESFAS pressurizar pre: '" o trips.
Discuss why a key-operated switch is not used Eer :he high log power level trip bypass, and hev the access to the present manual switch is controlled and how it meets the re-quirements of IEEE 279. Also it eppears that the si;a in
~0 Tabic 7.2-1 should be less than (<) 10 % when the bypass is autonatically removed (cf. Section 7.2.1.1.1.2).
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WITNESS OIANG!s Once the affected unit declares 2 the emergency, their onsite organiratien and facilities 3 would be activated to the extent necesrary for that 4 emergency.
The unaffected unit would also man up their 5 emergency organization and activate their centers to get in 6 readiness sta tus, standby readiness status.
7 BY MR. SHOLLYa (Fesuming) 8 C
On pages 20 and 21 of the testimony you speak 9 briefly about the technical support center as being in the 10 remote shutdown location.
What sort of conditions might 11 render the THI-1 control room uninh abitable ?
12 Is there any projectad set of circumstances when 13 that might occur?
14 (Pause.)
15 A
(WITNESS GIANGI)
Offhand, I really cannot come up 16 with a condition that may render it uninhabitable.
I would 17 like to also point out that it has its emergency 18 recircula tion ventila tion system to isolate that portion of 19 the control tower ventilation to the control room.
But 20 offh and, no, I cannot really come up with a situation.
21 0
Is that more in the nature of a contingency?
22 A
(WITNESS GIANGI)
I'm sorry.
23 0
Is that more in the nature of a contingency 24 preparation of some sort or --
25 A
To the extent that in the event the control tower i
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2346
1u,046 1 building, for example, may have high airborne contamination 2 or g aseous or ; articulate conta.71 nation, the contrcl room 3 can go on its independent emergency recirculation vent 11atiCn system.
5 3R. ZAHLER:
Mr. Giangi, I think the question was 6 the position of a remote shutdown room, more of a 7 contingency, in the event that the control room becomes 8 uninhabitable.
g WITNESS GIANGIs I'm sorry.
Yes, it is.
10 BY 3R. SHOLLYs (Resuming) 11 0
Where is the remote shutdown location in 12 comparison with the control room ?
13 A
(WITNESS GIANGI)
It is below the control room, 14 322 elevation of the control tower building.
15 0
Can you conceive of any circumstances under which 16 the control room would be rendered uninhabitable that would 37 no ' also render the technical support center uninhat table?
18 DR. JORDAN:
I am a little confused.
There are 19 two words being used here, it seems to me.
One is the 20 technical support center, and the other is the alternate.
l 21 What was the other?
22 MR. ZAHLEBs Remote sh utdown f acility.
DR. JORDAN:
res.
23 MR. ZAHLER:
They are the same building.
The 24 25 technical support center is the name of the emergency i
ALDERSON REPORTING COMPANY,INC, j
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14,0n7 1 facility that is located in the area that is normally 2 designated in the plant as the remote shutdcun facility.
3 DR. JORDAN:
Are they identical?
4 dR. ZAHLE?4 Yes.
Ycu have to understand that the 5 names of the emergency operating f acilities are names d tring 8 the emergency plan.
They occupy areas in the plant that 7 have other names.
8 DR. JORDAN:
I see.
So the emergency operations 9 f acility then, you sa y --
10 5R. ZAHLER:
I am using the term unfortunately a 11 little loosely.
The emergency operating facility, for 12 example, is the TMI observation center 13 DR. JORDAN:
We are not talking about that now.
14 ER. ZAHLERa The technical support center, that is 15 an emergency response facility.
18 DR. JORDAN All right.
37 HR. ZAHLER:
That happens to be in the area 18 normally designated as the remote chutdown part of the plant.
19 DR. JORDAN:
Fine.
Thank you.
Mr. Sholly 20 understood this and was using the terms interchangeably, and 21 I did not not understand it.
22 Go ahead, Mr. Sholly.
23 MR. ZAHLER:
Could I have.the last question 24 repeated, the Reporter read it back7 25 MR. SHOLLI:
I can repeat it.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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SY ME. SH011Ti (Resuming) 2 C
Can you conceive of any circumstances under which 3 the control room would. te rendered uninhabitable which would 4 no t also render the technical support center uninhabitable?
5 A
('4ITNESS ROGAN)
Perhaps an oversimplified, highly 8 nonengineering response to that might be a fire in some of 7 the electronics which generates a great deal of smoke and i
8 for some short period of time would make it extremely g difficult to operate in the control room, but need not be 10 radiological 1r associated whatsoever.
11 Most of the' concerns revolve around a radiological 12 hazard, but one could construct, I am sure, a scenario 13 involving, for instance, a fire which may be short-term and 14 where you would still want to have the capability to monitor 15 the condition of the plant and so forth.
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Q Also, who functions as the coordinator of the 2 technical support cen.,Jr?
Is that a particular person?
And 3 if so, what is that pe r son ' t title no rmally?
4 A
( W I T.. E S S GIANGI)
Okay.
That is normally a senior 5 engineer, an engineering pe r son.t three of them designated 6 for that function, much the satce way as the emergency 7 director philosophy discussed earlier.
8 (Pause.)
g Q
On pages 38 and 39, discuss ~es the length of time 10 necessary to fully activate the offsite emergency support 11 organization.
And I believe -- am I not correct, it 12 references a figure of six hours as the total for that 13 portion -- f or that portion of the offsite support 14 organization which deals with radiation monitoring?
15 Is there any estimate available of how long it 16 would take for that portion to be fully operational?
17 A
(WITNESS GIANGI)
I am assuming you are talking 18 about the environmental assessment command center.
gg Q
Does it have --
20 A
(WITNESS GIANGI)
It is on --
21 Q
Doesn't that function include the offsite 22 radiation monitoring teams and the dose assessment and dose 23 projection capabilities that would be at the center?
24 A
(WITNESS GIANGI)
To the extent that that 25 supplements the onsite emergency organization within six ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345 i-v
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t 14,050 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />, that is correct.
Initially at the onret of the 2 emergency, the on-shif t capabilities allow us to dispatch 3 both onsite and offsite radiation monitoring teams as 4 necassary.
5 0
Okay.
What I am trying to get at is how long i
i 6 vo tid it tr.k e f ollowing the declaration of an emergency for 7 tue offsite center to be able to send -teams into the field?
8 In other words, I am assuming that the offsite organization g supplements the onsite.
I as trying to find out how long it 10 would take for that supplomentation process to begin.
11 A
(WITNESS GIANGI)
The requirement is six hours.
12 Q
I understand the requirement.
You cannot do any 13 better than that?
In other words, six hours is what you 14 have planned and projected?
15 A
(WITNESS GIANGI)
That is the extent that we rely 16 on the environmental assessment people to relieve, if you 17 will, the onshift and onsite.
They start the manning 18 process upon notification.
They become f ully activated and 19 functional -- they must be fully activated and functional 20 within six hours.
t 21 0
On pages 43 and u4, you provide brief descriptions 22 of some of the primary state response agencies and what 23 their general responsibilities are.
On page au you mention 24 Penn-DOT.
Can you elaborate a little bit more on what 25 Penn-DOT's role is as you understand it?
t F
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A (WITNESS FOGAN)
To the best of my understanding 2 of their contribution, it would clearly be in the areas.of 3 traf fic management, route clearances in the event of adverse 4 weather such as we discussed earlier today, certainly would 5 and should serve to coordinate mass transportation 6 requirements.
7s In general, the kindsof support we would expect 8 and wha t wt believe conceptually we would expect from o Penn-DOT would be in the areas of coordination and 10 management of transportation and transportation networks, 11 their basic responsibility day to day.
12 Q
On pages 45 and 86 --
13 MR. ZAHLER:
Mr. Shelly.
Mr. Chairman, could I 14 have a two-minute break ?
I received a notice that there is 15 a very important phone call for me to take.
If we could 16 just take tv) minutes, I will be right back.
17 CHAIRMAN SMITH:
Yes.
18 ER. ZAHLEB Thank you.
1g (Recess.)
20 ER. ZAHLER:
Thank you, Mr. Chairman.
21 (Counsel for ANGRY conferring.)
22 CHAIRMAN SMITH:
Was there -
proceed.
23 MR. SHOLLY:
Okay.
24 BY MR. SHOLLYa (Resuming) 25 Q
On pages 45 and 46 you deal witt t agencies ALDERSoN REPORTING COMPANY,INC, 400 VIRG4NIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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t 14,052 1 offsite that I.icensee might rely upon in the event of an 2 emergency.
Cne of the facilities listed is Hershey Medical 3 Center.
Isn't it true that the Eerrhey Medical Center is 4 within the plume exposurt E?Z?
5 A
(WITNESS GIANGI)
It is my understanding it is 6 just within the plume exposure EPZ.
7 0
How would Hershey 'edical Center fulfil its d
8 support role if the EPZ is evacuated?
9 A
(WITNESS ROGAN)
Let me tak e the first part of 10 wh at I believe is a two part answer.
And I will ask Mr.
11 Giangi to follow up.
12 The natural inclination in discussion of 13 evacuation is first that it's the entire 360 degrees, and 14 second it is the entire ten miles.
It is not at all clear 15 th at either in fact would be the case, or even probably be 18 the case.
And that would depend very much upon a number of 17 conditions we have discussed here, including meteorological 18 data, plume exposure, and so on.
19 0
Let us assume for the purpose of your answer that 20 it is a 360-degree evacuation of the entire plume EPZ.
21 Proceed from there.
22 A
(WITN ESS BOGAN )
Ihen I think I would like to have 23 a moment. to consult with a map, because I am -- I am not 24 exactly sure that Hershey Medical Center is in fact in the 25 ten-mile EPZ.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE.,5.W WASHINGTON, D.C. 20024 (202) 554 2346
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1 Q
Hershey Medical Centar is located near the i
2 intersection of Foute 19 and Foute 232, if that is en the 3 map.
4 MR. SHOLLYs dr. Chairman, there is a rap in front 5 of the bench.
It looks like a topographic map.
e CHAIRMAN SMITH That is not the ten-mile one, 7 though, is it.
8 Incidentally, let's.co off the reccrd.
t g
(Discussion off the record. )
to CHAIBHAN SMITH:
Are we ready to proceed?
v 11 I.think we were headed toward a nonresponsive 12 answer.
I think you are required to assume in your question 13 that the Hershey Medical Center is within the plume EPZ.
14 WITNESS ROGANs Given that assumption, which I 15 clearly have been unable to establish yet, my answer would 16 have to be that, insofar as it remains a valid and viable 17 institution to use, we would use it.
The fallback position 18 is to use the services of the Radiation Management tg Corporation in conjunction with the University of 20 Pennsylvania Medical Center, which is clearly beyond the 21 ten-mile EPZ.
22 BY HR. SHOLLY :
(Resuming) 23 0
Those facilities are a backup, then, for the 24 medical center?
25 A
(VITNESS RCGAN)
We have -- let me answer that by I
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 564 2346
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14,054 1 saying, to the extent of my knowledge, which is we have a
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2 contractual agreement with FMC, and I would have to confirm
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3 all the details.
4 FR. S? LLY:
Has anyone been able to confirm the 5 loca tion, or is tha t necessary?
6 CHAIRMAN SMITH:
Well, you -- I think you sort of 7 made it irrelevant when you asked your last question.
Now I 8 do not know what your next question is.
g MR. SHOLLYs Very well.
10 CHAIRMAN SMITH:
The state of the testimony is now it that it is almo'st exactly in or out or something.
It is on 12 -- did you say your memory is -- did you want to clarify his 13 testimony on it?
14 Dr. Little is pointing out on the PEMA map the 15 ten-mile circle seems to cut right through the facility, the 18 cashier 's of fice, probably.
17 WITNESS ROGAN:
Our understanding was that it was 18 in a location such that it could reasonably be expected to 19 be usable.
However, again I would restate that we also have 20 a continuing contractual agreement with RMC, Radiation 21 Management Corporation.
And I believe our testimony 22 indicates that they also have certain f acilities available to handle radiation casualties.
23 24 Clearly, the Hershey Medical Cente r is the better 25 approach to the extent that it remains available.
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WITNESS GIANG!s Chairman Smith, I would like to b
2 just add that the plume expcsure pathway,'F?Z, on the PEMA 3 map. is really the white circ'le.-
I am not sure if tha t was 4 made clear.
5 CHAIRMAN SEITH:
Yes.
My reference was to'the 6 circle, the ten-mile radius circle.
7 WITNESS 30GANs Well --
8 (Counsel handing document to witness.)
e (Witnesses reviewing document.)
10 MB. ZAHLER:
Mr. Chairman, based on my. view of the 11 PEEA map, Licensee will stipulate that Hershey Medical 12 Center is within the plume exposure pathway, EPZ.
13 HR. SHOLLYa Tha t -- that is quite satisfactory.
14 BY MR. SHOLLY:
(Pesuming) 15 0
On page 69 Licensee discusses the meteorological 16 data and notes computer-maintained by Digital Graphics, 17 which stores meteorological data for the site and updates 18 its file every four hours.
How frequently -- first of all, is is there is data storage facility onsite for the I
20 meteorological inf ormation ?
21 A
(WITNESS GIANGI)
To the best of my knowledge, 22 there are three meteorological parameters that are in the 23 control room.
That is wind range, vind speed, and the delta 24 T, the change in temperature difference between 33 and the 25 50-foot elevation, which are on strip charts.
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The question can best be-answered by Mr. Eiethel, 2 who I understand will be tectifying either today or 3 tomorrow.
4 Q
Nove tu pages 79 and 6 0.'
The testi:ony is 5 addressing the dispatch of radiation monitoring teams.
How 6 many radiation monitoring teams are available immediately
'7 upon a declaration of an emergency or shortly thereaf ter?
8 A
(WITNESS GIANGI)
THI has the capability, as the 9 emergency plan states, to dispatch two radia tion monitoring 10 teams as necessary within a half-hour and get the.results 11 back.
12
- Er. Sholly, as a correction, I would like to also 13 add to my last answer.
I believe I said wind rance, wind 14 speed, and delta T.
There is also wind direction.
15 0
How many more teams would be available at some 18 time f ollowing the declaration of the emergency?
How.many 17 teams would it be and when would they become available?
18 A
(WITNESS GIANGI)
Within ene hour we have the la Capabilities of an additional three radiological control 20 technicians that would augment the onsite emergency l
1 21 organiration.
To the extent the radiation monitoring teams l
- 22. are necessary, looking at the priorities of the scenario, 23 certainly, they will decide whether inplant or offsite
- 24. sur~reys are warranted.
25 The three radiological control technicians could P
ALDERSoN REPORTING COMPANY,INC, 400 VIRGNA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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- 1. conceivably, at the very max, make up,another three teams.~
2 0
~4ould it be reasonable to arrume that in the event i
3 of_ a general-emargency -- I believe one of the documents, 4 perhaps it is tne emergency plan, indicates that there will 5 be a greater measurement on off site.
'dould it be reasonable 6 to assume, then, that in at least many cases those
- 7. additional teams would be dispatched, to the field?
8 A
(WITNESS GIANGI)
No, it would-not.
g MR. SECLLY:
Could I ha ve a moment, please, Mr.
10 Chairman.
11 (Pause.)
12 13 14 15 16 i
17 18 19 20 21 22 23 24 25 ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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WITNESS ROGAN:
Ur. Sholly, could you restate that 2 last question sgein, please?
3 PY MR. ShCLLY:
(Pesuming) 4 Q
It is my recollection -- and like I said, I am not 5 sure where I read this, whether it is within Licensee's 6 emergency plan or perhaps within NUREG-0654, but it 7 indicates on the declaration of a general emergency there is 8 a shif t in amphasis in radiation monitoring to offsite 9 areas.
10 And I am wondering if under such conditions it 11 might be reasonable to assume that these three additional 12 technicians might be dispatched, forming additional teams in 13 the field.
14 A
(WITNESS ROGAN)
It strikes me -- and I may he 15 misunderstanding, but I think we are mixing two issues.
The 16 first is, our understanding of your question was would all 17 of the radiation tech people who would be supplementing th e 18 onshif t people in one hour assume the role of offsite 19 monitoring teams, to which the answer was no, because there l
20 will still be onsite requirements and there will still be -
21 requirements f or radiation control and protective programs 22 for the emergency response people in the plant.
23 So the distribution of the total technically 24 qualified personnel staffing will have to be determined on 25 the basis of the requirements of the scenario.
- However, 1
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
i 14,059 1 what you perhaps did read in the energency plan is that in 2 the event of the general e:ergency the anvironcental.
3' assessment center is activated, as is also for the site
}
c 4 emergency, and the shifting ~of responsibility for offsite 5 emergency sonitoring shifts from the radiological assessment 6 coordinator in the control room to the environmental 7 assessment coordina tor off site a t the ECC location.
8 And he has the capability then to supplement 9 whatever the onsite capability had, plus his own integral 10 orgsnization capabilities.
And to the extent that you vould 11 interpret that as a shift in emphasis and a shift in the 12 amount of effort that is being put in that direction, that i
13 is clearly true.
14 C
Perhaps I was not being clear with my question.
15 How many teams would the off site environmental assessment 16 center, how many teams does that f acility have available to 17 do offsite monitoring once it is activa ted ?
t 18 A
(WITNESS ROGAN)
I think the person who is most 39 qualified to answer that is Mr. Riethel, the environmental 20 assessment coordinator.
21 A
(WIT 3ESS GIANGI)
Mr. Sholly, if I could clarify 22 my response, I said no.
My understanding of your question f
23 was such tha t in the general emergency would you 24 categorically expect that all the radiological control 25 technicians that we mentioned -- for example, the three that l
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i 1 were onsite, augmented with the three additional -- within 2 one hour, would all of th ose personnel be on the radiation 3 monitoring teams.
4 Yy response to tha t was no.
However, let me 5 clarify by saying that you are correct as to Licensee's 8 testimony suggesting, in going to a general emergency, there 7 is a greater emphasis placed on off site monitoring to the 8 extent that perhaps another team or two, depending again on P
9 the scenario, would be warranted.
10 I also want to point out that during a general 11 emergency, as well as a site emergency perhaps, there is 12 also some need for onsite radiological controls in the area 13 of access control, surveying, analyses, and other monitoring 14 areas.
15-Q I think it was perhaps imprecision in the 16 terminology that got us fouled up.
I think I understand it 17 no w.
18 One final question.
Page 97, the testimony 19 references the use of N AWAS, N-A-W-A-S, system as a backup 20 to contacting PEMA by telephone.
Does the NAWAS system 21 provide a direct communications link between the Licensee 22 and PEMA, or does that go th rough intermediate steps?
m A
(WITNESS GIANGI)
The NAWAS, or the National 24 Warning System, line is really a dedica ted line using radio 25 procedures.
It does have 13 drops, one drop of which goes ALDERSoN REPORTING CoWPANY. INC.
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14,061 1 to the Pennsylvania Energency !anagement scency EOC, as well 2 as the Three Mile Island e:ergency control center.
3 G
In other words, scmeone at the site, at the plant, 4 would pick up this NAWAS line and use it te contact people.
5 He would speak directly with PEXA and not with a third 6 party?
7 A
(WITNESS GIANGI)
He would pick up the NAWAS 8 line.
It is voice activated and you would says This is g Three Mile Island requesting Pennsylvania Emergency 10 Hanagement Agency to come on the line.
Please respond.
l 1
1 It And PEMA would have its line on and would hear 12 this and would transmit its information.
13 (Pause.)
14 HR. SHOLLY.
That is the end of ANGRY's 15 cross-examination of this panel, Mr. Chairman.
I 16 CHAIRMAN SMITH Tr. Aamodt?
17 5B. AAMODT.
I have some questions I would like to 18 ask myself, and my wife also has some questions should would 1glike to ask following.
20 BY ER. AAMODTs 21 Q
Referring to your testimony, to the Licensee 's 22 te stim on y -- I am going to ask all my questions citing pages 23 and specific items.
So perhaps you would like to follow 24 me.
I would like to refer first to page 60, question
~
25 ALDER $oN REPORTING COMPANY,INC, 400 VIRGIN (A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
14,062 1 us, and page 61, question 37, the answers to those 2 questions.
You state that:
"*he operational line permits 3 an unimpeded discussion of plant parameter systats, status, 4 core conditions, et cetera," and that, "this capability 5 enhances management f unction and decisionmaking processes."
6 Would you define the use of the word " enhances"?
7 A
(WITNESS ROGAN)
Yes.
