ML20126H111
| ML20126H111 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/21/1985 |
| From: | Rorem B COMMONWEALTH EDISON CO., ROREM, B. |
| To: | |
| Shared Package | |
| ML20126G862 | List: |
| References | |
| OL, NUDOCS 8506180254 | |
| Download: ML20126H111 (88) | |
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i ROREM SU8 CONTENTION 1(c) I ATTACHMENT D i
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
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In the Matter of: :
COMMONWEALTH EDISON COMPANY : Docket Nos. 50-456
- 50-457 (Braidwood Nuclear Power Station, s Units 1 and 2) :
x Isham, Lincoln & Beale 50th Floor Conference Room Three First National Plaza Chicago, Illinois 60602 DEPOSITION OF:
BRIDGET LITTLE ROREM called as a witness herein by Counsel for the Applicant, t
Commonwealth Edison Company, commencing at approximately 5:00 o' clock, p.m., Tuesday, May 21, 1985, pursuant to notice, taken before ANN RILEY, a Notary Public in and for the District of Columbia, when were present on behalf of the respective parties:
ANN RlLEY 8t ASSOCIATES COURT RsPoRTERs s e2s i stResT. su Ts 921 WASHING 7oN, DC 20004 202 293 39so
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1 APPEARANCES OF COUNSEL:
2 For_the Applicant Commonwealth Edison Company: , ,
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3 JOSEPH GALLO, ESQUIRE l l l Isham, Lincoln & Beale t j 4 1120 Connecticut Avenue, Northwest l Suite 840 l
- 5 Washington, D.C. 20036 l l i I e -and-l '
l 7 VICTOR COPELAND, ESQUIRE .
l Isham, Lincoln & Beale 1 8 Three First National Plaza I Chicago, Illinois 60602 i 4
For the NRC Staff: f i
,. ELAINE CHAN, ATTORNEY-AT-LAW 11 Of fice of the Executive Legal Director ;
U.S. Nuclear Regulatory Commission i 12 Washington, D.C. 20555 i i
13 For the Intervenor Bridget Little Rorem
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r M TIMOTHY WRIGHT, ESQUIRE
17 ALSO PRESENT W David Smith, CE Monte Phillips, NRC
- Tom Ploski, NRC !
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I WITNESS: EXAMINATION BY: PAGE:
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f Bridget Little Rorem Mr. Copeland 4 1 Ms. Chan 71 i 3 Mr. Wright 80 Mr. Copeland 82 [
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1 PROCEED i NOS 2 15400 p.m.)
3 MR. COPCLAND: This is the deposition of Bridget 4 Little Rorem in the operating license proceeding for tho 5 Braidwood Nuclear Power Station before the Nuclear Regulatory C Conen i s s I on .
7 This deposition is called by the Appilcant, O Conenonwea i t h Ed i son Company .
9 I am Ulctor Copeland of Isham, Lincoln & Beale, the 10 attorneys for Cornmonw ea l t h Edison Company. My address is 1920
, 11 Connecticut Avenue, Northwest, Washington, D.C. 20036. With 12 me here today also is Joseph Gallo.
It Do the other parties want to identify themselve:s?
14 MR. WRIGHT: I am Timothy Wright, an attorney with 15 Bpi, representing Ms. Rorem for purposes of this deposition.
16 MS. CHANT My name is Elaine 1. Chan with the 17 Nuclear Regulatory Commission, and I am counsel for the NRC 18 Staff. And with me here today --
19 MR. PH I LL il'S e I 'm Mon t e Ph i l l i p s , Chief of the 20 Emergency preparednoss Section, NRC Region Ill.
21 MR. PLOSKI Thomas Ploski, Emergency preparedness 22 Analyst, Region Ill.
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4 1 Whereupon, 2 BRIDGET LITTLE ROREM S was called as a w6tness and having first duly affirmed to tell 4 the truth, the whole truth, and nothing but the truth, w a .s I
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.; 5 examined and t e.s t i f i ed as follows:
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, 6 EXAMINATION 7 BY MR. COPELANO:
G Q Ms. Porem, I am going to be asking you questions to '
9 find out what the extent of your knowledge and concerns are 10 regarding your Contention No. 1, which I.s raised by you 11 concerning emergency planning.
12 If you hear a question and you don't understand what i
j 13 1*ve said, feel free to ask me to repeat it, or if you don't 14 understand the question, feel free to say so also, and if you 15 rea l iza somewhere a long the way that you gave an inconsistent ;
i 16 an swer earlier, feel free to correct it, or if you have an 1
17 incomplete answer, feel free to stop me and complete your 18 answer. And if at any time you are feeling tired or want to l
19 stop and stretch your legs or anything, j u.s t feel free to say 20 so.
21 Could you state your name and address for the 22 record, please?
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5 1 A My name la Dridgot Little Rorem. I live at 117 2 North Linden Street in Essex. Illinois 60935.
3 Q And you are an intervenor pro se in this proceeding.
4 la that correct?
5 A And?
6 Q Appearing without counsel in the proceeding, except 7 for today where you appearing with counsel in this doposition.
O A Yes.
O Q Are you also acting as a representative of Appleseed 10 Alliance?
, 11 A It's not Alliance. it's Appleseed.
12 Q Are you employed?
13 A Self-employed.
14 Q What do you do?
15 A i sell knitting patterns.
16 Q Have you ever had any employment, regular 17 employment?
10 A Regular employment, yes.
. I 19 Q What was the nature of those positions?
20 A The last time I was employed by someone, it was the 21 American Friends Services Ccecilttee as a --
the word's slipped ,
22 my mind -- what did I do? -- as an organizer. I couldn't
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t remember the mord. Excuse me.
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- 2 Do yone mant other employ +ent previoJs to thati 1 L I
3 Q Do jou have anything else' What other employment i i !
4 have you hadi !
t 5 A Cefore that, I think the last time I was eep'oyed i f
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i 6 was by Riverside Hospital in Kankakee- l 7 C What did you co for Riverside Hospital? j l 8 4 4
I was a clerk-typist, I was an admitting' clerk, to ,
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10 C 'Ja s this ter an emergency room or --
- i l 11 A Yes.
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' l 12 Q Can ytu tell us about yoar education?
j 13 4 I was gradJated from the University of Illinois '
1 14 High School in 1967. I attended the University of Illinois 4
15 frem 1967 until '63, and then again from '69 th-ough '70.
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j 16 Q Oo you have a degree from the University of i 4
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18 A No. I do not .
19 Q What was ycur primary area of study while you were i
- 20 there?
- 21 A An t hr opo l cg y , although I didn't really study
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22 anthropology nearly as much as I studied literature. I mean. ,
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6 1 I was an anthropology major, but I don't have most of my 2 credits in anthropology.
3 Q Have you had any other formal education beyond that' 4 A Formal education?
5 Q Such a.s seminars or picked up a course here or 6 there.
7 A No, I do not have any other formal education.
i O Q Have you ever studied health physics in any way?
9 A i have not formally studied, no.
10 Q Have you ever done any study on the biological
, 11 effects of radiation?
12 A No formal study.
13 Q Or any medical training?
14 A No.
15 Q Have you ever studied communications beyond your i 16 study of literature?
t 17 A No.
18 Q Have you ever had any training in civil defense, 19 such as civil defense training for emergency actions?
20 A When I was in Girl Scouts.
21 Q l was a Boy Scout. I won't knock that.
22 And have you ever authored any articles or papers.
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l 0 A No, I have not.
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3 Q Or expressed your opin6on anywhere? ,
4 A Yes, l*ve expressed my opinion.
t 5 Q Can you tell us where that was? l i
6 A Do I have to tell you all the places? That's a very h 1-7 difficult thing to do.
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i G Q What was the nature of this communication?
9 A Organizing meetings. Free speech forums.
to Q What is a free speech forum? i I I 11 A Well, for instance, the college complexes here in 12 Chicago weekly holds a meeting where they invite a speaker, 5 i-13 and, you know, that sort of thing.
14 O What have you spoken on?
15 A The necessity for participation in democratic 16 institutions. i i
17 Q How long have you lived where you live new?
18 A For nearly eight years. It will be eight years in 19 August.
20 0 Where did you live before that?
, 21 A 1 lived about twelve miles southeast for a year and l
l 22 a half.
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1 Q And before that, you were in Champaign. I presume?
I 2 A No. Before that. I was in Kankakee for three years.
3 and before that. I was in Urbana.
4 O And how many children do you have?
, 5 A Four.
l l 6 Q And what are their ages?
1 7 A Twelve and a half, nine and a half, eight, and five.
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l O Q la thlm the first time that you have ever intervened I
j 9 in a proceeding before the Nuclear Regulatory Commission?
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I 10 4 No, I intervened in the relicensing of the General
, 11 Cloctric liorris operation.
12 O What was the nature of your intervention there?
13 A Short.
14 Q Were you there on your own behalf, or were you with 15 Appleseed at the time?
i 16 A Yes, I was with Appleseed. Appleseed was not 17 accepted as an Intervenor in the proceedings, so I was 10 intervening on my behalf, and there were three other --
I 19 Q May I ask why you were not accepted as an 20 intervenor?
21 A Why Appleseed was not accepted?
22 Q Yes, i
( 10 1 A Thia la going back six years. I'm trying to 2 remember why they would not accept ua, but they wouldn't 3 accept us. I don't remember.
4 Q Oo you remomber the issue that you wore raising?
5 A 1 can't remember. I'm sorry. I would have gono 6 over these things, if I had known you were going to ask. But 7 1 didn't -- don't remember. l 8 Q Have you ever participated in any other NRC 9 proceedings other than the one you have just named?
10 A Just this one, up until now.
, 11 O Have you ever participated in any other 12 administrativo preceedings, such as before the Illinois ;
13 Commerce Commission or the --
14 A Walt a minute. Excuse me. Ask me the question you 15 asked before this once more.
16 0 1 believe it was, have you ever participated in any !
17 other NMC proceedings other than Braldwood and Morris?
18 A Yes. But i instigated it it wasn't any k ind of 19 formal proceeding. Th'ree years ago, I filed a 202.6 reque.st 20 concerning the LaSalle Nuclear Station.
21 Q And I take it that request was denied?
22 A No. Well, they went through various permutations of i
I 11 1 process. Don't ask me to descelbe them, t Q What was the lasue that you raised there? l l
3 A Quality assurance, quality control.
t 4 Q And this was three years ago? ,
5 A Yes. April -- March or April of 1991 ~~ '927 882, l
6 it must have been.
