ML20127K536

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Transcript of 850624 Evidentiary Hearing in Apex,Nc. Pp 7,768-7,942.Supporting Documentation Encl
ML20127K536
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 06/24/1985
From:
Atomic Safety and Licensing Board Panel
To:
References
CON-#385-645 OL, NUDOCS 8506270480
Download: ML20127K536 (176)


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OR G NAL UN11ED STATES NUCLEAR REGULATORY COMMISSION IN THE MATTER OF: DOCKET NO: 50-400 OL CAROLINA POWER & LI,GHT COMPANY and NORTH CAROLINA COMPANY MUNICIPAL POWER AGENCY (Shearon Harris Nuclear Power Plant) Evidentiary Hearing l

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\v LOCATION: APEX, NORTH CAROLINA PAGES: 7768 - 7942 DATE: MONDAY, JUNE 24, 1985 TR. o! @

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ACE-FEDERAL REPORTERS, INC.

OfficialReportes 444 North Capitol Street 23725.0 Washington, D.C. 20001 Og6270400050624 r ^"" **pg= s e os - cov m ce t -

Joe Wnich 7768 1 UNITED STATES OF AMERICA (w NUCLEAR REGULATORY COMMISSION I (_) 2 3 BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 4

5 -----------------X 6 In the matter of:  : Docket No. 50-400 OL 7 CAROLINA POWER & LIGHT COMPANY  :

and NORTH CAROLINA COMPANY  :

8 MUNICIPAL POWER AGENCY  :

9 (Shearon Harris Nuclear Power  :

Plant) Evidentiary Hearing  :

10  :

X 11 12 Ramade Inn Intersate 55 ~~

U.S. 1 South ~

)

  • Apex, North Ca'rolina 27502 14 Monday, June 24, 1985 i i

15 .

i 16 The hearing in the above-entitled matter i 17 convened, pursuant to recess, at 10:00 a.m. i i

18 BEFORE:  !

19 JAMES L. KELLEY, Esq, Chairman ,

Atomic Safety and Licensing Board  :

20 Nuclear Regulatory Commission l Washington, D. C. 20555 21 GLENN O. BRIGHT, Member 22 Atomic Safety and Licensing Board Nuclear Regulatory Commission 23 Washington, D. C. 20555 j 9 24 Ace. mseret Reponers, Inc.

25 JAMES H. CARPENTER, Member Atomic Safety and Licensing Board Nuclear Regulatory Commission Washington, D. C. 20555

Joe W2lch 7769 I APPEARANCES:

O

-%/ 2 On behalf of the Applicants' 3 THOMAS A. BAXTER, Esq.

DELISSA A. RIDGWAY, Esq.

4 Shaw, Pittman, Potts & Trowbridge 1800 M Street, N.W. <

5 Washington, D. C., 20036 6 DALE E. HOLLAR, Esq.

Associate General Counsel 7 Carolina Power & Light Company P. O. Box 1551 8 Raleigh, North Carolina 27602 9 On behalf of the NRC Staff:

10 CHARLES A. BARTH, Esq.

JANICE E. MOORE, Esq.

II Office of Executive Legal Director U. S. Nuclear Regulatory Commission 12

(}

13 BRADLEY JONES, Esq.

Region II Id Nuclear Regulatory Commission 15 On behalf of FEMA:

16 STEVEN M. ROCHLIS, Esq.  !

Atlanta Regional Office  !

17 Suite 700 l 1371 Peachtree Street, N. E.

18 Atlanta, Georgia 30309 l l 19 On behalf of the Interveners:

( I l 20 MR. WELLS EDDLEMAN, pro se j 718-A Iredell Street i 21 Durham, North Carolina 27705 22 DANIEL F. READ, President

, CHANGE /ELP 23 5707 Waycross Street l

Raleigh, North Carolina 27606 24

(~)

Am , seer:: n.ponen, ine. JOHN D. RUNKLE, Esq.

25 Environmental Consultant l P. O. Box 4135

, Chapel Hill, North Carolina 27514 l

___ . _ _ _ _ _ _ _ - _ - _ - _ _ ~ _

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7770 I

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- _N _T _E _N _T _S~ t t t 2 WITNESS DIRECT CROSS REDIRECT RECROSS BOARD l

3 . Joseph F. Myers and 4 Dennis S. Mileti 7780 7784 7879 7883 7862 5 Guy Martin, Jr.

and 6 . Joseph F. Myers 7893 7905

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8  !

9 EEE1E111 l IDENTIFIED ADMITTED 10 Applicants' Exhibit Number 29 7901 12

13 ,

_L _A _Y _I _N _S Testimony of Joseph F. Myers and Dennis S. Mileti 15 i on EPJ Contention 4 (b) Following Page 7782 16

{ Direct Testimony of Guy Martin, Jr. on 17 Eddleman Contention 57-C-10 7895 18 Direct Testimony of Joseph F. Myers on Eddleman Contention 57-10-C 7897 19 20 21 -

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1-1-Joe Wnl 7771 1 EEEEEEEEEEE 2 (10:03 a.m.)

3 JUDGE KELLEY: Good morning. Let me first 4 introduce the Board.

5 My name is James Kelley, aid I am Chairman of 6 this Atomic Safety and Licensing Board. On my left is Dr.

7 James Carpenter, on my right Judge Glenn Bright. l 8 And the three of us comprise the Board for this 9 proceeding. We are here very briefly for evidentiary 10 hearings on two emergency planning contentions, one having i

11 to do with the bus drivers who might be called upon in the 12 event of an emergency, and the other having to do with the f^)

v 13 protective factors associated with different kinds of buildings 14 inside the Emergency Planning Zone.

15 Let me ask the parties next to introduce them-16 selves, and we will proceed from there.

17 Mr. Eddleman, do you want to begin?

18 MR. EDDLEMAN: I am Wells Eddleman. Intervener, 19 representing myself, 718-A Iredale Street, Durham, North 20 Carolina. l 21 MR. READ: My name is Daniel Read. Representing 22 CilANGE, Chapel liill Anti-Nuclear Effort, Post Office address 23 is Post Office Box 2151 Raleigh, 27602.

n

(,) 24 MR. RUNKLE: John Runkle, representing the A Fwna nnonen im:. ,

25 Conservation Council of North Carolina.  ;

1-2-Wal, Joe 7772 1 MS. MOORE: My name is Janice E. Moore, Counsel 2 for NRC Staff. To my right is Mr. Steven M. Rochlin, 3 Counsel for the Federal Emergency Management Agency, who 4 will be representing FEMA in this proceeding.

5 Also present today are Mr. Charles Barth, 6 Counsel for NRC Staff, and Mr. Bradley Jones, from NRC 7 Region II.

8 MR. BAXTER: Here on behalf of the Applicants, 9 I am Thomas A. Baxter, and to my right is Delissa A. Ridgway, 10 and to my left is Mr. Dale E. Hollar.

11 Mr. Hollar is Associate General Counsel for f

, 12 Carolina Power and Light Company. Ms. Ridgway and I *are 13 both from the law firm of Shaw, Pittman, Potts & Trowbridge.

14 JUDGE KELLEY: Thank you. Ladiesandgentlemen,l i

15 let me next acknowledge receipt of certain papers in  !

16 association with this hearing.

i 17 We had testimony due and received testimony and l 18 an exhibit from the Applicants on both contentions -- at l 19 least there was an exhibit on one. I believe that is correct..

t 20 The Staff filed testimony on behalf of FEMA,  ;

21 and we received from Mr. Eddleman at that time a set of  ;

i 22 exhibits, in which he would have in connection with 57-C-10, 23 and Mr. Read mailed to us last week a set of papers that  ;

O 24 A .r.e.,e n. con.n, inc.

he does not vue forward as evideneiarv exhibies, but rather i l

25 as material that he has in mind using in cross examination.

1-3-W21, Joe 7772-A 1 And we have received all those papers and 2 acknowledge that for the record.

3 Let me mention that we previously gave notice 4 of our intention to have a so-called limited appearance 5 session this evening here in the Ramada Inn in Apex, and 6 that is still on for tonight.

7 It will begin at 8:00. Under our usual rules 8 we have typically a fair number of people come who want to 9 speak and we allow about five minutes apice for speakers, 10 either pro or con or neutral on the general subject of 11 Shearon. Harris, so we would appreciate those of you here l l

12 if you have occasion to pass on that word, we would ,

() , 13 appreciate it.

14 We did, I might add, put out a press release j 15 through the NRC Public Affairs Office and I trust that l 16 some of the local media picked it up.

17 We would like to get right into our first 18 contention and get the first witnesses sworn. There is I 19 one other matter that we want to take a few minutes to talk 20 about.in relation to a separate contention, known as WB-3,  !

21 and it has to do with alleged drug use.  ;

i' 22 We have been through the process -- we admitted 23 the contention, we have been through discovery, and we are  ;

l ( 24 now up at a point where we might have either summary

' wr.n.<: n.corwei, inc.

I 25 disposition or later a hearing, and in that connection we

1-4-Wal 7773 1 received from Mr. Runkle a short while ago a motion to stay O

O 2 these proceedings essentially pending the completion of 3 some criminal proceedings against some people who had been 4 arrested at the site early last year I believe.

5 We received oppositions to that motion for --

6 I would rather call it postponement than stay, because 7 technically I think it is more a schedule matter than a 8 stay of a decision in that sense, but in any event we did 9 receive opposition from the Staff and Applicant.

10 We got a cross-motion from Mr. Baxter, asking 11 that we establish a specific schedule for either/or summary 12 . disposition or hearing ori that contention, looking toward O '3 e a ert=9 te o= were =ece erv i= 1ete sevee=ner or et en-14 same time that we would be probably having a hearing on the i

15 siren contention that is still pending.

i 16 I understand that the Staff -- I believe Mr.

17 Baxter stated in his motion that the Staff agreed with that 18 motion, and it would be useful I think this morning to see l

19 if there has been any further discussion among the parties >

20 and just where that stands, i 21 Mr. Baxter, can you report in that connection? I i

22 MR. DAXTER: Mr. Runkle and I had a brief l 4

) 23 conversation this morning. I won't report his position, but  :

24 I think we have essential agreement on the schedule. l Me Farlerd Reportets, Inc. i l 25 By way of some additional information, I made an

7774 1-5-Wal, Joe 1

effort to check the status of the criminal proceedings g>

relating to the eight members that were arrested, and while 2

3 I wasn't able to locate the responsible attorney, CP&L 4 personnel have talked to the Sheriff's personnel who were 5 involved in the matter, and told us that six of the eight 6 have entered pleas of guilty to some charge, and I don't 7 know whether it was the ones they were charged with a initially, and that the other two are coming up for either 9 entry of plea or trial this week. ,

i 10 So, I can't say exactly when they are going i l

11 to be over, but it looks to me like they are on a fairly 12 rapid schedule, and there should not be the interference j

() , 13 that Mr. Runkle contemplated in his postponement motion.

l 14 JUDGE KELLEY: Mr. Runkle, do you want to 1

15 speak to that?

16 MR. RUNKLE: Yes. Looking over Mr. Baxter's 17 suggested schedule, it seems reasonabic to us. We would 18 add to the first day where it says Applicant's last '

19 opportunity as f ar as summary disposition, we also have that 20 same day if we wanted to present a motion for summary 21 disposition.

22 GUDGE KELLEY: Is that implicit, Mr. Baxter?

23 MR. DAXTER: We have no objection to that i O

(m/ 24 modification. l A. F ie,.i nememi, ene.

25 JUDGE KELLEY: Is that agreeable to the Staff,

1-6-W21, J. 7775 m

1 this modification?

, 2 MS. MOORE : Yes, Your Honor.

3 JUDGE KELLEY: Okay. With that modification, 4 we will grant the Motion, and that will set the schedule.

5 You may have to fine tune come September. We have two 6 contentions , and so on, but in any event it sets us into a 7 time frame, and that would be useful.

8 We appreciate you coming out, Mr. Runkle.  ;

9 Is there anything else of a preliminary nature .

10 that we ought to raise before we call the first witnesses 11 on the bus driver contention?

12 (No response.) ,

13 Anything else, Mr. Road, or can , we go right

' ')

14 to it.

15 MR. READ: No, sir.

16 JUDGE KELLEY: Ms. Mooro?

17 MS. MOORE : No, Your Honor.

18 MR. ROCHLIS: We do have one thing to bring 19 up, Your Honor. At the hearing in November wo had indicated 20 that the exorciso report should be available at this timo, 21 and unfortunatoly we haven't boon able to moot that deadlino.

22 However, wo do have a targot dato of July 8th, 23 and we hope to have it available to the NRC for filing at 9 24

,w . . ,, i n n u t. .. inc.

25 that timo.

JUDGE KELLEY: My rocollection is that the 1

1-7-W21, J. 7776 1 exercise was, in fact, held along about May 18th or so, is q

lJ 2 that right?

3 MR. ROCHLIS: That is correct.

4 JUDGE KELLEY: And I believe we were supplied 5 recently with a transcript of some post exercise meeting.

6 MR. ROCHLIS: Public meeting. .

7 JUDGE KELLEY: But the report you refer to 8 is the FEM) analysis of the exercise, if you will?

9 6.7 ROCHLIS: Analysis of the exercise and 10 FEMA interim findings.

11 JUDGE KELLEY: Thank you. Mr. Eddleman?

12 MR. EDDLEMAN: , Judge, that reminds me that i I

(^T 13 I do havo one other thing to adviso the Board of, and that v;

14 is that people working on my behalf have boon trying to got ,

15 from the Stato the logo and other records of the Emergency 16 Planning Exorciso, finding information on which contingencies 17 would be based on the conduct of the exorciso.

18 So, far they haven't produced anything to us.

19 I believe that North Carolina law requires thom to releaso 20 them, and if necessary wo will tako legal action to compell 21 the production of thoso documento, but we havo not succoodod 22 in obtaining any yet. ,

23 JUDGE KELLEY: Dut you are advining the Doard (n) 24 w .i.,a n. m n.,i,ene.

for the record of your offorts to do thin, correct?

25 MR. EDDLEMAM: That in right.

1-8-W21, J. 7777 1 JUDGE KELLEY: You are not asking us to do anything about it at the moment?

2

/

3 MR. EDDLEMAN: No, sir. It is up to us, but 4 as I understand it the time for formulating the contention 5 isn't triggered until the information is available to you.

End 1. 6 Sua W fois.

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7778  !

  1. 2,-1-SueWalsn JUDGE KELLEY: Well, that's the Catawba formula- ,

2 tion sort of roughly. Whether we would want to take a 3

position on that this morning, I think we probably wouldn't 4

want to, in terms of arguing it all around.

5 But I understand your point. I think you are  ;

6 telling us now that you are doing this as an indication of 7

due diligence on your part which I -- do I correctly interpret 8

that?

9 MR. EDDLEMAN: I just want to get on the record what we are doing.

11 JUDGE KELLEY: Righ t.

MR. EDDLEMAN: It would be my position -- I don't

'O 13 V want to arguo it out, as you say the timo for formulating 14 I

F contentions isn't triggorod until the information is in l hand.

16 '

JUDGE KELLEY: Mr. Baxtor, comment?

I MR. DAXTER: Just one comment, Mr. Chairman. I 18 think the NRC caso law also establinhos that proponents of 19 contention are not entitled to discovery in ordor to formulato thoso contentions but are supposed to do no on the basis of 21 publicly availablo information.

22 And Intervonora did havo repronontativon at the 23 Stato EOC during the oxorcino. I agroo thin in acadomic at

( 24

.sc id ,e n.none,i, ine. thin point. I'm just trying to put nomo context around Mr.

25 Eddleman's report.

7779

  1. 2-2-SueWalsh JUDGE KELLEY: Okay. Isn't this where we stand?

2 Mr. Eddleman is clearly indicating he might want to file some 3 contentions about the exercise, and he will do that whenever 4 he can. And then he may be met with an argument that he is

-5 late, he should have been earlier. And then the Board will ,

6 decide it.

7 MR. EDDLEMAN: That's right. And just for the 8 record, in response to Mr. Baxter's point, the Intervenor ,

9 observers were placed in a place where they couldn't hear 10 most of what was going on. And they couldn't see any of the II written information. ,

12 So, that's one of the reasons that we are trying  !

13 to get the written information.

Id JUDGE KELLEY: Okay. I think we can def'er the I

15 resolution of this until later. It may not come up. And 16 if it does, sufficient unto the day will be the evil thereof, ,

1 i 17 right? I 18 MR. EDDLEMAN: Right. Let me just also say that l 19 documents that are supposed to be public records and are ,

t 20 being withheld by the State, that's not discovery of Applicants. !

t 21 JUDGE FELLEY: Okay. Anything oise before we  !

22 call the first witnesses on EPJ4(b)?  !

23 MR. EDDLEMAN: Pardon me, Judgo, but some of these 24 are in possession of the Countios as well as the State in A. . ,s numi.,i, w.

25 North Carolina. I just want to clarify that. [

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7780

  1. 2-3-SueWalsh JUDGE KELLEY: Okay. Mr. Baxter?

l 2 MS. RIDGWAY: Your Honor, Mr. Chairman, the i 3 Applicants call Mr. Joseph Myers and Dr. Dennis Mileti to 4 the stand.

5 JUDGE KELLEY: Thank you. Gentlemen, be seated.

6 MS. RIDGWAY: All right.

7 JUDGE KELLEY: Would you raise your right hands, 8 pleaso?

9 (The witnesses are sworn by Judge Kelley.)

10 JUDGE KELLEY: Thank you.

11 Whorcupon, 12 , , JOSEPl! F. MYERS I

(~") 13 - and - .

Id DENNIS S. MILETl 15 are called as witnoscos by and on behalf of Carolina Power and H

16 l Light Company and North Carolina Company Municipal Power Agency 17 F and, having first boon duly sworn, woro examined and testified 18 as follows:

DIRECT EXAMINATION 19 'l INDEXXX 20 BY MS. RIDGWAY:

21 0 Dr. Miloti, plonso stato your namo, position and 22 buoinoso addrono for the record.

23 A (Witnons Miloti) My namo in Donnis Miloti. I am llh

,w e 7d

.,3 n. m ,i.,i,inc, a Profoonor of Sociology and Director of tha llozards Annonn-25 mont Laboratory at Colorado Stato Univoralty, Fort Collinn, l

7781

  1. 2-4-SueWalsd Colorado, us 2 Q And, Mr. Myers, please state your name, position 3 and business address.

4 A (Witness Myers) My name is Joseph F. Myers. I 5 am the Director of the North Carolina Division of Emergency I

6 Management, 116 West Jones Street, Raleigh.

7 Q Dr. Mileti, directing your attention to a document 8 entitled " Testimony of Joseph F. Myers and Dr. Dennis Mileti ,

9 on EPJ Contention 4(b), Role Strain in Adult School Bus 10 Drivers," including the attached Academic Vita of Dennis S.

II Mileti, was the attached Academic Vita and the testimony 12 , which is associated kith your initials prepared by you or 13 ' under your supervision?

)

Id A (Witness Miloti) Yes, they woro.

15 [ Q Do you have any changos or corrections to thoso 16 documents?

n 17 A No, I do not.

18 Q Aro thoso documents true and correct to tho best U of your knowledge, information and belief?

l 20 A Yos, they aro.

21 Q And do you adopt thoso documents as your testimony 22 in this procooding?

23 A Yes, I do.

24 Mr. Myors, I direct your attontion to the samo Q

25 l document, including the attached capability Profilo. Han

7782

  1. 2-5-SueWaldh the attached Capability Profile and the testimony which is 2 associated with your initials prepared by you or under your 3 supervision?

4 A (Witness Myers) Yes, they were.

5 Q And, do you have any changes or corrections to 4 i

6 that -- those documents?

7 A No. .

8 I Q Are those documents true and correct to the'best 9 of your knowledge, information and belief?

10 A Yes, they are.

II Q And, do you adopt those documents as your testimony 12 in this proceeding?

I3

(]) A I do.

M MS. RIDGWAY: Mr. Chairman, I move that the 15 document entitled " Testimony of Joseph F. Myers and Dennis S.

I 16 f Mileti on EPJ Contention 4(b)," including the attached il 17 statements of professional qualifications of Dr. Mileti and i

18 Mr. Myers be admitted into evidence and bound into the record

" as if read.

20 MR. READ: No objection.

2I JUDGE KELLEY: Mr. Barth?

22 MR. DARTil No objection.

23 JUDGE KELLEY: So ordered.

24 '

XX (The testimony follows.)

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4 June 10, 1985 5

6 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION 7

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD 8

9 In the Matter of )

)

10 CAROLINA POWER & LIGHT COMPANY )

and NORTH CAROLINA COMPANY ) Docket No. 50-400 OL 11 MUNICIPAL POWER AGENCY )

)

12 (Shenron Harrin Nucioar Power )

Plant) )

13 ,

w 14 U 15 TESTIMONY OF 16 JOSEPH F. MYERS AND DENNIS S. MILETI ON EPJ CONTENTION 4(b) 17 (ROLE STRAIN IN ADULT SCHOOL BUS DRIVERS) 18 19 20 21 22

. 23 24 25 26 A

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1 Q.1 Please state your names.

O

\' 2 A.1 Joseph F. Myers (JFM) and Dennis S. Mileti (DSM).

3 Q.2 Mr. Myers, by whom are you employed, and what is your 4 position?

5 A.2 (JEM): I am the Director of the Division of Emergen-6 cy Management ("DEM") of the North Carolina Department of Crime 7 Control and Public Safety. The basic responsibilities of DEM 8 include fulfilling the State's role in emergency planning for 1

9 natural and manmade disasters, in responding to and recovering 10 from disasters, and in miuigating their effects.

11 Q.3 Please summarize your professional qualifications and 12 experience.

13 A.3 (JEM): As Director of DEM, I have been involved in 14 the development of the offsite emergency capability for the O 15 Shenron Harris Nuclear Power Plant, as well as the Catawba, 16 McGuire, and Brunswick nuclear plants. Since February 1985', I 17 have had overall authority for emergency preparedness activi-18 tien concerning the Harris plant. Prior to thin, I was for 19 nine years employed an Area Coordinator for the Division of 20 Emergency Management Area E, which includes portions of the 21 emergency planning :ones for the Catawba and McGuire nuclear 22 power plants. In this position, I was responsible for offsite 23 emergency plans, drillo and exercisen for the countion involved 24 with those plants. I was also responsible for overall emergen-25 cy preparedness in that Area, and directed the State's response 26

o N

1 to hundreds of emergencies in the past two years in Area E. I O 2 have also coordinated the State's response to over 100 3 emergencies while in my current position as Director of the Di-4 vision of Emergency Management. In addition, I have supported 5 DEM staff on location in responding to statewide emergencies 6 such as the tornadoes in March 1984, Hurricane Diana in 7 September 1984, and the forest fires which occurred across the 8 State in the Spring of this year. A complete statement of my l 9 professional qualifications is appended as Attachment 1 to this 10 testimony.

l 11 Q.4 Dr. Mileti, by whom are you employed, and what is l 12 your position? '

13 A.4 (DSM): I am a Professor in the Department of Sociol-14 ogy and Director of the Hazards Assessment Laboratory at 15 colorado State University, specializing in those areas of study 16 dealing with organizations, hazards, policy and methods (with a 17 particular emphasis on public response to emergencies).

18 Q.5 Please summarize your professional qualifications.

19 A.5 (DSM): I received my Bachelor of Arts degree in so-20 ciology in 1968 from the University of California at 21 Los Angeles. In 1971 I was awarded a Master of Arts degree in 22 Sociology from California State University, Los Angeles. From 23 1971 to 1972, I was an Instructor in the Department of Sociolo-24 gy at the University of colorado, Boulder. I completed my doc-25 torate degree in Sociology in 1974 at the University of O l l

l 1

i 1 Colorado, Boulder. From 1974 to 1978 (when I was appointed an r

( 2 Associate Professor at Colorado State University), I held the 3 position of Assistant Professor at that institution. I became 4 a full Professor this year. I have taught numerous undergradu-5 ate courses including Introduction to Sociology, Complex Orga-l

6 nizations, Sociology of Disasters, Research Methods, Theory, 7 Demographic Processes, and Social Change. In addition, I have 8 taught courses at the graduate level such as Advanced Quantita-9 tive Analysis, Research Methods I and II, Demography and Popu-10 lation, and Complex organizations.

11 In 1975 I was appointed Visiting Assistant Professor at 12 the University of Southern California Graduate School of Public 13 Administration. From 1978 to 1979, I was an Invited Instructor 14 for the Chautauqua Short Course Program sponsored by the Ameri-15 can Association for the Advancement of Science. In 1981, I was 16 appointed Policy Analyst for the Seismic S'afety Commission by 17 the State of California. (During the year I served this ap-18 pointment, I was on leave from my university duties).

19 I am also active in a number of professional organiza-20 tions, including the American Sociological Association; the In-21 ternational Sociological Association; the Pacific Sociological 22 Associations the Midwest Sociological Society; the Earthquake 23 Engineering Research Institute; the Society for the Study of 24 Risk Analysis; and the American Association for the Advancement 25 of Science. I currently also serve as a member of the 4

1 Committee on Natural Disasters in the National Academy of Sci-2 ences. A complete statement of my professional qualifications 3 is appended as Attachment 2 to this testimony.

4 Q.6 What is the purpose of this testimony?

5 A.6 (JFM, DSM): The purpose of this testimony is to re-6 spend to EPJ Contention 4(b). As originally admitted by the 7 Atomic Safety and Licensing Board, that contention asserted:

8 Section E4d of State Procedures (p. 47) is deficient because [ajdult bus drivers have 9 minimal education and are paid very low wages. They cannot be trusted to put their 10 jobs above family obligations or to perform adequately in emergency situations.

11 However, the Board has since " rule [d] out litigation on whether 12 the wages the adult drivers are paid'and the education they've 13 , .

received *are so low that they 'cannot be trusted' to perform their public duties competently in an emergency." The Board 15 focused on adult school bus drivers (as opposed to student-age 16 drivers) based on its reasoning that adult school bus drivers 17 "would very likely not already be at the schools when they were 18 called upon to evacuate the schools, and are more likely than 19 the student drivers are to have family obligations." The Board 20 therefore concluded that, in the event of an evacuation, " adult 21 drivers would very likely have the opportunity student drivers 22 would not have -- to weigh conflicting obligations." In short, 23 the sole remaining issue is " role conflict" or " role strain" 24 (between family obligations and emergency response roles) in 25 6

Q i

_ 1 adult school bus drivers in the event of an evacuation due to a

(  !

2 radiological emergency at the Harris plant.

3 Q.7 What is " role conflict"?

4 A.7 (DSM): The notion of " role conflict" is a concept in 5 the social sciences based on the following ideas. Individuals 6 in society play many different roles, and each role has certain 7 rights and obligations in particular social relationships. Be-8 cause each person plays many different roles, the rights and 9 obligations of one role may be consistent with those of another 10 role, or irrelevant to or in " conflict" with another role. The 11 concept of role " conflict" in generally used uncritically, as 12 an eithor/or matter in which a person is forced to choose be-13 tween two or more roles. " Conflict" implies equally weighted

(~y 14 contradictory alternatives, requiring a person to choooo ono 15 role to play while abandoning another. This condition is raro-16 ly, if ever, found in actu'la social life. A more accurato term 17 is rolo " strain," which denoton the difficulty felt by an indi-la vidual in fulfilling different role obligations at the namo 19 time. Rolo "ntrain" is proforable becauno it doncriben moro 20 accurately the actual conditions that people experienco in all 21 of nocial lifo, not just thoco of omergencies. Rolo " strain" 22 in something with which people copo in most social nituations 23 and in a permanont fonturo of nocial life.

24 Q.0 llow did the idon of " role conflict" originato?

25 7x 26

] .G.

1 A.8 (DSM): The seed of the present controversy over role

~

2 strain in workers in radiological emergencies may be found in 3 the widely-quoted article by Lewis Killian, "The Significance 4 of Multi-Group Membership in Disaster," American Journal of 5 Sociology, January 1952, pp. 309-314. Killian's article was 6 one of the first major publications on behavior in emergencies 7 and disasters that had widespread distribution among social 8 scientists, and it provides an unusually vivid illustration of 9 the purported consequences of " role conflict." As a result, it 10 has been used repeatedly to explain the concept in introductory 11 textbooks and has recently been used to support a hypothesi cd 12 " problem" for emergency planning, that in, that the ability of 13 emergency workorn to do their omorgency jobe during a ra-(~'; 14 diological omorgency at a nuclear power plant might initially n-15 be constrained by fasily obligations. What was intended by 16 Killian an a more illustration of a concept han now boon din-17 torted into the status of a univernal truth about behavior in 18 omorgencion, primarily by thoso who have not road K1111an's ar- i 19 ticle carefully.

20 Killian illustrated neveral difforont potentini " role con-21 flict" nituations. Savoral of those woro situations in which 22 people involved had no definito reopensibilition in the amor-23 goney social nymtom (that in, in the mobilination of community 24 recourcon to deal with the omorgoney), Sinco thono people had 25 no epocific dinactor ronponsiblition, it in difficult to know

, -) 26 x' '

7

7 1 exactly what it was that their " family" obligations are sup-2 posed to have prevented them from doing.

3 Thus, Killian's examples stood for the simple proposition 4 that, if people have no definite " role" in an emergency, it 5 will be unclear to them what they should do. Significantly, in 6 the illustrations Killian used (which were case studies), those 7 who did have occupational roles relevant to the emergency per-8 formed them and even expressed concern that they could not do 9 more. In addition, Killian, while seeming to present cases of 10 potential conflict, pointed out that none of this had any real 11 effect on the operation of the emergency social system. An 12 accurato reading of Killian's original article is that although 13 people with emergency roles will express anxiety about poten ,

m 14 tial conflicting obligations in emer.gencien, they will perform

~

15 thone rolen that are more immediately relevent to the emergency 16 social nyntem.

17 In short, rolo strain (or what le called " role conflict" 18 by como) in what in experienced by people who find themselvon 19 in a situation whoro the domands of differont roles are being 20 made on them at the como time. Roln strain (or " conflict")

21 does not imply that one rolo'n obligations will be nerviced 22 while another'n are abandoned.

23 Q.9 Can you givo un an examplo of " role conflict"?

24 A.9 (DCM): Most of the exampion unod to illustrato rolo 25 conflict are based on clannic ntarcotypon of family life that 26 are, in reality, quito atypical.

0-

L 1 The classic stereotype postulates the following hypotheti-2 cal family and social situation: an employed (and competent) 3 male whose place of employment is separated from the location 4 of his unemployed (and incompetent) wife, who is with their 5 small (and anxious) children. The family's location is in 6 potential danger. This isolated family segment is presumed to 7 lack alternative sources of immediately available support, such 8 as kin or neighbors. Further, it is assumed that the husband 9 has no means of assuring the safety of the rest of the family 10 while at his post. Finally, it is presumed that the 11 employee-husband has a vague and perhaps inconsequential emer-12 gency responsibility.

13 From this mix of assumptions, one might prophesy that the 14 strong, competent husband might leave hin' post and go home to 15 take care of his family, or delay doing anything, until he 16 nomehow was personally assured that his wife and children were 17 being taken care of. If he did leave or delay, the organica-18 tion would lone an employee, albeit one who lacked organica-19 tional commitment and perhaps adaptability. That loss, how-20 over, in unlikely to be particularly significant to the 21 operation of the organization. On the other hand, the individ-22 ual might return in a few minuten to annume his role.

23 Moreover, the family nyctem visualized in the clannic 24 " role conflict" example in an atypical living arrangment. Fam-25 ilies with an employed male and unemployed wife with small 26

\

v

,9,

i i

i

, f_s I children at home constitute only about 13 percent of American i

(_) 2 families, according to the 1980 census.

3 Q.10 How closely do the adult bus drivers who would assist 4 with school evacuation fit such stereotypes?

5 A.10 (JFM): Of a total of approximately 96 bus drivers to 6 be used in school evacuation, only approximately 38 would be j ,7 adults. Approximately 15 of these 38 live in the Harris plume 8 exposure pathway emergency planning zone; and, of those 15, i

l 9 only 3 have pre-school children, or disabled or aged relatives 10 at home during school hours. Two of these three typically have 11 other competent adult family members at home during school 12 hours. While these numbers obviously will fluctuate somewhat 13 over time, it is reasonable to expect that those serving as 14 drivers during the 1984-85 school year (as discussed above) 15 would be typical of coming school years. Consequently, it can 16 be expected that only a very few of the adult bus drivers are 17 likely to have dependents at home during school hours for whom 18 arrangements would need to be made.

19 In addition, at least some of the bun drivern with fami-20 lies inside the EPZ would be assuring the safety of their own 21 children by annisting with the evacuation of their children's 22 school nyatom in an emergoney.

23 Q.11 In it possible that noma of the emergoney workorn 24 would experience role atrain (" conflict") in the event of a ra-25 diological amorgoney at the !!arrin plant?

1o.

e

(

1 A.11 (DSM): It is important to distinguish between role

!7[)

\

2 strain, which is a mental state (a feeling of concern and 3 unease), and role abandonment, which is a type of behavior.

4 Thus, while it is to be expected that emergency workers would 5 experience some role strain during an emergency at Harris, this 6 does not mean that they would abandon their emergency roles be-7 cause of it.

8 Q.12 Is there any authority to su port this view?

9 A.12 (DSM): Yes. Human response to emergencies has been 10 a topic of investigation by social scientists for over three 11 decades. This research history has covered many aspects of 12 human behavior; and an important component of this work has 13 been to investigate the , behavior of people with roles of re-g- 14 sponsibility in emergency response. The principles of emergen-(

15 cy worker response -- well-established through decades of re-16 search and investigation -- would be applicable in the event of 17 an emergency at a nuclear facility such as the Harris plant, 18 and would be as applicable to adult bus drivers as to any other 19 group of emergency workers.

20 The scholar who first gave un the concept of " role con-21 flict" in disasters and emergencies was also the first to step 22 forward to begin a clarification of what really goes on in 23 emergencies with respect to " role conflict" and role abandon-24 ment. In 1954 (only two years after his first article on role 25 conflict) Lewis M. Killian published a paper entitled "Some 26 b) s

  • 11

1 Accomplishments and Some Needs in Disaster Study," The Journal O 2 of Social Issues X: 66-72.

3 Killian's 1954 article addressed whether or not role 4 strain will result in role abandonment during emergencies. He 5 wrote, on page 69, that "The possession by the individual of a 6 clear conception of a role which he can or should play seems to 7 be conducive to organized adaptive behavior." What Killian was 8 saying is that emergencies are not social disorganization, and 9 role strain does not result in role abandonment M emergency 10 workers are provided -- before an emergency -- with a clear 11 idea of what their emergency roles are.

12 Q.13 Have later studies confirmed Killian's theories?

In1961,.ChablesE.Fritzwroteanother 13 A.13 (DSM): Yes.

l r~ 14 classic piece of literature in the field in which he tried to 15 bring things up-to date'. It was titled, simply, " Disaster" 16 (pages 651-694>in Merton nnd Nisbet'-(eds.) Contemporary Social Problems, .NewLyork: Harcourt).

17 -<

18 on page 675 of this book (which'itself became a classic

~

19 textbook on social problems), Fritz adciresses -ho( f adtilies, y ^a _ .

20 emergency _ jobs, peop.1.e with emerg,ency ioby, a.3 d 'p e o p l e. without

_ .m ,

21 emergency jobs are refated. In essence, Fritz (whci was until 22 recently od'the National Academy of S$1hnc6s! National Research

. m , ,

23 Counciloin \

the " disto:ter-resee.rch" component) laid the ground-

. s u-24 work for the fo!. lowing hypotheses: (1) All people are con- ,

25 cerned for loved ones in dicaster. (2) Most peo'ple do not have

'y' 26 '

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, -k 1 emergency roles, and these people are torn between loyalty to U

2 intimates and loyalty to the community; most of these people 3 first tend to their intimates and only then volunteer for emer-4 gency work. (3) People with clearly defined emergency jobs, 5 however, do these jobs, but with a considerable degree of per-6 sonal stress until they are assured of the safety of intimates.

7 (4) Special provisions can be made to assure emergency workers 8 of the safety of family and intimates and to alleviate this 9 stress for them. Consequently, (5) role conflict for emergency I 10 workers that have a clear notion of their emergency role is a 11 mental and not a behavioral phenomenon.

12 Q.14 What other support is there for this view?

13 A.14 (DSM): In 1962, Meda White wrote a report at the

{} 14 University of Chicago. It was entitled Role Conflict in 15 Disasters: Not Family but Familiarity First. White did her 16 work eight years after these disasters occurred, so she was re-17 searching the disasters in communities with emergency plans of 18 the generally unsatisfactory sort that were to be found in the 19 early 1950's. Nevertheless, she found in research on three 20 different emergencies that 92% of the people studied contrib-21 uted to disaster activity first over the family and that this 22 rose to 89% after the first four hours of the disaster. She 23 concluded that " role certainty" is a requisite for what emer-24 gency workers do in an emergency - -that is, people seek role 25 certainty in emergencies. If the emergency work role is 3

26 6

e 1 uncertain, people will opt for family roles, which are more

(_ ) '

2 clearly known and certain. However, if emergency roles can be 3 made "certain," then people will perform their emergency jobs.

4 Q.15 What are the most recent authoritative works on this 5 subject?

6 A.15 (DSM): In a 1970 book titled Organized Behavior in 7 Disaster (Lexington, Mass.: D.C. Health), Russell Dynes tried 8 to set the record straight. In a different way, he reported 9 the knowledge reviewed above. Citing Killian's statement that 10 "in none of the four communities studied did the disastrous 11 consequences contemplated above seem to have materialized,"

12 Dynes explained:

13 Part of the explanation of the fact that the " disastrous consequences contem-

,r 3 14 plated" did not materialize is that the i

s ) abandonment of organizational roles simoly 15 does not occur. While such conflict is theoretically possible and while individ-16 uals are obviously confronted with the choice of alternative actions, it seems 17 clear that they do not abandon their roles in disaster-relevant organizations.

18 Perhaps the most all-inclusive research work on role 19 strain / abandonment ever performed was written by E. L.

20 Quarante111 (and co-authored by Russell Dynes, although his 21 name does not appear on the report), through the Disaster Re-22 search Center at Ohio State University. It is titled 23 Structured Factors in the Minimization of Role Conflict: A 24 Re-Examination of Significance of Multiple Group Membership in 25 26

(~';' xs

a 1 Disasters. This work was based on 150 different emergencies

\

)

2 and disasters, and included interviews of more than 6000 emer-3 gency workers. Not even one case was found where the func-4 tioning of an emergency organization was undermined by emergen-5 cy personnel not reporting for duty. Indeed, in many 6 instances, an over-supply of personnel was reported.

7 In short, research conducted on the actual behavior of 8 people with defined organizational responsibilities in 9 emergencies establishes that emergency workers who have a clear 10 idea of their emergency roles do their emergency jobs.

11 Q.16 Can you briefly summarize why this is the case?

12 A.16 (DSM): The absence (for all practical purposes) of 13 evidence of persons abandoning known emergency roles over a 73 l 14 wide range of emergency events in the past illustrates that

\

15 there are certain structural changes in the community during 16 emergencies that reduce role strain. Role obligations are 17 based on values and, during non-emergency " normal" times, peo-18 ple expend effort on many different values, some potentially 19 contradictory. An emergency changes this process dramatically.

20 Some values become clearly more important than others, and peo-21 ple experiencing the emergency generally agree on the few that 22 take precedence over all others.

23 This phenomenon is the development of what has been called 24 the " emergency consensus." In this consensus, people become 25 altruistic, and protection of the community becomes the highest 26 U' .

1 priority. Other values become drastically less important.

1

'~

2 This temporary shift in values simplifi.es the role obligations 3 of people, and greatly reduces the potential for role strain.

4 People are " released" to concentrate on the critical tasks of 5 the emergency. The value priorities in an emergency thus alle-6 viate, rather than aggravate, role strain for community mem-7 bers. Those with identified emergency roles are therefore able 8 to fulfill them, rather than ignore the emergency in order to 9 tend to the obligations of other roles.

10 Q.17 If an emergency worker knows his role in advance, is 11 the worker better able to prepare for an emergency?

12 A.17 (DSM): People who know in advance of an emergency 13 (should one ever occur) that they have emergency roles to play f~y 14 are able to.make informal family contingency plans in advance L-) -

15 of the emergency. For example, families can make plans in 16 advance of an emergency to ensure that -- in an emergency --

17 the non-emergency-worker spouse (or other appropriate person) 18 will take the appropriate measures to protect the family unit 19 in the absence of the emergency worker. Similar pre-emergency 20 plans can be made to provide for the continuation throughout an 21 emergency of child care arrangements in place at the time any 22 emergency occurs. Such pre-emergency planning can also provide 23 for the assumption by relatives, friends or neighbors of other 24 usual responsibilities of the emergency worker. Indeed, in 25 past emergencies, even in the absence of such contingency 26 L

(_[x l plans, th'e role obligations of emergency workers toward inti-V 2 mates (including family) have generally been shifted and as-3 sumed by other non-emergency-worker members of the intimate 4 group, thereby freeing the emergency worker to fulfill assigned l

5 emergency roles.

6 Q.18 Is there anything else about emergency workers that l 7 makes them less susceptible to role abandonment?

8 A.18 (DSM): Because emergency workers' jobs provide them 9 with information about the emergency, they have access to 10 accurate and more informed knowledge of the scope of the risk, 11 and are therefore better able to assess the " danger" to family 12 members.

13 In addition, emergency workers fulfill their role obliga-14 tions in emergencies because of the cohesiveness of the work 15 group. People with knowledge of their emergency roles do not 16 wish to let their co-workers down. In emergencies, the need to 17 have emergency work performed is obvious, and the emergency 18 role takes on added importance. The sense of obligation to 19 perform that role is strengthened, and the sense of obligation 20 to the community as a whole is strengthened. And, since part 21 of the traditional image of spouse and parent includes the ob-22 ligation to perform adequately the necessary work-related emer-23 gency roles, the traditional role reinforces (rather than con-24 flicts with) the emergency role of the emergency worker.

25 l

l i 26 I

! Q-s l

1 g.19 Is the location of an emergency worker at the time of t

v 2 an emergency an important factor in determining whether that 3 worker will respond to his emergency position?

4 A.19 (DSM): No. Emergency workers who are at home when 5 an emergency begins will likely continue to play the roles they 6 are performing at the time (for example, father, husband, wife, 7 mother, and so on) for a relatively brief period of time.