In the context in which that particular line or 8 that statement is made, it 9 network permits representatives of the engineering staff at to the technical support center, the operational support 11 personnel in the OSC, the emergency support director in the 12 emergency operating facility, representatives of the 13 alternate f acility, and representatives of Babcock E Wilcox 14 in lynchburg, Virginia, to in effect conference call with 15 all parties or some parties, directly with the emergency 16 director in the control room to resolve specific issues 37 which may be at hand and for which he is seeking 18 assistance.
1g In effect, it provides the same enhancemen't of 20 mission accomplishment as vould a conference call in any 21 other business proceeding.
22 0
Then the implicas. 'n is there is a significant 23 enhancement in the ability to communicate relative to that 24 situation, in ef f ect, to the accident at Unit 27 25 A
(WITNESS ROGAN)
I am sorry, I'm going to have to
)
ALDER 8oN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W,, WASHINGTON, D.C. 20024 (202) 554 2345
l 14,063 1 ask you to restate the question.
]
2 Q
Then what you a re suggesting is that is an 3 enhancement in the ability to communicate offsite relative 4 to the situstion that-was in eff ect during the accident at 5 Unit 2?
6 A
(WITNESS ROGAN)
That is not necessarily implied 7 nor properly inferred from that statement.
It is a proper 8 -- I believe a proper use of the word " enhancement" in the 9 sense that, without regard to the Unit 2 accident, the
~
10 ability to conference call to several stations, all of which 11 might be involved in a decisionmaking process with regard to 12 plant conditions, is an enhancement in the sense that it is 13 an improvement over not having that particular network.
14 0
I believe that the several investigations into the 15 accident pointed to a difficulty in communication between 16 the various -- among the various interested parties.
Is 17 that your understanding?
18 A
(WITNESS ROGAN)
I must admit, I cannot recall a 1g specific statement to that effect.
But then, it has been 20 some time since I have read the exact reports.
21 0
Mr. Giangi?
22 A
(WITNESS GIANGI)
Yes, Mr. Aamodt, that was one 23 recommendation.
Exactly how it was worded I believe was not 24 quite the way you said.
25 0
No, I am not implying anything specific there, ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564 2345
i 4
14,06u i
1 only that a problem did -- that this was pointed out to be a 2 problem.
3 A
(WITNESS GIANGI)
Yez, sir.
4 0
And.I inferred, then, that when you said the 5 system was enhanced, that that enhancement sprang from a 6 recognized need for an increased ability to communicate 7 off site. - Is that true?
8 A
(WITNESS GIANGI)
No.
Ihe word " enhanced" -- and
{
g I may even have been the one who chose the word -- was 10 really meant to imply that accident management functions 11 would be facilitated and perhaps be expedited, if you will, 12 with this dedicated line, namely the operation line.
13 0
Then you are saying that accident management, 14 insofar as it relates to offsite communications, has been 15 enhanced, in your judgment, by installing this f acility, 18 this line, this capability?
17 A
(WITNESS GIANGI)
This operation line is really an 18 in-house function.
It deals with the operational 1pinformation from the emergency directer in one facility to 20 the operations support center, to the technical support 21 ce n t er, a s w ell as --
l 22 0
To BCW at Lynchburg.
23 A
(WITNESS GIANGI)
That is correct, BCW is also 24 -
25 0
An d th e re aso n -- is it not true that the reason P
ALDERSoN REPORTING COMPANY,INC, 400 VIAGNA AVE., S.W WASHINGTON. D.C, 20024 (202) 564 2346 m
10,065 1 for a dedicated lina to Lynchburo'is to have access to 2 information tha t migh t be helpful in the citigation of an 3 accident ?
4 A
(WITN ESS GI ANGI)
Yes, sir, it is.
5 Q
In view of the fact that no fewer than 19 6 references are made to telephone calls in NUREG-0600 7 discussion on technical support, pages 1316 through 1335, 8 one call being not less than 25 minutes in duration, it is 9 very difficult to determine from the discussion exactly how
?
10 long the discussions are, and no reference is made to 11 difficulty in obtaining an open line.
l 12 Yes?
13 MR. ZAHLER:
Is there a question pending?
14 MR. AAMODT ies, there is a question.
I would 15 not be speaking if there were not.
16 BY MR. AAMODTa (Resuming) 17 Q
dy question here is the concern of ycur question 18 and statement here is an increased ability to communicate 19 vital inf ormation in the eff ort to mitigate the consequences 20 of an accident; is that true?
21 A
(WITNESS TS AGG ARIS )
Mr. Aamodt 22 0
You just did say yes to that, I believe.
23 A
(WITNESS TSAGGABIS)
I believe Mr. Giangi answered 24 yes to that.
25 0
Yes.
That being the case, it appears from what is ALDER $oN REPORTING CowANY,INC, 400 VIRGIN 4A AVE., S.W., WASHINGTON, D.C. 20024 (202) 664 2346
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14,066 1 availabis from the investication that the difficulty has not 2 been the ability f or one person to talk to ancther.
- he 3 difficulty seems te have been adequate communication, the 4 distinction being not words but the informatien actually 5 passed through.
e One can speak, but one can not communicate.
Do 7 you understand the difference?
8 I am wondering whether in any way this addresses 9 that problem?
10 A
(WITNESS ROGAN)
The particular network you 11 suggested as the target of this particular line of 12 questioning is in fact a voice netwcrk and subject to th e 13 same communications difficulties of any voice communication 14 between two human beings.
To that extent, one only hopes 15 that the people who are manning the telephones are 16 technically competent to both express themselves in an 17 articulate way and to understand the data that is being 18 transmitted to them.
39 However, I think it also is indicated quite 20 pointedly in our testimony that we rely on a great deal more 21 than telephone communication to transnit data over dedicated 22 lines and data display links.
23 0
Fine.
Was the -- oh, here.
I would like to 24 pursue that, that display capability.
Would you like to 25 comment on what you think to be -- I am not sure h e w -- then ALDER $oN REPORTING COMPANY,INC, 400 VIRGIN!A AVE, S.W, WASHINGTON. D.C. 20024 (202) 554-2345
14,067 1 if I understand you correctly, you did say that offcite 2 display capability.f or pertinent plant paraneters enhances 3 the ability to communicate in the situation I described?
4 A
('41TNESS ROGAN )
I did say that, yes.
5 Q
Yes.
On page 62, line 2, you say, quote:
"This 6 establishes a reliable channel of communication f or in-depth 7 diagnostic and corrective engineering assistance between the 8 f acility operator and thu nuclear steam supply system e vendor."
10 Is this a voice channel?
tt A
(WITNESS ROGAN)
I believe this particular line is 12 in fact a voice channel.
13 0
Then in the context of our earlier discussion you 14 would say it is not reliable?
15 ER. ZAHLERt Objection.
16 CHAIREAN SMITHS That was phrased as a question.
17 MR. ZAHLER4 He was going 18 CHAIRMAN SMITHS I do not think you got the 1g inflection at the end.
MR. AAEODT It was a question, that's right, 20 21 sir.
22 HR. IAHLER:
I may have jum ped too early.
I 23 withdraw the objection.
CH AIRM AN SEITH Well, it was on the boundary.
24 25 But we vill take it as a question, then.
It was intended as ALDERSoN REPoRTWG COMPANY,INC, 400 VIRGMA AVE, S.W. WASHMGTON, DA 20024 (202) 864 2346
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14,068 1 a question.
2 WITNESS RCGAN:
Let me then say that, no, I would i
3 not say that the Parsippany-PC'J line is an unreliable source 4 of communications, not do I believe that I said so in my S previous comments.
6 BY HR. AAMODTs (Resuming) 7 Q
I did not ask you if it was an unreliable line.
I i
8 asked you if it was a reliable line.
g A
(WITNESS ROGAN)
And I believe to the extent that 10 any such communication network is reliable, it is reliable, 11 Yes-12 Q
And did you not earlier say that subject to all of r
13 the difficulties of voice communication that could be, that 14 one could or could not communicate?
15 A
(WITNESS ROGAN)
Indeed I did.
But let me also 16 extend the point which you apparently have chosen not to 17 raise, which is tha t most of these terminals we also have 18 hard copy telecopiers, which is intended to transmit is specific data.
2g C
That -- tha t is of great interest to me and an 21 area I wanted to pursue.
How many parameters are read out 22 on the telecopier?
23 A
(WITNESS BOGAN)
I believe there is a technical 24 disconnect between the question you asked and the mechanics 25 ve are describing in telecopier can copy as much data as the t
ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE S.W, WASHINGTON, D.C. 20024 (202) 564-2345
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14,069 1 sender chooses to out into the telecopier.
The data link, 2 on the other hand, display: parameters based en a specific 3 sof tware program.
4 0
Yes, I acknowledge the f act that the telecopier is 5not a displayer of parameters.
It is a mechanism for e transmitting data relating to parameters.
And also, 7 apparently f rom what you said, it also is fed in by a 8 person, as opposed to an instrument; is that correct?
9 A
(WITNESS ROGAN)
That is correct.
10 Q
So it is subject to the same errors or similar 11 errors to voice communication?
12 A
(WITNESS ROGAN)
If -- if the issue is whether in 13 fact the communications system which relies upon human input 14 at both ends is subject to human error, then I certainly 15 concur in that.
16 0
Thank you.
17 On page 62, question 49, is this communication --
18 are the communications -- or is the telephone mentioned ggthere a dedicated line?
20 A
(WITNESS GIANGI)
No, it is not.
It is the same 21 phon e line, that conventional Bell telephone.
It is l
22 normally used to contact a county dispatcher at Dauphin 23 County.
I believe that is 911.
l 24 0
Would you clarify this fCr me, then?
Is that the 25 same line that is used for notification of Dauphin County in i
1 ALDERSoN REPORTING COMPANY,INC, 400 VIRGIN 1A AVE., S.W., WASHINGTON D.C. 20024 (202) $54 2346
=
14,070 1 the event of an emergency?
2 A
(WITNESE GIANGI)
Yes, sir.
3 C
And the transmission of tha t telephone call could 4 be impeded by a busy signal?
5 A
(WITNESS GIANGI)
The transmission of that phone 6 call ?
7 Q
Could be prevented by a busy signal.
In other 8 words, the circuit could be busy.
There could be an g overload of circuitry in the area on the line on which you 10 are notifying Dauphin County in the event of an emergency.
11 A
(WITNESS GIANGI)
I am not sure whether the 12 Dauphin County dispatcher can take in a certain amount of 13 calls beyond the no rmal Bell Telephone amount.
14 0
Thank you.
15 Page 63, question 51A.
51, the answer -- the 16 question is:
"The two communications systems are the NRC 17 emergency notification system (ENC) and the NEC health 3
18 physics network line."
Concerning the purpose of the tgsubject line, you states "To provide reliable notification 20 and communication of operational plant data."
21 Does -- I am concerned again about the reliability 22 of this function.
Are we talking about dedicated lines this 23 time again or are we not?
24 A
(WITNESS GIANGI)
Yes, sir, we are.
25 0
Good.
ALDERSoN REPORTING COMPANY,INC.
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14,071 1
Page 72, question 61 and 62.
2 (Paure.)
3 C
In the third paracraph, the answer to question 61, 4 you. say, quotsd. "The second method requires the plant 5 operators to compare plant parameters and conditions to the 6 energency action levels iden tified in the ETIT's when an 7 action level," and so on.
8 Do the EAL's comprise a closed set?
Do you know 9 what I mean by "a closed set"?
10 A
(WITNESS GIANGI)
I am sorry, could you please 11 repeat that, your latter.
12 Q
The EEL's -- the EAL's, do they comprise a closed 13 set?
Are they, in other words, the universe of emergency 1
14 action levels in your judgment are -- are all of the 15 possible emergency action levels included in those you 16 specif y?
17 A
(RITNESS TS AGG ARIE )
Mr. Aamodt, I would say yes, 18 because one of the emergency action levels gives 19 discretionary judgment to the shift supervisor or emergency 20 director that if the particular event does not fall into a 21 specified initiating condition he has in his judgment the 12 ability to declare the event.
You should also recognize that those EAL's were 23 24 developed to attempt to envelope all possible transients.
25 0
But you yourself just said, "in an a ttempt to I
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564 2345
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t 1u,072'
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1 envelope."
Did you succeed in envelocing then?
2 A
(W!!.4ESS TSA3GAEII)
! do not think I an 9
3 personally qualified to answer that.
I did not develop the 4 initiating conditione in Appendix to tUEEG-0652...
i l
5 C
With -- is anyone qualified to answer tha t?
6.
A (WITNESS TSAGGARIS)
I would say that the 5
7 individual who developed Appendix I would perhaps he better-r 8 able to anseer that q'lestion.
-g CHAI3 TAN S!ITH:
Well now, just as a natter of --
l 10 of logic, if you iisve one which allevs for the unlisted, 11 then the plancer must have assumed that you have not 12 enveloped them all.
- 13 WITNESS TSAGGAEIS:
Well, I think it would be 14 dif ficcit to come up with a list.
A list vocid be extremely 15 long if you tried to come up with every particular piece of
(
16 equipment tha t could fail in the plant and then develop an r
17 action level.
18 The attempt that was used in developing the 19 specific action levels for the Three Mile Island site was 20 first using the guidance in 065u, and second to cone up with l
21 parameter indications, which would be the manifestation of a 22 varied number of equipment f ailures.
t k
23 For instance, the containment pressure indicator.
24 That particular action level could be the manif estation of a 25 variety of equipment failures and accident scenarios.
The nossoM MPomWG CoWPW. WC, 400 vmGesA AVE., S.W. WASHeNGioN. o.C. 20024 (20:D $64-2348
14,073 1 key thing is that all of those would impact on that 2 containnent pressure.
3 It is true that our emergency plan, as does 0653, 4 gives the emergency training, through his training, his 5 simulator training, his training on emergency planning, and 6 the training in the philosophy, to assess and declare even 7 events of a minor nature, a discretionary judgment to 8 declare an emergency.
g
- dT.TNESS GI ANGIs Chairman Smith, the answer to 10 your question is yes, that is correct.
By virtue of having 11 a catch-all, if you will, emergency action level, it is by 12 our own admission that there may be some action levels that 13 have just not been incorpora ted.
14 W'
feel that the key parameters, however, and the 15 guidance used in Appendin 1 to -654 have been incorporated.
16 BY MR. NORMAN:
(Resuming) 17 0
My concern obviously is one of adequacy there.
18 Mr. Tsaqqaris, you were involved with the Unit 2 gg at the time of the accident, were you not?
Or you were with 20 Metropolitan Edison at the time of the accident at Tnree 21 Mile Island?
22 A
(WITNESS TSAGGABIS)
Yes, I was.
23 Q
At the time of that event, did the -- did the 24 shif t supervisor or some other relatively equivalent person
- 25. have the same discretionary authority relative to announcing ALDERSoN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., W4iiNGToN. D.C. 20024 (202) 554-2346
14,074 1 or notifying relative to an accident?
2 A
(WITNESS TSAGGAFIS)
First-of all, let me state 3 that I was not there personally and cannot speak for the 4 shif t supervisor.
5 0
There must have been a plan, however.
As I recall 6 your testimony' earlier, you were involved in that?
7 A
(WITNESS TSAGGARIS)
Yes, in the emergency plan, 8 not recalling the specific emergency action levels..
Since g it has been several years, I would hesitate to answer that.
10 I cannot recall whether the discretionary judgment was 11 specifically there in writing.
12 0
But wasn't the catch-all to catch those outside ia the envelope, giving someone in the operating room the 14 discretionary ability to say, we have an accident?
15 A
(EITNESS TSAGGARIST Mr. Aamodt, I believe I just 16 said I could not recall that.
17 0
All right.
18 Hr. Giangi, do you know the answer to that?
19 A
(WITNESS GIANGI)
No, I really d'o not.
20 Q
Okay, thanks.
CHAIRMAN SMITH:
Give us just a moment, would you 21 22 please.
HR. AAMODT:.
Yes, sir.
23 (Board conferring.)
24 CHAIRMAN SMITHz Proceed, Mr. Aamodt.
25 ALDER 5oN REPORTING COMPANY, INC, 400 VIRGINIA AVE., S.W., WASHINGTON 0.C. 20024 (202) 554-2345
14,075 1
BY MR. AAMODT:
(Resuming) 2 0
Might I request of the Licensee the apprcpriate
~
3 material here relative to action levels at the the of the 4 Unit 2 accident?
5
'MR.
ZAHLER:
Without a further showing 6
ME. AAHODT:
The thing I am concerned about here 7 is it was two and a half hours from the onset of the 8 accident until anybody was notified.
And I would like to 9 know what has changed to ensure that the Licensee does a 10 better job this time.
11 I think that is appropriate, is it not, Mr.
12 Chairman?
13 HR. ZAHLERs That is a very different question.
I 14 velcome the panel to answer that.
15 EY MR. AA.MODT (Resuming) 16 0
Specifically with regard to action levels and the 17 responsibility of the shif t supervisor, if we do not know 18 what they did before, it is hard for me to understand how 19 you can tell me now how it changed.
20 A
(WITNESS TSAGGARIS)
I did not say in my previone 21 response that I did not know what they did before.
22 answered tha t I could not recall whether the shift 23 supervisor had discretionary judgment.
24 What I can say is that the emergency plan prior to 25 the THI-2 accident, without reca lling the specific action l
ALDERSoN REPORTING COMPANY,INC, l
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14,076 1 levels, had a significantly less number of action levels for 2 each accident category.
The philosophy at that. time, again 3 going on my reccliection, was much more of a confirmatory 4 nature prior to declaration, some instrument parameters 5 indicated in the action levels but some confirmatory 6 measurements required.
And I would have to go back and 7 check ' that.
8 I think the key thing now, and wha t has improved, g are several things.
Numbe one, the action levels are much 10 more inclusive f ollowing the Appendix 1 guid eline, the 11 philosophr of a graded response and declaring even events of 12 a minor nature, especially in the unusual event category, 13 which serves to get organizations and personnel mobilized, 14 in the event that the situation were to degrade further.
15 I think that is the significant philosophy that 16 comes through in 0654, and the action levels reflect tha t.
37 Secondly, the training is substantially upgraded.
18 And we discussed the training program, I believe yesterday, 1g a little bit.
The communications systems -- we have 20 discussed that -- have been upgraded.
Facilitie$; have been 21 upgraded, and the organizational approach has been 22 upgraded.
23 0
I am -- I certainly acknowledge that f rom h a ving 24 read the testimony.
25 I do not want to belabor this, but the area in ALDER $oN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 564 2346
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14,077 1 which I am concerned is this.
And perhaps you can help me.
2 Perhaps the licensee can provide the inf orzation if you do 3 not have it.
We will check that you don't.
4 dany of those who were involved in the 5 investigations -- there were several who commen ted, such as 8 former Governor Peterson of Delaware, in his minority view 7 in the President's Commission report -- stated that it was 8 their judgment that there would never be another accident 9 like this for guarding against inadequately.
The next 10 accident will be one coming from a to tally unexpected it quarter.
12 Your early -- the inferences from the questions I 13 have cited here, questions 61 and ' 2, is tha t we do not have 14 a closed set of EAL's, and insofar as the set is not closed 15 ve are subject to, or let's say the probability of Mr.
16 Peterson's concern materializing is enhanced.
And you are 17 sa ying, cover all of those elements outside the envelope by 18 giving the shift supervisor discretionary power.
19 My question is, at the time of -- and now, when we 20 ge t into discretionary things, as opposed to a distinct line l
l 21 of command in the Army, for example, implicit in l
22 discretionary judgmen ts are delays.
1 23 The Unit 2 accident my question only is, can i
l 24 you help me understand how the use of the discretionary 25 accident has been add ressed ?
~
ALDERSoN REPORTING COMPANY,INC.
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14,078
'1 A
(WITNESS TSAGGARIS)
First of all -- and I will 2 reiterate, T cannot speak for the chift superviser and I 3 cannot speak for the delay in declaring the energancy.
I 4 was not there.
I de not know what was going thrcuch the 5 shif t supervisor 's mind.
6 I do know, and as I have stated, a comparison of 7 th e pla nning phases and the philosophy towards planning has 8 drastically changed.
The training has drastically changed.
g The shif t supervisor is relied upon on a daily basis to to exercise discretionary judgment, whether it is in an 11 accident situation or a routine situa tion.
12 I feel that the envelope is sufficiently.large, 13 and in those cases where some discretionary judgment should 14 be used by the shift supervisor it is very clear to him tha t 15 there is a problem at the plant and he would not hesitate to 16 declare an emergency.
That is the way we approach the 17 training and the drills, and I myself am satisfied.
18 HR. AAMODTs I do not want to belabor this, j
19 either.
I only have one more question or comment relative I
20 to this, and tha t is, I think this is an element missing in 21 your testimony.