7 Q And that was before the plant had received its [
9 license? '
9 n it was, it was fuel loading. I r
10 Q la that 64 for NRC proceedings? (
, 11 A Yes. <
1 12 O Have you part ic ipated in any other administrative 19 proceedings, .such a s t)ef ore the Illinois Commerce Commission 14 or the Environmental protection Agency?
15 A Yes, the Environmental protectlen Agency, two, three 16 years ago, this coming fall, I think it would be, or maybe it 17 was four years ago this coming fall, Sonstar Corporation was 18 attempting to alte a hazardous waste incinerator and recycling 19 facility in Kankakee County, and I was part of a group of 20 people who -- I'm not sure -- their proceedings are called 21 different things than what yours are -- but we did whatever we 22 had to do to interject ourselves.
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i i O You participated? ;
t 2 A We participated, yes, i 9 Q And what was the issue there? i L
4 HR, WMISHT: Counsel, at this point. I may have to '
5 Interpose an objection. I understood the purpose of this 6 deposition was related to Contention 1, Emergency planning. I i
? have allowed quite a bit of latitude with respect to t
8 background, I suppose that's what you're getting 6nto, i g HR, COpCLANO: If I may answer that, also, i 10 believe, part of the deposition is, we are attempting to f i
11 estabilah what, if any, biases or prejudices that she msy have f
I 12 and find out ekactly what her poaltion is with regard to the ;
13 leavea. Anti for the sake of expediency. I'll proceed.
14 SY HM, COpCLANO IS Q Unre there any other administrative proceedings? l 16 A 1 don't think so. I i
i l 17 0 Have you ever participated in any way as a witness i i
18 or party to any civil proceeding where there was a public 19 health issue or environmental leaue. a civ,Il proceeding -- I to mean, before a court, rather than administrative?
21 A No, I don't believe so.
22 0 Okay. Now you represent ==
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i k 13 1 A Walt a minute. I might have to take that back. I C did testify at the trial of someone who was involved in a 8 demonstration at a plant. I was a character witness.
4 O Have you ever been called to testify in regards to 5 -- or excuse me -- give an opinion on public health issues or '
8 6 environmental issues?
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s i V 7 A Yes. Many timea. I've testified at HMC things, i
l 8 whatever they call them, hearings.
9 Q WhIch hearings 7 10 A Hearings on safety standards that were held here in l 11 Chicago four years ago, I think it would be.
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12 O This was a generic proceeding?
l 10 A Yas, yes.
14 Q And what was the nature of your -- did you give a 15 statement, or did you actually testify?
] 16 H I gave a statement t
j 17 0 A Iimeted appearance atatement? I*m not famiiiar .
1 18 with these generic proceedings.
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19 MS. CHHN Excuse me. I would 1ike to cIarIfy. Was 20 this a public meeting, or was this a licensing proceeding.
21 THE WITNESS: It was not a licensing proceeding.
22 They were collecting testimony for the purposes of cening up 1
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( 14 1 with safety standards.
+ ' 2 MR. PHILLipS: It sounds like a public meeting to 3 me.
4 THE WITNESS: But the witness was administered by e
5 the League of Women Voters, cred_ there were various NRC 6 personnel taking testimony, sometimes asking questions of 7 people, but you had to --
you know, you had to get on the list 8 to testify.
9 BY MR. COPELAND:
10 0 Do you remember the theme?
11 A Yes. It had to do with the fact that I felt it
. 12 would be difficult to come up with suitable safety standards 18 for all circumstances, for me in particular.
14 Q These safety standards, what were they relating to, 15 what particular aspects of nuclear power, do you recall?
16 A 1 didn't think I had such a faulty memory. My 17 testimony had to do with the fact that I might possibly be 18 evacuated for accidental happenings at any of four nuclear 19 facilities, and that in such documents as Final Safety 20 Analysis Reports for Nuclear plants, the necessity for 21 risk-taking is partly justified by the fact that those who
'22 live nearby the plant also receive benefits from the taxes and
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15 1 so forth. And I remember being exasperated with that fact, 2 because I don't receive any benefits from the taxes, because 3 l'm not in the taxing area for any of these plants. I mean, 4 in other words, i was arguing about the justifications the 5 Nuclear Regulatory Commission gave for the need for certain 6 parts of the public to accept the risk of living near 7 facilities like this.
G Q I may revisiting that subject in a second here.
9 Did you testify in any other proceedings, such as to that one you just mentioned?
11 A 1 don't believe so.
12 O l asked you this before. You represent Appleseed; 13 is that correct?
14 A Yes.
15 Q is that organi=ation still in existence and viable?
16 A Yes, yes. Inasmuch as most of the people still 17 consider themselves members of Appleseed have been from the 18 start largely inactive members.
19 Q When'was Appleseed formed?
20 A in February of 1979.
21 Q Was it formed particularly for the intervention in 22 the Braidwood proceeding?
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k 16 1 A No.
2 Q What purpose then?
3 A Because of the great number of nuclear facilities in 4 the area in which I live, and the concern of people who live 5 in various surrounding communities, that there was no focus, 6 no group that could answer questions or give information.
7 Q So the focus of the group is on nuclear power?
e A Yes.
9 Q Let me recount a little history here. Were you 10 associated with the Bailey Alliance? Is that the correct name 11 of that organization?
12 A Do I have to tell the truth? Yes.
18 Q And what was the nature of their involvement in 14 the Braidwood proceeding?
15 A Well, when I informed cer t a i n n, embers of the Bailey 16 Alliance in January -- December of 1973 or January of 1979 17 that I intended to intervene in the licensing of the Braidwood 18 plant, there was no group at that t i,me. Appleseed did not 19 exist. I was asked if they could sign on, or they said, 20 "Look, you're a member of our group. You know, you gave us 21 fifteen dollars. Would you do it in the name of Bailey 22 Alliance," and I said, "Sure," being naive.
I 17 1 Q And what was the relationship of the Bailey Allianco 2 with Appleseed?
3 A At the time, there was no relationship because 4 Appleseed did not exist.
5 Q But I take it later Appleseed was formed and --
6 A When Appleseed was formed, many of the people who 7 became Appleseed were members of Bailey Alliance, in fact, 3 they were the people upon whom we were basing, you know, this 9 inter -- the reason why members of the -- why Bailey Alliance 10 would be allowed to intervene. IJhen Appleseed was formed, it 11 was many of the same people who live in our area, and when 12 people in Chicago in Bailey Alliance said they did not have 18 the time to devote to an intervention, I requested at the 14 prehearing conference that summer that we be allowed to 15 substitute Appleseed for Bailey Alliance.
16 O Are you a member of any other organizations that 17 have taken up environmental.or public health causes?
13 A Yes.
19 Q Can you identify them, please?
20 A l'm a member of Friends of the Earth. I'm in i
( 21 current status in a number of things. Sierra Club.
22 Q Do you hold any positions in any of these l
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18 1 organizations?
2 A 1 am currently President of Illinois Friends of the S Earth.
4 Q That's an international organization, isn't it?
5 A Yes, it is. Well, Illinois Friends of the Earth is 6 part of Friends of the Earth, United States Friends of the 7 Earth.
3 Q l'm going to ask you a few questions to try to 9 determine generally what your views are towards nuclear power.
10 Do you believe that there are --
I take it you 11 believe that there are hazards associated with con.mer c i a l 12 nuclear power; is that correct?
13 A Yes.
14 Q And what do you believe those ha=ards to be?
i 15 A 1 believe there are hazards associated with 16 radioactive nuclear waste, with nuclear waste, with the 17 byproducts. I believe there are hazards associated with the 18 normal running of a nuclear plant where low-level radiation is 19 emitted. I believe there is potential for a catastrophic 20 accident. Those three things sort of, you know, sum it up, 1 21 would suppose.
22 Q Do you believe it is possible to design a nuclear l
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l 19 1 plant so that there would be no risk involved? This is not a 2 trick question.
3 A 1 don't know. I would probably have to say no. 1*m 4 not an engineer.
5 Q What I'm getting to is, do you believe there would 6 always be some risk, despite any safeguards that --
7 A Yes.
S Q -- that you could use?
9 A Yes, 10 Q And do you believe that these risks that are 11 associated with nuclear power are unacceptable, regardless of 12 ' hew many safeguards that could be used? Or the alternative 18 question is --
let me put it a different way -- is there a 14 level of risk that you would find acceptable, that you could 15 live with?
16 A That's --
can I speak with my attorney please?
17 [ Discussion off the record.]
18 THE WITNESS: It is less that I find levels of risk 19 unacceptable than that I find it unacceptable that people do 20 not have the ability to make decisions about the levels of 21 risk that a society takes.
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1 BY MR. COpELAND:
2 Q Moving now to your emergency planning contention, 8 currently this is the only contention that you have admitted, 4 and we notice that it's virtually identical to parts of the 5 Niener Farm emergency planning contention, which has now been 6 withdrawn.
7 Can you tell me how your contention came about 8 originally? For instance, was it pared down from what Niener 9 Farms had submitted, or did they expand on yours?
10 A No. No, because all the contentions that were 11 admitted by the Atomic Safety and Licensing Board at the 12 special -- or at the prehearing conference in August of 1979 13 were contentions that had been bandled about and agreed on 14 between the NRC Staff -- that was Myron Karman -- and --
1 15 can't remember his name. He used to work for Isham.
16 MR. GALLC: paul Murphy.
17 THE WITNESS: paul Murphy and me. There were only 18 two. I had two contentions. I have no idea --
I was not 19 present when he met.or they met with Niener Farms, so I don't 20 know quite how that happened. It may have happened at the --
21 it may have happened in agreement, it may have happened at the 22 prehearing conference. I don't recall But they were sort of f
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2 BY MR. ':OPELAND:
S Q The contention states that an adequate emergency 4 pian should include the three provisions which are specified, 5 the three areas that you cover.
6 What was the basis for stating that a plan should 7 include such provisions? Were you relying on a regulatory S guidance?
9 A No. Common sense.
10 Q All right. Are you familiar with the regulations 11 regarding emergency planning that's found in --
12 A Are you asking me a question for now at the present i
1D time, or are you asking a question for that time?
14 O Now, are you familiar with 10 CFR 50.47?
15 A I read it recently, but it's not at the tip of my 16 tongue.
17 Q And NUREG-0654, are you familiar with that document?
13 'A No.
