ML20137W825
| ML20137W825 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 02/06/1986 |
| From: | Shaye S GEORGIA POWER CO., GEORGIA, STATE OF |
| To: | |
| References | |
| CON-#186-110 OL, NUDOCS 8602200377 | |
| Download: ML20137W825 (64) | |
Text
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Q y y g ggzqwy g3 ggg l' UNITED STATES OF AMERICA
(
NUCL5:AR REGULATORY COMMISSION BeforetheAtomicSafety[gificensingBoard-J c
In2 the Matter of 116 FJ818 P3:23
)
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. GEORGIA POWER COMPANY, eeWagC[7g)~ it'- ^:g: . Docket Nos'. '5 50-425-Nogtle Electric Generating )
Plant,-Unit 1:and 2) ) ,
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Deposition of SEYMOUR ISHAYE$ t,akenfon.
behalf 'of the Applicantsp purs'uant to ' No'tice ,.
in accordance with/the NucleargRegulatoryj A p ', ; -
E., t ' . ~
? ;^ -
Commission 's Rules ' of Pra~ctice , be fore Sharon,D. Upchurch, certified Court ~ Reporter a c - -
. and Notary Public,.at 1400 Candler Building',
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A t l'a n t a , Coorgia, on'the 6th day of January, 1986, commencing.at the hour of 10:00:a.m.
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b STUART S. H USEBY & ASSOCIATES,l NC.
CERTIFIED SHORTHAND COURT REPORTERS Suite 400 One Pork Place P. O. Box 719 1900 Emery Street, N.W. Goinesville, Georgio 30503 Atlanto, Georgio 30318 (404) 536 7028 (404) 351 0300 h22OO377860206 i ADOCM 03000424 PDR
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2 f 1 APPEARANCES OF COUNSEL:
() 2 On Behalf of the Applicants: HUGH M. DAVENPORT, Esq.
Troutman, Sanders, 3 Lockerman & Ashmore 1400 candler Building 4 Atlanta, Georgia 30043 l 5 On Behalf of the Intervenors: L AU RIE FOWLER, Esq.
220 Grant Building 6 44 Broad Street l Atl ant a, Georgia 30303 1 7 I 8
9 I 10 MR. DAVENPORT: For the record, 11 this is the deposition of Seymour Shaye, taken pursuant 12 to Notice at a time and place agreed upon between the 13 parties. This deposition is being taken in accordance
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14 with the Nuclear Regulatory Commission's Rules of 15 Practice f or domestic license proceedings.
16 Mr. Shaye, has your attorney explained to you 17 your right to review and sign your deposition if you 18 choose?
19 MR. SHAYE: Yos.
20 HR. DAV ENPORT: Do you wish to reserve 21 that right?
22 HR. SHAYE: Yea, I do.
23 SEYMOU R SH AYE, 24 being first duly sworn, was examined and testified as 25 follows:
_1
3 1 EXAMINATION
() 2 BY MR. DAVENPORT:
3 Q Mr. Shaye, would you state your f ull name f or 4 the record, please.
5 A Seymour Shaye.
6 Q And what is your current address?
7 A 1225 Euclid Avenue, N. E. , Atlanta.
8 Q And your telephone number?
9 A Home is 581-0405.
10 Q Mr. Shaye, have you ever had your deposition 11 taken before?
12 A No.
r3 13 Q Have you talked to your attorney about LJ 14 depositions in general? Do you know what a deposition 15 is?
16 A I believe I do.
17 Q You know that you are responding to questions 18 under oath and that your responses are being transcribed 19 by the court reporter just as if you were testif ying at 20 a hearing bef ore the Atomic Saf ety and Licensing Board?
21 A Yen.
22 0 I basically want to get some information 23 about you, your background, and whatever inf ormation you 24 intend to testif y to on behalf of the Intervenors. And O'
25 I'm not trying to trick or confuse you. If I ask a j
4 1 question you don't understand, please stop me; and I'll
( [) 2 try to rephrase it.
3 Have you done anything to prepare f or this 4 deposition.
5 A No.
6 Q Have you looked at any documents?
7 A No, not recently.
8 0 When you say recently, within the last two 9 weeks?
10 A tiothing in the last two weeks.
11 Q Have you talked to any representatives of the 12 Intervenora or the attorney f or the Intervenors about c' 13 this deposition?
14 A Yesterday I spoke to Tim Johnson.
15 0 What did you talk to Hr. Johnson about?
16 A That I would be meeting with Laurie thin 17 morning and how to meet her.
la Q Would you please describe f or me your 19 education since high school?
20 A I have a Bachelors degree f rom Old Dominion 21 University in Norf olk, Virginia; it was a Dachelorn 22 degree in psychology, BS in psychology. I received my 23 Masters degree f rom West Georgia College in Carrollton, 24 Georgia, in 1973.
O 25 Since then I' ve taken college cournen, but
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4 i
2 1 not towards a degree. Well, I've taken courses, but I
[ 2 have not actually in the Ph.D. program.
3 I've had other kinds of education, as well; r
'4 but in a college as such, that's been primarily it.
5 0 The Masters degree at West Georgia college, 6 was that in psychology?
l 7 A Yes.
8- Q Any particular area :of psychology?
'S A Humanistic psychology.
10 0 Can you describe f or me briefly what is meant
{
l 11 by humanistic psychology?
1 12 A Well, humanistic psychology started off as a ;
13 response to two other primary forms of psychology. The
)
14 first school of psychology was psychoanalysis, and the 15 second was behavioral psychology. And many .
18 psychologists f elt that that was not really the whole 17 study of the human being. They wanted to study the ,
t 18 values and behavior and look at what is health rather I
19 than pathologic. And that's it briefly.
20 0 What year did you obtain your Bachelors i
{ 21 degree?
f-j- 22 A 1971. ,
23 O And the additional college courses that you !
{
i 24 have taken since you obtained your Masters degree, what l 25 schools did you take those courses at?
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6 1 A West Georgia College and Georgia State
'() 2 University.
3 0 Were those additional courses also in the 4 field of psychology?
5 A Primarily. Some were in sociology, and some 6 were in counseling education. We'll say counseling 7 psych.
8 Q Did you have to w rite a dissertation f or your 9 Hasters degree?
10 A I had to w rite a thesis. I didn't have to, 11 but I chose to.
12 0 What subject was your thesis on?
13 A That might be dif ficult to describe. I had a
)
14 very long title, but it was a comparison of East and 15 West cultures as well as as how men and women relate to 16 their bodies differently.
17 Q eased on cultural dif f erences?
18 A Cultural differences, psychological 19 differences.
20 Q Now, you mentioned that you had other 21 educational opportunities in addition to these college 22 courses that you described. What other educational 23 opportunities have you ever been engaged in?
1 24 A I've taken a course in programming, computer !
' programming, particularly; everyone in doing that now.
25
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i l l
l 1 I've taken a woodcraf t course at Atlanta Area Tech; and
() 2 I have a real estate license, I have taken a couple of i
3 real estate courses. And I believe that covers all the 4 educational courses that I've taken. There might be i
-5 some others that I haven't thought about other than, 6 like, CPR and stuf f like that. t 7 Q Have you ever served in the military?
8 A. Yes, I have.
9 0 What branch were you in?
10 A The army.
11 Q When and how long were you in the service?
12 A I volunteered in 1955 and served through 13 1968.
14 0 What did you do when you were in the 15 military?
16 A I was an electronic technician.
17 0 What was your rank at discharge?
18 .A specialist 5, E-5.
19 0 Did you ever hold any other rank?
20 A Well, I went up the ranks f rom E-1 th rough 21 E-S.
22 Q And what type of discharge did you receive?
23 A Honorable.
24 0 nave you ever been charged with any crime, O 25 Mr. Shaye?
8 1 A No.
() 2 0 Are you currently employed, tir. Shaye?
3 A Yes, I am.
4 0 sy whom?
5 A The Department of Human Resources, Georgia 6 Department of Human Resources.
7 0 What position do you hold at Georgia 8 Department of Human Resources?
9 A It's called behavioral specialist. It's a 10 mental health profennional.
11 Q How long have you held that position?
12 A Well, I've had that title about seven or rm 13 eight years; and prior to that, I had the title of L) 14 psychologist.