And I wonde r -- or a t least, I have not 22 found it in any -- tied down in any of the reading I have 23 done, and I wonder if I might receive from the Licensee a 24 bounding of the discretionary powers of the shift supervisor 25 or his equivalent at the time of Unit 2.
Wo uld that be 4
l l
ALDERSoN REPORTING COMPANY,INC.
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1u,079 1 appropriate?
2 CHAIE2AN SMITH:
I guess you already indicated 3 that that was an appropriat? line of inquiry.
Now he is 4 asking for the inf ormation.
5 MR. ZAHLER:
I am not sure his que stion -- his 6 question was appropriate to the panel.
But what he is nov 7asking to be produred is the bounding of discretion that the 8 shif t supervisor had during the time of the Unit 2 9 accident.
And I do not see a showing of relevance between 10 that information and his inquiry with respect to the I
11 adequacy of the present plan.
12 The panel has described the difference between the 13 present plan and the old plan and the reasons why they 14 conclude that it is adeq ua te.
Whatever discretion the shif t 15 supervisor did er did not have at the Unit 2 accident is 16 irrelevant to whether the presen t plan is ad equate.
I do e
17 no t see how that furthers the inquiry one bit.
18 CHAIRMAN SMITH Does the direct testimony purport tg to compare the present EAL's with the former EAL's?
20 MR. AAMODT:
It does not, Mr. Smith.
l 21 (Roard conferring.)
22 CHAIEMAN SMITH:
We vill defer ruling on it.
23 MR. AAMODT I beg your pardon?
i l
24 CHAIRMAN SMITHS We vill defer ruling on it.
We we are not sure where it is going to lead.
25 do not ALDERSoN REPORTING COMPANY,INC.
400 VIRGINtA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
14,080 1
MS. AAMODT:
Might I address that just very 2 briefly?
3 CHAIEMAN SMITH:
Yes, it might be helpful.
4 MR. AAMODT I am only addressing one very narrow, 5 I think critical, element.
And that is, insofar as somebody 6 responsible for notifications has the ability to act with 7 discretion, there is the opportunity for not meeting, for 8 exam ple, that two-minute response you mentioned ye ste rda y.
g And all I would like to know is -- we had a 10 similar situation earlier with the ability to use 11 discre tio n.
And wha t a re there -- what additional 12 constraints now can we infer, knowing what they are doing 13 now, to say that that problem has gone away?
14 CHAIRMAN SMITH:
Okay.
As I said, we will rule.
15 MR. AAMODTa Thank you, sir.
16 CHAIRMAN SMITHz Unless somebody has the answer 17 right now and can just give it.
18 MR. ZAHLER As to the discretion available to the 19 shif t supervisor at the Unit 2 accide'nt?
To tell you the 20 truth, I am not precisely sure what it is that Mr. Aamod.t is 21 looking for.
22 I might pose one question to the panel that may 23 help, if that is okay.
I do not know whether it will.
24 Assume the Unit 2 accident were to happen under 25 the new emergency plan.
What would be the first emergency l
1 ALDER 8oN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
14,081 1 action level that would be tripped and when would you expect 2 that to occur?
3 WITNESS TSAGGARIS.
Going back to my knowledge of 4 the Unit 2 accident, I would say that within the first two 5 minu tes, if I can take a quick look at the emergency plan, 6 that an unusual event would have been declared, because I 7 believe the initiating condition one, reacto r trip followed 8 by an unplanned automatic ECCS initiation, that did occur.
9 That is one of the action levels.
10 So I would expect under the new plan that an 11 unusual event would be declared immediately.
12 BY MR. AAMODTt (Resuming) 13 C
Yes.
You in a sense prove my point.
What de are 14 saying -- when we a re dealing with action levels that we can 15 an ticipa te, you have do'ne a superb job.
No one will 16 question that, at least from my point of view.
17 I as concerned about those action levels that 18 migh t not be included in this set of action levels, how we 19 handle those.
20 CHAIRMAN SMITH:
You see, this is the difficulty 21 that the Board is having.
In the first place, we ha ve a l
22 continuing difficulty throughout the proceeding as to what 23 extent do we inquire into the circumstances that existed 24 during the accident in comparing the circumstances now.
the 25 Board among its own members has not been able to always ALDERSON REPORTING COMPANY, INC, 4
400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2346
14,082 1 agree on that.
And that'is a problem.
2 We have ;enerally allcwed a li:1:ed inquiry into 3 what the circumstances were to. test the adequacy of the 4 present circumstances.
This has been cur general approach 5 to Lt*
6 But so.far you have not demonstrated on your 7 cross-examination that you could even use the information 8 rou are requesting.
Tha t is why I suggested we defer our a ruling.
I do not know how you would use it yet.
10 Do you understand?
11 5R. AANODT Yes, sir, I do.
12 This is difficult for me to address in terms of 13 how we are going to use it until we get to that point.
But 14 the general area in which I as concerned is simply and 15 purely whether or not what I would like to demonstrate to 16 my own sa tisf action; if I am not able to do that, I would 17 like to demonstrate hopefully to the Board's satisfaction 18 that there is the probability for delay under this system, 19 where people have discretionary abilities.
}
20 CHAIBMAN SMITHS Okay.
I thought that was what l
21 you were trying to do.
Yet you have not -- you seemed to 22 vant to get the discretionary actions available to the shift 23 supervisor a t the time of the accident and somehow compare 24 them with the circumstances as they prevail today.
25 Eut I still do not understand how you are going to i
l ALDERSoN REPORTING CoWPANY. INC.
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in,083 1 connect the two.
2
?.E. AAdODT That can be done simply in terms of 3 the constraints on the person.
4 CHAIRdAN SMITHS I think you can inquire all 5 af ternoon on the restraints upon the shift supervisor 6 today.
But you have not done that.
And until you do that, 7 you have no -- you have nothing to compare the two.
8 Even when you do have, when you will have done g th a t, if you do, it is dif ficult for me to see the link.
10 But as I pointed out, the Board has disagreed on this 11 problem before.
But at least until you develop a record 12 upon which you can try to make a comparison, you have not 13 even demonstrated any usefulness.
14 NR. AAMODTs I was on the wrong order there.
I am 15 sorry, sir.
I will not belabor this.
16 BY MR. AAMODT (Resuming) 17
.0 Let me just simply ask you the question.
'Jh at are 18 the constraints on the shif t supervisor that in the event --
19 that is, in the case of an unexpected event not covered by 20 the EAL's, that he does take appropriate prompt action, as 21 opposed to a two and a half hour delay like we had at Three 22 Mile Island Unit 27 23 A
(WITNESS TSAGGARIS)
To address your comment about 24 constraints, I think the emergency plan states it best, and 25 I can give you a direct quote.
But the shift supervisor ALDERSoN REPORTING CoWPANY. INC, I
'400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
14,084 1 unilaterally has the authority to assess and declare an 2 emergency without any constraints.
3 0
Except his constrsint of judgment, do you not 4 agree?
5 A
In other words, he could not proceed 6
7 8
9 10 11 12 13 14 15 16 17 18 19-20 21 22 23 24 25 ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WA8HINGToN. D.C. 20024 (202) 56e-2346
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14,085 1
CHAI32AN SMITHS It seems that there has_not been 2 a crossing of the minds on tnis particular peint.
You use
^
3 the verd " constraints."
You are usino it in a positive 4 senses What compels th em tc decla re an emergency when the 5 EAL's, listed FA.L's, are not met?
And you are saying there 6 is nothing that prevents them from it.
7 Well, that is not -- you ar e not communicating.
8 Tell him -- tell us what recuires him to declare an gemergency.
Is that what you are trying to get at?
10 MB. AAMODT That is precisely right, Mr. Smith.
and I 11 WITNESS TSAGGABISs The requirement 12 cannot quote a specific reference in the emergency plan; 13 Perhaps one of the other pan.el members can think of it 14 his tra,ining is geared toward the whole philosophy of 15 NUBEG-0654, in that he is required to assess all abnormal 16 events against his operating procedures and against the 17 emergency plan.
18 And if the action levels are exceeded, he is to 19 declare an emergency.
20 CHAIRMAN SMITH:
But there was the final -- you 21 see, this is -- there was the final EAL and tha t is all of 22 everything else other than that which was listed.
Now what 23 is there, if anything, which compels him to go to the final 24 EAL and declare an emergency when it is not listed.
And if 25 there is nothing other than just his engineering j ud gmen t,
ALDERSoN REPoRDNQ CoWPANY,INC, 400 VlMGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 564 2346
- ~r 14,086 1 well, give that answer.
2 "ITNESS TSAGGARIS:
There are specific EAl's which 3 list judgment, and that is why he is trained and tha t is why 4 he is there,. to exercise his engineering and operational 5 judgment.
l 6
CHAIRMAN SMITH:
Okay.
7 WITNESS GIANGIs Mr. Smith, as I think we are all 8 finding out, it is quite difficult to quantify or' to bracket g that discretionary rule.
I would like to read one excerpt j
10 of the energency plan, for whatever good it may help in this it problem, and it reads as follows.
In fset, this is page 4-3 12 of the TNI emergency plan, at the very top, the very first 13 paragraph s 14
" Lastly, the emergency director shall declare an 15 unusual event any time that in his judgment the plant status 16 warrants such a declaration.
Training shall stress the 17 need:
18
"(a) to analyze all minor events in light of their l
l 19 potential for f urther degradatio'ns of the level of safety of l
20 the plant; and 21
"(b) not to hesitate to declare this particular 22 emergency class."
HR. AAMODT I have one more question with regard 23 24 to that.
BY ER. AAEODT:
(Hesuming) 25 ALDERSON REPORTING CoWPANY,INC, 400 VIRGINIA AVE S.W WASHINGTON, D.C. 20024 (202) 554 2345
14,087 1
0 Are there any criminal penalties associated'with 2 f ailure to do that?
3 A
(9ITNESS GIANGI)
Please repeat ' hat.
4 0
Are there any criminal penalties to which the 5 emergency director might be subject should he' fail to do 6 what he should have done?
7 A
(WITNESS GIANGI)
I am afraid I am really not 8 qualified to answer that question.
g C
You are not aware of a'ny such constraints?
10 A
(WITNESS GI ANGI)
I am not, no.
11 0
All right.
12 CHAIRMAN SMITH:
You came very close to an 13 objection there, Mr. Aamodt.
14 MR. AAMODT:
I was waiting for it, to be honest.
15 MR. ZAHLER:
I have good judgment in my witness' 16 ability to give a practical answer.
37 BY MB. AAMODT:
(Resuming) 18 0
On page 81 19 CHAIR AN SMITH:
Now, you have described now, I 20 think, all of the standards that you know of that are 21 available which require the shif t supervisor to declare an 22 emergency.
Now, would you --
WITNESS ROG AN :
Mr. Smith, one thing has not been 23 l
24 said because it was not asked, while I think it is germane 25 to this.
If we are going to compare or if the question is I
l ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE S.W., WASHINGTON O.C. 20024 (202) 554 2346
14,088 1 whether or not some sort of a comparison is appropriate, 2 then it is at 1sast appropriate to note two items which I 3 think we have heard in previous testimony.
4 The first is the emergency action levels as they 5 now exist are a considerably expanded set of guidelines as a 6 result of the publication of 0654.
7 And secondly, that as a result of that expansion 8 and the fact tha t they not only incorporate specific 9 accident scenarios, but generally represent the spectrum of 10 abnormal events which might occur in a' plant irrespective of 11 a particular scenario, the amount of judgment that is left 12 to the emergency director is in my view considerably less 13 than it used to be.
14 MR. AAMODT I cannot leave it at that point.
15 BY MR. AAMODTs (Resuming) 16 0
You said it describes the spectrum of emergencies 17 -- w ha t you really mean, is it not a spectrum?
You cannot 18 include them all.
We just got finished saying that.
I want is th e record to show that I agree to the f act that you have 20 defined them all.
21 A
(WITNESS ROGAN)
I stand corrected, a spectrum.
22 Q
All right.
23 CHAIREAN SMITH:
Now what is your pleasure now 24 with respect to the comparable EAL, that is the catch-all 25 discretionary standard which was in existence during the i
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564-2346
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14,089 1 accident?
What use will you make of that in your case, if 2 you have this inf orna ticn?
3 MR.-AA'0DTs dr. Smith, this would require ~a good 4 deal of judgment.
?ut off the top of my head, it' appears to 5 se t ha t I would attempt to m ake a. case to sa y that the 6 possibility still exists to wait two and a half hours in the 7 event of that accident which no one had anticipated.
8 CHAIRMAN SMITH Okay.
And so you want to report, s th en, on -- let us assume --
10 MR. AAMODTs I do not think it is terribly --
11 CHAIBMAN SMITHz We have to make a ruling and they-12 have to get it.
We have to address it.
You may have to 13 come back.
And it may be important or not, but it still 14 requires a ruling.
It requires attention.
15 And would you -- what would be your position if, 16 for the assumption, you assume f or the purpose of the 17 questioning that the emergency director-had the identical --
18 I mean that the shift supervisor had the identical 19 discretion then as he does now?
That would be an assumption 20 most favorable to your case, wouldn't it?
a l
21 MR. AAMODT:
Yes, sir, it would be.
l
\\
22 CHAIRMAN SMITH:
Would you be willing to proceed 23 under that arguendo stipulation and address the issue?
{
24 MR. ZAHLEBs A set of questions to the panel, 1
25 every one of which would be preceded by the assumption that i
l ALDER $oN REPORTING COMPANY,INC.
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i 14,090 1 the discretion of the shift supervisor now is the same as-it 2 was during the Unit 2 accident?
3 CHAIRMAN SMITH.
Yes.
That was my suggestion.
4 That might go more directly to the problem, because I do not 5 have any faith that it is going to lead to much if we --
6 MR. ZAHLER:
Yes, I have no problem with that.
7 Let me just make it clear, so my panel does not fight that 8 assumption, that they have to accept that assumption, and 9 also to recognize that their testimony is to the contrary, 10 their previous testimony, but to disregard it for the 11 purposes of answering this line of questioning.
12 CHAIRMAN SMITHS This may be a dangerous lin'e of 13 inquiry.
It is very complicated.
I do not have any 14 confidence that the answer is going to lead to any useful 15 information.
16 But I think perhaps you had better identify what s
17 the discretionary -- discretion was to the shift supervisor 18 to declare an emergency during the accident.
19 MR. AAMODTa Thank you, sir.
20 This -- Mr. Smith, I a m to receive something along 21 those lines, is that right?
22 CHAIRMAN SMITH 4 to you oppoce tha t?
I mean, see, 23 you just complicated it yourself when you said the 24 assumption i; contrary to their own views, and now we have 25 to have what their own views are as to what the shift
\\
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
14,091 1 superviso r's discre tion was bef ore.
2 MR. ZAF1ER:
No, no.
I am -- my previous-
'3 statement was based on "r.
Tsaggaric' testimony that while 4 he did not recall all of the e:tergency action levels from 5 the older plan, he was however confident that the list of 6 emergency actions that was in the new plan was substantially 7 larger.
8 CHAIR!AN SMITH We ha ve heard this three full g times, four times.
The argument now is an extremely narrow 10 one and just simply is not an important one at all.
And 11 that is, he wishes to compare, after you have listed all of 12 the specific EAL's, he wishes to compare now what was left 13 over as far is discretion then and discretion now.
That is 14 what he wishes to compare.
15 For the lif e of me,- I do 'not see what the 16 comparison is that we're coing to do.
But this is a ruling 17 problem that the Board has had throughout this proceeding.
l l
18 And we have usually ruled that a minimal inquiry into the l
l 19 conditions as they existed at the time of the accident may l
20 be produced -- may be made, for whatever value it can have 21 to test improvement and to test the standards of the 22 situa tion toda y.
23 MR. ADLERs Mr. Chairman, sir, I may have 24 misunderstood all along.
Is the question with respect to i
25 whatever is residual, whatever is lef t over?
Is the l
I l
i ALDER 8oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
b 14,092 1 exercise of discretion with respect to the lef tover part, 2 regardless of whether it is large or small, the same today 3 as it was at the Unit 2 acciden t ?
4 MR. AAMODT:
Yes, sir, that is precisely the 5 question.
6 MR. ZAHLER:
I thought that was a given.
I do not 7 know how you exercise discretion other than discretion.- So 8 maybe we have been talking around in circles for hours.
9 CHAIB"AN SMITH:
' dell, he wants to know -- here is 10 his point.
I do not know.
I believe -- I have not read 11 this on your cross-examination plan.
But what he wants to 12 do is, he is going to say, well, look, the man had the same i
13 discretion then as he has now.
He still did not declare an 14 emergency for two and a half hours.
So how can you say that 15 what you have now is going to be adequate?
16 I know what the answer is.
I have heard i
17 nine-tenths of the answer.
Well, we have all these 18 additional mandatory EAL's, that is going to be the answer.
19 That is the way it is going
- to come out.
20 But I do not know how to get there, other than to 21 allow' him to try to make his comparison.
+
22 MR. ADLER:
Mr. Chairman.
23 CHAIRMAN SMITHS Mr. Adler.
24 MR. ADLER:
In NUREG-0600 on page II-2-7, there is 25 a table, Table II-2-1, entitled " Emergency Conditions and l
ALDER 8oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2346
l 14,093 j
1 Times Met on March 28."
And our interpreta tion of this 2 table is tha t it shows precisely what conditions were used 3 at what times to declare various emergency situations-during i
4 the emergency.
5 Now, if Mr. Aamodt -- and which ones were not 6 used.
7 CHAIRMAN SMITH:
I still think this' escapes the 8 particular narrow point that Mr. Aamodt is trying to make.
~
g But let's take a look at this.
f 10
-(P a use. )
11 CHAIRMAN SMITH &
I think -- are we back on the 12 record?
13 Was your observation, Mr. Adler, that on Table 14 II-2-1, that there are no discretionary emergency 15 classifications authorities?
16 MR. ADLERs No, rather that no discretionary 17 criteria were used., that these were the criteria that were r
18 used during the accident.
19 CHAIREAN SMITHS I see.
So that is a different 20 poin t.
That is a good point.
?
21 MB. AAE0DTs I was just asking Mr. Adler if that 22 mean s -- I a m sorry to digress into an argument here.
But 23 does that mean that f or two and a half hours there was no 24 existing action level met, when it deteriorated that y
25 significantly?
So that that leads me to believe that ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
A e
l 14,094 1 somewhere along the line somebody did not ha ve adequa te 2 constraints on him to do hir job.
3 CHAIRYAN SMITH 4 All right.
So even if that is 4 the case, you still have not related it to the comparison 5 you are undertaking to make now.
8
'MR. AAMODT:
No, sir.
We are broadening and going 7 in and out like a jellyfish on this one.
But I think 8 everyone understands what it is we want.
9 Perhaps the Licensee can respond.
10 MR. ZAHLER:
I do not know.
If the Board will 11 tell me what they wan t a t this poin t, I will produce it.
12 (Laughter.)
13 MR. ZAH1ER:
I am saying that in all seriously.
14 CHAIRMAN SMITH:
This, as you might sense, this 16 member of the Board has no patience whatever for this line 16 of inquiry.
It is not, I can predict, going to produce one 17 usef ul finding of f act.
But I think it is Mr. Aamodt's 18 right.
jg We have permitted it in the past, in other issues, 20 to determine what was in place at the time of the accident l
21 by way of discretion.
You seem to be limited to the shift 22 supervisor.
I do not know why.
23 MR. AAMODTs Only in the sense that he was the earlier I said, whoever was charged 24, fellow charged with 25 with the responsibility of making the notification.
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE S.W., WASHINGTON. D.C. 20024 (202) 554 2345 t
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I 14,095 1
CHAIR.YAN SMITHS
'J h a t discretion was in him to 2 declare a local emergency, site emergency, and general 3 emergency, or a personnel emergency, which were the levels 4 at that time, over and above the stated conditions?
That is 5 what he wants to know.
6 MR. ZAHLER:
Licensee will undertake to provide 7 that information to him.
8 MR. AAMODT:
!r. Smith, would this be part of the g record so it can be used in findings?
10 CHAIRMAN' SMITH:
When it comes and it is produced 11 in e viden tia ry form, yes.
12 MR. AAMODT:
I as awfully sorry to trouble you, 13 but what does that mean ?
14 CHAIRMAN SMITH:
Mr. Aamodt, nothing can be used 15 in findings unless it is in evidence.
16 MR. AAMODT:
And the fact that he submits it will 17 no t automatically put it in evidence?
18 CHAIRMAN SMITH:
That is correct.
Now, you ma y be 19 ve ry well accommodated.
You may get your answer back by way 20 of a letter which will satisfy you.