19 Q Which expands on.10 CFR 50.47?
20 A No, 1*m not familiar with that i
r 21 Q So when you or ig ina l ly came up with the contentions, 22 though, you weren't relying on those documents?
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i 22 1 A No, no, because I'm not sure they had been written 2 at the time.
3 O Well, you're right on that point.
4 I want to turn to the answers you gave us in your 5 interrogatories.
6 Before I go to those, we submitted a second set of 7 interrogatories to you awhile back. Did you not receive 8 those?
9 A No. No, I have not received them.
10 MR. COPELAND: Let's go off the record a second.
11 CDiscussion off the record.3 12 BY MR. COPELAND:
13 Q In your answers to our interrogatories, the first 14 set, in response to interrogatory 3, you responded that the --
15 MR. WRIGHT: Just one second.
16 Epause.]
17 BY MR. COPELAND:
18 Q The question we had put to you in Interrogatory 3 19 was: Inasmuch as the emergency plans for the Braidwood 20 Station are not available, state the basis for intervenor's 21 inference that the three items specified in your Contention 1, 22 Subparagraphs (a) through (c), are not or will not be included i
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f 23 1 in the emergency plan for Braidwood Station?
2 And you had responded that, "Intervenor believes 3 that the emergency plans for other Commonwealth Edison nuclear 4 plants have relied too heavily upon" and you list four items 5 there.
6 I would like to take the four items one by one now.
7 The first statement is, you believe the emergency plans at 8 other Edison plants rely too heavily upon the unlikelihood of 9 any radiological emergency -- unlikelihood of any radiological 10 emergency requiring a large-scale evacuation.
11 Now is that in reference to the plan itself, or were 12 you referring to the emergency planning brochure that you had 13 seen?
14 A in part, the emergency planning brochure.
15 Additionally, the fact that many -- I am outside, for 16 instance, the emergency planning zone for Dresden and LaSalle, 17 only four miles outside Dresden's.
18 Quite a few people who are members of Appleseed are-19 in both and have expressed dismay that nobody has ever
-20 attempted with them, aside from the drills or what do you call i
21 them --
22 Q The emergency planning exercises?
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( 24 1 A Whatever those are. public instruction about 2 emergency preparedness.
S Q Had they received a pamphlet?
4 A Yes, they had.
5 Q And they did not find that to be adequate?
6 A No. I received the pamphlet, too. I must be in the 7 billing area that they sent those out to. And I don't feel 8 it's adequate.
9 Q But have you ever looked at the actual emergency 10 plans as found in the Illinois Plan for. Radiological 11 Accidents?
12 A No. But since I feel that any emergency plan should 18 take public instruction as one of its basic elements, the fact 14 that those plans do not have public education in any way that 15 has touched various people who do live in the emergency 16 planning zone is evidence that the emergency plans do not 17 include what I feel would be adequate in the way of public 18 instruction.
19 Q Have you ever looked at an Illinois Plan for 20 Radiological Accidents for any of the plants? Any of the 21 specific plans for any of the plants?
22 A I may have glanced at some document that I don't i
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e 25 1 remember.
2 Q Are you aware that that plan calls for the 8 distribution of brochures to fulfill the purpose that you are 4 talking about?
5 A Yes, yes.
6 Q Eut you don't believe that to be adequate?
7 A No.
G Q Is there a problem with the method, you believe, or 9 is it a problem with the content of the brochure?
10 A Both.
11 Q Let's focus on the method aspect at the moment.
12 (Jha t me t hod wou l d you believe to be adequate?
10 I noticed in your answers elsewhere in the 14 interrogatories, you did mention that there should be 15 comrnun i t y programs of some sort.
16 A Yes. Now what exactly is your question again?
17 Q You.have stated that you see a problem with both the 18 method of information through the --
19 A Are you aski'ng what do i find wrong with the method?
20 Q Yes.
21 A Number one, that it is not far-reaching enough, that 22 the brochures are distributed to ratepayers, that ratepayers I
k 26 1 are -- that's probably as inclusive as you're going to get, 2 however. Most people I know open their bills and throw S everything else away. I know quite a few people who received 4 them have never read them. Children below a certain age 5 cannot read. Elderly people sometimes cannot see to read.
6 Unless a parent n.a k e s it available for children to read, 7 there is a large segment of the population that is operating 8 unaware of the information contained in the brochures.
9 Q You mentioned several different classes of people 10 here.
11 A Yes.
12 O Let's take them one at a time. First, you mentioned 13 son.e peop l e received them, and they do not read them, although 14 they would be otherwise capable of doing so.
15 (Jh a t would you propose to cure that problem?
16 A 1 don't know if I really can -- have a proposal for 17 how to cure that problem. I'm simply pointing out that that 18 is a problem with the method.
19 Q And you also mentioned that some people are not 20 capable of reading it themselves, such as young people and 21 children.
22 Are you aware that the pamphlet, on its opening
27 1 page, requests that the head of- the household share the 2 information with the family?
3 A 1 don't remember that specifically, but I accept 4 that. But that does not necessarily mean that it is done, or 5 that, you know - you don't sit down and read a pamphlet to a 6 two year-old, not that pamphlet anyway.
7 O You mentioned community programs, possibly as an 8 alternative method to providing information to the public.
9 Do you believe that this would be any more effective 10 than a distribution of pamphlets?
11 A 1 believe it has the possibility for being more 12 effective, because it involves a certain amount of public 13 relations, and I don't mean public relations of the kind, "We 14 are good; we are benevolent; we are wonderful humans." I mean 15 public relations of a real community service nature, where 16 people know that this is a problem that they have to deal with 17 because they live in an emergency planning zone. And if they 18 are aware of the fact that a program is going on, they will be 19 talking about it, about the fact that it is happening. And i 20 think that that interchange of ideas real'ly leads to more j l
21 comprehension about what a good plan would involve and what 22 the public's response or responsibilities should be.
l l
i
f 28 i
1 Q Let's focus on the content of the pamphlet. You '
-2 have mentioned in your answers to your interrogatories two
'3 specific concerns --
I take that back it's more than two --
4 but two of the same kind here that inned i a t e l y draw my 5 attention.
6 First, you believe that the use of the words -- if I 7 may take a moment here first.
8 Now you've stated that you've seen the Dresden 9 emergency pamphlet and the Zion pamphlet, is that correct?
10 A Yes. I saw it three years ago or so, two, three 11 years ago. I don't know if it's been updated.
12 Q 12 this the Dresden pamphlet that you saw (handing 13 document to witness)?
14 A No No, it was much smaller 15 Q Was this the Dresden pamphlet?
16 A Yes. I have that one taped up next to my telephone.
17 Q And this is the same pamphlet, I take it? That's 18 virtually identical?
19 A Yes, right.
20 Q Now you have not seen this latest version of the 21 brochure for Zion and Dresden?
22 A No.
_ _ _ .-- . ._. - - - - . ~ . __
e I
29 1 Q l'd like you to take a look at the -- you're now 2 holding the current edition of the Dresden pamphlet. It's a S violet-colored cover, and it says, " Emergency Information, 4 1935," on the cover. And lock on the inside of the first 5 page. It's the introductory language.
G If you will look at the second paragraph in that 7 first sentence, the word "unlikely" is used there as well 8 We assumed, when we read your interrogatory answers, 9 that was what you were referring to.
10 A It wasn't.
11 Q But apparently you were referring to an older 12 version, i which also -- the old pamphlet stated, began, "
Dear 18 Resident:
In the unlikely event that a serious accident 14 cccurs at a nuclear generating station, we want you to know 15 about the emergency plans for your area."
16 And the current pamphlet, which is uniform for all 17 the plants begins, "
Dear Citizen:
," and there's a paragraph 18 explaining the purpose of the pamphlet, and then the second 19 paragraph begins, "We have never had a serious accident, and 20 it is unlikely that we ever will."
21 Do you still have the same comment there, now that 22 it is shifted into the second paragraph, expressing virtually
i 30 i 1 the same i dea?
l 2 MR. WRIGHT: Could you rephrase that question?
8 BY MR. COPELAND:
4 Q Well, what I'm getting at is, now you locked at an 5 old brochure. --
6 A Yes.
7 Q -- and you had a problem with the words "unlikely 8 event" being used.
9 A That wasn't the word. That was not what I said.
10 What I said was.that any such brochure developed by 11 Commonwealth Edison should not promote the idea that any. event 12 or emergency --
there's a glitch there -- which might require 13 evacuation is unlikely.
14 There's a difference between mentioning a word and 15 promoting an idea.
16 Q Okay. Do you see -- what I'm asking you is, is your 6
17 concern still the same with the new pamphlet? Do you :s t i l l 18 view that as promoting --
19 A Well, I would have --
I don't know. I would want to
. 20 see --
21 Q Assuming that there's no place else in the pamphlet 22 where they use that kind of language.
, , .r . .-r . - y - - _ m_ - - . . -. - - - - . . . , , - -
(
S1 1 A I think that that --
all right --
2 MM. WRIGHT: Counsel, if you can allow Ms. Rorem a
,1
- 8 moment 4 MR. COPELAND: Yes, I'm perfectly willing to do 5 that.
6 CThe witness reviews the document.]
7 BY MR. COPFLAND:
8 Q If you look at --
well, focusing on the same 9 subject, whether an event is likely or not, I believe Chapter 10 7 also would address that.
11 A '
saw that. I was going to get to that point.
12 EThe witness continues to review the document.]
13 MR. ' WRIGHT: perhaps if you'd like to hold your 14 question until after a break, and she can read through it at 15 the break in order to make that comparison. That might be 16 helpful.
17 MS. CHAN: Counsel, could we take a break now?
18 MR. CODELAND: Yes. Why don't we take five minutes?
19 CBrief recess.3 20 BY MR. COPELAND:
21 Q Ms. Rorem, have you had a chance to look at the new 22 and improved brochure?
- c --=w ari w g- -w? w-t++
e
( 32 1 A Yes, yes.
2 O Do you still have the same concerns regarding the a promotion --
4 A Yes.
5 Q --
of the unlikelihood of an event?
6 A Yes.
7 Q Where do you see that idea expressed? Tell me where 8 that is.
9 A It's not --
understand, let's make it clear, the 10 idea is expressed in Chapter 7.