15 0 When were you first employed by the Georgia l
- 16 Department of Human Resources?
17 A September 17th, I believe, 1973.
18 0 was that bef ore or af ter you completed your 19 Masters program at West Georgia?
20 A That w as af ter. I did start a job, and I may 21 have been employed by the Department of Iluman Recources 22 before that and started that job before getting my 23 Masters. I worked in a center f or the mentally 24 retarded, and I was an instructor. The instructor O 25 position may have been as an employee of the Department l
l
9 1
1 of Human Resources.
O 2 Do you know what approximate time period that t_)
s Q 3 would have been?
4 A That would have been f rom about April or Hay 5 until the beginning of August, '73.
G Q What are your duties in your position as a 7 behavioral specialist?
8 A Well, there are about six or seven of us who 9 were mental health professionals at the center. So we 10 rotate doing evaluations f or intake or emergency 11 services. And on new clients that I choose or that are 12 assigned to me, I will do a mental atatus examination r~s 13 and evaluation to see if they are in need of f urther (J
14 oervices at our program. Otherwloe, we may refer them 15 on to a different cl inici an.
16 0 What f acility do you work at?
17 A Douglac County Hental Health Clinic. I also lo have the ability to do psychological testing; but as of 19 late, there has not been a need to do that.
20 0 Do you report to anyone in this position?
21 A Well, I have a supervinor.
l l 22 0 Uho la your supervisor?
l 23 A Margaret Hard, i l
24 Q And what is har position? !
() 25 A She's coordinator of the conter. i i
10 1 Q Have you worked at the Douglas County Hental
() 2 IIealth Clinic the whole time that you have been a 3 behavioral specialist f or the Department of Human 4 Resources?
5 A The whole time I've had that t i tl e .
6 0 How long has that been?
7 A As I said earlier, I had a title change 8 somewhere around seven, eight years.
9 0 And bef ore that, you were a psychologist?
10 A Right; at Georgia Rugional Hospital in 11 Atlanta.
12 0 Did your duties change at all during the 13 period that you've been employed at Douglas County
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14 Mental Health Clinic?
15 A Yes.
16 0 How have they changed, if you can just 17 describe that briefly?
18 A There was a time period f or about a year and 19 a half, two years, I was i nvolved in emergency services.
20 There have been other times where I have buon doing 21 psychological testing.
22 When I first came to work at Douglas County, 23 it was only myself and one other clinician. I know the 24 duties have changed.
O 25 Q When you say amorgency services, what i n ge---y,, y %y, - e- a -- ---.,-%
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! 1 included within that term?
1
() 2 A Well, that would mean 24-hour services l 1
i 3 whereas what I'm doing right now, I only respond during !
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- 4 regular normal working hours, f rom 8:00 to 4 :30. Well, i 5 different days of the week I work late at night.
l 6 0 so the emergency services just meant that
) 7 basically you were on call 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />?
8 A Right. I would be having a beeper so if a i
9 mental health emergency occurred, I might have to go to ,
i :
1 10 a mental f acility, like an emergency room in the 1
4 11 hospital at Douglas County. I i
- 12 0 out it does not relate to any sort of natural !
4 13 or man-made emergency, such as a fire? >
l l () 14 A No. That just occurred to me when I was i
]
F 15 saying thatt but that's how we use that in mental i
- l 16 health. I mean, it's possible; but we ordinarily are ;
1 1 17 using it in that term.
1
- 18 0 During the time that you were involved in !
- . 19 providing emergency services, were you ever asked to ,
i j 20 respond in any way to some sort of emergency, like a I
21 fire or hurricane or something like that?
l i
1 22 A 2 Not but if a natural disaster occurred in the l
} 23 county, that would be incorporated. Like in a sense ;
i 24 when the tragedy was happening in Atlanta of the missing l i' () 25 and murdered children, the local mental health l
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12 1 prof essionals were called on "to expand upon their
() 2 duties." Likewise, f or Douglas and Cobb County, I 3 would have had to do the same.
4 Q Dut the services that you would have 5 perf ormed would have been those of basically a clinical 6 psychologist?
7 A That's cor rect.
8 0 While you were a psychologist at the Georgia i
9 Regional Hospital in Atlanta, what were your duties?
10 A Well, there I did f requent psychological 11 testing. I was also essentially the chief clinician f or 12 the units and as such, I would supervise the 13 paraprofessional staff in developing treatment plans on
{) I 14 all the clients. l l
15 All the clients would have just a general 16 behavior modification plan; but on some clients that we 17 f ound dif ficulties in discharging, we developed specific 18 pl an s . And then I would supervine and coordinate that 19 with the staf f and train the staf f how to do that.
20 0 When you say you were the chief clinician, 21 are you referring to the Georgia Regional Hospital or a 22 particular unit?
23 A The particular unit, the Cobb Douglas unit. l 24 They have since changed the nano of the particut ar unit. ;
() 25 0 What was the f unction of that particular ;
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13 1 unit?
([) 2 A Well, we provided inpatient services f or all 3 the patients of Cobb County and Douglas County who could 4 not af f ord alternative hospitalisation. And at that 5 time I think we also had adolescents on the unit as 6 well. So it would be short-term and also somewhat 7 long-term treatment as well f or patients who could not 8 have their problems alleviated by our treatment.
9 Q Do you recall who you reported to while you 10 had the title of psychologist at the Georgia Regional 11 Hospital in Atlanta?
12 A Initially, Jenny Williams.
13 0 What was her position?
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14 A She was the director of the unit, and then 15 Penny Weimer.
16 Q Was she also in the position of director of 17 the unit?
18 A Well, Ms. Weimer was not -- shu may have been 19 on the unit when I first was hired, but Ms. Williams 20 hired me; and then Ms. Williams' position or 21 responsibility increased during those three years I was
- 22 there. And then it was Hs. Weimer whe was the one.
i j 23 0 So Mn. Weimer held the position between you 4
j 24 and Ms. Williana?
O' 25 A In the later stagen of my employment there.
14 1 Q Have you been employed by anyone other than n
't,) 2 the Georgia Department of Human Resources since you 3 obtained your Mastern degree at West Georgia?
4 A No, unless you consider like my real estate 5 license, because technically, I'm employed by a broker.
6 0 Which broker?
7 A John Wesley and Associaten, and his 8 name in Dan Swindle, the particular broker.
9 Q Do you actively sell real estate?
10 A No.
11 0 Prior to entering the Masters program at West 12 Georgia College, were you employed by anyone other than 13 the period of time that you spent in the army?
)
14 A Do you mean whether I had any other 15 occupation at all since I graduated f rom high school?
16 0 I'm just trying to find out who you might 17 have been employed by since graduating high school.
18 A Well, I worked one summer as a summer camp 19 counselor.
20 Q Did you have any period of extended 21 employment other than the period you spon*. in the army?
22 A Ho. I worked f or the Herta Corporation maybe l 23 alx months to a year. No; it may have been longer than l 24 that. I'n nomewhat vagun on that. It was at least nix
(> 25 montha.
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15 l 1 0 What did you do f or Hw:ts?
() 2 A I was essentially a file clerk s clerk.
! 3 0 Do you have any relationship with Campaign i j 4 f or a Prosperous Georgia or Educational Campaign f or a I
1 r i i 5 Prosperous Georgia?
i j 6 A As a volunteer. l i
! 7 0 Are you a member of either organisation?
i :
8 A Well, I'm not sure what makes a member of the i
! 9 organisation. I support its goals; so if that makes me 10 a member --
I 4
11 0 When you say you are a volunteer, what sort i
j 12 of things do you do as a volunteer? ;
4, 13 A I'm here today.
1
- 14 0 Other than appearing f or the deposition f 15 today, what sort of involvement have you had with either l 16 of those organisae. ions?
l 17 A I'm not sure if I've gone to any meetings ,
! 18 before. I've had contact with some of the people who >
i 19 are involved with that, but I'm not sure -- well, let me l
i ;
l 20 take that back. I have done volunteer stuf f, like C
} 21 mailing envelopes.
i 22 0 When you indicated that you were a volunteer l
- 23 for them, I was just trying to find out what sort of l 4
i 24 activities you've been engaged in that you considered
() 25 f alling within the definition of being a volunteer f or
I those orgnizations. Is that basically it, basically
() 2 mailing out envelopes? Have you done other things? '
3 A Well, I'm not cure. Could I speak to Laurie 4 one minute off the record?
5 0 Sure.
