ML20205F446
| ML20205F446 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 03/05/1987 |
| From: | Lindell M Neely Research Reactor, ATLANTA, GA |
| To: | |
| References | |
| CON-#187-2904 OL-3, NUDOCS 8703310164 | |
| Download: ML20205F446 (130) | |
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{{#Wiki_filter:RE1.ATED CORRESPONOLM
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'IRAXSCRIFf g,614. . <1<e 0 0 OF PRDCEEDINGS '87 ISR 25 P3:45 UNITED STATES OF AMERICA FFICE 0; tr d.tj Ain OCKET ttn '. SE6'EI-NUCLEAR REGULATORY COMMISSI N BRANCH DEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD - - - - - - - - - - - - - - - - - - -x In the Matter of: Docket No. 50-322-OL-3 LONG ISLAND LIGilTING COMPANY (Emergency Planning) (Shoreham Nuclear Power Station, Unit 1) - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x Q b.) DEPOSITION OF MICIIAEL K. LINDELL Washington, D. C. Thursday, March 5, 1987 ACE-FEDERAL REPORTERS, INC. Stenotyp 14vrters 444 North Capitol Street ]L Washington, D.C. 20001 (202)347-3700 Nationwide Coverage gs 07% 22 ggp 800-336-6646 e e g 9
I CR30072.0 j i 1 l KSU/cjg l l I UNITED STATES OF AMERICA i g- - 2 NUCLEAR REGULATORY COMMISSION BEFORE TIIE ATOMIC SAFETY AND LICENSING BOARD 3 _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x 4 In the Matter of: Docket No. 50-322-OL-3 5la LONG ISLAND LIGilTING COMPANY (Emergency Planning) 6 (Shoreham Nuclear Power Station, Unit 1) 1 - - - - - - - - - - - - - - - - -x 1 8 F l DEPOSITION OF MICIIAEL K. LINDELL j 9 I Washington, D. C. 10 l ( Thursday, March 5, 1987 ~ 11 Deposition of MICIIAEL K. LINDELL, called for examination 12 l I pursuant to notice of deposition, at the law offices of 13 J li Kirkpatrick and Lockhart, 1800 M Street, N.W., Suite 900, at 3 14 3 10:00 a.m. before KATIIIE S. WELLER, a Notary Public within and 15 for the District of Columbia, when were present on behalf of k 16 ) the respective parties: l I JAMES N. C l! R I S T M A N, ESQ. i IIunton & Williams i 1R j P. O. Box 1535 [ 707 East Main Street 19 j Richmond, Virginia 23212 ) On behalf of Long Island Lighting Company. l lI, l 21 j 22 1 -- continued -- i l (, 1 4 i B ACE-FEDERAL REPORTERS, INC. .~, s _,-
l .l 2 APPEARANCES (Continued): g--- i DAVID T. CASE, ESQ. Kirkpatrick & Lockhart 3 1800 M Street, N.W. Suite 900, South Lobby-4 Washington, D. C. 20036 On behalf of.Suffolk County. 5 RICHARD J. ZAHNLEUTER, ESQ. 6 Deputy Special Counsel to the Governor Executive Chamber 7 Capitol Room 229 8; Albany, New York. 12224 On behalf of the State of New York. 9 10 11 12 13 14 J is i 16 17 la l 19 l i 20 l 21 } l 22 l O l 9 i 1 l C ACE-FEDERAL REPORTERS, INC. I ,,m. m., ,_ u m.m., i
~ ~ e l J l 3 l I l s COMTENTS I 2 WITNESS EXAMINATION Mi hael K.
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by fir. Zahnleuter 4 4 .by Mr. Case 88 t '~ n 5 ;d I 1'_@ ; HI E 6 LINDELL DEPOSITION' NUMBER JDENTIFIED 7 l Exhibit 1 23 Exhibit 2 96 t I 9 I i i + 10 l 11 12 13 t 14 lI Il i 15 f 16 l 17 i t I t 18 j l 19 ' j r 20 ' 21 22 l s c l f /kG-FEDERAL REPORTERS, INC. i
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h: ~ ' ;;] 3;;D 7 .q f 4 (O + gas & ,.w ' \\ 3607L 0 (E [KSW D: 4 dWD lhy \\ .[. 1 .P_;R'Q C PJ E R 1 E g p,. ' s: f '7 hE, 2 Whereupon, + t 4 3 MICHAEL K..LINDELL 4 was called as'a.: witness and, having first?been duly sworn, ' -L i,5 was. examined and', testified as follows: s i i16 EXAMINATION n N., i7 ~ BY MR..ZAHNLEUTER L. 8 -Q Good morning, Dr. Lindell, I'm Rich Zahnleuter. I .t ? represent the. state of New York. This is David Case from the 10 t.irm of Kirkpatrick & Lockhart. He represents suffolk (] N1 County. I will be taking your deposition today. %) t 12 could you state for the record your name and m l i 13 business dress?' l s t 1, s, 3: q Yes. My name is Michael K. Lindell. My business 14 i 15 addrest, is School of Psychology, Georgia Institute of D16 . Technology, Atlanta, Georgia 30332. "17 Q The subject of today's deposition will be the 18 adequicy of LILCO's reception centers. I will ask you a few iuestions about that, and if you need clarification, please 19 l i lt 20 'ask me; and likewise, if I need clarification of your answers 3 I i i 21 I will ask that too. 22 To start with, what is your understanding of L .t. L g, x (' ace. FEDERAL REPORTERS, INC. l ') 202 347 3700 Nationwide Coverage 8043346M6 I
m-m g t 30072.0 1 5* KSW ,. 7 y; d 1 LILCO.'s reception center scheme? '2 A My understanding of.their, LILCO's, current 3' reception center arrangemenhs is thatxthere are three w .4 reception, centers located approximately 40 miles-from.the y 5 plant'. A 3 i 6 Q What did you mean when you.NAid "curren't reception-N 7 -centerscheme"? i
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A Well, it'is my understanding that in the past, 8 e 9 during the, for example, during the emergency ekereire that. 'c 10 was-conducted last -- I believe it was in February, that?the ~ -11 reception center was at Nassau County Coliseum, and that' ~12 .that's b~een changed to the-three reception centers that they 13 have plans to use at the current time. s,; j 14 Q Do you know if the plans that you are referring to 15 are-known'as revision 8? s A I don't know the number. 16 17 Q Have you seen a draft revisi'on to those plans. 18 dated February 20? 19 N No, I haven't seeN a copy of the plan that deals 20 ,wlth the reception centers. "My understanding of what the -21 plan is for the reception centers is based on discussions 22* with -,either with counsel or in conversations with LILCO ..p ACE. FEDERAL REPORTERS, INC. D ' 12 202 347 3700 Nationwide Coverage 800-336-6M6 g .pp%
.30072.0 KSW '6' ( l s_j ' i 1 personnel, 2 Q, So you have never'seen any paper that describes- ~3 wh'at the procedures are that LILCO intends to follow at 4 -reception centers?' 5 A No, I haven't seen a piece offpaper that describes 6 any procedures associated with, for example, activation of 7 .the reception centers. I have seen the locations of.the 8 reception centers on a map, but other than that, I dont '9 really.have any information about -- let's see ---the 10 reception centers l'n writing. I have seen one of the
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11 training-films that's-given to LERO personnel that. deals with
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.the activation of the. reception center, and the' operation.of 13 'the reception center. -14 .Q -When did you see that training film? '15 A oh, it was, let's see, it was about two weeks ago. 16 Q And when was the first time that you met with .17 counsel, LILCO pernonnel to discuss the reception centers? 18 A The first time that I had any discussions about 19 the reception center issue was in mid-February. 20 Q Can you tell me who was present when you had those 21 discussions? 22 A It was a telephone conversation. Jim Christman fY .\\ ) ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30072.0 KSW 7 ) I called me up and asked me if I would be willing to become 2 involved in the reception center issue. 3 Q Who are the LILCO personnel that you discussed 4 reception centers with? 5 A I don't recall having specifically discussed 1 6 reception centers with LILCO personnel. When I was in a 7 meeting at the LILCo training facility, I saw the films. I 8 don't think there was any discussion of the reception centers 9 at that time. I do think that reception centers might'have 10 been, but I can't remember for sure because it was not the 11 focus of the discussion, reception centers might have been -- (V) 12 have come up in the course of discussion with other members 13 of the panel of witnesses on the exercise issue, and so it 14 would have come up; possibly peripherally. 15 We had meetings on Saturday, and I met with Jim 16 Christman, and we talked a little bit about reception 17 centers, and then I went in and talked with Jessine Monaghan 18 about the exercise. 19 I have been on the road for six days so my memory 20 of what exactly took place at that point is a little bit 21 hazy. 22 Q Who are the other people on the witness panel that ('M %-) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646
30072.0 KSW 8 (' 1 you referred to? 2 A For the reception centers or for the exercise? 3 Q Well, I believe you said that you might have 4 discussed reception centers peripherally. 5 A Okay, it might have come up in discussion with 6 Chuck Daverio. That would be the only LILCO person that was 7 at that meeting. 8 Q Is it fair to say-your understanding of LILCO's 9 reception center scheme is based on conversations with 10 counsel, conversations with Mr. Daverio and the training film (; 11 that you saw? gj 12 A Yes. 13 Q Is there anything else? 14 A No. 15 Q Have you ever visited any one of the three 16 reception centers? 17 A No, I haven't. 18 Q Do you know where the three are? 19 A I saw them on the map, but other than the fact 20 that they are approximately 40 miles away from the site, I 21 have not visited -- I don't have any further information 22 about the specific locations. V ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
, c. r 30072','O KSW: 9. p [ 1 Q- -Can you remember their locations? 2 A I don't; remember the names. . Le t 's ' 's ee. The-- .L '3 Lnames, I remember the names sounded-familiar lwhen I heard- '4 'them, or.two of:the names soundedffamiliar,.but I' don't 5' 'really recall. 6 Q Would the names Hicksville', Roslyn and/Bellmore 7 refresh your memory? '8 A Hicksville and Bellmore ---Hicksville I remember 9 lbecause'the name was familiar. Bellmore because'the name was. 10 distinctive. I can't even' remember the_other name.now,'but- .D. 11 that does-sound like those were the three locations ~, yes. 'O 12 Q; Did you have more'than one conversation with 113 counsel regarding relocation centers? 14-A Let's-see. Well, there was at least the one:where 15 .he asked me if I would become involved.- Two, three, four. 16 Probably-four. 17 Q-Have you studied any documents-to. prepare yourself 18 for this-deposition? 19 A No. 20 Q None at all? That might include papers that you 21 have written. 22 A I haven't really had time to study any documents. I ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
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..,~ iKSW 10 - 1~ .As I said,'most ofIthe: meetings have:taken-place since-last: =2 Friday, and I'have been --:I met in New York'on-Friday night 3 and Saturday morning'with Jim Christman, and then again 4 . yesterday, and this morning, and'I have been on the road'th'e 5 entire time and haven't really had an. opportunity to lookuat-6 even'any of my._own work to review, which is 7 Q I take it you.have not started to draft testimony? '8 'A We have' started to' draft testimony. 9 Q Is it in written form? 10 A Yes. . 11 Q And I take it, then, also that:you understand that ~ ( 12 ' you'have been designated as a witness;on reception centers? 13 A Yes. - 14 Q Could you tell me, then, what your testimony will 15 consist of?- j ~ 16 A I think the main point in my testimony-would have '17 to do with whether the location of the reception centers - 18 would somehow, being 40. miles away from the plant, would
- 19 somehow be mistakenly inferred by evacuees as being a' cue to 20 the location of the edge of the hazard area and that people