8 These roles are serviced as decisions are made that enable them 9 to feel free about separating family members so that emergency 10 roles can be performed. What might seem to be a potential for 11 delay in reporting for duty is not, in operation, a real prob-12 lem because: (a) most emergencies do not begin with the need 13 for immediate and dramatic ac,tions like evacuation; emergency

, (~) 14 organizations can be mobilized in stages while families com-LJ -

15 plete decision-making, with other family members or intimates 16 assuming the potential family role obligations of the emergency 17 worker who has reported for work; (b) most families include at 18 least one other member who is competent (i.e., able to drive, 19 listen to emergency information, and make decisions) and able 20 to assume the potential family role responsibilities of the 21 absent emergency worker; and (c) workers are typically anxious 22 to resolve other responsibilities and report to their emerge!;cy 23 work stations. Workers away from home when an emergency begi{ns 24 typically improvise ways to assure themselves of the safety o f 25 intimates (through ad hoc, informal channels), while tending 5:o

-s 26 their emergency job duties at the same time.

l )

%J T

0 6

a 1 Q.20 Where are the adult bus drivers likely to be, should 2 they ever be called upon to assist with school evacuation due 3 to an emergency at Harris?

4 A.20 (JFM): Of the approximately 38 designated adult bus 5 drivers who would be available to assist with school evacua-6 tion, approximately 21 are employed in some other capacity on 7 the staff of the schools (12 inside the EPZ). Thus, a signifi-8 cant proportion of adult drivers would already be at their 9 emergency stations if an evacuation were ordered while school 10 was in session. Of the remainder, only approximately 14 are 11 typically at their homes on school days. In short, while these 12 numbers will fluctuate to some degree over time, it can be ex-13 pected that the majority of the adult bus drivers already would

(") 14 be away from home, at work (many at schools), if needed to as-V 15 sist with the evacuation of schools.

16 Q.21 Can you summarize why role strain would not be ex-17 pected to preclude an adequate emergency response in the event 18 of a radiological emergency at the Harris plant?

19 A.21 (DSM): The potential of role strain for reducing the 20 effectiveness of emergency response is minimized by the organi-21 =ational and occupational assignment of emergency responsibili-22 ty. Assigning clear responsibility creates clear direction for 23 behavior and ensures that the work of emergency response orga-24 nizations is fulfilled. Further, assigning clear responsibili-25 ty makes it clear to emergency workers that they have

_ 26

()

K_/ _1g_

s 1 responsibilities to their co-workers. Failing to report for

! )

2 work would increase the burden on others. In addition, advance 3 knowledge of one's emergency role allows the emergency worker.

4 to arrange to avoid role " conflict" and indeed to fill the role 5 of family member more effectively than if he or she were not an 6 emergency worker. The worker can preplan for family safety in 7 an emergency. Also, because of organizational ties, the emer-8 gency worker is more likely to receive information about the 9 nature of the emergency and the nature of the risk, which al-10 lows the worker to fulfill family obligations more effectively.

11 Finally, due to the formation of the " emergency consensus" 12 discussed above, in actual emergencies, people conform to 13 pro-social behavior patterns and assume their roles under the 7y 14 emergency plan, even where they have earlier asserted that they i 'J 15 would not do so. Thus, while it is possible that some few 16 might be found who would swear in advance that they would not 17 perform their emergency functions in an emergency (as would be 18 expected near other nuclear reactors besides Harris), I have no I 19 doubt that -- in a real radiological emergency -- emergency 20 workers generally (including adult school bus drivers) would 21 perform their assigned functions.

22 Q.22 How can emergency workers be made aware of their re-23 sponse roles, and be provided with information to ensure their i

24 performance in an emergency?  ;

25 26 C) .

i 5

e 1 A.22 (DSM): Emergency worker role performance is ensured 2 by training. Training provides the context for those individ-3 uals to preplan activities that allow them to implement their 4 emergency roles, such as providing back-up and supplementary 5 options for continuing family responsibility.

6 In particular:

7 (1) Training gives the emergency worker a clear understanding of what is expect-8 ed of him or her -- of what his or her emergency role is.

9 (2) Training makes the worker aware of the 10 advantages of making family contingen-cy plans in advance of an emergency.

11 (3) Training makes the worker aware that 12 the community and the emergency worker's co-workers depend on him or 13 her.

' y 14 (4) Training informs the wor,ker about the -

s_- nature of the radiation risk.

15 Q.23 Are the adult bus drivers who would assist with 16 school evacuation receiving such training?

17 A.23 (JFM): Like all emergency workers, all bus drivers 18 who would assist with school evacuation are being trained. In 19 fact, back up bus drivers are being trained, to ensure a ready 20 supply of substitute drivers should a designated driver be 21 unavailable for any reason at the time of an emergency.

22 The training provided to each emergency worker includes, 23 i at a minimum, (a) training on basic radiation concepts, (b) an 24 overview of the offsite emergency plen, and (c) training on the i 25

'~s 26 I

G L

5 i

1 individual worker's specific role in the plan. The training

~'

2 program also emphasizes to workers the importance of 3 pre-planning and discussing with their families their roles as 4 emergency workers and the actions to be taken by the family in 5 an emergency. The training for bus drivers will be completed 6 by the time of fuel load at the Harris plant. Refresher 7 training is offered on an annual basis.

8 Q.24 Dr. Mileti, please summarise your testimony.

9 A.24 (DSM): A large body of historical evidence shows 10 that the functioning of emergency organizations is not hampered 11 by failure of emergency workers to perform their jobs. In 12 spite of role strain, such workers perform effectively. More-13 over, traihing for emergency work can reduce role strain and 14 enhance the effective performance of emergency workers. While~

V 15 role abandonment may be theoretically possible, it is certainly 16 extremely rare, and consequently it does not reduce organica-17 tional effectiveness. Indeed, the typical problem,in 18 emergencies is not that too few workers report for duty, but 19 rather that too many persons volunteer.

20 Q.25 Mr. Myers, how does the experience of the State of 21 North Carolina compare to Dr. Mileti's observations?

22 A.25 (JFM): North Carolina emergency workers are on 23 record as performing their assigned functions in the face of 24 imminent life-threatening situations, such as the tornadoes in 25 March 1984, Hurricane Diana in September 1984, and the forest 7- 26 i )

~'

1

i, l

9 s 1 fires which occurred across the State in the Spring of this 2 year.

3 A specific illustration of this responsiveness is the 4 April 10, 1984 evacuation of Marshville, North Carolina, neces-l 5 sitated by the derailment of several railcars carrying 6 methanol. One of the derailed tank cars broke open, and a fire 7 started. Emergency officials -- concerned about the fire, the 8 threat of explosion, and the toxic properties of methanol --

9 made the decision to evacuate the Town of Marshville (including 10 the two schools then in session). Adult bus drivers, from the 11 school staff, were utilized to evacuate all of the students 12 from the two schools. The evacuation was completed within a 13 matter of minutes. A number of the school staff had family

(} 14 15 living in Marshville, within the evacuated area. Nevertheless, none of the bus drivers refused to undertake the assigned du-16 ties in this emergency'.

17 In short,-historical experience with State and local emer-18 gency workers, as well as the training being provided to all 19 bus drivers assisting with school evacuation, provide confi-20 dence that the adult bus drivers will respond in the event of 21 an emergency at the Harris plant, and will perform their as-22 signed function -- evacuating the students from the schools 23 within the EPZ.

24 25 l

l /- 26

\w))

l o l CAPABILITY PROFILE -

O JOSEPH F. MYERS EDUCATION i 1967 Graduated - Swain County High School Bryson City, North Carolina 1967 University of Tennessee Knoxville, Tennessee Department of Education -

1968 - 1971 Western Carolina University Cullowhee, North Carolina Graduated - B.S. Education Major Course Work: Socia 1 Studies 1975 Winthrop College Rock Hill, South Carolina Emergency Management Career Development Santa Barbara University

  • Santa Barbara, California HONORS. AWARDS AND FELLOWSHIPS RECEIVED 1966 Football Scholarship - Western Carolina University 1968 - 1971 North Carolina Vocational Rehabilitation Grant Western Carolina University ,

SPECIAL QUALIFICATIONS AND SKILLS Publication: Operational Guide For Fixed Nuclear Facility Accident (McGuire Nuclear Station). (A handbook for elected and appointed officials and key emergency personnel) '

Publication: " State Emergency Response Team Overview" (Handout)

Extensive Public Soeaking: TV; Radio; County and City elected officials; Educators; Emergency Service personnel; Health Service personnel; Law Enforcement personnel O

e

.o 4

EMPLOYMENT JOB TITLE Jan.1985 - Present Director:

North Carolina Division of Emergency Management Department of Crime Control and Public Safety Raleigh, North Carolina Duties and Resoonsibilities:

Itesponsible for the State of North Carolina emergency response and planning. This includes the coordination of all emergency response activities of 17 state agencies. '

I serve as the State Coordinating Officer and the Governor's Authorized Representative in all disaster related matters. In emergencies,I serve as leader of the State Emergency Response Team. I have coordinated the State's response to over 100 emergencies while in my current position as Director of the Division of Emergency Management. In addition, I have supported DEM staff on location in responding to statewide emergencies such as the forest fires which occurred across the state in the spring of this year.

As Director of DEM, I have been involved in the development of the offsite emergency capability for the Shearon Harris Nuclear Power Plant, as well as the Catawba, McGuire and Brunswick nuclear plants. Since February 1985, I have had overall authority for emergency preparedness activities concerning the Harris plant. *

( 1976 - Jan.1985 Area Coordinator:

North Carohna Division of Emergency Management Department of Crime Control and Public Safety Raleigh, North Carolina Duties and Resoonsibilities Responsible for assisting 20 North Carolina counties in developing a Comprehensive Emergency Management (CEM) Program. I assisted counties in developing and providing technical information in emergency planning, preparedness and response. Assisted counties and state agencies in maintaining a state of readiness to support any emergency operation. Provided assistance to local government and state regional agencies in developing plans and exercises in support of Radiological Emergency Preparedness.

Provided assistance in the development and amending of local government and state regional plans for responding to hazardous materialincidents. ,

I served as the on-scene coordinator of state regional response to a variety of emergency situations, predominantly within my 20-county area. However, I was subject to respond to any emergency situation within the state that was beyond the capability of one area.

Once at the scene, I represented the State Emergency Response Team and served as an on-site evaluator for the State making operational recommendations and serving as a liaison between local government and State government. For example: During a

I e

Presidential declared natural disaster, a fixed nuclear facility ir.ident, or a major chemical fire, the State Emergency Response Team serves as the Governor's on-site field O staff.

In su[nmary, my job encompassed the full spectrum of developing Comprehensive Emergency Management (Mitigation-Preparedness-Response-Recovery) at the locallevel and integrating it into the existing elements of government; i.e. emergency planning, communications, fire, medical end environmental health. At the area level, more emphasis is placed on preparedness and response activities. Preparedness activities constitute developing and/or maintaining 20 county Disaster Relief & Assistance Plans (all hazard), including hazardous material response plans, fixed nuclear faculty plans and Nuclear Civil Protection Plans. Training activities include developing and/or coordinating Shelter Manager Courses, Damage Assessment Courses, radiological Monitoring Courses, Field Exercises with Hazardous Material Scenarios and Public Officials Conferences. Response activities are usually of the hazardous material nature (alt-water-solid & hazardous waste), caused by fire, spills or contamination.

Accomolishments PUBLICATION (1980) -Developed Handbook for elected officials and .

emergency workers in response to an accident at the McGuire Nuclear Station Author of " SERT Overview" Handout (1980)

Appreciation Award (Speaker)

( Lincoln County Kiwanis Club

Subject:

" Protection in the Nuclear Age" (1979)

East Gaston County Rotary Club -(Speaker - 1980)

Subject:

" North Carolina Response to an Incident at the McGuire Nuclear Station" WBTV Channel 3 - Charlotte, North Carolina " Top of the Day" Show (Speaker)

Subject:

" North Carolina Response to an Incident at the McGuire Nuclear 4 Station" WAYS Radio - Charlotte, North Carolina

Subject:

" Fixed Nuclear Facility Planning" WSOC Radio - Charlotte, North Carolina

Subject:

" Fixed Nuclear Facility Planning" ,

WTVI Channel 42 - Charlotte, North Carolina Live debate on " Survival of Nuclear War" with State Department Officials WBTV Channel 3 - Charlotte, North Caolina "First Edition" Show

Subject:

" North Carolina Response to an Incident at the McGuire Nuclear Station" O

~

Coordinated the planning and implementation of county response plans to an incident at the McGuire Nuclear Station. This involved six North Carolina counties O and is onsidered one of the first offieiai Perationai Pians refieetinE the new regulations established by the Federal Emergency Management Agency and the Nuclear Regulatory Commission in 1980.

Coordinated the planning and implementation of county response plans to an incident at the Catawba Nuclear Station. This involved five North Carolina counties in 1984.

Coordinated a Fixed Nuclear Faculty Disaster Exercise. This exercise involved the actual notification, evacuation, sheltering and feeding of approximately 400 citizens due to an incident at the McGuire Nuclear Station. This exercise involved hundreds of Federal, State, local and private-sector resources.

Duke Power Company's Response to an Incident at the McGuire Nuclear Station Workshop - (Speaker - 1980)

Subject:

"The Role of North Carolina to an Incident at the McGuire Nuclear Station" Table Top Conferences for counties within a 10-mile radius of the McGuire Nuclear Station - (Speaker - 1980) ,

Worked on emergency planning for the Shearon Harris Nuclear Power Plant

[ Appreciation Award (Instructor)

N.C. Justice Academy *

Subject:

" Role of the Law Enforcement Officer in an Emergency Management Program"(1977)

International Conference of Police Chaplains - (Speaker - 1981)

Columbia, South Carolina

Subject:

" Developing a County Disaster Program" School Emergency Planning & Currieulum Development Conference (K-12)

Western Carolina University, Cullowhee, North Carolina 4 (Developed and conducted In-Service Training for County Principals &

Teachers)

Assisted in the disaster relief and recovery efforts between Federal, State and 16 North Carolina counties due to a Presidential declared disaster caused by flash flooding (1977 - 1978).

Assisted in the disaster relief and recovery efforts between Federal, State and 14 counties due to a Presidential declared disaster due to tornadoes and hurricanes in 1984.

Phase !! " Developing a Civil Preparedness Program"-(Speaker - 1978)

Appalachian State University, Boone, North Carolina

Subject:

"The Federal Audit System involving Civu Preparedness Funds &

Program" O

o Basic Sem'inar for New County Emergency Management Coordinators (Moderator and Chief Instructor)

(Vl Asheville, NC Conferences for Business & Industry (Speaker)

Subject:

"The Role of the Private Sector in a Comprehensive Emergency Management Program" Damage Assessment Workshops -(Speaker - 1978 - 1984)

(Spoke throughout 20 counties in North Carolina)

Subject:

" Systematic Methods of Compiling Damage Assessment Data in Order to Obtain Federal Assistance After a Disaster Incident" Shelter Management Workshops -(Speaker - 1977 - 1984)

(Spoke throughout 20 counties in North Carolina)

Subject:

" Shelter Organization, Staffing and Activation" Conferences for Elected Officials -(1980 - 1984)

(Conducted private session with county elected officials concerning the development of a county Comprehensive Emergency Management Program.)

Completed " Managing the Search Function Course and Instructors Workshop" (1984).

Table Top Workshops for 20 counties within North Carolina concerning local

. government's response to a disaster situation. .

O Deveieeee aad instreeted nazardous Materia 1 ResPons. Workshops taat refleet NorIn Carolina's integrated approach to hazardous material incident notification and on-scene coordination. These workshops were conducted for State and county emergency personnel (Fire & Health)in 1983.

North Carolina Association of Emergency Management Coordinator - (Speaker -

1978)

Subject:

" Federal Audit System" i

Coordinated the testing of 19 North Carolina counties' Emergency Operations Plans for War in a FEMA-sponsored simulated wartime exercise (1978).

l Completed General Administrative Training Program - 1981 Completed Phase II " Developing a Civil Preparedness Program"- 1977 Sponsored by the Defense Civil Preparedness Agency

! University of North Carolina - Charlotte, North Carolina ,

t Attended Plans & Operations Workshop - 1977 & 1982

~

N. C. Division of Emergency Management

, Attended Hazardous Materia 1 Seminar - 1976 & 1984 Southern Railroad, Inc. - Charlotte, North Carolina 0

(

. . _ _ _ _ _ . . _ . _ . - _ ._ _ ~ _ . _ _ _ --- _ __ . __

Completed Radiological Emergency Response Operations (RERO) School- 1979 o Sponsored by the Nuclear Regulatory Commission V Las Vegas, Nevada

~

Attended Disaster Relief & Assistance Workshop- 1975 & 1983

Sponsored by Federal Disaster Assistance Administration

Raleigh, North Carolina Attended North Carolina Association of Broadcasters Workshop - 1978  :

Raleigh, North Carolina

Subject:

" Emergency Broadcast System" >

National Fire Incident Reporting System (NFIRS) quallfled - 1981 Recipient of Col. William A. Thompson Award for Outstanding Achievement in Emergency Management in 1984. This award was presented by the North Carolina Emergency Management Association.

1975 - 1976 Training and Education Specialist:

North Carohna Division of Emergency Management *

, Department of Crime Control and Pub!!c Safety Raleigh, North Carolina Duties and Responsibilities

! As a Training and Education Specialist, I was involved with the following.

1) Developing and conducting various training programs for State and local governments and the elements of the private sector that would support emergency or disaster operations.
2) Assisted in the planning, implementing and field testing of school comprehensive disaster plans.

l 3) Assisted in the planning, implementing and field testing of a comprehensive emergency management program into the existing school curriculum (Grades K-12), in conjunction with the North Carolina Department of Public Instruction.

Accomplishments i

Recipient - North Carolina Long Leaf Pine Award * .

Completed Phase ! " Role of the Coordinator"- 1975 Sponsored by the Defense Civil Preparedness Agency Winthrop College, Rock Hill, South Carolina O

l .

t

e Comprehensive Schoo1 Emergency Plan Workshop -(Speaker - 1975) "

Person County Cabarrus County-Haywood County 1973 - 1975 Teacher - Coach:

Swain County High School Swain County Board of Education Bryson City, North Carolina Duties and Resoonsibilities While employed at Swain County High School, I taught five (5) daily classes of Social Studies and one (1) class of Physical Education. I also served as an athletic coach for the following:

1) Assistant Football
2) Assistant Baseball
3) Head Girls and Varsity Boys Basketball 1971 - 1973 Teacher - Coach:

Cherokee High School Bureau of Indian Affairs U. S. Department of Interior o -

Dut!es and Responsibilities Cherokee, North Carolina While employed as a teacher at Cherokee High School, I taught one (1) daily class (

of Psychology and was subject to teach any class for any instructor within the total school curriculum offered. I also served as a coach for the following:

1) Assistant Football
2) Assistant Softball ,
3) Head Varsity Girls Basketball
4) Head Junior Varsity Girls Basketball Accomolishments Won Conference Championship (Varsity Girls Basketball)

Recipient of Service Award Steve Youngdeer Post, NC VFW Cherokee, North Carolina l

0

[

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t 1968 - 1971 Coach:

g Cherokee High School Bureau of Indian Affairs U. S. Department of Interior Cherokee, North Carolina Duties and Responsibilities My employment was part-time, and I served as a coach for the following:

1) Assistant Football
2) Assistant Softball *
3) Head Girls Varsity Basketball
4) Head Girls Junior Varsity Basketball Personal Date of Birth: June 1,1949 Age: 35 Marital Status: Married Height: 5' 9" Weight: 170 -

Civic Club - Organizations North Carollry Jayeees -

Lincoln County Kiwanis Club North Carolina Emergency Management Association of Coordinators O State Employees Association North Carolina Association of Educators G

O f

' s,

- ACADEMIC VITA 0F DENNIS S. MILETI (j May, 1985 PERSONAL offten:

Department of Sociology Hazards Assessment Laboratory Colorado State University Aylesworth Hall Fort Collins, Colorado 80523 Colorado State University (303)491-5951 or 6045 Fort Collins, Colorado 80523 lic:t 1120 Monaco Parkway, Denver, Colorado 80220 (303)355-3031 EDtrATION University of Colorado, Boulder: PhD, Sociology, 1974 California State University, Los Angeles: MA, Sociology, 1971 University of California, Los Angeles: BA, Sociology, 1968 SPECIALI?ATIONS Complex Organizations, Applied (Hazards and Policy), Methods APPOINTuENTS 1974-date Faculty, Department of Sociology, Colorado State Uni-versity, Fort Collins (1985-date, Professor; 1978-1985, Associate Professor; 1974-1978, Assistant Professor),

1984-date IJ1 rector, Hazards As.essment Laboratory, Colorado State Volversity, Fort Collins.

1981-year Policy Analyst, Seismic Safety Commission, State of

( )* California, Sacramento (on leave from university).

V 1978-1979 Invited Insfructor, American Association for the Advan-coment of Science, Chautauqua Short Course Program.

1975-year Visiting Assistant Professor, University of Southern Cal ifo rnia, Graduate School of Public Acministration, Intensive Seminar P-ogram.

1971-1972 Instructor, Department of Sociology, University of Colorado, Boulder.

AWAPOS 1983-1984 Alumni Honor Faculty Award, Colorado State University Alumni Association for excellence in teaching, research and service 1981-year Cited in Outstanding Young Men of America 1978-1977 Cited for excel.lence in teaching, research and service by the Dean, College of Arts, Humanities and Social Sciences MEMBERSHIPS American Sociological Association, International Sociological Assocta-tion, Pacific Sociological Association, Midwest Sociological Society, American Association for the Advancement of Science, Earthquake Engi-neering Research Institute, Western Social Science Association, Natio-nal Coordinating Council on Emergency Management, Sigma XI.

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RESEARCH GRANTS M O, CONTRACTS

/G 1984-1985 Principal Investigator, " Assessment of Human Stress b Impacts from the Livingston Train Derailment and Chemi-cal Emergency," contract for Illinois Central Gulf Railroad.

1984-date Associate Investigator, " State-of-the-Art Assessment:

Evacuation," subcontract from Oak Ridge National Lab-oratories for the Federal Emergency Management Agency.

1984-date Associate Investigator, " International Study of Disas-ter Impact on Domestic Assets," subcontract from the University of Georgia for the National Science Founda-tion.

. 1983-1984 Principal Investigator, "Research and Applications for Emergency Preparedness," contract for Long Island Lig-hting Company, 1983-1984 Principal Investigator, " Intended and Forgotten Audien-ces for Emergency Warnings," quick-response grant from the Natural Hazards Research Applications and Informa-tion Center.

1982-1983 Associate Investigator, " Organizational Interface for Nuclear Reactor Emergency Preparedness," subcontract f rom Oak Ridge National Laboratories for the Nuclear Regulatory Commission.

1981-year Principal Investigator, " Nuclear Hazard Warnings and Emergency Evacuation Preparedness," contract for Pact-fic Gas and Electric Company.

l . 1980-1983 Principal Investigator, " Local Land Use Policy Doci-l p

  • stors," Colorado State University Experiment Station.

V 1979-1982 Priicipal Investigator, " Behavioral Aspects of the Three Mile Island Incident and Re-start," contract for l General Public Utilities via Shaw, Pittman, Potts and l Trowb ridge. ,

l 1977-1980 Principal Investigator, " Migration Impacts of Non-l metropolitan Areas in the West," Colorado State Univer-I sity Experiment Station.

1977-1979 Principal Investigator, " Adoption and Organizational Implementation of Policy for Land Use Regulations,"

grant from the National Science Foundation.

l 1975-1977 Coprincipal Investigator, Socioeconomic, Organizational l

and Political Consequences of Earthquake Prediction,"

grant from the National Science Foundation.

1972-1974 Research Sociologist, " Assessment of Research on Natu-ral Hazards," grant from the National Science Founda-tion.

couv1TTEE MEYBERSHIDS 1984-1987 National Academy of Science, National Research Council, Commission on Engineering and Technical Systems, Ccm-mittee on Natural Disasters.

1984-1986 National Academy of Sciences, National Research Coun-cil, Commission on Physical Sciences, Mathematics, and Resources, Board on Earth Sciences, Subcommittee on Earthquake Research.

O$ 1984-date National Institute of Mental Health, Public Health Service, Center for Mental Health Studies of Emergen-

cies, Advisory.

(] 1983-year National Science Foundation, U.S. Delegate on Ear-thquake Prediction Research to Japan, International Scientific Exchange Section.

1983-date Front Range Consortium on Natural Hazards Studies,  !

Colorado State University, University of Colorado, "

University of Denver.

1983-date International Sociological Association, Research Com-mittee on Disasters.

1982-1983 Pacific Sociological Association, Nominations Committee for the Standing Committees for 1983.

1982-date Earthquake Engineering Research Institute, Chair, Com- l mittee on Social Science Research, Serkeley. '

1981-1983 U.S. Department of the Interior, Geological Survey, >

Advisory Panel on the Earthquake Studies Program.

1981-1982 Pacific Sociological Association, Program Committee for the 1982 Annual Meetings in San Otego.

1981-1982 Governor's Emergency Task Force on Earthquakes, Threat and Reconstruction Committees, State of California, Sacremento.

1980-1981 Governor's Science and Technology Advisory Council, Committee 'on the Relocation of Uranium Mill Tallings, State of Colorado.  ;

1979-year American Association for the Advancement of Science, ,

Committee on Intergovernmental Research and Development on Fire Safety and Disaster Preparedness, Washington.

0.C.

^ 1976-1978 National Academy of Sciences, National Research Coun-cil, Commission on Sociotechnical Systems, Committee on Socioeconomic Ef f ects of Earthquake Prediction, Wash-ington, D.C.

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PU9tTCATIONS U Emil A M Monograehs (refereed)

Mileti, Dennis S.  :

Iha OrJ11r g Chaos .in Disasters (in progress).

Milett, Dennis S., John Schneider and D. Stanley Eitzen Graduate Research Nethods g 2g Social Sciences (in progress).

Gillespie, David F., and Dennis S. M11eti 1979 Technostructures Ag Interorcan f rational Relations. Lexington, Massachusetts: Lexington Books.

Gillespie, David F., Dennis S. Milett and Ronald Perry

1976 Organicational Reseense a chancing cemmunity syste-s Kent, Ohio:

Kent State University Press.

Charters (invited and refereed)

Milett, Dennis S.

1986 "Research methods and disaster research." In Russell R. Dynes and Carlo Polanda (Eds.). seef ologv_ g Disasterse Contributiens d sociologv M Disaster Research. Italy: Franco Angeli (forth-coming).

Milett, Dennis S., and John H. Sorensen 1985 "Why people take precautions against natural hazards." In Neil Weinstein (Ed.). Encouraging Sel f-Protection Behavior (forth=

coming).

Sorensen, John H. and Dennis S. Mileti -

Q V

1985 " Protective actions for natural hazards: a reiview of programs to stimulate public adoption." In Neil Weinstein. (Ed.). Enceuraging Sel f-Prote lha 9ehavier (forthcomirg).

Hartrough, Donald M., and Dennis S. Milett 1985 "The media in Disasters." Pp. 282-294 in J. Laube and S. Murphy (Ed s.), Preseectives & Disaster Recoverv. Norwalk, Connecticut:

Appleton-Centu ry-Crof ts.

Hutton, Janice, Dennis S. Milett and John forensen 1984 " Factors affecting earthquake warning system effectiveness." Pp. <

947-956 in K. Oshida (Ed.), Eartheueke Predictien. Tokyo: Terra Scientific Publishers for UNESCO.

2 Milett, Dennis S., Janice Hutton and John forensen 1984 " Social f actors af fecting the response of groups to earthquake prediction." Pp. 649-658 in K. Op f da (Ed.), Eartheuake Predie-

.t.ica. Tokyo: Terra Scientific Fublishers for UNESCO.

Sorensen, John, Janice Hutton and Cennis S. Mileti 1984 " Institutional management of risk information following ear-thquake predictions." Pp. 913-924 in F. Oshida (Ed.), Eartheuake Prediction. Tokyo: Terra Scientific Publishers for UNESCO.

Hutton, Janice, John Sorensen and Dennis S. Nileti 1981 " Earthquake prediction and public reaction." Pp. 129-166 in T.

Rikitake (Ed.). current Research ,in Eartheuake Prediction. Bos-ton: Reidel Publishirg Company, Tokyo: Center for Academic Puc11-cations.

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e M11sti, Dennis S.

1981 " Planning initiatives for seismic hazard mitigation." Pp. 44-53 in J. Isenberg (Ed.). social Anf., Eeenen t e Imo act af. Ea rt heu ak es

, m utility L.if e l i nes. New York: American Society of Civil Engi-neers.

Monograohs Agui chanters (quasi-refereed)

Milett, Dennis S., and Joanne Nigg 1985 " Social science earthquake investigations." In Roger Scholl (Ed.). Les sons Lea rned J.r.Qm Recent Ea rtheu akes. Berkel ey: Ear-thquake Engineering Research Institute (forthcoming).

Review Panel of the National Earthquake Hazards Peduction Plan 1984 Natienal Ea-theuake Hazards Reduction pregra-, f_1.Y.a X.sAr. Preg"am P_1.An. Washington, D.C.: Federal Emergency Management Agency.

Sorensen, J., E. Copenhaver, D. Milett and N. Adler 1984 Organizational Interf ace .ig Reacter E-ergenev Pl anning Ag1 h ponte. Washington, D.C.: U.S. Nucl ear Regul atory Commission, i

NUREG No. CR-3524

! Milett, Dennis S.

{ 1982 "A bibliegraphy for graduate research methods." Pp. 249-255 in Russel Schutt, Alan Orenstein and Theodore C. Wagenaar (Eds.).

Research Metheds cou rses! Sg,1,h A s s i e nme n t s AIU1 P ro f eeta. .

Washington, D.C.: American Sociological Associat. ion.

Milett, Dennis S., Janice Hutton and John Sorensen 1981 Ea rtheuak.. E:.;.:1.< ct io n Per een s e AIui cet i e n s f g.c Pub 1 ie Po l f ev.

S Boulder: I *.titute of Behavioral Science, Monogfaph ,28.

Santopolo, Frank, ana Dennis S. Mileti 1980 Maets af, Pecul atien Grewth .in Accicultural colorado committees.

Fort Collins: Cclorado State University Egeriment Station Bulle-tin.

Committee on Fire Safety and Disaster Preparedness 1979 f_tr.1 !afetv An:1 Disaster Precaredness. Washington, D.C.: American Asscciation for the Advancement of Science.

Committee on Sociceconomic Effects of Earthquake Prediction 1978 A Pregram sf, stueien an gg socieeeene=<e Ef f ects sf, Eartheu o.

l Prediction. Washington, D.C.: National Academie of Sciences- ,

National Pescarch Council. l Milett, Dennis, S., thonas E. Orabek and J. Eugene Haas 1975 timr.Ag Systems ,in Extreme En v i renmentir A sociological Perneec-lix.t. Boulder: Institute of Behavioral Science, Monograph 21.

M11ett, Dennis S. .

1975 Natural Hazard Warning !vnte-s .i.n iht united States. Boulder:

Institute of Behavioral Science, Monograph 12. Portions reprin-ted in Joseph Perry and Meredith Pugh, falleettve Behavior, Reseense la stressa 1978.

Erickson, Neil, John Sorersen and Dennis S. Milett 1975 Landslide Mazards .in itt united statest A Essearch Assess-ent.

Bculder: Instituto cf Behavicral Science.

Milett, Dennis S.

1975 Disaster Relief and R+ habilitation .in lag united States. Boulder:

, Institute of Behavioral Science.

C Ayre, Robert, Cennis S. Milett and Patricia Trainer 1975 Eart*cuake Ana 1' sum-1 Harares ,ig Ing united states' A Research i Assent-ent. Boulcer: Institute of Behavioral Science.

5

m Jeurnal Articlos e Discioline Focus (refereed)

Milett, Dennis S., and David F. Gillespie 1985 "The effects of legitimacy on goal change and formalization in organizations," Journal sf centweerarv socioloev (accepted and forthcoming).

Milett, Dennis S.

1985 "The human equation in earthquake prediction and warning," Poliev Studies Review (accepted and forthecming).

Mileti, Dennis S., Donald Hartsough, Patti Madson and Pick Hufnagel 1984 "The Three Mile Island incident a study of behavioral indicators of human stress." P.,Aga bergencies Ad Disasters 2(1):89-11a.

Milett,* Dennis S.

1983 " Societal comparisons of organizational response to earthquake prediction: J a p a n v s t h e lln i t e d S t a t e s." Eas.s, E m e ro e n c i e s And, Disasters 1(3):399-414.

Gillespie, David F., and Dennis S. Milett 1982 "Otfferentiation in organizations," Social Forces 60(4):1172-1175.

Milett, Dennis S.

1982 " Structure and process in the irrplementatien of pubi te policy,"

Political Science Review 21(1):1-34 Mileti, Dennis S. -

1982 "A review of research on pubi te policy adoption," PuBlie Admints-tratien Review (accepted and forthcoming).

Milett, Dennis S., Doug Timmer and David F. Gilles;:te G 1982 " Intra and interorganizational determinarts of cecentralizatten,"

Q Paeffic Sociological Review 2S(2):163-183.

Milett, Dennis S., David F. Gillespie and Stan Eitzen 1981 "The multidianensionality of organizatienal size," Ecciologv an social Renaarch 6S(4):400-414 Gillespie, David F., and Dennis S. Milett '

1981 "Heterogenecus samples in organizational research," !ccioleeical Metheds AM Research 9(3):327-388.

Mileti, Dennis S.

1980 " Human adjustment to the risk of environmental extremes," Socio-

,1.c;y,A g social Research (4(3):327-347.

Gillespie, David F., and Dennis S. Milett 1980 " Determinants of planning in organizations," Aeintstrative Is.i ,

inca Rev f ew 10(3):21-32.

Mileti, Dennis S., and David F. Gillespie 1980 " Organizational and techno1cgical intercepenceretes," feurnal af, centeveersev feef oleev 17(3-4):132-158.

Gillespie, David F., Penald Perry and Dennis S. Milett 1980 " Stress and transformation," Jeu rnal af, seei ni Rercarch 21(2):139-147.

Milett, Dennis S., David F. Gillespie and Stan Ettzen 1979 " Structure and decision making in corprate organizattnns," fecie-1n33, AM Seef s1 Research 63(4):723-744 Gillespie, David F., anc Dennis S. Milett 1979 " Action and contingency postulates in organizatten-environment rel at ions," 11ran Rel at tens 32(3):261-271.

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I Milett, Dennis S., David F. Gillespie and Elizabeth Morrissey

! O V 1978 " Technology and organizations methodological deficiencies and lucunae," Technology g culture 19(1):83-92.

Gillespie, David F., and Dennis S. Milett

( 1976 " Organizational technology and environment adaptation-manipula-

tion," Ecettish Journal d Socioleev 2(2)
205-219.

, Milett, Dennis S., David F. Gillespie and J. Eugene Haas 1977 " Size and structure in complex organizations," Social Forces 56(1):208-217.

Gillespie, David F., and Cennis S. Mileti 1977 " Technology and the study of organizations: an overv tew and j

appraisal," Mademv d Management Rev iew 2(1):6-19. Reprinted in Readings an dcx Manacers Manage. Englewood Clif fs, New Jersey:

Prentice Hall,1982.

Mileti, Dennis S., and David F. Gillespie .

1976 "An integrated formalization of organization-environment interde-pendencies," human Rel ations 29(1):80-100.

i Gillespie David F., and Dennis S. Mileti -

1976 " Organizational adaptations to changing cultural contingencies,"

Seefologien1 Incu i rv 46(2):135-141.

Gillespie, David F., Roy Lotz, Dennis S. Milett and Ronald Perry 1976 " Historical and paradigmatic differences in the use of the goal Concept," Inteanational Review g Histerv g Political Science 8(30):1-14. .

Gillespie, David F., and Dennis S. Mileti 1976 "A refined model of different14 tion in organizations," Seefologv G

d social Research 60(3):263-278.

Perry, Ronald, David F. Gillespie, Roy Lotz and Dennis S. Milett a 1976 " Attitudinal variables as estimates of behavior," Eurocean hgr ,

ngl g Social Psvcholeev 6(1):74-90.

Mileti, Dennis S., Ronald Perry ano David F. Gillespie 1975 "The analytical use of case study materials in the study of organizations," Sociological Incuirv 45(4):72-50.

Milett, Dennis S., and Elwood M. Beck 1975 " Explaining evacuation symbolically: communication in crisis,"

Coc?unication Research 2(1):24-49.

Gillespie. David F., Ronald Perry, Dennis S. Milett and Roy Lotz 1975 " Organizational tensions and decentralizations the interactive ef fect on member committrent," International Journal d Group

  • Tensions 5(2):26-37.

Perry, Ronald, David F. Gillespie and Dennis S. Mileti 1974 " Collective stress and comunity transformation," human Relatiens 27(8):767-788.

Milett, Dennis S.

1974 "Chan;e ratics in age-specific percent centriductions to fertil-ity: a new method with applications to the L*nited States," PJLc.- -

.lf.in Sociologic.11 Etx.111 17(1):3-26. First Prize, student paper competition, Pacific Sociological Associetien, 1974 Mileti, Dennis S., and David F. G111espio 1974 "An integrative approach to the r,tudy of organizational technel-ogy, structure and behaviere" Cur-ent feefologv 23(1):189-200.

Gillespie, David F., and Dennis S. M11eti 1974 " System stress and the persistence of emergent organizations,"

socieleafeil Incuirv 44(2):111-119.

7

Mileti, Dennis S., and Larry Barnett f].

A 1972 "Nine demographic factors and their relationship toward abortion legalization," Social Biologv 19(2):43-50.

Journal Articlose Aeolied EACEL (refereed)

Milett, Dennis S.

1984 " Role conflict and abandonment in emergency workers," Emergenev Manacement Review 2(1):20-22.

Mileti, Dennis S.

1984 " Earthquakes and human behavior," Eartheuake Seeetra 1(1):89-106.

Mileti, Dennis S.

1983 "Public perceptiens of seismic hazards and critical f acilities,"

Bulletic d ,thg Seitmnlogical Societv af America 72(6)l3-18.

elett, Dennis S., and Patricia Harvey 1978 " Correcting for the human f tetor in tornedo warnings," Disaster Precaredness 2(Feb ruary):5-9.

Haas, J. Eugene, and Dennis S. M11ett .

1977 "Sociceconomic and political consequences of earthquake predic-tion," Journal g ng Pbvsical M 25(4):283-293.

Haas, J. Eugene, and Dennis S. Milett 1977 " Earthquake predicticn and its consequences," california Geolog 30(7):147-157, 1977. Revised and reprinted in IAn Francisco 20(4):60-68, 1978.

Haas, J. Eugene, and Dennis S. Mileti ,

1976 " Earthquake prediction and other adjustments to earthquakes,"

Bulletin d ,thg Egg Zeal and Society fgr, Eartheunke Engfeeering 9(4):183-194.

SQQk Reviews (invited and refereed)

Mileti, Dennis S.

1984 "A review of Social and Economic Aspects of Earthquakes by Bar-clay G. Jones and Miha Tcrazevic (Eds.). Ithaca: Progran in Urban and Regional Studies,1983." MA 1 Emergencies Ami Disasters (for-thcoming).

Milett, Dennis S.

1982 "A review of Unequal Care: Intoror0anizational Relations in Health Care by M. Milner, J r. New York: Columbia University Press,1980." Social Forces 60(3):943-944 Milett, Dennis S.

1982 "A review of Fhistle B1cwirg: Loyalty and Dissont in the Corpora-tion by Alan Westin (Ed.). New York: McG raw-Hi l l, 1981." Soe f oi-ngxt. A Rev iew 21 Hax Ea2117(2).

Milett, Dennis S.

1980 "A review of Aftermath: Communttles After Natural Disasters by H.

Paul Friesema et al. Beverly Hills: Sage Publications,1979 and Af ter the Clean-up: Long Range Effects of Natural Of sasters by Jan.es Wright and Peter Rossi et al. Eeverly Hills: Sage Publica-tions, 1979." Journal g gg American Pl anning Anneciatien (Oc-tober):404-485.

M11ett, Dennis S.

O 1976 "A review of A !cciology of Organizations by J. Elcrid2e and A.

Cromb ie. New York: International Publications, 1975." contemee-IAry. Sociologv 5(6):784 8

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s Tee nical'Reco Ms (not' refereed) o _

MiletiJDennis S.

1985 Lt.Lu Impx u,1.1 A Yechne.fgical Emercench An Unc5trusive ljsil.hte.:.1.S.tcts. nf. L i v i ngs+2n Tra i n D e ra f 1 rent. New Orl ean s :

Lemle, telleher. ~ '

Mileti, De:iMs S.

1983 B:.una Eesconse se naciost LAr. Enfe'ecement Acolications and Media Imoligations; .Sacran, ento: Californ K Division of Mines and Geol-

, ogy. s Miletf(Dennis S. '

1962 Organizational g(havior and Inid.2 dan 4retional Relationg;; Incl i-cations ic.t &cl ea r Cower Pl ant Emerce~ciu Ana Preca reness.

. 0ak P.idge, Tennusse9: Oak P.1dge Nationel Laboratories. '

Milet!, Donnis 5., Donald M. Hartsough an'd Patti Medsori-1982, rha Ihr.ta lii.l.g Is1 and Incident A Study of Behavioral Indicators 4

p.,1 Hu m a n .$.tc2.2. W a s h i ng tori, D.C.: Shaw, Pittman, Potts and Trowbridge. 0 ,

Mileti, Dennis S., and Arthur Svenson 1981 f,a rthc/ ak e Ered iction-Wa rn ing (escento Eat Emercency Orcaniza-tiens %21hg Pr dictico Teminologv. Vnn Nuys: Southern Califor-nia: Earthquake Preparedness s'roject.

Hutton, Jahied, 'and Dennis S. Mileti 1979 An a l ys i s af Adoo t i o n d 1C72223*M'n 21 Commu n i tv Lap.ft Lis g

,s Recul atios.I'I.gn Eloedol ein2 San Franci:;;c: Noodward-Cl yde.

Haas, J. Eugene, and De'r.nis S. Mileti e 1976 Socioecanemic Imoact af Earthcuake Prediction an Government, p Bustrien And Comunity. Sou l der: Institute of Sehavioral Sci-V* ences Milett, Dennis, S., and David F. Gillespie-1976 Interorcanizttional Rel at ions And Cppun f tv Service Geliverv

.S.y.nati. Boul der: Canter for, Acticn Pasearch.

g Egblicatiens .in Preceedingt. (nct refereed '

Milett, DAnn'1s S. '

1980 "Huraan responte to earthqtake prediction." Pp. 36-56 in Walter Hays (Ed.). Prceeech af., the (pnferences na Earthcuaka Predie-thn Information. Menlo Park: U.S. Geological Survey. Paper pre-

- .sented at the January, 1980 Ccnference on Earthquake Prediction

'Information, Los Angeles.