11 Q Can you read Just exactly what language you're 12 talking about?
13 A No. It's not the language so much, as it's an 14 attitude. There's also some in 5. It's the way of describing 15 it, as though, well, you might get flooded out. You might get 16 hit with a tornado. You might get his with a nuclear 17 accident, it's the way it is expressed, so to make it sound 18 acceptable. It is the way it is expressed, so as to make it 1
.19 sound everyday or -- not everyday, but like an everyday risk, 20 fike it probably won't happen any more t h'a n , you know, than 21 anything else would.
22 It's not the specific language, and maybe there are
l
( SS 1 bits of specific language that do bother me.
2 The first paragraph in the seventh chapter promotes 3 -- it's not that it pr c.mo t e s nuclear power so much as it 4 describes it as an accepted fact, like it's here, we have to 5 have it, you know, et cetera.
6 That doesn't really have any place in this. If it 7 is here, then why bother saying all of this stuff? Do you 8 understand what I mean?
9 Q l'm asking the questions here.
10 A Yes, I'm sorry. I realized that as it came out of 11 my mouth. I guess I was asking whether or not I was 12 explaining well enough. I'm not comfortable with the 13 fanguage.
14 Q You would suggest an overall revamping of the entire 15 style of the pamphlet, it appears a is that correct?
16 A Some of the style is fine. It's the informational 17 pages.
18 Q (Jh a t do you mean by the " informational pages?"
.19 A pages or Chapters 1 through 6. I'm not sure they 20 involved everything I would desire to have in them. But they 21 don't -- they don't deal with the fact that one is accepting 22 the inevitability of having to take this, because one needs
I 34 1 these nuclear plants.
2 Q Okay. So primarily you object to Chapter 7 in its S entirety?
4 A Yes, primarily.
5 MR. GALLO: Counsel, can I interrupt a moment?
6 MR. COPELAND: Let me defer to my colleague.
7 MR. GALLO: The purpose of the interrogatories, Tim, G was to zero in -- the ones she didn't get -- was to =ero in on 9 or to ask Ms. Rorem to identify for us the sentence, the 10 offending sentences or passages, with the objective of us 11 being able to examine them ourselves to see, first of all, if 12 we agree that they were objectionable, and secondly, to look 13 at it from the standpoint of perhaps there is another way of 14 saying the same thing that would be less,of a problem from 15 your client's standpoint.
16 It doesn't appear that she's prepared to give us 17 that kind of analysis at this point. On the other hand, i 18 think it would be useful if we could get sometime soon your 19 assessment in that area.
20 MR. WRIGHT: If I may, I think there are a couple of 21 problems here. One is that they seem to be operating off of 22 different versions of the pamphlet. And the other problem is,
35 1 l'think, as Ms. Rorem has stated, she had not received the 2 second set of interrogatories.
S I don't know how we would wish to remedy this 4 problem right now.
5 THE WITNESS: Can I say this?
6 MR. WRIGHT: Sure.
7 THE WITNESS: If you ask me for specifics, even had 8 1 received the interrogatories, even had I see this, I 9 probably would have answered exactly the same way, and I would 10 feel the sarne way . It isn't necessarily the specifics.
11 Given that the plant is built: given that it is 12 almost assured to be granted an operating license, I feel 13 there is no room or need for any discussion of the need for 14 power, wh i .:h is tied in with the unlikely -- do you understand 15 what I mean?
16 There are two things I object to, and I --
17 MR. GALLO: I understand what you mean. But if i 18 were sitting in your chair, I would be able to say that 19 basically I object to Section 7, and basically I object to 20 either the first paragraph or all of Section 7.
21 THE WITNESS: All right. I object to the entire I
i 22 Section 7, okay?
l l
t l
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f 36 1 MR. GALLO: Those questions are calculated to elicit 2 those kinds of answers.
3 THE WITNESS: I object to Section 7. I objection to 4 the sentence -- I object to the sentence in the first -- on 5 the opening page where it says, "We have never had a serious 6 accident, and it is unlikely that we ever will "
7 That's fine, but you can't go on with, "But with any S potential emergency," et cetera, without putting a sentence 9 in, the fact that it is a possibility that it will happen.
10 There's a skew that happens to how it reads when that is not
, 11 mentioned. It just should be mentioned in the same way.
12 "It's unlike it ever will, but it could happen," you know, 18 "and you should be prepared." That's what I mean.
14 The other objection in -- I object to Section 6, 15 paragraph 6.
16 l'm sorry. I'm sort of jumping the gun. 1*m 17 getting into things that are beyond what you asked. You asked 10 the unlikely aspect, and I was getting into --
19 MR. WRIGHT: I would like to make one other point, 20 Counsel. I think if we can get the questions a bit clearer, i
21 perhaps we can get clearer answers. l 22 MR. GALLO: Well, we seem to have provoked her into
1 1
l 1
( )
37 1 giving us exactly what we were looking for. And I yield to 2 Counsel to --
S M9. W R I G H T.: Continue that provocation.
4 Claughter.3 5 THE WITNESS: I don't do enough of these things to 6 say.
1 7 MR. GALLO: You shouldn't feel reticent to tell us 8 what you think about that. I mean, that's the purpose. At 9 some point, you ought to tell us what your problems are with 10 Chapter 6.
11 THE WITNESS: Well, since I said that, do you want 12 me to tell you?
13 MR. COPELAND: Give me a second here.
14 THE WITNESS: So you can figure out the appropriate 15 question?
16 BY MR. COPELAND:
17 Q While you bring up the subject, does it relate to 18 one of your answers to your interrogatories, because I will be
.19 going over each one step-by-step.
20 As long as we're on Section 6, I'll move to that.
1 21 A 11 does indirectly, because it's one of the things i I 22 have checked, too, in the state programs and the things l
O
( SS 1 Commonwealth Edison does --
do in communities and so forth is, 2 it is not accurate, it leads to a different mind set.
3 I attended a meeting at the First Aid, Red Cross, 4 one of those type buildings in scoe obscure, remote place in 5 Kankakee, and Commonwealth Edison was showing slides of its 6 evacuation proceedings from four or five, maybe six months --
7 maybe a little longer than that --
at Zion in July or August 8 of 1931 and were --
the people from Commonwealth Edison --
9 there were two, I think --
were talking about, "See all 10 works see this emergency plan, see how we do this thing, 11 see how well it worked," and it happened that I had been up 12 there. It was just pure circumstance that I had been up at 13 the Zion plant during that drill 14 So I was really intrigued with the fact that they 15 were showing pictures of what they had done and how it went, 16 and we're talking about their work, you know, problems and so 17 forth. And the official from Commonwealth Edison said the 18 same thing.
19 Q You are referring to Chapter 6?
20 A Chapter 6, paragraph 5, that if a serious problem 21 occurred at Dresden Station, government officials would be 22 notified immediately over hot line telephones. This would
( 39 1 start the emergency plans rolling. That gets the public who 2 reads it or hears it the idea that the minute somebody pulls 3 the wrong switch, the minute the tornado hits the plant, the 4 minute whatever it is happens, they're going to get --
you 5 know, they'lI be packing their belongings and be out of there, 6 which gives them a feeling of safety of, "Oh, I can beat it."
7 We know that in actuality it would probably be six 0 to seven hours between the beginning of an accident scenario 9 which might require evacuation and the actual evacuation 10 procedures to even begin -- this is minimal, oka*'? -- but the 11 thing that is -- when you start --
this was just emergency 10 plans, and it makes pec;ple feel like, " Gee, everything is 10 fine They've got everything taken care of. I'll know tho 4
14 minute there's an accident," when, in actuality, they may have 15 been outside, walking around, having a few beers, doing 16 whatever they're doing, and completely unaware of the fact 17 that there has been an accident at the plant, and it is 18 time emitting radiation in excess of NRC's standards.
19 Q Do you believe that paragraph to be inaccurate, 20 then?
21 A '. 'e s , and misleading, both. That's no -- that's not 22 inaccurate s it is misleading, i
i
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( 40 1 Q Misleading in that it.gives a false sense of safety 4 2 is that your cpinion?
l 3 A Yes, yes. I believe that at this meeting I 4 attended, what he said was not as clear as this. The man said 5 the minute there is an accident, you know, everyone within ten 6 miles will know. And we got into a shouting match.
7 Q la that idea expressed here?
8 A Yes. It's the same kind of idea that the emergency 9 plans will be rolling.
10 Q But do the words state that in the pamphlet?
11 A No, but we start with the fact that there are 12 emergency plans for people within ten mile.s, and it 13 cross-references to give the same, exact impression, you know, 14 that --
15 Q Okay. Le t 's niowe on to another subject that you
! 16 raise in your interrogatories, in the answers to our 17 Interrogatories.
18 You also stated that a program for informing the 1D public of such pr ocedures should also described the 20 consequences of various types of accidents, including --
21 excuse me -- involving the release of radioactive materials 22 and should describe any and all protective measures which i
O I
41 1 might be taken before any accident or then to mitigate the 2 effects.
3 A Uh-huh.
4 Q For what purpose do you believe that the 5 consequences should be described in the pamphlet?
6 A Because I believe that people have a right to know 7 events which might befall them to the greatest extent l 8 possible, and that this is not an event upon which any action l 9 of theirs is likely to have any effect, unless they can 10 mitigate the effects. In other words, they can't stop 11 somebody from making a wrong decision about a gauge in a 12 nuclear plant, ckay? I mean, in other words, they cannot 3 affect an accident, but when something -- I think they have a 14 right to know what that might cause or what --
what events 15 might occur.
16 O Even an event that would not have any consequences 17 to the public?
13 A Well, that --
I think you pretty much did a good. job 19 of 'noak i ng peop l e feel that thern would be events that wouldn't 20 have any consequence to the public. It's the events that 21 would have consequence to the public that concern me.
22 Q You believe it's necessary that the different types
t~
42
~
-. 1 of accidents be described and what could happen?
. 2 A I think that a range of possibilities should be 8 described.
4 Q And you also mentioned that there should be a 5 description of the protective measures which might be taken 6 before any such accident?
7 A Yes.
8 Q Do you not believe that the --
9 A This does a c.ertain amount of that, although I think 10 it puts it in the wrong order. Well, it does --
if officials 11 say to evacuate and it gives a list of things to do, but it 12 isn't until back here that it says --
it talks about --
IS Q Where are you looking? Can you tell us the page 14 number?
15 A "Be prepared to check" -- in Section 5, it says 16 here, "Four Sensible Ways to Prepare for Any Emergenci," and 1
17 that's true, but I'm not ready at a moment's notice to pick up l l
18 and leave for two days, yotJ know.
l
^ ' -
.19 Q You believe the information is there s it's just not 20 ~ in the right order?