. 21 would mistakenly infer that any area within 40 miles of the 22 plant would actually be at risk, rather than being the ad. ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-33MM6
30072.0 KSW 11 / 1-10-mile EPZ being the potential. risk area. 2 Q From your description, it sounds like you are 3 generally challenging an assumption that you believe evacuees 4 will make. Is that correct? 5 A I'm challenging a suggestion that I don't believe 6 evacuees will make, but that others may be making. 7 Q Okay, could you explain what is that assumption? 8 A Briefly, it is what I said before, and that is 9 that the location of -- that evacuees may interpret the 10 location of the reception centers as being an indicator of (^j 11 the edge of the risk area. That is that people would N_/ 12 mistakenly assume that the reception centers were on the edge 13 of the risk area, and therefore, that anybody within 40 miles 14 would be at risk, and perhaps ought to evacuate, even though 15 they were not advised to evacuate. 16 Q Why did you think that that was the issue that 17 needed to be addressed? 18 A Well, there was some question based on, as I 19 believe, it was Stephen Cole's deposition, as to whether he 20 thought that that would be the case. 21 Q So you have read Dr. Cole's deposition? 22 A Yes, I have read Dr. Cole's deposition. (') s_/ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30072.0- .KSW 12 .j 1 Q That deposition was in connection with the 2 exercise proceeding, right? 3 A You would have to ask counsel. All I know is that 4 I was asked to appear as a witness in connection with 5 reception centers, and I was given a copy of Stephen Cole's 6 deposition, and given what he was saying there, it seemed 7 like there was a plausible connection between what he was 8 saying and that contention. I may have been mistaken. 9 MR. CHRISTMAN: Do you want me to clarify the 10 record? There are two depositions of Dr. Cole. First was on N 11 the exercise litigation, the second on the reception center ~ \\_/ 12 litigation. The deposition that Dr. Lindell is referring to 13 is the second one about the reception centers which was taken 14 February 12, 1987. 15 BY MR. ZAHNLEUTER: 16 Q Did you receive any other documents from counsel 17 to review? 18 A Not in connection with this, no. 19 Q So it was just Dr. Cole's deposition transcript? 20 A Right. 21 Q Is that the only issue that your testimony will 22 address? r~N i t i./ ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 l
30072.0 KSW 13 1 A I will be appearing as a witness in connection 2-with the exercise. 3 Q Okay, I think I should clarify that. This 4 deposition concerns the reception centers, and I know that 5 you are also a witness in the exercise proceeding. 6 A Okay. 7 Q But when I speak of testimony now, I mean of your~ 8 testimony, I'm speaking about your testimony at the reception. 9 center hearing, so will that testimony address anything 10 besides the point that you just raised? 11 A I'm not sure exactly how to answer that question. 12 In order to answer that question -- answering that question 13 is not a simple yes or no answer. In order to explain my 14 reasoning behind my answer, I would have to go into a number 15 of factors, so I'm not sure that I can really answer your 16 question because I don't know what other issues it is that 17 you might be thinking of. 18 Q Okay, do you understand generally what functions 19 generally occur at reception centers? 20 A Yes. There is radiological monitoring and 21 registration and congregate care are the three principal 22 functions that would be associated with the reception center. ,fq \\_/~ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646 i
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1 Q Do you understand that that's whatcoccurs at' 2 LILCO's reception centers? !~ I3 A' That's my-belief. I 4' Q Do you understand the' term " congregate-care. 5 centers"? 6 A-Congregate care centers, when somebody says i. -7 congregate. care centers, what I think of is temporary 18 shelter, _that-is people are registered and provided with i: 9 sleeping arrangements, some entertainment, some food..It is i: 10 what is in most emergencies is referred to aus a. reception ~ [ 11 ~ center. -Obviously,-in floods and'most other kinds of 12 emergencies, there is no need-for radiological monitoring orf 13 decontamination if. there has been some contamination. So-14 congregate care refers only to a provision-of location for 15 sleeping, for some entertainment and for feeding. 16 Q Do you understand whether or not the LILCO plan 17 makes a distinction between reception centers:and congregate 18 care centers? 4 19 A As I recall, but it wasn't salient -- at the time 20 that I looked at the training film, I was going through all 4 l 21 of the training films just to get a general sense of what 22 they were all about; so I wasn't looking specifically at the ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646 ..-n._-.~_._._-.--,..,
30072.0' KSW 15 1 reception center. I don't remember for sure whether there is 2 a-separate location for congregate care, that is, providing a 3 place to sleep, meals, the kinds of functions that are-4 typically performed by the American Red Cross. I don't 5 remember if that's-in a separate location or whether it is in 6 these -- whether it is associated with these three. reception 7 centers. The main question that I had concerned myself with 8 was the question of will people mistake the location of the 9 reception centers, the places where they are supposed to go 10 and register, to be monitored and to be decontaminated if /^'; 11 necessary, whether people will mistakenly interpret those as LJ 12 being the location of the risk area. 13 Q Okay, do you think that you will be testifying 14 about the number of people who might show up at a reception 15 center? 16 A I think that's imminently involved with the 17 question of whether people would mistakenly assume that the 18 reception centers mark the edge of the risk area. 19 Q Will you be testifying about any analyses or 20 surveys that you might have conducted regarding that issue? 2.1 A I have conducted a number of studies that I think 22 are relevant to that issue, so I would assume that if anybody (~h' v' ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
.W + { 30072.0 KSW' 16 Os_z ^ 'l wants to probe the reasons for my opinions, that those-2 studies wil'lfcome'up. .3 Q ~ We'll get to'that. Perhaps I should clarifyjmy. 4 question, though'. Do-you intend to Iestify about any 5 analyses or surveys that you might, conduct on Long-Island 6 .regarding LILCO and.Shoreham? a 7 A No, I have not conducted any surveys on Long 8 Island, and have no intention of doing so. 9 Q' RBy the way, do you' intend to visit'the reception 10 . centers? 'll A-I hadn't really discussed it with anybody, didn't } J 12 have any - -and don't currently see any:need to-to answer:the 13 . questions that I think I need to address. 14 Q Do youl envision-any'need to look at the.LILCO plan 15 and' procedures as they-apply to reception centers? 16 A It is possible that:I might, but what I expect to l (~ 17 be addressing has more to do with the assumptions on which a 1 18 plan and procedures would be based rather than upon the 19 actual implementation of those procedures. 20 Q Do you know if you will be appearing as a witness. 21 on a panel with other witnesses? 2:2 A Yes, I will be appearing with other witnesses. ACE FEDERAL REPORTERS, INC. l 202-347-3700 Nationwide Coverage 800 336-6M6
30072.'0 KSW 17 1 Q Do you know who the other witnesses on your panel 2 will be? 3 A Let's see. I believe Dennis Mileti will be one. 4 I would recognize some of the other names -- Roger 5 Linnemann. Is it Roger? Yes. 6 Q If you remember some of the others as we go along 7 could you bring them up? 8 A Certainly. 9 Q Will you be testifying about -- well, let me ask 10 this first: Do you know what " shadow phenomenon" refers to? (i .11 A Yes. \\_/ 12 Q Could you explain what your understanding is of 13 that? 14 A Certainly. A shadow phenomenon refers to 15 protective actions taken by those for whom the protective 16 actions have not been recommended; so, for example, that i i 17 would be if there were an evacuation recommended for I. 18 residents within two miles, that one would say a shadow, an j i 19 evacuation shadow had occurred if residents from outside that 20 two-mile radius had evacuated. 1 21 Q Do you think that you will be testifying about l l 22 shadow phenomenon on Long Island? r's N_,]' ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6646
30072.0. KSW 18 ~,, 1 A I think the concept comes up in connection with 2 this issue of whether people believe that the area between 10 3 and 40 miles is a part of the risk area. 4 Q Is " risk area" a term of art as you use it? 5 A You will have to explain what a term of art is. 6 Q You have used it several times and I actually 7 never heard of that term. How would you define the risk area 8 on Long Island? 9 A The risk area is the geographic area in which a 10 threat to public health and safety does exist or would exist (~'i 11 under certain kinds of environmental conditions. So for L ;' 12 example, in the case of a hurricane, the risk area would be 13 the area that would be inundated by the storm surge. In a 14 flood plain, the risk area is typically defined 15 probabilistically as being, say, a 50-year flood plain, that 16 is subject to a flood with a 50-year recurrence interval or a 17 100-year flood plain. 18 The risk area defined by NUREG 0654 and earlier 19 NUREG 0396 is the 10-mile radius EPZ for plume exposure, and 20 it is 50 miles for ingestion -- for the ingestion pathway, so 21 the risk area as defined by NUREG 0654 in this case is the 22 10-mile EPZ. ( ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8M336-6646
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' 19.- fi, O l' -Q- 'Or it' could,be the 50--mile EPZ. for ingestion; pathway;Jis that correct? 2 3 A Yes,.for that pathway. In~an actual'-emergency, ~ ~ 4 the risk area could be=much smaller than-that. The risk area 5 may-be confined'to the plant site or-even to specif'ic' areas 6 within the plant. 7 Q So_it might depend on the magnitude of the; -8 accident at-the nuclear power. plant? 9 A Yes. .10 Q-Could the risk area extend beyond 10 miles? 11 A~ I believe that NUREG 0654 says that'it could. .V(N ~ 12 'Q Is there a bound to how far it could extend? 13 A I'm a psychologist,-not a health physicist, so I 14 have no idea'what the risk -- what'could be the-extent of the 15 ' risk area. I know that it depends up'n what kinds of health and safety consequences you are referring to. If you are 16 17 referring to a consequence of, say, acute health effects like 18 short-term deaths, say within a few months due to acute 19 radiation exposure, it could be a very small area. If you 120 .are talking about long-term cancers or other more delayed 21 effects, it could be a larger area. 22 Q Could the extent of the risk area be dependent on ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 . -, - - - -.. -.. -.. - -, _. -, - ~. - - _,,...