Mileti, Dennis S., and Janice Hutton 1978 " Social aspects of earthqt =k es." Pp. 179-192 in c roceedincs af.

tha Second International Conterenc.g na Pierozonatien. San Fran-cisco: National Science Foundation. Paper' presented at the Novergi'-

ber,1978 Cor.ference on the Strie of the Art in Microzonaticr. for EactEquake Hazards Reduction, San Francisco.

Milett, Denr.is S.

1978 "Sccioeconomic effects of earthquake prediction on state policy."

Pp. in Eraceedings 21 Ita National Conference na Ea rthcu ake -

Rel ated ficant:i. Lexinpon, Kentucky: Council of State Govern-r.1ents. Sprech presentm ei '.N !!cverrter,1977 Conference on State (N Policy for Esrthquake Prediction Technolcgy, Soulder.

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  • Other Published Ccmments (invited or refereed)

O' Milett, Dennis S.

1984 "The character of traffic in an emergency," Bulletin 6(1):4-5.

M11eti, Dennis S.

1983 "Disasterous warnings," Cmni (March):24,44,152.

Mileti, Dennis S.

1982 " Hazards reduction work: the next era," National Hazards Observer 6(4):1-2. Reprinted in Earthcuake Information Bulletin 14(2):60, 1982.

Mileti, Dennis S.

1982 " Sociological aspects of earthquake prediction," Earthcuake Information Bulletin 11(3):102-105.

Haas, J. Eugene, and Dennis S. Mileti 1977 " Earthquake prediction response," .T.ite. (January 24):83.

Mileti, Dennis S.

1977 " Earthquake prediction: is it better not to know?" Mosaic 8(2):8-14.

Mileti, Dennis S.

1977 " Social haza rd s of ea rthqu ak e p rediction," Science Egxs 111(2):20-21.

Haas, J. Eugene, Thomas Drabek and Dennis S. Mileti 1976 " Individual and organizational response to threat," Ejluui. EAercen-s.im.:.1(4):247.

Mileti, Dennis S.

1976 " Social scientists and applied research," .T.ba Am9r'can sociol-ocist 11(a):220-221.

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Mileti, Dennis S.

1974 " Response to research and national needs," Footnotes 2(Octo-ber):6.

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/ PROFESSIONAt PACERS f20.PoEEENTATIONS V] Conference Pacers Mileti, Dennis S., and R. Gary Williams 1985 "A sociological perspe::tive on the siting of hazardous waste facilities," paper presentpd to the Social and Economic Effects of Public Perceptions Session of the Sympostuni on Waste Manage-ment, Tucson: March.

M11ett, Dennis S., Rick Hufnagel and David Gillespie 1984 " Regulation of the firm: toward a theory of consequences," paper presented to the Complex Organizations Session of the American Sociological Association, San Antonio: August.

M11ett, Dennis S.

1984 " Stress from risk uncertainties," invited paper preser.ted to the Social Aspects of Risk Uncertainties Session of the Society for Risk Analysis, Knowxille: October.

Mileti, Dennis S.

1984 " Social and political cbstacles to the use of nonstructural flood loss mitigation measures," paper presented to the Anerican Soci-ety of Civil Er.gineers, San Francisco: October.

Mileti, Dennis S.

1984 "Why people take precautions against natural hazards," paper

. presented to the Conference on Enceuraging Self-Protection Eeha-vior, Rutgers University: July.

Mileti, Dennis S.

1984 " Sociology in litigation: applicatf or s of disaster research,"

h, paper presented to the Sociology of Disasters Session of the Pacific Sociological Association, Seattle: April.

Mileti, Dennis S.

1983 " Social impact and use of earthquake prediction-warnings," paper presented to the US-Japan Seminar on Fractical Approaches to Earthquake Predicticn and Warning, Tokyc: No v err.b er.

Frey, R. Scott, Thomas Dietz, Dennis S. Milett, and Debre Cornelius 1983 " Structural deterruinants of coranrunity adoption of the National Flood Insurance Program," paper presented to the Rural Sociologi-cal Society, Lexington: July.

Mileti, Dennis S., Donald M. Hartsough; Patti Madson and Rick Hufnagel 1983 "The Three Mile Island incident: a study of unobtrusive indica-tors of human stress," paper presented to the Disasters and Hazards Research Session of the Fiidwest Sociological Society, Kansas City: April.

Hufnagel, Rick, and Dennis S. Mileti 1983 " Organizational and environmental catastrophe: factors affecting organizational response to a predicted earthquake," paper presen-ted to the Disasters and Hazards Research Session of the Western Social Science Association, Alburquque: April.

Mileti, Dennis S.

1982 " Earthquake predic t ton response: cultu ral comparisons between Japan and the Urf tec States," pepor presented to the Disaster l

O Research Session of the International Sociological Associetion, Mexico City: August.

11

a Mileti, Dennis S.

I 1982 " Influencing corporate decisions on the use of microzonation information," paper presented to the Third Inter, national Confer-ence on Microzonation, Seattle: June.

Milett, Dennis S.

1982 " Earthquake prediction and warnings: the human equation," paper presented to the Conference on Hazards Research, Policy Develop-ment, and Implementation Incentives: Focus on Urban Earthquakes, Policy Research Center at the University of Redlands, Redl ands:

June.

Mileti, Dennis S.

1982 "Public perception of seismic hazards," paper presented to the Seismological Society of Arterica, Anaheim: April.

Williams, Gary, Frank Santopolo and. Dennis S. Mileti 1980 " Perception of growth impacts in energy irnpacted communities,"

paper presented to the Rural Sociological Society, Ithaca: Au-gust.

Mileti, Dennis S.

1980 " Planning initiatives for seismic hazard mitigation," paper pre-sented to the Conference en Social and Economic Impacts of Ear-thquakes on Critical Lifelines of the American Society of Civil Engineers, San Francisco: May.

Timmer, Doug, and Dennis S. Mileti 1980 "Interorganizational and structural determinants of decision making," paper presented to the Session on Complex Organizations of the Midwest Sociological Society, Milwaukee.

Williams, Gary, Dennis S. Mileti pv 1980 " Community grow'th and impacts," paper pres,ented to the Western Social Science Association, Albuc,urque: April.

Milett, Dennis S.

1980 " Human response to earthquake prediction," paper presented to the Status o,f Knowledge Session of the Cc.nference on Earthquake Prediction Information, Los Angeles: J anu a ry.

Williams, Gary, and Dennis S. M11eti 1979 " Perceptions of growth impacts in non-metropol f Mr Colcrado,"

paper prewnted tc the Impacts 55:ssion of the Conference on F+gicnal Migration Trends, St. Louis: Octcber.

Mileti, Dennis S., and Gary Williams 1979 " Resident perepetions in growth impacted wettern agricultural ccmmunities," paper presented to the Rural Sociological Society, Vermont: August.

Gillespie, David F., Dennis S. Milett and Stan Ettzen l 1979 "The opf henominality of organizational size," paper presented to

the Session on Complex Organizatiens of the Midwest Sociological l

Society, Milwaukjee: April.

Mileti, Dennis S., Janice R. Hutton and John Sorensen 1979 " Social f actors and reesponse to earthquake prediction," paper presented to the International Symposium on Earthquake Predic-tion, UNESCO, Paris: April.

Hutton, Janice R., Dennis S. Mileti, and John Sorensen 1979 "Fectors af fecting eartbr,uake warning system ef fectiveness,"

paper presented to ibe International Symposium on Earthquake O Preciction, UNESCO, Paris: April.

b 12 l

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Sorensen, John, Janice R. Futton and Dennis S. Mileti

()' 1979 " Institutional naragement of risk information following earthquake predictions," paper presented to the Internettonal Symposten- on Earthquake Prediction, UNESCO, Paris: April.

M11ett, Dennis S., and Janice Hutton 1978 " Social aspects of earthquakes," paper presented to the State of the Art. Session of the Second International Conference on Microzonation, San Frarcisco: Novemb e r.

Milett, Dennis S., and David F. Gillespie 1978 " Organizational size, complexity and decision makir 3," paper presented to the Organizations Session of the American Sociologi-cal Association, San Francisco: Septetter. -

Gillespie, Devid F., and Cennis S. Mileti 1978 " Corporate size as work," paper presented to the Organization of Work Session of the American Sociclogical Association, San Fran-cisco: Septenter.

Mileti, Dennis S., and David F. Gillespie 1978 " Action postulates in organization-environment relations," paper presented te the Organizations-Environment Session of the Midwest Sociological Society, Omaha: April.

Gillespie, David F., and Dennis S. Mileti 1978 " Size and organizaticnal differentiaticn," paper presented to the Formal and Complex Organizations Session of the Pacific Sociolo-gical Association, Spokane: April.

M11eti, Dennis S., and Petricia Harvey 1977 " Correcting for the human factor in tornado warningd," paper presented to the* Conference on Severe Local Storms of the Ameri-can Meteorological Society, Omaha: October.

(]\

' M11eti, Dennis S., and David F. Gillespie 1977 " Organization and environment adaptat f or-r.anipulaticn," paper

-presented to the Organizational Relations Session of the American Sociological Association, Chicago: September.

Hutton, Janice P., and Cennis S. M11eti 1977 "The uses and abuses of scenariot in policy research," paper presented tc the Social Policy Session cf the Americen Sociolcgi-cal Associaticn, Chicago: Septemb e r.

Gillespie, David F., and Dennis S. Mileti 1977 " Organizational growth and managerial efficiency," paper presen-ted to the Sccial Organization /Formel/ Complex Session of the Pacific Sociclogical Association, Sacramento: April.

Milett, Dennis S., and David F. Gillespie 1977 "Organiz6tional meniptlet.icn and adaptation to complex environ-ments," paper presented to the Complex Organizations Session of the Midwest Sociological Society, Minneapolis: April.

Gillespie, David F., Dennis S. Nileti and J. Eugene Haas 1976 " Size and structuro in complex organizations," paper presented to the Organizational Change Session cf the Ar..erican Sociological Association, Few York City: August.

Mileti, Dennis S.

1976 " Learning theory and disaster warning response," paper presented l to the Issues in Envirormental Analysis Session to the Ar.ierican l Sociological Associetion, New York City: August.

15 l

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1 o

Haas, J. Eugene, and Dennis S. M11eti C, 1976 " Consequences of earthquake prediction on other adjustments to earthquakes," paper presented tc the Austral f an Academy of Scien-ce, Canberra: May. )

Mileti, Dennis S., and J. Eugene Haas 1976 "A methodology for future collective events," paper presented to the Collective Eehavior Session of the Midwest Sociological So-ciety, St. Louis: April.

Gillespie, David F., and Dennis S. Mileti 1976 " Operations technology and organizatforal structure," paper pre-sented to the Forr.al Organizations Session of the Midwest Socic-logical Society, St. Louis: April.

Haas, J. Eugene, and Dennis S. Nilett 1976 " Assessing the conserpie rces o' earthquake predictien," paper presented to the Social Fisk Session of the American Association for the Advancenient of Science, Boston: Feb ru a ry.

Milett, Dennis S., and David F. Gillespie 1975 " Technological urcertof t.ty in organization-environment rela-tior.s," paper presented to the Forn al cr u r f r ations Sos sion of the American Sociclogical Association, San Francisco: August.

Mileti, Dennis S., and David F. Gil kspie 1975 "A resolution of inconsistencies between size, complexity and the administrative component in organizations," paper presented to the Formal Organizotions Session of the Midwest Sociological Society, Chicago: April.

Mileti, Dennis S., and David F. Gillespie .

1975 " Technology and the study of organizations," paper presented to O

V

, the formal Crganizations Session of the Pacific Asscc.iaticn, V ictoria: April.

~

Sociological Milett, Dennis S., and David F. Gillespie 1975 "An interact f u rodel for organizet ten-environment relations,"

paper presented to the Interorganizational Relations Session of the Midwest Sociological Society, Omaha: April.

Mileti, Dennis S., and David F. Gillespie 1974 "A fortualization of organizaticn-cnvironraent dependencies," paper presented to the Formal Organizations S< ssior of the Pacific Scciological Associatien, San Jose: March.

Farhar, Barbara, and Dennis S. Mileti 1974 "Value and role issues for the involved social scientist," paper presented to the Applied Session c f the Pacific Sociological Associatien, San Jose: M arch.

Mileti, Dennis S.

1973 "Drowing: a communications disease," paper presented to tFe Mass Comnonications and Public Opinion Session of the American Socic-logical Association, New York City: August.

M11eti, Dennis S., and Sigtrund Krane -

1973 " Response to in pendine, system stress," paper presented to the Wryt Oc ile Know Session cn Human Behavior in Disaster of the Ar9erican Scciological Assccict fcn, Mew York City: August.

Filett, Dennis'S.

1973 "A paradign and sociology of kncwledge for theories of natural law," paper pts anted to the Theory Session of the Fidwest Socic-logical Scciety, Milwaukee: April.

14

Milett, Dennis S.

h-[ 1972 " Response to hazards warnings," paper presented to the Organiza-tional and Community Response to Disaster Settiner at the Disaster Research Center of the Ohio State University, Colurrbus: July.

Soeeches fad Guest Le5tures

" Social aspects of risk," Risk Analysis Seminar, Department of Industrial Engineering, Stanford University: Feb ruary, 1985.

"Comrnunic atirig engineering triformation to public officials," Social Appli-  !

cations Session, Earthquake. Engineering Research Institute, Seattle: Feb- l ruary, 1985.

" Social and ;mi tt ical obstacles to the use of nonstructural ficod loss mitigation rneasures," Arterican Society for Civil Engineers, San Francisco:

Ccteuer, 1984.

" Warnings: applying research f r the private sector," Plenary Session on Hazards Research and Management: Assesstaents of a Maturing Field, Natural Hazards Research Applicaticns Workshop, Soulder: July, 1984.

" Human respor.s e to emergencies," Emergency Preparedness Executive S'eminar for County Commissioners of the Cornmonwealth of Pennsylvania, GPU Nuclear -

Corporation, Harrisburg: March, 1984 "The uses of eart'hqueke predictien-warnings," Collogiun en Earthquake Pre-diction Research in the US, Ea rthc,uake Research Institute, University cf (V~T Tokyc: Neverrber, 1983.

" Human response in disasters," American Rec Cross, Mile High Chapter, Beulder Region, Boulder: July, 1983.

" Integrated emergency raanagement: chalienges and opportunities," Plenary Session of the Natural '"o ards Podearch App licat ions Workshop, Boulder:

July, 1983.

Public response to flood disasters," Conference on '.be Neec for Tearwork

."in Managing Flood Hazards, Association of State Floodplain Manager, Secrc-mento: April, 1983.

"Natu ral hazards, disasters and public policy," Envirc,nn. ental Manager-ent Institute, University of Southern California, Los Angeles: April, 1982.

" Myths of disaster response," Earthquake Planning Conference for Business and Industry, Les Angeles: Pey, 1982.

"Communicatir.g lessens learned f rori. Soc i a l science resear c.h cr. r e r-thquakes," Workshop of Identifying and Disseminating lessons Learned frcr Recent Earthquakes," Ear *.bquake Engineering Research Institute, Les Altos:

Decerrber, 1982.

" Social causes of earttquake predictien-warning response: implications for (V) the design of California's warning syster. and information dissemination,"

l 15

Southern California Earchquake Preparednoss Project, Van Nuys: October, h)

O 1981.

" Assessment of research on natural hazards: what have we learned and what problems demand further attention," Natural Hazards Research Applications Workshop, Boulder: July, 1981.

" Disaster reconstruction: patterns to guide pl anning," Governor's Task Force for Earthquake Emergency Preparedness, Concittee on Long Range Reccn-structicn, Sacremento, July,1981.

"Socio-cul tural dimensions cf earthqueke risk," Governor's Emer;ency Tcsk Force on Earthquakes, General Assen.bly, Sacrar., ento: May, 1981.

"Interorganizatienal relations and service delivery systems," Fealth Scien-ces Center, University of Colorade, Denver: Octob er, 1980.

" Social response to earttquake prediction: local policy issues," Southern California Emergency Services A.s:,ociation, Mentebello: Feb ru ary, 1960.

" Human response to vocib(r-borne hazards warnings," Department of Atmos-pheric Sciences, Colorado State University: C<3c ber, 1979.

" Natural hazards, disasters and social research," Department of Sociolcgy, University of Denver: ' December, 1980, 1979.

" Measuring implerrentation of public policy for ficodplain land use con-O trols," Natural Hazards Research Applicetions Workshop, Boulder: August, d 1978. .

"Sociceconomic effects of earthquake predict 'cn arid state policy," Confer-ence on State Policy for Earthquake. Prediction Technology, ScL1 der: Ne v er,v-b e r, 1977.

l "Popu l ation, resources and policy for sccial change," College of Naterol Rescurces, Colorado State University: Septerr.b e r, 1977; Feb ru a ry, 1978; t

Fct rue ry, 1980.

"The behavicr of governtsent and cor porate organizations in an earthqueke prediction," American Society for Public Adtrinistration, Colorado Chepter, Denver: April, 1976.

"The social and economic aspects of scientifically credible earthquake predictions," California State Seminar on Emergency Preparedness and Ear-

thquake Prediction, Palm Springs
June, 1976.

" Preparing to make use of earthquake pr e c'ictions," Ec:ergency Pre t t r+.dness Corraission for the County and Cities of Los Angeles, Montebello: Feb rua ry, 1976.

"The social organization of hazard warning systerns," Engineering Foundaticn Conference on Decision Making for Netural Hazards, Pacific Grove: Ma rc h, (3 1976.

U 9

16

" Briefing on the likely sociti and economic impacts of earthquake predic-tion," Governor's Conference Room, Sacrarr. ento: May,1975; Mayor's Conferen-ce Room, Los Angeles: October, 1975. j

" Social, economic and legal aspects of earthquake prediction," General Assembly of the International Union of Geodesy and Geophysics, Granoble:

Septerrber, 1975.

" Earthquake predictiori esir; 'is impl icatf ors for emergency preparedness,"

Center for Corrmonity Studies, Tokyo: Septernb er, 1975.

" Social . impacts of earthquake prediction: impiications for policy," Cal 1-fornia Water and Power Earthquake Engineering Forum, San Francisco: April, 1975.

G O .

O 17

S l

OTWER PROFESSIONAL SERVICE O

V Organizer fd Presider Sesgion on Nuclear Power, Third International Congress on Emergencies, Washington, D.C.: May, 198S; Session on Applied Sociology, Pacific Socio-logical Association, Seattl e: April, 1984; Session on Theoretical Asses-sments, Western Social Science Association, San Diego: April, 1984; Session on Methodological Approaches in the Study of Health Care Delivery Systems, Western Sociel Science Association, San Diego: April, 1964; Session en Erthquake Hazard Reducticn: Is the National Earthquake Hazard Reduction P rog rarn f*eeting its Congressionti flandate, Seventh Annuel Workshop on Natural Hazards Research Applications, Boulder: July,1982; Session on Disasters and Cataclysms: Can Sociology Help, Pacific Sociological Assoc *a-tion, San Diego: April,1982;'Sessicn on Collective Behavior, American Sociological Association, New York: August, 1980; Session on Complex Crga-nizations, Pacific Sociological Association, San Francisco: April, 1980; Session on Corrplex Organizations, Western Social Science Association, Tem-pe, 1976.

Discussant Session on Theoretical Assessments, Western Social Science Associaticn, San Diego: April, 1984; Session on Societal Response to Hazards, American Sociological Associetion, San Antonio: August,1984; Session on Pubi te Response to Earth Scienc6 Infortnation, flaturel Hazards Research App 1 tca-tions Workshop, Boulder: July, 1980; Session on Warning Systems, National (

n Conference on Natural Hazards, Boulder: June,1976; ~ Session on Warning

() Systems, National Conference on Natural Hazards, Boulder: J u l y, 197S; Session ct; Cisester Relief and War ning Systerrs, National Conference on Natural Hazards, Estes Park: June, 1973.

Particicant Panel on Disaster Research Its Funding and Future, American Sociclogical Association, San Antonio: August,1984; Review Panel, Corresponding fler:ter, l Task Group on Social and Economic Aspects of Earthquakes, Naticnal Academy I

of Sciences, National Research Council, Commission cn Sociotechnical Sys-tems, Washington, D.C.: 1982; Workshop on Disseminetits Lessons Learned f rom Recent Earthquakes, Earthquake Engineering Research It stitute, Los Altos: Decemb er, 1982; Tennessee Valley Authority Flood Plain Evaluaticn Panel, Boulder: No v errb er, 1982; Earthquake Prediction Warning Task Force Workshop, Southern California Earthquake Preparedness Project, Asilomar:

December, 1981; Syn'posium on Earthquake Prediction, Preparedness and Human Response, San Fernando: June, 1976; Seminar on Disaster Research, Colorado State University, Fcrt Collins: February,197S; Synfestun on Cortplex Orga-nizations: Fesecrch and Applicaticns, Western Social Science Association, El Paso: April, 1974 Editorshfes Corresponding Editor, Organf rations fg Occucations Newsletter of the Amer-ican Sociological Associatien, Western Region,1984-preser.t; Associate l

p)

( Editor for social science, Ea rtheu ak e Soectra. Journal of the Earthquake Engineering Research Institute, 1984-1987; Corresponding Editor on Hazards 18

l s l

l

,s and C!saster, Environmental Sociolocv. Newsletter of the Section on Enviro-I

(

'~ nmental Sociology of the American Sociological Association,1981-date; Guest editor, special issue on Environmental Stress, Threat and Social System Response, P_ui mergencies E 1(4):247-346, 1976.

Testimenv ,

Nuclear Regulatory Commission in the matter of emergency planning at the Shoreham nuclear reactor, Suffolk: December,1983 through June, 1984; Nuclear. Regulatory Commission in the matter of emergency planning at the Wolf Creek generating station, Burlington, Kansas: J anu a ry, 1984; Nuclear Regulatory Commission in the matter of pre-emergency public education and information for emergency planning at the Waterford Three nuclear reactor, New Orleans: Feb ru a ry, 1983; Suffolk County Legislature, State of New York, in the matter of emergency planning at the Shoreham nuclear reactor, Suf-fold: J anu ary, 1983; Nuclear Regulatory Commission ir the matter of emerg-ency planning at the Diablo Canyon nuclear reactor, San Luis Obisbo: Janu-ary,1982; Senate Subcommittee on Science, Technology and Space in the matter of the National Earthquake Hazards Reduction Act, Washington, D.C.:

April, 1980; Nuclear Regulatory Commission in the matter of the impact of floating nuclear plants on tourist behavior, Bethesda: May, 1977 and July, 1973.

Legislative and Program Reviews Earthquake Hazards Reduction Program, U.S. Congerssional Panel, Federal Emergency Management Agency, 1983-82; Earthquake Hazards Reduction Program

! (^h of the U.S. Geological Survey,1982; Final Regulations for Floodplain x/ Management and Protection of Wetlands, Federal Emergency Management Agency, Federal Register 176(45):59520-59538, 1980; Applied Research Program Eva-luation, National Science Foundation, 1979-78.

Precosal Reviews Societal Response Program of Civil and Environmental Engineering, National Science Founcation, 1985-81; Div ision of Policy Research and Analysis, National Science Foundation,1983; Sociology Program, National Science i Foundation, 1982-81; Design Research Program, National Science Foundation, l 1982; Division of Problem Focused Research, National Science Foundatien, f 1980; Division of International Programs, National Science Foundation, 1978; Division of Advanced Environmental Research and Technology, National l

Science Foundation, 1978-76.

Article Reviews Human Relations, 1985-83, 1978-77; Seefological Persoectives (Pacific Sc-ciclocical Review), 1984; Social Fo rc e s. 1980-79; Sociologv Ang Social Research. 1983-81, 1979-78, 1976; Ih2 Social Science Jou rnal,1985, 1981-77; Ihg Sociclecical Quarteriv. 1975; Journal ni ttg American Planning Associa-

~

liga,1985; ceviant Behavior, 1983; Eigt Analvsis. 1983; Ihg Environm ntal Pro fes s iona l, 1983-82; Bu l let in af it2 Seismological Sccietv af America, 1982; Sociological Focus,1980; Mas 1 E-ergencies, 1978,1976-7S; Pol iev

/~T Analvsis, 1978; Current Research in Earthcuake Prediction, 1984; Mass k_si Emergencies and Disasters, 1985.

19

s Q1hgg Reviews O

(-) L. Lave and D. Eppl e, "Futu re Scenarios," Chapter 21 in R. W. Kates .(Ed.).

Climate Imoact Assessmente Studies gf thg Interaction sf Climate And h sly. Geneva, for the International Council of Scientific Union's Scientific Coneitttee on Problems of the Environment,1982; Study na Earthouake Ha2ards Information Disseminatione Charleston. South Carolina. Reston for the U. S.

Geological Survey,1982.

Denactment And University Service College Schol arship Committee, 1985-84; Department Executive Committee, 1984-82, 1980-77; Department Graduate Affairs Coramittee, 1985-84, 1977-74; Department Five-Year Review Committee, 1982; Department Comprehensive Exa-mination Committee, 1984-75; Department ad hoc Committee on Research Space, '

1983; Department Evaluation of Independent Study Courses,1978; Department Faculty Search Committee, 1985-64; College Search Conmittee for Department Cha i r, 1985-84; University Committee on Ethnic Studies, 1976-74; University Committee on Latin American Studies, 1975-74 v h I

l l

O 20 i

= ,

TEACHING

\

Courses Taught (undergraduate)

Introduction to Sociology Complex Organizations Demographic Processes and Social Change Historical Sociological Theory Research Methods Sociology of Hazards and Disasters Courses Taucht (graduate)

Advanced Quantitative Analysis Multiple Regression and Path Analysis Research Methods I Research Methods II Demography and Population Complex Organizations Graduate Theses and Dissertations Chair, Ph.D. Dissertation Committee, 6 Memoer, Ph.D. Committees, 12 Chair, M. A. Thesis Committees, 4 Member, M. A. Committees,12 Student Evaluations b

Ranked as excellent by most students in most courses; evaluation summaries are available upon request.

Teaching Awards

  • Alumni Honor Faculty Award, Colorado State University, Alumni Association, for Academic Year 1983-1984; Cited for excellence by the Dean, College of Arts, Humanities and Social Sciences for Academic Year 1977-1978. <

21

7783

  1. 2-6-SueWalsh MS. RIDGWAY: Mr. Chairman, before I make the i

O i

2 witnesses available for cross-examination, they are prepared 3 to briefly summarize their testimony orally for the benefit 4 of anyone here who may not have had an opportunity to read 5 it. .

I 6 BY MS. RIDGWAY: (Continuing) 7 Dr. Mileti? I Q

t 8 A (Witness Mileti) My testimony can be summarized j 9 as follows. The historical research record suggests that ,

10 emergency workers, including for example school bus drivers, 11 who know that they have an emergency job and know how to do 12 that emergency job, in fact, do that emergency job when an

() 13 emergency occurs.

14 One way that emergency workers can come to learn

\

15 I of their role in an emergency is through training. And train-16 ing can familiarize them with what their job is.

17 Role strain is a mental state and does occur in 18 emergency workers, but role strain is not a behavioral problem 19 in the sense that it keeps emergency workers doing their 20 emergency job when it is they need to do their job.

21 Additionally, role strain can be minimized if one ,

22 wanted to take steps in an emergency plan, for example, to 23 minimize role strain in a psychological sense by advance plans.

() 24 Ace-Federal Reportets, Inc.

For example, having emergency workers know ahead of time that i 25 they may have a job in an emergency and having them discuss .

)

7784 l l

  1. 2-7-SueWaldh with their family ways to ensure that they can do that job 2 l when the need arises.

3 O And, Mr. Myers, could you summarize your testimony, l 4 please? ,

5 A (Witness Myers) We believe in North Carolina that 6 if you have a specific job and training that North Carolina v

7 workers are on record of being responsive to meet the needs l

8 in any type of life-threatening situation, and would carry i 9 out the function of evacuation in the event of an accident ,

10 at the Shearon Harris Plant. 2 II MS. RIDGWAY: Mr. Chairman, the witnesses are t

12 available for cross-examination.

13 JUDGE KELLEY: Thank you. Mr. Read.

Id CROSS EXAMINATION 15 BY MR. READ:

INDEXXX 16 Dr. Mileti and Mr. Myers, my name is Daniel Read.

0 l 17 I will be asking the questions for the Intervenors.

. 18 And my questions will be directed primarily at I9 Dr. Mileti, so if I don't preface my question with a reference

' 20 to one of you individually, you can generally assume it will i

21 be for Dr. Mileti.

22 Dr. Mileti, could you -- I'm a little bit unclear I

23 from your Vita and from your testimony exactly what the 24 Hazards Assessment Lab is.

Aa 4.o.<.: n. cort.ri, Inc.

Is that a branch of Colorado State University?

l

7785

  1. 2-8-SueWalshi Could you describe it a little bit?

2 A (Witness Mileti) The Hazards Assessment Laboratory 3 is not affiliated with any college or department at the 4 Unive rsity . It is housed in the Graduate School. It has 5 been in existence for about a year now. And it was my idea 6 to build it, j 7 And it's under the direction right now of myself I

8 and the Academic Vice-President for Research. And the point ,

i 9 of the Laboratory is to have the University create a position  !

10 where different people from different departments can come II together and pool their expertise and do research of various 12 sorts that have to ,do with natural and technological hazards 13 in emergencies from all different points of view.

Id Q Different people from different departments within 11 15 the University?

16 Yes.

A That's the idea.

I 17 I And does this Laboratory have any full time Q

18 employees other than yourself, or are you --  !

A Well, I'm not employed in it full time. I am at 20 the present time half time in the Laboratory and half time 21 in the Department of Sociology. At the current time, there 22 is another sociologist who has no other affiliation with the  !

23 University aside from the Laboratory. There is a professor 24 of economics who is affiliated with the Laboratory currently,  !

Aa er:> Reporters, Inc.

25 and several students.

t

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' 7786

  1. 2-9-SueWalsd Q From my review of the literature, it seems --

/^N l

(_) 2 I am aware that there is a similar center at the Ohio State l 3 University; is that correct?

4 A No, that's not.

5 Or, does that -- could you describe the center Q

i l

^

6 at Ohio State?

7 A There is no center at Ohio State. It has been 8 moved to the University of Delaware.

9 Q Oh, okay. Are there a number of institutions 10 like the Laboratory in this country?

II A I think the Laboratory is unique. There are other 12 universities and other professors at other universities that 13 do research in this area, some of whom have different sorts

(~}

x-l Idl of organizational arrangements with their own universities.

h .

15 But, would it be safe

  • to say then, Doctor, that Q

16 your Laboratory is one of the leading institutions in this 17 I field, in this field of disaster research in the United 18 States?

" A I wouldn't say it's one of the leading. That's 20 for others to judge. I would say that it exists.

2I O Okay. Have you testified often before the Nuclear 22 Regulatory Commission?

23 A I've testified several times before.

24 l

I ')

Anr+._;f:.1 Reporters, Inc.

Q Have you testified before other tribunals in your 25 capacity as a disaster research -- or, an expert in disaster

7787

  1. 10-SueWaldt phenomena?

2 A I'm sorry. I don't know what you mean by tribunal.

3 But, if you mean by that what I would call decision makers, 4

yes, on several occasions.

5 For example, the California State Legislature and j the United States Congress.

7 So, you are familiar with preparation of testimony, Q

8 and in this testimony that I have before me you :aave used  ;

what you consider to be authoritative text in your field? l A I think there were two questions that you asked 11 me. Which one would you like me to answer first?

I Q All right. Question number,one, you are familiar i

O with the pregeration of testimony before these tribunais ane I decision making bodies?

'l A I have prepared testimony before. I don't know 16 that I am familiar with it. Things that are legal are not l

familiar to me at all.

Q Okay.

19 A But I have prepared testimony before. Yes.

O Q And in the preparation of this testimony you do, to the best of your ability, attempt to use the most authorita -

22 tive texts in your field; is that true?

23 A No, not necessarily. For examp1e, in this testimony O 24 AwFederst Reporters, Inc.

I tried to give some examples of the research that has occurred ,

25 .

from its first piece of writing on this topic back in 1952

7788

  1. 2-11-SueWalsh right on through some of the more contemporary ones. So, O 2 1 wouta eive e ch of the references, for ex mg1., eh.e 1 3 use different weight and come to a conclusion about the 4 behavior of people with emergency jobs.

END #2 3 Simono f1ws j

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10 11 12 13 ,.

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15 16 17 18 19 20 21 ,

22 23 24 i Arol Moporters, Inc.

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7789 31,3-1 1 Q Turning to your tootimony, Dr. Mileti, turning 2 to page 6 of that testimony, you describe the notion of role (x '

R.)

3 conflict, and there is a good deal of discussion in here about 4 the term " conflict" and also in the literature that I have 5 reviewed.

6 One of the questions that came to my mind was 7 how exactly do we define role in this particular context?

8 could you describe that briefly?

9 A (Witness Mileti) My definition of role would 10 be a job.

11 Q But aren' t we also talking about an individual's 12 function within his family as a role?

13 A Yes. ,

14 Q So it is not simply a job?

15 A Well, a job in the sense that there are certain 16 behavioral rights and obligations associated with it, 17 and in that sense a father role could be considered a job 18 behaviorally.

19 Q Does an individual have any roles per se, in 20 other words, any role obligations or perceived roles with 21 respect to his or her own well being as an individual in 22 your concept of role?

23 A That is an odd use of the term and it is 24 unfamiliar to me. I am sure people have perceptions about ug : hpore.rs, :=.

25 a raf t of things, but role is a structural element in

1 7790 I

Sim 3-2 society and typically has to have a structure dimension to 1

l

() 2 it and can't really exist just from a perceptual point of 3 view.

4 Q But isn't it true, Dr. Mileti, that in this I 5 field of role conflict that one of the factors that needs i 6 to be considered is the individual's basic instinct for

. 7 self perservation?

! 8 A Well, first let me say that I don't think there 9 is a field of role conflict and, second, we could debato 10 for the next week about whether human beings have instricts

. 11 or not.

l 12 What is relevant in reference to the matter at t 13 hand is whether or not people do their emergency job, and 7s l \-] 14 from the record that I am familiar with, I don't think that .

15 people's perceptions are relevant to understanding why 16 emergency workers do their jobs when they are asked to do 17 them. ,

18 Q Let me get that straight, Dr. Mileti. You said c

19 that people's perceptions are not relevant to their job

20 performance in the emergency context?

21 A What I said was that people's perceptions is 4

22 not relevant to understanding why emergency workers who have 23 cmcrgency jobs do their job when they are asked to do it.

24 JUDGE KELLEY: When you are saying people, do j Ac of Reporters, Inc.

j 25 you mean people other than the emergency workers?

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_ _ _ _ . _ . _ _ - - _ - . - - _ . - . _ . - _ - _ _ _ _ _ _ - - _ _ . . _..-_-______m-_ . -:_____.. _ _ _ _ . . _ . _ - _ ___ _ _ . - _ . _ _ _ - . _ _ _ _ _ . _ _ _ _

7791 Sim 3-3 WITNESS MILETI: No, sir. I was talking about 1

() 2 emergency workers.

3 JUDGE KELLEY: Their perceptions?

4 WITNESS MILETI: Yes.

3 BY MR. READ:

6 0 And as a sociologist, Dr. Mileti, you examined 7 this topic strictly in terms of individual's behavior 8 with societal structures?

9 A (Witness Mileti) If you are asking how I have 10 researched the concept, I would have to say that I have 11 cxamined it in a variety of different ways. The field as 12 a whole has people within it who approach the study of 13 human behavior from every different point of view that one O 14 could possibly have of the study of human behavior.

15 Q But that is not limited to societal structurcs, 16 is it?

17 A Sociologists can investigate any behavior in 18 any way they see fit and have.

19 Q Turning to page 8 of your testimony, Doctor, 20 you at linos 4, 5 and 6 thoroof, you are discussing Killian's 21 cxampics of a rolo in an emergency.

22 Could you describe which exampics you are 23 referring to?

24 A Killihn as a basis for his article used Ac r;l Reporte,s, Inc.

25 investigations from four different emergencies. They werc

l  :

7792 Sim 3-4 1 investigations, I don't believe that he performed himself,  !

O 2 due rather research data ehae was housed at a universter 3 in Oklahoma where he was employed at the time. They l

4 were tornadoes. (

5 Q All four of them were tornadocs? l l

6 A As I recollect. It is possible that one of j 7 them might have been a flood, but I am not sure. I am f 8 sorry, one was an explosion, as I come to think of it.

9 Q so that in those didn' t Killian focus primarily 10 on the Texas City explosion?

i II A It is hard to know what ho focused on primarily i 12 because he was using all of them and.doesn't really report f

13 any of the data.

14 Q But in each of the disasters referred to in j 15 Killian's article you say in lino 7 of your testimony "Those 16 who did have occupation roles relevant to the omorgency ,

t I

17 performed them and even expressed concern that they could 18 not do more. Woron't those occupations roles which they 19 had in the emergency, woron't they already at their job (

20 place, the place at which they were to perform this role? l 21 A Some of them woro, yes.

22 Q Turning to page 10 of your combined testimony, l

23 and this is a question for Mr. Myers, you stato "That of the f I 24 Acgil Reporters, Inc.

approximately 96 bus drivers," et cotora, et cotora, "15 25 of those 38 live in the liarris plume exposuro pathway j i

L --___

7793 Sio " 3-5 I cmcrgency planning zone. Of those 15, only 3 have prcschool

~

2 children," et cetera.

3 Is that correct? You have previously testified 4 that you still stand by that, Mr. Mycrs?

5 A (Witness Myers.) Yes, I do.

6 Q Doesn't that figuro assmuo that only thoso 7 people who live in the plume exposure pathway emergency 8 planning zone would be concerned about their families in 9 an emergency?

10 A Would you repeat your question, please?

11 0 Doesn't your figure 15 of 38, and then of those 12 15 only 3 have preschool children, as a demonstration of 13 how minimal the problem we are looking at here is, docan't

~'

14 that assume that only those people who live within the 15 cmergency planning zone will experience this kind of role 16 strain?

17 A No, sir.

18 0 It does not.

19 A (Witnoss Mileti) I must add that those numbers 20 don't mean to illustrate how minimal or major a problem is 21 or isn't. Whether emergency workers have families that 22 live within the EPZ or outside the EPZ will not mako a 23 difference in terms of whether or not those emergency 24 workers will do their emergency work. These numbers were Ach,al Report.ri. Inc.

25 simply met to illustrate that it is incorrect to presumo

i 7794 sim 3-6 that all emergency workers are the same, that is have i 1

l.

families that live far or closo away. Behaviorily what

(]) 2 3 we are concerned about is whether they do their work or 4 not. Wheretheirfamil1cslivedocan'tmakethatmuch' 5 difference. In fact, it doesn't make any difference.

6 Q Do you agree with that, Mr. Myers7 7 A (Witness Myers) Yes, I do. ,

i ond Sim 8 Joe fois ,

9 i 10 1

11 12 l r

13

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i 18 19 20 21 22 23 AdlhLa ng.nm. . . .

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4-1-W21, J.

7795 1 Q Turning to pago 12 of your testimony, Dr.

O 2 Miloti, you refer to Dr. Fritz, or Mr. Fritz, whatever it 3 is. Whatever his titio might be. Classic picco of literature 4 in the field, and then you describe at pago 675, Fritz 5 addresses family emergency jobs, et cetera.

6 Turning to my cross examination Exhibit No. 3 --

7 do you have that beforo you?

8 A (tlitnons Miloti) I can in a moment. I havo 9 it now, yes. l 10 Q Could you point out to mo whoro on pago G75 ho II addresson their familios, at cotora, people with emorgoney  !

t 12 jobs and poople without omorgency jobs are relatod?  !

l O ^ rrie='s reicio -- actualiv eni i= a chavear  :

I

'd in the book. And the important roforenco I felt for me to f

15 mako in this tontimony in trying to givo tho story about 16 where sociological restarch bogins and how they ovolved, Mr. ,

17 Fritz was in charge of oversocing mont of tho studios that 18 '

wont on for a decado and a half at least at the Nationni 19 Academy of Sciencon, and back in 'G1 when thin book como out, 20 thin was his attempt to summarizo and rononrch records, 21 Moro knowledge grow as timo want on. This is l l

22 nomowhat the middio of the road, and what Fritz in stating  !

! 23 in still nomowhat confusod, and still doonn't revoal all tho l 24 wrm.o n,non.... ine.

knowledgo that we havo today on---on how omorgoney workorn 25 do their omurgoncy job in omorgoncion. l l

0 f

4-2-Z21, J.

7796 1 What I said in my tontimony reference to Fritz, 2 and my tontimony was trying to portray the continuing saga 3 to the curront day, was to point out how what he was doing 4 in the first paragraph, the first two paragraphs actually 5 on pago 675, was to point un in the direction of laying 6 groundwork for the following hypothonon that are listed on 7 pago 12 and 13 of tho tantimony.

t 8

Andspecificallywhathotalksaboutin--woll,{

9 I can road it if you like. This lack of familiar pattorn 10 and uniformity in action ofton loads to outsido obnorvorn 11 to the orroneous conclunion that the population han panicked.

12 i

What ho in witnonning in not panic, but social disorganization.

]) 13 If I might add,horo at thin point in timo wo Id fool it in uncoordinated activity on the gonoral lovol. It 15 in important to recognize that this nocial disorganization 16 nood not indicato a pornonal or small group disorganization.

17 On the contrary, many individuals in small groups to are acting with purpono and connidorablo control to copo with 19 the problemn they faco.

20 llowevor, their attention in apt to bo focunod 21 on tho immediato tank at hand, and no they appear oblivioun 22 to tho more gonoral thingo that have arinon an a ronuit of the 23 dinantor, et cotora.

$ 24 A. . e ... . ti . ... ... . . W And what rrit: wan naying from a thoorotical 25 point of view wan nomowhat mixed ntroam, in betwoon, that

7797 4-3-W31-J 1 -- what Killian was saying that is a role conflict. As a O 2 casua1 re ains, one ishe con =1=ae i taere proste , aa 3 eventua11y the more current literature that we have now, the 4 role conflict or stress doesn't alter people's behavior if 5 they have no emergency response responsibilities at that 4 time. ,

7 MR. ROCHLIS: For the record, I would just a like for you to identify the document that you are 9 testifying from.

10 MR. MILETI: This is Chapter 14, edited book 11 by Robert Burton and Nesbith, and it is called contemporary 12 Social Problems, and was published .in 1961.

13 MR. ROCHLIS: Thank you.

14 JUDGE XELLEY: For clarity, let me state l

15 it is labeled in our copies as an exhibit. It is being used ',

16 by Mr. Read as a -- the cross examination that actually gets !

17 in the record is just what is said.