6 (Thereupon, an of f-the-record discussion 7 was had.)
8 THE WITNESS: Last year I went to Augusta 9 prepared to do -- not a deposition, t 't I went prepared 10 to testif y bef ore the NRC on another contention, on the 11 one on f ear.
12 MRS. POHLER: I think that was a GANE 13 contention that was dismissed.
)
14 DY MR. DAVENPORT:
15 0 Han this at the special prehearing 16 conference?
17 MRS. PONLER: Yes.
18 MR. DAVENPORT: So that would have been 19 1984 rather than 19857 20 HRS. POHLER: llan it been that long? No, 21 it w as last year, wasn't it? It van April of -- no, 22 you' re right. That's wby we can't remember.
23 DY MR. DAVENPORT: f r t
24 0 In that your recollection, Mr. chayo, that it O 25 was April? ,
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17 j
r 1 A I'm somewhat vague on the time f rame of that.
() 2 Q Other than being ready to appear at the 3 special prehearing . conf erence bef ore the Licensing 4 toard, have you had any other involvement with Campaign 5 for a Prosperous Georgia or Educational Campaign for a l 6 Prosperous Georgia? :
i J
7 A No. ,
i l 8 Q Are you an of ficer of either organisation?
9 A No. ,
f )
l 10 Q Are you on the Board of Directors of either i j
i 11 organisation?
I j 12 A No, I'm not.
1 i 13 0 Do you participate in any of their f unctions
)
14 or activities other than the ones that you've described?
1 15 A Mo.
16 Q Do you have any relationship with Georgians -
17 Against Nuclear Energy?
- j. t j 18 A well, I was mentioning last year, whether 19 that is '85 or '84, I had a joint relationship with GANE l ,
l 20 and Campaign for a Prosperous Georgia. l i 21 Q Are you a member of GANE7 j 22 A In fact, I'm not sure if I'm a member of ,
1 23 GAHE.
I 1 24 Q Do you participate in any of GANE's ,
! (]) 25 activities?
1 i
I i
18 1 A Not in a very long time. Other than that
() 2 last activity, going down to Augusta, I don't believe 3 I've gone to one of their meetings since then.
4 0 Do you receive newsletters routinely f rom 5 them?
6 A Periodically.
7 0 Which organization?
8 A rrom both.
9 0 Educational campaign f or a Prosperous Georgia 10 and f rom GANE?
11 A Yes.
12 0 Are you an of ficer or on the Board of
( 3 13 Directors of GANE7 U
14 A No, I'm not.
15 0 Mr. Shaye, have you ever served on any 16 advisory panel or committees that have addressed any 17 issues concerning a nuclear plant or public utilities?
18 A No.
19 0 llave any pape rs, studies, treatisca, or 20 articles that you have authored been published?
21 A No.
22 0 Have you authorod, co-authored, or edited any 23 paper, article, or treatise relating to nuclear power 24 emergency pinnning with the public utility industry?
O 25 A No, I have not.
19 1 0 Have you ever appeared as a witness in any
() 2 proceeding bef ore a court or administrative agency?
3 A Well, as I mentioned earlier, I was prepared 4 to come as a witness; but I was not called.
5 0 And that was at the special prehearing 6 conference?
7 A Yes.
8 0 On any other occasion, have you appeared as a 9 witness in any proceeding?
10 A tio , I have not.
11 0 so you then have not appeared as a witness in 12 any proceeding that was held by the fluclear Regulatory 13 Commission other than the special prehearing conf erenen?
)
14 A That's cor rect.
l 15 0 llave you appeared as a witness bef ore a state l
! 16 public nervice commission or any other body regulating l
l 17 utilition?
18 A tio .
19 0 llave you ever appeared an a witness in any 20 other type of proceeding of any kind relating to nuclear 21 generating planta?
22 A 11 o . ,
i 23 Q llave you ever provided any pornon, any group, 24 or any organization an af fidavit f or their use in a
' () 25 proceeding relating to a nucinar generating plant?
I ,
20 1 A No.
() 2 0 Have you ever submitted w ritten comments to 3 the Nuclear Regulatory Commission, the Department of 4 Energy, the Federal Emergency Management Agency, or any 5 other federal agency, any state public service 6 commission, or any other state agency that related to a 7 nuclear f acility?
8 A Excuse ne one second.
9 (Thereupon, an of f-the-record discussion 10 was had.)
11 THE WITNESS: That would be no.
12 HRS. FOWLER: I think you' re talking 13 about something outside the scope of this proceeding, t
14 aren't you?
15 HR. DAVENPORT: Yes.
16 DY MR. DAVEMPORT:
17 0 nr. shaye, I'm asking you about things 18 outside the scope of this licensing proceeding, any 19 written comments that basically had your name attached to 20 them.
21 A No. '
22 0 Have you ever provided any amnistance to any 23 party to any type of proceeding involving nuclear energy 24 or a nucione f actitty other than thin licenning i
() 25 proceeding?
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21 1 A No.
() 2 Q Are you a member of any prof essional 3 organizations?
4 A Yes, I am.
5 0 Which organizations?
6 A I'm an associate member of the American 7 Psychological Association; I'm a member of the 4
8 Association f or Humanistic Psychology -- you' re talking i
! 9 about professional organisations?
! 10 0 Yen. Any other than those two? j i !
11 A Ho. That may bo the only prof essional 12 organisations.
)
13 0 What nonprof essional organisationn are you a
)
14 member of?
15 A Well, I guesa that would also include clubs 16 and stuf f like that. I'm a member of the Dierra Clubs 17 I'm a member of Common cause; I'm a member of 18 Psychologists f or Social Responsibility. Dometimes I'm j -
19 not cure of all the groups I'm a member of. Of f hand, 20 that's w hat I would say.
I 21 0 The Sierra Club is involved in environmental ;
i 22 issues?
23 A That's correct, j l
24 0 What sort of activities in Common cause (
() 25 involved in? !
- i i
~
22 1 A Well, they change their issues year to year
() 2 depending upon what the membership wants. The leaders 3 of the organization may list a dozen, let's say, and ask 4 a membership which ones they think should be -- what 5 they would recommend f ollowing. And they also have the 6 opportunity to suggest other ones.
7 0 Are they a lobbying organization?
l 8 A Sierra Club?
9 0 No, Common Cause.
10 A Yes, they are.
l 11 0 Have they, to your knowledge, been involved 12 at all in any lasues relating to nuclear power?
l (s 13 A Not to my knowledge.
\-)
l 14 0 What nort of activities does the organisation 15 Psychologists f or Social Responsibility engage in?
, 16 A They' re primarily engaged in educating the 17 public about the dangers of the arms race.
18 0 Do they engage in any activities relating to 19 the use of nuclear power in a nonmilitary senoo?
20 A No.
21 0 nr. Shaye, in this proceeding, have you 22 received any inf ormation or other type of assistance 23 from any person, group, organisation, or other entity 24 other than campaign f or a Prosperous Georgia, O 25 Educational Campaign f or a Prosperoua coorgia, or
23 1 Georgians Against Nuclear Energy?
() 2 A No.
3 0 Have you received any inf ormation, for 4 exampl e, f rom the Nuclear Inf ormation and Resource i 5 Service?
6 A Yes, I have.
7 0 What sort of inf ormation have you received 8 from that organization?
9 A Last year or thereabouts, I was in contact 10 with them when I was requesting inf ormation when I was 11 preparing my case on the contention on f ear.
12 0 Have you received inf ormation f rom the 13 Nuc1 car Inf ormation Resource Service on any other
)
14 issues?
15 A No. I don' t believe I' ve requested 16 inf ormation in regard to this particular innue.
17 0 When you talk about the issue og f ear, could ,
18 you just describe briefly which issue that was just so i
19 I'n clear on that? I 20 A Well, I guesa that issue daten back to when l
21 Three Mile Inland had its accident. 80 that when they l 1
22 were requesting that Plant !! be re-turned on, the !