{. 4 s - 3'0072.0 KSW: 20 p 1, howJpeople perceive whether theyfare at risk or not?. 2 -A Well, the radiological consequences are' physical -3 effects, and so therefore, the size of risk area for 4 radiological consequences is independent of' people's 5 perceptions. 6 Q I'm sorry, I missed a word in your answer. It was 7 something like independent? 8 A Independent, yes, so that whether people -- 9 independent in the sense that the ef fects -- that. a physical: 10 effect would' occur or not' occur independent of whether .IY 11 somebody believed that the effect could occur; that is, you .V 12 don't have to believe that you are going to experience an 13 acute radiation syndrome in order to have it' occur to you; if 14 .you are exposed you will suffer the symptoms. And even if 15 you are standing, say you were standing at the -- you went 16 into the containment building and somehow erroneously -17 believed that you wouldn't be affected by going into the i 18 containment building, you would in fact experience. acute l l I 19 radiation syndrome. 20 Q Again you used that term " acute radiation l 21 syndrome" as, perhaps, a term of art. Is it? .] 22 A I think so. It is one that -- it is not an area ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30072.0 KSW 21 1 that I deal with a lot. As I recall, that is a term that is 2 used by physicians. You could check with Roger Linnemann 3 about it, but my understanding is that it refers to 4 short-term' effects within a period of days, weeks, months, 5 that is characterized by nausea, vomiting, loss of hair and 6 the other relatively short-term effects of a very intense 7 radiation exposure. 8 Q Do you think that you will be testifying about the 9 behavior of people as they are awaiting access to a reception 10 center, or as they are inside a reception center? ^ 11 A It is possible, yes. (;') ( 12 Q Do you intend to do any further research or study 13 to finalize the draft of your testimony? 14 A Well, you would have to be a little more specific 15 as to what you mean by further research or study. To say 16 research encompasses a wide range of activities. 17 Q Do you intend to resort to the literature to 18 prepare your final draft of your testimony? 19 A I think that -- the process that I would follow in 20 drafting testimony would probably be to, if some issues come 21 up, to say, okay, here's what I think about that issue. 22 Here's my opinion or here's my professional judgment, given (')) 'w ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
s 30072.0-22~ KSH-' 1 all of the inconvenience, I think you are~ entitled to a. 2 professional: judgment, not to an opinion, and-then what-I 3 'would do is then come up with documentation. I would review 4 _ documentation,=that is, other' studies, either my_own' studies 5 or studies conducted'by others, to satisfy myself that-my-6 recollection of what the literature.'says-is.in fact l correct. 7 So I don't have a list of studies at this point. 1 8 that I would refer to, but I find it -- it11s very improbable-9 -that I would not at some point prior to filing testimon'y 10 refer to'some other studies. That's called good scholarship. 'll Q Could you describe what your draft. testimony } -12 consists of thus far? -13 MR. CHRISTMAN:- Objection. The discussion of-what'
- 14 is in the contents o't that document, which is obviously trial 15 preparation materials and work product, is improper.
If you 16 want to ask him about what his opinions are', what'he might be 17 testifying about, that's okay, but the witness should-not 4 18 answer any questions about the contents of the draft 19 ' testimony that he has already prepared. 20 BY MR. ZAHNLEUTER: 21 Q I'm going to show you a document. Have you seen 8 ' ~ 22 this before? O-Ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646 . - - _,. ~..,, _ _ _-__ _.,,. -.-
r-30072.0 KSW 23 v 1 A Yes. 2 MR. ZAHNLEUTER: I would like to have this 3 document marked as Lindell Exhibit 1. 4 (Lindell Exhibit 1 identified.) 5 BY MR. ZAHNLEUTER: 6 Q Did you prepare this document, Dr. Lindell? 7 A I will tell you what I did do. I provided counsel 8 with a copy of my resume. From that, they prepared a draft 9 statement of professional qualifications. They sent a copy 10 of that to me, and I approved it and looked to see if I 11 thought it was accurate and called them up and suggested a ('i w 12 couple of changes, a couple of things that I felt showed a 13 small misinterpretation on the part of, I think, it was a 14 paralegal that prepared it, and suggested changes, and I 15 looked in a couple of places and those changes have been 16 made. 17 Q Could you describe for me, just in terms of job 18 positions, what your present employment is? 19 A I am a visiting associate professor of psychology 20 at the Georgia Institute of Technology. I teach courses in 21 industrial / organizational psychology and social psychology. 22 Q Are you simultaneously now, also, a research ,q \\_/ ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
1, 30072~.0 KSW .24 1 scientist at Battelle? f 2 A Yes. I am not --~I don't have a full time 3 position there, obviously, because my primary affiliation for 4 this year is with Georgia Tech. 5 Q And Battelle is in Seattle, isn't it? 6 A That particular ress. arch center is in Seattle. 7 There are others. 8 Q The one you are associated with, though, is.in 9 seattle? 10 A Yes. ') 11 Q And are you simultaneously now also employed at s 12 the University of Washington? 13 A I maintain my adjunct appointment there. 14 Q Could you explain what it means to maintain an 15 adjunct appointment? 16 A Yes. It is a university's way of saying, we will 17 include you in our listings of faculty. We will allow you to 18 teach classes for free, and in exchange for that we will give 19 you the title of adjunct professor, and so it is just an -- 20 it is loosely the equivalent of an honorary degree, worth 21 about as much. 22 Q Do you teach classes there now? ,m i i \\_) ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
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25 . j, s ; , ' ~ - -1 A. .I have in the:past taught a class.on the_ analysis 2 of survey data every other spring.. ordinarily, I would be 13 teaching this spring except I will be in' Atlanta,1so that 4 will preclude' teaching.a course. 5 .Q When'did yo'u start your position inLAtlanta?' ~ 6 A- 'During the fall. Fall quarter. It was on 7 September 15, I think, is when I started. 8 Q. 'Could you explain what it means to be.a visiting-9 ' associate professor, which is what you are.at. Atlanta, right?- 10 A. Right. To be a visiting associate professor:-- ~ -(~} 11 well, the visiting means that-I have-a one-year contract. $J 12 I'm not in a tenure-track position. Associate is;just the 13 second rung on the ladder.- Assistant, associate and then 14 full professor. 15 Q. Are you currently teaching classes at Georgia? 16 A At Georgia Tech?. 17 Q -Yes. 18 A Yes, I'm teaching classes this quarter at Georgia 19 Tech. 20 Q And I think you said before those are in 21 industrial / organizational -- e 22 A Yes, this quarter it is two sections of ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6686
30072.0 KSW 26 ) v 1 industrial / organizational psychology. 2 Q Could you explain what industrial / organizational 3 psychology is? 4 A Sure. Industrial / organizational psychology deals 5 with the application of psychology to organizations. 6 Specifically, there are two distinct aspects, partly for 7 historical reasons; one labeled industrial psychology, the 8 other one labeled organizational psychology. 19 Industrial psychology deals with primarily with 10 selection, placement, classification, performance appraisal, -11 and training. Organizational psychology deals with various (~'); 12 aspects of organizational influences on behavior such as the 13 job satisfaction, motivation, role definition, stress, the 14 perceived characteristics of jobs, labor relations, and some 15 other topics. Conflict in organizations. 16 Q Does your expertise in this field, 17 industrial / organizational psychology, have any relationship 18 or application to the people who will evacuate from the 19 Shoreham EPZ to reception centers? 20 A No. I don't think industrial / organizational 21 psychology per se really is connected with evacuees. It has 22 to do with or would be applicable to the functioning of the /~T U ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
f 30072.0 .KSW 27 / ' v 1 emergency response organization. 2 Q Is it fair to say that your testimony on reception 3 centers will be oriented towards the evacuees rather than the 4 psychological processes that LERO members go through? 5 A Yes. 6 Q Do you have in mind what kind of psychological 7 factors will be considered by evacuees as they evacuate? 8 A Yes. That comes from my background in disaster 9 research, which is more closely related to the courses that I 10 teach in social psychology. And the factors that evacuees (~'), 11 are liable to consider have to do with their perceptions of V 12 the characteristics of the hazard and their perceptions of 13 the alternative protective actions that they can take, 14 especially the characteristics of those alternative 15 protective actions; and their perceptions of the sources of 16 information that they receive regarding the nature of the 17 hazard, and of the alternative protective actions that they 18 can take. 19 Q At this time, do you know what the perceptions of 20 the people on Long Island are of the characteristics of a 21 radiation hazard? 22 A Not specifically, no. I don't and I don't think ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646
z 30072.0 F KSW 28- -l -v 1 anybody else does know specifically what are the perceptions 2 of the hazard and of the alternative protective actions tur-3 residents of Long Island. 4 Q Will you need that information? 5 A I would love to have that information. I think 6 that anybody that -- it would be nice to have such 7 information. Unfortunately, it doesn't exist, so everybody 8 is trying to piece together, in the absence of that 9 information, their ideas as to how people on Long Island 10 would respond in a radiological emergency based on the I"') 11 existing information on how people respond in emergencies of L.) 12 a variety of types. I think that the best answer comes from 13 research that's been done on prior behavior and disasters. 14 Q Is it fair to say, then, that in the absence of 15 that information about how the people on Long Island would 16 respond to a radiological emergency, you would have to make 17 several assumptions? 18 A Yes. You would have to make some assumptions, the 19 same as you have to make assumptions any time you develop 20 emergency plans in which public response becomes an issue, 21 which is always. 22 Q I want to be clear. I'm not really referring to nb ACE-FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6M6
7_ __ -30072.0 KSW 29 /. i Q,i ~1 assumptions that LILCO might make in its planning process. 2 What I'm really interested in is assumptions that you will 3 make about how the people on Long Island perceive a 4 radiological hazard. Will you be making those kinds of 5 assumptions? 6 A I think that it would be fair to say that I would 7 be making some assumptions. Any application of data to a 8 situation requires making some assumptions. 9 Q Is assumption a correct term? Would a better term 10 be an educated guess or a prediction? (^] 11 A Not necessarily. It depends upon what the context v 12 is. If you are making -- attempting to make some prediction, 13 there is inherent an assumption that what has held -- that 14 the empirical regulators, the scientific laws or whatever 15 that have held true in the past will hold true in the 16 future. If I'm going to say that I expect the sun to come up 17 tomorrow morning, I am assuming that nothing is going to 18 intervene in the meantime that would prevent the sun from 19 coming up as it has every other morning for the entire 20 duration of my lifetime that I know about. 21 Q Okay, in the absence of information, then, about 22 how people actually will respond to an emergency at shoreham OO ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