It The document itse1f, at this juncture at least, 19 is not in. .

20 BY MR. READ (Continuing) 21 Q But doesn't Fritz go on to recognize, Doctor, i t

22 that these particular problems of personalization will 23 occur -- do, in far;t, occur?

24 A (Witness Mileti) Some of what Fritz says in en ,=. , W.

25 this article is thought to be correct today, and some of the

7798 4-4-W21, J.

1 stuff hs talks about in thought,to'be incorrect. '

,_ i N._ 2 It was wiint he thought was the case based on 3 research that was generally done in 'the 1950s.

4 It takes;.a while for thing's to appear in 5 print.

6 0 You just finished reading this one paragraph x

uhich ended that' peoples attention is apt to be fo'cused on 7

8 the immeditie task dtthand, et cetera, et cetera.

9 Coald yoid read the next para, graph?

10 ,A ,

I could,'but should I do tliat before I have  ;

i 11 to?,I haven't finished annvering your last question. j s

i g 12 .

Q Go ah{ad and finish: your answer.

I am soEry.

{} .M A I have forgotten what I just ,

14 said. -

15 Q Okay. 'Wil.L pou read the next para' graph, i

16 please? ,

i 17 A The one that begins -- two common?  !

18 Q Yes.,  !

19 Two cor.3 mon' human responses to disaster i i

20 initially cont:kbudd / to[this form of social disorganization. l l l

, f ,

21 A, the initial tenden'cy to particularize and personalize the I.

22 disaster. To think of it as happening only!.to oneself, and o

23 as being confused t'o ones immediate environment, and b, the h 24 Am-Federal Reporters, Inc.

anxiedy and concern for welfare of family members.

25 Let me point dut that this particular paragraph

4-5-Wal, J. 7799 1 of Fritz's is describing post-impact.

I) 2 For example, in an earthquake, when people find 3 themselves in a room that is falling all around them. And 4 additionally he is talking here about common human responses, 5 which is really talking about the public and not trained 6 emergency workers.

7 Q In dealing with a radiological emergency such 8 as this, as we are contemplating here, Doctor, you are 9 distinguishing post-impact emergencies. How would you 10 classify this particular radiological-type emergency?

11 A Well, it depends on what part of it you were i 12 talking about.

13 Q The part where bus drivers would be asked to -

14 go to the schools and pick people up.

15 A Well, I must presume that if bus driver's are I 16 going to schools to pick up students, that is because there i i

17 is going to be an evacuation, and I also presume that if there 18 is going to be an evacuation, that is the safest thing to do.

19 Sheltering, for example, would be a better option, t

20 and therefore it would be in a pre-impact -- what I would call 21 a warning situation.

22 Warning of an impending impact.

23 Q How would people know that there was an 24 impact?

Am- al Reporters, Inc.

25 A What you mean by that is a radiological

4-64Wal, J. 7799-A 1 emergency?

2 A The emergency information that was going out 3 to the public at the time. That everyone else was listening 4 to the emergency information would be describing as happening.

5 Q But that information would be simply that 6 there was either a potential for a release, or there had 7 been a release at the plant, and the person sitting on his 8 front porch wouldn't know which there had been necessarily, 9 would he?

10 A No, I think that is incorrect. In fact, we

, 11 in the social sciences know an important amount. We don't 12 know how much I might add that is useful, but we do know 13 about emergency public information and if the emergency 14 public information scheme at the Harris plant is sound, that 15 wouldn't be the case at all. l 16 The public would be given the information that 17 could lead them to form conceptions of risk and what was 18 going on.

19 Q I understand your point, Doctor. What I am >

l 20 saying is -- well, assuming that there has been a release 21 from the plant, and the person is aware of the risk involved, i

22 nonetheless, how does a person become aware? What 23 difference does it make? Should we say whether or not it  !

l I

() 24 Am Federal Reporters, Inc.

is pre or post-impact? A person cannot see the radiation, 25 can they? Assuming that the release has arrived at the place i

4-7-Wal, J. 7800 1 where they are, or is on the way?

() 2 A From what people tell me, I believe that 1

3 radiation is invisible, and other than that, I am a bit 4 confused by your question.

5 Q Well, the question is simply if -- I will 6 preface it by saying if, as you believe, radiation cannot 7 be seen then the pre / post impact scenario that we are 8 familiar with from such tangible events as tornadoes, 9 explosions, isn't quite as relevant, is it?

10 A No, I don't think I agree with what you just i

11 said.  ;

12 Q Can you explain why you don't agree with me, 13 Doctor? .

14 A First of all, if what we are talking about is --

and I think the question began with Fritz's paragraph on 15 I

16 Page 675. Fritz was describing what he thought to be the i

17 case back in 1960 or so, whenever he wrote this, about the 18 -- about emergencies and human response in general to them 19 involving in this paragraph at least, response to visible 20 damage. l 21 The notion that radiation is invisible and j i

22 therefore can't be perceived by people is erroneous, because j i

i I

23 people form perceptions of any impending emergency on the j i 24 basis of the information that they have access to about that

, Am. s n.poners, inc.

25 emergency.

i l

lf

4-8-Wol, J. 7801 1 In this case and in other cases, other 2 emergency information, if we are talking about the general 3 public as we are, that is formed on the basis of the 4 information they received at the time of the emergency.

5 Q There has been at least one radiological 6 emergency in this country to date, hasn't there? Three y Mile Island in particular?

8 A Yes, Three Mile Island did occur.

9 Q Was the information that the public received 10 at that tine correct in the initial stages of the accident?

11 A To be perfectly frank about it, I would use .

I

!2 Three Mile Island as a text book example of how to make i

() 13 every conceivable mistake you coul'd make in reference to I

14 public emergency information.  ;

l 1

15 The whole thing was botched up from beginning 16 to end.

17 Q And that includes the quality of information?

18 A It includes what one would want in terms of 19 how I might evaluate how good emergency information can 20 be. ,

21 Q I don't fully understand your response. j 22 A It includes the information that has been .

l 23 published, yes.  !

l

/~T 24 All the information that was made public l

(_j Q l

! Am-Federal Reporters, Inc.

l 25 to the citizens in and around the area?

L

7802 4-9-Wal, J.

1 A Not particularly. But from a human response

( 2 point of view.

3 0 In describing Fritz's work at classic, what 4 do you mean by that?

5 A It is one of the most widely read pieces of 6 research in disasters that exists, largely because it was 7 in a sophomore level textbook that most of the practicing 8 socialogists today had as texts when they were in school.

9 Also, given his position at the National 10 Academy, he is known by everybody. Killian's work and 11 Fritz's work simply can't go unreferenced if one is talking 12 about role conflict, regardless of whether or not one should l 13 take what their views of what they were, or if they are more i i 14 accurate or not today.

l 15 It is important to understand the evolution of 1

16 knowledge and skill.

l 17 Q Are you aware of subsequent additions in which 18 this article appears?

l 19 A I am certainly aware of it. I own a l

I i

20 subsequent addition, and was disappointed to find out -- l 21 Q At page 13 of your testimony, Dr. Mileti, you  :

22 are discussing Meda White's report about role conflict in  !

l i t

23 disasters, not family but familiarity first. l t

24 Are you discussing this -- can you describe to  ;

Am al Rmorwrs, Inc. l 25 me briefly the purpose for including this particular study l

4-10-Wel, J. 7803

! I in your testimony?

O 2 A Yes. I think this is a very important study.

3 White was a graduate student. In fact, I don't even know

+ 4 if she finished her degree or not at the University of 5 chicago, and she in this work gave the-first clear 6 articulation or some theoretical meaning to try to impose 7 understanding on emergency workers in emergencies. .

8 Her conclusion was that role certainty, 9 knowing that you have an emergency job, is a requisite for 10 doing emergency work.

11 This work is key, in my opinion, to suggesting 12 what we now know today; that emergency planning is useful.

I

() 13 And she also helped, thereby illustrating where researchers 14 like Killian observed people who didn't know that they had

.15 an emergency job in that emergency doing something else, 4

~16 that it was unfair- to consider that role abandonment for  !

t I

17 not doing the job. i i

i- 18 Q When you say that this was an articulation of 1

19 trying to impose understanding on emergency workers in i L I i 20 emergencies, I believe those are your words, what do you

' l i

21 mean by that, Doctor?

j 22 A I don't recall that those were the words that 23 I used, and if I did, that is not what I meant. I think I i

  • 24 was talking about theoretical understanding in the field Ace-Federet Reporters, Inc.

25 to understand why emergency workers do emergency work if

. , - . . . _ . . - - - . . - - . - . - - - . - . . . . - . - . - - - - _ . - - , . . - . . - _ - u - - . - .- - ..- - . . - . - -

4-ll-Wal, J. 7804 1 they knew they had an emergency job. That is basically 2 what it was.

3 Q So, White suggested the guidelines for further 4 empirical research in the affect of clearly defined roles 5 on response emergency?

6 That is my understanding of the testimony.

7 A I don't recall saying that. It is the case 8 that any sociologist when they get done with a piece of 9 research calls for more research. That is how we train l

10 each other, and how we stay in business.

1I What I think is important -- she used the  !

f

. 12 words, ' role certainty.' And basically said people who

  • O is a e neve emeree=cv sod due aeve e r 1e i= ene re 117 cae I

14 for being with their family, and people who have a clear f I

15 understanding of role certainty with reference to their

{

16 emergency job, do their emergency job.

17 Q Do you recall what kind of people White 18 interviewed?

19 A Yes. She interviewed mid-line people in ,

20 different organizations, in different emergencies. And l 21 they were, as I recollect, selected in a random scheme so ,

t 22 she felt confident about being able to generalize all 23 emergency workers in the organization.  !

24 Q Would you accept Dynes' summary of White's l Ace-Feder;l Reporters, Inc. j l 25 research in my Exhibit 2, from Organized Bahavior in a

r 4-12-Wal, J. 7805 1 -disaster by Russell' Dynes, in 1970, at page 154.

(f 2 I believe it is the third page of the exhibit.

3 JUDGE KELLEY: What page, Mr. Read?

4 MR. READ: 154. It is the third one from 5 the top.

6 And for the record, this-is Chapter 7, Problems 7 of Organized Activity and Disaster, from the book, Organized 8 Behavior in Disaster by Russell Dynes, as cited by Mr.

( 9 Mileti in his testimony.

i 10 WITNESS MILETI: Well, I really would want i

j 11 to read this in detail.

12 Let me say in general that I think well of w

13 Russell Dynes. And would imagine that he wouldn't misrepresent 14 White's work, but in order to answer your question totally 15 and fairly, I would need to compare the two, but in general '

16 I accept Russell Dynes work, so I am . sure that is accurate. .I i

17 BY MR. READ: I l

(Continuing)  :

I 18 Q Starting at the fourth line from the top --

19 JUDGE KELLEY: Let me just ask. You mean you f l

e 1

l 20 have to read the whole article, or do you want to read the l{

21 page? 1 t

i 22 WITNESS MILETI: I would want to read what Russell 23 Dynes had to say, to refresh my memory here.  !

24 JUDGE KELLEY: A page, or ten pages?

j e R w m n m irw.

25 If you want a few minutes, you can have that. Can you read

F 4-13-Wal 7806 I what you need to read in a few minutes?

2 WITNESS MILETI: Yes.

. 3 JUDGE KELLEY: We will take a five minute 4 stress.

5 (Short recess taken.)

- E nd 4 . 6 i Sun T fols.

l 7

8 9

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f 13 14 15 i i 16 I i

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i 18 t

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21 22 23 O 24 Ace-Federd Reporters, Inc.

25

7807

  1. 5-1-SueWalsH -

(Whereupon, the hearing is again in session at O

(_j 2 11:05 a.m.)

3 JUDGE KELLEY: Okay. We are back on the record.

4 Mr. Read can resume his cross examination.

5 BY MR. READ: (Continuing)  :

6 Q Have you had time to review this article, Dr.

7 Mileti? i 8 A (Witness Mileti) I had time to review the passage 9 in Russell Dynes' work.  ;

10 Q And do you think that is a fair summary of her 11 report?

12 A, It's accurate in terms of what it is that Russell

- N 13 Dynes chose to say about her work, yes.

14 JUDGE KELLEY: Could we narrow down exactly what J

15 -

we are talking about? Page 154, is that correct?

16 ' MR. READ: Yes, Judge Kelley. At the very top 17 there is -- well, the initial preamble began on Page 153, 18 i but --

I9 JUDGE KELLEY: Okay.

20 MR. READ: -- on the first line -- "Meda White..."

21 JUDGE KELLEY: You are referring then to the 22 first paragraph in connection with your statement, Doctor? i 23 WITNESS MILETI: Yes.

24 JUDGE KELLEY: Thank you. l A mi Reponers, Inc.

25 BY MR. READ: (Continuing) l l

s

7808

  1. 5-2-SueWalsN O White did select a number of organizations.

n-

- 2 Do you disagree with that statement, Dr. Mileti? That, 3 according to the list of organizations which is in this 4 paragraph here?

5 A In White's study, yes, she did select different 6 organizations.

7 Q And do you -- are there any omissions in this list  !

8 that Dr. Dynesgives? i 9 A I can't --

10 Q To your knowledge?

II A I don't remember. I didn't compare it to her 12 original work, and I don't remember the list of all organiza-() 13 tions. ,

14 O To the best of your knowledge and recollection, l'

15 ' are there any ondssions?

16 A I don't remember. I would guess not. There could 17 be one or two I suppose.

18 Q All right. Thank you. Certainly, if there had 19 been an important omission it might have -- scratch that.

20 Could you read off the list of organizations that  ;

21 Dynes identifies White as having studied? ,

What Dynes says is as follows:

22 A She selected a number s

23 of organizations, city government, police department, fire

() 24 Amfwerd Reprters, lrw.

department, state police, power company, gas company, radio l 25 stations, Red Cross, the Salvation Army, and civil defense.  :

i

7809 1

1

  1. 5-3-SueWal l O Uh-huh. And could you read the next sentence after

(')T

's 2 that, Dr. Mileti?

3 A "In each organization, an attempt was made to 4 interview one person of middle rank in the organization as 5 well as three persons of lower rank chosen by the every kth j 6 name method. In addition, the de jure leader of the organiza-'

7 tion during the disaster was interviewed."  !

8 0 If you will go down to the next paragraph, Dr. f 9 Mileti, and read the sentence that begins -- well, read the 10 sentence that begins with "While the sampling plan. . .? f II Do you see where I am?

I2 A Not yet. .

() 13 0 All right.

14 lj A "While the sampling plan she used overrepresented 0

15 f upper level persons who might be more likely to fulfill their i

16 organizational responsibilities, it would seem that,with the 17 excess personnel that Type I organizations usually have, 18 of so-called role conflict do not immobilize the consequences 19 organized disaster activity."

20 Do you have any comment on that, Dr. Mileti, as Q

21 being a correct or incorrect summary of White's research?  !

22 A I -- what would you like me to comment on? l 23 You stated earlier that you disagreed -- or, that Q

/'N 24 ,

()

u24w.,o nemnm. ire.

you had some disagreement with this summary. And I just  !

i 25 want to know if that includes this particular sentence.

I i

I 7810

  1. 5-4-SueWalshI MS. RIDGWAY: Objection. I think that's a m's-i I 2 characterization of what Dr. Mileti asserted. I think that 3 he said that in essense Dr. Dynes' characterization was 4 accurate so far as it went.

5 JUDGE KELLEY: Would you agree, or do you want to  !

l 6 '

rephrase or --

7 MR. READ: I will rephrase the question.

8 JUDGE KELLEY: All right.

9 BY MR. READ: (Continuing) 10 Q Do you agree or disagree with this particular 11 sentence?

12 A It -- I'm going to reread the sentence to my- .

O -

ee11- -

Id Q Okay.

15 A (The witness is reading the sentence.)

I0 No. I agree with that sentence.

I7 Do you agree with the part that says, "While the Q

18 sampling plan she used overrepresented upper level persons...?"

19 A I sure do. Yes.

20 Q Can you explain why you disagree with that?

21 A No. I agree with it. ,

Q Oh, I'm sorry. Okay. Thank you.

1 23 In these particular disasters, Dr. Mileti, that 24 ,

A poderd Reporters, Inc.

White studied, you are familiar with what kind of disasters

! 25 j they were?

i

7811

  1. 5-5-SueWalsN A I -- yes. I'm not familiar with the disasters,  !

l'

/ i IJ 2 per se. But I'm familiar with the ones that she picked to 3 study, yes.

4 Q And what kind of disasters were they?

5 A White used the Worcester tornado; she used Waco 6 tornado. She was picking tornadoes because she wanted to 7 make her work as comparable as she could to Killian's.

8 Let's see, the Waco tornado, the Worcester tornado, 9 and the Flint tornado.

10 JUDGE KELLEY: Is that W-a-c-o?

11 WITNESS MILETI: W-o-r-c-e-s-t-e-r.

12 JUDGE KELLEY: Comes out Waco?

13 WITNESS MILETI
That's Worcester, Massachusetts.

a 14 1

! Waco, Texas. W-a-c-o.

15 JUDGE KELLEY: Oh. I always heard Waco.

16 (Laughter.)

17 l WITNESS MILETI: I beg your pardon.

18 JUDGE KELLEY: Okay.

19 BY MR. READ: (Continuing) 20 Q A couple of nore questions, Dr. Mileti, about 21 this particular subject. For the recipient of emergency 22 information in a tornado disaster, is there an independent 23 means of confirming that such a disaster is actually taking lll 24 Ace FnG 3r;f Reporters, Inc.

place for the individual who receives the information?

25 A Confirmation is one of the most basic concepts to 1

l

7812

  1. 5-6-SueWal 1 understand how people go about performing perceptions in an O 2 emergency. And confirmation, for example, getting access to 3 repeated public information warnings or advisements is one 4 of the key processes.

5 One way that I would measure the degree to which ,

i 6 confirmation occurred with a person is to examine the emergency 7 information that they had access to. l l

8 Q But, isn't it true, Dr. Mileti, that merely repeat-i i

9 ing emergency information -- I'm sorry, scratch that question.

10 Isn't it true that in a tornado, confirmation may II be achieved in individual cases simply by looking out the 12 window and seeing a tornado?  ;

( 13 A Oh, yes. Tornadoes can be seen. And that can "p help the confirmation process.

15 However, confirmation can go on independent of 16 visible, physical cues, or clues, in the physical environment.

I7 '

For example, this needs to go on in alerting publics on sunny 18 days that a flash flood is about to happen in their community.

19 As has been the case in several cases.

20 But, isn't it more difficult in that sort of Q

21 situation to alert the public to the pending danger?  ;

22 A It requires, when a hazard is not visible, that j 23 emergency planners pay even more attention to emergency public

& 24 It doesn't

()

Aw Feder:1 Reporters, Inc.

information because it becomes more important. -

25 make the job impossible.

i

f 7813

  1. 5-7-SueWalsh'l Q But.it does make it more difficult, does it not?

2 A It puts more importance, and more attention needs 3 to be paid to it. It doesn't make it impossible.

4 It can still be accomplished.

5

1  !

22  !.  :

23 24 i l

Am-P &&l Reportees, Inc.

' l 4

25 . -

1 I  !

I

.aw- -r y-w p--g-- eg.g. ,.,y., ,, . ,,,. 7,m,m g,,.w,9 ,-p,y,,-_rg-9.,,p_,q,,_ yg-a-y-m.wr 7820 Sim 6-1 I still think you haven't really answered my 1 Q 1 2 question, Mr. Myers, which is there have been various

)

3 calculations about the probability of a nuclear accident, 4 most of which are on the order of one per one thousand 5 years, et cetera, in other words, very low probability 6 calculations.

7 Is it appropriate to tell the emergency workers 8 about these calculation 4 in advance of an accident?

9 A (Witness Myers) Yes.

10 0 It is appropriate.

11 A (Witness Mileti) The issue at hand would 12 suggest that this might affect how an emergency worker

- 13 would be behaving in an e'mergency. There aren' t many

' ~'

14 people that I knew of that have emergency jobs who don' t 15 recollect that Three Mile Island happened, and I think 16 you would be hard pressed to find a person in the United 17 States who wouldn' t believe that there can be on occasion 18 a problem in a nuclear power plant.

19 We also know that people in general tend not 20 to understand probabilities very well. It is either a low 21 Probability event or a frequent event.

22 0 While we are on the subject of probability, I 23 guess it is an appropriate time to talk about the training 24 that is referred to in your testimony.

Ac rol Reporters, Inc.

25 At Page 21 and 22, Mr. Myers, you talk about

7821 Sim 6-2 j the bus drivers, "All bus drivers who would assist with

() 2 school evacuation are being trained." Can you describe 3 that training, please?

4 A (Witness Myers) The training is one hour, the 5 training on basic radiation concepts, an overview of the 6 offsite emergency plans and training on the individual 7 specific role in the plan with a question and answer session 8 that could vary sometimes in length, depending on the amount 9 of questions.

10 0 And that is one hour of training which is given 11 how frequently?

12 A We have trained about two-thirds of the emergency 13 workers. The training will begin again in August at the 14 .beginning of the school year. And I also would like to say 15 that those emergency workers now going into the EPZ will get 16 an additional two hours training on the usage of KI and 17 dosimetry.

18 Q But for those bus drivers who will be going into 19 the EPZ, they will just receive the one hour of training?

20 A No. The bus drivers going into the EPZ will get 21 an additional two hours starting in Augsut or before the 22 plant goes on line.

23 0 How of ten will this be repeated, Mr. Myers?

24 A As necessary, and we would plan on having Ac rol Reporters, Inc.

25 a refresher each year.

7822 cim 6-3 j Q So that the people we are talking about here would 2

receive three hours of training every year?

3 A The bus drivers in leaving the EPZ would get one 4

hour, as I stated earlier. Those coming into the EPZ wonld 5

get one hour plus two, and this would be ongoing training 6

Program traditionally we hope at the beginning of each school 7 year.

Q Will the bus drivers, in the course of this 4 8 9

training will they be provided with literature about their 10 role in an emergency?

11 A Well, of course, literature, we will use training 12 aids of course in the course.

13 Q And how will each driver be made aware of his 0 j4 or her specific role in an emergency?

15 A The specific role, exactly what routes, et cetera, 16 will be made available to the school bus drivers by their j7 respective school bus supervisors.

18 Q So the school bus suerpvisor will provide the j9 individual drivers with their maps?

20 A Well, the maps will be furnished through the 21 state and the country together and then to the school system 22 in that particular entity on which they would make their selection of the bus drivers that are best suited to do this.

23 24 Q And how are those drivers selected?

Ac of Reporters, Inc.

25 A As I stated earlier, the school bus supervisors,

7823 Sim 6-4 1 the bus supervisors make this determination on a daily basis i '

, 2 of who drives what bus and what route. So we feel that is 3 in the best interest of the plan if they do this themselves.

4 Q So this would be decided on a daily basis?

5 A Well, it would be determined as needed by the 6 school bus supervisor.

7 Q But the actual routes that these people would be 8 driving would be determined on a daily basis?

9 A It is not a daily basis determination. It is in 10 accordance to the plan laid out and then it is the school 11 bus supervisor's job to keep this function intact.

12 O Is it f air to say that all the bus drivers who might 13 be called upon to perform an emergency task would have received 14 the training by the time the plant has loaded fuel?

15 A Yes, Plus I might want to add that we will be 16 . training some backup bus drivers.

17 O But their specific emergency role would depend on 18 the availability of people at the time the emergency occurred 19 and the particular routes that they were driving that day?

20 A Well, normally their routes don't change. It is 21 just like we don't pick what firemen will be out there in the 22 EPZ during certain functions. That is up to their respective 23 leaders of those particular services. It will be laid out 24 at the beginning of each school year which bus drivers will AcAeral Reporters, Inc.

25 be running, as for example, Route A or whatever it is, and

7824 Sim 6-5 1 then if there are changes needed, the school bus supervisor 2 will address this.

3 0 But the drivers who will be coming frcm Cary 4 and Raleigh would not be the regular school bus drivers, 5 would they that are assigned to a particular school in 6 question?

7 A From Raleigh?

8 Q From Athens driving to Raleigh?

9 A There are desginated drivers coming from Athens 10 and Cary.

, 11 Q And they would not be the regular drivers on l

12 those routes? -

l 13 A That would be made familiar with their routes

( )

14 in their training.

15 Q But that is not the route that they drive every 16 day, is it?

17 A I wouldn't think that that would be their 18 particular route that they would travel every day.

19 Q How many hours of training do these people receive 20 per year cotal from the school system? In other words, we 21 know that they will receive a maximum of three hours of 22 emergency response training. What other kinds of training I

23 will they receive?

24 A I would say a minimum of three hours, and then Ac r;l Reporters, Inc.

25 up to there of course they get their normal school bus driving

( i ,4

, 7825 Sim 6-6 1 training *that goes along with this,in how to maintain a s u

(') 2 bus and run a bus. Then any additiondl~ training would be 3 up to their respective school system ,or tha ,c~ountry.

4 ,

Q Mr. Myers, are you familiar with the State 3 of North Carolina response to the recent tornadoes that

.+

6 occurred last year in Southeastern North Caroiina?

7 -A Yes, I am.

7 8 Q Can you describe when the state received

/

9 information that tornadoes might strike?

a +

10 A Well, I was not in the Raleibh4EOC.at that 11 particular time.s I was stationed as a field man in Linkaton, 12 but at that time several members of the s(ate staf f were in 3 13 Ashville and wa pad people or course in the emergency center ,

V 14 it1 Raleigh.

15 _

I can' t recall the exact days or the time, but 16 as soon' as the occurrence happened there was'a rapid i

17 response to the areas. My'self, I went to the worst area I 18 guess, one of the / worst hit areas in the southeastern part 19 and actually saw people coming out from under'their homes 20 in the Maxton area and Red Springs, and established operations 21 in the Lollison area emergency center and worked around the 22 clock for about two straight weeks.

23 Q It sounds like you really served the state well, 24 Mr. Myers. But it is true, isn't it, that there really Ac ril Reporters, Inc.

25 wasn't any preliminary response to this disaster? In other

7826 Sim 6-7 j words there wasn' t any pre-impact response?

[v ') 2 A No, that is not true, 3 0 Well, could you describe the pre-impact response 4 to the tornado disaster?

5 A By which particular ---

6 0 By the emergency workers.

7 A The emergency workers did a tremendous job, and 8 the coun' ties,. of course that would be your first line of 9 response. Rescue squads were not only serving their own, 10 they were going into other communities and helping out. There 11 was massive amount of emergency management coordinators that 12 we brought from all over the state. As a matter of-fact, gs 13 I coordinated that effort. There was about 14 of them that L).

14 came and helped implement emergency plans and any of the 15 fatigue that might have set in with county workers, the 16 response was great. We also had all types of homeown.ers 17 coming in to help organizations to build homes. We had 18 probably some of the greatest response that North Carolina 19 has known.

20 0 But that was all post-impact, wasn' t it?

21 A Well, prior to the emergency, as conditions 22 warranted, there as some prior impact preventiveness. Of 23 course the situation started in South Carolina and came 24 right on up the state. So there was some knowledge of Ac A.rai n. porters, Inc.

25 tornadoes being within the area and the weather conditions,

7827 Sim 6-8 1 your cold fronts and your warm fronts colliding and things

!qj 2 of that nature.

3 A (Witness Mileti) It has been shown in some of the 4 research that has gone on that if one is thinking about the 5 general public and explaining whether or not they volunteer 6 to do emergency work, that largely is in terms of massive 7 numbers of people post-impact phenomena, but for emergency 8 organizations it is also a pre-impact phenomenon in the 9 evacuation period.or wanting -pdriod, for example.

10 In fact, one of the major problems has typically

-11 been in both pre-impact and post-impact periods of what to do 12 if you are an organization with emergency resposibilities with 13

()

7s 14 all the extra people that have come to work, at least too many people show up for work, and the problem is managing the

'15 too many people being there.

16 Q But in this context, Dr. Mileti, aren' t we talking 17 about an emergency in which perhaps one or two individuals 18 have been assigned -- well, I should ask this question of 19 Mr. Myers first.

20 In the North Carolina emergency plan, isn't it true 21 that we have bus drivers and backup bus drivers, but that 22 only one or two or a very small number of individuals will be 23 assigned a particular route in an emergency?

24 A (Witness Myers) No. All of the bus drivers will AcAertl Reporters, Inc.

25 be assigned routes, whatever is necessary to take care of l

7828 Sim 6-9 1 the population.

2 Q Right, but each particular route, how many people

)

3 will be responsible for each particular route?

4 A Well, you will have a designated bus for each 5 route, and then we have designated backup bus drivers to back 6 up the ---

7 Q So that we are talking about two people?

8 A No, we have I believe something like 57 backup 9 bus drivers.

10 0 But for each route, or we are talking about a 11 primary person and then a pool of backup people?

12 MS. RIDGWAY: Objection. Your Honor, maybe the 13 witness understands the question, but I am getting confused I 1 14 about whether we are talking about day-to-day routes or 15 whether we are talking about an emergency when everyone is 16 going like to relatively few reception centers or shelters, 17 and I guess I would just like a clarification of the question 18 about whether we are talking about how many backup drivers 19 there are on a daily basis when there are lots of different 20 routes or whether we are talking about an emergency situation 21 where there are only a relatively small number of shelters in 22 use with a relatively small number of routes.

23 JUDGE KELLEY: Could you clarify that?

l 24 MR. READ: Okay. In an emergency -- I will l Ac r:I Reporters, Inc.

25 withdraw the question, Judge Kelley, in that case.

7829 Sim 6-10 1 BY MR. READ:

s 2 Q When you say that there is a designated bus, 3 Mr. Myers, are there also designated backup buses?

4 A (Witness Myers) There is an ample supply of 5 designated buses throughout the system, plus there are 6 other designated bus systems, such as Trailways, if it would 7 ever be necessary.

8 0 To return to the 1984 tornadoes, Mr. Myers, you 9 have talked at some length about the post-impact activities 10 and that diere was some prior knowledge that these tornadoes 11 would strike. What actually happened in an emergency response 12 context before the tornadoes struck?

13 A Okay. Of course; you get your tornado watch,

'~'

14 and then when you get your tornado warning that means that 15 one has actually been sighted. As a matter of fact, I got 16 a call the first -- it was not confirmed as a tornado. The 17 first wind damage was in the Mecklinberg-Union County 18 area which was in my area at that time, and we course assessed 19 the situation and brought that situation to the leadership 20 at that time and made them aware of it. Of course, then 21 when you start seeing that you have got some type of tornado 22 damage and knowing that damage has been done in South Carolina, 23 you start montoring the situation and issue bulletins.

24 0 But in terms of getting the organizational people Ac r:l Reporters, Inc.

25 into the field before the tornadoes?

-~

j

7830 j A Well, y u don' t get your teams necessarily Sim 6-11

'~'

in the field prior to the tornadoes. Your emergency workers 2

from the counties are already there and on standby.

3 4

Tranditionally when there is a tornado watch, there are such actions that you would do. If you were a 5

law enforcement officer, it is recommended that you go 6

7 ahead and, for example, have your car filled up with 8

gas and you would see who is on call at the hospital during tornado watches and see if there is a possibility of any 9

10 large areas where there would be gatherings of people, 11 precautionary measures of that nature.

12 0 And were these precautionary measures actually taken in this tornado emergency?

13 A I"wasn't the director at the time, but as much 14 15 as possible when there are weather situations, certain are going to take precautions as necessary. Of 16 counties course, again in a tornado watch you get two warnings. You j7 18 get a tornado watch, which means that conditions are 19 possible for a tornado, and then a tornado warning means 20 that one has actually been sighted and that you should take 21 shelter.

22 0 And to get back to my original question, to 23 the best of your knowledge, were the appropriate emergency 24 measures taken prior to the tornado striking?

' Achril Reporters, Inc.

A Prior to the tornado striking, to the best of 25

l 7831 )

cim 6-12 1 my knowledge, those counties that had access to the information,

() 2 there would be prior planning or whatever you want to call 3 it that would take place there. Then of course when one 4 strikes you could have damage, or someting of that nature 5 that could hinder this somewhat. But to the best of my 6 knowledge, yes, there was.

7 Q But you would agree, Mr. Myers, that when a 8 tornado watch is in effect that the emergency worker has a 9 confirmation or at least has a strong possibility of a 10 confirmation of the dangerous sitaution independent of the 11 emergency bulletin?

12 MS. RIDGWAY: Your Honor, I object to this entire 13 line of questioning going any further. The Licensing Board O

'~#

14 here has focused this issue quite narrowly. I have tolerated 15 it for a while, but I think it has gone on too long.

16 We are here to focus on the issue of whether role 17 conflicts exist, and if it does and if it has anything to 18 do with how emergency workers behave, that is whether or 19 not they do their jobs and whether they abandon their roles, 20 and I just don't see the connection here.

21 MR. READ: Well, I believe Mr. Myers answered the 22 question and I am willing to end the line of questioning 23 there.

24 JUDGE KELLEY: Go ahead then.

Ac rtl Reporters, Inc.

25 MR. READ: Okay.

7832 Sim 6-13 j JUDGE KELLEY: I think we would have been I) 2 sympathetic to the objection, but under the circumstances 3 let's go ahead.

MR. READ: I don' t have too much more, Judge Kelley . i 4

5 BY MR. READ:

6 0 Dr. Mileti, you say that Mr. Dynes attempted 7

to set the record straight in your testimony, at page 14 8 of your testimony.

A (Witness Mileti) Yes, I said that. ,

9 1 1

10 0 Did he in fact set the record straight?

11 A No. He set the record straight for some people and not for others. In fact, to this day and likely into 12

~

r 13 the future people being concerned about their perceived

. (g/ ,

14 problems of emergencies are riddled with myths fed by 15 Hollywood movies about emergency workers not doing their 16 job and the public panicking and looting going on in 17 emergencies, et cetera. These myths pop up across the 18 land as concerns despite the labors of not only Russell 19 Dynes but of many others to try to set the record stright.

end Sim 20 So we keep trying.

Joe fois 21 22 23 Ac c 1 Reporters, n .

25

7-1-Wal, J. 7833 1 Q But leaving aside the popular media -- in (G

,/ 2 other words, your research is that he tried to set the 3 record straight simply means that he was trying to counter-4 act this mythological activity of Hollywood --

5 A (Witness Mileti) He was trying to speak 6 forward on how people actually -- that emergency workers 7 actually behave in emergencies.

8 Q And do you feel that his article is a fair --

9 is fairly accurate in that respect in terms of actual 10 behavior?

11 A Well it depends -- he talks in his book -- it 12 wasn't an article -- about a raft of different kinds of 13 behaviors.

14 I do agree that role abandonment is not a l

i 15 problem in emergencies if what we are concerned with is i 16 emergency workers doing their emergency job, and we are 17- talking about trained emergency workers who know that they 1

18 have an emergency job.to do.

l 19 Q Dynes breaks organizations down into fou'r j l

20 categories in this article, Exhibit 2 -- or actually this l 1

21 chapter, excuse me. Are you familiar with those four 22 types of categories?

23 A Yes. Type 1, Type 2, Type 3, and Type 4.

24 Q And Type 1 organization consists of -- could Am- al Reporters, Inc.

25 you simply describe briefly what a Type 1 organization is?

i

7-2-Wal, J. 7834!

1 A I will try. Dynes was attempting to develop

() 2 a typology which are a set of four classes which are ideal 3 types, none of which may actually exist in reality.

4 Some organizations may come close .to resembling 5 one type versus another type.

6 It is a way of classifying, but we in the 7 social sciences don't get to classify things as neatly as 8 physicists do, for example.

9 Type 1 organizations Russell Dynes was talking 10 about are organizations that are established and exist before 11 the emergency begins.  !

' l' 12 For example, fire departments who put out fires g 13 in emergencies exist before specific fires start.

{J u

14 Q Do Type 1 organizations have a -- is a major I

15 portion of their activity emergency response?

16 A It can be, yes. Some emergency response 17 organizations routinely do emergency work like fire i

18 departments.

19 Q When you say that the organization is established 20 and exists before the emergency, do you mean that the- j 21 organization as a whole or -- if we said that there is a l 22 group -- a small core group which is supplemented by other 23 kinds of workers in emergency, wouldn't that be a Type 2 24 group?

al Reporters, Inc.

25 A I would have to look. I think what you just

7-3-W21, J. 7835 1 described would be an expanding organization. Yes, that is

() 2 Type 2, where there are supplemental workers who come in 3 who don't work at that organization every day in the pre-4 disaster context.

5 Like the Red Cross, for example, where most 6 of its workers come from volunteers from the general public 7 in emergencies.

8 Q But the kind of organizations that are -- in 9 White's work, she is basically focusing on Type 1 10 organizations in the Dynes Typology?

11 A Well, I would have to go back and look. As 12 I recollect, some of them I would think are Type 1 13 organizations. Others may not be..

14 Q Such as -- would the power company be a Type 1 15 organization? It is one of the organizations referred to 16 by White. I 17 A I think most power companies would fall more 18 closely'to a Type 1 classification than any others.

19 Q Why is that?

I I suspect that -- and I know power companies 20 A 21 do a lot of emergency work in emergencies. I don't recollect 22 that power companies use volunteers to do the kind of 23 emergency work that power companies do. But I could be 24 wrong.

Ace. IA Reporters, Inc.

25 Q What about the -- how would you -- if you were

.7-4-W21 J.- 7836 1 to fit the bus drivers that we are talking about here into  ;

.2 one of these typologies, do you -- into which typology would 3 .you fit them?

4 A Well, bus drivers are people, not organizations, 5 so it would be hard to fit them into any one of these 6 classes.

7 Q The organization of these particular bus 8 drivers.

9 A I would fit them into schools, and schools 10 largely into Type 1.

Il Q BLit isn't it true the vast majority of this 12 particular -- of the school organization -- the vast majority of its time and energy are devoted to no'n-emergency

~

13 14 activities?

15 A I think the bulk of activities at schools are 16 devoted to education, I would hope.

17 Q Yes. And by, ' bulk,' you would categorize that 18 as being the great bulk. Would you agree with that?

19 A Yes. I think schools spend most of their time l

20 engaged in educational and socialization activities.

21 Q And isn't it also true that as the -- for 22 example, comparing a police -- let's take the example we are 23 talking about schools, let's compare that to a police 9 . 24 A . esw:s n.porwri, Inc.

25 department, Dr. Mileti, what kind of proportion of a police department's work involves emergency -- dealing with

7-5-Wal, J. 7837 1 emergencies?

,^

(_) 2 A My gosh, I don't know. I think most of what 3 the police do is in some way dealing with emergencies.

4 I mean, if you could think of a speeder as 5 a potentially -- potentially contributing to a possible 6 emergency, et cetera.

7 Fire departments, police departments, et cetera, 8 certainly have more of their activities devoted to emergency-9 type work than just schools.

10 Q So, they would receive a great deal more emergency Il training?

12 A Well, I don't know. I think pclicemen are

{} 13 trained in reference to doing police work, and that involves, 14 I am sure, some specific kinds of emergencies. What is 15 relevant is whether or not people who have to do an emergency !

i 16 job know that they -- know how to do that job, and know that  !

17 they have that job.

18 Now, it is nice to think about the police 19 department for specific emergency, like an emergency at a 20 nuclear power plant. They probably require a lot less 21 training, because they know how to already direct traffic.

22 You don't have to teach them that.

23 With the same regard, bus drivers know how to 9 24 Ace- oderd Reporters, Inc.

25 drive buses. They are not doing anything all that different.

But, yes, I think police probably engage in

7-6-Wal. J 7838 1 more emergencies than do school bus drivers on a routine 2 basis.

'3 I am guessing that. I don ' t really k now.

4 Q And their experience would be -- this 5 particular experience would be very important in responding 6 to future emergencies?

7 A I would guess that it would help. However, let 8 me say that it has long been established, and has been part 9 of general. knowledge in the nation , and in fact in many 10 FEMA documents it has been said that if you are putting 11 together an emergency plan, the best people to do the different 12 jobs in the emergency plan are the people who do those jobs

(]) 13 on a. routine basis. The best people to drive school buses 14 in an emergency are people who know how to drive school 15 . buses, and who have that job as their on-going routine jobs.

16 Q That is once they have arrived at the scene, 17 and are ready to do the job?

18 A No, I was talking about de

.ing who should drive l 19 the buses as part of the plan. They are the people who --

20 because they drive buses routinely, are the best candidates 21 for those jobs, with training, of course, specific to that 22 emergency.

23 Q Judge Kelley, could I have about five minutes

() 24 Ace Feller $ Reportett, Inc.

to collect my thoughts?

25 JUDGE KELLEY: We will take a sort of stretch in

7-7-W31, J. 7839 1 P lace, including the hall'if you wish, but let's not scatter F

2 to all corners of the building.

3 Thank you.

4 (Short recess taken.)

5 JUDGE KELLEY: We are back on the record.

6 MR. READ: I don't think this will take too much 7 longer, Judge Kelley.

8 JUDGE KELLEY: All right.

9 BY MR. READ: (Continuing) 10 Q Getting back to a question I asked you earlier, 11 Mr. Myers, you discussed the probability of nuclear accidents, 12 and I guess I would -- it is simply a yes*cn: no question.

Would it be appropriate to tell individuals

( 13 l 14 that the probability of a nuclear accident was so low that 15 they shouldn't worry about it?

16 A (Witness Myers) Ugh --

17 Q If you would answer yes or no, please, and 18 then if you want to explain your answer, go ahead.

4 19 A Yes. But --

l 20 Q It would be appropriate?

21 A But we address this, as I said earlier, in all 22 emergencies. The probability of the types of emergencies.

23 The probability is low. We don't tell them not to worry about f

14 O 24 e.e.,e n con.n inc.

it-25 The probability is fow, the probability is higher i

t.

7-8-Wnl 7840 1 in a hazardous material accident. We have one daily.

()

2 The probability is not as high in a tornado.

3 It is, of course, more on peoples minds now. The probability 4 of a hurricane.

5 We had one this past year, but there again as 6 an example possibly a lot of people are saying that the 7 probability is much higher this year. So, we are not telling 8 people not to worry about it. We don't know if one would 9 come, but we are making preparations, as an example, in that 10 area.

11 Q So it ~would not be appropriate to tell them not 12 to worry about it?

g 13 You have said that twice. If you will just --

U 14 you said you wouldn't tell them not to worry about it. You 15 did say that.

16 A What is the question now?

17 0 You did say that you wouldn't tell people, 'not 18 to worry about it.'

19 A Well, let me rephrase it. We would tell them 20 the probability is low.

21 0 Period.

22 A Period.

23 A (Witness Mileti) I have to add something, and 4 24 that is it is unclear to me at least as to what you mean by

s neporwes, Inc.

25 telling people not to worry about it.