- I 23 Intervonora in Ponnnylvania requented that it not be {
24 turned on; and they uued the primary contention of fear l
() 25 that it not bo. And so I was going back on the hictory N
1 of that.
() 2 Q This is f ear of a subsequent nucl ea r 3 accident?
4 A Yes.
5 0 nave you received any inf ormation f rom the 6 Environmental Action Foundation? l 7 A Not that I'm aware of.
8 0 lihat about the Union of Concerned Scientisto?
9 A That's another organization I'm a member of.
10 I f orgot about that one. But I have not requested any 11 opecific inf ormation f rom them on thia. I believe I h2d 12 contact with a member of the organization when I was 13 dealing with the contention on f ear, but not s ubs eq u e ntl y..
)
14 0 And that contact related to that particular j 15 contention on f ear?
16 A Yea.
i 17 0 How long have you been a member of the Union l l
18 of Concerned Scientiato?
19 A A couple of yearn.
20 0 What sort of involvement have you had in the 21 activities of that organization?
22 A Just no a member, just an a pasuive member, i 1
23 just getting their mailings. l 24 0 What nort of involvement have you had an a f
! (:) 25 member of Poychologinta f or Social Responsibliity? i l
, 25 7
1 1 A well, I attend their monthly meetings; and
() 2 I've been on their speakers' bureau list so that schools, 3 churchen, other agencies, men's clubs, women's clubs, 4 when they sometimes want a speaker, specifically, if 5 they want a speaker reisted to this, they might contact 6 Physicians f or Social Responsibility or Psychologists 7 f or Social Responsibility. I've been called once for 8 that.
9 0 What topic did you speak on?
10 A The dangers of the arms race. I spoke that 11 time at DeKalb College in a sociology class.
12 0 What about the critical Hasa Energy Project?
em 13 Have you gotten any inf ormation f rom them in this U
14 proceeding?
15 A Not that I can recall.
16 0 lihat about the Governmental Accountability 17 Project?
la A No.
19 0 Have you received any inf ormation f rom L
20 intervonors in licensing proceedings f or other nuclear 21 pl ants?
22 A Not directly.
23 0 Indirectly?.
l 24 A Only copien, you know, through Campaign f or a O#
25 Prosperous Georgia. I've gotton copion of those i
26 l 1 interventions elsewhere.
() 2 0 So you have not been in direct contact with 3 any other intervenors in any other licensing procedures?
4 A No.
5 0 Do you recall which plants you have seen 6 materials relating to?
7 A Well, Three Mile Island, Shoreham on Long 8 Island.
9 0 Limerick?
10 A I'm not sure.
11 0 What about Indian Point?
12 A I believe so, yes, Indian Point.
13 0 Sheatron Harris?
)
14 A Po s s ibl y.
15 0 What about Catawba?
16 A No. Should I be looking at that one?
17 0 It's licensed.
18 A Okay.
19 0 Do you consider yourself an opponent of 20 nuclear power, Hr. Shaye? f 21 A As long as I think it's not safe, I f eel like 22 I am.
23 0 And do you currently f eel that nuclear power 24 is not saf e?
O 25 A Yes. '
27 1 0 So based on the state of the industry as it
() 2 exists today, in it your f eeling that no nuclear 3 generating plant should be granted an operating license 4 on any basis?
5 A Why, I didn't quite say that; but until 6 certain state of the arts can be significantly improved, 7 I would be against i t.
8 0 eased on the technology that exista today, 9 would you oppose the licensing of any nuclear plant?
10 A The technology as it is based today and how 11 it's applied, I an.
12 0 Do you f eel then that Plant Vogtle should not 13 be granted an operating license by the Nuclear
)
14 Regulatory Commission?
15 A Presently, on what I know, I believe so.
16 Q For what reasons do you believe it should not 17 be granted a license?
18 A Well, it would primarily be responnes outside 19 of the emergency evacuation at this point and some to do 20 with the emergency evacuation, as well. I'm not sure 21 that it's appropriate f or ne to go into that at thin time.
22 Well, just on the sense of coot itself, I ,
23 believe it's costlyI and there are ways of much more i
1 24 inexpensively generating electric power.
() 25 0 Do you have any reasons f or opposing Plant
_ - . - - . - _ _ - . . . .- i
28 1 Vogtle being granted a license related to emergency
() 2 planning?
3 A Yen.
4 0 What reason?
5 A Well, on how the plan is set up. It only 6 responds to the needs as if you' re just having, like, a 7 rehearsal in the school. It goes perf ectly well when 8 there is no emergency ordinarily; but then all sorts of 9 psychological components arise when there are, indeed, 10 some f acts to be concerned about. I mean, look at this 11 past weekend on Saturday. There was a mishap in 12 Kentucky, I believe. There were real dangers there; but 13 people were over-responding.
m) 14 0 Is this an incident at a nuclear plant that 15 you're refe ring to?
16 A No. I believe it's a reprocessing plant of 17 some kind. But you mention the word nuclear, and people 18 are going to over-respond.
19 Q Have you participated in any proceedings 20 other than the licensing proceeding opposing the 21 activities of Georgia Power Conpany or Plant Vogtle? ,
22 A No.
23 0 Have you provided any information to the ,
24 Intervenors in this proceeding f or their use in O 25 supplying the bases f or any contention admitted by
_ _ _ _ _ _ d
29 1 the Atomic Saf ety and Licensing Board?
() 2 A Other than that one and the previous one that 3 I worked on.
4 0 I'm asking specifically now whether you 5 provided information that the Intervenors used in 6 supporting contentions that have been admitted in this 7 proceeding?
8 A No.
l 9 Q Do you understand my question? l 10 MRS. F0WLER: He's talking about the 11 emergency response contentions.
12 THE WITNESS: Well, I have been going l em 13 over those; and I have provided inf ormation, yes.
O 14 BY MR. DAVENPORT:
15 Q Did you provide inf ormation that was used by 16 the Intervenors in first proposing those contentions?
17 A I don't believe I was involved when it was 18 first being proposed on, at least when that contention 19 was first being proposed.
20 0 Did you have any involvement with the l
21 Intervenors' proposed revised emergency planning 22 contention in June of 19857 23 A I'm not sure if I was involved at that point.
24 Q Do you recall what subject matters you've 25 provided inf ormation to the Intervenorc about relating
. _ . . ~ , _ _. . _ . . _ . . _ _ _
30 i
1 to emergency planning?
() 2 A Well, here, I don' t remember w hat some of
. 3 those documents are called. I believe this document was 4 f or general dispersal in the area surrounding the plant 5 on what steps for the public to takes and I reviewed 6 that plan and made comments about i t.
l 7 0 Would this be a brochure that was to be 1 l 8 distributed to the public?
e 9 A Yes, t
10 0 Are you f amiliar with the interrogatories .
- 11 that have been served upon the Intervenors by the i
12 Applicants in this proceeding relating to emergency j 13 programs?
. {}
~
4 14 A I' ve looked through them.
I 15 Q Did you provide any inf ormation to the 16 Intervenors f or their use in responding to those 17 interrogatories?
18 A On some of them, I have. Like I was 19 mentioning, on that plan f or emergency response, what i
20 was to be distributed to the community, I looked through
[ 21 that. There are other areas that I looked through, but
! 22 I'm not quite sure which once I specifically responded i
23 to and which I didn' t.
24 Q Do you recall w hat subj ect areas you 4
(
() 25 addressed, generally?
i.
. 31 1 A I primarily looked at those contentions that
() 2 I f elt had a psychological component to them.
3 0 Do you recall which contentions those are?
4 A Well, they were onen where I f elt that people 5 might ba over-responding or under-responding to the 6 threats, real or otherwise.
7 Q Nr. Shaye, you have been identified by the 8 Joint Intervenors in this proceeding as someone who may 9 testif y as a witness on their behalf in hearings held 10 bef ore the Atomic Saf ety and Licensing Board on 11 emergency plan issues. Have you been asked to appear 12 as a witness bef ore the Licensing Board on behalf of the f s, 13 Intervonors?
(._)
14 A Previously, on that previous contention last 15 year.
16 0 On any other contentions other than the f ear 17 contention?