30072.0 KSW 30' \\j' 1 -on.Long. Island, what. assumptions are you going to make based. 2 on, I think you said.your--knowledge ofcour. disasters?- 3 A I think the assumption that I would make is that 4 'the model that.has been developed by. disaster researchers is-5 sufficiently general in its scope that it would encompass any-6 behavior that would be exhibite'd in a radiol'ogical emergency-7 at that' site. I think that's the primary assumption. 8 Q Are you assuming that people will respond to 9 radiological emergencies in.the same way that they-respond-to' 10 natural disasters? t( 11 A Well, "in the same way"-is a very loose term. 'One \\m/1 12 can in the sense -- it is' sort-of like a strict. 13 constructionist versus a loose constructionist in the 4 interpretation of the constitution. I think the'model 15 generally applies. I think a very narrowly defined 16 application of the model probably doesn't apply. 17 To illustrate what I mean, I think that it is 18 clear that people do, people generally do regard radiation 19 hazard as being more threatening than other types of -- most 20 natural hazards that I can think of, and a number of 21 technological hazards, and that's really been the focus of my 22 work is to -- or some of my recent work on risk perception is O ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
m r a u .m M t
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'KSW 31 s .( a N _J ( 1 to try to expl' ore those perceptions, 'ih what respectz -- to f r 2 find out in what respects do people perdive rgdiktion bacard 3 as being dif ferent and to' what extent do they perceive it as 4 being different along those dimensions that thev perceive l'c i-5 as being different on or along those dimensions that they 6 consider. 7 Q 'If you think that' people think that radiation 8 hazard's are more dangerous than natural hazards _. what do you t 9 think the consequence of that, perception by the people will-Q, I 10 be at, say, an evacuation around Shoreham? r ~ s if think,' orfe', based on the data that.I have l (3 11 A I L.) i 12 collected, one of thevfacTorn that people use is the. 13 availability or the existence of physical cues, so the facts 14 that there are not ob' servable cues to the onset of radiation 15 exposure as there are, for example, in the. case 4f a flood, 16 makes people more' inclined to or makee them less-inclined to 17 stick around and wait for the onset of_the hazahd, and more i 18 likely to take prompt action. An analogy -- 19 Q Excuse me; before you go ipto the analogy -- I 20 don't mean'tc, interrupt and I want you to continue, but I thinkyoumaybegojngfartherthanI'mpreparedt'or-- 21 22 A You have to remember that I'm a professor and I (O) .I t v ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-h i
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1 tend to have an inclination, like most professors, to keep on 2 talking, because students don't usually stop me and say "I 3 don't understand that." 4 Q It would be better if students did stop you? 5 A It would be, but I can't get them to do it. 6 G I want to ask about your use of the term " physical 7 cues 'I don't have the same understanding you do or maybe I 8 need to understand what you mean by physical cues? '9 A By physical cues I mean sights, sounds or scents ~10 that are available to the eyes, ears or nose that give some 11 indication as to the onset of the hazard. 12 Q So you are saying, like in a hurricane, there's 13 wind and rain. In a chemical spill there might be a smell? 14 A Ihere might be, yes. 15 Q But are you saying in a radiation hazard situation 16 there would not be a physical cue? 17 A No. I'm not aware of any physical cues that would 18 be present in a radiological emergency. ' 19-Q What if people didn't have the ability to sense 20 the physical aspects of radiation, but they had knowledge of 21 it from other sources? 2d A If they have knowledge of it from other sources i /\\CE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6
7 4 8 30072.0 kI ( KSW '33 \\ 1 then that's sufficient. For example, the people that go out 2 and do radiation monitoring cannot taste, see or hear the-qf v 3 radiation, but they have instruments that are capable of 96; s 'l e- 'd [hl 4 detecting the radiation fields. And so if they detect that 't - s 5 and they can pass that information on to other people, then 1 s:/ I .c" 6 that serves as-a cue. It is not a physical cue'but it is a 4 of the actual 7 social cue for the presence of the hazard, Y' 8 presence of the hazard or for somebody that lives, say, 10 9 miles away from the plant. And there are radiation 10 instruments on the site that indicate that there's an d - /~') 11 elevated level of radiation, that that information may be nj w 12 analyzed by people on site, transmitted to LERO, and then 13 that information disseminated once a decision is made'as to 14 whether that constitutes grounds for taking a protective s 15 action. 16 That information can be disseminated to people in N 17 the EPZ. It is very similar 10 w at goes on in hurricanes, s ,ted by radar, by airplanes, 18 that there's a hazard that os 19 by satellites. They detect the existence of a hurricane. 20 That in'nmation goes to the National Hurricane Center. It 21 is analyzed to determine whether there's a hazard along the 22 Gulf coast or the Atlantic coast, in the Keys or whatever, ,~~ \\_/ - 4 ACE FEDERAL REPORTERS, INC. +/ 202-347-3700 Nationwide Coverage 800-3?6-6646 x
30072.0 KSW 34 9 1 and that information is disseminated to local emergency 2 management' organizations. So there's nothing really 3 radically different about a radiation hazard from that 4 perspective. 5 Q If a resident in the EPZ saw a LERO member taking 6 a radiation measurement, like, in their backyard, and that 7 resident became aware of what the reading was, would that be 8 a physical cue much the same as a resident would look out the 9 window and see a rain during a hurricane? 10 A No, it would be more like looking out the window (~') 11 and seeing a rain gauge. That's the detection instrument. - x. / 12 It is not -- I don't think the analogy is apt. 13 Q Could you continue with your own analogy that you 14 were going to give me before I asked about physical cues? 15 A I'm trying to remember what it was now. I lost my 16 train of thought. I don't remember. Maybe if you could ask 17 some more questions, it will come back. 18 Q I'm not sure exactly what it was either. We'll see if it comes back. 19 l 20 Could you turn to page 2 of your statenient of 21 professional qualifications? 22 A Okay. ,/, V ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646
30072.0 'KSW 35 _x ] ^ 1 Q You list several projects on this page. I would. 2 like to ask you about the fourth one, for example. 3 A-Okay. 4 -Q The project is described as " technical assistance 5 in implementing emergency preparedness requirements." That 6 assistance given to the Nuclear Regulatory Commission. Does 7 this have any relationship or application'to reception 8 centers or analogous situations like evacuees of a community 9 traveling to a particular point? 10 A On that one, let's see -- we focused on analyzing [ 11 or evaluating the compliance of emergency plans with the 12 requirements of NUREG 0654, or actually I think the NRC 13 refers to that as guidance, not requirements. 14 Q Do you recall when that project occurred? 15 A Around -- well, it started six months after TMI, 16 so it was september of '79, and ran through -- that one was 17 funded on an annual basis, but it was renewed for a number of 18 years, probably through '83. 19 Q Okay -- 20 A There were some other tasks that were performed in 21 conjunction with that. We did an analysis -- really 22 developed recommendations for emergency public information .G V ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
c 30072.0 KSW 36 ~ 1-brochures in connection with-that. We did an analysis of 2 evacuation time components following the Mount St. Helens 3 eruption of-May 18, 1980. We also did -- I can't remember, I 4 think there was one other special study-that1ae performed. 5 Q. Okay. Am I correct-in understanding, then, that 6 this. project doesn't have any relationship or application to 7 reception centers in the LILCO plan? 8 A Well, I have said what was done. I guess it would 9 be up to you as to whether you consider that to be relevant. 10 What I got out of it or the connection that I would draw /~h 11 between that project and the reception center issue is just a U 12 better understanding of the factors that go on in an 13 emergency. So I think there's some relevance to it or 14 between that project and this issue, but I don't know if 15 there's anything in the work that we produced, the paperwork 16 that we produced for the NRC that I would go back to and say, 17 well, this is relevant to this issue, I'm going to Xerox a 18 copy of this and I'm going to use it as part of my testimony. 19 Q Okay, that's what I'm trying to find out. 20 A I thought that might be the intent, so -- 21 Q The next project refers to an " evaluation of 22 licensee emergency response facility designs." When did that AV ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage 8%336-6M6
b 30072.0 KSW 37 s. 1 project occur? 2 A .That one took place around 1983 or 1984. I' don't 3 remember for sure, but it is right around in that vicinity. 4 It was when the Nuclear Regulatory Commission issued a letter 5 to the licensees requiring their conceptual designs for their 6 emergency response facilities: the technical support center, 7 the operations support center and the emergency operations 8 facility; and we evaluated their conceptual designs. 9 Q Did the emergency response facilities described in 10 the project include reception centers? /'] 11 A No. Those were off-site facilities. 12 Q okay, this project only concerned on-site 13 facilities? 1 l 14 A Or near-site, since the emergency operations l 15 facility is typically off-site, and in many cases or in a 16 number of cases it is more than 10 miles away, so in that } } 17 sense it does include off-site facilities; but the reception 18 centers are not classified by the NRC as being emergency 19 response facilities. 20 Q What about the next listing, concerning evaluation 21 of emergency exercises at nuclear power plants. Did you 22 evaluate reception centers as part of this project? \\._ / Ace-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmcrage 800 336-6M6
g 30072.0 KSW 38 1 A No. 2 Q Did anyone'in this project evaluate reception 3 centers? 4 A. No. Until FEMA was formed, we did some 5 evaluations at state and county emergency operations. centers, 6 but did not do any reception centers. I think -- I'm trying 7 to think back to those exercises. I think any evaluations of 8 reception centers were done by federal people, so somebody 9 from the NRC or from DCPA or maybe from HEW. 10 Q When did this project occur? f^] 11 A That occurred roughly the same time as technical 'J 12 assistance in implementing emergency preparedness 13 requirements. What happened was that very early on, the 14 evaluation of emergency exercises was included as a subtask 15 within the technical assistance project. Then about -- I 16 can't remember, it was '81 or '82, there was a big -- during 17 the first couple of years of annual exercises at nuclear 18 plants, NRC was very short-staffed, and so we went to a 19 number of the emergency exercises. So I think it was around 20 '81 or '82, but some of the exercises that I attended were 21 part of the technical assistance contract. This evaluation 22 of emergency exercises became a separate contract because it f~h J ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8043364M6 }
30072.0 KSW 39 1 was so large, rather than a task within the other one. 2 Q With respect to the next-item, " analysis of 3 - emergency staffing," did that include staffing at reception 4 centers? 5 A No. It was on-site. It was table B-1 6 requirements in NUREG 0654. 7 Q The next item lists a project for the atomic-8 industrial forum. Did the planning concepts and decision 9 criteria for. sheltering and evacuation have anything to do 10 with reception centers? (] 11 A Yes. ,,7 12 Q Could you explain what the relationship is between 13 this project and reception centers or a similar situation 14 like an evacuation to a particular point? 15 A one of the questions that was addressed in the 16 report that was prepared for that project had to do with the 17 question of how many people were likely to use what I 10 ordinarily refer to as reception centers, that is who 19 register, are taken care of, that have temporary shelter -- 20 shelter in the nonradiological sense, just shelter from the 21 elements -- a place to sleep, some entertainment, maybe some 22 TV, some cards, some shows for the kids, babysitters, and hot .,m \\v) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6 ~. _.