You are the one who is 21 seeking the evidence, and you are entitled to have it in a 22 reliable form.
23 Of course, the Boa rd has the overriding 24 responsibility to make sure that the entire record is 25 reliable, too, notwithstanding your willingness to accept ALDERSON REPORTING CoWPANY,INC, 400 VIRGIN!A AVE., S.W., WASHINGTON, D.C. 20024 (202) 554-2346
1f4,096 1 some thing less.
2 MR. AAMODI:
Ihen when !' accept it, then it i
l 3 becomes a part of the record ?
4 CHAIEMAN SMITHS If it.is satisfactory.
5 f.R. AAdODTs All right, sir.
Thank you.
8 CHAIRMAN SMITH:
I --
7 MR. AAMODTa I will' skip th e next question I have 8 on there.
I just could not see how they understood my 9 contention.
10 CHAIRMAN SMITHS I might say, Mr. Aamodt, for the 11 record now, it is my view that you have not demonstrated how 12 you can use whatever this information is in proposed 13 findings.
But the Licensee has agreed to produce it, and 14 the Board has allowed that type of inquiry.
15 But I still do not understand, no matter what the 16 answer is, I do not understand how you can use it in your 17 proposed findings.
18 MR. AAMODT4 I will --
tg CHAIBMAN SMITHS That is your prerogative, to use 20 it-21 MR. AAMODTs It was not frivolous.
It really does 22 rela te.
23 MR. GRAI Mr. Chairman, so Mr. Aamodt does not 24 misunderstand, if he gets a letter from the Licensee laying i
25 out this information, I hope that he does not think that i
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON O.C. 20024 (202) 554 2345
14;097 1 that is then evidence that he can cite and use in proposed 2 findings.
3 CHAIR.1AN SMITH:
'" h a t is right.
Other parties can 4 object.
5 3R. AAdODT:
May I ask the licensee to enter it 6 into evidence for me?
7 MR. ZAH1ER:
Mr. Chairman, I hope to have the 8 information either by the end of this evening or the first g thing tomorrow morning.
10 CHAIRMAN SMITH:
Okay.
11 MR. AAMODT:
Thank you.
12 BY MR. AAMODT:
(Resuming) 13 0
Page 85,, the answer to ' question 75.
14 It has been a lonc night and a long day.
It will 15 take me a minute to catch up here.
16 (Pause.)
17 0
Oh.
"The goal in assessing radiological releases 18 during an accident is to make such assessments sufficiently 1gfar in advance of the actual release so as to permit time l
20 for taking protective action if such measures are l
21 varranted."
l i
Would you please reconcile the assertion that the 22 23 assessment goal is to be made far in advance of actual 24 releases, with the sentence beginning " Consistent" on l
l
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.1u,098 1
(?ause.)
2 Q
That paragraph, you note, assumes those doses that.
3 have unavoidably occurred prict to assessment.
4 (Pause.)
5 Q
This question relates, of course -- your answer 6 there responds to the question:
"Do you believe it 7 necessary to install of f site monitoring devices around 8 TMI?"
g That exercise that we just ran through, reading i
10 those two pa ragra phs, suggests that the length of time 11 involved to make -- take protective action is not as simple 12 as knowing it is coming and telling the people to take 13 action.
There is a whole spectrum of times from there back 14 to, it has already ha ppened, wha t do we do.
15 Do you not feel that under those circumstances 16 offsite monitoring devices would be a distinct advantage for 17 the public in protecting itself against the consequences of l'
18 radiation ?
19 A
(WITNESS TS A'GGARIS)
Mr. Aamodt, I as not exactly 20 sure what the specific question is.
Could you please state 21 the question?
22 0
In answer to question 75, you state that the goal 6 of measuring, offsite seasuring using teams, is to assess 24 radioactive releases during an accident, to make such 25 assessments sufficiently f ar in advance of the actual l-l ALDER $oN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W. WASHINGTON. D.C. 20024 (202) 554 2348
~
14,099 1 release so as to permit time to ta k e protective action.
2 Back en page 74, para graph 2, you note that there 3 are times when there is no time available; the release has 4 already been made bef ore you have the opportunity to 5 dispatch a radiation measuring team.
And I -- my question 6 then is, does this not suggest considerable merit to having 7 offsite monitoring devices that remotely read back to the 8 plant?
g A
(WITNESS TSAGGARIS)
First of all, implicit in 10 your statement is you _re equating assessment with 11 dispa tching monitoring teams.
That, if you look at our 12 previous testimony, is not the case.
13 C
I am aware of that.
14 A
(WITNESS TSAGGARIS)
We have the capability of 15 doing the assessment without sending out the monitoring 18 teams.
17 With respect to a conflict in those two, potential 18 conflict in those two statements, I would ag ree with you 19 that it is possible that a release start and then the i
20 assessment process would begin at that point in time.
21 If you look a t the statement on the top of page 22 85, it says, quote, "The goal in assessing."
23 Q
That is right.
That was precisely my question, to 24 reconcile that event with the goal.
25 A
(WITNESS TSAGGARIS)
And I would say that in the l
I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
14,100 l
l 1 situation where the release would begin immediately that it l
2 migh t be difficult to achiave the cosi in assessing the 3 release before the release started.
4 0
Is it not also true that it can be expected that 5 there will be some releases occur for which you would not 6 have had opportunity to make a dose assessment from the 7 control room or from the plant, and'therefore it would be 8 very helpf ul?
For example, at the' time of the 28 psi spike 9 in the accident, nobody was prepared to go out, was even 10 prepared at that time to say exactly what was coing to 11 happen.
12 Dose assessment was not adequate at that period of 13 time, nor was -- well, dose assessment was not ad equa te.
14 Wouldn 't it have been very helpful to have had remote 15 monitors?
Wouldn't the public have been significantly I
16 better protected by having remote monitors that you could 17 look at?
18 A
(WITNESS TSAGGARIS)
I think -- and a cia in, I was ggnot there on the day of the accident.
But as I recall, at 20 the time we are specifically talking about, the time of the 21 pressure spike occurring, the monitoring teams had been out 22 for hours.
CHAIRMAN SMITH:
You are getting 23 WITNESS TSAGGARIS:
The monitoring --
24 25 CHAIRMAN SMITHa You are getting into a digression ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
14,101 1 now.
His point is -- well, I think he has explained his 2 point quite well.
3 I guess it lesds -- leads to what change would be 4 made in the emargency plans if there had already been a l
5 release which would have an impact on the amount of 6 radioactivity leading toward the protective action guides, 7 before it was monitored by your mobile -- by your dispatched 8 team?
What effect would that have on your emergency plan?
9 Does that go in the direction that you want?
10 MR. AAMODTs Yes.
It CHAIRMAN SMITHS And I think his point is, the 12 emergency plan should take into account all releases, not 13 just those that are monitored by your dispatched teams, 14 those which may have been missed earlier in the accident.
15 WITNESS TSAGGARIS:
Again, I think -- to go back 16 and look at the record this morning, and I believe it was 17 me, although I cannot recall -- we discussed the fact that 18 ve do not rely on confirmatory measurements from the teams, 19 and that we utilize the in-plant instrumentation to make th e 20 assessments and the protective action recommendations, 21 without that confirmation.
22 That is the way the plant is designed.
And we 23 discussed the offsite monitors, real time monitors.
And I 24 believe as we go back -- I think it was discussed at the 25 time.
If you would like me to go through that discussion I
ALDERSoN REPORTING COMPANY,INC, l
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)
==
14,102 1 again, I will.
2 3Y ME. AA50DTs
( 3e s uming )
3 Q
Perhsps I am laboring under 'a ' misa pprehension 4 here.
But is it not possible -- possible for a release to 5 go offsite which you did not know happened?
6 A
(WITNESS TSAGGARIS)
Yes, tha t would be possible.
7 Q
All right.
In other words, in that case the only 8 way to know it happened would have been by reading it from a 9 remote monitor; is that right?
l 10 A
(WITNESS TSAGGARIS)
No.
I would like to qualify it that.
12 Q
The only likely way, let's put it that way?
13 A
(WITNESS TSAGGARIS)
No.
And perhaps I am not the 14 best person to discuss this.
But based on my operational 15 background, there could conceivably be a situation were a 16 minor unmonitored release could occur.
17 However, a plant operator, in his knowledce of the 18 pland and when he is opera ting the plan t, has many other gg indications available to him than just the radiation 20 monitoring system.
He has tank pressures, tank volumes, 21 strip charts indicating on all his tanks which contain 22 radioactive fluids and radioactive liquids.
If an abnormal situation occurred, there would be 23 24 other indications which would lead the operator to believe 25 that something was occurrino.
And if it were not showing up 1
ALDERSoN REPORTING CoWPANY,INC, 400 VIRGNA AVE., S.W,, WASHINGTON, D.C. 20024 (202) 564 2346
1a,103 1 on the sonitoring, radiation sonitoring-system, for whatever 2 conceivable reason, he -uculd dirpa tch :cnito ri.ng teams to 3 take some measurenents.
4 Let se go one step further to say that any 5 significant-release 'would certainly have other paraaeter 6 effects that the operator would be aware of.
And without 7 being presented with a specific scenario ! veuld be, you 8 know, hard pressed to give you an example.
9 Q
I appreciate that.
10 This relates somewhat to the earlier long, lengthy 11 discussion that we had, and I will not pursue it any 12 fu rt h e r.
But again, don't you agree we are in the area 13 again of whether or not an individual does what he is 14 supposed to do?
Isn't -- in other words, what I as saying, 15 1f you had a remote monitor out there and it was read out, 16 you would not have to worry about somebody doing what he was 17 supposed to do.
The da ta wo uld be there.
18 Wouldn't that be desirable?
gg A
(WITNESS TSAGGARIS)
Frankly, I do not see how th e 20 offsite monitors and a person doing what he is supposed to 21 do, I do not see the relats>nship.
! really de not.
22 0
I will not pursue it further.
(Pause.)
23 24 0
Page 85, question 75A, line 2, the sentence 25 beginning "Thus."
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400 WEGN AVE, S.W. w ASHmGToN. D.C. 20024 (202) 566 2346
i i
1 14,10s 1
(Pause.)
,f t
I
-2 That sentence seems to imply that the limit cf
.j 3 interest in the radiolecical data is confirming in nature; 4 is that true?
j i
5 A
(WITNESS TSAGGARIS)
! am sorry, sir.
Would yo 6 repeat that.
l t
7 Q
The sentence beginning "Thus" on page 86, first i
t 8 paragraph, to.the end of the paragraph, seems to imply that t
g the limit of the intent of the use of the radiological data
[
t 10 is confirming in nature.
Is that true, as opposed to
{
11 predictive?
j C
12.
MR. ZAHLEBs Can I ask which radiological data you i
13 are talking about at this poin t ?
l l
14 EB. AAE0DTs Whatever they are measurino out 15 th e re.
16 ER. ZAHLEE:
You are talking about offsite?
{
17 HB. AAMODT4 Yes, yes.
I j
18 WITNESS 30GANs If I understand the question l
l Ig correctly -- and 1 understand it to be, is the offsite f
i 20 monitoring information essentially used as confirming rather f
21 than predictive -- there a re two parts to that answer.
f 22 The first is, in general that the statement is 23 co rr e ct.
The second part is tha t the da ta -- si::ce our plan 24 and our procedures rely on predicting radiation and t
i 25 radiation levels, rather than on confirming them, that is l
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400 VRGMA AVE. S.W. WASHm0 TON, D.C. 20024 (202) 564-2344
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14,105 1 from the standpoint of emeroency response, we use the data 2 from offsite monitors as we receive them tc upgrade or to 3 correct or to verify our source term, se that our 4 predictions are even more accurate.
5 MR. AAMCDT:
Thank you.
)
8 CHAIRMAN SMITHS Complete that question.
Then we 7 will take our af ternoon break.
l 8
MS. AAMODTs That satisfied me.
~
r g
CHAIRMAN SMITHS All right.
Now, for the balance jo of your cross-examination, I would appreciate it i
11 12 MS. AAMODTs I'm sorry, I did not see.
I had a 13 second half of the question here.
14 3Y MR. AAMODT (Resuming) 15 0
Yes.
Again, the offsite monitoring devices, you 18 just use in your response the expression, "or correct,"
17 which indicates a level of certainty both at the site in 18 terms of projecting what will ha ppen and also, frankly, 19 because you are familiar with the terrain around Three Mile 20 Island, particuarly going off our way toward lancaster i
21 County and Chester, an awful lot. of hills and valleys and i
22 th e wind takes very peculiar twists.
23 I notice you're nodding there.
It takes very 24 peculiar twists, and it is very difficult to know accurately 25 where something is going to be, you know, within a narrow l
1 ALDER $oN REPORTING COMPANY,INC.
400 VIAGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 56& 2346 l.
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4 14,106 1 band.
l 1
2 Again, wouldn 't Offsite scnitoring devices help
'l 3 relieve some of this uncertainty ?
f 4
A.
(WITiEES FCG A:;)
ist me take the first part,.and 5 then I will let the experts answer the second part. LI 8 believe my testimony was "to verify or to correct," used in 7 the same con text as one does a theoretical calculation on a
[
t 8 variety of subjects, and where one subsequently confirms by t
9 actual field test data that that information is correct.
10 A
(WITNESS GIANGI)
The process of sending radiation 11 monitoring. teams out I guess the best way of saying it, 12 it is a refinement to get a more precise,-actual dose rate 13 reading in that area, assuming again you designate the 14 radiation monitoring team to proceed to, ideally, the plume 15 center line.
16 There are uncertainties to the extent that in the-17 dose assessment process, built into the process is quite a 18 bit of conservatism, one for example, as we mentioned, being 19 adverse meteorology; another being, as we mentioned, the 20 containment leak rate that we are now going back to look.at; 21 and as Mr. Aamodt m e n tio ned, vind shifts.
22 We do, however, declare the emergency based on P
23 projections to the best of our knowledge on source terms, 24 and real time meteorology as assessed from the control 25 room.
And it is an ongoing process based on more data
[
i V
t ALDER $oN REPORTING COMPANY INC, 400 VIRGNA AVll, S.W. WASNINGTON, D.C. 20024 (202) 554-2346
i 14,107 1 coming in, actual measurements coming in, that the 2 refinement procass becins.
3 Namely, source term would ~ be updated consistent 4 with actual radiation monitoring team measurements.
5 I would also like to add -- I did not get the f
8 chance to say it earlier -- that we do ha ve prepositioned,
7 again as part of the Licensee's radiological and 8 environmental monitoring program, TLD's, thermo luminescent g dosimetry, preopositioned out there in various sectors of 10 the site, to provide for this accident assessment, if ycu 11 will, radiological assessment.
12 Q
I have one follow-up question on that, if I 13 migh t.
You mentioned that ideally you would like to measure 14 at the center line of the plume.
Upon obtaining that 15 measurement, the projected dose rates would be corrected.
16 Suppose the team missed and were on the edge, 17 where only one-tenth of the amount of,a narrow plume were 18 measured.
Would you then assume that what you had 19 calculated and projected from the plant was in error and so 20 notify PEMA?
l 21 A
(WITNESS GIANGI)
No.
The process has already 22 begun.
You have declared the emergency.
The radiation 23 monitoring teams keep being I'm trying to think of a way 24 to say it -- are reassigned over.and over again to various 25 points, depending on wind speed, wind direction.
ALDER 8oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 584 2346
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O Which is chancing all the tir.e.
2 A
(WITSEEE ~,IANGI)
That is correct.
Depending on 3 dispersion characteristics of meteorology.
4 MR. AAMODTt I have no more questions at this 5 time.
6 CHAIRMAN SMITH:
You have completed your 7 cross-examina tion?
8 MR. AAMODTs No, sir.
I have cotten to the point S
9 were you asked me to stop.
10 CHAIRMAN SMITHt All right.
I appreciate'it if 11 during the break you would consult with Mr. Sholly and go 12 over your cross-examination plan with him and determine 13 whether or not they are repetitive or cumulative to 14 questions that he asked during your absence today.
15 MR. AAMODTs So far we have not been.
16 CHAIRMAN SMITH:
How do you know?
There have been 17 large periods of time when you have not been here.
18 HR. AAMODTt My wife was here.
19 CHAIRMAN SMITH:
Is it that you don't wish to do 20 it, sir?
21 MR. AAMODT No, I am pleased to.
22 CHAIRMAN SMITHz Okay.
23 MR. AD1ER:
Mr. Chairman, before --
24 CHAIBMAN SMITH:
We will take -- Mr. Adler?
25 ER. AD1ERt Before we break, it occurred to me ALDER 8oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2346
14,109 1 that the Peard might consifer whether the scheduled meeting 2 tomorrow evening will have any impact en the hearing 3 schedule for the r?st of the week.
We are not making any 4 proposals.
! thougnt the Board might want to consider 5 whether their schedule will be impacted.
6 CH AIR M AN SMITH We had not talked about any 7 change, although maybe it would be appropriate that we do.
8 I had thought that perhaps we might be assured that we do e not adjourn any later than 5:00, maybe somewhat earlier, 10 tomo rrow.
But we had planned on having the Friday morning 11 session.
12 Now we're having some prediction of snow, and it 13 looks like the only possible time the snow could have 14 conflicted with one of our sessions it is going to.
But 15 with our usual foresight, you know, we have provided for a 16 snow date.
37 We do not -- other than perhaps returning somewhat 18 early, we would take suggestions.
We have not talked about ja it yet very much.
20 ER. ADLERs I just wondered if you had any 21 designs.
We are not making any proposals.
22 CHAIRMAN SMITH:
Let's take a ten-minute break.
23 (Recess.)
24 CHAIRMAN SM]THs There is somewhat of an open item 25 with respect to Dr. Molholt's testimony.
'Je made a possible t
E ALDERSoN REPORTING COMPANY,INC.
400 VIRGMA AVE., S.W. WASHINGTON, D.C. 20024 (20a 564 2346
14,110 1 suggestion to Mrs.
.n amodt that she may wish to have Dr.
2 Molholt 's testimon y marked a s a n Aamod t exhibit, which 3 becomes a rejected exhibit, to preserve the record for 4 appeal purposes.
5 I do not know if you think that suggestion 6 accomplished the fact or not, but it does not.
But if you 7 accept that suggestion, it would be --
8 MR. AAMODT We feel it would ' be h elpf ul, sir.
9 Yes, thank you.
10 CH AIREAN SMITH So that would be Aamodt Exhibit 11 4 What you have to decide is do you wish the testimony 12 the exhibit to include the appendices or not.
13 MB. AAMODTs Yes, sir, we do, and also the new 14 biography that Dr. Little has.
15 CHAIRMAN SMITHS So there will be in the rejected 16 exhibit file marked f or identification Aamodt Exhibit 4,
the 17 testimony of Bruce Mulholt a s presented, together with the 18 new professional qualifications.
19 Somehow we are going to have to make up a group of 20 -- how many exhibits do you need for the rejected exhibit I
i l
21 file?
Three.
Somehow we are going to have to come up with l
22 three.
I have one extra one and you have one extra one.
I 23 3R. AAMODT We will get l
24 HS. AAMODTs How many do you need?
l 25 CHAIRMAN SMITHS We need three altogether.
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., 5,W., WASHINGTON, D.C. 20024 (202) 554 234C l
4 14,111
. 'E.
AAMODTs
- 4e cannot do it by tomorrev, but we 1
2 can ' pet three fer you.
3 CHAIEYAN SEITE:
It does not rattar.
Any time.
l 4
(The document referred.to was 5
strXed Aamodt Exhibit No. 4 6
f or iden tification. )
7 CHAIEMAN SEITH:
Now, if you will move that into 8 evidence, we vill deny it and it will come into th'e redocted l
g exhibit file.
10 X3. AAHODT I would like to present Dr. Solholt's 11 testimony,with Appendixes 1, 2, 3, and his technical 12 qualifications, into the record.
I 1
13 CHA!ERAN SMITH:
Okay.
In conformance with our 14 previous ruling, that becores Aamodt Exhibit for-15 identification 4 and it goes into the rejected exhibit file.
r 16 (The document referred to, 17 previously marked for identi-18 fication as Aamodt Exhibit i
19 No.
4, was rejected and i
[
20 deposited in the rejected 21 exhibit file.)
2:
CHAIRMAN SMITH 4 All ri gh t.
Now, Mr. Aamodt.
23 EE. AAYODT I would like -- first I would like to t
24 apologize for the poor manners of speaking over people.
The f
25 reporter pointed that out to se and the difficulty of 1
I ALDEA$oN 8tEPoRDMG CoWP ANY. INC.
400 WIGINLA AW. S.W. WASHINGToM. D.C. :2024 (2C2) 554 2346
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14,112 1 reporting, and I apologize.