21 A partially, and I'm not sure all the information is 22 there. I'm very happy with what information is there, okay.
_e i
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+ - , -
43 1 l'm, you know --
2 Q I guess we're having a hard time determining what it S is you're upset with, what you object to here, then.
4 A You don't understand what I object to. Can you --
5 MR. WRIGHT: Could you ask specif6c quest,lons?
6 THE WITNESS: Yes, be specific, so I can look at 7 what my answer is that you don't understand.
8 BY MR. COPELAND:
9 Q Do you know of any protective measures that aren't 10 covered in the pamphlet that need to be covered?
11 A Okay. This gets into an order thing again. In 12 other words, by the time the sirens go off, some of those 13 protective --
for some of those protective measures, it may be 14 too late.
15 Q Which protective measures are you referring to?
16 A Getting inside, closing the doors and windows. You 17 know, it's a good idea maybe at that point, but it might have 18 been a much more excellent idea five hours earlier.
19 Q How is that a problem with the pamphlet?
20 A Well, did I say --
I'm looking at my page 4, 21 paragraph 2. Is that what you're referring to?
22 Q Yes.
44 1 A Okay. That wasn't necessarily talking about the 2 pamphlet. It's talking about a program for informing the 3 public.
4 Q Okay.
5 A I suppose I should have said that a program for 6 informing the public would also more adequately inform them 7 ahead of time about accidents starting to happen.
8 See, there's a middle ground here that's missing in 9 emergency planning where, because of the justifiable reason 10 that you don't want to panic the public .you don't want to 11 tell them each and every time, you know, you've done something 12 accidental, because it will just get people upset and start 13 hurrying out of town and all of that, or you'll probably have 14 worse accidents with traffic and so forth. I understand that.
15 At the same time, there's a whole amount of time 16 that happens after a potentially catastrophic action or even 17 minimally catastrophic accident where the public is unaware of 18 what is happening.
19 Perhaps the public needs to know how often 20 radioactive gases are emitted from the plant, how often 21 accidental releases have tended to occur at other plants.
22 Q So is your criticism, then, of the judgment of those
,~
j
)
l
(
45 1 people who would be in charge of the emergency at the time as 2 to whether they would release the information?
8 A No, because that is more structural than that it's 4 more --
it's more structural than that. It's not the judgment 5- of certain people. It's that it's not considered by various 6 companies, Com Ed being one of them, a good idea to upset the 7 public.
S How long was it between the time the accident 9 started at Three Mile Island or between the time --
let's put to it this way -- between the time that gases were emitted and 11 the public knew about it? That's the area of time that a lot 12 of education is needed on.
13 Q You are talking about education before an accident 14 ever occurs, though; is that correct?
15 A Absolutely.
16 Q in raising the public awareness of what happens in 17 an emergency and so on?
18 A Yes.
19 Q So you really are not concerned, then, about the 20 extent of their information regarding appropriate emergency 21 action to take?
22 A At the time, I guess I'm concerned about that, but I
_g __ _
3 46 1 feel'that it's much easier to respond in a very cool, calm, 2 and deliberative manner, if you've been educated beforehand.
S Q Okay I would like to move on to another aspect of 4 your answers.
5 Looking back to your answer to Interrogatory No. 3, 6 again, the second point you raised was that you believed that 7 the emergency plans relied too heavily on -- and then you have S B, the availability of appropriate transportation vehicles.
9 Can you tell us what population you are talking 10 about that would need transportation vehicles you specify, 11 appropriate transportation vehicles? Are you talking about a 12 particular population?
18 A We are talking about the population in the ten-mile 14 zone.
15 Q The entire population?
16 A The entire population.
l 17 Q Would you consider it necessary that there be enough 1
l 18 vehicles to evacuate them all at one time?
l j 19 A lt depends on the accident. There are accidents 1
20 where, yes, it would be important to evacuate them all at the 21 same time. There are probably ones where it wouldn't matter.
l l 22 Q Was your concern at this point related particularly
I 47 1 to appropriate vehicles for nursing homes and so on?
2 A Nursing homes are one of the things with which I was 3 concerned. Schools were another, campers, children left at 4 home.
5 MR. COPELAND: Excuse me a minute.
6 (Pause) 7 BY MR. COPELAND:
S Q Have you looked at any - you stated earlier that 9 you have not looked at any of the Illinois Plan for 10 Radiological Accidents.
11 is that correct?
12 A I have only glanced at it. I mean, I don't recall 13 anything of it.
14 Q So there is nothing in there that led you to 15 believe that the plan relies too heavily on the availability >
16 of vehicles?
17 A There is nothing in there that leads me to believe 18 that your plan --
19 Q That the Emergency Plan for the Braidwood Station 20 re l l e.s too heavily on availability of appropriate 21 transportation vehicles?
22 A Well, if I haven't -- that is a pretty convoluted I
~
_ _ -,- -w &- ~ ~~
7
48 1 question.
2 C l'm sorry, I will take that question back.
3 Let's move on to the next aspect of your answer to 4 Interrogatory No. 3.
5 You state that you believe the plans relied to 6 heavily on optimum weather conditions.
7 A Yes.
8 Q During any emergency evacuation. What leads you to 9 say that the plans relied too heavily on optimum weather 10 conditions? .
11 A I know how often you can't get around out there 12 unless you have a Snowmobile. And I know that there are 13 nuclear plants operating out there during this weathe . And 14 if they are operating, then obviously the emergency plans take 15 .such a thing into account, and they are assuming that there 16 will not be a need to evacuate.
17 Q Are you aware that for all the other plants and for 18 Braidwood, one is being prepared also, but an evacuation time 19 study has been prepared which considers adverse weather 20 conditions?
21 A It considers the percentage of time that there is 22 adverse weather conditions. I mean how much of the time is
( 49 1 there adverse weather.
2 Q lt considers the effect of adverse weather on the 3 ability to evacuate and the time it would take to evacuate, 4 are you aware of -- familiar with those studies at all?
5 A No, I am not.
6 Q Does that allay your concern at all?
7 A No. No.
8 Q And why not?
9 A Because I live out there, because I know how to difficult it is to move human bodies when there is four feet 11 of snow. And we live in an area where the winds blow a lot of 12 the snow a lot of places because there are not buildings to 13 stop it, and you can close a road in a matter of a minute or 14 two. I know, I have driven up a mile and driven back and 15 couldn't get through.
16 Q Do you have reason to believe that the emergency 17 plans do not adequately account for the weather conditions at 18 the time of the emergency?
19 A Yes.
20 Q What reason is that?
21 A What reason is that? Common sense tells me, it is l
22 absolutely not possible to come up with the vehicles to '
t
e 50 1 transport people safely in certain weather conditions. It is 2 just not possible.
3 Q Let me restate the question.
4 Do you have reason to believe that officials who are 5 in charge of determining what protective action to take, would 6 not be aware of the weather conditions and make a 7 determination on that basis?
8 A That doesn't mean --
they can make all the 9 determinations they want. It doesn't mean that they are 10 adequate determinations.
11 Q They are not adequate in that they would not --
12 A They wouldn't work. If you need to evacuate people 13 in certain weather, you just simply could not do it. You 14 would have to wait for the weather to clear.
15 Q All right. Let's move on to another subject.
16 Ms. Rorem, I would like to focus on the third part 17 of your contention, which states that an adequate emergency 18 plan should include a suitable plan for providing medical 19 treatment to operating personnel who might be exposed to 20 radiation in the event of an accident requiring transportation 21 to medical facilities that treat radiation casualties.
22 In response to Interrogatory 17, you indicated that
(
, 51 1
you were familiar with Commonwealth Edison's generating 2 station's emergency plan.
3 A I have read it, yes.
4 Q For handling affected on-site personnel, and that 2isple.ssed W 5 you were not isplaced with that plan.
6 is that correct?
7 A ,No, I'm not -- let me see my answer so I can 8 specifically know what I am saying. I am using my page 10.
, 9 Q You were not displeased except for two reservations 10 that you then stated. One, that there would need to be 11 assurance that the plan could handle large numbers of 12 personnel cn a serious emergency, and that there needed to be 13 a specific identification of transportation vehicles.
14 is that correct?
15 A Uh, huh. Especially when weather may be a 16 determining factor.
17 Q Other than those two exceptions, are you satisfied 18 with the plan for medical treatment of on-site personnel that 19 may be exposed to radiation injuries?
20 A I believe so.
21 Q Can you explain what you mean by large numbers of 22 people in a serious emergency?
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52 1 A That number would depend upon whatever facilities 2 were available. A large number of burn victims is ten, okay, 3 because it takes certain kinds of facilities to deal with burn 4 victims.
5 I am not saying there would be burn victims, but i 6 am saying that I know that for instance the hospitals in 7 Chicago could only handle a total of so many burn victims at 8 one time.
9 Q Are you talking about radiation burns?
10 A No, I'm just giving you -- okay, so ten is a large 11 number of burn victims, okay. I don't know, because it has 12 not been adequately described, or because it is not --
I'm not 18 pretending to know what the nature or extent of radiological 14 casualties could be. I mean I don't know. I just want to --
15 because of the fact that there are a large number of people 16 employed at a plant, and -- it could be two. I don't know 17 that. I mean, how many people can they care for if they are 18 injured in this way, or in this way, or in this way. That, i 19 think needs to be more adequately defined, that they -- there 20 need to be more assurances that they can deal with a large 21 number of people. I can't define a number for you. That is 22 why I gave the example of burn victims. You know, I am not
1 i
53 1 saying that burns have anything-to do with it. It has to do 1
2 !
with facilities adequate t o -- there need to be facilities S adequate to deal with as many casualties as might happen, and 4 1 don't know what that number is.
5 Q You are not aware then of what the degree of 6 severity of injury would have to be before medical treatment 7 would be required?
8 A i remember reading that stuff, vaguely, but it is 9 not the degree of severity, it is, like, how many people do 10 you have at that bottom -- in the bot tc w on the left, you 11 know the ones who don't need first aid, and what are the 12 different extents of their injuries, and can this facility 13 deal with all of them at the same time?
14 If you have five of them, can it deal with them? If 15 you have ten, can it deal with them?
16 How many are you likely to have in certain? I mean, 17 what is the largest numbers you are likely to come up with in 18 an accident?
19 1 don't know those things.