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That kind ofereception-center..How;many, people 2 generally sh'ow up at reception centersLduring evacuations-to 3 give -some '.inviicatiion -as to twhat' is a; reasonab'le planning 4 target"for how many_ people are going;to.show up.if youlhave LS - an, evacuation of a given size'. 6 Q Your interpretation of-this. project wasithat you 7 were concerned with the number of people-that would show up; .8 at-reception centers -- strike that. 9 The way;you used the term " reception centers"'just 10 ' now, I take it means that it did not-include radiation- '-(N. 11 monit'oring and decontamination but did include _ registration. ~ \\.J 12 Is that correct? 13 A I don'.t recall having addressed radiological-14 monitoring in any detail. Well, I can put it~a little.more 15 strongly than that. We did not address radiological -16 monitoring in considerable detail. As I recall, from.what we 17 -were thinking at the time, that we didn't discuss anything i i-18 more than to say that radiological monitoring might be 19 conducted at that location, and that people would be i; 20 instructed to stop in at the reception center if they needed 21 to be monitored, and then if they needed shelter they would ii 22 stay there. Otherwise, they would be free to continue on to 1 2 ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 + -,. - ,-w-- -,-,-y, ,___-w,7,,,m__,,_.,,,_ ,o_,- ,,___.,,y.p ,,,.__.,_p,y-,pm _,__.,,,.,,,.,,m.,,.,,,--.,.y._._,y.,.
30072.0' KSW 41 l 1 another location, since in fact somewhere between 85 and 95 2 percent of'all people stay with friends and relatives and 3 neighbors or make their own arrangements for accommodations. 4 Q I think I can phrase my question a little better. 5 Did this project address how many evacuees or what percentage 6 of evacuees would show up at a reception center for 7 monitoring and decontamination? 8 A Not as a distinct issue, no. 9 Q What was the result of this project? Did you have 10 a recommendation as to the percentage of people that would (~') 11 show up at a reception center as you defined it as a place \\_: 12 where monitoring and decontamination did not occur? 13 A 5 to 15 percent seems to be the range in most 14 emergencies, based on the literature that we had available. 15 I understand from AIF that that figure was checked with the 16 American Red Cross and that was consistent with their 17 experience. 18 Q So your project analyzed other disasters besides 19 radiation disasters? 20 A Yes. Well, I wouldn't say that we analyzed 21 others. We relied on the disaster literature, what we knew 22 of the disaster literature to say what kinds of behavior () () Ace FEDERAL RneonTens, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
30072.0 KSW 42 1 could be expected from the public in a' radiological 2 emergency. 3 Q The disaster literature, I take it, then, did not 4 include radiation monitoring and decontamination as one of l 5 the elements in going to a reception center? 6 A There are always hazard-specific aspects of 7 emergency response. For example, in a radiation' emergency, 8 you don't discuss sandbagging, so it would be nonsensical to 9 talk about sandbagging in connection with a radiological 10 emergency. It would be equally nonsensical to talk about 11 radiation monitoring in a flood emergency, and you can (~} s.- 12 extrapolate to other kinds of natural and technological 13 disasters. Inevitably there are things that are discussed 14 that are hazard-specific. 15 Q Do you have an opinion regarding the number of 16 people on Long Island -- do you have an opinion regarding the 17 percentage of people within the EPZ that would go to a 18 reception center for radiation monitoring and 19 decontamination? 20 A Are you going to give me some more information? 21 Q What kind of information do you need? 22 A Well, it would depen. upon people's -- to start ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6M6
l.. i10'072'.'0 ~ 'KSH 43 ,gk) fr'mithe-left-hand side of.my model and work toward-the 1 o 2' .right-hand. side, in' something of a chronological order -- it' ~ -3 would depend: upon their prior belief s --about-the hazard,.the' -4 characteristics of the-information-source, the content of. '5 - messages prior to the emergency -- that' is that come by means 6 of~ emergency public.-:information brochures -- and information-7 that cones:during the emergency regarding the characteristics. 8 of the hazard and the characteristics, the nature and 9 characteristics of alternativ'e protective actions. Those 10 feed into people's perceptions of, during the situation,oof-11 the characteristics of the emergency'and of the alternative } 12 protective actions. 13 Those in turn affect their responses, so in order 14 to say how many people would show up, then I would have to 15 know what their prior beliefs are, what kinds-of information 16 you are talking about in terms of the emergency public 17 information brochures, what information was disseminated 18 during the emergency, what was the circumstances that 19 facilitated or served as barriers to certain kinds of 20 actions. For example, if families are separated or together 21 makes a difference in how many people show up at a particular 22 time in a particular location. O ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-3346M6
l30072.0 KSW 44 t i ..J 1 People's concerns about other issues, such as 2 property protection and so forth, also have an impact; so in 3 order to come up with a number, I would, and anybody else 4 would, have to have a lot of information. 5 Q Let's assume that there was an accident at 6 Shoreham that necessitated the evacuation of the entire 7 10-mile EPZ, and that indeed that was the recommendation that 8 was made, and that information was conveyed by messages and 9 disseminated to the public. 10 A I still need more information than that, because (] 11 it depends upon -- there are circumstances under which, given tj 12 the kind of attitude that the Nuclear Regulatory Commission 13 has and has pressed the licensees to adopt, any evacuation is 14 liable to be precautionary, and that is that if there's an 15 evacuation of the entire 10-mile EPZ, it is liable to be 16 based upon loss of two containment barriers and the potential 17 for a loss of a third. If that is the case and that is 18 conveyed to people, then it is entirely possible under those 19 circumstances that virtually nobody would show up for 20 monitoring. 21 Q Why is that? 22 A Because if the licensee, as backed up by ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 3346M6
'30072.0 .KsW 45 x 1 governmental agencies, says that there is the potential for a 2 release, but there has been no release to this point, then it 3 is entirely possible that nobody would show up. There would 4 be no reason to show up, any more than there would be no 5 reason to sandbag if somebody said there could be a flood, 6 'but it has not occurred yet. 7 MR. CHRISTMAN: Could we go off the record? 8 (Discussion off the record.) 9 BY MR. ZAHNLEUTER: 10 Q Can you accept a hypothetical situation where an 11 evacuation of the 10-mile EPZ was recommended and it was also .( } 12 recommended that all of the people within the EPZ go to a 13 reception center for monitoring and decontamination? Can you 14 accept that that might occur? 15 A That's what I'm trying to think of. I'm trying to 16 think of any conceivable set of circumstances, and I'm having 17 a hard time, so if you will give me a minute, maybe I can -- 18 Q Regardless of the cause, can you accept that that 19 might be the result? 20 A Well, a result has to have a cause. 21 Q Okay, well, what I'm saying is -- 22 A I can't think of a plausible set of circumstances O t\\_J Ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 6M6
30072.0 . KSW-46 l 1 .that would generate a recommendation like that. 1! Q But can you assume that such a recommendation 3 would occur and that-the people would be directed to go to a 4 reception center'for monitoring and decontamination? Let's 5 assume that that is the case. 6 A You can assume walking on the ceiling, but if you 7 assume that I -- if you assume something that I don't believe 8 will happen, and I can't conceive of any reason for it, it is 9 hard for me to assume something that doesn't make any sense 10 to me and then come to a sensible conclusion that follows -(~} 11 from what doesn't strike me as being a sensible assumption. As 12 Q Let me give you a possible reason then. Say from 13 a planning basis you want to assume that those facts are 14 made. You want to assume a worst-case incident and we want 15 to plan that it would happen, and then assume that 100 16 percent of the EPZ is asked to evacuate and to go to a 17 reception center for monitoring and decontamination. Based 18 on people's behavior, do you have an estimate of the 19 percentage of that population that would go to the reception 20 centers for monitoring and decontamination? 21 A Well, I don't think you have to assume what you 22 asked me to assume to answer the question. If you tell ss ACE. FEDERAL REPORTERS, INC. 202-347 37(X) Nationwide Coserage 8(K)-336-M>46
30072.0 KSW 47 ./ 1 people.to go to a reception center for monitoring and -2 possible decontamination, I would say that it is reasonable 3 that most of the people would do so. 4 Q Like 90 percent? 5 A Sounds like a good number. 6 Q In between 90 and 100? 7 A 90 percent is probably a good number. 8 Q I wanted to ask you about two more projects on 9 your list, and then perhaps we can take a break, okay? 10 A Sure. (~T 11 Q There's one for the National Science Foundation 12 that refers to behavioral response to technological hazards. 13 Would that include the type of behavior that might occur at a 14 reception center or the type of behavior that might occur 15 waiting to obtain access to a reception center? Would that 16 have any relationship or application? 17 A The focus of the study was on the perceived 18 characteristics of different hazards, and with an attempt to 19 get at more general affective and behavioral intentions for 20 sheltering or evacuation in an emergency; and so the data 21 would be relevant, I think, to the question of reception 22 centers, how people would respond, that is, whether people ace. FEDERAL REPORTERS, INC. 202 347-3700 Nationwide CoveraFe 800-336-(M6
V 30072.0 KSW 48 ) 1 would in fact go to reception centers. 2 Q .Okay, how about the last item on the list, which 3 refers to a project for the Nuclear Regulatory Commission 4 evaluation of licensee emergency response facilities; would 5 that include reception centers? 6 A No -- well, reception centers -- well, every place l l l 7 other than Shoreham the reception center is not run by the l 8 licensee. I was about to say reception centers are never run k 9 by licensees, but that's not the case here. That project is 10 a follow-on to the evaluation of emergency response facility /~') 11 designs. These were actually on-site evaluations of the v 12 operations support center, technical support center and 13 emergency operations facility. 14 Q Other than what we have discussed, then, in the 15 way of projects, are there any other projects that perhaps 16 you didn't include here or that might be relevant to 17 reception centers or evacuating to a particular point? 18 A The only conceivable one that would be relevant is 19 -- let's see if it is listed on here. No, it is not. It is 20 a project that I have worked on over the past three years 21 with Jack Kartez at Washington State University that deals 22 with planning and the kinds of conditions that facilitate U ace. FEDERAL. REPORTERS, INC. 202 347 3RX) Nationwide Coserage 8m33MM6
30072.0 KSW 49 i n 1 planning, emergency response planning,.but it is not related 2 to radiological emergencies. It is a broad based community 3 planning, and I think that was -- there's one-technical 4 report that we have so far. There's another one that's in 5 progress, but'one that's been produced so far, and I already 6 provided that in connection with the other topic. 7 Q The exercise proceeding? 8 A Yes. 9 MR. CHRISTMAN: Let's take a break. 10 (Recess.) /"N 11 BY MR. ZAHNLEUTER: .] 12 Q Dr. Lindell, on page 4 of your statement of 13 professional qualifications there's a listing at the top of 14 the page for a general article entitled " Nuclear power plant 15 emergency warning; how would the public respond?" Does this 16 article have any relationship or application to reception 17 centers or analogous situations? 18 A Yes, I think it does. l 19 Q What is that relationship or application? 20 A It would be related to how people interpret 21 emergency messages, and in this case, I think that we 22 reported some data in there that might be useful in A (_) ACE FEnERAL REPORTERS, INC. 202 347-3700 Nationwide Cmerage A b3 % 6646