7-9-W21, J. 7841 1 In reference to earthquakes in Calif,o,rnia, for ,

() 2 example, or tornados in Kansas, it is appropriate to tell 3 people not to worry about it on a routine daily life -- daily 4 basis.

5 They shouldn't worry about it. But that doesn't 6

mean that there shouldn't be plans, and that you shouldn't 7 take those plans seriously, and that people can get the 8 training they need to deal with those events when they occur.

9 They are all low probability events.

10 0 Well, I am glad you brought that up, Dr.

11 Mileti, because it seems like this whole idea of probability, 12 having plans, doesnet this all relate to the degree of 13 familiarity with the role of emergency worker in the -- in 14 an emergency situation?

15 A In some ways it can, and in some ways it 16 doesn't. If an emergency worker has played out that role 17 many times, they have that experience.

18 If the emergency worker hasn't played out that 19 role, then familiarity has to come from the training that j 20 they get, and what is important is that they become familiar 21 enough with that role to know that they have it, and how to 22 do their job.

23 If they know how to do their job, they will try 24 n.pon m ,inc.

their best to do it when the day comes, and if they know that 25 they have it, then they will likely do it.

i

7-10-Wal, J.. 7842 1 Q So.that -- strike that. Mr. Myers, I think I k '2 we have been over this before, but isn't it true that a 3 tornado is a visible event? ,

4 A (Witness Myers) To some.

5 Q To some.

6 A Some people don't see the tornado.

7 Q Okay. Is it -- can it be heard?

8 A- They say it sounds like a train.

9 Q Is the destruction that it does visible?

10 A Definitely. Well, yes, it would be.

11 Q And how would you compare that with a 12 radiological emergency? ,

.O 13 MS. RIDGWAY: Your Honor, I am going to object 14 again. Unless this can be tied specifically to the question 15 of whether or not role conflict occurs, and if so, what 16 effect it has on the behavior of emergency workers, -- that i

i 17 is, whether or not they do their jobs -- I just don't see 18 the connection, and I would object to it as irrelevant.

19 JUDGE KELLEY: Could you explain the relationship, 20 Mr. Read?

21 MR. READ: Well, I think Dr. Mileti just 22 discussed the concept of familiarity through experience, and 23 f amiliarity through training, and I am trying to connect the 9 24 Ase- ederal Reporters, Inc.

25 concreteness of the particular types of accidents that are well documented in historical record as opposed to the

7-11-Wal 7843 1 unfamiliar novel type of situation that we are dealing O 2 with here-

~

End 7. 3 Suo W fols.

4 5

0 1

7 8

9 10 11 12 O 14 .

15 .

16 17 18 19 20 21 22 23 i

d Reportets,1 .

25

7844

, #8-1-SueWalshl MS. RIDGWAY: Your Honor, I think he mischaracterizes

("' .

K 2 Dr. Mileti's testimony. I think Dr. Mileti's testimony is 3 directed to the worker's familiarity with his own role as f

4 opposed to the familiarity of the general public with what-5 ever the hazard might be.

i 6 JUDGE KELLEY: Any further comment, Mr. Read? l 7 MR. READ: Well, it's familiarity with the situa-l 8 tion, Judge Kelley.

9 And the particular -- the worker's ability to j 10 respond to the particular hazard or -- ,

11 JUDGE KELLEY: Perhaps you could restate the 12 question at this goint?

(} -

13 MR. READ: Well, perhaps I should go on to some-14 thing else right now and come back to this.

15 BY MR. READ: (Continuing) 16 O Dr. Mileti --

17 JUDGE KELLEY: Well, I would rather not. We've 18 heard a lot of argument. If you can't remember the question,  !

19 it can't be all that important.

- 20 If you can't restate it, let's drop it.

21 BY MR. READ: (Continuing) 22 Q Okay. Mr. Myers, isn't a radiological emergency 23 different from a tornado in that you can't see it approaching

()

e Am rwerei neporters, im.

24 or hear it, and that you cannot see its effects, its direct l 3

i 25 effects?

i i

7845

  1. 8-2-SueWalshi MS. RIDGWAY: Your Honor --

l 2 JUDGE KELLEY: That's the question, and the objection 3 is that it has got nothing to do with role conflict.

4 Can you explain to the Board what it has to do 5 with role conflict in some fairly direct way?

6 MR. READ: Well, just that the danger to the 7 individual and his family is tangible and direct in a tornado, !

8 and whereas it isn't in a radiological emergency.

9 JUDGE KELLEY: And so?  !

10 MR. READ: And so that effects -- that plays on Il the individual emergency worker's concern about his or her 12 role in the emergency as an emergency worker..

13 -

MS. RIDGWAY: Your Honor, Jr. Mileti has flatly i

~

14 testified several times that the emergency workers do their 15 l jobs if they know they have their jobs.

16 And it's with -- I mean, he has not established 17 this with regard to what kind of disaster. If he wants to 18 establish that, so be it. But otherwise, I think it's  !

19 l irrelevant.

l 20 JUDGE KELLEY: Well, if it develops that workers

' 21 like bus drivers did their job in a tornado, wouldn't it 22 follow a fortiori, if you will forgive me, that they will do 23 it in this situation, if the thesis is that they are more 24 worried about their wife and kids in a tornado case than they l Are Feder:1 Reporters, Inc, 25 are in a nuclear case.

i L_

r .

7846 98-3-SueWalsh1 Is that the thrust of your point, Mr. Read?

tm 5

s) 2 MR. READ: I believe I'm trying to go the other 3 way around, Judge Kelley.

4 JUDGE KELLEY: It escapes me, then. You were 5 saying that the threat to the family was more direct in the i

6 case of a tornado, correct?

7 MR. READ: It's more tangible.

8 JUDGE KELLEY: Tangible? Believable?  !

9 MR. READ: Yes.

10 JUDGE KELLEY: And then you are saying that it 11 follows that he would be less likely to go home? I just 12 don't understand your thesis.

13 MR. READ: Well, as I -- from my reading of the '

['J'T 14 plan, it wouldn't be -- the people would be going home, it 15 would be the people coming from home or from work to the 16 scene of the emergency and leaving from there with the school 17 children.

18 So, in that context, the perceived nature of the 19 emergency becomes very important.

20 JUDGE KELLEY: Is it your thesis that there is 21 more danger of bus drivers defecting from their duty and 22 going home in a nuclear situation than there is in a 23 tornado?

9 24 re nema neporters, ine.

MR. READ: Yes.  ;

25 JUDGE KELLEY: I'm going to allow the question. '

I

7847

  1. 8-4-SueWalsh1 Okay. Can you answer the question? i l

2 WITNESS MYERS: We don't believe that there would 3 be that great a difference, because North Carolians, we've 4 had some nuclear emergencies where North Carolians have 5 responded. We've had transportation accidents. One in i

6 particular in Cabarrus County where we've had a truck wreck 7 carrying radioactive material. We've had a train wreck in 8 Anson County carrying radioactive material, different types 9 of radioactive material found supposedly and labeled radio-10 active, and emergency workers have responded.

II WITNESS MILETI: There are several other comments 12 I have to add here, as well. And that is, there are --

/

13 well, for example, the bus drivers at Three Mile Island

(%)

v Id didn't abandon their roles. They went to the schools and did 15 ! what they needed to do when the emergency had begun.

16 There are other examples of emergencies that in-17 ! volve hazards that are somewhat invisible. For example, 18 some gas in Santa Barbara got into pipes that were going to I9 people's stoves in their homes that was -- could kill people 20 immediately, and the public couldn't smell it or detect it 21 or know that it was there. And emergency work went fine.

22 In fact, I have to add that in the history of 23 this nation, to the best of my knowledge, and I mean from

(~h (j 24 1776 on, there hasn't been an emergency where emergency Am Feder;l Reporters, Inc.

25 organizations haven't been able to accomplish what they needed

7848

  1. 8-5-SueWalab to accomplish because workers haven't showed up to do the .

r~\

(_) 2 job. The invisible character of radiation makes it more 3 important that we have emergency planning. And it makes it 4 more important that people devote some attention in emergency 5 planning for the general public in emergency information for ,

6 the emergency, et cetera.  !

7 It doesn't mean emergency planning doesn't work. f 8 BY MR. READ: (Continuing) i 9 0 But the basic question is -- or, Mr. Myers, the ,

10 question was, there is a difference, is there not, between ,

t 11 the two types of emergencies, tornadoes and radiological 4

12 emergencies?

A (Witness Myers) Are you talking --

(]) 13 u Q There is a difference? Mr. Myers, I'm asking -

15 you.

16 A Response is response. As long as they know their 17 job and they are trained, the people are going to respond to 18 the different types of emergencies. We don't try to 19 characterize the differences.

20 Q But there is a difference between the two types 21 of emergencies? .

t 22 A There is a difference between a nuclear accident 23 just like it would be a chemical spill or a tornado. And

() 24 Arv Federtl Reporters, Inc.

there is a difference between a tornado and a hurricane, or a 25 hurricane and a flood. I

7849 8-6-SueWalsh Q So, there is a difference; is that correct?

- 2 (Laughter.)

{

3 JUDGE KELLEY: Aren't you saying no? His question 4 is, is there a difference in terms of response. And if i

5 that isn't the question, I don't know what we are doing here. l l

6 And you are saying there isn't any difference; 7 is that right?

8 WITNESS MYERS: Right.

9 JUDGE KELLEY: Fine.

10 BY MR. READ: (Continuing) 11 Q Dr. Mileti, will you look at my Exhibit Number l?

12 A (Witness Mileti) I have it. Yes.

1 13 Q Turn to Page 98 of that exhibit.

14 A I'm there.

I 15 MR. ROCHLIS: Could that be identified for the 16 record?

!i 17 MR. READ: Oh, that is Exhibit Number 1, Chapter 18 6, " Disaster Behavior and Role Conflict" from the book, 19 Community in Disaster by William H. Form and Sigmund Nosow, 20 N-o-s-o-w, New York 1958.

21 BY MR. READ: (Continuing) 22 Q At the beginning of the second paragraph, it --

23 well, could you read the second paragraph, Dr. Mileti?

lll 24 c,w & n1x1 Reporters, Inc.

A Yes. As they wrote in 1958, "The location of the 25 individual at impact time seemed to have been of crucial

7850 l

  1. 8-7-SueWalsh1 "importance in his action patterns and in the incidence of tm ,

x- 2 conflict that he underwent. Despite the limitations and the f

i 3 number of persons interviewed from the various locational 4 categories, certain behavioral trends with regard to location 5 were apparent."

6 However, may I refer you to the second paragraph 7 on Page_96 of th'at same article where it says, "It should be '

8 recognized that reports of conflict by individuals did not ,

9 mean that their behavior was ineffective in the emergency.

10 Some persons who reported several types of conflict during 11 their various phases of activity were, for the most part, 12 objectively effective in their actions. Most individuals who 13 experienced some type of conflict, at one time or another,

((}

M l resolved the conflict rapidly and proceeded to perform vital k

15 i rescue functions."

16 l And if what we are talking about here is conflict i

17 or strain versus behavior, we have to be careful to keep l

18 those concepts separate. Conflict and strain does exist 19 in an emergency but it doesn't affect the behavior of trained 20 emergency workers to do their job.

21 They can have conflict or stress while they are 22 doing it.

23 Q And turning to the bottom of Page 99 of this n 24

() article, would you read that paragraph there beginning with u,1.+,o n.porim, Inc.

25 "A further examination...?"

k - _ _ _ _ _ _ _ _ _ _ _ . . _ _ . .

7851 48-8-SueWalsh A "A further examination of the descriptions given 2 by those who lived outside the area emphasizes the meaningful-3 ness of being able to define the social situation for one-4 self., Among those who lived and were outside the area when 5 the tornado struck (in most cases with their families) 6 practically all evidenced some type of conflict. Here we  !

7 would have a group of individuals who had become involved in 8 rescue, who were certain about their own safety and the f 9 safety of their loved ones, experiencing conflict. The 10 fact is that as they entered the damaged area they did not 11 know what to do, or they were too involved in assessing 12 the effectiveness of what they were doing.".

O 13 I might point out that these o d pieces f research 14 largely did what they did in communities that tried to under-15 i stand the behavior of publics as well as people they thought 16 should be emergency workers. There were very few emergency 17 plans in American communities at this time.

18 It's not quite the same thing as thinking about 19 the kinds of plans we have nowadays.

20 Q So that to state that the location of the individual 21 and his or her ability to define the situation in responding 22 to an emergency no 1onger applies?

23 A Well, if what you are talking about when you say O 24 w r.,i. .i n.po w . inc.

peop1e is peop1e in eenera1, that is humanity when they eo .

25 through emergencies, where you are in reference to an emergency.

7852

  1. 8-9-SueWalshI does have an effect on how you form situational perceptions

() 2 at the time. Yes, it does; did then; does today.

3 In reference to emergency workers, what's important 4 is whether or not they have a job, and they know they have 5 that job, and they are able to perform it in terms of explain-6 ing whether they do that job. ,

i 7 Now, if we want to study the perceptions of emergency 8 workers rather than their behavior, we could get off on any  !

9 number of interesting hypotheses. In fact, I likely will in 10 the course of my career.

II O Turning to Exhibit Number 5, would -- ,

12 MR. ROCHLIS: Please identify that for the record.

{} 13 BY MR. READ: (Continuing) id 0 -- which is " Coping with Victimization by Technolo-i 15 l gical Disaster." It's an article by Andrew Baum, B-a-u-m, 16 and others from the Journal of Social Issues, Volume 39, 17 Number 2, 1983, pages 117 and following.

IB Have you had a chance to look at this article, 19 Dr. Mileti?

20 A Yes, I have.

21 Q And the authors make a distinction between 22 technological mishaps and natural disasters in terms of 23 the individual response to that, psychological response.

() 24

,,, m i .i n.ime ... inc.

Do you agree that that's a valid distinction? '

25 A What these authors were doing was trying to i

i 7853 I i

8-10-SueWalshI distinguish between some kinds of technological emergencies l 2 versus some kind of natural emergencies.

3 Q And do you feel that they hcve made a valid 4 distinction? .

l I

5 A In some ways I agree with therc., snd in some ways  ;

i 6 I disagree with them. I disagree with them when they lump 7 all of the natural emergencies together and presume that 8 they are the same.

9 And on some fronts, I believe their technological 10 emergencies are different from some aspects of natural ones.

11 So, yes and no.

12 0 You say on some fronts you agree that technological i

emergencies are different.

(]) 13 14 Can you describe in what way?

15 MS. RIDGWAY: Your Honor, I'm going to object 16 again, and I have two bases for objection here. I was wait-l l 17 ing to see if I could discern where he was going to go with 18 this line of cross-examination.

19 First, I object on the grounds that this article, 1

l 20 as I read it, has nothing to do with either role conflict or i

21 role abandonment.

22 And the basis for my second objection is simply 23 that, to the extent that he is trying to explore natural versus

() 24

. 6 nearni Reporters, tric.

technological, I think again that we have already been through <

25 that line of questioning. It's getting repetitive. The i i

l

7854 i

  1. 8-ll-SueWaldh witnesses have established that in their experience and in ,

(

V) 2 their research it makes no difference.

' l 3 JUDGE KELLEY: Is this particular article cited 4 in the testimony?

5 MR. READ: No, Your Honor, it isn't. i 6 '

JUDGE KELLEY: Okay. Do you want to respond?

7 MR. READ: Well, I don't think the -- I think I ll l 8 will respond to Number Two first, which is that I don't think  !

9 the distinction between natural and technological disasters ,

10 per se is really critical at this point. '

II Admittedly, this article does not deal with role 12 conflict and role abandonment directly.

, But I would contend 13 that indirectly it points to some of the problems underlying

'd the basic theory that I'm trying to pursue here, which is 15 that there is -- because of the uncertainties involved in 16 this particular kind of disaster, that the historical record I7 is not necessarily conclusive.

IO JUDGE KELLEY: I expect the witness would agree I9 with that, that it's not conclusive.

20 Can you tie this to any particular part of his 2I testimony, either of the witness' testimony?

22 MR. READ: '

Other than to get back to what I was 23 gettinc Mack to -- getting at before, Judge Kelley, about 2d the radiological disaster or emergency -- excuse me, having

& I esterfA Reiporters, Inc.

25 a greater impact as it were on the individual, no.  !

7855 l#8-12-SueWal 1 JUDGE KELLEY: In the sense that it's scarier, f

k 2 more mysterious, and so on?

3 Is that the idea?

4 MR. READ: Pithily summarized, yes.

5 JUDGE KELLEY: Well, this marginal. We will let i I

l '

6 you pursue this briefly, Mr. Read, and see where it goes.

7 MR. READ: All right.

t 8 JUDGE KELLEY: Bearing in mind that there is some 9 merit in the objection. But we will let you have a go at  ;

10 it.

11 MR. READ: Could I have the Reporter read back

, 12 the question, please?

() 13 ,

(The Reporter read the record as requested.)

14 JUDGE KELLEY: Did you gentlemen understand the 15 question?

16 WITNESS MILETI: Oh, I'm sorry. I didn't --

17 JUDGE KELLEY: Go ahead.

18 WITNESS MILETI: -- know I was supposed to answer l 19 it now.

20 Yes. To the -- because they involve technologies 21 that would effect the kind of things people need to be trained 22 about. Other than that, I don't believe it would have any 23 different effect on the behavior of bus drivers.

O ts_j 24 It would not, I don't believe, have any different j 1 =-r e m i n+porwes,ine. j END #8 25 effect on the behavior of bus drivers.

Simons flws  !

i

7856 Sim 9-1 1 Q Mr. Myers, did you attend the hearing that took j 2 place following the emergency preparedness exercise?

3 A (Witness Myers) Are you referring to the public 4 meeting?

5 Q Yes, the public meeting.

6 A Yes, I did.

7 Q Are you familiar with the question that was 8 asked at page 68 of the transcript of that meeting regarding 9 that during the exercise a state official reportedly said 10 that "If this was real, I would go home to get my wife and 11 get the -- explitive deleted -- out of Dodge"?

12 A I am not familiar with that statement being 13 said at the public meeting.

()

14 0 Well, that question was asked and read into the 15 record. It wasn' t responded to. Is it your contention that 16 this simply would not happen in an emergency?

17 A Well, I have to go on my experience and knowledge 18 that the workers that I have on my staff and those of the 19 technical support people that support what we call the 20 state emergency regrose team, we have no knowledge or 21 experience of any individual not responding or doing their 22 duties in the past, and this encompasses quite a few 23 emergencies.

24 Q Dr. Mileti, do you share tha t belief ?

ter;l Reporters, Inc.

Ace-25 A (Witness Mile ti) I have no doubt that a person

7857 Sim 9-2 i could say that. In fact, one could conceive of getting many

'~'

2 People to speculate about that kind of a response in a O' i 3 future emergency of any sort. You could even structure 4 a questionnaire, and how you word the questions depends on 5 the percentage that you could get which might prophesize 6 that depending upon the scenario that they happen to be 7 dealing with.

8 But we in the social sciences have known since 9 the 1930's that what people say about their behavior and 10 their actual behavior don't necessarily coincide, and I have 11 no doubt that some emergency workers, bus drivers, for 12 examP l e, could be found who would say that they wouldn't 13 drive a bus in an emergency even. But I don't think, twat is v

14 going to affect whether or not they actually drive the bus 15 when the time comes. Those aren't the significant factors 16 that determine behavior in an emergency.

17 Q But didn't some doctors and nurses actually l 18 flee the Three Mile Island area in an emergency?

19 A Well, I am glad you brought that up because I am 20 happy to talk about it. In my opinion, absolutely not. There 21 are several publications that have been published by M.D.'s 22 af ter the Three Mile Island incident that accounted stories i

l l 23 about what happened in local area hospitals.

24 Now these hospitals, mind you, had no emergency

, AAwol Rgehrs, inc l 25 P l ans for radiological emergencies. Friday came along and l

L

7858 l l

l Sim 9-3 1 they had a minimal staff routinely on the weekends and y 2 released most of their staff. That Friday coincided with the i l

3 beginning of a major medical convention in San Francisco 4 and hordes of them lef t Harrisburg to go to San Francisco 5 to go to the medical convention, and later on in the weekend 6 they found out they wanted to evacuate the hospitals. They 7 said it would have been nice to have more people around to 8 engage in that evacuation, but they never said to the people 9 in San Francisco come back and they never said to the people 10 who had left for the weekend, which is what I would have done II if I lived in Harrisburg, I would have gone someplace else, 12 that they should come in and help. So they didn't know x 13 that they had a job. -

(- i 14 This is another case where we are looking at who 15 we would point to being appropriate emergency responders and 16 they are people who didn' t know that. they had an emergency 17 job and they were doing something else, and it is unfair 18 to call that role abandonment. They had no role to begin with.

19 Even though there are some who chose to interpret 20 that set of circumstances as role abandonment, I don' t consider 21 it role abandonment and I have also talked to some of the 22 people who were involved in those actual studies and they 23 don't consider it role abandonment, but there are some 24 sociologists around who chose to call it role abandonment Acger: I Reporters, Inc.

25 because it suits their preconceived bias and interest.

7859 Sim 9-4 j By the way, I don't think M.D.'s should do

() 2 sociological research.

3 (Laughter.)

4 MR. READ: I think that concludes the questions 5

I have, Judge Kelley.

6 JUDGE KELLEY: Thank you, Mr. Read.

7 It is 12:30. Why don't we say a quarter of 8

2, slightly more than an hour, when we will resume here.

9 Thank you.

10 (Whereupan, at 12:32 p.m. the hearing recessed, jj to reconvene at 1:45 p.m., the same day.)

12

)

14 15 16 17 18 19 I

20 21 22 23 Ac .rzi n porters, ac.

25

7860 Sim 9-5 1 AFTERNOON SESSION

() 2 (1:47 p.m.)

3 Whereupon, 4 JOSEPH F. MYERS 5 and 6

DENNIS S. MILETI 7

resumed the stand and, having been previously duly sworn, 8

were further examined and testified as follows:

9 JUDGE KELLEY: We would like to go back on the 10 record.

11 At the lunch break Mr. Read had concluded the 12 cross of the present panel, and Mr. Eddlgman is going to 13

'T be picking up in Mr. Read's stead for the remainder of the

~J 14 contention of this afternoon.

15 Let's go to the NRC staff and FEMA. Are there I 16 l questions?

l t

17 l MR. ROCHLIS: Yes, just one gustion, Mr. Chairman.

18 l CROSS-EXAMINATION

, BY MR. ROCHLIS:

l INDEXXXXXX Q Dr. Mileti, through your studies, or through 21 your personal studies or studies that you are familiar with, 22 have you come across any difference as to the emergency 23 response capability of the sworn public officials, such as 24 Ac eni n porten, ine.

a Police officer, who was also compensated versus say the 25 bus driver or rescue squad worker who is not a sworn public

l 1

7861 1 ficial?

cim 9-6 a, 2 A (Witness Mileti) In general, no. There was 3 one case where the county employees were required by law 4 not to participate in emergencies, and that is the only instance 5 I can think of. But in general how much a person gets paid 6 has nothing to do with whether they do an emergency job or 7 not.

8 0 Well, how about whether they are sworn such as 9 a sworn public official, such as a police officer or a fireman, 10 versus a compensated worker who is not a sworn official?

11 A No. To the best of my knowledge, tha t wouldh~' t 12 make a difference. .

\

13 0 'Would that affect role strain?

L ,'

14 A I don't know how I can answer that question. I 15 don' t know of any studies that would enable me to answer that 16 question. I don't think it would affect behavior. But whether 17 or not it would affect role strain is an interesting question, l

18 but I don' t think it is relevant in terms of behavior.

19 Q Are you familiar with any studies dealing with the 20 National Guard or Army Reserve response capability to 21 emergencies?

22 A There is a history oi research on the National 23 Guard. The earliest study I can chink of is from back in the 24 50's. A variety of studies havce looked at organizational AcAer;l Reporters, Inc.

25 response, and when organizational response in emergencies

7862 Sim 9-7 1 has included the National Guard they have looked at that.

7 2 0 What kind of job has the National Guard done 3 in responding to emergencies?

4 A I suspect that one could say that, at least 5 in terms of the emergencies that I am familiar with, that 6 the National Guard has done what the National Guard was 7 supposed to do.

8 MR. ROCHLIS: Those are all the questions I 9 have.

10 JUDGE KELLEY: Thank you.

11 BOAMD EXAMINATION INDEXXXXXX 12 BY JUDGE CARPENTER 13 0 I guess I would like to begin with a couple

i .

14 of questions to Mr. Myers.

15 A point of information, Mr. Myers. In the 16 recently conducted exercise or in the exercises that are 17 planned for the future do the adult school bus drivers 18 actually drive to their assigned schools as part of the 19 exercise? I unders tand that you don' t actually 20 take the children out of the school and so on, but do the 21 bus drivers actually go through that part?

22 A (Witness Myers) During the last exercise, no, 23 they didn't. We have had exercises in the past of other 24 neulear plants where we have actually used some of the

' Ac eril Reporters, Inc.

25 bus drivers that would be executing during a real emergency.

t

7863 Sim 9-8 1 0 Well, I would like to leave that question right

( ) 2 there for just a moment and go on to ask what I hope will 3 be foundation questions and turn to you, Doctor.

4 You have emphasized I think in your testimony I 5 that the training is very important because then the indi-6 vidual knows that they have a job to do. Is that a fair 7 characterization?

8 A (Witness Mileti) Yes, as well as how to do it.

9 Q To what extent to you think training might 10 produce discipline /in the sense of an individual, no matter 11 what they feel would carry out an assigned duty, discipline 12 in that sense?

13 A I am sorry, but I don't think I understand i /

14 what you mean by discipline. Do you mean being able to 15 do it effectively?

16 Q And I think you have emphasized the difference 17 between observed behavior vis-a-vis the feelings that the 18 indidividual may have while he is behaving or she is 19 behaving in a particular way.

20 A Yes.

21 Q I am trying to focus on the individual behaving 22 in a particular way even though they may have feelings, 23 a number of feelings that are perhaps coming and going 24 which would tend to divert their behavior into another AcQerd Reporters, Inc.

25 direction, but becuase of training they are disciplined

7864 l

Sim 9-9 1 to t,he point of behaving in the way that thejob requires.'

2 A I think I understand your question now.

)

3 Q For example, a military recruit the first day 4 in camp is not the soldier he is going to be sometime later, 5

that kind of discipline but not to that extent, but the 6

notion that training can cause the development of a 7

characteristic that we most commonly call discipline.

A I would answer your question in two ways. Yes, 8

9 I think training could help someone become more comfortable 10 with an emergency job, just as experience might for people 11 who experience an emergency role time and time again.

12 Additionally, however, training can also, in 13 reference to this role, conflict or abandonment issue, help .

1 .

i '

14 emergency workers talk things through with their family 15 and have the f amily make some contingency plans about what 16 to do in an emergency and therefore freeing up the emergency worker from concern.about their family during the emergency.

17 18 0 Well, with that broadbrush background, I would

~

19 like to ask Mr. Myers about .the State of North Carolina's i

20 Posture about this and whether he sees any merit in the 21 motion that if these school bus drivers do actually go 22 through the exercise that this gives them some time to think 23 about what they are doing, e t cetera, and perhaps reinforces 24 the need to talk to their family and to resolve these Ac er;l Reporters, Inc.

25 conflicts because, while it is an exercise, it does make l

7865 Sim 9-10 l 1 it more real than sitting in a classroom and simply listening

() 2 to somebody say well, you may feel that you ought to talk 3 to your family about what you are going to do.

4 To the extent that I have been rambling on 5 in trying to create a background, do you feel that for the 6 Harris facility that the exercises in the future will 7 include requiring the adult school bus drivers to actually 8 drive to schools and actually go through the exercise?

9 A To answer your question, it could be done if 10 necessary. We really haven't, like I said, haven't felt 11 it to be necessary. We have felt that the training they 12 have gotten has been ample because they do drive in other 3

13 types of emergencies where .there are early closings of' 14 schools, whether it be weather conditions or other types 15 of emergencies. So they are exposed to certain adverse 16 conditions.

17- We felt tha t this would meet the requirement 18 that they did have ample training. There have been case, 19 as I said, in the other drills where we have actually done 20 some random sampling of bus routes, but not necessarily 21 all of the bus drivers.

22 O But that was more from the point of view 23 of sampling rather than an integral part of the training 24 program, and you just wanted to see what the response was?

Ac il Reporters, Inc.

25 A Right.

7866 Sim 9-11 1 Q I am going to continue along the same line,

( , 2 but it may not be obvi6us from' the next couple of questions 3 that I am.

4 Mr. Read asked you about whether you advised 5 these bus drivers to worry. I would like to ask, do you 6 know what dose the bus driver, or what radiological dose 7 these bus drivers might receive in the course of going to 8 a school to pick up children?

9 A My job, it doesn' t ercompass knowing all of 10 the exact details, but I am supported, because no decision 11 is made totally alone. Our Radia tion Protection Branch 12 would be working with me in making these types of assessments, 13 does projections that the e'mergency worker, and in this

~

14 case the school bus driver may receive. So I would 15 depend on my technical support people from the State's 16 Radiological Branch to give me this type of information.

17 Q Of course, we are at a disadvantage from a 18 technical point of view in that there has onlY been. one 19 incidence in the history of the nuclear industry, and it is 20 pretty hard to talk about the statistics when the sample 21 size is one, and I am referring to Three Mile Island, and 22 there haven' t been enough events like that to talk with 23 any confidence from real experience.

24 I have the impression that for most accident Ac r;l Reporters, Inc.

25 sequences evacuation would occur before there is any I

7867 Sim 9-12 1 release of radioactive materials. Do you agree with that O. 2 imgreseien2 3 A In North Carolina it is basically our plan that 4 if there is a release that we would try to keep people 5 in place until the situation was determined to be safe. If 6 there is not enough time to evacuate, and of course there 7 are other factors that you.would weigh in evacuation, not only the. projected do' sage, but you would' look at weather

~

8 9 cbndition's'& gain and the feasibility of evacuation versus 10 in place shelter.

11 So we will work on the assumption that if 12 there is an immediate release, that we would stay in place

~

13 before there would-be an evacuation, if there would be 7s

(.

14 one at all.

15 0 I notice that you are the author of a publica-16 tion entitled "The Operation And Guide For A. Fixe'd. Nuclear 17 Facility Accident" according to your capability profile.

18 A Yes, sir.

19 Q I was wondering in the course of being the 20 author of that document whether you looked at the frequency 21 for these , and I think .one can only call them hypothetical 22 accidents or hypothetical emergencies, in which there is 23 an early release of radioactive materials vis-a-vis the 24 frequency with which there might be a release 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

, AAwil Rqmows, Inc 25 or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> into the accident. Did you look l

i

7868 Sim 9-13 j at that at all?

) 2 A Yes, we did.

3 Q This document you are alluding to, we addressed 4 in notification and warning the concept of operation when we would evacuate and we wouldn't evacuate, and this 5

6 Particular document was designed for emergency workers 7 Primarily and a lot of elected officials to make them more aware of the situation. It was developed for the nuclear 8

9 power plants around the Piedmont section of the state, 10 the Charlotte area primarily.

11 Q But without the aspects that are geographically 12 specific, did you discover that it is more probable that

,.- 13 some radioactive mdter.ials would be released very early i

~

14 on in an accident sequence or at some numbers of hours 15 into the sequence?

16 A It would be numbers of hours. It would be an 17 hour1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br /> determination more probably than it would be a build-18 up situation where there would be enough time to conduct 19 an evacuation. That is why we have done time and motion 20 studies and used these figures in our drills or in a 21 real situation to address which areas we would evacuate 22 first if we had enough time to get the people out of the area and based off the certain peaks of the season and 23 24 so forth.

Ac eral Reporters, Inc.

25 Q Would you say that in this area of hypothetical

7869 Sim 9-14 1 even.ts of the variety of accident sequences that one could (s) 2 hypothesize that evaucations where an individual receives 3 doses during the evaluations are less frequent than cases - . - _

4 where people are evacuated and they receive no dose because 5 the evacuation was begun during the build-up period and the 6 release was anticipated and therefore people lef t before 7 there was any possibility of exposure, and I don't mean 8 to answer the question by the way I am asking it, or is it 9 the other way around, that you would expect in most cases 10 people will get some exposure while they are being evacuated?

11 A That would not be the way that we would want to 12 conduct our evacuation in North Carolina because, as I said 13 earlier, we would stay in in-place shelter if we could U,s 14 not evacuate a zone in thatgiver period of time that the 15 time and motion study had determined. We stay in place.

16 In other words, we do not anticipate evacuating people in 17 the middle of a release.

18 Q Do you in your training of these adult school 19 bus drivers make it clear to them that that is the situation'/

20 that they are not going to drive into some invisible hazard?

21 A In our plan overview we address the total concept 22 of operations which would address when we would evacuate 23 and when we would be in place shelter. So, yes, it is 24 discussed in the section of the concept of operations of Aceeral Reporters, Inc.

25 the overview of the plan.

7870 Sim 9-15 i O Well, what I was focusing very specifically on I[

us 2 was in addition to this overview of the plan, this very 3 specific aspect of the hazard that these individuals might 4 have to weigh in looking at their value systems, for them 5 in particular.

6 A Yes, we address this issue to the emergency 7 workers, plus we plan on, as I said earlier, when we get 8 into the more advanced training for those particular 9 individuals that would going into the' emergency planning 10 zone the use of KI when it would needed and the use of 11 dosimetry, which is basically designed for self protection 12 readings, and then those that are inside the EPZ, we would 13 not be asking for an evacuation if there was a relaese,

(~)3 u.

14 Q Are these adult school bus drivers that we have 15 been talking about in the group that you would call the 16 emergency workers?

17 A Yes. We consider them as emergency workers.

18 Q Do they have dosimeters?

19 A The instruments themselves will be made available 20 through the local emergency mangement office and the 21 Potassium iodide also, and it will be their job to pre-stage 22 or however their particular procedures call for, to get 23 the equipment for the KI to the particular individuals 24 you are alluding to.

Ac ol Reporters, Inc.

25 JUDGE CARPENTER: I think I will stop there, and

7871 Sim 9-16 1 I may come back in a minute.

/

j 2 BOARD EXAMINATION INDEX 3 BY JUDGE KELLEY:

4 Q I have a few rather miscellaneous questions 5 on miscellaneous points.

6 Mr. Myers, on the point of training I think you 7 said that the bus drivers got like an hour a year and there 8 is another category that got a couple more hours a year 9 in terms of training. It occurred to me that if I had 10 a one-hour training session that six months later I might 11 forget quite a bit of it, and I wondered do the buses them-12 selves have any sort of card of what to do if there is a 13 radiological emergency or handy reference thing that a .

',' i 14 bus driver could turn to?

15 A (Witness Myers) There will be a brochure for 16 the students of the schools, just like the brochure going 17 to the general public on, but I think you are saying right 18 in the bus itself.

19 Q Yes. I am asking about something tailored to 20 the bus drivers, something very simple, four or five bullets, 21 do this, do that and don't do this and don't do that, and 22 so on.

23 A No. sir.

24 Q Okay.

Ac erzl Reporters, Inc.

25 Dr. Mileti, I gather that of the various studics

7872 Sim 9-17 you cite that none of them really focused directly on the 3

( adult bus driver per se, right?

) 2 3

A (Witness Mileti) No. There haven' t been, to 4 the best of my knowledge, studies on bus drivers in emergencies in particular. They just looked at all 5

6 emergency workers, including bus drivers.

end Sim 7 -

Joe fols 8

9 10 11 12 es 13 U 14 15 16 17 s

18 19 20 21 l l

22 23 Ac erIl Reporters, n.

25 l

10-1-Wal, J. 7873 1 Q You can't point to a particular study and

) 2 say this is really right on target as far as our concern?

c 3 A  ! Witness Mileti) There is no one study on 4 bus drivers in particular, no.

5 Q I was wondering -- drawing on my own rural 6 background some years back, the Iowa buses anyway during

- 7 the day were driven by farmers, and the farmer would take 8 the kids to school and drive back home and park it in the 9 yard and go out and plow all day, and if something happened 10 I guess he would run to the bus and go back to school.

4 11 That kind of a bus driver wouldn't have any 12 conflict because he is home already, where the bus is. ,

13 Where are the buses in this, case? For the 14 adult bus drivers who might be called upon? Are they in 15 some central lot, or do they take them home?

16 A (Witness Myers) The buses are at different

{ 17 places. Some of them are in place within the EPZ itself.

18 Some within the ten mile emergency planning 19 zone.

20 Q In place --

21 A At the respective schools that would be 22 evacuating.

23 Q We got a lot of bus drivers who are students, t.

24 right?

Am- WAgomn,lm. .

25 A Yes, sir. In other words, in North Carolina

10-2-Wal, J. 7874 1 some of the buses stay right there at the school.

r'S

(,_/ 2 Some of them will have to be augmented with i 3 buses.

4 Q My question really is this: Of the adult bus 5 drivers, not the people who are there in school already, but 6 of the adult bus drivers that we are focusing on, -- at home 7 or at work -- they work at some machine shop, who knows what 8 -- is the bus right there, or do they have to go some place 9 to get it?

10 A They would have to -- in some cases they would 11 have to go get it. I might say there are something like 12 21 adult bus drivers, I believe, that work right there within 13 the ten mile EPZ itself, and 12 of them work for the school I 14 system in some various capacity.

15 Q I am not stating my questions very well. To ,

i 16 make my point -- my point really is the bus that is at home,  !

I i

17 so that there is no conflict, is there any such person, or j i

18 can we just forget about that as a variable?

19 A In some cases they would be at home. l l

20 Q There are a few. l l

l l 21 A Yes.

22 Q But not a great number; but a few?

23 A A few.

24 Okay. I want to ask Dr. Mileti -- as I am sure Q

el Reporters, Inc.

! 25 you are aware -- we hear expert testimony from a pretty wide

1 10-3-Wal, J. 7875 1 range of disciplines.

(h

(_) 2 And I think that it is fair to say that it 3 comes with some varying degrees of certainty. If you have 4 an expert who is going to tell you what the pressure will be 5 on the containment under certain postulated circumstances, 6 and he says it will be 85.3 pounds per square inch, that 7 is exactly what he means.

8 And he will maintain, I suppose, that he is 9 very positive of that. And he can show you equation and 10 show you the data and that is all pretty well laid out.

Il That is sort of a QED type demonstration. ,

12 Then we get other kinds of expert testimony.

{} 13 It was said at least some years ago that our risk analyses 14 were very interesting, but no basis for regulation because 15 there wasn't enough data for them. The Rasmusson Study ,

l 16 was criticized on that basis. I am sure you know about 17 that. ,

18 Ihaveheardtestimonyfromsiesmologiststalkinh i

19 about earthquakes, where you get a 7 in the next forty years, 20 and they vary among themselves, but I think most will concede 21 that the data base on big earthquakes is pretty small. And 22 that they can't make terribly confident predictions.

23 On a sort of scale of say one to ten, when we 9 24 Ace- oderst Reporters, Inc.

25 say to you what are the chances of these adult bus drivers doing their job, and given the data base that you have got,

10-4-Wal, J 7876 1 are you giving us a very strong conclusion, a sort of medium

() 2 range, or an educated guess, or -- where would you characterize l 3 your own bottom line in terms of certainty?

4 A (Witness Mileti) Well, let me answer that 5 question in a couple of ways.

6 First of all, in refe,rence to the things we 7 sociologists study, which is human behavior, it is 8 theoretically possible that you could think a behavior up.

9 For that behavior to occur some time. So, it can be an 10 exception to anything a sociologist says.

11 Given the track record of emergency workers in 12 emergencies, and knowing that the factors that guide whether

{} 13 they do their job or not is how much they buy into that job, 14 how well they have been trained, whether they know they have 15 that job or not, I feel very confident.

16 Now, I couldn't pick a number and say it is a 17 9 versus an 8, versus a 10. But I can say with confidence, 18 and I think most of my colleagues -- all of my colleagues that l

19 are very familiar with this area of research -- would agree 20 that if the training is sound, the evacuation of school children 21 on school buses would not be a problem in an emergency at the 22 Harris plant.

23 There may be some problems. It may be that the l h 24

' Am-rederal Reporters, Inc.

volunteer bus drivers, or the back-up bus drivers report in 25 when they don' t need to report in. That is more likely the

10-5-Wal, J. 7877 1 kind of problem that might be encountered with bus drivers.

() 2 Not that there are children left at schools that 3 should be evacuated. I feel very confident, but it is hard 4 for me to put a number on it.

5 0 Okay. Thank you. I just have one sort of 6 picky question. On Page -- excuse me a minute. On Page 20 7 of your testimony, and this is an answer that is coming from 8 Mr. Mileti -- Dr. Mileti -- the middle of the page, where 9 you say: Thus, while it is possible that some few might 10 be found; the phrase, 'some few, ' does that mean very few 11 or quite a few?

12 A Actually, that, number could vary from place to 13 place, depending upon what is going on, and what they are 14 being asked. ,

i 15 For example, right now if we asked that question,:

16 or a year ago if we asked that question in Suffolk County, I 17 bet we would find more than if we asked that question two 18 years ago in Coffee County.  !

19 One could always find some who would say that.

20 0 Well, I guess I am still after whether -- is 21 the idea you are trying to get across that this would be i i

i 22 unusual, or that this would be pretty common.

23 A It would be to be expected that you would find 24 people who would say they didn't want to participate in an l 7

Aa- el Roorwrs, inc. l 25 emergency response. l

10-6-Wal, J.

1 I would be surprised if there were a place where you didn't find any.

([ ) 2 3 Q So, it is closer to quite a few than very few?

4 A I think that could vary across time and place, 5 depending upon what is going on when you ask.

6 For example, if there is a raging controversy 7 about the licensing of a nuclear plant, you would find more I 8 saying, no, I wouldn't respond in an emergency than if there 9 weren't.

10 0 But here you are testifying sort of in the j 11 abstract. You are not trying yourself to any set of  !

i 12 circumstances, so some few was intentionally a little vague?  !

13 A I didn't mean to specify a number, To say it 14 would be a large number or a small number. I would expect 15 if we went around asking here, in reference to the Harris 16 Plant, that there would be people saying that they wouldn' t 17 perform their emergency role.

18 Q One of the reasons it caught my eye, I remember ;

19 reading about -- I guess I had a record, a jazz record, some a

l 20 jazz group, and one of the players nickname was Some Few 21 Clothes, as in Joe, Some Few Clothes Joe, and that meant he i

22 had a lot of clothes, not a few. j i

23 So, I wondered what you were after here.  !

24 I think you answered it, though. j s n worim.im. j 25 We have redirect at this point.  ;

i l

l i

10-7-Wal, J 7879 1 MS. RIDGWAY: Yes, Your Honor. Before I do o

k-) 2 redirect, I would like to clarify a misimpression that we 3 may have left on the record before lunch.