If I do it, somebody throw 2 something at me.
o 3
I would call the ranel's attention to pages 91 and 4 92, questions 62 and 83.
5 (Pause.)
6 BY !R. AAMODTa (Resuming) 7 Q
This is the scenario -- this is part of the 8 scenario that you constructed to cla rif y response 9 procedures.
What in your judgment would be the minimum time 10 which could elapse between the situation described in 11 question 2 and the situation described in question 83?
12 CHAIRMAN SMITH:
Question 82 and question 83?
13 MR. AAMOD75 Isn't that what I said?
They were 14 t wo very short nights.
I apologize.
15 (Pause.)
16 WITNESS TSAGGARISs I understand the question to 17 be, what would the time be from a set of parameters in 82, 18 indicated in question 82, until the set of parameters 19 indicated in 83.
2g BI MR. AAMODTs (Resuming) 21 Q
In your opinion, what would be the minimum time 22 th a t that could be?
23 A
(WITNESS TSAGGARIS)
I would have to say that it 24 is difficult and I could not make a judgment, not knowing 25 the accident, not knowing the actual scenario.
You cannot ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 564-2345
14,113 1 equate a 700 degree thermocouple reading to a 100 millirem j
2 per hour of f site.
It depends on what is happening in the 3 plawnt.
4 0
Let me rephrase the question.
Coing from an 5 emergency set of conditions to a genersi emergency set of 6 conditions, what would be the minimum interval of time that 7 could pass?
What would be the minimum length of time that 8 would be possible to get from one to the other?
g A
(WITNESS TSAGGARIS)
To get from a site emergency 10 to a general emergency?
11 Q
Yes.
12 A
(WITNESS TSAGGARIS)
There is an infinite set.
It 13 would depend on the plant conditions.
14 C
Right.
15 CHAIRMAN SMITHS Wait a minute.
It is going to 16 have to be from the end of a site emergency to the beginning 17 of a general emergency.
If there was a site emergency, it 18 would have to be instantly.
19 So you're going to have to rephrase your 20 question.
Do you mean from the beginning of a site l
21 emergency to the beginning of a general --
l 22 MR. AAMODTL From an equivalent stage in one to an 23 equivalent stage in another.
l CHAIEMAN SMITH:
I think you are going to have to 24 l
25 make it the beginning.
You are going to have to have some J
I ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
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1u,114 1 --
2 MR. AAMGDT:
That would be fine.
And then 3
WITNESS TSAGGARIS:
Only the mininum time ?
4 BY MR. AAF.CDT (Resuming) 5 0
Yes.
6 A
(WITNESS TSAGGARIS)
Depending again on the 7 accident scenario.
If the instrumentation was passing.
8 through the site action level and went right on into the 9 general emergency, it could be a very minimal time'.
- Again, 10 it is very difficult to put a time on that, not knowing it actual plant conditions.
12 C
Would it be unlikely -- that is, would it be 13 inconceivable -- that one could have a site emergency, 14 notify Dauphin County, PE!A, the appropriate set, and 15 suddenly the condition deteriorates very rapidly, so that 16 instantly upon having made that notification you are all of 17 a sudden la a general emergency and things going that 18 quickly?
Could tha t happen?
19 A
(WITNESS TSAGGARIS)
That is conceivable, yes.
20 0
Is it conceivable under those circumstances that 21 that individual responsible for the notifica tion of the 22 parties could f orget to do it the second time?
23 A
(WITNESS TSAGGARIS)
Given that he has already 24 declared the site emergency --
25 0
He has just declared a site emergency.
He has ALDERSoN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554-2345
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14,115.
1 just hung up the phone.
Someone comes over and says:
2 George, it is going f ast, all right,'you know, with no 3 implication s.
There. is a certain level of excitement, the 4 human ' factors impact on the situation.
Errors are most 5 likely in.a situation like th a t.
6 Is the error of failure to notify likely, 7 unlikely, or impossible?
8 A
(WITNESS TSAGGARIS)
I would say it is 9 conceivable, yes, to notify that it has gone to the next 10 level.
11 Q
In a case like that, then, it might not be 12 unreasonable to notif y all five counties in the event of a 13 site emergency?
14 A
(WITNESS TSAGGARIS)
Would you restate that, 15 piea se ?
16 CHAIRMAN SMITH:
Well, let's back up just a 37 moment.
I 'was just about to request that you not phrase 18 Your question in terms of " conceivable," which is a problem 19 in this type of hearing.
l 20 MR. AAMDDTa It is.
21 CHAIRMAN SMITH:
And then you did exactly that, 22 you used likely-unlikely.
And then you answered in terms of 23 conceivable.
So I think you have a jumped record up to 24 now.
25 So would you ask the question in terms -- answer ALDER 8oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
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1 the question in terms in which it was asked, a n:1 that-was
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2 impossilla, likely or unlikely.
3
'JIT.N ESS !? AGG ARIS:
I would say 1: is highly 4 unlikely.
l a
5 BY "E.
AAECDT.
(Resuming) 6 Q
But possible?
l 7
A (WITNESS TSAGGARIS)
Possible, yes.
4
?
?
8 0
Thank you.
I l
10 l
11 12
+
13 14 15 16 i
17 i
18 i
+
19 20 j
21 22 23 24 I
I 25 i
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l ALDERSON REPORTING COMPANY, WC, 400 WIGINGA AVE. 3,W. *ASMeeGTON, D.C. 20024 (202) 564-2346
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14,117 1
Pace 94, the answer to Question 94.
2 MR. ZAHLER:
Is that 94 the-answer to 84?
3 MR. AA?ODTs I am sorry, page 93, the answer to 4 Question E4, the lart sentence, first paragraph.
5 SY MR. AAMOCT:.(Resuming) 6 0
This level has been selected low enough -- this is 7 one-tenth of the lower limit EPA recommended PAG. "T his 8 level has been selected low enough to permit sufficient time g to first evaluate the need f or and then implement 10 appropriate actions."
11 I would like to esll your attention to the fact 12 that low enough and sufficient time are highly subjective 13 te rm s.
There is not a great deal of precision.
14 What is the probability of the radiation level 15 increasino from one-tenth of the lower limit of the PAG to 16 the P AG in two hours, one hour, a half-hour?
Can you l-17 quantify this?
18 CHAIE%AN SMITHS Pefore you answer, is this one of 19 th e levels tha t is being adjusted for consistency at the 20 NRC's raquest?
21 WITNICS TSAGGARIS:
Yes, that is correct.
22 CHAIRFAN SMITH:
I think the question better be 23 addressed, then, to the reality of it rather than the 24 testimony.
25 Do you understand what the problem is?
i 400 VIRGINIA AVE, S.W., WASHINGTON, D.C. 20024 (202) 554 2345 l
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1 1u,118 1
MR. AAMC'DT:
Yes;.but I do not think it-is e
2 applicable,
'r.
Smith.
3 CHAIRMAN EMITHs All right.
4
- 13. AA*0CT I am aware that the levels are being l
5 changed to provide consistency throughout. hy question, f
6 however, goes to the statement that the levels have been 7 chosen. low enouch, whatever they-are, so that enough time is 8 available to do ro=ething.
How much ic enough time?
Fnough
(
g time is dependent on the level of radiation to which people 10 migh t be exposed.
One times the TAG is a lot worse than 11 one-tenth, two-tent hs or thr ee-ten ths, whatever it might be 12 ch anged to.
13 BY ME. AAHODT (3esuming) 14 0
What is the probability, in the event of the whole 15 spectrum.of acciden ts -- we could do this mathematically in i
16 terms of known accidents, I suppose, known scenarios.
17 Ecuchly speaking, what is.the probability that you 18 have an hour, a half-hour, an hour, two hours before you 19 reach the TAG?
20 A
(WITNESS TSAGGARIS)
I do not think I can 21 ad eq ua tely a nswer t hat.
I do not know.
It would depend on 22 the particular plant conditions.
23 C
Are thers scenarios which had been considered 24 where we could go from one-tenth the TAG to the TAG in ten 25 minutes?
I ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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A
(' LIT *RS S OTANGI)
The answer to that question is 2 obvicucly yes, it is pessitie.
3 XE. AAPODTs T h a n k.
you.
4 CE;IFTAN S!!?Ha
$ow vait a.-inuta, that was not 5 the question.
The cuestion iss have there been scenarios t
6 considered.
I 7
WITNESS GIANGI I am sorry, I cuess I must have 8 misunderstood.
9 CHAIN *AF S%ITHs Do I recall the question f
i 10 correctly?
Wasn't that your question?
11 SY %E. AA%OCTs (Resuming) 12 G
What I want to know is is there a scena rio which l
t 13 has been considered which would say thtt we could ce fron l
14 one-tenth to one in ten minutes.
t i
15 A
(WITNESS GIANGI)
It is my mistake. I thought you 16 said can there be a scenario that can get you from one-tenth 17 to one TAG.
l l
18 C
I interpret that as the same question.
Answer i
19 that ene.
t 20 A
(VITNESS GIANGI)
Okay.
My understandinc is there 21 may be a scenario that would do that.
22 0
Thank you.
I i'
l EE. ZAHLIE 3r. Chairman, if ! could interrupt 23 24 for a second because I think %r. Aamodt's first question is l
25 worthy of answerine.
?
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1 AreLycu aware Of = ny rcenario that har been l
2 considered wher+ levels wecid from One-tenth c.f tha icvar i
3 PAG to the PAG. in t+n -inutes?
)
4 2:TNESS O!ANG!:
'! c t that ! 7:ov of.
5 DE. JOSOAN4 Now I cuess I ar confused.. Have you 6 considered various scenarios, a spectrum of scenarios, one:
7 of which gets you to one-tenth PAG and the next to one PAG 4
8 ana so f orth?
Ey that I mean acciden t scena rios.
i g
WITNESS GIANG!:
We have considered scenarios that t
10 would get into the varicus gradas of enargencies.
Fer 4
11 example, there must be a sc ena rio,.and from our lac ( of 12 postulation in the final saf ety analyis records that would 13 get into a general emergency and by;ars the unusual event 14 alert and site.
There must be an unusuel scenario that gets 15 into the site directly without going through' the lover. t wo k
t 16 classes.
i i
17 WITNESS TSAGGASI5 I think that to go back and 18 look at NU3EG-Cf54 and the planning basis that is the basis 19 for the action levels, that certainly considered some
~
20 scenarios, and we talked about this, I believe, a little bit 21 yesterday in the Class 9 area when we had the Class 9 22 discussion.
The guidance in Appendix ! has been fer:ulated 23 to provide an adequate envelope for those.
24 LB. JOEDAN:
Yes, but you did not yourcelf 25 consider the various accident scenarios.
I l
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400 VIRGINIA AVL S.W., WASHINGTON. D.C. 20024 (20lD $54 2346
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'iITNEEE TS AGG AEIS:
I would say that ir an 2 accu rate st a twnt.
'4 ' personally did not considar the i
3 specific accident scenarios.
4 D?. JCEDA'3 All right.
5 WITNTSS ROGAN:
Nor have.ve, to the best of my-r 6 knowledge, done any predictive calculations based on the
-7 various scenaries and permutations of neterological data to 8 calculate the probabilities of something occurring within i
e some finite ti:r.e description, which I believe was what the 10 first question was.
11 "3.
ZAHLEh The thrust of my question want to the
?
12 time of moving from one. to the other rather than just the j
13 scenarios.
I am not aware of analyses done with respect to 14 the time to move from one. scenario to the other.
That was 15 the thrust of the question.
16 DR. J0FDAN:
All right.
17 BY MR. AAMoDT:
(Resuming) 18 0
Would you agree that knowledge of those time jgintervals would impact on the judgment of appropriateness of 20 protective actions and notification?
i 21 A
(WITNESS TSAGGARIE)
I think in general I would 22 no t agree because one thing that has to be understood in the 23 accident assessment process is that once that accident 24 assessment process becins, in the example you gave in a site i
25 emergency that assessment is a contin uous process.
(
ALDER 5oN REPORTING COMPANY,INC.
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7 0
I an aware of that.
The point ! an addressing, 8 though, in that time can shrink t-nor cucly depending en the 9 scenario, and the upropria taness, then, cf the notification 10 rout e.
11 One of the areas which we are c0ntendin;, as you 12 migh t know, is that we vecid like to see all the counties 13 notified en any event just to avoid the poscibility of 14 so me thin g happening that they do not kn0v in tire, =nd
- hat 15 need can be de onstrated to be dependent er net dependent 18 based on inf 0riation of thi kind.
17
?on 't you agree?
- n part.
Not entirely, but in 18 pa r *.
39 A
( *J....' N.. i ~. n' N G. )
7.'
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o# s'.',
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20 clarification, the coun ties are all tifiM in all of the 21 ev en ts.
22 0
You racember cur discussions about that, thcuch; 23 no t ini ti all y.
That is my ;cint.
In the case of a general p,4 em e r g e n cy, all of the counties are notified initially, and 25 incident =.117, just to clarify ry thinkin; here, and all of ALOERSCN REPCAT.NG COMPANY,INC, 400 VIRGMA AVL S.W W ASHINGioN D.C. 2llC24 (20D 554-::345
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184,123 l
1 thosa are notified by or di.9a ry 411 Telephone circuits 2 rather than dedicated liner; ir tnat truei
(
3-A (VIT1EST EOGAN )-
! do not think we era.rreparad to
}
4 testif y as to the datails of the cor.munication links'used by j
5 the Commonwealth of ' Fennsylvania.
[
P 6
0
'lo, sir, I did not ask that.
!-said in the case 7 of a general emergency where notification emanates from the 8 control reom, is notification made over conventional Bell t
g Telephone lines as oppoced t o dedicated circuits?
10 A
(WITNESS GIANGI)
It is an auto dialer by 11 conventional Bell means in. the shif t supervisor's office.
12 Q
Again, cubject to busy signals which might occur i
13 if someone suspected beforahand that there was an accident 14 going on.
15 A
(WITNESS HOGAli)
Let me clarify, however, a very 16 important point: that the notification by the Licensee in i
17 the event of a general emergency is a parallel notification j
18 backed up by the entire emergency notification system of the 19 Commonwealth of Pennsylvania.
20 C
Yes, sir.
I am aware of that.
21 A
(WITiESS GIANGI)
Mr. A:.na d t, let me further add 22 that, as you mentioned, the bury signal in the case of 23 Dauphin Ccunty -- and I can speak for Dauphin County only, I 24 am not aware of the other four ccunites having this 25 ca pa bility -- there are two lines, each line having the i
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.3 Q
I in aware of th t t.
Y o u. '< n o v, I hav+-three lines 4 coming ints r.7 office, ud very often they are all busy, and.
5 we have eigh t empicyees in that one office.
So, you know, 6 this is my concern.
And would you judge, then, from this 7 discussion, relative to the various things tha t we have t
8 discussed here, that the use of ordinary telephone circuits' g is adequate?
i 10-A (WITNESS GIANGI)
Yes.
Licencee believes that 11 through the notification process established with the 12 Pennsylvania Emergency Eanagement Agency, Eureau of 13 Radiation Protection, and the five co un ties, that j
14 confirmation that the counties have received notification 15 within 15 minutes and our truct in the Pennsylvania 16 Emergency Management Agency's normal accident mitigation 17 processes such as floods and fires, we believe this 18 notification scheme to be adequate.
19 Q
Thank you.
20 CHAIRMAN.F%ITH:
Mr.
- 3. a m o d t, I want to point cut 21 what I think you have done here.
You began with a major 22 question which related to the notification of counties, and 23 then you digressed on a subquestion --
24 MR. AAMODT:
Yes, sir.
i
.25 CHAIRMAN SMITHS on the adequacy of i
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t 14,125 1 telephcnes.
It will make it almost 1:;ossible te follow 2 it.
Mave you a t e n t.C n e d your tjer querti:n?
3 "2.
EA?OOT:
~1 have not aram!oned it.
.I think we 4 have pursued it far enough.
5 CHAIETAN CZITHs All riant.
6 X 3 '. AA 0DT Just a minute.
7 (Mr. snd Mrs. Aamodt conferring.)
8 325. AA20DT dr. Smith, !.want to explain why Mr.
gAamodt is'doin: this.
He is. extremely tired.
I'do not-know 10 whether he would like to continue.
I just wanted to say 11 that he is extremely tired in doing this cro ss examina tion.
~
12 hE. AA'0DTs It took a litt1e time to put together.
1 13 the thing we gave you this morning.
14 BY M3. AA20DTa (3esumin7) 15 0
I call your attention to page 99 and-100, Question 16 93 and the answer.
Our side discussion here was whether we 17 finished the question bef ore, although ! cannot remember, to 18 be perfectly honest.
We will cc, as you suggest, ' rom there.
19 CHAIBMAN SMITH 4
! En not suggesting that. I do l
20 not want you to --
21 MR. AAFCDT Mr. Smith, the fact of the matter is 22 I forget the line I was going on, and therefore, having 23 when I made the digression, which seemed appropriate because 24.he broucht u p the subject of telephones and it was a 25 question on which ! questioned earlier, and then I did not I
l
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14,126 1 recall vhare we had te+r befora thst.-
2 Eo r=.ther t h s. n treuile sveryone,-! tacught we 3 woulf just keer cin;.
4 C " !. I.? l N SM!!Es let me := mind ycu.
Your lina 5 was,.as I recall -- I as not sure, but your-succestion was-6 that the counties, all five counties, should be notified 7 directly at the lowest level, the unusual ~ event or site 8 alert or something other than general emergency.
And in the 9 process of asking that cuestion, that ic when you f.igressed 10 into the adequacy of telephones to begin with.
11 MB. AAMODT Yes.
12 CH AIR AN SMITH :
Have you exhausted your inquiry?
13 MR. AAMODT4 I really think now as I recall it we 14 ha ve pursued that far enou;h.
Thank you, sir.
I appreciate 15 knowing where we we re anyhow.
16
?! NR..AAMODT:
(Resumino) i 17 0
Page 99 and 100, question 93, the answer.
Is 18 education of the public planned relative to the harards of' gg exposure of varying levels and forme vf radioactive' go materials in the plant invantory?
21 let te provide you a little background for my 22 question.
The public has the general perception that 23 radiation is radiation.
Everyone in this room knows that is t
24 no t true.
25 Now, do you plan to address that questicn, and if so, 9
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1u,127 1 how?
2 A
(lII:!IEI C T.* *!'iI )
Fir,
Of $.11 1:- -s sat-that 3 radiatica is radiation.
u0v vc plan o-adf.resrine that 4 problem I believo va r a ecr:tely add rersed 2.n Mr. Shelly's d
5 cross-examination, I tellevc,.cn Thrae Mile !rland's intent 8 to develop and carry out the.public education program, and 7 too, as ve mentioned, I believe in the' supplemental, what 8 plans we have of modifying the Appendix 3, namely, the 9 Emer9ency Public Information ?lsn, in the areas of public 10 educa tion.
11 0
Mr. Sholly and I vent over this'and he falt that 12 this was net covered.
Neto shen I said radiation is not 13 radiation, what I am sayinc is the effects of gamma 14 radiation and radiation froc an alpha particle can be 15 substantially diff erent~ in terms 'of how they might impact on 18 -- f i rst, how the individual might come in contact with it, 17 and secondly in terms of the long and shcrt-term e_fects of 18 th e s e, and also the levels of radiation have different 19 mean ings.
20 So frca that peint of view is education of the 21 public planned' relative to the harards of exposure of 22 varying levels and forns of radioactive materials in tha 23 plant inventory?
24 A
(iiIT'iESS B OG A N )
I believe in earlier testimony 25 today I indicated that we are presently verkinc with ALDERSoN REPORTING COMPANY,INC, 400 VIRGIN!A AVE., S.W WASHINGTON. D.C. 20024 (202) 554 2345
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6 14,128 1 representatives from the Co monvealth cf ennsylvania in 3
2 d.ev91cpire s prcora. with them regarding educatin; the 3 public with re;ard to radistien harards and rsdiation 4 emergencies.
i 5
'4 e are, in fact, attempting to reconcile at this I
6 point exactly what the responsibilities and what channels 7 these kinds of procrams should be followed throuch.
For 8 instance, th e Department of Education.
What should be 9 presented to the public in the f orm of emergency rasponse 10 education programs, what programs which vill be unilaterally.
11 pursued by the Licensee separately, a n d. I do not believe at 12 this point we are in a position to outline in specific 13 detail what that program is going to involve or who 14 specifically is going to do what particular part of it.
15 0
I think the question nas been misunderstood.