30072.0 KSW 50 ~J 1 connection with the question of whether people would 2 misinterpret.the location of the reception centers as marking 3 the edge of the risk area. 4 Q Was this an article on nuclear power plant 5 emergencies in general or was there a specific subject? 6 A It was an interpretation of data from a variety of 7 sources. The central theme was trying to interpret some of 8 these data from various sources within the context of a 9 warning response model derived from natural, primarily from 10 natural hazards, but also from some other technological (~'; 11 hazards. (_) 12 Q The title refers to nuclear power plant emergency 13 warning. What kind of warning are you referring to? 14 A Protective action recommendation. 15 Q Evacuate or shelter? 16 A Yes. 17 Q And what was your conclusion about what the 18 public's response would be? 19 A I haven't read over that article in a long time, 20 so I don't remember specifically what we said, and it may be 21 -- so what I say now may be reinterpreted in light of what I 22 certainly believe, if there's any difference; but in general, v ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage mx)-3364M6
30072.0 .KSW 51 d' 1 the idea was that'if you look only at people's prior beliefs 2 about a radiological emergency, that they tend to exaggerate 3 -- might not be a good word, or entirely accurate,-but it 4 will do -- tend to exaggerate the potency of a nuclear power 5 plant accident, and that because of that, an effective 6 emergency public information program is required both in 7 terms of emergency public information brochures disseminated 8 on an annual basis prior to any accident and effective 9 communications during the emergency that address these 10 misconceptions. 11 Q Would you consider yourself an expert in emergency 12 planning for nuclear power plants? 13 A I suppose so. 14 Q Based on what you know or what you assume about 15 the people on Long Island and their prior beliefs, the type 16 of information that LILCO will distribute according to the 17 LILCO plan, the type of messages that LILCO envisions in the 18 LILCO plan and the circumstances around Shoreham, what is 19 your opinion of the number or the percentage of evacuees that 20 LILCO should plan for to arrive at reception centers? 21 A Okay, I will have to address some of the 22 assumptions first before I can answer the question, and I may r\\ aU ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Cmcrage MX)-33M646
} 30072.0 ~ KSW 52 \\ + 1 ' forget what the question is by the time I address the 2 assumptions. 3 As far as the assumptions, what people's prior 4 beliefs are on Long Island. As I think I indicated earlier, 5 I don't have any data on what people's perceptions of the 6 characteristics of the hazard and of the alternative 7 protective actions are for a Long Island sample. No one else 8 does either. In the absence of information specifically on 9 people in the Long Island area, then I would assume that they 10 would be pretty much like the people that I have collected (} 11 data on. 12 Specifically, people within the 10-mile EPZ for 13 the Trojan nuclear power plant. Now, people on Long Island 14 may well be somewhat different. If they were' going to be 15 different -- I wouldn't expect them, on the basis of what I 16 know about the circumstances regarding the construction and 17 licensing of the Shoreham nuclear power plant, I wouldn't 18 expect them to be less fearful than people in the EPZ for the 19 Trojan nuclear power plant, so I would say that they are 20 either the same or maybe a little bit more extreme, that is 21 that they think that -- they might believe that the speed of 22 onset is greater. They might possibly think that the scope ACE. FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 8(U-336-MM
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'KSW .53 c 'x. 1 of impact is a little greater; but-lacking any specific data 2 .I would have to go with the data that I know about. 3 Q Okay. 4 A Okay, as far as the LILCO program is concerned, I 5 don't have specific information on the LILCo emergency public 6 information program. I do know-that Dennis Mileti has been 7 involved in the design of the EBS messages, although I have 8 not seen them myself. Lacking, having not gone through it 9 myself, I would tend to assume that they are like the ones 10 that I have seen in emergency exercises. Maybe if I'm -- 11 there are offsetting biases here, maybe, that if I'm assuming (']N L 12 that the people on Long Island are like the people in 13 Longview, Washington, that may be a conservative assumption 14 in one direction, but then I am making a conservative 15 assumption in the other direction if I'm assuming that 16 LILCO's public information program is like all other plans. 17 I think that that's probably safe to say. 18 Given those factors, and my belief that a 19 dominating factor in an emergency is the information that's 20 provided at the time of the emergency, that I would expect 21 that it is the latter factor that's going to significantly 22 influence the number of people that comply with any b v ace FEDERAL REPORTERS, INC. 202-347 370) Nationwide Cmerage 8Gh33MM6
i 30072.0 KSW 54 f x s 1 recommended protective action, whether it is shelter or 2 ' evacuate or evacuate and report to a reception center for 3 monitoring. 4 Q Are you able to quantify that with a percentage? 5 A With a percentage? 6 Q A planning basis percentage? 7 A Okay, now then we get back to the question of what 8 can one reasonably expect given -- I'm afraid I'm going to 9 introduce another term of art, the planning envelope. That 10 is what is defined in NUREG 0654 and previously in 0396, as () 11 being the planning basis for emergency response. That is to x-12 say that even though there's a spectrum of accidents that 13 could occur, that there was a point on that spectrum that was 14 selected as being the planning basis, and that there are -- 15 while less severe accidents could easily -- not easily occur, 16 would be more probable to occur, and there was some remote 17 possibility that more extreme accidents could occur, that 18 this is the planning envelope within which -- for which the 19 licensee has to demonstrate capability or demonstrate an 20 emergency preparedness capability that can be extended, if 21 need be, in a more severe accident, in order to get to an 22 evacuation of people as far away as 10 miles. I find it V'O Acn FnDnRAL RneonTuns, INC. 202-347-3700 Nationwide Coverage Hm33MM6
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1 Implausible to believe that there's going to be a full 2 10-mile radius evacuation. 3 My expectation is that there would be an 4 evacuation out to a two-mile radius and maybe as much as 10 5 miles downwind in the affected sector and then the adjacent 6 sectors, so there might be as much as 1/8 of the circle 10 7 miles downwind, and that's what really has to be planned for 8 as far as linking up the spirit or the philosophy of NUREG 9 0654, in which case those who would be told to monitor, 10 report for monitoring would be roughly 20 to 30 percent of (~) 11 the EPZ population. 12 Given that, I think that 90 percent of those 13 people would show up for monitoring, and that there may be 14 people outside that group that would show up for monitoring, 15 but if, especially if the evacuation were precautionary, that 16 is before a release takes place -- which, again, because of 17 what I have seen on the part of the Nuclear Regulatory 18 Commission Staff, the emergency preparedness staff and the 19 way that they deal with licensees, I think that is the most 20 plausible scenario -- and I think that it is relatively 21 improbable that there will be many people other than those 22 advised to report for monitoring that will in fact show up, r Acn.17EDERAl. ReponTens, INC, 202 347 370) N,itionwide Cmcrage mm).3364M6
30072.0 56 ,, KSW 'i -m i 1 Q Correct me if I'm wrong, then, the quantitative i 2 planning basis, according to your opinion, would be 90 I 3 percent of 20 to 30 percent of the population of the EPZ? i - 4 A Yes, plus a few extras, so it might be 100 percent 5 of the 10 percent extra that were not advised to report for 6 monitoring, so something like 100 percent of the evacuees, 7 maybe some more, but I think that's my expectation, that 8 would be somewhere in the vicinity of 100 percent of the 20 m 9 or 30 percent that were advised to evacuate. 10 Q What is your explanation for why those few extras, /l 11 I think you said 10 percent, would evacuate, and I believe '~ V 12 you said go to the reception center? 13 A Yes, and it is because I think that there are some 14 people that are frightened of a radiological emergency, and 15 there are people that have erroneous beliefs, erroneous in 16 the sense that their beliefs about the hazard differ from the 17 data that have been produced by technical analyses, that is 18 reactor accident analysis beliefs. 19 Their beliefs are inconsistent with the technical 20 data and some of them, a lot of people that do have erroneous 21 beliefs will accept credible data and revise their beliefs in 22 the direction of being more, " realistic" if they receive Ace FEDERAL REporrERs, INC. 202 347 37(N) Nationwide Cmerage Mab33MM6
y 130072.0 KSW 57 ._.s 1 information from a credible source or group of sources. If 2 the information can be explained to them, if it can be 3 explained to them satisfactorily why their beliefs are 4 erroneous, and why the data that they are being given are 5 correct, most people will accept that. But I think it would 6 be -- it is improbable to assume that everyone is going to be 7 influenced by accurate information, even accurate information 8 from credible sources. 9 Q Could those people who comprise the 10 percent 10 figure be residents of the EPZ as well as residents of the (~N 11 areas outside the EPZ? U 12 A They could be people from outside the EPZ, 13 although that gets you back to the questions of what is the 14 nature of their misperceptions. Anybody who lives close to 15 the plant is more likely, all other things being equal, to 16 think of themselves as being at risk than somebody who lives 17 a great distance from the plant, and so if there are people 10 who respond inappropriately, that is they take protective 19 actions even though protective actions are not recommended 20 for them, then it is more likely if you take that group of 21 people and, as they come in to a reception center, ask them, 22 "how far from the plant do you live?" or better yet, that O ACE. FEDERAL REPORTERS, INC. 202 3474 700 Nationwide Coverage 800-336-6M6
- 30072.0' KSW 58
%,.e 1 you can actually document how far they live, because most 2 people can't judge distances very well -- if you find out 3 where they live, that a higher portion of them will live 4 closer to the plant than farther away from the plant. 5 Q Is this opinion based on specific research or 6 surveys that you have in mind or is it your general intuition 7 and insight into the matter? 8 A It is my insight into the matter. That's the 9 reason I collected the data that I did, that my intuition 10 told me that that would be correct, but the whole purpose of 11 being a scientist is to try to collect empirical data to } 12 verify your hypotheses, and in this case, I think that there 13 are data from a number of different sources that substantiate 14 that idea. 15 Q Okay, with respect to the people who you said 16 would evacuate beyond the 20 to 30 percent, the 10 percent, 17 what is your basis for arriving at a 10 percent 18 quantification as opposed to a 40 percent? 19 A It is possible that it could be 40 percent. It 20 would depend upon how people interpreted the information that 21 they had received. If they received -- I'm assuming that 22 there's a very effective emergency public information. I'm !n V) ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage 800-336-6M6
}, ' ~.;;,_ [3 1 s ~ y ( y. (/: f k i' (, .30072.0 9 1 KSW 59 r J _ K 1 saying that the 10 percent is probably a'imost. an irredudble
- h. /
2 minimum, that itjust strikes me that there arv. going d Nb'b i-10 percent of.the peopl'e thEt av{not advised t'osivagyste, 3 3 y ,( s. 4 you know, 10perce[tofthepopuAationcloseto.the'a2ea \\ 3 defined in th$ war 6ing message, that is 10 miles downwind, ina 6 certain sectors, that what happens is that pecpl? Anderstand ?