4 There was a question that was posed by Mr.

5 Read, where he quoted from page 68 of the transcript of 6 FEMA public meeting held after the May 17-18 exercise, and 7 just for the record, I wanted to clarify that what he was 8 reading was a direct quote from a written question that l i

9 was posed by a member of the general public that is from the l 10 audience at the meeting. I 11 It was not a statement by a public official

  • 1 12 there at the time of the meeting. It was merely a stgte j I

(^T 13 official reading a question that had been posed by a member  !

x/  ;

14 of the general public. i 15 JUDGE KELLEY: Okay.

16 REDIRECT EXAMINATION

'17 BY MS. RIDGWAY:

18 Q Doctor Mileti, Mr. Myers has testified that  !

19 bus drivers will receive a minimum of one hour of training.

20 Could you comment on the adequacy of that training to assure 21 that workers will do their jobs? l 22 A (Witness Mileti) The amount of time that should !

23  :

be devoted to emergency training should be in proportion to lll 24 Am FMwel Rmorwrs, inc.

what the emergency job is.

j 25 And it is hard to say an hour is too much or too '

I i

l

10-8-Wal, J. 7880 1 little.

r'x

(-) 2 What is important in reference to bus driver 3 training is that those bu s drivers in that training learn 4 how to drive a bus.

5 Well, they already know how to do that, so that, 6 I presume, doesn't need to be addressed. And that they know 7 they have a job to do in an emergency at the Harris Plant.

8 Now, I have looked at the check list of topics 9 covered in the training for those bus drivers, and although 10 I am not familiar with how those specific items are carried 11 out in reference to the training, the check list includes a 12 whole lot more than I would say is essential for bus driver .

(^)T

\_

13 training, so it covers their role, suggesting that they know  !

14 what it is they have to do and how to do it.

i 15 It gives them an overview of emergency planning l 1

16 and describes nuclear risk a bit, and those are the three 17 important elements to my way of thinking that training should 18 cover.  !

19 So, from that point of view I think it is quite

! 20 adequate.  ;

21 Q Doctor Mileti, could you comment on the necessity:

I 22 for all emergency workers, including the group we are focusing i

23 on here. Bus drivers to participate in an exercise in order j l

24 to assure that they will do their jobs?

l Am. .s.rw neporwrs, inc.

25 A I suspect that the exercise is important in the l

I l

i 10-9-Wn1, J. i e . ,

7881

'g  :

I

  • I sense that it helps people that have emergeddy jobs come to-2 understand them when they don't already know them.

,1 3 And I don't see that any harm would come from 4

havingbusdriversdrivetheevacuationroyte,butIdon't 5 know that it is essential. l

$ ~

(.

6 I suspect it depends on how familiar those bus ,

7 drivers are with the roads in and around where they live.

8 Q Doctor Mileti, could you discuss Shether past-9 emergencies that you have described where there have been 10 effective responses have been preceded by exercised ?

l II A Some of them ha.ve; some of them haven't. Most l 12 of them haven't. (

i ,

} ,

13 Although training goe on a,ldt in some places, 14 it doesn't go on,in other places.Y l 15 g Pobtor Mileti, would the location of the buses  !

16 at the time o an' emergency, whether they were at home or at i

^

17 wor,k, have any e fect on whether the bus drivers will do their 18 job, assuming of course that you can get the bus drivers and l 19 the buses toger'.Pr at s'omePjuncture, which rea$ly isn't at 20 contest hr.re . Mr would the location of the buses have anything 21 to do with the willingness of the bus drivers to do their j 22 job? s 23 A Based on the evidence that was accumulatad in l

24 ' the social sciences to date, I would say no. What wculd matter mi neponers, inc.

, j 25 is whether or not they know that they have their job, and that t

t ge

10-10-Wal, J . 7882 1 they are feeling like they want to participate in that

() 2 job at the time.

3 So, it is the training, and knowing that they 4 have that role, which determines whether they get in the 5 bus or drive to the bus, and then get in the bus.

~

6 Q Finally, Mr. Myers, there seems to be some 7 concern and some confusion I guess on the record this

8 morning with the idea that bus drivers might have varying i

9 routes.

10 Could you -- and I guess that they might get 11 lost, perhaps, on their way to the shelters. Could you l 12 describe how the bus drivers will be traveling when they

{) 13 leave the school?

14 That is, whether they will -- from one particularj 15' school whether they will be going to one shelter, different I 16 shelters; whether they will be traveling as a group, along l 17 that line?

18 A (Witness Myers) We will have them going to the 19 school to pick up the students, and then they will be leaving i

20 in groups of buses to their respective shelter that has been l 21 already predetermined, based on which are being evacuated, 1

22 and so forth. j i

1 23 MS. RIDGWAY: That is all I have, Your Honor. l 24 JUDGE KELLEY: Mr. Eddleman, do you have el Rgeners, lrm.

25 any recross. '

O

7883 10-ll-Wal,E.

1 MR. EDDLEMAN: Just a little bit, Judge.

X INDEX 2 RECROSS EXAMINATION 3 BY MR. EDDLEMAN

4 Q Mr. Mileti, I believe you said the extent to 5 which the workers buy into the plan was one of the three 6 critical variables for them doing their jobs.

7 A (Witness Mileti) At the time of the emergency.

8 Q Have you done any studies of the extent to 9 which emergency workers buy into these sorts of plans at the 10 time of radiological emergencies?

l 11 A Yes, I have, if what you mean by that is the l 12 degree to which emergency workers who have been trained 13 perform their emergency jobs during the emergency, yes, I

[}

14 have. I 15 For example, I did a study of the behavior 16 of emergency workers at Three Mile Island. I did a study 17 of behavior of emergency workers among others right here in IB North Carolina, in fact. In Wilmington and Wrightsville  !

19 Beach back when an earthquake was predicted back in the mid-20 '70s.  ;

21 Believe it or not, it was taken quite seriously.3 i

22 And in a few other places.

i 23 Q And you characterize that as a radiological i 24 emergency, Doctor? i i

erd Reporars, lm A  !

25 I beg your pardon? No, I wouldn't say an earthquake i

'l 7884 I 10-12-Wa1.

4 1 prediction is a radiological emergency, no.

( 2 O Okay. And, at Three Mile Island radiation had 3 already been released, radioactive material had already been 4 released before any evacuation was ordered, was that not so?

5 A I don't believe an evacuation was ever ordered 6 at Three Mile Island.

7 Q Was it not advised that pregnant women and 8 children under six years leave the area?

9 A I believe it was five years, and yes, that 10 was an advisory, not an order.

II Q Okay. So, in your terms an evacuation is when i

12 the Governor orders people to get out, or sode responsible 13 official orders people to get out? j

(}' l I4 A No, not at all.  !

l 15 Q What is an evacuation in your terms, Doctor?

16 '

A An evacuation is when people go from one place I7 to another.

18 Okay.

Q Did people, in fact, evacuate from  !

19 Three Mile Island regardless of whether they were ordered l

P 20 to do so? i 21 A 144,000 people left, yes.

22 And were emergency workers among those who Q

i 23 left?

24 A Some emergency workers left, yes, but that was Am- " Reporters, Inc.

J 25 not role abandonment.

10-13-Wal 7885 1 Q None of that evacuation actually required n

v 2 emergency workers to perform -- strike that, please. In 3 that evacuation, were emergency workers assigned to assist 4 people evacuating? Was that part of their responsibilities 5 in your study?

6 MS. RIDGWAY: Your Honor, I am going to object 7 here. I let this go a little bit longer than I really 8 anticipated. There has been a change of counsel here, and 9 I am concerned that we are going significantly beyond the 10 scope of the redirect.

i II MR. EDDLEMAN: This is based on the Judge's  ;

i 12 question. l l

. {} 13 JUDGE KELLEY: Or the cross, I assume. It I4 i could be based on our questions. t 15 MS. RIDGWAY: Yes, Your Honor.

16 JUDGE KELLEY: Is it based on our questions?

I7 MR. EDDLEMAN: Yes, sir, Judge.

i 18 JUDGE KELLEY: In what way? i 19 MR. EDDLEMAN: You asked a question of what i

20 were the certainties of his statement that the workers would f  !

21 do as he expected, and his response was that although there l l

22 could be exceptions, there were three basic variables that l) 23 were important, and one of them was the extent to which the 24 workers buy into the plan.

Ace Federal Reporters, Inc. l 25 And I am asking about the study of Three Mile l l

1

, , - ~ - . _ . - - - - - . . . . - - . . . - , - . , . - . - . - - - - -, -, - -

l

7886 10-14-Wal, J .

1 Island.

(-)\

(_ 2 It seems that some of these workers didn't 3 buy into the plan, or actually got out of there on their ,

4 own.

5 JUDGE KELLEY: Well, did we -- we have to strike 6 some reasonable bounds here, but I don't recall getting into 7 the details of TMI, per se, in our questioning.

8 MR. EDDLEMAN: Well, I asked him if he had done 9 any studies of it, and the only radiological emergency that 10 he mentioned was TMI, and that is what we are talking about 4

11 here is radiological emergencies.

12 As Judge Carpenter said, we only have a sample 13 of one, at least at large scale.

14 JUDGE.KELLEY: We are really talking about 15 bus drivers, but -- anything further? I am inclined to let ,

16 this go a little bit. I think it is marginal.  !.

17 Why don't you go ahead. Briefly.

18 MR. EDDLEMAN: Could the reporter please read f 19 the question back? ,

i 20 (Reporter reads back the question.)  ;

i End 10. 21 Sus W fols.

22 23 l

24 4 erst Reporters, Iric.

Am.

25

7887 l

  1. 11-1-SueWalsd MR. EDDLEMAN: Let me try to rephrase that. I'm i 2 not sure it came out right.

3 JUDGE KELLEY: Okay.

4 BY MR. EDDLEMAN: (Continuing) 5 Q Were emergency workers, Dr. Mileti, assigned to 6 assist in the evacuation, the spontaneous evacuation, that i

7 actually took place-at Three Mile Island?  !

1 8 A (Witness Mileti) Well, by definition, given how 9 you have worded the question, spontaneous evacuation means 10 that people chose to do it on their own.

II Q Well, that's what you testified happened, wasn't 12 it?

. j 13 '

A i don't recall using the word " spontaneous," no.

\

J Id I don't believe you did. But, you said the Q

15 Governor didn't order them, and nobody ordered an evacuation,

  • 16 so wouldn't you characterize it as spontaneous, that people 17 left on their own initiative?

18 A Some of them did and some of them didn't. Some  !

I9 of them left way before the Governor's advisory and some of 20 them left way after the Governor's advisory, and some of 21 them left coinciding with the Governor's advisory.

22 But in all cases, they had a choice. They were Q

23 You testified to that, did you not ordered to evacuate.

n t, sir?

ers n.porms, ne. ,

A To the best of my knowledge, one needs to declare l

7888

  1. 11-2-SueWalsh marshal law to order people to evacuate in this country. And,

() 2 therefore, most evacuations are advisory.

3 Q So, the answer to this is that this was a 4 spontaneous evacuation; isn't.that correct?

5 A I think --

6 JUDGE KELLEY: I think it would be good to home i

7 in on the emergency workers.

8 MR. EDDLEMAN: Yeah. I just want to get that out 9 of the way, and I think we are there if --

10 JUDGE KELLEY: I think we are there, too. So 11 why don't we just move right on into the emergency workers?

12 BY MR. EDDLEMAN: (Continuing)

I rT 13 Q All right. The question is, in this spontaneous l

(_/ . t 14 evacuation that took place at TMI,, Doctor, were the emergency '

15 '

9xrkers that you studied assigned to assist in that?

16 A Some emergency workers, in a variety of different 17 kinds of organizations, during the course of what we could 18 c all Three Mile Island were assigned jobs associated with the 19 emergency and some weren't. All of them weren't.

20 0 But you are talking about jobs associated with the 21 emergency now.  ;

22 I'm talking about assicting with the evacuation.

l $

l 23 A Yes. Some emergency workers were assigned jobs l 24 specific l e s{-}. uei neponers w. to the evacuation, that ended up being the evacuation l l

{

25 of a hundred forty-four thousand people. For example, on the i I I s

L

7889

  1. 11-3-SueWalsh spot the Pennsylvania Emergency Management Agency had to put 7,

(,) 2 together real quick an evacuation plan. And people came in 3 and worked around the clock until that evacuation plan was 4 drafted and then implemented.

5 0 When was that plan implemented, Doctor? '

i 6 A During the emergency.

7 Q I mean, do you know the date?

8 A Gosh, I don't remember the date.

9 Okay. Mr. Myers, in the course of their instruction Q

10 and training that the bus drivers get, will they be given any II set of permanent instructions such as Judge Kelley asked about i 12 that they could keep with themselves rather than keep on rm 13 their bus? ,

()

14 A (Witness Myers) The bus drivers will be given, 15 '

along with the school students, will be given brochures, 16 general guidance on what to do if there was an accident.

17 0 Is it the same brochure that the Company is going 18 to circulate, or the State is going to circulate to people I9 living withinthe ten mile EPZ?

20 A I don't believe it's the same one, per se. No.

21 g well __

22 A It addresses the school issues, whereas the one 23 to the general public addresses the general public.

24

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Ac Ard Reporters, Inc.

This zeroes in on schools.

25 Q I'm sorry. This is the first I've heard of this t

7890

  1. 11-4-SueWalsh separate school brochure.

) 2 Do you know if that has been made available to i 3 the parties?

4 A I don't believe it has at this time.

5 Q Do you know if it's written at this time, sir?

I 6 A I believe it may be in some form of draft. I'm 7 not sure at this time.

8 Q Uh-huh. Dr. Mileti, I believe you testified --

i 9 I'm looking at the checklist of items for bus driver training --

10 that the information about nuclear risk was one of the three 11 important items there, in your view?

12 A (Witness Mileti) Yes. I think that's one thing 13 that needs to go into training. Yes. -

14 Q Okay. Would the credibility of that information t

15 have something to do with the extent to which the bus drivers 16 buy into this plan? .

17 l A Whether, given your words, the bus drivers buy 18 into the plan, I don't know. That's an intoresting hypothesis.

19 I don't know that something like that has ever 20 been studied. I don't know that I can offer you an answer.

21 Whether they buy into their role or not is determined by the 22 adequacy of the training.

23 And from that point of view, what I mean, buy 24 into their role, is how they behave during the emergency.

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- L erei n w o,teri. i x.  ;

25 From that point of view, the training is quite adequate, given ,

I 7891

  1. 11-5-SueWalsh what it covers.

,Q b 2 O Okay. And the role that we are talking about 3 buying into is actually performing the work, or going into 4 the zone and picking up people and getting them out, right?

5 A Whether they perform their emergency duties as 6 an emergency bus driver versus doing something else, yes.

7 MR. EDDLEMAN: Okay. I believe that's all the re-8 cross I have.

9 JUDGE KELLEY: Okay. Anything further from the 10 Applicants? l 11 MR. ROCHLIS: Nothing further from the Staff or 12 FEMA.

i 13 MS. RIDGWAY: Nothing further from the Applicants.

14 JUDGE KELLEY: Okay. Very well, Dr. Mileti and 15 Mr. Myers, we appreciate your coming very much.

16 You are excused.

17 (The witnesses stood aside.)

18 MR. EDDLEMAN: Judge, if I might, Joint Intervenors 19 would be willing to stipulate the joint testimony of the 20 FEMA witnesses on this contention, since this is very short, .

21 into the record. We don't have any problems.

22 MR. ROCHLIS: That's fine with FEMA.

23 MS. RIDGWAY: Applicants have no objection.

24 JUDGE KELLEY: It's unanimous. Okay. The l w .,.s.,o nepo i.,i,ine.

25 testimony of the FEMA witnesses is stipulated into the record  !

, 7892 ~

L l

#11-6-SueWal&h as is without cross. ,

l 2 MR. EDDLEMAN: Now, that's on Contention 4 (b) .

3 JUDGE KELLEY: Right. Only on 4 (b) .

4 Could we usefully call the first couple of wit-1 5 nesses and get the preliminaries over with before we take a .

I '

i 6 . break? j

-7 MR. HOLLAR: Certainly. We can go forward right l

8 now if you like.

9 JUDGE KELLEY: Just get them sworn in perhaps and I

10 through the formalities, and then we will take a break.

l ,

II I might just say for the record that that con-12 cludes the cases on EPJ-4(b), and we will now move on to 13 . Contention 57-C-10. And we will begin with the Applicants Id calling their first witnesses.

, 15 MR. HOLLAR: Mr. Chairman, Applicants call as 16 our witnesses on 57-C-10, Mr. Joseph F. Myers and Mr. Guy I

I7 Martin, Jr.

18 JUDGE KELLEY: All right. Gentlemen, Mr. Myers I9 is already sworn. Mr. Martin, would you raise your right hand, 2C pie,,,7 l 21 (Mr. Martin is sworn by Judge Kelley.)

22 JUDGE KELLEY: Thank you.

{

23 Whereupon, 4

O

, mou.n .. w.

24 GUY MARTIN, JR. l

25

-and- I l i l l

7893

  1. 11-7-SueWa3 JOSEPH F. MYERS A

(_) 2 were called as witnesses by and on behalf of Carolina Power 3 and Light Company and North Carolina Eastern Municipal Power 4 Agency and, after having been duly sworn, were examined and 5 testified as follows:

1 6 DIRECT EXAMINATION i i

7 BY MR. HOLLAR: '

8 Q Mr. Martin, would you please state your name, 9 position and business address for the record?

l 10 A (Witness Martin) My name is Guy Martin, Jr. My  ;

11 position is, I'm the Manager of Ebasco's Radiological Assess-12 ment and Health Physics Department. My business address is 13 2 World Trade Center, New York, New York 10048.

g3

\_)  ;

14 0 Mr. Myers, would you again state your name, position 15 and business address?

16 A (Witness Myers) My name is Joseph F. Myers. I am 17 the Director of North Carolina Emergency Management, 116 1

18 West Jones Street, Raleigh. '

19 Q Mr. Martin, I would like to direct your attention 20 to a document entitled " Direct Testimony of Guy Martin, Jr. I 21 on Eddleman Contention 57-C-10, Protection Factors of i

22 Institutional, Commercial and Industrial Structures, which ,

23 consists of thirteen pages and eight attachments.

24

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A&,_uo neponen. w.

Was the testimony in that document prepared by you I 25 or under your supervision? l l

7894-

  1. 11-8-SueWalsh A (Witness Martin) Yes, it was.

O)

(, 2 Q Do you have any changes or corrections to your 3 testimony?

4 A I have two minor changes to the testimony.

5 Q What are they? .

6 '*A On Page 11, the third line from the top, the word  !

7 " analysis" should be replaced by the word " survey. "

8 And on Page 12, the fourth line of the second ,

i 9 paragraph, there is a typographical error which should read j 10 '

" construction."

II MR. EDDLEMAN: Where is that?

< I2 WITNESS MARTIN: Page 12. The fourth line of the i

13 second, paragraph, there is a typographical error.

I4 MR. EDDLEMAN: Oh, construction. I see. I didn't 15 follow you, that you meant the second full paragraph. That's 16 why I couldn't find it.

17 WITNESS MARTIN: That's all I have.

18 MR. HOLLAR: Mr. Chairman, I have marked those I9 corrections in the copies that we have given to the Reporter.

20 BY MR. HOLLAR: (Continuing) 2I Q With those changes, Mr. Martin, is that testimony 22 true and correct to the best of your knowledge, information 23 and belief?

24 Yes, it is.

e. eral Reporters, Inc. A  !

h 25 And do you adopt that as your testimony in this 0

i

7895 l

  1. 11-9-SueWalsh proceeding?

() 2 A Yes, I do.

3 MR. HOLLAR: Mr. Chairman, I move that the docu-4 ment entitled " Direct Testimony of Guy Martin, Jr. on 5 Eddleman Contention 57-C-10"-including all attachments be 6 admitted into evidence and bound into the record as if read.

l 7 MR. EDDLEMAN: I have no objection. I see that 8 although the testimonies are filed separately we are taking  !

9 these people as a panel. That's fine. i 10 '

JUDGE KELLEY: Yes. I think that's right. And 11 then you are going to be moving Mr. Myers' testimony separately, 12 right?

13 MR. HOLLAR: Yes.

O 14 JUDGE KELLEY: Okay.

15 MR. HOLLAR: Yes, they are a panel.

16 JUDGE KELLEY: Right. Right. But they have I

17 separate pieces of testimony.

18 MR. HOLLAR: That's right.

19 JUDGE KELLEY: Fine. And Mr. Martin's -- without 20 o bjection, his testimony is admitted.

INDEXXX 21 (The testimony follows.)

22 23 24

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AcfarrLI Reporters, Inc.

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. l Juns 10,1985 1

0 -

l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY )

AND NORTH CAROLINA EASTERN ) Docket No. 50-400 OL MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power Plant) )

)

DIRECT TESTIMONY OF GUY MARTIN, JR.

ON EDDLEMAN CONTENTION 57-C-10 ..

(Protection Factors of Institutional, Commercial

  • O and Industrial Structures) e O

t

DIRECT TESTIMONY OF GUY MARTIN, JR.

ON EDDLEMAN CONTENTION 57-C-10 (Protection Factors of Institutional, Commercial and Industrial Structures)

Q1. Please state your full name, employer, position, and business address.

A 1. My name is Guy Martin, Jr. I am employed by Ebasco Services, Inc. as Manager of the Radiological Assessment Department. My business address is Two World Trade Center, New York, New York 10048.

Q2. What is your professional training?

A2. I graduated from the City College of the City of New York in 1974 with a bachelor's degree in mechanical engineering. I received a master's degree in nuclear engineering from the Polytechnic Institute of New York in 1976. I have also completed training offered by the Federal Emergency Management' Agency (FEMA) for certification as a fallout shelter analyst. The requirements to become a FEMA-certified fallout shelter analyst are to be either a graduate engineer or architect and to successfully complete a graduate level course on shelter analysis given by FEMA. The two-week course covers the fundamentals of shielding analysis of structures and the application of FEMA computer codes in the i

Successful completion of the course is based on passing two analysis.

approximately four-hour examinations.

Q3. Please describe your professional experience.

A3. Since joining Ebasco Services, Inc. In 1973, I have had extensive experience in developing engineering safety analyses for radiological and toxic chemical protection related to nuclear power plants. Among my areas of responsibility has been preparing the sections of Safety Analyses and Environmental Reports for l

W nuclear plants dealing with the impact of toxic chemical and radiological

] releases. This work includes estimating radionuclide releases from plant effluents and calculating radiological doses to blota and man. I have also been involved in preparing radiological surveillance programs for nuclear power plants. As a FEMA-certified fallout shelter analyst, I have performed shelter effectiveness studies of various buildings within several southern California school districts and the California Polytechnic State University (CPSU) a*. San Luis Obispo. These studies consisted of calculating protection factors for various radiation exposure pathways using FEMA's Shelter Analysis for Nuclear Defense (SAND) computer program and other analytical shielding methods. I have prepared reports for CPSU and the California Office of Emergency Services on the sheltering effectiveness of buildings. I have served as manager of Ebasco's Radiological Assessment Department since 1982. A more detailed summary of my professional training and experience is appended hereto as Attachment 1.

O e4. Mr. Martin, what is the purpose of your direet testimonye A4. The purpose of my testimony is to describe the activities that Ebasco has taken on behalf of Applicants and in conjunction with the State of North Carolina Division of Emergency Management (DEM) to address the remaining issues concerning Eddleman Contention 57-C-10. As originally admitted by the Licensing Board, <

Eddleman Contention 57-C-10 stated:

The State Plan (PT I pp 45-46 and 50-53) provides no useful analysis or information on sheltering effectiveness; but without knowledge of

  • sheltering effectiveness, a decision of that option versus evacuation will be ill-informed and quite possibly wrong. The plan's discussion of protective actions is mostly a list of them and a little handwaving-it's hopelessly inadequate. The plan, for potential shelters in those in the SHNPP plume EPZ, does not comply with Evaluation Criterion J.10.m of NUREG-0654, which calls for inclusion in the plan of " expected local protection afforded in residential units or other shelter for direct and

..nhalation exposure. . . ."

! O In admitting Eddleman Contention 57-C-10, the Board indicated that what is needed to comply with Criterion J.10.m. are " sound estimates of the protection afforded by potential shelters typical of the SHNPP plume EPZ." "Further Rulings on Admissibility of Offsite Emergency Planning Contentions Submitted by Intervenor Eddleman" (June 14,1984), at 18. In order to address the Board's ruling, Applicants commissioned a survey of structures within the Harris plume exposure emergency planning zone (EPZ) which I directed. On the basis of the survey results, information regarding the sheltering effectiveness (measured by protection factor) of typical residences in the EPZ was derived. The survey results and protection factors were summarized in the Affidavit of Robert G.

Black, Jr. in Support of Applicants' Motions for Summary D!sposition of CCNC Contention 2 and Eddleman Contention 57-C-10 (January 11,1985) (" Black

. Affidavit"), and the protection factors have been included in the of'-site f emergency plan for the Harris Plant. -

In denying Applicants' motion for summary disposition of Eddleman Contention 57-C-10, the Board nevertheless ruled out litigation of many of the issues originally raised in this contention. The Board explicitly ruled out "the issue of protection factors afforded by the types of housing prevalent in the Harris plume EPZ" and stated that the Applicants undertook a "well-designed, well-executed, and thoroughly documented review of these protection factors." " Memorandum and Order (Ruling on Remaining Summary Disposition Motions)"(April 24, 1985),

l.

at 3. According to the Board, the one issue which remains concerning the

(

J Applicants' review of typical sheltering in the Harris plume EPZ is the " adequacy

! of the Applicants' review of sheltering other than single-family residential." The 1

l Board went on to suggest that the offsite emergency plan for the Harris Plant

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O  !

i i

I

should include information on the sheltering effectiveness of "typicalinstitutional O '

structures (sehoois, ehorehes, etc.), commerciai struetures and industrial faeiiities in the plume EPZ" in order to bring it into complete compliance with Evaluation Criterion J.10.m. of NUREG-0654. Id. at 6-7.

In order to address the issues identified by the Licensing Board in its April 24, 1985 Memorandum and Order, I have directed a survey of institutional structures, commercial structures and industrial facilities within the plume exposure EPZ of the Shearon Harris Nuclear Power Plant. This survey is a supplement to the earlier survey which concentrated more on residential structures. We have analyzed the results of the latest survey in order to determine a range of protection factors for categories of institutional, commercial and industrial structures.

Q 5. Please explain what you mean by the Protection Factor of a structure.

AS. The sheltering effectiveness of a structure is measured in terms of its Protection Factor (PF). The PF is the ratio of the radiation dose outside the structure to the dose inside. It indicates the degree to which a structure would afford protection from a radiation release in comparison with no shelter at all. Thus, a building having a PF of I would not reduce radiation exposure at all compared to the absence of any shelter, while a building with a PF of 2 would reduce exposure by 50 percent.

Q6. Evaluation criterion J.10.m. of NUREG-0654 calls for a determination of protection for both direct and inhalation exposure. Please explain the differences between these types of radiation exposure.

A6. Direct exposure is that which results from radiation impinging directly on the human body and organs either from airborne or deposited nuclides. Airborne O

nuclides are the source of radiation in the air; exposure results when radiation (mainly in the form of gamma rays) is absorbed by the body. Deposited nuclides may be on the outside of the structure, such as on the roof or in the ground surrounding a building; radiation from these sources may penetrate a structure and the occupants inside. In contrast to direct radiation which results from radiation impinging directly upon the body and its organs, inhalation exposure results from breathing radioactive material in the air. In the event of an airborne release of radioactive material, the inhalation exposure to a person in a structure increases over time because air carrying radionuclides penetrates the building so that the concentration of radionuclides inside eventually approaches the outside concentration. How quickly this will occur depends upon the air exchange between the structure and the outside atmosphere.

Q7. What structural characteristics are most important in determining the PF of a structure?

A 7. The sheltering effectiveness of a structure is a function of the mass of material between the source of radiation and the person inside. The PF of a building will generally be greater for a building that is constructed of dense materials and in i

which there are a number of floors between the radiation source and the occupied area. Thus, the most important structural characteristics are the type of i

! construction and exterior finish, number of stories, and presence or absence of a l

basement. A building of brick, concrete or similar construction generally has a higher PF than one of wood frame construction. A multi-story structure generally provides more protection than a one-story structure. If a basement is available,it will provide even better protection. Since the inhalation exposure PF is a function

of the air exchange rate between a structure and the outside, data concerning the i

windows and other exterior openings are also relevant.

C 1 l

L

Q8. How did you obtain information needed to determine the PFs of institutional, O e===erei 1 a i o tri 1 tr et re i= the sez?

A 8. Working with the DEM staff, I organized a group of persons (all familiar with the building characteristics relevant to sheltering effectiveness) to gather the necessary information. Initially, we attempted to identify what types of institutional, commercial and industrial structures could be considered " typical" of such structures within the Harris EPZ. To obtain this information, we relied in part upon information that had been previously developed during the earlier survey of potential shelters in the EPZ. Information on structures was obtained from the property tax records of the counties in the EPZ and by a field survey of selected highways within the EPZ. A shelter survey of the hospitals, nursing homes and family care facilities in the EPZ had previously been conducted to respond to Eddleman Contention 57-C-13. This was supplemented by information from a e f eme t ree s vey teams (each composed of two persons) to gather field data. Two survey teams were composed of Ebasco personnel (including myself). The other team was composed of two DEM staff members. At least one FEMA-certified shelter analyst was on each survey team. In order to identify larger commercial / industrial facilities (which are likely to shelter larger numbers of persons), survey teams contacted Carolina Power & Light Company district managers in Cary, Fuquay-Varina, and Sanford. Listings and addresses of large commercial power users within the Harris EPZ were obtained from the district i managers. In addition, discussions were held with various persons knowledgeable about the Harris EPZ, including members of local chambers of commerce, p municipal clerks and postal employees. Information was also gathered using O -s-1 l

1

l resources within the North Carolina State Government. Aerial photographic maps  ;

O at ** sez r =* t ti tias or - aar etarias r eititi ae =t t t x r eara-l i

were an used as aids to obtain information. Finally, the plume EPZ was divided i 0

into roughly 120 segments and a road survey was conducted by the three survey teams. During the road surveys, institutional, commercial and industrial facilities were observed. Major commercial and industrial facilities identified as a result of the previously outlined approaches were visited, and notes taken regarding their general construction and composition of the building material. In addition, any facilities observed which were not previously identified were recorded.

Q9. Usin* the survey results, how did you categorize these structures?

A9. With respect to commercial / industrial structures, the predominant type of such structures in the EPZ is small retail establishments, such as service stations, fast food restaurants, and convenience food markets. These establishments are typically of brick veneer construction and are similar in terms of sheltering effectiveness to single family residences of the same constrdbtion. Although j these facilities predominate in terms of number, a smaller number of major i

establishments has a greater capacity for sheltering the population. From the sources described above, we identified 51 large commercial and industrial facilities that may be occupied by a large number of persons on a regular basis.

These 51 facilities are listed by geographic location in Attachment 2 to my testimony. In order to study these larger commercial / industrial structures more closely, they were placed into six categories based on similarities in the construction material and building design. The six categories ares (1) shopping i centers; (2) Butler-type buildings; (3) steel frame, brick / concrete buildings; (4) >

multi-story homogeneous structures; (5) complex sites; and (6) downtown shopping i O i i

i

districts. Attachment 3 lists the number of structures in each category and also describes the major characteristics associated with each category. As can be seen from Attachment 3,70 percent of the large commercial /industrialstructures fall in the categories of Butler-type buildings and steel frame, brick / concrete buildings.

With respect to institutional buildings, most fall within three basic

~

categories: (1) schools; (2) churches; and (3) hospitals and nursing homes. There are also a number of other institutional structures in the EPZ, such as family care facilities, Homes for the Elderly (a senior citizen community), day care centers and Camp Agape (a Lutheran church retreat). However, the family care facilities, Homes for the Elderly, and Camp Agape were not separately analyzed since they are essentially residential-type structures. The day care centers were not separately analyzed because they are either residential-type structures or are an integral part of another institutional strueture (a church or school). Information O' ,on the PFs of residential structures is already in the North Carolina Emergency Response Plan in Support of the Shearon Harris Nuclear Power Plant (the "ERP" or "offsite emergency plan").

Q10. How were the protection factors for commercial, industrial and institutional buildings determined?

A10. For larger commercial / industrial structures, representative structures within each of the six categories listed above were selected for more detailed analysis. At least two structures were selected within each category except for the downtown shopping district category. For that category, only one building typical of the downtown Apex shopping district was analyzed. The buildings were selected so as to represent the rapge of construction type within each category. For example, in

the steel frame, brick / concrete building category, the structures selected for

, detailed analysis include concrete block, brick and poured concrete structures. A conscious effort was made to avoid analyzing two buildings in each category which are composed of identical materials. Based upon this approach, a total of 13 large commercial / industrial facilities was selected. These facilities are listed in Attachment 4. The schools in the EPZ were visited. As a result of these visits and inspections, two schools were selected as representative of the type of design and construction used by all facilities. These two schools, Apex Elementary School and Fuquay-Varina Senior High School, were analyzed in greater detail.

To perform the detailed analysis for a structure, visits were made to each facility and information was obtained regarding the construction material, wall, floor and roof thickness. In addition, the size of the building, windows and doors and the distance between the shelter area and other buildings located nearby were obtained. The information was most often obtained by reviewing architectur'al O end construction diewings of eeeh of the butidinzs and through dise ssions with a a

responsible person at each facility such as the plant manager or plant engineer.

When facility drawings were insufficient or unavailable, direct tape measurements were performed.

After the detailed information for each structure was obtained, the data were (

transmitted to FEMA for input into FEMA's Shelter Analysis for Nuclear Defense (SAND) computer code. This computer code was used to calculate PFs for direct exposure to deposited nuclides. PFs for direct exposure to airborne nuclides were calculated using the models in David H. Slade, " Meteorology and Atomic Energy" (July 1968). This document is a standard reference for radiological dose esiculation methodology iss 'ad by the U. S. Atomic Energy Commission. To C

calculate PFs of the structures for inhalation exposure, the methodology described O ta ^tt ea = at 5 ratio o-The application of the above analytical techniques to develop the PFs for the various exposure pathways was restricted to the large commercial / industrial structures and schools. The identification of PF values for churches and small commercial structures was made by comparing their construction characteristics to those of typical residences for which protection factors have already been determined.

In general, churches and smaller commercial units (e.g., service stations, fast food restaurants, banks, etc.) have construction features which are, on average, comparable to or somewhat better than the typical residence in the Harris Plant EPZ in terms of sheltering effectiveness. Whereas the typical private residence is of wood-frame construction with a large percentage having a wood outside covering, the s. mall unattached commercial units are typically either

(/ of poured concrete or concrete block construction with or without a brick veneer covering. As such, these smaller commercial structures were evaluated relative to private residences. They were found to offer comparable or somewhat better

  • ' protection against radiation than the typical private residence in the Harris Plant EPZ. The same was concluded for the churches. They were found to be of comparable construction material (wood frame with brick veneer or wood covering) to private residences. The added advantage of churches is their larger size which helps increase the isolation distance between their occupants and exterior sources of radiation.

The two hospitals, three nursing homes, nine family care facilities and flomes for the Elderly were surveyed earlier in order to address the issues raised O - io -

by Eddleman Contention 57-C-13, which concerned the identification of the best PF areas of these facilities. I personally visited each of these facilities. As a result of a detailed $$$!!: of the structural features of each facility (such as types of construction, construction material, presence of basement, outside covering, type of windows), areas in the facilities with the best PFs were identified for the purpose of determining where to best shelter residents if a radiation release occurs. This information is reflected in the Affidavit of Jesse T.

Pugh, III in Support of Applicants' Motion for Summary Disposition of Eddleman Contention 57-C-13 (December 12, 1984). As I previously stated, the family care facilitics and Homes for the Elderly are of residential-type construction. The hospitals and nursing homes have construction characteristics that provide somewhat better protection than a typical residence. Both the hospitals and nursing homes are generally constructed of concrete blocks, sometimes with brick veneer exteriors. Their interior walls are also of concrete blocks. The hospitals

'G offer better protection than the nursing homes because of two structural characteristics: (1) they have flat roofs with a concrete base over a steel decking rather than asphalt shingle roofs; and (2) they have more interior rooms with concrete block walls and no exterior windows.

Qll. Please identify the range of protection factors within each category of '

institutional, commercial, and industrial structures.

All. The protection factors for direct radiation exposure for the 13 major commercial / industrial structures selected for detailed analysis are shown in Attachment 6. The comparable PFs for the two representative schools are given in Attachment 7. Attachment 8 summarizes the ra.nge of direct exposure protection factors for the schools ano for each category of major l

C1 .

commercial / industrial structures. The range of inhalation protection factors for O a11 eemmercial and industrial streetures and scheels is set forth in the table in Attachment 5, page 4 of my testimony.

For the typical smaller commercial establishments and churches, the range of PFs for direct radiation exposure is comparable to that for residences in the EPZ. Because a typical smaller commercial establishment is of concrete or concrete block constr[ction, its PF range will be most similar to that for brick residences (which have higher PFs than wood frame residences). Because of the added isolation distance available in churches, the PF range for churches will be perhaps slightly higher than that for residences of like construction. The derivation of the direct exposure PFs for residences was discussed in the Black Affidavit, and the PFs are provided in the offsite emergency plan at Part 1, section IV.E.8. The PFs are derived from information in EPA 520/1-78-001B on the degree of protection afforded by wood frame or brick single story homes without basements, which is the typical residential structure in the IIarris EPZ.

" Protective Action Evaluation, Part II, The Effectiveness of Sheltering As A Protective Action Against Nuclear Accidents Involving Gaseous Releases" (EPA 520/1-78-001B) at 18, 24. In EPA 520/1-78-001B, the level of protection is expressed in terms of the reduction factor or attenuation factor. The PFs in the offsite emergency plan are the reciprocal of the reduction factor or attenuation factors. For typical smaller commercial establishments, the range of PFs for inhalation exposure is as set forth in the table in Attachment 5, page 4 of my testimony. For a typical church, the range of PFs for inhalation exposure would be comparable to that for residences. The methodology for calculating these PFs is the same as that described in Attachment 5 to my testimony, and the PFs are provided in the ERP at Part 1, section IV.E.8.

O - - - - - - --

As I stated earlier, the family care facilities which we surveyed are of O re iaeati t eoastructio Taeir r #se or ersis the -e rortvPie tre soe=ces in the EPZ. The relevant structural characteristics of the nursing homes are similar to those for the smaller commercial establishments. Thus, the . nursing home PFs have a range comparable to that for the tsical small commercial structures. Finally, the two hospitals have structural characteristics comparable to certain wings of the schools that were visited and analyzed. Thus, the hospital PFs fall within the range of school PFs identified in Attachment 5, page 4, and Attachment 8. The hospitals and nursing homes have some areas where patients 5

i could be sheltered where the PFs are significantly better than other areas of the same facility.

Q12. In your opinion, does the availability of this information satisfy the requirements of Criterion J.10.m. of NUREG-0654?

A12. Yes. With the availability of this information, DEM qill be'able to amend the i

offsite emergency plan for the Harris,. Plant to include'. Information on the

't prctection factors of typical institutional, commercial and industrial structures in the PZ. Along with information on PFs of typical residences (which has l

previously been incorporated into the offsi,te plan), this will comport fully with the literal wording of Criterion J.10.m., which calls for inclusion of information on '

l the " expected local protection afforded in residential units or other shelter for i

1 direct arad inhalation exposure."

l I ,-

'^

Q13. Does this conclude your testimony? <

A 13. Yes. y e

v d .

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. ATTAC1 DENT 1 P ge 1 of 3 GUY MARTIN, ,R Manager Radiological Assessment I

SUMMARY

OF EXPERIENCE (Since 1965)

Total Experience - Twelve years participation in preparation of engineering safety analysis of radiological and toxic chemical protection. Six years in cost analysis for insurance premium determination. l Professional Affiliations American Society of Mechanical Engineers Health Physics Society American Nuclear Society Intern Engineer in New York State o Certified Fallout Shelter Analyst Education - M.S., Nuclear Engineering, Polytechnic Institute of New York, 1976 B.M.E., City College of the City of New York, 1974 REPRESENTATIVE EBASCO PRO ECT EXPERIENCE (Since 1973)

Manager - Radiological Assessment Department Areas of complete responsibility include the preparation of Safety Analysis and Environmental Reports (part of the Construction Permit and

(] Operating License application for nuclear power plants) sections dealing with impact analyses of toxic chemical and radiological releases. Such analyses are performed for both routine plant operation and under accident conditions. In this regard, conduct reviews of radwaste handling systems, air handling and cleanup systems and h&bitability systems. Estimate radionuclide releases from plant effluents and calculate radiological doses to biota and man. Calculate the in-plant dose rates to equipment and personnel from airborne radionuclide exposure <

and perform "as low as is reasonably achievable" (ALARA) reviews of air cleanup systems. Perform safety reviews of engineered safety systems, their specifications and operation from a radiation protection viewpoint and provide design recommendations based on assessed radiological doses and established nuclear safety criteria. Perform the analysis of transport of toxic chemicals postulated to be released accidentally and calculate their concentration in critical locations of a power plant and, provide technical feedback on required protection level. Assist responsible disciplines in determining toxic chemical detector specifications based on worker and equipment protection criteria.

Additional area of resconsibility include the preparation of radiological environmental surveillance programs. In this regard, prepare detailed surveillance program description based upon site-specific critical pathways of exposure. Specify samoles, frequency and types of analysis to be performed, prepare vendor and/or laboratory bid request, select O contractor, assist in monitoring equipment selection and review periodic surveillance reports sucmitted by contractors.

. , Prge 2 of 3 GUY MARTIN, JR (Cont'd)

O Participate in the defense of the licensing documents. Activities involve preparation of responses to intervenor interrogatories, testimonies and furnishing technical support to Ebasco's clients in licensing presentations (e.g., ACRS, NRC, etc.) and, ASLB safety and environmental hearings.

Experience to date spans over the following Ebasco projects:

Client Project Heactor Type Houston Lighting & Power Co many Allens Creek 1 BWR Comision Federal de Electricidad Laguna Verde 1 & 2 BWR Taiwan Power Corporation Chin Shan 1&2 BWR Louisiana Power & Light Company Waterford 3 PWR Carolina Power & Light Company Shearon Harris 1-4 PWR Washington Public Power Supply WNP 3 & 5 PWR System Florida Power & Light Co m any St Lucie 1 & 2 PWR As a Federal Emergency Management Agency (FEMA) certified fallout shelter analyst, performed shelter effectiveness studies of various buildings within several Southern California school districts and the California Polytechnic State University (CPSU) at San Luis Obispo. These studies consisted of calculations of protection factors for various radioactive O a1ume exoos re aeta vs u=too ecsa's sa"o oomauter oroor = mo otaer analytical shielding methods. Prepared reports for CPSU and California l Office ]f Emergency Services on building shelter effectiveness.