18 A No.
19 0 So at this time, do you have any plans to be 20 a witness on any of the contentions that have been 21 admitted by the Licensing Board?
22 A On the other ones, no.
23 !! RS. F0WLER: He's talking about 24 emergency response contentions.
13
\~I 25 I l
l
_. . - - . - +
32 1 BY MR. DAVENPORT:
() 2 Q Let me start over. I'm referring i
3 specifically to the emergency planning contentions.
4 A Yes. If they wish me to appear, I will.
5 0 What subject matters related to emergency 4
6 planning do you consider yourself to be an expert about?
7 A Hell, I f eel I have more knowledge -- well, I I 8 have some knowledge when it comes to the psychological 9 variables on how people do, indeed, respond when an 10 emergency occurs rather than how we hope for them to 11 behave.
12 Q Have you had any specific training or 13 educational background that relates to how people
{')
14 respond in emergencies?
4 15 A I haven't taken any specific course or 16 specific training as such, just my general psychological 17 training and background.
18 0 Have you ever had occasion to evaluate people 19 who have been involved in an actual emergency to 20 evaluate their psychological responses?
21 A Only af ter the f act, when they then come into 22 mental heath because they have handled the emergency 1 23 badly.
24 0 What sort of emergencies?
O 25 A Well, something resulting f rom an auto J J
_ , _ - . . _ . . _ _ . _ _ . . _ . _ . . _ ~ _ _ _ _ ..._ - _ . _ _ _ _ . _ _ . _ . _ - .
33 l
1 accident, they were in a fire; all different sorts of fu) 2 trauma like that. More often it has a psychological 3 component to it.
4 Q And your involvement was with people who had 5 psychological dif ficulties that developed later as a 6 res ult of having been involved in a traumatic incident?
7 A At least the incident aggravated and brought 8 out underlying problems they already had, but this 9 worsened the situation.
10 Q But yegt work was not related directly to how 11 they actually responded at the time of the accident or 12 the emergency?
13 A No. I only came into contact with them
-)
ss 14 af terward.
15 Q Do you consider yourself an expert on 16 emergency planning?
17 A I consider that I have some expertise on it.
18 O Por all types of emergencies?
19 A I have some expertise on emergencies.
20 0 Again, your expertise relates to how people 21 react to emergencies?
22 A Uh-huh.
23 Q Dut as f ar as actually planning f or 24 cmergencies themselves, do you have any expertise in i G
k 25 that area?
l
___ _ _ _ _ . _ _ _ _ _ _ _ . _ . I I
l
34 1 A I have not done that.
() 2 O When you say that you haven't done that, do 3 you f eel qualified to develop emergency plano, to 4 evaluate emergency plans?
5 A Hell, I will attempt to do it. I'm not 6 sure -- if there was particular training I could obtain, 7 I would do that; but I feel like I'm probably as bent 8 qualified as most other people are to evaluate that.
9 Q Have you ever been involved in actually 10 developing emergency plans of any type?
11 A I developed a fire drill emergency plan f or 12 our center.
13 Q Anything other than that?
Lj) 14 A Not that immediately comes to mind, no.
15 0 Have you ever had any specific training in 16 the development of emergency plans?
17 A No. I remember when I was in the army, I 18 guess I had come emergency training there.
19 0 what type of emergency training?
20 A Well, the kind of things the army does f or 21 emergency training. You know, if there van -- it 22 was more, like, individually, how I would react and how 23 I would get myself prepared rather than apart from 24 myself.
(3 25 Q Did that training relate in any way to
35 1 nuclear materials?
() 2 A Well, there was some nuclear training, 3 but it was ridiculous.
4 Q So it didn't provide you with much 5 inf ormation?
6 A No; it was outrageous.
7 Q Are you f amiliar with the various emergency 8 plans that have been developed f or emergencies arising 9 at Plant Vogtle?
10 A I've looked at them.
11 0 Which specific plans have you looked at?
12 A Well, I'm not sure which ones I've looked at 13 and whether or not I've looked at all of them or not.
)
14 0 Have you looked at the State of Georgia Base 15 Pl an?
16 A That name doesn't ring a bell for me.
17 Q Have you looked at --
18 A I may have looked at it, but I don't recall 19 the name.
20 0 Have you looked at Annex D of the State of 21 Georgia Base Plan which relates specifically to Plant 22 Vogtle?
23 A I believe I have, but I don't recall the 24 name. -
0 25 Q Do you recall whether you havo looked at the
--,-g--- , w ',-i,gw, yr -w w -
w- i.,,,w -, % a.m - - , - - - ^-r,- * " - " " ~ *
- r- y- +17"'T M t --d e'--*
36 1 Durke County Emergency Plan?
rT
(_j 2 A Yes, I have.
3 Q Have you looked at the Plant Vogtle Emergency 4 Pl an?
5 A I believe I have. I wish I was more certain.
6 0 Are you f amiliar with the contentions 7 relating to emergency planning that have been admitted 8 in this proceeding by the Atomic Saf ety and Licensing 9 Board?
10 A I'm not sure which ones have all been 11 accepted and which ones have been denied.
12 Q Do you recall whether you have reviewed the f ~3 13 memorandum and order entered by the Board on August 13, (J
14 1985, that admitted certain issues relating to emergency 15 pl anning?
16 A I believe I've read that. I believe I've 17 read that.
18 0 Are you going to testify about any issues 19 raised by contention EP-1(a) which concerns the 24-hour 20 per day staf fing of the Emergency Notification Network 21 terminal at Burke County Emergency Operations Center?
22 A I don' t believe so, because that doesn't 23 relate to psychological variables. I will only 24 do those that I f eel more competent with that deal with b') 25 psychological issues.
37 l
l l
1 Q So that contention in your opinion has no r~'\
- (_/ 2 psychological --
3 A The w ay I' ve read it, I have not read into it 4 a psychological issue.
5 Q Do you have any basis f or contending that the l 6 Emergency Notification Network terminal at the Burke l
! 7 County EOC will not be manned on a 24-hour per day 8 basis?
9 A I have no information one way or the other.
l 10 Q Do you know what the Emergency Notification ;
1 11 Network is?
12 A I've read through it, but I could not tell 3 13 you exactly what it entails.
(~)
14 0 Are you aware of any instance in which 15 someone had tried unsuccessfully to contact the director 16 of the Burke County Emergency Management Agency or any 17 other emergency response personnel in Durke County?
18 A only what I've road. There was that one l
19 example where that was contended, but I don't know -- I J 20 don' t have other inf ormation on it. I l
21 Q You yourself have no knowledge of --
22 A No, I don't.
23 Q Do you know whether the Burke County sheriff 24 would play any role in Plant Vogtle's initial 25 notification of Burke County of an emergency at the
--. _-_ _ ___ a
38 1 plant?
l) _
2 A Could you say the beginning part of that 3 question?
4 Q Do you know whether the Burke County sheriff S will play any role in Plant Vogtle's initi al 6 notif ication of an emergency at the plant?
7 A He in supposed to; I believe he's nupponeu 8 to. Well, I think he's supposed to be a backup f or the 9 emergency personnel if they can't be reached.
10 0 Do you have any basis f or contending that the 11 cheriff or his personnel would not be able to f ulfill 12 that function?
r m, 13 A I have not studied that.
- ,1 14 0 Are you going to testify about any issues 15 rained by contention EP-2(a) which concerna 16 administrative controls over the une of the Emergency 17 Notification Network?
18 A I know there are some paychological innues 19 related to the emergency notification system; but an it 20 relates to that particular one, I don't know.
21 0 What psychological issues are you referring 22 to?
23 A Well, now, that one -- could you briefly tell l 24 me what that one is stating now?
(~b ;
25 Q Contention EP-2(a) concerna the
39 1 administrative controls over the use of the Emergency
() 2 Notification Network.
3 A I don't believe I'll be saying anything 4 directly about that.
5 0 Now, can you tell me what psychological 6 issues relating to the Emergency Notification Network 7 you were ref erring to?
8 A Well, I was saying many times people will i 9 over-respond, they will under-respond, and they will 10 ignore it, different from how i t's ideally set up.
11 0 Can you tell me how that relates to the 12 Emergency Notification Network?