- );e t
7 that there are not walls on radiation plume. ~ There'agNthink, s' ,f' l, 8 that would suggest that there's a clean-cut break theres { 9 Q There's no physical cue? y 10 A Okay, fair enough. And so wha [ happens is that if ? 1 s /~T 11 you name'a particular boundary that's a, geographic boundary G f 12 Eut'is not a physical bdrrier to the plume, then peopld are 13 going to wonder to what extent, but what if I live righ t next ,1 14 to that boundary? Welig general y wrpt hypp ns 10 t' nit that 15 has been accounted for,by fome kind of safety margin im the 16 plume calculations, t h.a t "i s they will say the exposures won't; 17 exceed five, rem beyond tiis point, but 've ' re going to -- so 18 that this is tne definiff on M the plume. This is the trea 19 that's going;to reach c fiye-rem exposure you are over the 20 duration of t he relean*, shut we'll add a safety margir here, 21 realizing thery. may be eddles in tag wind currento and i. 22 building wake ef fec ts and v.tricus kinds of things, /^\\ (/ Ace-Fnonex. Repot Tnia : INCe 202 347 3700 Nationwide Coverage duk33MM6 L
r = ~ ~ k 0 .( <. (# 130072.O h KSW 9.. -3 60 q ) l ) .y i1 topographical' effects, so what we will do is instead of v s. g telling the people to evacuate within this area, we're going. 2 3 to extend it out to here. i s 4 Well, to try to explain all of the. factors, all of 1 7 4 5 the factors t' hat govern the safety margin, may be extremely ly ( 6 confusing to' people. At any rate, they are typically not t 7 discussed whon protective action recommendations are given, 8 and I think, generally, for good reasons. The problem is / ( y ) 9[ that it is defined as apparen-y being a sharp edge and y t.. y ( people don't understand that so they will add their own 10, t s y
- (]
11 safety margin on to that, and I don't really have any problem V 12 with that. I don't think it is going to be a problem. If s y 'p 13 you have accurate information coming from a credible group of 14 sources, then I think that that irreducible minimum will be s s 15 cloue to 10 percent. It could well be smaller than 10 s y ,~ 16
- percent, O(
f e 17 r Q If you have information that is less accurate and i 18 comes,from a source that is less cred5ble, could the 19 percentage consequently rise above 10 percent, and I think 20 you used 40 percent, could it rise above that? s 21 A Well, there you get into the question of given -- 22 there we start getting into the other proceeding. (A) { . pl 4 L ace FEDERAL REPORTERS, INC. 202-347 3700 Natianwide Coserage 800-336 6646
s 30072.0 x, 61 KSW ~ lk ( h . Jf"- . 1 It hinges upon what peop}e will do, what the 2 ' emergency organization will do in an emergency, what kind ofi s p i '3
- information that will be transmitted to the publit in an s
i 4 emergency, and that in turn is significantly effected by 5 the,1r emergency procedures.. Andsotothedegreethattheh 6 have effective emergency procedures in place, that they have 7 an effective plan and implementing procedures in place prior 8 to the emergency and they have an effective training program,. 9 then what will happen is that there's little reason to 10 believe that they will give out bad information, conflicting 11 or inconsistent information, during an emergency, therefore, 12 and as a consequence of that, then it becomes relatively 13 improbable that the number of people taking protective / 14 actions who were not advised to take protective actions would q. 15 be larger than 20 percent or 30 percent or, you know, 40 16 percent. Each one of those numbers becomes increasingly 17 ,improbabl e, v. 18 Q And on the other side of the model, I think you 19 used before left-hand and right-hand side of the model. i 12 0 There's another side of the model,.isn't there, that the q 21 number of people taking protective actions who are not 22 advised to take protective actions could increase if the o k L_,.I ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6646
30072.0 'KSW 62 N. I credibility of the source and the information is not as 2 accurate? 3 A Say that again. 4 Q I think you explained to me th.ht it is your 5 opinion that credibility of the organization and the accuracy 6 of the information could result in a low probability that 7 people would evacuate when they were not told to evacuate or 8 take protective actions. 9 A Right. 10 0 I'm asking a corollary as part of your model also, (/) 11 that on the other hand, the other extreme or the other side w 12 of the model, that the probability that people would take 13 protective actions when they are not advised to would 14 increase if the credibility of the source and the accuracy of 15 the inf oriaation was not as good as it could be? 16 A Yes, that's true, although I would qualify that by 17 saying -- I said sources, because in an emergency, 16 information will be coming from a number of different 19 sources, and the credibility of the sources depends upon two 20 factors. One is their expertise, perceived expertise; and 21 the other is their perceived trustworthiness, and that one of 22 the propositions that we put forth in our atomic industrial ,r~, ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646
- 30072.0 KSW 63 1 forum ~ report is that a composite source or a panel of sources 2 can mutually affect each other's credibility, so if all of 3 the sources agree upon a protective action recommendation or 4 agree upon the data or agree upon a fact, that even though 5 one particular source may be suspect with respect to one 6 attribute, that the panel of sources operating together has a 7 -- can have a very high degree of credibility. Higher than 8 -- the panel as a whole can have more credibility than any 9 individual member. 10 Q So you are saying that perhaps a panel of sources /; 11 that would be comprised of utilities and governments would be L,I 12 more credible than one of those entities just alone? 13 A I think so, yes, than either one alone, because it 14 raises a question -- see, what happens, the question that 15 people would have in mind is to what degree does somebody or 16 a group of people know what's going on and will they convey 17 that accurately to me; and both those questions have to be 18 addressed. So if one perton knows what's going on but may 19 have a perceived reason for not conveying the information 20 accurately, then there may be some question as to the 21 credibility of the information. 22 Conversely, if another source has every reason in p %,r ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
's 7.' 30072'.0 .KSW 64 ,j 4~- 1-Ethe'wo'rld tofpass on.the information accurately butisimply E2 doesn't.know what the information is,-then that's not 3
- sufficient either.
You have to have both of those operating 4 together in order to have a credible ~ source. -5 Q What types of entities would be on'th'io 6 Lhypothetical. panel of credible sources or information 7 sources? 8 LA Well, I think there are -- I think if you look at .9 the potential sources that might be available', they include, 10 just in general.for nuclear power plaats, they include the ~ 11 utility, the township or county -- whatever the local }- 12 jurisdiction or: jurisdictions might;be. In New England 13 there's a huge number of townships -- and the state, and thec 14 federal government, and of course within the state ard within 15 the federal' government, there are a variety of agencies. If 16 you had somebody.from -- if you just said somebody from the 17 state, well, that's not enough information. If you had 18 somebody from the state department of motor vehicles, 19 -obviously that would not be a terribly credible source. If 20 you had somebody from the state radiation protection bureau, i[ - ~ 21 that would definitely be a credible source and would make a 22 contribution to the panel. 10-ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 ..-_.,,_. _,- - ~._. -._-, -
c-30072.0. KSW 65 ,.I 1 .I think there are a. variety of ways that you could 2 get a credible panel. I think that if you had the utility 3 and the county and the state, that would be a credible 4 group. If you had the utility -- and I think you always have 5 to have the utility, because they are the ones that know 6 what's going on in the plant, in order to be credible -- the 7 utility and the state and the NRC, you know, if you pick 8 people, if it is clear that some agency of the state that's 9 relevant to radiation protection would provide credible 10 protective action recommendations, that is, whether or not it- ~N. 11 is appropriate to implement certain protective action J 12 recommendations. 13 Now, the question of the county, again, under 14 normal circumstances, local officials have the most -- tend 15 to have the most accurate information about the feasibility 16 of conducting an evacuation because they know about the road 17 nets and are going to provide traffic guides -- sorry, 18 traffic police, under most circumstances, and are going to 19 organize the school buses, transportation for those who are 20 transit-dependent, ambulances for evacuating hospitals, if 21 necessary, or for evacuating those who have limited mobility 22 but are not institutionalized; those are usually done by the . t'3 (-) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
30072.0 KSW 66 i w-1 local government. So it would be necessary under'most 2 circumstances to have local governnent be a part of the panel 3 in order to say, yes, not only are'these protective actions 4 needed but they can be implemented. S' Now, as the present case seems to have 6 demonstrated, it is not essential to have local government be 7 a party to that, because LERO is stepping in and performing 8 those kinds of evacuation support functions. So in that 9 sense, the fact that the county is not on the panel, I 10 wouldn't regard as terribly significant. It is the function, (~' 11 not the organization, that's critical. V; 12 Q Getting back to the 20 to 30 percent figure that 13 you identified earlier as a planning basis, from your 14 familiarity with the LILCO plan, do you know what resources 15 LILCO would have available in the event that the percentage 16 were higher? 17 A It is my understanding that if the percentage -- 18 well, that they do, in fact, what is required by or the 19 guidance that is recommended by NUREG 0654, and in fact 20 that's exactly what any organization does in an emergency. 21 They have a certain capability. They have a capability to 22 monitor and decontaminate a certain number of individuals. 's_) ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
t 130072.0-KSN ~ 67 7 q-Q 1-If the number of individuals ~ exceeds'that, there are backups-2 'for-that,Lso th'ey would call upon oth'er utilities to_ provide 3 . trained personne1 Land equipment'through INPO to respond.to 4 the. emergency, and inLthat sense'it is no.different from what. -5 any county.that's done adequate. emergency planningfwould do '6 or any city or state would-do in calling upon other- '7 organizations that have' emergency response capabilities .8 through a mutual aid agreement. 9 Q Besides INPO and a' mutual agreement, do you know ' 10 if theres anything else that.the LILCO plan provides for to { L N 11 expand'LILCO's capability to monitor and/or decontaminate a
- (J.