20 Q Are you aware that the planning basis for these 21 medical facilities assumes that no more than a few personnel 22 would ever suffer radiation injuries severe enough to require i
l _
, _ __-_ ~ -
~ ~ - ' - '
9 0
54 1 more medical treatment?
2 A 1 believe that is stated scoeplace in the --
in the 3 __
4 Q Are you also aware that this planning basis has been 5 found acceptable by the NRC at Edison's other plants?
6 A Okay. All right, I am aware of it now.
7 Q You don't have any information to refute that, do O you?
9 You just said that you don't know how many people 10 would need medical treatment.
i 11 A No.
12 Q Can you describe any scenario in which large numbers 13 of people would be exposed to radiation?
14 A Ch, ! could desce.be and list numbers, but how 15 likely --
4 16 Q Radiation so severe that they would require medical 17 treatment?
18 A No, I could not describe such a scenario right now.
19 Q By a' serious emergency, or as you state in your 20 answer to the interrogatory, are you contemplating a l I
21 coincidence of a general public emergency with an incident on 22 the site itself?
t a
' 55 t
1 A That's a possibility. Yes, that is one of the 2 things I was considering.
3 Q And were you contemplating that members of the 4 public would be suffering injuries that would also require 5 medical treatment?
6 A possibly. I wasn't -- yes, I was contemplating that 7 that was a possibility that I was possibly contemplating.
8 Q You stated you are familiar with the GSEp for 9 Commonwealth Edison's plants. Are you familiar with the 4
10 arrangements that are made with the local hospital for 11 treatment of persons who have injuries and also have 12 contamination?
13 You are aware of that, I guess?
14 A Yes.
15 Q And you are aware of the arrangement that has been 16 made with the Northwestern Memorial Hospital to treat victims 17 of severe radiation?
18 A Yes.
19 Q The second objection you had to the on-site 20 emergency planning for medical treatment for persons suffering 21 radiation injuries, was that transportation vehicles need to 22 be specifically identified, and transportation routes need to I
1
i 56 1 be identified.
2 Are you aware of the arrangements that are made at 3 all of Commonwealth Edison's other plants and which are being 4 made at Braidwood to provide ambulance service from a local 5 ambulance service?
6 A I am f ami l i ar- to the extent that someone who lives 7 near another plant had told me about that, someone -- yes, but 8 -- yes. Okay.
9 Q Co you consider that to be specific enough?
10 A No, no.
11 Q Why is that not?
12 A 1 don't consider it specific enough, because it does 13 not take into account weather conditions, for instance.
14 Q l'm talking about just the identification of the 15 vehicles now.
16 A Yes.
17 Q You raised two points: The vehicles need to be 18 identified and their routes must be identified.
19 A But especially when weather may be a determining i
20 factor the routes are not identified, okay? I'm not sure of 21 the time element. I'm not sure what an ambulance might be 22 doing other than that.
57 1 in other words, when you are talking about the 2 Braidwood area, for instance, you are talking about a smalt 3 area with, I think only one or two -- one private ambulance 4 service, and the emergency -- volunteer emergency groups in 5 towns like mine. I'm not sure that that adequately describes 6 the vehicles, if they are elsewhere at the time they are 7 needed, or if their persor..I for their volunteer 3 organizations cannot come quickly enough.
9 Q Why do you believe it is necessary that'the 10 transportation routes be identified?
11 A Because it is sometimes difficult to get from one 12 place to another because of heavy traffic, because of weather
- 13 problems. There need to be -- I don't mean for the general l
14 public there needs to be this knowledge.
15 Q (Jouldn't it be reasonable to expect that an 16 ambulance delver would know how to find his way from one point 17 to another in the quickest manner, especially if he is 1
18 familiar with the local area?
19 A Yes. That's generally true. But it does not 20 describe what ~ happens when the weather is so poor that the 1 21 usual transportation routes cannot be followed or, if there is 22 a tornado, you know, whatever the weather might be. Or, l
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53 )
l 1 roads are being torn up or whatever.
2 If you are dealing with local people, fine. What if 3 those people can't get there fast enough? I mean 1 --
4 MR. WRIGHT: Excuse me. Can we go off the record 5 for a moment?
6 (Discussion off the record.)
7 (Recess.)
8 BY MR. COPELAND:
9 Q Ms. Rorem, in answer to your interrogatory No. 10, 10 you had listed a nursing home; however, you did not list any i
11 hospitals which were raised in your original contention.
12 Do you know of any hospitals in the area?
IS A No. I probably should have eliminated that one. We 14 changed --
the original contention said 25 miles, and when it 15 was changed to 10, we eliminated the prison, but I wasn't 16 thinking to eliminate the hospital 17 Q Okay. So as far as you know, there are no hospitals 18 within ten miles of the Braidwood Station?
19 A So far as I know there are no hospitals within ten 20 miles of the Braidwood Station.
( 21 Q And you are aware of the Royal Willow Nursing Home 22 in Wilmington. Are you aware of any others?
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f 59 1 A No. That's what I answered.
2 Q Your contention states that plans should include 3 assurance that institutions within ten miles should have the 4 assurance that they can be evacuated or adequately protected, 5 and you stated "such as hospitals or nursing homes."
6 I would take it, your contention is not limited to 7 those two items, hospitals or nursing homes?
8 A No.
9 Q But it could involve any other types of facilities?
10 A No. It's not limited.
11 O in your response to interrogatory 11, you were asked 12 to identify all other institutions that you contemplated, and 19 you answered that you contemplated that all schools, 14 kindergartens, nursery schools, licensed and unlicensed 15 day-care facilities, and classes or field trips being held 16 within a ten-mile area of the Braidwood plant should also be 17 given assurance that they could be evacuated and protected 18 against a radiological emergency.
19 Can you identify those facilities that you were 20 talking about? Is it possible for you to name the schools and ;
21 kindergartens?
22 A All of them? No, it's not possible for me to do f
1 l
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60 1 that.
2 Q Would it be possible for you to come up with a list 3 which you cculd submit to us later? We ar e going to be asking 4 you to answer these interrogatories anyway, but --
5 A It would be possible to come up with some of them, 6 most of them perhaps. Some of them, because of the nature of 7 what they are, are not identifiable.
S Q Such as?
9 A Unlicensed day-care facilities.
10 Q If they are not identifiable, how can the people who g 11 are responsible for developing emergency plans be expected to 12 identify them?
13 A That's what I want to know.
14 Q Could you name some of them? Or would you be 15 willing to give that information to the people who are 16 preparing the emergency plans?
17 A lt's a thing that changes. I live in a ccwmunity 18 where people work different hours. Sometimes there will be 19 four or five children being cared for in this home or that 20 home. I don't know all of those times and places. For one 21 thing, I only have one child who is of such an age that i 22 would be constantly aware of what people were being caretakers i
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61 1 within the community. I don't know what people would be 2 caretakers in South Wilmington or Gardner or Braidwood or 3 Wilmington.
4 Q So you would only be famillar with those in your 5 immediate area, is that correct?
6 A To the extent that --
if I am familiar with them, 7 even.
S Q Can you identify these classes and field trips that 9 you refer to in your response to Interrogatory 11?
10 A Sometimes field trips are taken by schools to state 11 parks or recreational facilities within the area. Brownie 12 troops go camping. Most of these would be to the state parks 15 or some of the recreational areas. I don't know what other 14 field trips might be taken to some factories or so forth.
15 Q So when you drafted this answer, it was out of the 16 general knowledge that there were groups moving in and out, 17 but you didn't have any particular groups in mind; is that 18 correct?
19 A No, I don't keep a log of who moves in and out 20 MR. WRIGHT: Excuse me. Is that corrected to that 21 full question that he asked, or just as to the groups that 22 would be moving in and out of the area?
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62 1 I think there was more to the question that you 2 asked.
3 THE WITNESS: Say that again.
4 BY MR. COPELAND:
5 Q l was referring to groups that would be identified 6 as being on field trips in the area, or as you stated, classes 7 being held within the area.
8 MR. WRIGHT: I was kind of confused by the 9 question. I think your question was "at the time that you 10 drafted this contention."
11 MR. COPELAND: No. At the time she drafted her 12 answer to the interrogatory. That's what I was referring to.
13 not the contention. I was not attempting to raise that.
14 BY MR. COPELAND:
15 Q All right. Locking at your response to 16 Interrogatory 9, still concerning the institutions within ten 17 miles, you stated that the number, type, and special 18 requirements of all patients must be completely recorded and 19 updated.
20 Can you tell us who would --
who do you contemplate 21 would be doing this recording? Who would keep these lists?
22 A I would contemplate that whatever people were i
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i 63 1 responsible for emergency planning, who were identified within 2 any nursing home or hospital 3 Q For instance, if it was the Sheriff of the county 4 who is responsible for evacuation or protection of people in 5 the nursing home, that he should have that list?
6 A He might be one of the people who would have that 7 list.
O Q Would you believe it was reasonable for the 9 emergency planner to rely upon the information provided by the 10 proprietor or the manager of a nursing home or institution to 11 get that information?
12 MR. WRIGHT: I would object, in that that question 13 tends to call for speculation on the part of Ms. Rorem.
14 MR. COPELAND: Well, we've been trying to determine 1
15 what she would consider acceptable and what she would not 16 consider to be acceptable. She has raised this contention as l
17 to what she thinks is adequate, and I believe it is perfectly l
l l 18 reasonable to ask her that i
19 MR, WRIGHT: Then I think you should ask a specific 20 question toward that, and not one asking her, would she think 21 it was reasonable.
22 BY MR, COPELAND:
I
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64 1 Q Would you find it acceptable for an emergency 2 planner to rely on the information provided to him or her by 3 the manager or proprietor of an institution as to the number 4 of people in the institution and their special needs, or do 5 you believe it's necessary that the emergency planners 6 themselves go in there themselves and get that information?
7 MR. WRIGHT: Again, I would object. I think that's
- 8 becoming a bit confusing. You stick with one question at a 9 time. If she doesn't know the answer, she can tell you so.
10 BY MR. COPELAND:
11 O Do you understand the question?
12 A Yes, I understand the question. I -- yeah, i 1S understand the question.
14 Should I answer it (addressing Counsel Wright)?
15 MR. WRIGHT: Yes, you should answer.
16 THE WITNESS: Understanding that it is opinion, 17 okay? I think that I would find it acceptable if I --
or if 18 it were clearly understood by whomever the health care
~19 personnel are that such information needs to take into account 20 the possibility that, however unlikely, that such people might 21 need to be evacuated.