13 A Well, if they have heard the emergency
-)
14 notification going out numerous times, they may 15 have heard it -- I'm not quite sure how to respond to 16 that in a cense that it depends on how it's eventually 17 done. People are going to respond differently to it, so 18 I'm not quite sure --
19 0 Do you know who will be receiving 20 notification by means of the Emergency Notification 21 Network, who that in designed to contact?
22 A Well, I know there are neveral different 23 means that are being looked at f or the people that live 24 in the plume area or within a certain distance of the O 25 pl an t . I know there are a number of ways that are being
- + _ , . . , - r - . w
40 1 looked at on how to contact them.
(]) 2 Q The Emergency Notification Network will be 3 used only to contact emergency response organizations.
4 Based on that, are you aware of any psychological issues 5 that relate to the use of the Emergency Notification 6 Network?
7 A No.
8 0 So you would not be testif ying on any issues 9 relating to the Emergency Notification Network?
10 A No.
11 0 Are you going to testif y about any issues 12 raised by contention EP-2(c) which concerns the 13 Applicants' use of NOAA tone alert radios as a means of (J
'S 14 alerting residents of the plume exposure pathway emergency 15 planning zone?
16 A I might. I have to get additional 17 information. I have some reason to believe that people 18 may turn them oCf, but I have not really done enough 19 research to be sure about that.
20 0 What subject matters relating to that 21 contention do you intend to testif y about?
22 A Well, in the sense that they may not always 23 be turned on, so they will not have the desired result 24 that they' re hoped f or.
b- 25 0 Are you f amiliar with the NOAA tone alert
41 1- system that the Applicants intend to use in the Plant rm
(_) 2 Vogtle plume exposure pathway emergency planning zone?
3 A I need to look at it more.
4 Q Can you describe that system f or me today?
5 A No.
6 Q Do you know how it's designed to work in the 7 event of an emergency at Plant Vogtle?
8 A No.
9 0 Is it your contention that the NOAA tone 10 alert radios are likely to be shut off permanently by 11 residents of the Plant Vogtle plume exposure pathway 12 emergency planning zone?
es 13 A Some may.
(_)
14 Q On what basis?
15 A That this is -- again, I haven't done enough 16 looking at it; but I just hav,e -- it's my hypothesis 17 that a f air number may eventually turn them of f because 18 they go off at times that annoy people.
l 19 Q Do you have any inf ormation to base that 20 hypothesis on?
21 A Hone that I could really present at this 22 time.
23 0 Is it just basically your idea that people 24 may turn them off?
O 25 A I've heard it, but I haven't checked out the
42 1 source.
I 2 0 Who have you heard it f rom?
3 A This is, like, going about third persons but 4 I have not checked out the material directly.
5 0 Are you aware of any documents that contain 6 inf ormation relating to this?
7 A I believe thero are documents, but I have not 8 read the documents yet.
9 Q For what reasons do you contend residento 10 would shut off those radios?
11 A As they' re primarily irritating them.
12 0 What would cause the radios to be irritating 13 to the residents?
)
14 A Well, they go off at times that are not 15 expected.
16 0 When you say that they go of f at times that 17 they are not expected, are you talking about times when 18 the radios are activated by NOAA?
19 A No; I'm not talking about the times when 20 they' re purposely activated.
21 Q Basically, your contention is that the radion 22 may be activated on their own?
23 A Yes.
24 O Ilow frequently do you contend that they would
() 25 have to go off to cause the residents to turn them off? i i
j l
L I
, _ - --.w - - - - -
43 1 A That would depend on each person's
() 2 toleration.
3 0 What percentage of the population within the 4 Plant Vogtle plume exposure pathway emergency 5 planning :one would you expect to turn the radios of f ?
6 A I don't know. I guess it depends on how 7 often the thing went off ' accidentally."
8 0 Suppose it were to activate accidentally once 9 a year. In your opinion, would that be enough to cause 10 people to turn them of f ?
11 A If it went off accidentally once a year, it 12 probably would make it less likely; but I haven't dono
<- 13 the full research yet.
I _3) s 14 0 Do you have any knowledge as to how many 15 activations, false activations, per year would be 16 required to cause five percent of the residents of the 17 plume exposure to turn the radios off?
18 A That would depend. I mean, some people have 19 very high f rustration tolerance, and other people have 20 very low. Some people just on the first time that the 21 thing goes off, they might turn it off. I don't know 22 how many of such people live in that area.
23 0 People also generally have a concern about 24 nuclear power, do they not?
O 25 A Yes, they do.
44 i
i 1 0 wouldn't that tend to influence people with 4
() 2 the radios to leave the radios on?
- 3 A Some people would be influenced that way and ,
4 some not. I don't know.
, t 5 Q How of ten do you contend NOAA tone alert l 6 radios are likely to go off without any reason?
, 7 A I don't know.
8 0 Do you have any information that indicates
- 9 the f requency with which some radios are likely to
- 10 activate without reason?
1
! 11 A I don't know yet.
12 0 So I take it at this time you don't have any ,
13 information? ,
)
14 A Ho, I don't have the inf ormation.
l 15 Q Are you aware of any experience that other
} 16 plants or other f acilities have had with tone alert F
J 17 radios?
s l 18 A That is what I'm planning to look into.
l 19 Q What f acilities are you aware of that have ,
20 had experience with tone alert radios?
I 21 A Of f hand, I don't know.
l i
22 So you at this time have not looked into that ;
0 t
23 at all?
I 24 A No, I have not.
() 25 0 can you identify for me at this time any ;
i 1
- ~ '- -
, 45 1 f acility of which you are aware that has had any i
(_m) 2 experience with tone alert radios?
3 A No, I do not know.
4 0 Do you contend that the problem lien with 5 NOAA tone alert radios an opposed to other types of tone 6 alert radios?
7 A Now that, I do not know.
8 0 So it la your contention that the une of any 9 tone alert radio in the plume EP2 f or Plant Vogtle is 10 inappropriate?
11 A That, I don't know.
12 0 You don't know what you're contending?
13 A I don't know. If you' re asking if there are
)
14 other tone alert radios that might be botter -- maybe I 15 misunderstood that.
16 0 Let me ask the question again. What I'm 17 asking, now, is whether you contend that the une of any 18 type of tone alert radio as part of an alerting system 19 in inappropriate or do you just object to the use of 20 NOAA tone alert radios?
21 A I still need to look into that. I do not 22 know. '
23 0 Do you know whether or is it your contention 24 that NOAA tone alert radios are more likely to be shut 25 off by residents than other typon of tone alert radion?
46 1 A I don't know.
() 2 0 Are you aware of any other nuclear f acilities 3 that use NOAA tone alert radion as part of their radio 4 system?
5 A I don't know.
6 Q Are you aware of any other nuclear f acilities 7 that use any other type of tone alert radios as part of 8 their alerting system?
9 A I don't know.
10 0 What type of public alerting system do you 11 contend should be used f or Plant Vogtle?
12 A Well, I don't know s and I don't believe 13 that's my responsibility to know which one would be the 14 bent.
15 Q Rather than which one would be best, are you 16 aware of any that you consider satisf actory?
17 A I have not looked into that.
18 0 So your answer la no, I guess?
19 A That's correct.
20 Q Are you f amiliar with the plume exposure 21 pathway emergency planning zone f or Plant Vogtle?
22 A I've looked at that.
23 0 Do you contend that any specific conditions 24 exist in that emergency planning zone that make the use O 25 of NOAA tone alert radios an an alerting system
47 1 inappropriate?
(]) 2 A I don't know.
3 Q so you're not aware of any conditions at this i
4 time that make the use of such radios inappropriate?
5 A Yes.
6 0 Yes?
7 A Yes, I'm not aware of it. '
8 Q Do you contend that the area encompassed by t
9 the plume exposure pathway for Plant Vogtle is likely to 10 experience more severe storm watches and warnings and 11 marine storm watches and warnings than other areas? ,
i 12 A Well, I believe the Applicants themselves say 13 that it's a relatively turbulent area.
)
14 Q Do you have any specific ref erence* you can l 15 give me f or that?
16 A No, but I believe I saw that acknowledged.
17 Q Is there any other reason that you have to
- 18 think that this area would experience more watches or i 19 warnings than other areas?