The 18 testimony is clear in describing the intent of the licensee 17 to work out a procedure of education of the public to be 18 sure they know where to ;c, protective actions relative in 19 response to the declaration of an emergency or information 20 from PEMA.
21 I saw no reference in the text of your testimony 22 to the fact that you considered the need to inform the 23 public or tha t you planned to inform the public concerning 24 the fact tha t there are different kinds of radiation which 25 have different meanings to them, as, for example, exposure ALDERSoN REPORTING COMPANY. INC.
400 VIRGtNIA AVE., S.W., WASHINGTON, D C. 20024 (202) 564 2345
iu,129 1 of radicactive iodine in very small quentitier te.a pregnant 2 woman.
3 It any information of thst kind planned, any 4 inf ormation program of that kind planned?
5
'AITNESS ROGAN:
Again I will broaden my response 6slightly and then pass over to tr. Giangi.
With regard to 7 the specific details of the content of the program, that has 8 not-yet been settled on, and to the extent that I might g express a personal opinion, it would have or may have no 10 bearing on the final program which needs to be coordinated 11 with the State of Pennsylvania, with the repartment of l.
12 Education of the Sta te of Pennsylvania.
l 13 CH AIR:1AN SMITE:
I would like to observe here that 14 the brochure that was discussed earlier does discuss what is 15 radiation and the detection of it.
16 MR. AAXODT4 Yes.
17 WITNISS GIANGI I vac going to say, Chairman 18 Smith, in addition that at a minimum, the three areas would 19 be to inform the public about the concept of radiation and 20 its hazards. Secondly, what to do in the event of hearing 21 the sirens blowing as we described in the early warning discussion ea rlier.
Third ly, upon receiving the message, 22 23 how to interpret and actually implement the various 24 protective options that the public will be hearing over the 25 emergency broadcast system or the radio and television.
(
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14;130 1
n Y.:P. AAMIT:
('esuminc) 2 C
That is vident it th: t'rtir0ny, I t h i 9. vell 3 Covered.
4
- 0 t evilant i n :n '- testimony ir Wha t in.3y Oind 5 would be cubstantial ef f ort to unlearn the public in' its 6 perception of the f act that it is safe.
That is, do you 7 f eel there is an ef f ort or can you state that an effort vill 8 be made to unlearn those people who, being convinced that 9 nuclear power ic saf e, could 50 expected to not take 10 notification seriously, assumin; that such a situation 11 exists?
12 MR. ZAHLER:
I object to that question, if I 13 understood the last part, assuming the situation exists.
I 14 could not figure out the rest of it, but as I understood the 15 question it was: is Licensee proposing a program to unlearn 16 people that nuclear power is safe?
!s that the quortion ?
17 CHAIF?AN ?!!TE:
That is what it sounded like.
18 MR. AAMODTs Would it be appropriate for se to 19 comment here a little bit on what I am driving at, what is 20 in my mind?
21 CHAIEMAN SMITH:
I think we can see where you are 22 goin g.
I think you made your question more complicated than 23 it has to be.
24 MR. AAMODT:
When I travel all over the United 25 Statas, nearly every major airport in which I pass --
ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W. WASHINGTON D.C. 20024 (202) 554 2346
1 14,131 1
CH AI3:. A:: C.:!TF:
Ue know, we hava bean in airports.
2
3. 22fC;!s Thers ir crcur tr*: sa'ls -- p-ople 3 believe thic.
4 CM.* IT " A ! 63 IT*d s You =re Jicressinc.
5 -
H3. AA:f0DI:
I a: only askin; is thera an 8 ed ucational program which is 7
CHAIRMAN SMITH:
The objection is sustained.
8 BY "E.
AAMOCT:
(Resuming) _
g
'O Who ir responcible -- who has final authcrity in 10 determining, you know, and maintaining a program of 11 education, implementing and maintaining?
Is that a 12 government -- is that a function of the state government or 13 a function of the Licensee ?
14 '
A (NIISESS E0GAN)
That-is an issue. Certainly both 15 have a moral obliga tion, the legal authorities and 18 responsibilities with regard to, for instance, education in-17 the school system.
Frograms presented within the public 18 school system clearly come under the purview of the 19 Department of Education.
The licensee has a-full staff who recognize and 20 21 work on programs specifically and unilaterally. The 22 prerogative of the licensee.
To go beycnd tha t and say who 23 overall has some specific lagal authority is 1:possible to 24 do.
25 C
Doas the Licensee plan through the use of inserts ALDER $oN REPORTING COMPANY,INC.
400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2346
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3 10,132 1 in its bills te notify the public relative tc hazards that-2 migh t te uniqu-to t=cc a.t:
ci the repula. ice such as 3 presnent we,sn?
4 A
(1ITMISS TCGA!.)
The licences is conciderin the 5 use of bill inverts the specific content of which I am not 8 prepared to discuss at this time.
I frankly do not know.
7 A
(WITNESS GIANGI)-
Mr. Aamodt, in respect to your 8 earlier question, wa refer to "UREG-0554, section C, number 91, where it talks about the public educa tion specifically.
10 I think f rom looking at that it shows the the Licensee state 11 and local people, it is a coordina ted ef fort to ensure that 12 the public ed ucation program is adequately a ddressed.
13 Q
It is not 14 A
( *4:T N FSS GIANGI)
We have held several meetings 15 with the state agencies on the same subject and are 18 undergoing a program.
~
17 CHAI3 MAN SMITH:
Gentlemen, I think the problem we 18 are having here with.*r.
Aamodt's cross examination is he is e
19 not addressing the thoroughness of the publi c "ed uca tion 20 program but the content of it.
I 21
-(Poard conferrinc.)
22 MR. AAMODT:
I am not questlaning the thoroughness 23 a t all.
24 DR. LITTLEt Let me try to rephrase the question.
I 25 I think he is asking about the le vel of technical r
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h 14,133 1 information that is goin? tr b' t:1nsmitted.
.Ih e trochure
?"A dic - Var han'ed out raid,. f o r 3-n -S+, u nc c rn a nd 0
2 frot 3 very younc children ar= mere ransitive. to rs distien than are 4 older children an adults.
5 I think hir cuestion ir are you coinc tc.co into j
8 more detail than that rather than just simply stating that 7 as a fact.
8
'4!TNSSS RCC AN :
I have to answer this in a purely 9 speculative way and say that that kind ef brochure is-the 10 sort of thing that we have considered acpropriate to date, 11 and beyond that I really cannet say that we have identified 12 a need for a much more technical document.
13 CHAIEZAd SMITH:
If the best answer you have, 14 gentlemen, is "I do not know," Well, that is quite 15 appropriate.
18 MR. AAMODTs Sure.
Thank you.
l 17 CHAIR AN SMITH Although if you can explain, you 18 should ; but if you really do not know, you just say "I do j
19 no t know.
j 20 MR-I$AMODT:
I have no quarrel with that at all.
21 3Y #E AAMODT4 (Peruming)
(
22-0 This is my problem.
The education of the public 23 is very important.
I do net sne from 065u, whatever the 24 number is, or from your testimony that there is a defined 25 criteria or set of criteria against which excellence can be t
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'J h a r e is it?
2 CHAIAf 5%ITd:
'xc=11etre in educatine the I
3 public?
i 4
- '.I.. J A. G T, C :
Inie is en action that has to he 5 takan.
6 CHA!ENAN EMITH:
This is excellence in the quality 7 of the education program.
That is the content of'it.
Is 8 that the thrust cf your question?
9
%3. AA!ODT Yec.
i t
10 WITNESS ROGAN:
We have been given a minimum set 11 of criteria according to the.1uclear Eequiatory Commission s
12 guidance.
Beyond that I cannet establish for you a set of 13 criteria for excellence.
[
14 3r EE. A1.YODI:
(?.ecu ing) 15 C
Is there any single body that hac ultimate 16 authority in determining adequacy of that prograe?
17 A
(WITNESS 30GAN)
I do not know.
18 A
(WITNESS GIANGI)
I would like to add to that that 19 the NBC and the Federal Emergency Management Agency, as I 20 understand, will be reviewing the trochures for their i
l 21 ad equa cy.
I 22 Q
! am.avare of that.
i 23 A
(WIINESS GIA3GI)
! would also like to peint out j
i 24 that for emergency planning purposes, those three arear that 25 I mentioned at a very mini:us being included in the ALDER $oN REPORTING CoWPANY,INC.
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14,135 1 brochuras give'the rublic cufficient inf orma tion to be a ware 2 of tne proble
? nd a d eq ua t- '.y i n im i r r-the i pa rt :=
b t.c 3 problem by eitMr adoptinc shelterint er syscuatien or.any 4 oth*: protectivc-action option
.s srrgested by the ctste 5 agencies and th e licenseer in coo rdination, anc these, 6 again, are agencies who are in' the business of looking out 7 for the public interest and help-in the areas of 8 radiological controls.
9 C
I will not belabor it.
Perha.ps you could maka one 10 more comment that will be helpful and we will key on my t
11 problem.
12 The public can be described for a normal' 13 distribution curve in all' of itc characteristics.
That 14 applies to the susceptibility of the effect of radiation as 15 well.
I am locking for a standard somewhere that takes care 16 of other people than those that are within narrow limits of 17 th e peak of the distribution curve.
18 ro you heve any help?
Can you tell me any wa y 19 that that problem is being addressed?
20 A
(WITNESS POGAN)
No, I cannot.
21 Q
Thank you.
22 CHAI?. MAN SMITH:
So you accept the premise of his 23 question ?
24 WITNESS ROGAh4 I am not sure I truly understood 25 tha question.
If I did, the answer was he was again askinc ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345 4
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4 1u,136 1 if"I could provide come st u dard uten which ! could design a 2 protra-whirh would tar.e c ue cf the ;rciatility 3 dictributicas of the varicus kncviedge leveic ci the 4 population a t large, and I balieve that is the program that 5 I have indicated we are tryinc te develop at this time.
But 6 beyond that I am not su re I could cive hi= some definitive 7 standard or rule.
8 3Y
'P.
(?esucing) g C
Ih e re was a misunderstandinc.
I was not talkine t
10 about the distribution of-the knowledge of the people. I was 11 talking about the distribution -- all -- what I said was, 12 and this is.what
.r.
Smith, I understand, asked you -- do 13 you agree with the premise that all of the populatio', the n
14 popula tion a t la rg e can in all of its characteristics or in 15 most of its characteristics, many of its characteristics be 16 described in a bell-shaped curve?
17 You know, characteristics vary normally in a l
18 normal population.
That being the case, one could infer i
3g reasonably that the eff ect of radiation on individuals 20 varies across the population also.
And I simply asked, that l
I 21 being the case, if that is the case -- and I am not asking 22 whether you agree that that is the case or not, but if that l-23 were the case, does the plan in any way at all address the
(
24 need s of people outside, let's say, one sigma, ?3 percent of 25 the population, whatever it is?
?
5 4
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"e is sh wine by M s hands the l
2 bottem cf auch side Of :ne rell-chaped curva.
3 "It:73E TIAGC7.RIS:
First o f r 11, !.ould questien 4 tne prer.ise of the question and quartion what the technical 5 basis would be for assuming that the radiation effects on 6 the population are on a bell-shaped curve.
And secondly, to 7 be a ble to adequately answer the question I think you would 8 have to have a technical basis for the assumption.
I would g' find it' personally difficult and could not answer the-10 question as ' presented.
11 WITNESS RQGAN:
And I would agree with the 12 response by Mr. Tsaggaris.
13 DR. LITTLE:
The simple question is are protective 14 actions and all of the other emergency planning geared to 15 take care of the more sensitive groups of the population, 16 not just, say, the average citiren?
17 WITNESS E0GAN:
I think there is provision, and I 18 think this pamphlet, among other information that has been 19 distributed to the public, where there has been a suggestion 20 that there is a granter sensitivity to radiation or an 21 alleged greater sensitivity to radiation, that sort of i
22 information has been included in some of the p ublic 23 information programs that have taken place and pamphlets 24 that have been distributed.
t 25 Beyond that, I think there is even an issue of ALDER 8oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W,. WASNINGToN, D.C. 20024 (202) 554 2346
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14,138 1 cont est within the expert world on whether or not some of 2 that data is r u 111 aver valid.
Sa te ta c t exten., again !
3 just ic not thi-k : am cor.ratent te derien ths.t program yet.
4 WITNTEE GIA'M :
"r.
Little, we ". ave ads;ted 5 guidance provided for in the EPA protective action manual, 6 and this is also consistent with the Bureau of Radiation 7 Protection in the Departmeni of Environmental Resources, 8 such that we looked at the lower limit protective action g guides for the whole body and the child thyroid as the 10 limiting f actors.
11 (Mr. and Mrs. Aamodt conferring.)
12 MR. AAMODT Thank you, Dr. Little.
13 BY MP..
AAMODT:
(Fesuming) 14 Q
Again, pace 100, paragraph 2,
the first sentence, 15 "PEM A and the various county and local emergency management 16 agencies have develeped a pu blic awareness program."
You 17 note the last sentence, " Licensee has assisted in their 18 distribution process by mailing brochures in utility bills."
19 A large segment of the populati*on in the E2Z of 20 Unit 1 is served by TPCL.
How does TPEL's effort interface 21 with yours in this regard?
i l
22 A
(WITNESS GIANGI)
Could you please repeat the 23 question again?
l 24 0
Yes.
Simply what you have testified to here is 25 that Licensee is an integral part of the dissemination of ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
f 14,139 1 information te the public ty providine -- in the !?? -- that i
2 is inf erred, n o. r-d l -- t n i c u ? ". the m.;chanir Of Treviding 3 brochurcs with your reiling cf till:.
(4 2
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73 4
a I
5 Q
Your mailing of conthly state:ents.
- point out i
6 that the significant portion of the population within the 7 EPZ is not served by Metropolita n Edison, and I am asking if 8 the assistance of ~75L has teen obtained in a rimilar way.
9 A
(WITS!SS 0! ANGI)
Yec, sir.
In my previous 10 testimony I sentioned that the brochures that ware
!ted through the utility bills was a coordinated r
- the TPCI customers and the Zet Ed customers.
t iould also like to add that is but one way that
!.e ri ng acco plishing the goal of public 1
w I am sorry, I missed that.
i 17 Page 10u, the ansvar to question 99, sheltering.
j I
18 Will the public be informed concerning the unique hazard of 19 inhalation of alpha or beta particle-emitting p a r ti cul a t e.s ?
20 This question goes to the fact that pecple only do what they 21 figure th ey have to do as a general rule, and I recember in i
22 the Army how difficult it wa s to wea r the gas. tasks.
23 Now, taking protective action of that kind to l
24 protect oneself against that kind of radia tion -- insult to is going to be avkvard, and satisfactory 25 the body 1
ALDER $oN REPORTING COMPANY,INC, 400 VIRGINIA AVE. S.W WASHINGTON, D.C. 20024 (202) 554 2345
14,140 1 response could only be ahticiented if the people kne w that 2 it was nacded.
3.
Therefere, the questions will the public le 4 informed concerninc the unicue Parard cf inhe.letion of alphs 5 or beta particle-enitting particulates?
6 A
("4ITNESS GIANGI)
First of all, I.really do not 7 know what the Public Information Department and FEMA and 8 Eureau of Radiation Protection have got in mind fer some of 9 the informatien in pamphlets.
! have alreacy mentioned at a 10 minimum what should be contained in the pamphlets, and I 11 would also like to stress that the protective actions given 12 the public a t a time of an emergency wculd be the best 13 recommended protective action ba sed on all the agencies and 4 consistent with the guidance set forth in MUEEG-0396 and th e 15 EPA Protective Action "anual.
16 Q
On the other hand, in your plan for preparing for 17 an emergency which requires the having in place of a 18 mechanism f or adequa te sheltering, you do not addre: ' the 19 question of whether or not the public can be expected to 20 protect itself adequa tely for unique exposures of this kind.
21 A
(4ITNESS GIANGI)
First of all, I may be missing 22 the point. I know that in the event of a plume, radioactive 23 plume, if sheltering is picked as a protective action it is 24 so picked because of a various number of factors, namely, 25 time of release.
Approaching the lower limit. protective ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564 2345
i 14,141-r 1 action guide r, evacuation cannot be well under way prior to 2 pl ume a rriv 11.
3 The ciphs and heta probler th'.t ycc :+for to, if 4 that were in the plume, the radioactive plume, it really 5 would posa no problem with regard to sheltering as an 6 option.
It is really the higher energy ganma radiation or 7 the whole bod y radia tion during the two hours of sheltering 8 that would predominently be the more limiting.
9 Ac you well know, alphas and tetas would not 10 penetrate through a vinter-worthy home.
11 Q
I also know that inhaled, they are ur 12 dangerous.
13
'J o uld the other two members of the pane;
+pt 14 Mr. Giangi's statement as the position of the licensee?
15 A
('4 IT N E55 ROGAN)
I am not prepared at this point 16 to state what the ' official pclicy or position of the 17 Licensee is; however, as a poin t of cla rification for me so 18 that I understand w ile re they are going, I gather that this i
19 whole issue revolves around the issue of whether or not the L
20 public can better protect itself by knowing the specific 21 technical da ta with regard to ra diation as versus the 22 Licensee through and with the cooperation of the 23 Commonwealth of Pennsylvania and the Bureau of Eadiatien 24 Protection providing protection information to the public 25 based on technical information.
ALDERSoN REPORTING CoWPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2346
lu,142 1
To th" extent that th a t is the direction we are 2 in, that is quito 2 differer.t question thin we a.
= beine 3 asken.
4 C H A II A N EMITH:
No, I think that tha original 5 question if it had been answered directly would have pretty 6 vell gone to that, and this is where your attention is 7 beginning to lag.
I think you should listen more carefully 8 to the question.
g First, if you agree with the premise, then answer 10 th e question.
If you disagree with the premise, as you did, 11 then state your disagreement and see what ha ppens.
If you 12 had answered the question first put to you, I think you 13 would have seen where he is going.
14 DE. JORDAna Could I ask just maybe one question 15 that migh t help clear it up a little bit?
16 Do you, in calculating the consequences of a 17 plume, assume that there are gamma emitters which vill 18 irradiate the whole body?
3g WITNESS GIANGI Yas, we do.
l 20 DR. JORDANS Do you assume that there are beta 21 emitters which will possibly be breathed in and thereby 22 irradiate the body in that manner?
23 WITNESS GIANGI Yes, sir, we do.
i l
24 DR. JORDANS Do you-assume that the cloud will
\\
25 have appreciable amounts or any of alpha emitters which will I
l ALDER $oN RE9ORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
l l
14,143 1 he breathed in and irradiate the body?
2 VIT3.III 'IANG : Y0s, rir.
! am answerin; yes in 3 th ? cenbe that there is a plume expesure pathway and a plume 4 ingestion pa thway, and clehrly the tve, given approximate 5 radii of 10 miles and 50 miles, look at those concerns that 6 you mentionad.
7 DR. JORDAhs Which alpha emitters are you speakinc 8 of ?
9 WITNESS GIANG:s Specifically dauchter products, 10 decay daughter products of certain fission products.
11 DR. JCRDAN All right.
I don't know of any, but 12 that is all right.
13 BY MR. AAMODT (Resuminc) 14 Q
I call your attention to pa ge, if I can read my 15 vriting, page 110, question 109, the answer, part 3.
16 I understand from Mr. Sholly that he did not cross L
17 examine in this area, although I believe you had a l
18 contention in that area earlier.
This is of unique interest 19 to me since I have a number of Amish friends.
20 MR. ZAH1ER:
Mr. Chairman, if I might pose an l
21 objection at this point, I guess, the response in the 1
22 testimony is somewhat in the way of avoidance, which was I
23 this was a specific contention by Mr. Sholly and ANG3Y, and 24 there were interrogatories because it was a specific 25 contention of-theirs that we addressed to them with respect ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
. -.-,=,,.
1u,144 1 to inferestion, and t hey uriertook to provide that 2 inf ormation to us a nd wc-ne ver..ad any in.#creatice.
3 At this coint I g'lerz ! wculf object te an 4 intervenor whos3 contention war not cross exar.ining en this, 5 notwithstanding tne Prairie Island Eule, ;iven the unicue 6 circumstances of it.
We obviously did not pose 7 interrogatories to the Aamod ts.in this area because it was 8 not their contention 9
3h. AA30DO:
"r.
Smith, I would like to respond 10 this way.
If there had been no --
11 CHAIRMAN SMITH 4 Just a moment, please.
12 (Board conferring.)
13 CHAIEMAN SMITHS You do not have to respond, 3r.
i 14 Aamodt.
We can see from your cross examination plan that 15 the question is related to your Contention c.
l 16 ME. AAMODT Yes, sir.