- 22 BY MR. COPELAND
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, _ _ , _ ,__ _ . . . _ _ ~ . . ._ .- .__ e - _...
O l
l 65 1 Q So you would see it mainly as an issue of whether 2 the manager or proprietor understands the impact of what the 3 information he'd be giving is, is that a fair statement?
4 A Yes.
5 Q Or the significance of the information that he is 6 relaying to the public official 7 A Yes.
O Q Ms. Rorem, do you plan to testify as a witness on 9 this issue, on this contention?
10 A 1 do not know.
11 Q Do you have any witnesses that you intend to call on 12 this issue?
13 A I intend to call witnesses. I do not have any 14 specifically designated at this time.
15 Q The only position of the witnesses you intend to 16 call --
by that, I mean, would you be calling experts, 17 consultant experts, or would you be calling on public 18 officials; do you know offhand?
19 A 1 don't know specifically because of budget and 20 availability of people i might call. They would probably fall 21 into one of those two categories, however, 22 Q You do have some people in mind, then s is that t
O i
. 66 1 correct?
2 A Yes, I do.
3 MR. GALLO: Ask her who they are.
4 BY MR. COPELAND:
5 Q (Jho are these people?
6 A 1 don't wish to tell you that.
7 MR. COPELAND: Can we go off the record for a 8 second?
9 [ Discussion off the record.3 10 MR. WRIGHT: I have just had a discussion with l 11 Mrs. Rorem and asked her the identification of those people 12 she was thinking about as witnesses.
13 The reason she will not disclose those names is 14 because she has not entered into an agreement with anyone 15 regarding that, and she has a confidential, if you will, 16 relationship with those persons, and said she would not 17 disclose their names until they had actually agreed to 18 testify.
19 So that is the basis on which she is withholding the 20 names of people that she has been discussing the option of 21 testifying with.
22 BY MR. COPELAND:
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i 67 1 Q Have you consulted with these people regarding this d
2 contention, regarding the merits?
3 A Some of them.
4 Q And these people have provided you with some 5 information regarding the contention, have given you some 6 advice?
7 MR. WRIGHT: Regarding the specific contention in 8 the Braidwood case?
9 MR. COPELAND: Yes. Or emergency planning matters 10 in general 11 BY MR. COPELAND:
12 Q Have you consulted any potential witnesses who have 13 given you advice or information regarding emergency planning?
14 A Yes.
15 Q Well, I don't see how you can object to us knowing 16 who these people are. it is a discoverable matter for us to 17 -- we could depose these people and find out their views as 18 well.
19 MR. WRIGHT: They are not going to be witnesses in 20 any hearing.
21 MR. COPELAND: Well, regardless of whether they're 22 witnesses or not, they have been a source of information for
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I se 1 Ms. Rorem in this proceeding.
2 MR. WRIGHT: Did you ask her that question?
3 MR. CopELAND: l*m asking her to identify these 4 people.
5 THE WITNESS: I have agreed with several of them not 6 to identify them until they decide whether or not they will 7 agree to be witnesses, l i
O MR. COPELAND: All right. Well, we will object to 9 your non-disclosure.
10 MR, GALLO: Well, we have got,.I guess -- are you 11 just refusing to answer the question s is that what it boils 12 down to?
13 THE WITNESSt Yeah, Yes.
14 MR. GALLb: We will have to consider whether we want 15 to ask the Board for an order to require her to answer that 10 questlon, 17 Let me ask one last question on that subject. Are 18 these people that you are considering the ones that you refuse 19 to identify? Are they state and local officials in and around 20 the Braldwood site?
21 THE WITNESS: Some of them are, yes.
22 MR. GALLO: And if I ask you, you will decline to l
I L 69 l
! 1 answer that, right?
l 0 THE WITNESS: ENo response.1 3 MR. GALLO: Go ahead. Victor.
l l 4 BY MR. COPELANOr 5 Q Ms. Morem, are you familiar at all with the progress 6 of the development of the plans for the Braidwood area, the 7 tilincola Emergency plans?
8 A No.
9 Q Are you aware that that process is going on at this 10 time, and that local officials are being consulted by 11 representatives from the Illinois Emergency Services and t
12 Disaster Agency in the development of plans?
IS A Yes, I am.
14 Q And you understand that those plans are not c omp l e t e 15 at this time?
16 A Yes, if those answers sound contradictory, it is 17 that I thought you meant in your first question, was I aware 18 of at what stage of development those plans were.
19 O And what do you understand that state of development 20 to be?
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21 A 1 don't. I don't understand. I do not know.
22 Q Have you been talking to any local officials about o
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70
- 1 the development of the emergency plans f ot* the Braidwood 2 Station?
3 A I have, yes.
4 Q And you are aware that they are involved in the 5 planning at this time, that the local officials are being 6 called upon by the Illinois Emergency Services and Disaster 7 Agency to participate in the preparation of plans for the 2" -
8 Braidwood station' Are you aware of that?
9 A ! was aware of it in the past. I'm not aware that 10 it is happening right now at this time.
11 Q Aware of it in the past for the Braidwood area?
12 A Yes, meaning -- we're talking months here. You 13 know, I did not know it was an ongoing process.
14 Q So you knew there was some activity going on months 15 ago?
16 A Yes.
17 Q And lately you haven't heard of anything going on?
18 A N o ". that's not necessarily true. I just --
' ' 19 Q You just having paying attention?
20 ELaughter'.3 21 A 1 was not specifically aware of any specific 22 activity.
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i 71 1 MR. COPELAND: All right. I don't have any further 2 questions.
3 EXAMINATION 1
4 BY MS. CHAN:
5 O Ms. Rorem, earlier in response to Mr. Copeland's 6 questions, you mentioned that you were aware of plans or 7 arrangements for the medical treatment of operating personnel 8 at Northwestern and some other medical facilities; is that 9 correct?
10 A I was aware that there exist plans.
11 Q That there were some arrangements?
12 A Yes.
18 Q In your opinion, are these arrangements 14 satisfactory, this prearrangement for medical treatment with 15 the leading institution?
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16 A Yes, yes, if those facilities can deal with whatever l
l 17 number of people might be injured in an accident. ;
l 18 Q So these facilities have the capacity to deal with !
)
19 that problem, that portlon of your concern in 1(c), is 20 satisfied; is that my understanding?
21 MR. WRIGHT: I would object. I think she said --
22 she mentioned "whatever number of", and I didn't hear that in l
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72 1 your question.
2 BY MS. CHAN:
8 Q If the facilities have the capability to handle the 4 nun.b er s that are anticipated, is this portion of Contention 5 1(c) satisfied? And then would your concern in that part of 6 the contention be limited to transportation of these 7 individuals in inclement weather?
O MR. WAIGHT: I would object to that question.
9 That's a ccepound question. I think you can break it down and 10 make it simpler.
, 11 MS. CHAN: Okay. I'd be happy to oblige.
12 BY MS. CHAN:
IS Q is your concern in 1(c) now whether or not these 14 potentially injured operating personnel can be transported in 15 inclement weather?
16 A Yes. Yes, and precluding any particularly strange 17 accidents which make transportation, you know -- yeah, okay, 18 they have to do with transportation, yeah.
s 19 Q And on part (b) of your contention, would you 20 anticipate or'do you anticipate that when the plan is provided 21 and more specific evacuation plans are set forth, would that 22 be adequate assurance to you that such plans were in i
(
73 1
l 1 existence, that is not yet issued?
2 A lt would be adequate. When the plans are -- come 3 forth, it will be adequate proof that they have come forth, l 4 yes. That was what you asked?
5 Q l wanted to know if this would be adequate 6 assurance. You are looking for assurance.
7 A Adequate assurance of that?
8 Q May I restate the question?
9 MR. WRIGHT: please.
10 THE WITNESS: please. .
, 11 BY MS. CHAN:
12 O Your contention states that you want assurance that 13 institutions within so many miles can be evacuated or 14 adequately protected in the event of a radiological 15 emergency.
16 . Would the issuance of an emergency plan provide the 17 necessary assurance?
18 A Not necessarily.
19 Q is your concern in this instance primarily the 20 implementation of an evacuation in the event of inclement 21 weather?
22 A No.
i 74 1 Q Can you please elucidate for us what assurance, in 2 addition to the list, you would like supplied, assurance in 3 the way of vehicular provisions? I believe you discussed the 4 availability of vehicles.
5 A I discussed that and referred to part -- or to 6 subparagraph (c).
7 Are you now talking about subparagraph (b)?
8 Q l'm talking about (b) now. part of (b) says, 9 " Assurance that institutions within ten miles of the station, 10 such as hospitals and nursing homes, can be evacuated or 11 adequately protected," and I'm asking whether -- what 12 suggestiens you would make as to the vehicles to be provided 18 for evacuation?
14 You mentioned earlier that there is one ambulance in 15 the area.
16 A Yes.
17 Q What solution would you pose in that instance?
18 Would you want more public vehicles available on call? What
'19 solution are you proposing?
20 A Well, you're talking about nursing homes. There are 21 no hospitals now, but there might be. We're talking about 22 ambulances, or we're talking about schools. We're talking i
i 75 1 about where the school buses are and how many people that can 2 handle -- or your talking about Girl Scouts on a camping 3 trip. Yona're talking about the ability to get vehicles to 4 them, or you're t a lk ing about --
do you understand what 1 5 mean?
6 in other words, it's difficult to make such a list-7 Q perhaps I can clarify my question. The assurance C that you are looking for, are you looking for a standby 9 vehicle for each of these situations? For example, for a 10 school, are you looking for school buses to stand by and be 11 available for a camping trip, or are you looking for 12 transportation to be there all the time?
13 in other words, you can't take children to a camping 14 spot and leave them. You have to have a vehicle there just in 15 case there's a radiological energency and they have to be 16 transpcrted out.
17 What would satisfy this assurance that you're 18 looking for?
19 A I don't want to be completely pinned down, you know, 20 because I'm not sure. School buses standing by to evacuate 21 children _is an ideal circumstance. Vehicles to take away Girl 22 Scouts and Brownies is an ideal circumstance. There needs to 5
r-(
76 1 be awareness on the part of institutions, groups, and so forth 2 that they are living in or entering an emergency preparednesa 8 =one, and that, therefore, special precautions need to be 4 taken.
5 Q Would it be safe to say that your concerns in (b) 6 concerning the education and awareness of the public that 7 special precautions need to be taken be covered by the S educational program that you discussed in (a) about educating 9 the public, informing the public?