20 A Of a storm alert nature?
1
- 21 Q Yes.
'22 A No.
23 Q Do you have any inf ormation about the number 24 of times on an annual basic the NOAA station in Augusta,
() 25 Georgia broadcasts watches or warninga?
I L
f
.w.,,,%.- ,--% --,-_,.-.--r,-,,.---.. ev.--+ ,.r-n.-,.,,.--y _,,w_,,-,.-----,..w- em.-..-, n.. , -,e. . . . - , --r .- ~ - , , ~ . . - , . . - . - - - ,
48 1 A I don't know.
p)
(_ 2 Q Do you have any information about the 3 f requency with which NOAA broadcasts watchen and 4 warnings in any other areas?
5 A No.
6 0 Are you yourself f amiliar with the weather 7 pattern f or the area in which Plant Vogtle is located?
8 A No.
9 0 Do you contend that the system f or alerti. g 10 the public within the plume exposure pathway emergency 11 planning zone of a nuclear plant must be designed so 12 that it cannot be deliberately disabled by members of 13 the public f or whose benefit it was installed?
14 A Can you say that again?
15 0 Are you contending that the public alerting 16 system f or Plant Vogtle has to be designed in such a way 37 that it cannot be deliberately disabled by the people 18 for whose benefit it is installed?
19 A I'm not sure if I'm contending that or not.
20 I mean, in a sense that I know that there is that 21 possibility; but whether or not I'm asking that it will l 22 be designed that way, I really haven't thought about 23 that.
24 0 So you have no opinion one wa/ or the other?
O 25 A I know there is that risk if it's designed I l
1
49 1 like it is presently; but whether or not I'm asking that
() 2 it be designed differently, I haven't thought about 3 that.
4 0 By contending that the present system isn't 5 adeq ua te, aren't you really contending that Plant Vogtle 6 has to design an alerting system that cannot be disabled 7 by the public?
8 A That may be a f air assumption, but I have not 9 made that assumption myself.
10 Q Are you aware of any Nuclear Regulatory 11 Commission or Federal Emergency Management Agency rules, 12 actions, regul ations, or other authority that would 13 impose such a requirement?
)
14 A No, I'm not.
15 Q Are you going to testif y about any issues 16 raised by contention EP-2(h) which addresses inf ormation 17 to be provided to transients in the Vogtle plume 18 exposure pathway emergency planning zone?
19 A I'm not sure. I mean, in all likelihood, no.
20 0 I believe you indicated earlier that you had 21 reviewed Burke County's radiological emergency plan f or 22 incidents at Plant Vogtle?
23 A Yes, I have.
24 0 Do you know how Burke County plans to alert O 25 any transients who oight be in the vogtle plume exposure
. _ - -. . . _ . = . - - - -
, . -_ _ _ _ _ _ - . _ ~ ~ _ _ _ _ _ _ - _ _ .
50 1 pathway emergency planning zone?
() 2 A I guess there are those transients who are 3 known as hunters, and I believe they are planning on 4 putting up certain notices. I don't know what the 5 present state of that is because I believe there are some discussions about whether or not to put them in I 6
7 telephone booths. But I don't know whether that was in 8 the Applicants' plan or whether that was what I was 9 thinking in response. I know I was thinking that might 10 be -- it might be helpful in putting them in motels in 11 the community, but I don' t believe that w as w hat they 1
12 were asking. I think that is what I was asking.
i 13 0 Mr. Shaye, you're talking about pre-emergency
)
14 informations is that correct?
15 A Yes.
16 Q Do you know how Burke County plans to 17 actually alert any transients who might be in the Vogtle 18 plume EP5 of an emergency at the plant?
19 A No, I don't.
20 Q Do you contend that transients might 21 misunderstand the implications of a warning given by 22 Burke County?
23 A Yes.
24 0 On what basis?
O 25 A It depends on how the warning was given; if
51 1 it was given on a verbal loud speaker where someone
() 2 could hear the alert immediately, but a tone and other 3 sounds could be misinterpreted f or other types of 4 emergencies.
5 0 suppose the warnings were given by of ficial 6 vehicles driving through areas using sireno, bu11 horns, 7 or a public address system?
8 A Then that would be f airly clear unless the 9 people were deaf, if the transients were deaf.
10 0 Can you identify any areas in the plume 11 exposure pathway emergency planning zone that are likely 12 to be f requented by transients?
13 A I guess along the river for the hunters. But 14 I guess anywhere also in the area where hunting is 15 permitted.
16 Q Do you know what areas in the plume EPZ might 17 have hunters?
18 A No, I don't.
19 Q Do you have any idea what would be the likely 20 number of people to be along the river hunting?
21 A tio , I do not.
22 O Are you f amiliar with the methode described 23 in the Plant Vogtle Emergency Plan by which inf ormation I
24 will be provided to transienta about emergency planning O 25 f or Plant Vogtle and, in par ticul ar, about the meaning !
I
52 l 1 of warning signalz? '
() 2 A I've read that.
i 3 Q Do you recall what those methods are?
4 A I have a general feel for its but if you ask 5 me what specifically, no.
6 0 can you recall any of the methods at this 7 time? '
8 A This is how to notif y the general public who 9 reside in the area?
10 0 I'm asking now about means that the 11 Applicants designed to use to provide information about 12 an emergency plan to transients prior to the occurrence 13 of an emergency?
)
14 A Well, transients wouldn' t have access 15 ordinarily to the booklet. I know there is a booklet.
16 Whether or not they have since added how the booklet 17 will be given to transients --
18 0 Are you aware of any other means by which 19 inf ormation would be given to transients?
20 A I believe the Applicants said that there 21 would be signs in some of the hunting areas.
22 O Any other means that you can recall at this 23 time?
24 A No.
O 25 Q What methods do you contend should be used to
53 1 provide information to transients prior to any
()
2 emergency?
3 A Well, I was thinking that it might be helpf ul 4 if such notice was given or was available in motels in 5 the area.
6 Q Are you aware of or can you identif y any 7 motels in the plume EPZ f or Plant Vogtle?
8 A No.
9 0 Can you think of any other methods chat you 10 contend abould be used?
11 A Perhaps at service stations.
12 0 Any others?
rs 13 A None that have occurred to me right now.
V, 14 0 With regard to the signs and notican that the 15 Applicants intend to place in areas f requented by 16 transients, do you have any opinion as to where those 17 signs should be placed in the plume SPE?
18 A Well, as I was mentioning, it could be, let's 19 say, a sign on each motel door if there are motels in 20 that area. Let's say that service st'ations have signs 21 as well.
22 0 Any other areas?
23 A Well, as well as the signa that they were 24 already planning to place in hunting areas.
(~b 25 0 Can you identif y any specific locations that
1 you contend those signs ought to be placed?
(') 2 A No; I haven't looked into that.
3 0 Mr. Shaye, are you going to testify about any 4 issues raised by contention EP-4 which concerns the 5 identification of existing hospitain f or treatment of 6 contaminated inj ured individuals?
7 A Ho, I'm not going to be testifying on that.
8 0 Do you have any inf ormation about medical 9 facilities in the area?
10 A I have not looked into that.
11 0 So you have no knowledge one way or the other 12 whether the f acilities identified by the Applicants are 13 capabic of treating contaminated inj ured individuals?
-)
14 A Yes. I mean, I don't know whether or not 15 they' re adequate or not.
16 0 You have no inf ormation about whother they 17 are adequate or not?
18 A That's right.
19 0 Are you going to testify about any issuen 20 ra' sed by contention EP-5 which concerns the capacity of 21 the reception centers in Burke County?
22 A It hadn't occurred to me whether there were i ,
23 any psychological ef f ects that would relate to that.
24 0 So at this timo you do not know? )
25 A I won't be testifying.
1 1
55 1 Q Do you know what f acilities will be used by
() 2 Burke County's reception centers?
3 A I believe there was a high school.
4 0 Burke County Comprehensive High School?
5 A That sounds right.
6 0 Do you recall w hat backup f acilities might be 7 used?
8 A I don't recall their names.
9 Q Do you have any knowledge concerning the 10 number of evacuees Burke County might be able to 11 accommodate at reception centers?