In addition to the above, participated in the following tasks:

Decomissioning Recuirements for Nuclear Waste Repository Licensing Was principal investigator on a study whose principal component was the establisnment of comprehensive data base covering D&D as it applies to a high-level waste repository located in specific geological formations.

The report prepared by Envirosphere presented a compilation of the various regulations and existing industry guidance and experience pertinent to D&D. In addition, a discussion of the various D&D alternatives which may apply to such waste repository facilities along with D&D strategies and scenarios were presented.

Remedial Action Project - Kellex Laboratory Site Supervised (on part-time basis) the health physics activities related to the decontamination work. Such activities included personnel and environmental monitoring, field raciation surveys and quality control.

O

.* Paga 3 of 3 C'Y J MARTIN, JR (Cont'd)

O . earoa exeeate"ce <6 ve rs)

Equitable Life Assurance Society of the US Cost Analyst Work involved calculating and analyzing cost of various activities performed throughout the company; assisting departmental managers in their budget preparation work. Made statistical studies for determination of activity costs and providing company's actuaries support information for premiun determination.

Publications Martin, G and J Thomas 1978. Meeting the dose requirements of 10CFR100 for site suitability and general design criteria 19 for control room habitability: a parametric approach. Transactions of American Nuclear Society 24th Annual Meeting. Vol. 28.

Martin, G, D Michlewicz and J Thomas 1978. Fission 2120: a program for assessing the need for engineered safety feature grade air cleaning systems in post - accident environment. Proceedings of 15th DOE Nuclear Air Cleaning Conference.

Letizia, A P, G Martin and J F Silvey 1979. - Implications for nuclear facilities of changes being initiated in the NRC standard atmospheric p diffusion model. Proceeding of the 41st Annual Meeting of the American

'd Power Conference.

Bhatia, R K, Mauro, J, Martin, G. Ef fects of Containment Purge on the Consequences of a Loss-of-Coolant Accident. Transactions of American Nuclear Society 1980 Annual Meeting.

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O' ATTACHMENT 2 LISTING OF MAJOR COMMERCIAL AND INDUSTRIAL STRUCTURES WITHIN THE TEN MILE EPZ Apex Vicinity Fuquay-Varina Vicinity Apex Shopping Plaza Fuquay-Varina Shopping Center Piggly Wiggly Grocery Store Milkove Shopping Center Apex Shopping Center Variety Wholesalers Data General Corp. Tobacco Grower's Services Amsco Medical Products Servisco Uniform Rental Carolina Plywood Stephen's Hardware Plunkett-Webster, Inc. Francis Feeds N. C. Fire and Safety Equipment El Dorado Tire Co.

Jeff Mullins Chevrolet Green Seed Co.

Tastee-Freez of North Carolina Fuquay Cooperative Warehouse Potter Industries Betts Tackle Co.

Henry Wurst, Inc. Arrowhead Tool Builders Tipper-Tie Watkins Johnson Almay Cosmetics Fidelity Bank of Fuquay-Varina Ramada Inn Hudson Belk Cooper Group Lufkin Universal Polymer Apex Town Hall Lan-O-Sheen .

Apex Downtown Shopping

  • District Flex-Line Shaddock Construction Co. Kendall Company B. Everett Jordan Project Office Cornell Dubilier Electronics Fuquay-Varina Downtown Shopping District i

Moncure Vieirity  !

Haywood-Moncure Comm. Health Center Cherokee Brick Chembond Corp.

City of Sanford Water Treatment Plant CP&L Cape Fear Steam Electric Plant Jones Memorial Park Rec. Center Allied Corp.

Boise-Cascade l

Weyerhaeuser

! Federal Paperboard Co.

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ATTACHMENT 3 O

NUMBER OF COMMERCIAL AND INDUSTRIAL STRUCTURES BY CATEGORY Category Number Description I. Shopping Centers 5 Single story structure, 3 load bearing walls, subdivided into smaller stores with concrete block partitions, flat roof, glass front.

II. Butler-type Buildings 20 Single story, steel frame, metal roof and siding, typical warehouse style building.

III. Steel Frame Brick / Concrete 15 Single story, steel joists, brick or concrete curtain wall, flat or sloped roof.

IV. . Multi-story Homogeneous 6 Multi-story buildings, brick or block construction, homogeneous

/~ construction on all floors. .

V. Complex Industrial 3 Manufacturing sites with several Groups buildings which may or may not be of similar construction.

VI. Downtown Shopping 2 Early 1900s downtown shopping Districts districts of brick or block construction. Storefronts have '

adjoining walls.

. . . - _ . = .

ATTACHMENT 4 O

COMMERCIAL / INDUSTRIAL FACILITIES SELECTED I FOR DETAILED PROTECTION FACTOR ANALYSIS l l

Category Facilities Analyzed I. Shopping Centers Fuquay-Varina Shopping Center Apex Shopping Center II. Butler-type Buildings Amsco Medical Products Weyerhaeuser III. Steel Frame Brick / Concrete Henry Wurst Almay Cosmetics Lan-O-Sheen IV. Multi-Story Homogeneous Ramada Inn Fidelity Bank of Fuquay-Varina Data Genera 1(office area)

V. Complex Jndustrial Groups . Cooper Group Lufkin .

Allied Corp.

O VI. Downtown Shopping Districts Apex c

8 O

i ATTACHMENT 5 Paga 1 of 4 O

METHODOLOGY AND CALCULATION OF INHALATION PROTECTION FACTORS FOR INSTITUTIONAL, COMMERCIAL AND INDUSTRIAL STRUCTURES IN THE SHNPP PLUME EPZ The protection factor of a structure for inhalation exposure can be determined by evaluating the fraction of the radiation dose avoided by remaining in the structure. For a structure with a given ventilation rate and for a given immersion time, the fraction of dose avoided can be calculated using mathematical equations which describe the concentration history of the airborne contaminants in the structure. Rather than present the fairly complex calculations in this testimony, a graph illustrating the results has been taken from an available reference. This graph, which is reproduced on page 3 of this Attachment, is excerpted from a planning document issued by the International Atomic Energy Agency. The curve shown in the graph represents the fraction of dose avoided for various ventilation rates and immersion times. Since inhalation protection-factors are for the most part a function of the building air exchange rate (or ventilation rate), this parameter was evaluated for representative institutional, commercial and industrial structures. The range of values of air exchange rates used varied from .5 to 1 air exchange per hour. The choice of this range is based on known values of ventilation rates ,

for residential dwellings and structures designed for air-tightness. Typical ventilation -

rates for private residences have been found to range from 1 to 2 air exchanges per hour. " Protective Action Evaluation, Part L The Effectiveness of Sheltering As A Protective Action Against Nuclear Accidents Involving Gaseous Releases" (EPA 520/1-78-001 A), at 8. Structures such as control rooms for nuclear power plants which are of low-leakage design typically do not permit more than .15 to .5 air exchanges per hour.

The representative institutional, commercial and industrial structures which were surveyed have construction features better than the average private residence but not O specifically designed as low-leakage structures. They fall into an intermediate category l

Page 2 of 4 1

with respect to ventilation rates. Consequently, the use of the air exchange rate values O of s to i ir exene se 9er aour is iestified. severet tvees of structures cehurches, famils  !

care facilities, day care centers, Camp Agape and Homes for the Elderly) are exceptions; they are more comparable to residences in terms of ventilation rates.

Using these ventilation rates, a range for the fraction of dose avoided can be estimated for various immersion times using the graph on page 3 of this Attachment. To estimate the fraction of dose avoided, it is necessary to determine the product of the ventilation rate (air exchanges / hour) and the immersion time (in hours). Where this number intersects the curve on the graph, the fraction of dose avoided is shown on the i

vertical axis of the graph.I For example, if the immersion time is five hours, the fraction of dose avoided would be approximately 0.28 with a ventilation rate of 0.5 air exchanges per hour and 0.2 for a ventilation rate of one air exchange per hour. The

  • relationship between the protection factor and the fraction of dose avoided is given by i the following mathematical equatiom -

PF = 1/(1-F)

Where PF = protection factor = ratio of dose outside the shelter to dose inside the shelter, and F = fraction of dose avoided by remaining in the shelter Based upon the estimated ventilation rate of 0.5 to one air exchange per hour, the

' graph illustrating the fraction of dose avoided and the mathematical relationship described above, estimated PFs of commercial, industrial and institutional structures for inhalation exposure are presented in the table on page 4 of this Attachment for various immersion times ranging from one-half hour to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. As previously discussed, the figures in the table on page 4 show that the level of protection afforded by a structure j from inhalation exposure is reduced over time.

i l

[

1The graph showing fraction of dose avoided assumes that a person either leaves l

the structure or ventilates the structure promptly once the plume passes.

l t

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. _ _ _ _ _ _ _ . . _ _ _ _ . _ _ _ . , _ . . _ _ ~ . ,

ATTACHMENT 5 P ge 3 of 4 0

LC '

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CJ 2 4 6 41.0 2 4 6 s to 2 4 6 8 120 IVE NTit AT404 R Altl a llWW E R1f C4 IIWil O

V Effect of ventilation rate and immersion time on fraction of dose avoided. Ventilation rate is measured in air exchanges / hour and immersion <

time is in hours.III (1) Source: Planning for Off-site Response to Radiation Accidents in Nuclear Facilities, Safety Series No. 55, International Atomic Energy Agency, Vienna,1981.

O V

ATTACHMENT 5 l Prga 4 of 4 1

1 h INHALATION EXPOSURE PROTECTION FACTORS FOR TYPICAL INSTITUTION AL, COMMERCIAL / INDUSTRIAL STRUCTURES LOCATED IN THE SHNPP PLUME EPZ*

Immersion Time (Hours) Protection Factor 0.5 10-5 1.0 5-2.5 1.5 3-2 2.0 2.5-1.7 5 1.4-1.2 10 1.2-1.1 Excluding churches, family care facilities, day care centers, Camp Agape, and Homes for the Elderly. The range of inhalation exposure PFs for these institutional structures is comparable to that for a typical single-family residence in the Harris EPZ. These values are listed in the Harris offsite emergency plan at Part 1, section IV.E.8.

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ATTACHMENT 6 O

DIRECT RADIATION EXPOSURE PROTECTION FACTORS (PF)* I FOR MAJOR COMMERCIAL / INDUSTRIAL FACILITIES ANALYZED IN SHNPP PLUME EPZ Airborne Deposited Type Structure Nuclides Nuclides of Structure Fuquay-Varina Shopping Center 1.2 3-5 Shopping Center Apex Shopping Center 1.2 2-3 Shopping Center Amsco Medical Products 1.1 2 Butler Building c Weyerhaeuser 1.2 2 Butler Building Henry Wurst 1.2 3-6 Steelframe, Brick / Concrete Almay Cosmetics 1.2 2-6 . Steelframe, Brick / Concrete p Lan-O-Sheen 1.2 2 Steelframe, t,j Brick / Concrete Ramada Inn 4-7 4-20 Multi-Story Homogeneous Fidelity Bank 1.2-2.3 3-20 Multi-Story Homegeneous Data General (Office) 1.2-2 4-8 Multi-Story

omogeneous Cooper Group 1.3 3 Complex Allied Corp. 2-5 6-40 Complex i

l Downtown Apex Business District 1.1 3-4 Downtown Shopping Dist.

The protection factor is the ratio of the radiation level outside of the building relative to that inside. A PF=1 Indicates no protection.

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ATTACHMENT 7 1 /

DIRECT RADIATION EXPOSURE PROTECTION FACTORS FOR l SCHOOLS SURVEYED IN SHNPP PLUME EPZ School Airborne Deoosited Nuclides Nuclides Fuquay-Varina Sr. High School 1.6-5.7 10-25 1.2 4 Apex Elementary School l

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ATTACHMENT 8 O

SUMMARY

OF PROTECTION FACTOR RANGES FOR DIRECT RADIATION EXPOSURE FOR CATEGORIES OF MAJOR COMMERCIAL / INDUSTRIAL STRUCTURES AND SCHOOLS IN THE SHNPP PLUME EPZ Protection Factor Range Type of Structure Airborne Deposited Nuchdes Nuchdes I. Shopping Center 1.2 3-5 H. Butler-type Buildings 1.2 2 III. Steel Frame / Brick or 1.2 2-6 Concrete Wall Buildings IV. Multi-Story Homogeneous 1.2-7 3-20 Buildings V. Complex Industrial Groups 1.3-5 3-40 ,

Downtown Shopping Districts VI. 1.1 3-4 VII. Schools 1.2-5.7 4-25 O

7896

  1. 11-10-SueWaldh BY MR. HOLLAR: (Continuing)

{

() 2 Q And, Mr. Myers, I would like to direct your at-3 tention to a document entitled " Direct Testimony of Joseph F.

4 Myers on Eddleman Contention 57-C-10, Protection Factors of 5 Institutional, Commercial and Industrial Structuren," which 6 consists of three pages and one attachment.  :

I 7 Was the testimony in that document pr5 pared by  ;

I 8 you or under your supervision?  !

i 9 A (Witness Myers) Yes, it was. '

l 10 Q And do you have any changes or corrections to that ,

11 testimony?

i 12 A Yes. I have two. Page 1, Line 7, change "lll" to i 13 "116."

{~)}

u 14 And on the attachment labeled " Capability Profile" 15 add Attachment 1 to the upper right hand corner of the first 16 page.

17 MR. HOLLAR: We have also marked those corrections 18 in the copies provided to the Reporter.  !

19 BY MR. HOLLAR: (Continuing) 20 Q With those changes, is that testimony true and 21 correct to the best of your knowledge, information and belief?  ;

22 A Yes, it is. i 23 Q And do you adopt that as your testimony in this 24

()

Aa_auo neponers. im.

p roceeding?  !

, 25 A I do. I I

i

7897

  1. 11-11-SueWalsh MR. HOLLAR: Mr. Chairman, I would now move that 2 the document, entitled " Direct Testimony of Joseph F. Myers 3 on Eddleman Contention 57-C-10" including the attachment be L

4 admitted into evidence and bound into the record as if read.

5 JUDGE KELLEY: No objection?

6 (Mr. Eddleman nodded in the negative.)  !

t 7 JUDGE KELLEY: So ordered. {

INDEXXXX 8 (The testimony follows.) i 9  !

10 11  :

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23 24 O

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June 10,1985 O

UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD

)

In the Matter of )

)

CAROLINA POWER & LIGHT COMPANY Docket No. 50-400 OL

)

AND NORTH CAROLINA EASTERN )

MUNICIPAL POWER AGENCY )

)

(Shearon Harris Nuclear Power Plant))

DIRECT TESTIMONY OF JOSEPH f. MYERS

  • ON EDDLEMAN CONTENTION 5't-C-10 E O (Protection Factors of Institutional, Commercial and Industrial Structures?

l i

O e

i DIRECT TESTIMONY OF JOSEPH F. MYERS i ON EDDLEMAN CONTENTION 57-C-10

+

- (Protection Factors of Institutional, Commercial and Industrial Structures)

Ql. Please state your full name, employer, position, and business address.

A 1. My name is Joseph F. Myers. I am the Director of the Division of Emergency Management (DEM) of the North Carolina Department of Crime Control and Public Safety. The basic responsibilities of the Division of Emergency Management  !

include fulfilling the State's role in emergency planning for natural and manmade disasters, in responding to and recovering from disasters, and in mitigating their effects. My business address is N W. Jones Street, Raleigh, North Carolina 27611.

. Q2. Please describe your professional qualifications and experience.

A 2. As Director of DEM, I have been involved in the development of the off-site

' emergency capability for the Shearon Harris Nuclear Power, Plant as well as that for the Catawba, McGuire, and Brunswick nuclear plants. Since February 1985, I have had overall authority for emergency preparedness activities concerning the 4

Harris Plant. Prior to that, I was for nine years employed as area coordinator for i

i the Division of Emergency Management Area E, which includes pxtions of

' emergency planning zones for the Catawba and McGuire nuclear plants. In this position, I was responsible for off-site emergency plans, drills, and exercises for the counties involved with those plants. I was also responsible for overall emeagency I

preparedness in that Area, and directed the State's response to hundreds of emergencies in the past two years in Area E. I have also coordinated the State's t response to over 100 emergencies while in my current position as Director of DEM. In addition, I have supported the DEM staff on location in responding to statewide emergencies such as the tornadoes in March 1984, Hurricane Diana in i

1 i

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-_ _ _... ~ .. __ _.. .z_-.......-.-.- - - _ . - - - - - .-

~

September 1984, and the forest fires which occurred across the State in the spring

( of this year. A complete statement of my professional qualifications is appended hereto as Attachment 1 to this testimony.

Q3. What is the purpose of your testimony?

A 3. The purpose of my testimony is to describe the steps that DEM will take to address the remaining issues concerning Eddleman Contention 57-C-10. It is my understanding that the Board's only outstanding concern is whether the North Carolina Emergency Response Plan in Support of the Shearon Harris Nuclear Power Plant (the "ERP") should identify the protection factors (PFs) afforded by typical institutional, commercial and industrial structures in the Harris plume EPZ in order to comply with Criterion J.10.m. of NUREG-0654. The ERP has already been amended to provide information on the PFs of typical residential structures in the EPZ. ,

Q4. 'Have you reviewed .the results of the survey of institutional, commercial and industrial buildings that has been commissioned by Applicants?

A 4. Yes. I have reviewed the results of the survey which are summarized in the Direct Testimony of Guy Martin, Jr., which is being filed concurrently with my testimony. Members of my staff worked closely with Ebasco personnelin gathering information and analyzing the sheltering effectiveness of commercial, institutional and industrial structures. For example, two DEM staff members comprised one of the three teams that surveyed commercial / industrial facilities in the EPZ. I have also discussed the survey results personally with Mr. Martin. I believe that the results of this survey accurately identify and categorize institutional, commercial and industrial buildings within the Harris EPZ. I also believe that the estimated range of protection factors, as presented in Mr. Martin's testimony, accurately represents the level of protection afforded by structures with the characteristics O identiried for eeca cetezerv.

Q5. What does DEM intend to do with the information obtained from this survey?

A S. DEM accepts the results of the survey and the protection factor estimates for typical ihitutional, commercial and industrial structures in the EPZ. The ERP will be amended to reflect the results of the survey and to include an analysis of the level of protection from radiation releases afforded by commercial, institutional and industrial structures in the Harris EPZ that could be used as shelter in the event of an accident. Based upon the information reflected in Mr. Martin's testimony, the estimated protection factors of commercial, institutional and industrial structures will be listed in the ERP. With the addition of this information, the ERP will comply fully with Criterion J.10.m of NUREG-0654, which calls for inclusion of information on the " expected local protection afforded in residential units or other shelter for direct and inhalation exposure" in off-site emergency plans. The information will be available to officials who will decide what protective action (that is, evacuating or sheltering the population) to i.

G V tak*e in the event of an accident at the Harris Plant.

Q6. Does this conclude your testimony?

A 6. Yes.

l 1

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e._ _

A+1a.c.hmenf I CAPABILITY PROFILE O JOSEPH F. MYERS EDUCATION 1967 Graduated - Swain County High School Bryson City, North Carolina 1967 University of Tennessee Knoxville, Tennessee Department of Education 1968 - 1971 Western Carolina University <

Cullowhee, North Carolina Graduated - B.S. Education Major Course Work: Social Studies 1975 Winthrop College Rock Hill, South Carolina Emergency Management Career Development Santa Barbara University Santa Barbara, California O

HONORS, AWARDS AND FELLOWSHIPS RECEIVED 1966 Football Scholarship - Western Carolina University 1968 - 1971 North Carolina Vocational Rehabilitation Grant Western Carolina University SPECIAL QUALIFICATIONS AND SKILLS Publication: Operational Guide For Fixed Nuclear Facility Accident (McGuire Nuclear Station). (A handbook for elected and appointed officials and key emergency personnel)

Publication: " State Emergency Response Team Overview" (Handout) ,

Extensive Public Speaking: TV; Radio; County and City elected officials; Educators; Emergency Service personnel; Health Service personnel; Law Enforcement personnel i

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r .

EMPLOYMENT JOB TITLE O Jan.1985 - Present Director:

TorRarolina Division of Emergency Management Department of Crime Control and Public Safety Raleigh, North Carolina Duties and Responsibilities:

Responsible for the State of North Carolina emergency response and planning. This includes the coordination of all emergency response activities of 17 state agencies.

I serve as the State Coordinating Officer and the Governor's Authorized Representative in all disaster related matters. In emergencies, I serve as leader of the

, State Emergency Response Team. I have coordinated the State's response to over 100 emergencies while in my current position as Director of the Division of Emergency Management. In addition, I have supported DEM staff on location in responding to statewide emergencies such as the forest fires which occurred across the state in the spring of this year.

. As Director of DEM, I have been involved in the development of the offsite emergency capability for the Shearon Harris Nuclear Power Plant, as well as the Catawba, McGuire and Brunswick nuclear plants. Since February 1985, I have had overall authority for emergency preparedness activities concerning the Harris plant.

. 1976 - Jan.1985 Area Coordinator:

~

j North Carolina Division of Emergency Management Department of Crime Control and Public Safety Raleigh, North Carolina Duties and Responsibilities Responsible for assisting 20 North Carolina counties in developing a Comprehensive '

Emergency Management (CEM) Program. I assisted counties in developing and providing I technical information in emergency planning, preparedness and response. Assisted counties and state agencies in maintaining a state of readiness to support any emergency operation. Provided assistance to local government and state regional agencies in l developing plans and exercises in support of Radiological Emergency Preparedness.

t Provided assistance in the development and amending of local government and state l

regional plans for responding to hazardous materialincidents.

I served as the on-scene coordinator of state regional response to a variety of emergency situations, predominantly within my 20-county area. However, I was subject to respond to any emergency situation within the state that was beyond the capability of one area.

Once at the scene, I represented the State Emergency Response Team and served as an on-site evaluator for the State making operational recommendations and serving as a liaison between local government and State government. For example: During a O

Presidential declared natural disaster, a fixed nuclear facility incident, or a major

()

v chemical fire, the State Emergency Response Team serves as the Governor's on-site field staff.

In summary, my job encompassed the full spectrum of developing Comprehensive Emergency Management (Mitigation-Preparedness-Response-Recovery) at the local level and integrating it into the existing elements of government; i.e. emergency planning, communications, fire, medical and environmental health. At the area level, more l emphasis is placed on preparedness and response activities. Preparedness activities constitute developing and/or maintaining 20 county Disaster Relief & Assistance Plans (all hazard), including hazardous material response plans, fixed nuclear facility plans and Nuclear Civil Protection Plans. Training activities include developing and/or coordinating Shelter Manager Courses, Damage Assessment Courses, radiological Monitoring Courses, Field Exercises with Hazardous Material Scenarios and Public Officials Conferences. Response activities are usually of the hazardous material nature (air-water-solid & hazardous waste), caused by fire, spills or contamination.

Accomplishments 3

PUBLICATION (1980) -Developed Handbook for elected officials and emergency workers in response to an accident at the McGuire Nuclear Station Author of " SERT Overview" Handout (1980)

Appreciation Award (Speaker)

O ti#eeta ce##tv xi =i cted

Subject:

" Protection in the Nuclear Age" (1979) i Ea t Gaston County Rotary Club -(Speaker - 1980)

Subject:

" North Carolina Response to an Incident at the McGuire Nuclear i

Station" WBTV Channel 3 - Charlotte, North Carolina " Top of the Day" Show (Speaker) +

Subject:

" North Carolina Response to an Incident at the McGuire Nuclear '

Station" WAYS Radio - Charlotte, North Carolina

Subject:

" Fixed Nuclear Facility Planning" WSOC Radio - Charlotte, North Carolina

Subject:

" Fixed Nuclear Facility Planning" WTVI Channel 42 - Charlotte, North Carolina Live debate on " Survival of Nuclear War" with State Department Officials f

WBTV Channel 3 - Charlotte, North Caolina "First Edition" Show

Subject:

" North Carolina Response to an incident at the McGuire Nuclear Station" O

I

- - . . - _ ~ , - . . _ , . _ , . - , _ - , -~ -.-_____,-m- , , , _ . .~ m_-u-.,___-y. - , . - - ,,,..-,,-r, -,y ---

Coordinated the planning and implementation of county response plans to an incident at the McGuire Nuclear Station. This involved six North Carolina counties O i and is eensidered one of the first offiei i ePer tional P ans refieetine the new regulations established by the Federal Emergency Management Agency and the Nuclear Regulatory Commission in 1980.

Coordinated the planning and implementation of county response plans to an incident at the Catawba Nuclear Station. This involved five North Carolina counties in 1984.

Coordinated a Fixed Nuclear Facility Disaster Exercise. This exercise involved the actual notification, evacuation, sheltering and feeding of approximately 400 citizens due to an incident at the McGuire Nuclear Station. This exercise involved hundreds of Federal, State, local and private-sector resources.

Duke Power Company's Response to an Incident at the McGuire Nuclear Station

> Workshop - (Speaker - 1980)

Subject:

"The Role of North Carolina to an Incident at the McGuire Nuclear Station"

]

, Table Top Conferences for counties within a 10-mile radius of the McGuire Nuclear Station - (Speaker - 1980)

Worked on emergency planning for the Shearon Harris Nuclear Power Plant Appreciation Award (Instructor) ,

N.C. Justice Academy ' '

Subject:

" Role of the Law Enforcement Officer in an Emergency Management Program"(1977)

! International Conference of Police Chaplains - (Speaker - 1981)

Columbia, South Carolina

Subject:

" Developing a County Disaster Program" School Emergency Planning & Curriculum Development Conference (K-12)

Western Carolina University, Cullowhee, North Carolina (Developed and conducted In-Service Training for County Principals &

Teachers)

Assisted in the disaster relief and recovery efforts between Federal, State and 16 1

North Carolina counties due to a Presidential declared disaster caused by flash flooding (1977 - 1978).

Assisted in the disaster relief and recovery efforts between Federal, State and 14 counties due to a Presidential declared disaster due to tornadoes and hurricanes in 1984.

Phase II " Developing a Civil Preparedness Program"-(Speaker - 1978)

Appalachian State University, Boone, North Carolina

Subject:

"The Federal Audit System Involving Civil Preparedness Funds & L Program"  ;

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i Basic Seminar for New County Emergency Management Coordinators J p (Moderator and Chief Instructor)

Ashevule, NC I

V Conferences for Business & Industry (Speaker)

Subject:

"The Role of the Private Sector in a Comprehensive Emergency Management Program" Damage Assessment Workshops - (Speaker - 1978 - 1984)

(Spoke throughout 20 counties in North Carolina)

Subject:

" Systematic Methods of Compiling Damage Assessment Data in Order to Obtain Federal Assistance After a Disaster Incident" Shelter Management Workshops - (Speaker - 1977 - 1984)

(Spoke throughout 20 counties in North Carolina)

Subject:

" Shelter Organization, Staffing and Activation" Conferences for Elected Officials -(1980 - 1984)

(Conducted private session with county elected officials concerning the development of a county Comprehensive Emergency Management Program.)

Completed " Managing the Search Function Course and Instructors Workshop" (1984).

Table Top Workshops for 20 counties within North Carolina concerning local government's. response to a disaster situation. ,

Developed and instructed Hatardous Material Response Workshops that reflect O North Carolina's integrated approach to hazardous material incident notification and on-scene coordination. These workshops were conducted for State and county emergency personnel (Fire & Health) in 1983.

North Carolina Association of Emergency Management Coordinator - (Speaker -

1978)

Subject:

" Federal Audit System" Coordinated the testing of 19 North Carolina counties' Emergency Operations Plans

  • for War in a FEMA-sponsored simulated wartime exercise (1978).

Completed General Administrative Training Program - 1981 .

Completed Phase II " Developing a Civil Preparedness Program"- 1977 Sponsored by the Defense Civil Preparedness Agency University of North Carolina - Charlotte, North Carolina Attended Plans & Operations Workshop - 1977 & 1982 N. C. Division of Emergency Management Attended Hazardous Material Seminar - 1976 & 1984 Southern Railroad,Inc.- Charlotte, North Carolina O

Comp. ced Radiological Emergency Response Operations (RERO) School- 1979 Sponsored by the Nuclear Regulatory Commission pd Las Vegas, Nevada Attended Disaster Relief & Assistance Workshop - 1975 & 1983 Sponsored by Federal Disaster Assistance Administration Raleigh, North Carolina Attended North Carolina Association of Broadcasters Workshop - 1978 Raleigh, North Carolina

Subject:

" Emergency Broadcast System" National Fire Incident Reporting System (NFIRS) qualified - 1981 Recipient of Col. William A. Thompson Award for Outstanding Achievement in Emergency Management in 1984. This award was presented by the North Carolina Emergency Management Association. ,

1975 - 1976 Training and Education Specialist:

North Carolina Division of Emergency Management Department of Crime Control and Public Safety Raleigh, North Carolina Duties and Responsibilities As a Trainin'g and Education Specialist, I was involved with the following:

1) Developing and conducting various training programs for State and local governments and the elements of the private sector that would support emergency or disaster operations.
2) Assisted in the planning, implementing and field testing of school comprehensive disaster plans.
3) Assisted in the planning, implementing and field testing of a comprehensive emergency management program into the existing school curriculum (Grades K-12), in conjunction with the North Carolina Department of Public Instruction.

Accomplishments l

Recipient - North Carolina Long Leaf Pine Award Completed Phase I " Role of the Coordinator"- 1975 Sponsored by the Defense Civil Preparedness Agency Winthrop College, Rock Hill, South Carolina 0

l

-~ - - __ __

Comprehensive School Emergency Plan Workshop -(Speaker - 1975)

Person County Cabarrus County Haywood County ,

1973 - 1975 Teacher - Coach:

Swain County High School Swain County Board of Education .

Bryson City, North Carolina Duties and Responsibilities While employed at Swain County High School, I taught five (5) daily classes of Social Studies and one (1) class of Physical Education. I also served as an athletic coach for the following:

1) Assistant Football
2) Assistant Baseball
3) Head Girls and Varsity Boys Basketball 1971 - 1973 Teacher - Coach:

Cherokee High School ,

Bureau of Indian Affairs .

U. S. Department of Interior p Cherokee, North Carolina

\

Duties and Responsibilities ,

While employed as a teacher at ' Cherokee High School, I taught one (1) daily class of Psychology and was subject to teach any class for any instructor within the total

> school curriculum offered. I also served as a coach for the following:

1) Assistant Football
2) Assistant Softball '
3) Head Varsity Girls Basketball
4) Head Junior Varsity Girls Basketball Accomplishments Won Conference Championship (Varsity Girls Basketball)

Recipient of Service Award

> Steve Youngdeer Post, NC VFW Cherokee, North Carolina O

7

m 1968 - 1971 Coach:

Cherokee High School O 8 r u er i di n itr ire U. S. Department of Interior Cherokee, North Carolina Duties and Responsibilities My employment was part-time, and I served as a coach for the following:

1) Assistant Football
2) Assistant Softball
3) Head Girls Varsity Dasketball
4) Head Girls Junior Varsity Basketball Personal Date of Birth: June 1,1949 ,

Age: 35 Marital Status: Married Height: 5' 9" Weight: 170 Civic Club - Organizations North Carolina Jayeges Lincoln County Kiwanis Club -

North Carolina Emergency Management Association of Coordinators

4 7898 i

  1. 11-12-SueWah BY MR. HOLLAR: (Continuing) i O'x_/ 2 O Mr. Myers,'I would also like to direct your at-3 tentiontoanother/bocumentwhichhasbeenmarkedas '

i 4 Applicants' Exhibit Number 29.

5 (Mr. Hollar is handing-thd witness a document.)

6 Could you identify that document, please? i 7 A This is taken from the. . State's Emergency Response  !

  • r 8 Plan for the Shearon Harris Nuclear Power 21 ant. f f

9 Q, What section of the plan g is that?

a Se6 tion IV.

10 A -

11 Q Is that Part 1,Section IV.E.8?

12 A Yes. Pages 49, 50 -- to 51.

13 MR. HOLLAR: Mr. Chairman, I would move that this (s~-}-

14 document, which is an excerpt from the North Carolina Emergency; l 15 Response Plan, Part 1,Section IV.E.8 be admitted into evidence

/

16 as Applicants' Exhibit Number).39 for the limited purpose o'f' 17 identifying information in the plan on the protection factors l 18 of typical residences in the Harris EPZ, to which both Mr. I

/ ~

19 Myers'and Mr., Martin',s testimony refers.

20 MK.#EDDLEMAN:

Your Honor, this is not in the nature; 21 of an objection.

/

I'm'notJsure what the proper law is, but I 22 think I would like it in for any purpose that it shows what 23 it shows.,

()

A=-rdttd Reporurs, lm.

24 JUDGE KELLEY:\ Wouldyoubejustashappyifitwere{ '

25 introduced as evidence without restriction?

s l

t i I .4

7899

  1. 11-13-SueWaldh MR. HOLLAR: Your Honor, we only intend to use it

(~3 ,

(/ 2 for the purpose of showing the protection factors that have  !

3 been developed. We have no other reason for wishing to have 4 it admitted into evidence.

5 JUDGE KELLEY: It's a brief document, though, right, ,

6 two pages? 1 7 MR. HOLLAR: Two pages.' l i

8 JUDGE KELLEY: You want the bottom half of the  ;

' 1 9 page and -- yeah, okay. f 10 Well, under your proposed restriction, Mr. Hollar, II the matter would not be in for the truth of what it asserts, 12 simply that it shows what was done in the plan; is that right?

() 13 MR. HOLLAR: It shows what was done with respect Id to identifying protection factors of typical residences in 15 l the EPZ and the numerical values that were derived.

16 JUDGE KELLEY: Let me be sure I know where we 17 are. You are offering it for a limited-purpose. You want 1

18 it in for general purposes, right?  !

I9 MR. EDDLEMAN: That's right. I want -- that's 20 what is currently in the plan, as I understand it. It shows .

21 what it shows. .

22 JUDGE KELLEY: Are you objecting to its being let i

23 in for a limited purpose?

() 24 0.5+ed;rd Reporters, Inc.

MR. EDDLEMAN: I'monlyobjectingtothelimitationl 25 of purpose. I want it in. I'm not objecting to letting it in.!

1 e

7900 i ill-14-SueWall I'm objecting to limiting its purpose if you let ,

2 it in, a

3 JUDGE KELLEY: Do you have a real objection to 1.

4 just letting it in, period?-

'5 MR. HOLLAR:' Our reason for wanting it in for a

. 6 limited purpose is to avoid opening up a discussion of i i

7 protective action decision making.  !

l.

The only reason that we wanted the.section in is i 8 -

l i

. 9 to'show the numbers that have been developed. We think if g 10 it were let in for a larger purpose that it might broaden  !

11 the area of. questioning beyond the scope of this contention.

12 JUDGE KELLEY: Well, if we let it in without ,

i

(} 13' prejudice to your making that point, should -- if and when 14 it arises, wouldn't that meet the same need?  !.

15 MR. HOLLAR: I suppose it would, Your Honor. i 16 JUDGE KELLEY: Well, that seems like a diplomatic i

i, '17 compromise.

18 We will admit the offered Exhibit Number 29 with l

! 19 tJun understanding that the Applicants do not at this point i

20 waive an objection should the questioning go off on decision 21 making with regard to protective action.  ;

V l 22 Is that a fair statement of your concern?

, l l

f 23 MR. HOLLAR: Yes, Your Honor.

L

\

24 JUDGE KELLEY: Okay. I didn't ask the Staff. I'm I

! Mr.dwal Reporters, Inc.

25 sorry. Does the Staff have a problem with that?

lI Y

l

(.

.. ._ . . . -. , - ~ - - - . . , _ _ , - . . . . _ , , . - . , . . . , . _ . . - _ . . ~ . - - - - . _ , , . . . _ - _ , . . . - - - . . - . - - . . .

7901 l

  1. 11-15-SueWals?. MR. ROCHLIS: No objection, Your Honor.

r'

(,)/ - 2 JUDGE KELLEY: Okay.

3 MR. EDDLEMAN: Let me just say that I am not agree-4 ing that the decision making use of this is not relevant to 5 this contention. That is what the contention talks about.

6 JUDGE KELLEY: Well, we will cross that bridge 7 wten we come to it. It's also without prejudice, your right i 8 to try to raise the question.

9 And then we will just deal with it in a concrete  !

10 context rather than now in the abstract. Okay.

11 MR. EDDLEMAN: Thank you.

12 (The document previously marked l t

13 as Applicants' Exhibit Number 29 (w}

(- ,

14 for identification is admitted '

INDEXXX 15 in evidence.)

16 JUDGE KELLEY: Are you ready to tender for cross 17 ' at this point?

18 MR. HOLLAR: Yes, Your Honor. Except that the 19 .w itnesses are prepared to provide a brief summary of their 20 testimony.

21 JUDGE KELLEY: Why don't we go ahead with that and 22 then we will take a break.  ;

I 23 BY MR. HOLLAR: (Continuing) l p 24 4..adtral Reporters, inc.

Q Mr. Martin, could you briefly summarize your j I

25 testimony?

l

7902

  1. 11-16-SueWalph A (Witness Martin) Yes. My summary is based upon

() 2 the requirements of NUREG 0654, which is a FEMA document and l 3 the study which was performed as a result of that, both the 4 requirements of NUREG 0654 and the Shearon Harris ASLB.

5 NUREG 0654, Item J-10.m requests that expected 6 local protection in residential units or other shelters be 7

included as a basis for the protective actions which are l suggested in the plan.  !

8 9

Further, the Shearon Harris ASLB has interpreted 10 that requirement to mean that sound order estimates of 11 protections afforded by potential shelters be included in the 12 plan. As a result of the Board's interpretation, I directed

/'}

C 13 a study which was based upon four major parts.

14 The first one was an investigative part, which --

15 in which the types of structures, residential, institutional, 16 commercial and industrial were surveyed within the Shearon 17 Harris emergency planning zone. Following the investigation 18 of these structures, I went into what is called the categoriza-19 tion of the structures in terms of putting together a listing i

20 of the major categories of such structures as I mentioned 21 before.

22 Having categorized those structures, the detail f 23 survey of the typical structures within each category was

() 24 Ace Federrt Reporters, Inc.

performed. The detail survey itself consisted of an examina- ;

25 tion of the structures themselves by teams of certified fallout i

i

7903 )

l

  1. 11-17-SueWalls shelter analysts and also included a review of the construction

('O

_/ 2 and architectural drawings for such structures. )

3 Following the detailed survey of the structures, 4 tdue data which are necessary for the mathematical analysis of 5 the protection factors were determined and input into the 6 FEMA computer code for the purpose of . analyzing the pro- ,

7 tection factors for deposited nuclides. And the same data i

8 were used in the analysis of the protection factors for air- l 9 borne nuclides as a result of inhalation. f 10  !

END #11 Simons flws 11 12

)

14 15 16 17 18 19 20 21 j 22 l 23 24

{~}

awaro seponers, Inc.

25  !

7904 Sim 12-1 1 The PS for the various patterns of exposure 2 were calculated and the information was then available for

\

3 transmittal to the State of North Carolina Division of 4 Emergency Management. This is in essence my testimony.

5 MR. HOLLAR: Thank you, Mr. Martin.

6 Mr. Myers, could you briefly summarize your 7 testimony.

8 WITNESS MYERS: Yes. The Division of Emergency 9 Management has reviewed the results of the study and accepts 10 the results of the survey and protection f actor estimates 11 for typical institutional, commercial and industrial 12 structures within the EPZ.

~~

13 Based upon the information reflected in

~

14 Mr. Martin's testimony, the estimated protection f actors 15 of these mentioned structures will be listed in the 16 emergency response plan of the State. With the addition 17 of this information, the emergency response plan will comply 18 fully with the criteria J-10-M of NUREG 0654, and this 19 information will be used by the officials who will decide what 20 protective actions would be needed in case there was an 21 accident at the Harris plant.

22 MR. HOLLAR: Thank you.

23 Mr. Chairman, the witnesses would now. be 24 ready for cross-examination. Would you like to take a Ac rll Reporters, Inc.

25 break now?

Sim 12-2 JUDGE KELLEY: Yes. Why don't we take a break f r 10 minutes or so.

2 Thank you.

3 4

(Recess taken.)

JUDGE KELLEY: We are back on the record.

L t me just note briefly that we had an 6

informal conference of the parties just now concerning 7

timing, and without going into all the whys and wherefore's, 8

I will just state thai. we are going to proceed for another 9

hour this af ternoon and quit around 4. Then we will resume 10 jj in the morning here at 9 o' clock presumably with Eddleman's further cross-examination, and we expect to 12 finish this contention sometime tomorrow af ternoon.

13 j4 I will just say once more, we do hdve back 15 here tonight at 8 o' clock the limited appearance session and y u ar all w lcome to come.

16 Okay. iMr. Eddleman.

37 CROSS-EXAMINATION 18 j9 BY MR. EDDLETAN:

INDEX Q Mr. Myers, let me first refer to your capability 20 profile. That is sort of like a vita or a resume for somebody 21 who is not in emergency planning, isn' t it?

22 A (Witness Myers) I think you could call it a 23 resume, yes.

24 A er:1 Reporters, Inc. Q Okay. Now on page 2 it shows that you stepped 25

7906 int y ur pr sent employment in January 1985, correct?

Jim 12-3 1

2 A Yes, around the latter part of January.

3 Q That was after the change of Administrations?

4 A Yes, it was.

5 Q Can you tell us how many of the area coordinators, 6 which I see you had as your previous job before that, there 7 are in the division?

g A There are six area coordinator positions within 9 the Division of Emergency Management.

10 Q And were all of them or other people interviewed 11 for this Director's job? How did you move up to that?

12 MR. ROCHLIS: I am scing to object that it is 13 beyond the scope of relevancy, Your Honor.

t  !

~

14 MR. EDDLEMAN: Well, I think that he is 15 testifying about the state's plan and he has only been in 16 his job for about six months.

17 WITNESS MYERS: Le t me say this, in the ---

18 MR. ROCHLIS: Your Honor, would the Board rule 19 on the objection?

20 JUDGE KELLEY: Let me take this a step at a 21 time. We have a pending .gmstion and we have an objection, 22 and if you would just let Mr. Eddleman respond first, then 23 we may well want you to elaborate a little bit, Mr. Myers, 24 but hold off for a moment.

A er:l Reporters, Inc.