I 1
17 CHAIRMAN SMITH:
That is the direction he is 18 coin g.
Much of it, not all.
19 BY MR. AAMODT (Resuming) 20 Q
Does the Licensee know that all older Amish have l
21 no radios except a young kid who might have snuck one in?
22 Does the Licensee know that ?
23 A
(WITFISS GIANGI)
I have been tc1d that.
24 Q
Does the Licensee --
25 CHAIRMAN SMITH:
In the first place, we have to ALDERSoN REPORTING COMPANY,INC, f
400 VIRGINIA AVE S.W., WASHINGTON, D.C. 20024 (202) 554 2345
L i
14,145' 1 ponder the knowledce of a public atility, and then te ha ve
(
2 an Of ficini of the purlic utility say t.'. a t ke has 'een told 3 that the utility kncvs it.
Do ycu knew it?
lc your i
4 planning of ficisis - knew thst,.if tha t ' is tru+?
5
'4ITNISS ROG 4K I do not knew as a personal fact 6 that that is true.
7 CHAIR 2AN SMITH:
Has it been a planning 8 assumption?
Have there been sny assumption: made on it?
g
'4ITNISS RCGAN:
To the best of my kncvledge, no 10 specific planning assumption was made'on that b' asis.
11 RY.93. AAMODT (Resuming) 12 Q
I would like to ack Mr. Gianci and Mr. Tsaggaris 13 th e same question.
14 Mr. Giangi, you indicated a general svareness of
[
15 the f act that they do not use electrical products, right?
16 A
('4ITNESS GI ANGI)
That is correct.
[
17 O'
Mr. Tsaggaris?
18 A
('4ITNESS TSAGGARIS)
As a general rule I am aware 19 they do not use electric products.
20 0
So therefore, in preparing this testirony, which j
21 is your testimony concerning the adequacy of on-site t
22 emergency preparedness which does relate to notification, 23 you had a general awareness that the Amish do not use 24 electrical appliances.
25 A
(7ITUESS GIAXGI)
Y*C-i f
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400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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14,146 1
ME. ~ 3 F L F i. :
Fave we changed fror 2.m i c h to what I 2 'though t was Cid Orde r Amish before?
3 ME. AAMCDTs I c211 Anirh Cid Crder Amish.
I will 4 use the werd ":misn" to mean vid Crder Amish in tha 5 discuscion, or ! will use Old Order Amish.
6 BY MF. AAMODTs (Resuming) 7 0
Do 8
%3. "AHLERs The record should.te clear.
Pick one e so it is clear.
10 MR. AhMODT:
Old Order Amish, which in itself is 11 not a unique sect.
12 (M r. and M rs. Aamodt conferring.)
13 BY MR. AAMODT.:
(Resuming) 14 C
Then all of our discussion se far has related to 15 Old Order Amish.
Is that understood?
16 A
(WITNESS GIANGI)
Yes.
17 0
Now, I assume that having heard no noes, you say 18 Ye3' 19 DR. LITTLES We are havin?l a problem with head 20 nodding not being in the trsnscript.
21 WITNESS GIANGIs We are having a problem with 22 whether a question has been posed or not or whether he is 23 just making a statement.
If that is a question, the answer 24 is yes.
l 25 MR. AAMODT:
I will' start over briefly.
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7AfCDI:
(Tesuminc)
Is it'th9 General knowledca cf. embers c' the 2
3 proup who prepared the licansee's testirony en the adequacy 4 of on-sita emergency preper +dn+rs, which includes the 5 subject of timely nc tification and method of notification, 6 was there knowledge on the part of these people generally 7 that the Amish do not use radios?
8 A
(WITNESS RCGAN)
Two cf the members of the panel 9 responded yes.
The third, myself, indicated I had no 10 first-hand knowledge that was factual.
11 0
Then we can reasonably assume that a majority of 12 those involved knew.
13 A
(WITNESS TSAGGARIF)
Yes, two out of three is a 14 majority.
15 C
Do 16 CHAIRMAN SMITH:
Incidentally, I know it, too.
17 MR. AAYODT:
Yes, we all do.
I do not mean to 18 belabor it.
19 BY ME. AAMCDT.
(Resuming) 20 0
Do the members of the panel also have general 21 knowledce to the effect that the Old Crder Amish do not have 22 phones in their houses?
23 A
(WITiiESS TS AGG ARIS )
I do not know that as general 24 knowledge.
25 A
(WITNESS ROGAN)
Nor did I.
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1 A
( % !!Ir tSS GIASGI) her did !.
2 20 rea h=v eneral.<nowl=d;o to the effect tha t j
3 they de not own automotil- ?
4 A
("IT7?SS 200AX)
~t is ny und ersta nding that co=e 5 do not, yes.
6 CHAIRMAN SMITH:
All right; now we get into a 7 problem.
I overruled the objection --
j s
8
- 39. A;dOCT:
Yes-9 CHAIETAN SMITH:
-- based upc the fact that your r
t to Contention 4 was based upon dissemina tion of informa tion and 11 no t upon the particular problems of the Old Order Amish.
i t
12 B u t I caution that not all of your line of questioning was 13 within the scope of the contention, or is it?- Maybe it is.
s r
14 MR. AAMODT:
Fro: tnis point it will be, sir.
15 CHAIRMAN SMITH:
All ri;ht.
16 EI ME. AANGLT (Resuming)
I 17 Q
In the second sentence of item 3, you ray, 18 "However, we have no reason to believe that if necessary, 19 adequate protective messures could not be taken in a timely i
20 manner for the Old Crder Amish ccmmunity."
The majority of j
21 rou know that they do not listen to the radio.
None of you 22 knew they did not have telechones, but we expect the
{
23 telephones to be clogged if there is an emergency.
All of i
24 you knew they did not drive autcmobiles.
l 25
.}o w can you support that statement tha t you have
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i 400 VIRGINIA AVE. S.W. WASHINGTON, D.C. 20024 (202) 554 2345
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14,149 1 no reason to believe that if neesstary, adequa ta protective 2 mea ures could net be tak?n in a tirely ma r.n e r ?
3 A
( W I T N E S S
".0 G.4 F )
7 beliavs it is.rucportsble on 4 the basis that tirrt,-the installation of the Iror;t Alert 5 Notification System provid?s for notificatien and coverage 6 of 100 percent of the exposure pathway irrespective of the 7 locations of telephones and other devices. So as a minimum, 8 the Licensee's system will provide the initial alert 9
I further believe that although certain modern 10 devices may not be available within select homes, there is 11 still the opportunity to. distribute infccmation through the 12 public information program, both in terms of written 13 information and information through the school's programs 14 and other discribution means which may develop as the i
e 15 program evolves.
16 Third, I would refer back to a statemant I made 17 yest erday with regard to the concept which calls f or 18 red undant procedures for assuring that all of the population l
19are aware of an ongoing event, and that redundancy is 20 accomplished in the case of those people with modern 21 technology by following up the siren alert with EES 22 no tifica tions and so fo rth.
For those that do.not, the local county and 23 24 municipality ' plans clearly should be targetted in that direction and make provision, and we are encouraging that to 25 ALDEA$oN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON D.C. 20024 (202) 554 2345
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J 14,150 1 the extent that we can influence that, a nd ve bellave that 2 the governn?n ts 5:ve that sa ric 5:ral ccncern ar.d 3 obligation.
4 They are prepared to tc11cv up on a local baris to i
5 maka sure that those people not contacted by the normal --
6 le t me define normal -- telephcne, radio-type means can be y contacted either by. door knockers, robile public address 8 systems or whatever may te required and available.
g Q
Mr. Ecgan, you did net respond to :7 cuestion.
10 The sentence which I asked you to respond to. sta tes :
11 ho we ve r, we hava no reason to believe that if necessary, 12 adequate protective measures could not be taken in a tim ely 13 manner.
14 I am not at this point concerned with I
15 notification.
All three of you knew that Amishmen drive
[
i 16 buggies.
You know they do not drive cars.
The alternative f
17 means of transportation might he buggies.
They do,not drive i
18 ca rs.
In the event of an evacuation order where time is a f
39 critical factor, we have an ele'ent of the population m
20 comprising rouchly 50,000 people, that is, the 21 Me nn oni te - Amish community -- I guers the Old Crder Amish 22 community probably comprice arcund 15,000.
Say it is cnly i
23 5,000.
You have a significant portion of the popula tion 24 which not only cannot drive out but also vill tend to clog 25 the reads with their buggies.
t f
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400 VIRGINLA AVE., S.W., WASHINGTON. D.C. 20024 (202) 564-2345 t
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This being the c=
e -- and here-you will assume' 2 it ic the ce.e :+ce.ure I a rure you it is tre esce -- r e w 3 can you rake tn+ sszertien that we have no reascn to t e-lie v e 4 that if necpesary, =dequat-protective r=srures could not be '
i
(
5 taken?
g i
e ME. ZAHLER*
Objection, Mr. Smith, not only on 7 your comment ea rlier that he has now mcVed out of 8 no tification, but in addition this contantion, that is, 9 Sho11y 's and AaGRY's as oridinally ph re sed, dealt with an 10 Old Order Amish community outside of the plume expcsure 5
11 pathways that is that there were concentrations of them from 12 the 10 to 20-mile grea and therefore maybe they need to 13 expand the plume exposure pathway.
14 Fr. Aamodt has now assumed th a t there are la rge 15 numbers of Amich within the plume exposure pathway. There is 16 no evidence on the record and ! do not think that allowing r
i 17 questioning in a hypothetics1 vein in this instance serves 18 to develop th e re co rd.
{
tg CHAIRMAN SMITHS Mr. Bradford, were you going to 20 commen t?
)
21
?S.-3PADFORD4 Yes.
! wo uld just like tc correct l
22 Mr. Zahler's statement as to wha t cur contention shared with
(
i 23 Mr. Sholly is.
It says -- I do not know what Mr. Zahler's 24 numbering on this is.
Numerous members of the Old Order 25 Amish community reside in relatively close proxirity, within ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 564 2345
- -. ~. _,. -
t 13,152 1 ten miles of tha outer Youndary of the Licenree's plume EPI 2 in Lancastar C:unty.
3
%E. IAHLES:
Ihat is e xactly what I had in mind.
4 I un derstand-that to be within 1C -iler of the outer 5 boundary of the E?I, a boundary which maans 10 to 20 miles 6 from the plant.
7 MR. AAMODT Fr. Chairman.
8 CHAI2"AN SMITH:
All right.
In the first place, 9 there is a problem if, as Licensee states in Fcotnote 3, 10 that they did not receive adequa te responses to 11 interrogatories to address the contention, then we 12 necessarily would have to limit the inquiry beyond the reach 13 of your Contention 3 14 ME. A A.MOL T :
I am agreeable, sir.
l 15 CHAIEMAN SMITH:
So I think you did go beyond that 16 when you started talking about clogging the roads and that 17 type of thing.
18 MR. AAMODTs The reason I thought that was 19 rele vant, Mr. Smith, is that the amount of time needed for 20 notification is a f unction of how fast people can travel.
21 CHAIRMAN SZITH:
'J ell --
22
- 43. AAMODT:
- iov you have a wnole new parameter 23 added in on the calculation of what is adequate time for 24 notifying relative to an evacuation.
It is an issue that 25 Licensee has clearly not considered, and I think that the ALDER $oN REPORTING COMPANY. INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
18,153 1 statement was irresponrible and I think the record should 2 shcw tha t.
3 CHAIR"AN EMITH:
All right. "ovever, the Board, or 4 at least this enmber of the Eoard, ic interected te what 5 extent, if any, there is_a particular' problem with the Cid.
6 Order Amish within' the EPZ' and to what extent it is being.
7 addressed. I do not know.
Maybe the Commonwealth can tell 8 us if this is coming up in any.cf the testimony, or is it 9 coming up from any source.
We have not read all the.
10 testimony which hac been given to us.
11 MR. ADLEP.
We have not specifically _ add re ssed 12 this point in our direct testimony.
However, Mr. Lothrop 13 will be here for the purpose of testifying on evacuation in 14 general, and I am sure he can provide whatever information 15 PEMA.has available at that time.
16 CHAIRMAN SMITHS I do believe you were incorrect 17 in your statement when you'said tha t Mr. Rogan's answer was 18 not responsive to your question.
The question you put to 39 him was how could he reconcile that sta temen t with those 20 facts, and he did give you an answer.
how go ahead and ask what you want te, but in view 21 22 of our ruling and our interests and the fact that they have demonstra ted that they have not made particular plans, there 23 is not much more you are going to be able to do.
24 MR. AAMODT:
That is' exactly where I wanted to go.
25 ALDERSoN REPORTING COMPANY. tNC, 400 VIRGINIA AVE., S.W,. WASHINGTON. D.C. 20024 (202) 554 2346
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14,154
~
1 I am finished with that que s ti en.
2 CMAIR"AN IMITH:
'll ri;ht.
3 Now, vill you te here when the witnesres a re 4 available to edcress the issue?
5 hB. 3A30CT
'.r.
Smith, I hope I shall be.
Ycu 6know, private intervenors have a substantial problem, as you 7 can see by the fact that most of them are already gone.
8 CHAIRMAN SMITHS Then I recommend if you have g you seem to have an unusual source of information -- that to you make sure that whoever is nere in conformance with our 11 order has the benefit of ycur knowledge on this r ' -cc-12 MR. AAMODT Yes.
13 MR. SHOLLY Mr. Chairman.
14 CHAIRMAN SMITH:
?.r. Sholly.
15 MR. SHOLLYs I must confess at least my failure M.
16 address this was most definitely an ove rsigh t, and I think 17 there is a very specific question which can be put which 18 will perhaps help clarify the re co rd, if I might succest it, 19 an d let the chips f all where they may.
20 The testimony states, in somewhat of a double 21 nega tive term, Licensee 's view, and I think perhaps the 22 direct question is does the Licensee ha ve any reason to,
l 23 assert that protective measures can be taken in a timely l
l 24 mann er.
25 CHAIEMAN SMITH:
Well, that question can be put to l
l ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
14,155 1 them ; but recognize this was not a very forceful statement 2 that was in'the testimony.
It was not intsnded t o h e a.
3 f orcef ul sta temen t in the c n te :e t in which it was effered.
4 But ask the quartien.
5 EE. ZAH1E?.a Wasn't that "r.
Bocan's:last anrwer, 6 however?
/
CHAIPMAN'SMITHa I bea your pardon?
8 MR. ZAHLEEa Wasn't Mr. Eccen's last answer the 9 answer that "r.
Shelly is --
10 CHAIP"AN SMITH:
I think it would.
I think it 11 is.
But I io not wan+ r.c n aak M:- Fogan.
I am already
+
12 talking t^-
Ml'*
dicor should, I believe.
t.
5 t' /
'n' a page 110.
Would you 13 14 an sw er t a.-
t ;.i t e r en t;1 y if the statement were do you 15 have affirmu;.
cnason to believe that adequate protective 16 measures can be taken in a timely manner for the Old Order 17 Amish community?
Would you answer the question any 18 differently?
19 WITNESS RCGANa No, I would not.
I still believe 20 it can be accomplished.'
21 CHAIRMAN SMITH:
All right.
Well, it would be 22 helpful if shoever appears is cognizant on this subject and 23 is prepared to address the Board's interests in this area.
24 MR. ADLEF:
I will make sure he is aware of that 25 fact.
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
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"F.
AAM00Ts Mr. Fr ith, woulr! it be any help t o',
2 hava an AmishmAn nr. pear?
3 CH AIE.' A N SMITHS I
4 MR. AAf0DT It would
.o t be a difficult thing.
5 CHAIRMAN SMITH:
I just do not know.
I de not i
6 know.
7 MR. AAMODT I know the Amishman would like it.
I 8 am not sure if anyone else would.
If it would be helpful, 9 it certainly could be arranced.
10 CHAIRMAN SMITH:
Well, I think the Ecard, simply 11 from our general knowledge that in this general part of 12 Pennsylvania live a group of people who may not fit into the 13 general population of emergency planning, we may take some 14 type'of primitive official notice tha t there micht be a 15 problem.
16 To what extent we want to pursue it would have to 17 depend upon how the evidence unfolds.
I would have a o eat 18 deal of suspicion about any one individ ual purporting to
'f people.
19 testify for a large group o
20 But let's see how well the Commonwealth people have the demographics and the information at hand.
21 MR. AAMODTs Mr. Chairman, I have completed that 22 that cross-examina tion on these witnesses that 23 testimony 24 I am prepared for.
CHAIRnAN SMITH:
Excuse me.
Along this line, too, 25 ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE.- 3.W., WASHINGTON, D.C. 20024 (202) 554 2345
14,157 1 one of the reasons why I think it is sppropriate fer the 2 Posrd to ask particularly stour the cid AmiFh, cid Order 3 Amish, is that I woul guses it would
'c vary unlikaly for a 4 member of the cid crder Amish community to intervene en one 5 of our, proceedings.
6 And I think under those circumstances it would be 1
7a little bit more appropriate for the Ecard to make s 8 particular inquiry than otharvise.
9 AP. AAMODT:
'Mr. 2mith, there is an item here that 10 migh t be of interest to you.
The way*the Amish is 11 structured, they do have a bishop who literally goes to 12 Washington and represents the Amish.
And he could be 13 prevailed on, I would think, to intervene, if that were an 14 option you would like to consider.
15 CHAIREAN SMITH:
Well, you have just taken away 16 the justification I had f or the particular inq uiry.
But 17 neve rtheless, I do think it is appropriate to inquire 18 especially.
39 OR. JCHNSRUD:
Mr. Smith, mi;ht be appropriate to 20 add the observation that there are, amonc the old order 21 Amish, many who do not speak or understand the Enclish 22 la n g ua g e.
And I see no indication that this issue has been 23 addressed.
I should think the Board might be interested in 24 it.
l l
25 CHAIRMAN SMITH:
Thank you.
l l
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON. D.C. 20024 (202) 554 2345
14,158 1
Have you concluded your cross-examination?
2 U.
7AMODT:
.i o, sir.
I h a ve cCrpleted tha t which 3 relates to the prefiled material here.
But I have several 4 questions on there that are appropria te to ssk from Mr.
5 Sholly.
I will limit that to one.
And then I have one 8 additional question that is inferred from what is going on.
7 CHAIRMAN SHITH:
We will leave it up to you.
8 Would you prefer to wind up tonight?
9 MR. AAMODT:
Yes, sir.
10 CHAIRMAN SMITH:
If there are no objections --
11 sR. AAMODT:
We can easily do that.
l l
12 CHAIRMAN SMITH:
Okay.
13 MR. AAMODT I think I would like to defer to my 14 wife on this questiCn.
It is of particular interest to 15 her.
18 BY MS. AAMODT:
(Sesuoing) l 17 Q
Could you gentlemen tell me what the Met Ed policy 18 rega rding reports to the media of low level radioactive 19 releases is?
20 A
(WITNESS ROGAN)
I am sorry, I cannot answer that 21 policy statement.
I do not know.
22 A
(WITNESS GIANGI)
I am not qualified to answer 23 that.
24 Q
For instance, if there were a transient at the 25 plant, an unusual event or something like tha t, and there ALDERSoN REPORTING COMPANY,INC, 400 VIRGINlA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
b 14,159 1-was radiation releaced, in repcrt Cf this wha t wculd ' --
2 would this de charactorized ar to raciation releasad?
3 A
(VIT'< FES ?CG A':1)
?beelutely nct.
Io the' extent 4 that I ar. f amiliar with th: ;ublic relations ;clicy of the 5 licensee, it is their pc icy to keep the public informed of 6 any events which occur at the plant and to be quite frank 7 and straightf orvard, incluc.ing the' details of any releases
'6 or any areas of general information to the'public.
That is g my best understanding of our approach to the public to relations.
11 0
h*ould you tend to interpret this data, if you say-12 radiation is released, by sa ying, no, there was no hazard to 13 the public health and safety?
14 A
(WITNESS ROGAN)
I am sorry, you will have to ask 15 that question again.
18 Q
Is the -- is the terminology "no hazard to the i
17 public health and safety" ured in your releases where you 18 report that radiation was released?
gg A
(WITNESS ROGAN)
I am really not sure.
20 The problem I am having is I am not sure whether 21 you are asking if that is used as a replacement for -- for 22 radiation data or as an extension of a release, of a public information release where we have advised the public that 23 24 something has occurred at the plant, tha t there has been a 25 release, what that release is, and then we interpret that ALDERSoN REPORTING COMPANY. INC, j
400 VIRGINIA AVE., S.W., WASNINGToN, D.C. 20024 (202) 664 2346
I 14,160 1 relence in ter?e of its potentia l hszard to the public a t 2 large.