12 A No, I don't.
13 0 Are you f amiliar at all with the f acility (xss.,
14 that aurke County will use as its primary reception 15 center at the Burke County comprehensive High School?
16 A No, I'm not.
17 Q So you have no inf ormation about the size of 18 that f acility or the number of people it can 19 accommodate?
20 A That's cor rect.
21 0 Do you have any knowledge about whether the 22 students at that high school would have to be dismissed 23 in order to accommodate all evacueen at that f acility ?
24 A I don' t know.
25 Q Are you f amiliar at all with the two
_ _ _ . .. _ _ _ _a
56 1 f acilities that Burke County has designated as backup r
rx
( ,) 2 reception centers, the old Waynesboro High School and 3 the Waynesboro Elementary School?
4 A No.
5 Q Do you have any knowledge about tne size of 6 thoce f acilities or the number of people they could 7 accommodate?
8 A No, I don't. l l
9 Q Are you going to testify about any issues 10 raised by contention EP-7 which concerns simultaneous l l
11 emergencies at Plant Vogtle and the Savannah River I 12 Pl ant?
I f- 13 A I don' t believe so.
14 0 Do you have any knowledge concerning w hat I
j 15 assistance the Department of Energy's Savannah River 16 operations office has agreed to provide to Plant Vogtle 17 in the event of an emergency at Plant Vogtle?
18 A I don't know what assistance they have 19 of f ered to give.
20 Q Are you aware of any type of assistance that 21 they have offered to provide to Plant Vogtle?
22 A I know -- I believe I've heard that they will 23 be offering assistance, but I don' t know specif ically 24 what that is.
O 25 Q So you don't know of any particular type of
~
i 57 1: assistance they would provide?
() 2 A Yes, I don't know.
3 Q Do you have any knowledge about the l
4 likelihood or possibility of simultaneous emergencies 5 occurring at both Plant Vogtle and the Savannah River 6 Pl ant?
7 A No, I don't.
8 Q Do you contend that the occurrence of
]
9 simultaneous emergencies at the Savannah River Plant and 10 Plant Vogtle would prevent the Savannah River Plant f rom 11 providing any of the types of assistance that it has 12 agreed to f urnish Plant Vogtle?
13 A It's a possibility. Well, it would make 14 sense. If they are having an emergency, it would 15 somewhat restrict them.
16 Q But you are not aware of any particul ar type 17 of assistance that the Savannah River Plant has agreed 18 to provide?
19 A That's cor rect.
20 0 So you, I would assume, are not aware of 21 whether the Savannah River Plant is capable to provide 22 that assistance at the name-time that they respond to an 23 emergency at their own f acility?
24 A That's correct.
O 25 Q Do you contend that if simultaneous
58 1 emergencies were to occur at the Savannah River Plant f I) s, 2 and Plant Vogtle, that other f ederal, state, or local 3 cmergency response resources would be divided between I
4 the two f acilities? l l
5 A Well, that would make sense to me that they I I
6 would.
l 7 Q Can you identif y any specific f ederal, state, I 8 or local emergency response resources that would be 9 divided between the two?
10 A No, I'm not able to.
11 Q Do you contend that if simultaneous 12 emergencies at the Savannah River Plant and Plant Vogtle r3 13 resulted in an evacuation being orderd f or both V
14 facilities, that the simultaneous evacuation at the 15 Savannah River Plant would adversely af f ect the 16 evacuation of persons in the vicinity of Plant Vogtle?
17 A Yes.
18 0 on what basis?
19 A That there would be psychological f actors to that would bring into play in such a situation, and 21 people would invariably over-respond.
22 0 How would, spe cif icall y, an evacuation at the 23 Savannah River Plant affect an evacuation at Plant 24 Vogtle?
{^5 ~#
25 A Decause people in the Plant Vogtle area would
59 1 hear that, and they would wish to leave.
() 2 0 Aren't they already being evacuated if there 3 is an evacuation at Plant Vogtle?
4 A I'm sorry. I misunderstood. I thought you 5 were just having an evacuation just at the Savannah 6 River Plant.
7 0 If there is an evacuation at both f acilities, 8 how would the evacuation at the Savannah River Plant 9 adversely aff ect the evacuation at Plant Vogtle?
10 A It might adversely aff ect it because there 11 might be that much greater load on the roads and other 12 ways to evacuate.
13 Q Are you aware of any bridges that connect
)
14 Georgia and South Carolina in the vicinity of Plant 15 Vogtle?
, 16 A No, I'm not aware.
17 0 Do you know what the closest bridges are to 18 Plant Vogtle?
19 A No, I'm not.
20 0 Assuming that the nearest bridge was 20 miles 21 f rom Plant Vogtle, would your opinion still be the same, 22 that there might be crossover evacuation in terms of 23 people ovacuating the Savannah River Plant incident 24 interf oring with Plant Vogtle?
() 25 A There may. It just dependo on how severe the l . - _ - -
I .~. _ _ _ . _, _
60 1 people perceive the threat to be.
() 2 Q Do you contend that the occurrence of 3 simultaneous emergencies at the Savannah River Plant and 4 Plant Vogtle would result in an overload of medical 5 facilities and emergency vehicles?
6 A Possibly. I mean, it might just depend on 7 the nature and neverity of the event.
8 Q Can you identif y any specific medical 9 f acility that you contend might be overloaded?
10 A No. That would just depend on what the 11 incident in, et cetera.
12 O Do you know what medical f acilitien Plant 13 Vogtle would use in the event of an emergency?
)
14 A I don't recall the namen of the immediate 15 facilities. -
16 0 Do you know what f acilities the Savannah 17 River Plant would use in the event of an emergency at 18 it's f acilities?
19 A No, I don't.
20 Q Do you know whether any of those f acilities 21 are identical, whether Plant Vogtle and the Savannah 22 River Plant would be using the same f acilities?
23 A I don't know.
24 0 Do you know what cources of emergency O 25 vehicles would be used f or Plant vogtle?
l l
1
-- -- - - l
61 1 A No, I don't.
A
(_) 2 Q Do you know whether the Savannah River Plant 3 would use any of the same sources of emergency vehicles?
4 A They might if they are using the same 5 emergency f acility, such as an ambulance.
6 Q Do you know of any specific ambulance 7 organization that would be used by both the Savannah 8 River Plant and Plant Vogtle?
9 A No, I don't.
10 Q Do you contend that there would be inadequate 11 coordination of activities between Georgia and south 12 Carolina agencies if simultaneous accidents were to 13 occur at the Savannah River Plant and Plant Vogtle?
)
14 A That's a good possibility.
15 Q Do you have any basis f or contending that?
16 A I don't have any immediate information, no.
17 Q so you have no inf ormation that you can 18 provide today that would support that contention?
19 A . No, I don't.
20 MR. DAVENPORT: That's all the questions 21 I have. Thank you, Mr. Shaye.
22 (Deposition concluded.)
23 24 O 25
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62
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4
-5 6
7 -----------------------------
SEYMOUR SHAYE 8 I hereby certif y that I have read or have had read to me 9 the f oregoing.
10 11 Sworn to and subscribed bef ore me 12 th i s _____ d a y of ___________ ,19 8 5 .
13 O ___________________________________
Notary Public.
14 My Commission expires _____________
15 16 17 18 19 20 21 22 23 24 O 25 i
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-. . . - _ . . = . . - . ~ - ~ .
63 1
CERTIFICATE G'E O R G I At 3
FULTON COUNTY:
4 I hereby certify that the f oregoing 5
deposition was taken down, as stated in the 6
caption, and the questions and the answers 7
thereto were reduced to typew riting under 8
my direction; that the f oregoing pages 1 9
through 62 represent a true and correct 10
- transcript of the evidence given upon said 11 hearing, and I further certify that I am 12 not of kin or counsel to the parties in the
() 14 case; am not in the regular employ of counsel for any of said parties; nor am I in anywise 15 interested in the result of said case.
16 This, the 7th day of January, 1986.
17 18 19 20 6 '
- d. _ b $Ch $ s h .!
SHARON D. UPCHU RCH,/ CCR-8-93 8 21 My Commission Expi'res the 22nd day of September, 1989 22 23 24
() 25 A
LAWYER'S NOTES
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