25 Go ahead, Mr. Eddleman.

7907 Sim 12-4 j MR. EDDLEMAN: Well, I think the relevance of 2

this is that he is testifying basically as to the nature 3 of the plan he is one of the people who in going to have 4 to carry it out. He has only been in the job he now hrlds 5

for six months, and I want to have some idea of how he 6 got there. I think it is to establish basically his 7 credentials, if you will, of how he sees the job and what 8 his experience is with these matters.

9 JUDGE KELLEY: And your exact pending question, 10 could you repeat it for me, please?

11 MR. EDDLEMAN: I think I asked him were other 12 area coordinators or other people interviewed for the job 13 Coordinator that he now holds.

14 JUDGE KELLEY: I will sustain the objection 15 to that. I think it goes too far afield. You can get to 16 his credientials without getting into the selection process 17 for the job.

18 MR. EDDLEMAN: All right, sir.

19 BY MR. EDDLEMAN:

20 0 You s tate that you have coordinated the Sta te's 21 response to over a hundred emergencies while in your current 22 position. That is since January, sir?

23 A (Witness Myers) Since the latter part of 24 Janaury, yes.

Ageral Reporters, Inc.

25 Q Okay. This is now the latter part of June, and 1

7908 Sim 12-5 1 that is 20 emergencies a month or about one every working 40 2 eay, correce2 3 A That is true. We have something almost daily 4 that comes down in terms of an emergency response within 5 the Division. We cover the entire State.

6 Q Are these primarily things like chemical spills or 7 wrecks involving potentially toxic materials?

8 A I would say this year it is projected that we 9 will have right at 1,000 emergencies within North Carolina, 10 and over half of them will be of the chemical nature. That 11 also includes search and rescue, weather phencmena and also 12 an emergency can be a community losing its water system,

- 13 it could be losing its emergency power. Those are the types 14 of emergencies that we are involved in, and also emergencies 15 at nuclear power plants, if that be the case.

16 Q But you haven't had any of those this spring, 17 have you?

18 A Yes. We have had, since I have been onboard, 19 we have had about three or four unusual events at one of 20 the nuclear power plants, and in my previous experience d 21 was involved in emergency response in these general areas.

22 O And you characterize an unusual event at a 23 nuclear plant as an emergency?

24 A It is one of the four emergency classifications.

11 Reporters, Inc.

25 Q All right, sir. Now with your responsibility i

i i

7909 Sim 12-6 1 for all these other matters, ,about how much of your time

", 2 do you spend on the Shearon Harris emergency plan, and in 3 what percentage, if you can tell me?

4 A Since I have been onboard I have spent quite --

5 I don't know what the percentage would be -- but I have 6 Probably spent 25 percent of my time since Janauary at least 7 on this particular plant.

8 Q Now does that include planning for the exercise 9 that went off in May?

10 A It includes planning for the exercise, the 11 planning for future exercises, it incudes the plan itself, 12 it encompasses training, coordication with other state 13 agencies, coordination with local government officials,-

~

14 actually conducting some training exercises 'in r6spective ^

15 counties, emergency operations simulations and so forth.

16 0 Would you be one of the people who if this 17 plan were activated would have to make decisions about the 18 question of sheltering or evacuating if an event of a 19 radiological release were possible from Shearon Harris or 20 had already happened?

21 A I, along with others. I would have advisers, 22 what are called technical support people, and the primary 23 being out of the Radiation.. Protection Section of' Human 24 Resources of the North Carolina State Government. And along Ac rol Reporters, Inc.

25 with those other agencies, probably another 10 or 15 agencies

7910 Sim 12-7 that support this plan, their techincal support people, i

just as though like if it was a forest fire that I mane.ged

(~)

\

us 2

3 this spring, and the Forest Service was the lead technical 4 support people in this particular case, it would be 5 radiation protection.

6 Q Now if an evacuation were deemed to be required, 7 could you order that, or would it have to go to a higher 8 level of state government?

9 A It depends on the authority and who is in command 10 and control of the operations at the time. If it was the 11 local government in control of the operation, it could 12 be ordered by the local government. But I would be 13 representing the Governor's Office of my boss, the u >

14 Secretary of Crime Control and Public Safety, I would be 15 representing him, who then represents the Gove,rnor's 16 agency.

17 The operations in the State is organized, we 18 call it the State Emergency Response Team. And when more 19 than two state agencies are involved in these operations 20 and if the state has assumed direction and control of the 21 operation, the order would be given from the Governor upon 22 recommendations from the various support people, the 23 technical support agencies to us that I have already 24 mentioned.

h.,ti n.pon.ri, Inc 25 0 Okay. Now if the evacuation were ordered at

7911 Sim 12-8 j the ammty level, would tha t require the authority of the 2 County Commissioners?

3 A The County Commissioners would be the ultima te 4 authority in charge of this decision.

5 0 All right. Now were you involved in preparing 6 radiological response plans when you were an area 7 coordinator?

8 A Yes I was. As a matter of fact I was called 9 from my office in Linkoton, and the first plans that were 10 developed after Three Mile Island, I was called on an 11 unlimited amount of time to Raleigh to work on the original 12 Brunswick plans that reflec ted 0654. Also, I coordinated

~~ 13 the development of the local plans for the Maguire Nbclear '

)

  1. S ta tion , for the five counties surrounding it. I also ja 15 supported in the development of the Cataba Nuclear Station 16 plans and also in the Shearon Harris plans.

17 Q All right. And in connection with that work, 18 did you become familiar with a document called NUREG 0654?

19 A I have been working with that document since 20 it became available.

21 Q And that is the basic criteria for preparation 22 and evaluation of radiological emergency reponse plans 23 and preparedness in support of nuclear power plants, right?

24 A That is the criteria that we are charged with A er;l Reporters, Inc.

25 using, yes.

1 l

l l

7912 Sim 12-9 1

Q All right, sir. In your wczk on the Shearon

[h

\/

2 Harris plant had you an occasion to read Criterion 2-J-10-M 3

before the plan was initially circulated, before the first 4

version was put out?

5 A Would you restate your question, please?

6 0 In your work on the Shearon Harris plan had 7

you known about the existence of Criterion 2-J-10-M of 8

NUREG 0654 before the first version of the Sheearon Harris 9

emergency response plan was put out?

10 A In the original beginning of th'e Shearon Harris 11

, plan, in that particular area, no, I was not. I was 12 aware of in general the details of 0654, but that particlar

~~

13

(}

element, no. .

14 Q Did you deal with that element in connection 15 with the other emergency response plans for nuclear 16 power plants uhich you helped to prepare?

17 .

A' In the other nuclear power plants we dealt 18 with this element, yes. Of course, in my line of work 19 it was more in coordinating and bringing in our particular 20 -

expertise that we have on our staff in shelter analyst 21 type people that we have, and my job would be overall 22 cordination in bringing in the three licensed shelter 23 analysts who get more into the detail, just like in the M,a n.por,,, o, communications area I bring in my communications expert, 25 or in the radiological area of training we bring in our

, - . - - - . . - - , - . - , . - , . - . . . . , ~ - , . -, , .-- -, -

7913 Sim 12-10 . .

I radiological instructor.

J)

V 2 Our course, my job encompasses overall 3 coordination and direction of this group.

4 0 So your responsibility with respect to these 5 other plans was to bring in the shelter analysts to do the 6 work that 2-J-10-M requires; is that right?

7 A To ensure that this is being done, to 8 ensure the training is being done and to ensure that all 9 the basic components are being met.

10 Q Well, now in order to do the shelter analysis 11 these people have to be trained, do they not?

12 A Yes, they do.

13 Q So your job was .to ensure that they were trained

) 14 and then ensure that they did the analysis; is that right? ?

15 A Being the Director, I have to put faith in my 16 staff. He have three quaif.ied FEMA fallout shelter 17 analysts and they do this. This is their normal job, 18 whether it is for the Shearon Harris plant or any type 19 of radiological surevey that would be requested.

20 Q Do you have a copy of NUREG 0654 available to 21 you?

22 A No, I don't.

23 Q Do you have one at your office?

24 A There are copies in my office.

hti it. port.ri, lac.

/ 25 0 Let me just ask you if you disagree with this

7914

  • ~

1 statement that criterion 2-J-10-M of NUREG 0654 requires

(~D 2 emergency response plans to include the bases for the choice U

3 of recommended protective actions from the plus exposure 4 pathway during emergency conditions and, further, that this 5 shall include, this bases shall include. expected local 6 Protection afforded in residential. units or other shelters 7 for, direct and inhalation exposure as well as evacuation 8 time estimates? Would disagree with that reading of 9 2-J-10-M7 10 A That is basically what I believe it is implying, 11 not having the document in front of me.

12 O okay. But there is nothing that jumps into your 13 mind that says that is not what it says, or that is wrong 14 as you have used that criterion, is there?

15 A Without having that document right in front 16 of me, and it is a rather lengthy document, that seems 17 basically in line with it.

18 MR. HOLLAR: Mr. Chairman, applicants will' 19 stpulate that that is what J-10-M says.

20 MR. EDDLEMAN: Thank you.

21 JUDGE KELLEY: Fine.

22 BY MR. EDDLEMAN:

23 Q Now, sir, you are testifying on this contention.

24 Do you have a copy of the contention? I am not sure if rd Reporters. Inc.

25 you are the one that repeats it in your testimony or whether

I 7915 Sim 12-12 1 it is Mr. Martin. Have you seen Mr. Martin's testimony?

2 A Yes, I have.

')

3 0 If we could just turn in Mt. Martin's testimony 4 to the bottom of page 2 and answer 4. Do you have that 5 available to you?

6 A Yes.

7 Q Now do you recall whether contentions were 8 submitted after the first version of the Shearon Harris 9 emergency response plan was made available to the intervenors' 10 A Not being the Director of that, I don't know the 11 answer.

12 hm. EDDLEMAN: Would the applicants stipulate 13 to that?

I 14 MR. HOLLAR: We will stipulate that there were 15 contentions proposed on the basis of the first version 16 of the emergency response plan.

17 MR. EDDLEMAN: Will you stipulate that 57-C-10 18 was one of them?

19 MR. HOLLAR: Certainly.

20 MR. EDDLEMAN: Thank you.

21 BY MR. EDDLEMAN:

22 0 Mr. Myers, when did you first become aware 23 of the existence of this contention 57-C-10 in connection 24 with 'our f duties with the Division of Emergency Management?

Ah.r: Reporters, Inc.

25 A (Witness Myers) Shortly after my appointment.

7916

.Sim 12-13 1 Q Your appointment as Director this Janaury?

O. 2 ^ ve -

3 O But you didn' t have anything to do with that 4 in your previous work on the..Shearon Harris plan?

5 A My previous work on the Shearon Harris plan was 6 more centered initially in preparation of local governments, 7 in preparing local governments to respond to the emergency 8 as it had in the other plants, the functions within emergency 9 operation centers that I related to earlier, emergency 10 opera ting simulations, direc tion and control, plant overviews ,

II and things of this nature.

12 O You said you had three shelter analyst.s in 13 y'our division?

I4 A That is true.

15 0 When you became aware that this contention 16 existed, what action, if any, did you ask them to take?

17 A Two of the individuals have served as one of 18 the teams that went out, that actually went with Mr. Martin's 19 group in conducting the surveys.

20 0 And was that done at your initiative? Did you 21 start that survey?

22 A I requested that my employees be part of the 23 team.

2d Did you request that the team be set up? Did Q

ed n.pors.ri, Inc.

25 you request tha t that be done?

7917 Sim 12-14 j A No, I didn't.

2 0 Who did request it, if you know?

A That I couldn't answer.

3 4 Q Was it somebody in s tate government, to your 5

knowledge?

6 A There again, I couldn't answer.

7 0 All right, sir.

What supervisory role, if any, did you play 8

9 yourself in the work of this team?

10 A Well, I am overall responsible for the operation 11 of the Division and to ensure that my employees are 12 functioning and carrying out their jobs to see that emergency 13 Plans meet all the criteria, you know, all of the various-s* that are involved in emergency planning. I am over all ja direction and control. I am the Director of the Division, 15 16 and I think it speaks for itself.

j7 Q Now by the various criteria there, do you mean 18 the criteria of NUREG 0654, among others?

39 A No. I was really alluding to all of the 20 different types of criteria that are laid out in emergency 21 P l anning.

22 0 Excuse me. Go ahead.

A There are other areas of emergency planning 23 24 ther than just this partiuclar area.

A$.r: n.porteri, Inc.

25 Q Okay. But with respect to nuclaer power plant 1

7918 Sim 12-15 1 plans, the basic criteria are those of NUPIG 0654, would t 2 you agree with that?

3 A The basic criteria is in NUREG 0654.

4 Q Mr. Myers,.let me return, if we can, to your 5 prefiled testimony.- Do You have that before you?

'cnd Sim 6 ,

A Yes, I do.

Jo2 fois ,

7 8

9 10 11 12

.o 14 15 16 17 18 19 20 21 22 23 h I n.porteri, a.

25

1 13-1-W21, J. 7919 1 Q I would like to show you a two-sided -- a sheet 2 of paper that is printed on two sides. One side marked 3 Exhibit 57-C10-A, and the other side marked 57-C10-B, with 4 some writing on it, which I submit to you is information 5 which is contained, and didn't xerox well off of an original 6 document, that I will now show you if your counsel doesn't 7 object.

8 MR. HOLLAR: Not yet, Mr. Eddleman.

9 MR. EDDLEMAN: Okay.

l 10 BY MR. EDDLEMAN: (Continuing) i 11 I would like to ask you if the handwritten Q l I

12 . information with the arrow pointing to the blacked out top I l

,s 13 of the Floor Mass Thickness Manual for Walls, Floors, and  !

14 Roof cover that is on this Exhibit B, is the same as what it 15 actually says in the dark part of the original document that 16 I am showing you.

I 17 (Mr. Eddleman hands document to 18 Mr. Myers.)

l9 A (Witness Myers) Part of it is. I am having a 20 hard time reading the dark part. I think it says supersedes !

21 TR-68, dated September 1980, which may be used. l t

22 It supersedes it. It looks like it is the 23 same thing, other than this (pointing) should be right in h 24 Ace +ederd Heporters, Inc.

here.

25 Well, this is another one. The top one is a 0

I

\

13 W21, J . 7920 I different one.

2 A You are saying it should be in this general 3 area right here?

4 Q This is the other one, if you would like to 5 compare them.

6 JUDGE KELLEY: You could agree it is the same, 7 subject to check. If you want to just leave open that 8 option. ,

9 WITNESS MYERS: It appears to be the same.

10 BY MR. EDDLEMAN: (Continuing)  ;

II Q Okay. Do you have a copy of my exhibits j i'

12 available to you, sir?

13 A' (Witness Myers) No, I don't,. I do. >

Id Q You have copies, don't you?

15 A

  • Yes, I do.

16 All right. Now, do you in your emergency Q

17 planning work for nuclear power plants, have you ever seen f

18 the documents whose covers are reproduced on Exhibits A and l 19 B?

1 20 A These documents -- there again, these are 21 detailed documents that would be used by fallout shelter ,

22 analyst men. I would assume they would be in the office l 23 there, yes.

24 And the methodology of fallout shelter analysis I QA a n.corwes, anc.  !

25 is the same methodology you used to evaluate shelter and

- -. . _.. - - _ _ - _ . - _ _ - . . - . . ~ - ..

13-3-W21, J.

7921 1 effectivenss for nuclear power accidents, isn't it?

() 2 A (Witness Martin) Yes, it is.

3 Q You were saying, Mr. Myers?

4 4 A (Witness Myers) I think there is some basic i

5 similarities. Not being a fallout shelter analyst myself.

6 Q All right, sir. Mr. Martin, as long as you ,

7 spoke up, you also have a copy of these exhibits available 8 to you?

l i 9 A (Witness Martin) Yes, I do.

10 Q Okay. Have you ever seen the documents whose i

11 covers are reproduced on Exhibits A and B? l l

12 A Yes, I have. l 13 Have you ever used them? l Q ,

14 A Yes, I have.

15 0 In your work cs a shelter analyst? i 16 A Yes, I have.

17 Q Thank you. Mr. Martin, were these documents  ;

18 that the covers are reproduced on Exhibits A and B, were {

19 they available to you before -- pardon me. Had they been 20 published and made publicly available before March of 1984 t 21 to your knowledge? l 22 I believe that it helps to check that the A's i

23 are dated January 1984, and the B's are dated May '79 and I 24 January '84, respectively.

s nepon n. inc.

25 MR. HOLLAR: Mr. Eddleman, who are you directing a+--

13-4-WS1, J.

, 7922 l

1 the question to?

l 2 MR. EDDLEMAN: To Mr. Martin. I thought I said 3 Mr. Martin.

4 WITNESS MARTIN: According to the note, which 5 is in the right hand margin here of Exhibit B, it looks like 6 the document is dated January of '84, and Exhibit A is 7 dated January '84, so the answer to your question then would 8 be, yes, they would have been published prior to March of '84..

l 9 BY MR. EDDLEMAN: (Continuing) 10 Q Okay. I have the original of that document 11 if you would like to check the handwriting against it, or l 12 if you would accept it subject to check, that it is ,what it

, 13 says. -

Id The date of the document is what the handwriting 15 says on Exhibit B. l 1

l 16 MR. HOLLAR: I am not sure what we would be  !

17 accepting subject to check. I am --  !)

18 MR. EDDLEMAN: That the handwriting on l

19 Exhibit B shows the actual language that appears on the dark l t

20 part of the document. The same one that I showed Mr. Myers i

21 earlier.

22 MR. HOLLAR: We will accept that.

23 MR. EDDLEMAN: Thank you. i 2d JUDGE KELLEY: Have you offered these yet, Mr.

s meserwes tae.

25 Eddleman, A and B?

I

13-5-W21, J. l 7923 1 MR. EDDLEMAN: No, sir. I think that nails 2 it down to the point where I would like to now go ahead and 3 offer Exhibits A and B into evidence.

4 JUDGE KELLEY: No objection?

5 MR. HOLLAR: Yes, Your Honor.

6 JUDGE KELLEY: You do have an objection?

7 MR. HOLLAR: Yes, I do object. I am not sure j i

8 for what purpose Mr. Eddleman intends to offer these exhibits,l 9 and he certainly has not demonstrated that either one of 10 them was used in developing the information to respond to  !

11 Contention 57C-10.

12 MR. EDDLEMAN: I believe Mr. Martin already j i

"'s "13 testified that'he had used these documents in his work as l

~_ ,

14 i a shelter analyst. I believe Mr. Myers stated that he 15 believes those doucments are available in his agency for use 16 by shelter analysts.

17 They purport to have made shelter analysts 18 here, and I don't think I have to say the purpose for which 19 I am going to use the document. All I have got to do is find 20 that the witness knows what the document is, and identify it, 21 and then it can be placed into the record.

22 JUDGE KELLEY: Well, if you have got an objection i

23 that its purpose is not apparent in terms of relevancy, I 24 eeral Reporters, inc.think you are under some obligation to spell out why you are Am l 25 offering it. i

.( - ..

13-6-W21, J.

7924 I

l 1 It is not clear to me why it is being 2 offered. We 'either have looked at protective factors well

  1. 3 enoughoYwehaven't.

<4 These particular additiens and the dates on 5 them, how are they significant to the contention?

6 MR. EDDLEMAN: Well, I think that the dates show 7 that the information was available early enough that it could I 8 have been incorporated into the plan previously.

l l 9 I think that the document showed that the 10 -

information on which you could make such analysis was availabl,e 11 to both Mr. Martin and his company, and to Mr. Myers agency l

l 12 and that they could have used that information at any time.

4 13 r They didn't have to wait until there was a j 14 contention, and I think that also it does show the -- it ,

, i 15 does identify specifically the documents in addition to the l

j 16 documents which are used in sheltering analysis.

17 JUDGE KELLEY: But as to the first point, without 18 expressing a view one way or the other, I assure you I don't 19 have one, let's suppose hypothetically that the licensee has l

i 20 an emergency plan and has some flaw in it, and some l l l

j 21 Intervener files a contention on it, and the licensee realizes-t 22 there is a problem, or wants to make it, better, so he fixes k

23 it.

l 24 Is that relevant to this Board? To our ruling?

d Moporwes,Inc.

l '

i 25 MR. EDDLEMAN: I think, Judge, when the question 9 f^

13-7-W31, J. ,

7925 1 is how information is going to be used, that it is relevant

( ). 2 to look at how the information that was in hand ear' t.r was 3 used, and I think the question in this contention is how 4 they are going to be able to use the information that has 5 been developed, and I think their willingness to develop that 6 information is a relevant point.

7 JUDGE KELLEY: Does the Staff have a comment?

8 MR. ROCKLIS: Yes, Your Honor. As I understand 9 the Ruling from April 24th, we are here to determine whether 10 or not the survey -- whether the plan should include the 11 protection factors available from -- not the residential, but; 12 the commercial and institutional structures in the EPZ, and 13 I thought that was the reason why we were here. ..

(s .

14 I don't see how whether or not that information 15 was available earlier, or whether it is available now, has 16 any effect on whether or not the survey done by the Applicants

i 17 is a valid survey, and should be included in the plan.  !

18 JUDGE KELLEY: It sounds like you are arguing, l

19 Mr. Eddleman, that the contention almost goes to attitude. t 20 That we have to determine whether a particular set of 21 officials will act with diligence, given the fact that you i 22 may wish to show that there was information around that they {

l 23 should have used before, they didn't use. l 24 MR. EDDLEMAN: Judge, I think that is exactly the' d Reporters, Inc.

25 finding you have to make. Not just under this contention, but.

4

13-8-Wal, J, 7926 1 udder 10 CFR 5047 a 1.

7 )

U ! 2 And I think that the contention states that 3 the reason that you need this information is to make the 4 decision do you -- the decision on whether to evacuate or 5 whether to shelter.

6 And I think that the attitude a.nd the abilities 7 of the decision-makhrs are very relevant to that question. i 8 JUDGE KELLEY: Just a minute.

9 (Board confers.)

10 MR. HOLLAR: Mr. Chairman, could I make one II point? I 12 JUD'GE KELLEY: Just a minu.te, please.

(~x) 13 (Board confers.) .

a \

Id JUDGE KELLEY: We are just going to take a 15 moment to look at our own ruling.

16 Well, it seems useful at this poirit to focus 17 on this question of scope., Mr. Eddleman, I guess what j

18 troubles us is that, looking at our own order here, which l9 in effect cut back on 57C-10, and we said at Page 6: The 20 one issue which remains concerning the Applicants' review 21 of typical sheltering in the Harris plume EPZ is the adequacy ,

22 of the Applicants' review of sheltering other than single  !

l 23 family residential.  !

24 erd Reporters, Inc.

And we go to say some more things, but the  !

25 thrust of it is that is what is in, that coupled with the  !

13-9-Wnl, J.

7927 1 wording of 57C-10 itself, it doesn't seem to me to encompass s ) 2 an attitudinal argument, if you want to call it that.

3 If you want to restate your point, please do.

4 MR. EDDLEMAN: Well, let me try to respond to 5 that, Judge.

6 I think in the first place, I don't think it 7 is the Applicants' review of whatever that statement may say. ,

l 8 I think the emergency planning contentions have to do with i 9 the assurance that the plan can and will be implemented, and I i

i 10 they have to do with the plan.  !

11 And as to the question of whether you can take 12 that out, I think it is a question of how you define the j l

13 issue. l

)

l's-J l 14 In other words, ifyouwanttosaywelltheonly!

15 thing that is missing here then, the physical piece that is 16 missing, is the protection factors for the shelters other 17 than residential, okay, which is something I argued -- let 18 me see, I am looking to find my response argument.

19 Here it is. I am just not sure that the 20 argument was ever directly made that the usefulness of the l

21 information should be thrown out.

22 And I tried to look and see if I could find l 23 a response that basically said I think the usefulness of the ,

24 information should be in there. i Ace- err) Reporters, Inc.

25 JUDGE KELLEY: I am afraid I am confused. i i

13-10-Wal, J '

7928 1 I was talking about your argument, as I understood it, that 2 belated use of information indicated that the people in charge 3 might not be quite on top of things, and they really couldn't 4 be relied upon to do the right thing when the time came, if 5 it came.

6 It is called an attitudinal argument.

7 Now, usefulness of information, that is a 8 different thing isn't it?

9 MR. EDDLEMAN: Well, I think that -- okay, the 10 information's usefulness in the plan, I may have confused Il the issue by picking up that phrasing, okay?

12 The usefulness of the information in the plan

(~ 13 depends on the attitude of these. people who are using it.

Id I mean, you know, you can put say a math book full of the 15 most advanced mathematics in front of somebody who either i 16 does not or will not understand it, and it is not useful, I

I7 and the point of this information being in the plan is to help 18 -make that decision.  !

I9 So, in'other words, I don't think there is 20 really any purpose in having a concention at all if you just l l

21  !

say: Is the information there or not?

22 The question is: Are they going to be able 23 to use it effectively to protect the health and safety of the public.

.i n.ponen, anc.

That is the position I think I have always taken.

13-11-Wnl, J.

7929 1 JUDGE KELLEY: Well, let's pause a minute.

r-

,U 2 (Board confers.)

End 13.

Sus W fois .4 5

6 7

8 9

10 ,

i 11 l 12 S

r'j.

\

13  ;

14 1

15 i 16 l .

17 18 19 l

t 20 l i

21 i 22 23 24 Ace- eral Reporters, Inc.

25

7930

  1. 14-1-SueWalsh JUDGE KELLEY: I'm looking at your contention, and ,

() 2 I don't find language which fairly encompasses the notion that 3 the officials will not be competent or willing to use the 4 information that is there.

5 In the summary disposition, I thought we were 6 talking about what was there, and we found something missing.

7 Namely, protection factors for certain kinds of buildings i l

8 other than residential.  !

9 But 1 think we are surprised to hear it argued 10 that we are now into the motivation and ability of the people ,

11 who would be involved. And I dare say, that's not necessarily 12 our witnesses here.

13 MR. EDDLEMAN: Well, I think, too, J-10.m says 14 what it says. And it's true, I didn't quote the whole thing  ;

15 in the contention.

16 But you have got to remember, I was under that 17 hundred word limit for writing a contention, so I didn't 18 quote the whole thing.

19 JUDGE KELLEY: You are arguing that the whole of 20 J-10.m. should have been incorporated or understood as 21 incorporated in this contention?

22 MR. EDDLEMAN: Yes, Judge. I mean, my phrasing  ;

23 of the nature of the problems with the State plan above was 24 A

~')

! (bwderd Reorters, lu.that you've got to -- in order to carry out 2-J-10.m., you've  !

i l

l 25 got to do all of these things, including having the information' ,

i

,~-r - , . - n.- , -----e,-- , - , , ,

- ~ - - - , - - - - - - - - . - - . , ,,

7931

  1. 14-2-SueWalsh but that you've got to be able to use it effectively. I i

g%

2 think in the preamble to my contentions I was mentioning 3 50-47. See, 57-C was a deferred contention, and then it was 4 revised in the contentions.

5 And, as I recall the lack of compliance with 6 10 CFR 50-57.A.1, with the assurance that effective protective ,

7 action can and will be taken, was the underlying reason for 8 all of these contentions. So, I thought it was included 9 maybe in the way that the Board thought Mr. Vanvo's presence i

10 was included in the decision on the five factors on Contention !

11 41.G.  ;

l 12 But I did think it was included ~in that, and I've  !

i 4 13 always assumed that it is.  ;

}

14 JUDGE KELLEY: I would think a contention that did 15 ncthing but recite from 47.A.1 would be thrown out for vagrants.!

16 All it does is say make a safe plan.

17 MR. EDDLEMAN: Well, that's right. But what I'm 18 saying is --

19 JUDGE KELLEY: That gets us no place.

20 MR. EDDLEMAN: Beg your pardon, Judge. That wasn't 21 what I was saying,'that you should be able to just have a  ;

22 contention with 47.A.1 in it.

23 What I was saying was that failure to comply with ,

() 24 AmvWerd Reporurs, lm.

47.A.1 is the underlying criterion for all of these contentions, 25 thatyoucan'thaveanemergencyplanning--acontentionwithobt I

i I

7932  !

  1. 14-3-SueWalsh challenging the compliance with 50.47.A.1, and that that was  ;

{) 2 the -- I'm looking for the right word. It is the context in 3 which all these 57-C contentions exist.

j 4 JUDGE KELLEY: Well, we are basically talking about 5 the scope of your contention. I don't agree with the notion I

6 that you have to somehow invoke 47.A.1 in order to even get i 7 into emergency planning contentions.

8 I think you could allege an inadequacy under some '

9 more specific subsection without any reference ,whatever to  :

10 47.A.1 and it might be perfectly valid. i 11 But, in your contention you do refer to evaluation 12 criteria in J-10.m. and then you go on to say specifically, ,

t 13 this is the context you give it, which calls, for inclusion 14 in the plan of expected local protection afforded in residential 15 units or other shelter for direct inhalation exposure.

16 So, the word picked up on "other shelter" and said:

17 All I've got here is residences. Go out and look at the 18 commercial buildings. And that's pretty much how we came'into 19 the hearing room I thought, not on sort of an open-ended 20 excursion into what we could find in the plan with reference 21 to that criterion. .

22 Well, let me hear from the other counsel if they, i

23 care to add. Mr. Hollar?

24 MR. HOLLAR: Mr. Chairman --

{~}

ib Jerd Reporars, lm l

l 25 JUDGE KELLEY: The operational question is the f

7933

  1. 14-4-SueWal1 admissibility of Exhibits A and B I believe- and we are off l')

\m/ 2 on a rather broad issue, a broad discussion. But the narrow 3 issue is whether these two exhibits are admissible.

4 rou say they are not relevant. If you have nothing 5 to add, that's okay. ,

l 6 MR. HOLLAR:

~

Mr. Chairman, I would just add that i

7 I believe Mr. Eddleman's arguments can be summarized very -

I 8 succinctly as an effort to turn what the Board has made a I 9 very narrow contention on the basis of its ruling on the j 10 Motion for Summary Disposition, Mr. Eddleman would like to Il t urn that into some sort of a general contention on protective 12 action decision making.

13 And that's not the contentioh that we have before ,l 14 us.

15, As to the particular d'ocuments that you have, he 16 has made no showing that they were used to address the re-17 ' maining issues on 57-C-10, and I think they are clearly not 18 admissible documents.

19 MR. ROCHLIS: I would just ask Mr. Eddleman's 20 clarification. Is he admitting the entire document or just 21 a copy of the cover page of the document?

22 MR. EDDLEMAN: I'm just asking for a copy of the l

l 23 cover pages to be admitted.

f ( ') .

24

!d-rdirrd Reporters, Inc.

MR. ROCHLIS: I don't see how that is relevant at l l

25 all, other than to say that these documents were available l

l l . . _ . . , , _ . _ _

_ _ - . _ , = , , - ,

7934

  1. it-5-SueWall and I don't think that's the issue that is here before the A

_ ( ,/ 2 Board today.

3 JUDGE KELLEY: Excuse us a moment.

4 (The Board members are conferring.)

5 JUDGE KELLEY: The Board has heard arguments and 6 c onsidered this matter, and we are sustaining the objection 7 to the proferred exhibits.  :

I 8 And our ground is that thic is, as we have always 9 und'erstood it, and in the light of our rulings on Summary i

10 Disposition, a very narrow contention. And it has to do  !

with whether the Applicants and the State and local people

$ 11

?

j 12 have done an adequate job in determining the protective *

{

13 factors associated with certain types of buildings other than

}

14 residential buildings. l 15 We do not see that as encompassing some broad 16 inquiry on the capability of tdue decision maker and what they l 17 I would do with protective factor information. The contention 18 as proposed, and as modified, our Summary Disposition Order 19 doesn't say that, it seems to us that its whole thrust is 20 toward protective factor determinations.

21 So, we are disallowing these exhibits on that ,

l 22 basis.  ;

23 MR. EDDLEMAN: Judge, if I may, I would like to do 24 4

(~')

> $rwercl Rgorwes, Inc.

two things. I.would like to request that proposed Exhibits l 25 A and B on 57-C-10 be placed in the record as offer of proof.

l l

i

. - . . vn.,. . . . . ,,, ,,,,_,,-.,,-.l-.--.-.__., , , _ - . _ . - . , . . , , . . . - , . . , . , , , , - - , - , . _,...-,n

7935

  1. EF-6-SueWalsh JUDGE KELLEY: Yes.

~

/ )h

(_ 2 MR. EDDLEMAN: And I would like to state my 3 position for the record. I understand that ya'll are the 4 Board and that you haven't exactly decided the -- well, I 5 guess maybe you have implicitly decided the issue of the scope 6 of the contention. And I would just like to put my position 7 of that on the record.

8 I understand that I will have to go forward under .

9 the Board's ruling, because ya'll are the Board. '

10 JUDGE KELLEY: Right.

Il MR. EDDLEMAN: But, I think that in order to make 12 the finding that is required by the Rule 57-47.A.1 that you

__ i 13 have to know. that the people 4?ill be able to make effective 14 use of this information.  !

15 And if I can't cross-examine on that question, I 16 think it's very prejudicial to my case. I will go forward 17 under the conditions the Board has set. I don't have any 18 real choice.

I9 But I just want to make my position clear on the 20 record. Mr. Myers already testified on the previous contentioni 21 that if they didn't have time to evacuate everybody, their ,

l 22 choice would be sheltering. And so I think the question of j

! i 23 that decision is a very important one in deciding whether the i i

f) 24 AMsr:1 Reporters, Inc.

effective protective actions can and will be taken. l l 25 JUDGE KELLEY: Well, just a comment. I don't have I

7936 ilLF-7-SueWalsh1 my book right here, but you should be aware, Mr. Eddleman,

(* . i

\ 2 that there is a Rule -- I think we cited it in our last  !

3 decision -- which confines this Board to deciding contested 4 issues. The A.1 determination that you are talking about I 5 think only comes into play for this Board insofar as there are i

6 a range of contentions we are going to decide, and whether they.

7 all add up to a finding of adequate protection for the public.

i 8 This Board is not going to make some comprehensive 9 safety finding on all aspects of emergency planning. We are 10 n ot about to do that.

11 The Staff will do that with respect to everything 12 that doesn't get involved in this case. But we won't.

/~ 13 And that's why -- not the only reason, but in part L

^

%3) 1 14 we restrict our inquiry to the contentions that are admitted, 15 as they are modified by Summary Disposition or our rulings.

10 MR'.'EDDLEMAN: Well, Judge, I don't want to belabor 17 this. I am attempting to contest this issue, but the Board l

18 I has ruled and I want to go forward on that basis, because I 19 have no other choice.

20 JUDGE KELLEY: Okay.

^

21 BY MR. EDDLEMAN: (Continuing) 22 Q Mr. Myers, on Page 2 of your testimony, Answer 3, 23 do you take the meaning of structures other than residential

() 24

' AMIrd Reporters, Inc.

structures to be institutional, commercial and industrial 25 structures only? '

i

- - - - - - - ~ - . .,, - , - -- e -

7937

  1. 14'8-SueWalsh A (Witness Myers) I think that that's pretty correct,

^

/T eg 2 yes.

3 O All right. But the criterion is the protective 4 factors afforded by residential and other structures, without 5 just limiting it to those three areas, is it not?

6 A It says residential and other type structures 7 within the NUREG.

8 Q Okay. In Answer 4, had you read Mr. Martin's j 9 testimony when you prepared this testimony?  ;

10 A I had reviewed the results of the survey.  !

II Q Okay. But you had not reviewed his summarization 12 of those results when you prepared this testimony?

~~s 13 A I can't recall. I I4 O All right. Do you -- are you yourself a licensed '

15 shelter analyst?

16 A No, sir, I'm not.

I 17 0 When -- do you know the factors affecting inhalation :

l 18 I radiation dose within structures?

19 A I know in broad terms on radiation protection 20 factors, you are talking about time, distance and shielding 21 from the source of radiation. And the thickness of walls versus 22 windows and being in interior parts of buildings; basements are!

23 better than being outside, and it's better to be in certain 24

(^3 d%,jeral Reporars, Inc.

parts of homes, if you are double stacked, triple stacked, it's; 25 better to be in there than in certain other types of environments c i

7938

  1. 14-9-SueWalsh some little building that's not made out of concrete or things

() 2 of that nature.

3 Q And are those, in your view, the factors that affect 4 inhalation radiation dose within structures in the EPZ?

5 A I'm aware that, like I said earlier, in very 6 general terms about protection factors. But on my staff I ,

7 do have, and available to me through other agencies that are f

8 major parts of our emergency plan and decision making, would 9 be these individuals that have the knowledge and the expertise,;

10 the technical background to assist in making these decisions.

11 '

Q Let me refer you to the last sentence on Page 2, 12 also in your Answe,r 4.

13 Do you have the knowledge yourself to judge the

(~3 v

14 accuracy of the ranges of protection factors that were pre-l 15 sented in Mr. Martin's testimony?

16 A I have general knowledge of ranges of protection 17 I factor, knowing that one being the lowest and on up, the 18 '

protection factor being greater on your numbers and so forth.

19 But I, as an individual, have this information 20 available that is, as I said earlier, through members of my 21 staff.

22 Q Well, now I will come back to that in a moment, 23 sir, but do you -- what knowledge about protection factors 24 f^')

Ab. .ler:t Reporters, Inc.

do you have yourself that would lead you to believe that 25 ranges of protection factors presented in Mr. Martin's testimony

7939

  1. 14-10-SueWaB are accurate?

) 2 A I have, as I said earlier, general knowledge of '

3 protection factors, depending on what the building is made 4 out of, the construction material, the distance you are from 5 the radiation source, the time of exposure; that several 6 buildings are going to be stacked, two or three-story buildings',

i 7 that you want to -- that gives you more radiation protection 8 overhead; that if you are in a building with a protection  ;

9 factor of a hundred, it'sahundredtimessaferinsidethanitj 10 is outside. i 11 There again, I don't claim to be a health physicist 12 or 'a fallout shelter analyst, but we have these experts  !

13 available and they are always available in times of decision

(~]s u_ '

14 making of something of this magnitude.

15 ,

Q Well, now suppose we had a building where the range 16 of protection factor was listed at three to forty, would you 17 have anyway of your own knowledge to judge whether that range 18 is reasonable or accurate?  :

19 A Unless I had people to go out and actually calculate 20 it, no, I wouldn't personally.

21 Q All right, sir. Your Answer 5, the question is:

22 What does DEM intend to do with the information obtained from  ;

23 this survey?

24

()

.++.aeroi n. porters, Inc.

Would you, in fact, be using this information in  !

25 the event of a radiological emergency at the Harris plant?

l

l 7940 014-11-suewalsh A This, along with other information, would be one

(

f^w) 2 of the tools that we would use in determining whether we

! 3 would evacuate, shelter or so forth.

4 0 All right. Now, I think you stated earlier that 5 you hadn't read Mr. Martin's testimony when you prepared 6 this testimony; is that correct?

7 A I stated that I couldn't recall. -

8 Q You couldn't recall? Do you recall now? l l

9 A No, sir.  !

I t

10 Q Okay. I thought you might have recollected. But, 11 let me ask you, the -- do you recall the percentage of -

< 12 structures that were actually analyzed by Mr. Martin and l

13 his team?

(, ,). .

t

, w_s i 14 A Not right offhand, I don't. Maybe Mr. Martin may 1

15 ^ have the answer to the percentage. Members of my staff, as 16 I said earlier, formed -- it was three teams, and two of I

17 i the members of my staff were placed on these teams.

18 Q Uh-huh. Well, I will come to Mr. Martin later.  !

l 19 But what I want to ask you is, do you even have any idea i

20 what percentage of the structures in the EPZ, other than"  !

21 residential, that those teams actually did a detailed analysis 1

22 of the protection factors in?

23 A I don't know the exact percentage.

s 24 O Do you have any idea of what the percentage is?  !

c.(gjgertl Reporters, Inc.

25 A I don't know the exact percentage.

4

7941 5

  1. 14-12-SueWall Q Well, I understand that you don't know the exact

[~D 2 percentage. I asked you, do you have any idea about it?  !

\/

3 MR. HOLLAR: I'm going to object, Mr. Chairman.

4 I think he has answered the question. This is getting a 5 little repetitious.

6 MR. EDDLEMAN: Well, Judge, I think -- for example, !

I 7 you might ask me, what was CP&L's electricity growth rate 8 last year and I could accurately answer, I don't know the l 9 exact percentage. But if somebody asked me, do you have any ,

10 idea, I can say that it was sure less than ten percent. i 11 I'm asking him the same kind of question, is there 12 any scope to his knowledge other than not knowing the exact

,s 13 percentage.

("~ l '

14 JUDGE KELLEY: Overruled. You can answer the '

15 question if you can.

16 WITNESS MYERS: I don't have the answer.

17 '

MR. EDDLEMAN: Judge, is this a good place to stop?

18 I think we are around four o' clock.

19 JUDGE KELLEY: I believe so. As we indicated 20 earlier, we are going to stop for the day at this point and 21 be here this evening at eight for limited appearances. We 22 trust the Reporters will be with us. '

23 And all of you, I hope. And we will be here tomor-24 r ow morning at 9. Anything else before we stop?

qerst Reporters, Inc.

25 MR. HOLLAR: A point of information, Mr. Chairman.

7942

  1. 14-13-SueWalph JUDGE KELLEY: Yes.

~

2 MR. HOLLAR: Is the public session to be in this 3 room?

1 4 JUDGE KELLEY: Yes.

t 5 MR. HOLLAR: Thank you. l 6 JUDGE KELLEY: Thank you.  ;

i 7 (Whereupon, the hearing is adjourned at 4:01 p.m., l 8 Monday, June 24, 1985, to reconvene at 9:00 a.m. on >

9 Tuesday, June 25, 1985.) ,

i ENDDDDDD 10 .

11

- 12 ,

I 14 15 16 i

17 18 i 19 20 21 22 23 '

2A A6#2 erst Reporters, Inc. 4 25

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NO PAGE NUMBER CERTIFICATE OF OFFICIAL REPORTER A

k-This is to certify that the attached proceedings before the UNITED STITES NUCLEAR REGULATORY COMMISSION in the matter of:

NAME OF PROCEEDING: SHEARON HARRIS Evidentiary Hearing DOCKET NO.: 50-400-OL PLACE: APEX, N.C.

[vD DATE: .

MONDAY, JUNE- 24, 1985 -

were held as herein appears, and that this is the original transcript thereof for the file of the United States Nuclear Regulatory Commission.

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Y,'

(Typed) MYRTLE H. WALSH (TYPED) GARRETT J. WALSH, JR.

Official Reporter Official Reporter Reporter's Affiliation:

ACE Federal Reporters Reporter's Affiliation ACE FEDERAL REPORTERS m (Sigt)

N' (Typed) MARY SIMONS Official Reporter Reporter's Affiliation:

ACE Federal Reporters