10 A in large part.
11 Q So that that assurance would be provided if some 12 sort of community informational program were provided? That 13 would be adequate assurance?
14 A That'would be part of adequate assurance, but not 15 necessarily all 1G Q Can you suggest another part?
17 A My mind is blank. No, I can't right now. Education 18 does not guarantee results. It's part of a package. You 19 still need to know the vehicles. The responsibility has to 20 lie on someone's shoulders to make sure that all of these 21 things happen.
22 Q Numerous times in your testimony today, you have i
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77 l
1 mentioned the problem of road blockage due to weather l
1 2 conditions and the fact that some of the roads indicated on l l
3 the maps might not be passable.
4 And I would like, if you would, to turn to page 4 5 where it talks about after you receive emergency information 6 on the bottom of the page, it says, "In an emergency, stay 7 tuned to one of these radio stations," and then it lists 8 stations for Illinois and Wisconsin.
9 in this particular brochure --
this is for Zion, but 10 I assume it would be for lilinois -- and then it says, quote:
11 "This is your best source of information and instructions.
12 Other routes than those above may be given on the radio, 13 depending on road and environmental conditions," end quote.
14 Do you think this is a reasonable solution to the 15 problem of identifying alternate evacuation r ou t e.s in the case 16 of inclement weather at the particular time an accident 17 -occurs?
18 A Not necessarily.
19 Q Can you suggest a better method for informing people 20 at the time of an accident on alternative routes?
21 A 1 don't think it is possible to give alternative 22 routes. The radio stations -- well, for instance, for this t
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one in Dresden or in Joliet -- I don't know where W LL i 2 (indicating radio call letters) is -- I think maybe that's S Wilmington; I'm not sure --
I don't listen to any of those 4 radio stations.
5 The radio stations are not located necessarily where 6 people need to evacuate. The radio will not tell me that 7 Essex Road is closed, because it's difficult for them to 8 necessarily get that information. They won't know that the 9 road between Essex and South Wilmington is clcsed"whien it is 10 snow we're talking about. We're talking.about changing
, 11 conditions very quickly.
12 O We realize -- I think both of us realize that radio 13 stations are not omniscient, and they can't know everything, 14 but can you suggest a better method for letting people know in 15 case of emergency?
16 A No. No, I can't.
17 Q So if the plan suggests that people tune to their 18 radio stations for the best information whether to evacuate or 19 to seek protection, do you agree that that is probably the 20 best alternative available?
21 A It may be the best alternative. That does not make 22 it acceptable.
1 I
79 1 Q in the course of our discussion, I believe we 2 determined that there were no hospitals within the ten-mile 3 range.
4 A Not of Braidwood. There are things just outside of 5 it.
G Q Would you like to eliminate the hospitals from that 7 contention in lib)? I mean, if there aren't --
8 A Someone might build one. I don't know.
9 Q If there aren't any, then i doubt if there will be 10 any constructed and October 1st when we have the hearing.
11 A Let's leave it in for the moment, all right? I'd 12 rather leave it in right now, okay?
13 Q Okay. Ms. Rorem, it is my understanding .that you '
14 are not planning to appear as a witness in this case.
15 MR. WRIGHT: I would object, in that that was not 16 the testimony she gave. She said that she didn't think that 17 she would appear as a witness.
18 BY MS. CHAN:
'19 Q If you did appear, would you be appearing as a fact 20 witness or as an expert?
21 MR. COPELAND: I'm not sure she understands the 22 question.
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t' 80 1 1 BY MS. CHAN:
2 Q If you were appearing as an expert witness, I would 3 ask you your qualifications as an expert in emergency 4 planning.
5 A Ch, I see. No, I would not be appearing as an 6 expert witness.
7 Q So you would be appearing as a fact witness?
8 A Yes, I suppose.
9 Q But as of yet, you have not formulated your plans to 10 appear?
11 A No.
12 Q Nor formulated your plans for an expert to appear on 18 your behalf?
14 A Correct.
15 MS. CHAN: I have no further questions.
16 MR. GALLO: It's Mr. Tim's turn.
17 MR. WRIGHT: I have just a couple of questions on 18 redirect, if I may. That's what they call it in these
.19 settings.
20 EXAMINATION 21 BY MR. tJR I GHT :
22 Q Mrs. Rorem, I am holding the booklet given to you by
e i
81 1 Mr. Copeland, the Emergency Evacuation, 1995. Is this the 2 first time you have ever seen this booklet?
3 A Yes, it is.
4 Q in your responses to the first set of 5 interrogatories by Crmmonwealth Edison, did you rely on any 6 particular booklet regarding emergency planning when 7 formulating those responses?
8 A When I referred to brochures, I was referring to --
9 1 was relying upon the booklet that was sent out to ratepayers 10 within a certain distance of the Dresden Station and similarly 11 ratepayers within a certain distance of the Zion Station. But 12 this was -- these were sent out three years ago or so.
18 MR. COpELAND: For the record, you previously 14 identified those as the smaller, white-covered booklets; is 15 that right?
16 THE WITNESS: Yes.
17 BY MR. WRIGHT:
18 Q This small, white pamphlet is entitled "What to.Do 19 in Case of a Nuclear Station Emergency, Zion Station."
20 Now, Ms. Rorem, in the event that you do decide to 21 testify in the Braidwood hearings, are you in the process of 22 preparing that testimony?
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i S2 1 A No, I am not.
2 Q Have you completed your research on Emergency 3 Planning Contention A?
4 A No, I have not.
5 MR. URIGHT: No further questions.
6 MR. COPELAND: I have some questions.
7 FURTHER EXAMINATION 8 BY MR. COPELAND:
9 Q Your answer to Mr. Wright's last question indicates 10 that you are doing s ame . r esea r ch into emergency planning; is
- 11 that correct?
12 A Yes.
13 Q Let me follow up on Ms. Chan's questions. A're you 14 doing research of a factual nature of the development of the 15 plans in the area, or are you researching aspects of emergency 16 planning in general?
17 A Aspects of emergency planning in general 18 Q Are you researching the regulations, the walls 1.9 surrounding emergency planning?
~
20 A partially.
l 21 Q Can you identify for us what it'is you are 22 researching? What sources are you looking to?
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G3 1 A I would prefer not to answer that question, because 2 of my answer to another question which had to do with people.
8 O So your research is confined to the advice that you 4 are getting from other people s is that correct?
5 A No, it is not. My research is not confined to the 6 advice. The advice may point me in certain directions.
7 Q Are you reading any documents?
8 A Not at the current time.
9 Q Have you read any documents? It is quite apparent 10 to me that you are not reading any documents --
11 [ Laughter.]
12 I said there would be no trick questions.
13 MR. WRIGHT: I hope there will be not trick answers.
14 THE WITNESS: Have I read documents specifically 15 dealing with emergency planning? No.
16 BY MR. COPELAND:
17 Q What documents do you have in mind, then, that you 18 have read to prepare for this contention? Have they dealt 19 with the effects-of radiation, environmental effects?
20 A No, no.
21 Q Well, can you tell us, please, what --
22 A No, I really cannot tell you.
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84 1 MS. CHAN: Is that because you don't know?
2 THE WITNESS: No, I know. I don't want to --
3 BY MR. COPELAND:
4 Q is it the testimony of a witness in a prior case?
5 A Partially.
6 Q And I take it, it is authored by one of your 7 potential witnesses?
8 A Yes.
9 Q Whom you do not want to identify?
10 A That's right.
11 O Can you tell us of any documents you have been 12 reading of any nature that would not endanger this 13 confidential relationship which you have sworn to?
14 MR. WRIGHT: Affirmed.
15 BY MR. COPELAND:
16 Q Affirmed.
17 A Plato's Republic. No, I don't -- no, I can't.
18 MR, COPELAND: We will reserve our rights to raise 1
19 this to the Judges, .as well. l l
20 Do you have anything, Joe? l 21 MR. GALLO: No, I think we will have to move to 22 compel an answer and seek a remedy in that fashion.
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4 85 1 Have we got it clear on the record that we want 2 answers to those interrogatories?
8 MR. COPELAND: No. I was about to do that.
4 For the record, I am now submitting by hand a copy 5 of the interrogatories to Intervenor, Bridget Little Rorem and 6 Appleseed Alliance. I apologize for the misidentification of 7 Appleseed.
8 MR. GALLO: When were they filed?
9 MR. COPELAND: They were originally filed on April 10 25, 1985, by service by the U.S. mail. And now we are 11 delivering a copy by hand. We would ask that they be answered 12 within the fourteen-day period prescribed by the regulations.
18 MR. WRIGHT: I think we should also let the record 14 reflect that Ms. Rorem had not received the second set of 15 interrogatories until this very moment from Mr. Copeland.
I 16 EUhereupon, at 7:30 o' clock, p.m., the taking of the i
17 deposition was concluded.]
18
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19 20 21 22 j
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[
1 CERTIFICATE OF DEPONENT ,
2 I hereby affirm that I have read the foregoing i
3 pages 3 through 85 of my deposition testimony taken in the 4 above proceeding and, that with the exception of corrections 5 and changes, if any, hereto, believe them to be a true and 6 accurate transcription of the proceedings.
7 8 ______=_- __ _ _ _ _ _ = _
9 BRIDGET LITTLE ROREM 10 11
_ _ = - - - __
1 12 DATE IS ***
14 CERTIFICATE OF NOTARY PUBLIC 15 Sworn to or affirmed before me this the day 16 of , 19 17 18 _
19 NOTARY PUBLIC IN AND FOR 20 21 My commission expires:
22
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1 CERTIFICATE OF REPORTER 2 I, ANN RILEY, the officer before whom the foregoing 3 deposition was taken, pages 1 through 86, do hereby certify 4 that the witness whose testimony appears in the foregoing 5 deposition was duly sworn by me; that the testimony of said 6 witness was taken by me and thereafter reduced to typewriting 7 by me or under my direction; that said deposition is a true 8 record of the testimony given by the witness; that I am 9 neither counsel for, related to nor employed by and of the 10 parties to the action in which this deposition was taken; and 11 further, that I am not a relative or employee of any attorney 12 or counsel employed by the parties hereto, nor financially 13 or otherwise interested in the outcome of the action.
14 15 (/ny) (c._y Ann RilefJ 16 Notary Public in and for the 17 District of Columbia 18 hp as 21 j i 22 l
,