3 0
- am just comparinc this, say, with the weather 4 repo rts, which include tha air quality and, you know, give l
5 th e air quality.
Put they never come after it with "and 6 there is no hazard to the public health and sa f e ty. "
that have been
{
7 Now, readinc the reports from 8 out, that have come out of t ransients a t nuclear power e plants, I have f.m uently seen the terminology that 10 radiatior. released was low level and there was no public --
11 no hazard to the public health and safety.
12 Is that a terminology that you use in your 13 re po rt s ?
14 A
(WITNESS ROGAN)
I am not qualified.to answer that 15 question.
16 0
At the time you would issue a report to the media, 17 do you have a measure of radioactive iodine, strontium 90, l
18 or cesium 137?
19 A
(WITNESS BOG AN )
Again, I am not qualified to 20 answe r th at.
21 Q
Do any of the gentlemen -- could any of them 22 a'n sw e r t hat, answer that question?
23 A
(WITNFSS GIANGI)
Just for clarification, we do 24 not interf ace directly, the panel, with the media i
i l
25 specifically.
During an emergency, such information is 1
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1a,161 1 transnitted to the effsitd scencies, namely Eureau of 2 ?adia tion Fr0 tection and the.G C.
Trem t r. a t, the public 3 inf orma tion depa rtment, who har the media. center activated, 4 would bring all this indermction out tc the medis 5 representatives.
6 Q
I understood that there was a place for the media 7 to get reports en radiation right onsite, essentially, or 8 one of your of f site onsite locations; is tha t true?
9 A
('4I TN FSS ROGAF)
That is correct.
It is offsite.
10 0
It is offsite, but it is essentially an onsite 11 type of -- you would consider that a Licensee 12 A
('4 ITNSSS ROGAN)
It is a Licensee facility, yes.
13 C
Facility, yes.
14 So is that not a consideration, then, in this --
15 in this consideration of notification of the public, that ve-16 take up this issue?
Is there any way we can cet these 17 answers as to what their policy is on news releases, the use 18 of the terms "no radiation released," "no hazard to the 19 public health and saf ety," and measures of strontium 90, 20 cesium 137, and radioactive iodine at the time of these news l
21 releases?
22 A
(WITNFSS GIANGI)
Appendix B to the TMI emergency 23 plan is the emergency public information plan.
That 24 addresses how the public inf orma tion depa rtment is manned, 25 how the center is activated, and how the information is i
i ALDERSON REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASNINGToN, D.C. 20024 (202) 554 2346
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r 2
C I ?.12 not wan:
3 CH2.!..AL T4IThs Zhic content of the information 4 --
5 BY :13. A A O DT
( R e su r.in g )
6 0
Policy of the content?'
7 A
(WITSESS GIAhGI)
I am not aware of the content of 8 that information, sir.
9
S. AAMODT
'Is it pocsible to get that, Chairman 10 Smith?
I thought that we had provided for that in our 11 specification of this contention, that we were interested in 12 ~~
l 13 CHAIPMAN SMITHS I do think that in one of the 14 documents that you. brought.to our attention today,-which we 15 said we would construe your contention under, that there was 16 a reference to the content of the inf ormation.
17 But I think the question you have put, however, 18 would be a very difficult one to answer.
It is, I think 19 I think you would have to elabcrate.
I do not know how I 20 would answer such a question.
21 MS. AAMODTs Where I am going ic that I am 22 wondering whether thic is f air to the public in terms of 23 allo wing those who wish to take protective action, in that 24 they have no means of detecting radiation other than the l
25 repo rts that are given them.
l l
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CH 1.IE A H S ZITH You want to know if there is a l
2 policy 'ihich permite the izen.:ee to ute ruch terre as "no 3 radiation hn zs rd "
- n:1 if t h -rc-is a pclicy which :cquires 4 the cognizant efficial to :<fer to the cont =nt of radiation 5 rele ases, the type of radia tion release:7 Is that what you 6want to know?
7 MS. AAMODT4 Yes, I want that.
I wanted to know 8 whether it is the policy to say there is no hazard to the 9 public health and caf ety.
10 CHAIRMAN SMITH:. All right.
Do you know that?
Is 11 there a policy to say that there is no --
12 WITNESS ROGAN:
I do not know that.-
13 CHAIRMAN SMITH:
You do not know that.
14 W1TNESS ROGAN I do not know that, no, sir.
15 CHAIRMAN SMITH:
Okay.
I think we ought to find 16 th a t out.
If you are in doubt about it, I think we ought to 17 find out about it.
18 MR. ZAHLER.
fr. Smith, I will attempt to acquire 19 that information for tomorrow morning.
~
CHAIRMAN SMITH:
All right.
20 21 Then I think -- what is the second half of your 22 --
XS. AAMODT:
Well, I am also -- I guess it is 23 24 included in that.
I wanted to know at the same time whether 25 measures that are not able to be taken are rimply considered ALDERSoN REPORTING COMPANY,INC.
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i 14,164 1 as no radiation being released.
If it is not able tc be 2 tascured, it tPat the rama as rhyin: that
- r. c rtdistion is 3 released ?
4 CHRIE T;I 7'!ITH:
O h ?. y.
~e.n you find that out?
5
- 52. 2.3HLE.:.4 Just let me get clear what the last 6 request is, that if you are unable to measure the release 7 --
8 MS. AAMODTa I am assuming, from having talked g talked with, many years prior to this -- as information
[
10 director for'the Pennsylvania Farmers Association, I was 11 interested particularly in the Peachbottom plant, and I i
12 spok e with people there and I understood tha t they do not L
13 measure certain radioactivity from the stack -- iodine, 14 cesium 137, strontium 90 and that they at the same time 15 were putting out notices which said no radiation was I
16 released.
17 Then they said, oh, yes, that was released, but we 18 have no measure of it.
And that is the kind of tning I am l
1gasking, f rom that -- from that point of reference, I am 20 asking that question.
21 CHAIE2AN SMITH:
So the question is, is there a 22 policy on the p?.rt of the licensee to inform the public that 23 no radiation was released, when in fact some radiation was 24 released but was not measured.
Is that 25 dS. AAMODT:
Yes, that is the same philosophy as ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2346
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14,165 1 what is stealine.
The recend crader'sayr'it is'nct'being-I 2 caught' taxino rotethine.
3 CHA!?*.AN S?!"'F That is not a par t. of the 4 question.
I-just. anted yeu t: confir whcther'I rad
.5 restated your question' accurately.
6 MS. AAMODTs You did state it, yes, Chairman 7 Smith.
8 I also had just a very brief questioning of Mr.
9 Tsagga ris.-
to BY MR. AAMODTs (Resuming) l
-11 Q
Just so mine is finirhed, I just have one, just 12 some very brief - -just some'very brief follow-ups on Mr.
13 Shelly's.that.also relate te mine.-
14 In yesterda y 's testimony, Yr. Rogan, you 15 acknowledged -- you described 0654 in terms'of sufficiency.
16 You used.the word " sufficiency" in terms of describing 17 emergency preparedness at plants.
18 Woulc you say that in all cases you would consider 19 the guidelines of 0654 as sufficient?
20 A
(WITNESS ROGAN)
I would like to have time to r
21 review that specific testimony and the use of that word in 22 that context before I answer the question.
23 XR. ZAHLER:
Well, I do not know that we could 24 ever find th a t.
~Can we delete the reference and just ask 25 him to ask the question, do you believe that compliance with L
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.2 CH A I F..1N C.'
Ti! :
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3
R.
A MODT:
That is acceptable.
4 W:TNIFS ?.C F. A :i I !c not believe that simply 5 complying with 0654 is sufficient, nor is it our pclicy.
6 BY MB. AAMODTa (Resuming) 7 0
Thank you.
8 Mr. Ciangi, with regard to implementing action g levels -- this bears on the earlier lina of questionino.
I-10 just noticed I had this from yesterday.
11 You used the expression "try to take away 12 discretion f rom the operator," which relates to our 13 discussion earlier.
Would you like te elaborate on that i
14 thought?
15 A
(WITNESS CIAhGI)
To the extent that the emergency 16 action levels are much broader, much more definitive, much 17 more descriptive, and indica tors with specific numerical 18 values are indicated, to tha t level it minimites the 19 dependence of the discretionary rule that we talked about l
20 earlier.
21 C
So in fact here you are not trying to do t
l 22 something, you are doing something?
l 23 A
(WITNESS GIANGI)
Plea se repeat that.
24 0
I say, in fact here it is not a matter of an 25 im plied possibility of failure.
You are just simply saying i
t i
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i 14,167 1 you era doinc it?
2 3
( b !!:i ' F'! G ~.E : NI)
Yir, sir.
3 0
All *;i;ht.
4 (Faurs.)
5 0
And-the last one.
I note, Tr. Fogan -- let me 6 just have a moment to ba prepared for this one.
7
( Pa use'. )
8
.4 5. ZAHLIRs
?. r. Fmith, I would also lik e th e 9 record to reflect that 'as coon as Ms. 11dgway maken me a 10 copy, I have been handed the information that Mr. Aamodt 11 requested about the Unit 2 plan at the time of the accident 12 and the discretion it provided.
I would be prepared to give 13 that to him.
14 3E. AAs0DC:
Thank.you.
15 BY MR. AAMODTs
( D, esum in g )
16 0
Mr. Fogan, I note that the -- nearly your entire 17 -- s t least it appears from your qualifications sheet here 18 that nearly all of your professional career has been in the 19 military; is that correct?
20 A
(WITNESS ROGAF)
That is correct.
21 0
'4 hen in 0,he military, you served in some positions 22 of considerable aut hority?
23 A
('JITN ESS ROGA N )
Yer, I did.
24 0
In those positions, were you accustomed to 25 subordinates responding promptly and precisely to your t
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
14,168 1 directivas?
2 A
(.:L.iSS ??CAS)
'?ithin rear nable limits, yer.
3 0
.Le t t s cr = =. te a h ypc th e tical rit ua tie n..
t.ssume 4 that Three Tile Island was cwnee sn.e o p e ra t e r'. ly th*
5 military, tnat you had the responsibility for implementino 6 the procedures relative to emergency planning.
- Suppose, 7 more specifically, that you were the shift supervisor or his 8 immediate superior.
9 You santioned yesterday wall, we discussed 10 yesterday, or dr. Sholly did, the three steps that provide a 11 measure or sn estimate of the ma ximum response time required 12 f rom the initiation of an event until notification of the 13 public.
Maximum was 40 minutes.
14 If 'everyone involved was,well-trained military 15 people, f rom the time of classification of the accident i
16 until the time of notification of PEMA and Dauphin, how.long l
17 a period of time would elapse?
l l
18 A
(WITNESS BOGAN)
I would probably stick at 19 something like the estimate I gave yesterday, something like 20 two minutes for those two telephone calls.
21 0
Two minutes.
22 CHAIEhAN SMITH:
This may be testimony that you l
23 missed.
I 24
.4R. AAEODT:
.i o, I heard it.
I recall the seven 25 minutes very clearly.
l ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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CH AIRI' AN S MITF s Oksv.
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!? M I.. A A.': C 0 ! 1
( ? ? s ur. in ; )
3 Q
If you had a civilisn creup, would you expect a 4 different
?sponse?
Gener3117 do military personnel respond 5 more - prom ptly, more efficiently to orders than do civilian 8 people ?
7 MR. ZAHLE3 s Objection.
~
8 MR. AAMODT4
.N o.
I object to the objection, Mr.
9 Smith.
I think it is relevant.
10 (Laughter.)
11 CHAIRMAN SMITH:
I will have to rule on the 12 objections in the order in which they were received, which 13 means that we will never get to yours.
14 The point the point I think tha t you are 15 getting at is, isn't his assessment of these response times 18 biased by his military experience.
'ih y don't you just go 17 directly to the point, instead of these comparisons.
18 Could you give us your view of how you feel that, 19 within the area of the question, how you feel civilians 20 react compared to military people?
21
'4ITN ESS EOG AN :
Yes, sir.
In the case of the 22 control room operators and the level of training that I 23 believe they possess and will continue to possess, I would 24 see very little difference.
25 MR. AAMODT That -- that takes us so far.
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DY 53. AAMODTs (Resuming) 2 0
I n a v e.
ar additicnsi qucstion new.
!+Etsrday you 3 sali that you antiripatef that J E:' A cculd fc itr job in.no 4 more then five cinates.
Ec yeu still feel thr.t way?
5 A
( WIT::ESS ?.CG A L )
To tne extent tha t ! defined 6 their job, yes, I do.-
And for clarification, that was, once 7 they received the instruction to notify the. counties and to l
8 execute the notification system, it war my judgment that it g should require no more than five minutes for them to.make 10 those five calls.
11 Q
If they -- if they were -- if the people at the 12 state le vel were well-trained military people, could they do 13 it faster than that?
14 A
(WITSISS ECGAF)
No doub t in my mind about that.
15 My expecience over a number of years in many emergency j
i 16 operating centers tells me I could make those calls in less i
17 than 50 seconds if it were truly an emergency _and I was with l
18 a well-trained milita ry crew.
t 1
t 39 C
So then, what you are suggesting is the civilian l
20 people in the Commonwealth quite likely will perform a t a 21 lower level of efficiency than the people with whom you are 22 directly impacting at Three Mile Island or would have in the 23 military ? '
24 A
(WITJESS ROGAN)
That is a rather broad, sweeping j
25 inference, which may not be totally valid.
l f
ALDERSoN REPORTING COMPANY,INC.
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.C The point I a.t d rivinc at -- let te ask you the 2 final question, ant that is the'end cf y 'estirCny.
3 I
tha qu?stiCa of bias I think is very 4 im po rte nt, not tron the ;cint of vi ew ct intenticnal bias, 5 bu t from the point of view cf perspective.
We have a 6 political body in Harrisburg.
'ie have people who are not 7 trained, when asked to jump, to say how'high.
We have 8 people who are trained to worry about what-evarybody else 9 thinks about it.
10 Don't you think that, considering that kind of 11 12
3. ADLE54 Mr. Chairman, we have not had an 13 establishment that these witnesses are familiar with PE%A's 14 training.
And AI think the assumptions are getting out of 15 hand.
j 16 MR. AAMCDT:
All right.
I will leave it, fr.
17 Smith.
18 CHAIRMAN SMITH:
All right.
19 MR. ADLER:
In fact, most of them are career 20 military peo ple or were career milita ry people.
21 CHAIP%AN SMITH:
Anything further?
22 MB. AA7007:
That's all I have.
Yy wife has a 23 qu es tion.
24 CHAIEMAN SMITHz You are going to be here 25 to mo rrow, aren't you?
ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W WASHINGTON, D.C. 20024 (202) 554 2345
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MS. AAMODTs I ho.e to be, yes.
2 Ci. A!! A'i v.i ! !t. :
!11 right,.then.
I u say yeu 3 have a few more questions?
4
S. AAM00!:
Yec.
Ihir.i: rather brief.
5 CHAIRMAN S"ITH:
Just a few minutes after 5:00 we 6 thought we were within a few minutes'of cleaning up the 7 Aamodt's.
If it is not literally very brief, let's put it 8 over until tomorrow.
g MS. AAMODT:
I feel as though it is very.brief.
I 10 wanted to ask -- ho w much time did you -- what did you mean 11 by brief?
- aybe I should ask that, Mr. Smith.
12 CHAIEMAN SMITH 4 I mean a few minutes.
Less than 13.five minutes, is what I mean.
14 (Mr. and Mrs. Aamodt conferring.)
15 M5. AAMODT I will try it and then give up in 16 five.
Is that all right, Mr. Smith ?
Is it all right if I 17 try it, and then if it is not five I will give up?
18 CHAIRMAN SMITH:
Yes.
19 "S.
AAMODT:
Okay.
20 CHAI3")N SMITH 4 No.
This is follow-on 21 cross-examina tion?
l l
l 22 MS. AAMODT4 This is -- in a way, you could call 23 it that.
In a way -- would that be better?
24 CHAIRMAN SMITH Is it covered by a 25 cross-examination plan?
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I 14,173 1
"G.
- 3. b.O DI s Thic, no, it ic net ccvered by th e 2 plan that you have.
3 CH AIP A!! 3MITH:
Yes, okay.
'" ell, then it better 4 be f ollow-on cross-exarination, ! Iesn information that was 5 developed during the -- go thead snd ask your questions.
6 EI AS. AAh0DTs (3esuming) 7 0
I wanted to ask, Fr. Tsaccaris, is it true that 8 you were director -of training and supervisor of nuclear 9 training for Tetropolitan Edison Company between what 10 years, could you tell me?
5 11 A
('41T' NESS TS AGG ARIS)
First of all, I was director 12 of trLining and supervisor of training f or Metropolitan 13 Edison Company between Janua ry of 1976 to approximately 14 August of 1978.
15 C
And did you develop any part of the training 16 program there?
It was my understanding that you did in the 17 area of health physics; is that correct?
18 A
('4ITNESS TS AGG ARII)
At that time the health 19 physics program was developed by the health physics 20 de pa rtment.
21 0
Oh, I thought it said here in your biography that 22 y o u -- t h a t is the wrong page -- that you were -- that you 23 planned, coor dina ted and executed the annual radiation 24 exercises.
And then above that, that all -- that you were 25 in charge of all maintenance and health physics -- required ALDERSoN REPORTING COMPANY,INC, 400 VIRGINIA AVE., S.W., WASHINGTON, D.C. 20024 (202) 554 2345
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i 14,174 1 operations and maintenance and health physice programs at 2 the Three 111= ' cla :.d Statiar.
3 So you did not devalop that, but you were in 4 charge of tha t orog ra m, is that rl=ht?
5 A
(WIT'*rSS TEAGGARIE)
That is correct.
I did not 6 personally develop the procram, but training activities were 7 cond ucted under my supervision.
8 0
Yes.
'4 hat' is your opinion of that procram that g was in place 'at the time that you were there?
10 MR. ZAHLER:
Objection.
It is not follow-on 11 cross-examination and it is not covered by the direct -- the 12 scope of the direct testimony, either.
13 CHAIREAN SMITHS And it is the same problem we 14 have.
In addition, you are talking about the plan that was 15 in effect when?
16 MS. AAMODTs The plan that was in ef fect at the 37 time _that Mr. Tsaggaris was in charge.
18 CHAIRMAN SMITH:
I think you had better prepa re --
19 that is a very dif ficult question.
I think you had better 20 prepare maybe a cross-examination plan so we can see where 21 You are going, which you can do overnight.
22 What is your objective?
23 MS..T.AMODT My purpose is to find out whether Mr.
24 Tsaggaris was pleased or displea sed with the program --
CHAIR 3AN SMITH:
'4 ho cares ?
25 l
l.
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MS. AAM007 that was evidently in'effect at i
2 the tim + cf the acciden:, and wh e t he r - r.e ir ;1 eased or 3 disrleasec' rurrently with the Eevision 2, and whether he is 4 currently werkinc on
- hic.
5 CFAIR"AN IMITH That is a vary long plan of 6 cross-examina tion.
You prepare a ' cross-examina tion plan and 7 return tomorrow.
8 MS. AAMODT All right, o k. a y.
9 CHAIEMAN SMITH:
And then --
10
- f. R. AAtODT That concludes our cross-examination 11 tonight.
12 CHAIRMAN SMITHS Mr. Zahler, you want to 13 distribute --
34 MR. ZAHLIR:
Mr. Chairman, I am sorry, I missed 15 it.
There was some discussion before.
But I was just told 16 that I spoke too hastily.
We are not sure that the page I 17 thought was the page I wanted to give to Mr. Aamodt is the 18 correct version and the right time.
19 So I am going to have to do tha t at a later --
20 tomorrow.
I 21 CHAIRMAN SMITH 4 Okay.
All right.
We will 22 ad journ and meet tomorrow at 9:00 a.m.
23 (Whereupon, at 5 :3 0 p.m., the hearing was 24 recessed, to reconvene at 9400 a.m. on Thursday, March 5, 25 1981-)
ALDERSoN REPcRTING COMPANY,INC, 400 VIRGIN 1A AVE., S.W. WASHINGTON, D.C. 20024 (202) 554 2345
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I NUCLEAR REGUI.ATORY COMMISSION This is to certify that the attached proceedings before the in the ::latter of: METROPOLITAN EDISON COMPANY (TMI UNIT 1)
Date of Proceeding: March 4, 1981 Docket !! umber:
50-289 Place of Proceeding:
Harrisburg, Pa.
were held as herein appears, and that this is the original transcript thereof for the file of the Co= mission.,
David S.
Parker Official Reporter (Typed) m Mt_L-(s: mA r ?r er.=. 7cs.= ?.
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