12 ' higher percentage of evacuees, if necessary?- 113 A No, not specifically, but if there were an 14 emergency at'any nuclear power. plant, I think like any other 15 major emergency, that the full resources of local 16 jurisdictions would in fact be brought to bear, that the full 17 resources of the state and any neighboring states would be 18 made available, and that the-federal government would make 19 resources available in a major emergency, and that is the 20 . sort of thing that happens on a routine basis. Counties do 21 get and jurisdictions do get assistance from other 22 jurisdictions, even though mutual aid agreements have not O) ACE-FEDERAL REPORTERS, INC. . 202-347 3700 Nationwide Coverage 800-336-6M6
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been' signed. It is very-common. -2 -Q Let's_ talk about: reception centers, and ILwill_ask 3 .you if only onefdriver, if only'one person;infa vehicle ~were- ~ 4' monitored for' radiation, do you think, is it your opinion 5 that the'other people who might be in the car who are-not ~ 6 monitored wouldLexhibit certain behavior-under those 7 circumstances? 8 A Come on,'you got to tell me what certain behavior 9 youcare talk'ing about. 10 Q .That's a fair answer. - (,/ _ -11 What do you think the reaction of people would be-(~1 ~ 12 if they were in a car andsthey~were not monitored when just: -13 the driv'er was monitored? 14' A I think that if the monitor, the person who:was 15 performing the monit'oring said, "we're trying to process a-
- 1 46 number of-people through here, and if you have been in the 17 same location as'the driver of the vehicle, _ then you will 18 have the same degree of exposure if there's been any kind of 19
-- if the driver has been exposed, then you will have been 20 exposed. If the driver has not been exposed you will not 21 have_been exposed." If that's explained to people, I don't 22 see any reason why most people would have any difficulty in ,.;o 2kCE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646 I
~ M L30072.0 >KSW 69 ^rm.. ~ .v)._ ~ L 1 faccepting that and just saying, you know, ifyyou are really. 2 concerned'- maybe youlcan-come'back later or we can'make:some 3 -ad. hoc arrangements at the time, but the: major thingLis - "I 4 don't think people w'illabe particularly' disturbed. 5 .If.you have a household.that's been together?and .6 they all evacuate together,.they'came in the same-vehicle, 7 you can pic'k somebody randomly. Rather than pick the' driver: 8 -just say.we'll pick one, pick anyone. That would be '9 acceptable. But I1think if you., explain the rationale, 10 picking the driver alone is sufficient. V4%- 11 Q So you.think it is important for the monitor to-k ). 12 find out_the origin of all of the people in the car? In 13 other words, to. find out if they had come from the same 14 location? 15 A I think it would be useful to do on radiological 16 grounds, and I think it would be reassuring to people if-that 17 is in fact the way'that it is done, so it would take care of,, 18 -A, it would be the best procedure from a radiological 19 standpoint, and B, it would be the best procedure from a s: 20 psychological standpoint as well. 21 Q So then if the answer were yes, the group of 22 people did come from the same place, the same location, it lQ V Ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
v U. p.g c;, t p30072.0, ~ >-KSW 704 .Q 41 would.be reassuring'for the monitor,to-explain (to the people 2 ~whyythey.were n'ot'being monitored and just1one person;was~ ? 3 -being monitored? ^ 3 4 A-Yes. If in. fact they are doing-it because they. 5 have huge long' lines, peop'le do respond to.~the. circumstances'- I 6 and say, we.only have time to monitor one person in this. 7 group, so that we can get everybody else monitored within a-8 reasonable _ period of time, so.that's the reason that we want-h 9 to just pick one person and pass.the rest of you through, as .10 'long as you have all been together. If-that's-the case I /~N - .11 - . don't see any problem. \\_) ~ 12 Q Okay,- now let's look at the other side of the flow 13 chart. Suppose that indeed one of the persons in the car . 14 says no, I wasn't in the same location, how would the 15 monitorer be advised to react, then, from the point of view 16 of psychological stress and' behavior? 17 MR. CHRISTMAN: That's unclear. How would the 8 monitor be advised? 19 BY MR. ZAHNLEUTER: 20 Q How should that person deal with that to avoid possible stress or adverse behavior by the other people in 121 22 the vehicle? JO ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6686 m,._.
i ?. ,30072.0 [KSWD 71: , y )! !v ;g 1 MR.!CHRISTMAN: Objection, that's a; compound: 1 x It assumes-the.possibilityHof aberrant' behavior:-
- 2-Equestion..
3 'and also asks howsone'should be advised. The question is- ~ S4. . compound and confusing. 5 . THE WITNESS: I was going to separate the two 6 questions. 7 BY MR. ZAHNLEUTER:
- 8
~Q Go ahead. That would be the best way. From'a psychological standpoint, I think the first 9 A -10 -part'of your question deals with, from a psychological .Q("v . 11 standpoint, _ what is-the most effective procedure-for I 12 .ra'diological monitorsyto follow if.there are -- if the 13 . occupants of.a particular vehicle have' not all been together. 14' through'the course of the evacuation process.. In that case, 15 I'would say.that you come to the same conclusion on 16 psychological grounds that you do on radiological grounds. 17 If there's somebody in the car that came from - 18 someplace else they could have gotten -- could have been ~ 19 contaminated, and so that you would want to monitor that 20 person in addition to a representative or a sample of one -- 21 in this case it is a systematic sample of taking the driver i-
- 2:2 from the group that's been together and then take that other
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c w '4 30072.0 ~KSW1 72
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1 Lperson asfconstituting a separate group that needs to be -2 . monitored. 'So that makes. sense on~ radiological. grounds and '3 it makes sense, it will'make sense to the. occupants of.the 4 vehicle. 5
- As-far as.the consequences of;not following that 6
procedure, I. disagree that that would result in,'I think you 7 used the term " aberrant-behavior" or something like that. I-8 think'that people would be -- that some people would be 9 concerned that they might have been exposed at some'Sther 10 location. It could easily hinge on the information that was- {'}. 11 available, but again, we're supposing a lot of things. 12 In this case we're implicitly supposing that there 13 had been some kind of release. That's the reason people are 14 being monitored. If'that person had been picked up.from a 15 location-that was-farther away from the plant than the other [. 16 occupants of the car, then there would be-no consequence. It 17 wouldn't make sense to people that somebody that was farther 18 away would be more exposed than somebody that was closer to . 19 the plant, so I think that in many instances, especially if 20 that's the case, if people pick up somebody that's farther 21 away from the plant, then there would be no problem 22 whatsoever. bv ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 k-f
y _ 130072.0 .KSW 73 1 If they picked up somebody closer to the plant '2 there may be a question in their minds and there ought to be 3 'a question in the mind of the monitor in that case, so 4 there's nothing that you arrive at from the standpoint of 5 examining the psychology of the situation that you don't 6 arrive at'by looking at the health physics of the situation. 7 Q So distance from the plant would be one thing that 8 the monitor would have to inquire about at the time of 9 monitoring; is that right? 10 A _Well, contingent upon finding that the people had , ~T 11 not been together. D 12 -Q Right. That's correct. 13 A That the person who was picked up was in a i 14 location where they might plausibly have been exposed to the 15 release. I think that would let out -- that simple question 16 alone would screen out a lot of the excess people. What 17 would happen is that, suppose 10 percent of the people were 18 separated, did not all arrive together. Then I would say you 19 would probably have only about 10 percent, or 20 percent or 20 50 percent, whatever it is, but a fraction of those, that 21 would have actually picked up somebody that was closer to the 22 plant than the people in the car, because that's the only ,c- 'w/ ACE FliDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
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- case that you arelconcerned about.
2 Q: You would agree then, wouldn't you,'that"the 3 . monitor ~would also have to-know, for example, which zones 4 within:the EPZ were1 contaminated? 5 A Well, now you.are asking.me to be more of an-6 emergency preparedness or radiological' emergency prepare'dness-- 7 specialist than a psych' ologist,.and it.would;take me a lot! 8 longer -- what you.are asking me to do.is to assume:the role 9 of a health physicist now and say, what's the appropriate -10 procedure. You-are asking me to on-the-spot develop a )(~J'i. 11 procedure.for the radiological-monitors, and, given enough 12 ' time, I think I'_could do a creditable first draft of a 13 procedure, but I wouldn't do it myself:and then say, here's-14 .the procedure.,I'would-look'at it and say, okay, this makes 15 -sense to me, this is what makes sense on psychological ~ - 1 16 grounds, here,-give it to a health physicist and have him or 17 her look at.it. So I think you are kind of-leading me out of 18 my area of expertise a little bit here. 19 Q Short of developing a new-procedure, am I 2:0 correct -- 21 A I don't know if it is a new procedure. I don't 22 know specifically what their procedure is. That may be their Ace FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
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' procedure. 2 Q'; Well, -just-say short of devising. a procedure, am I-3 correct'in understanding:that it is your opinion.as a ~ 4
- psychologist that: monitors should be very much concerned with S
the psychologica'l factors involved in monitoring people when- ~ -6 they' arrive at-the reception centers? 7
- A-Th'e program'should-b'e-concerned about it.
Whether 8 the-monitors are concerned about it is pretty much irrelevant-19 a's.long as they follow their procedures. 10 -Q. A's~long'as they implement the program's concerns? e - 11 A-Sure. 1 '12 Q Would-that be an accurate way of describing.it, 13 -that the program should be concerned with the psychological > - 14 factors that go into. monitoring, and the monitors-themselves 15 should be concerned with implementing it? 16 A The program should not be inconsistent with the ' 17 psychological.-- should not be designed in such a way as to '18 lead ---as to lead people to be concerned about whether they 19 have been exposed to radiation, that they have been 20 contaminated but they have not -- that contamination has not 21 b'een detected; but as I said before, I think, given what we 22 have talked about this morning, I think you draw the same 0 G ACE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 .... -. - ~.,
30072.0 KSW 76 1,) 1 conclusions on radiological grounds as you do on 2 psychological grounds, and so I haven't seen any evidence 3 that there would be a conflict. Something that's well 4 designed from the standpoint of health physics is well 5 designed from the standpoint of psychological reactions. 6 Q Regarding shadow phenomenon, do you think that the 7 distance between the EPZ and the reception centers would add 8 to the number of people that would show up at a reception 9 center? 10 A I don't really think so. The emergency public f~N 11 information brochures talk about a 10-mile EPZ. When anybody J 12 says EPZ most people respond with 10 miles. That's prior 13 information or information disseminated prior to an 14 emergency. The information that's going to be disseminated 15 during an emergency is going to refer to, in all likelihood, 16 areas less distant from the plant than 10 miles. It is a 17 reasonable supposition that if there's an accident at a 18 nuclear power plant someplace, it is more probable that the 19 evacuation area will be two miles than it will be of 10 miles 20 radius. 21 So I think that the location of the reception 22 centers at 40 miles is virtually -- would be an undetectable \\_I ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
m;
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1 increment. It might occur to somebody. I would hesitate, 2 being a psychologist, to rule out=the possibility that 3 somebody somewhere wouldn't have his or her decision-making 4 process influenced marginally by that. I won't say that 5 nobody anywhere anytime would be affected to any extent by 6 that, but'I think you are pretty close to that level. 7 (Discussion off the record.) 8 BY MR. ZAHNLEUTER: 9 Q Dr. Lindell, could you turn to page 6 of your 10 statement of professional qualifications? ('s, 11 A Okay. G/ 12 Q The fourth article is entitled " Social and 13 political aspects of nuclear power plant emergency planning." 14 A Yes. 15 Q Are there any social aspects of nuclear power 16 plant emergency planning? '17 A Yes, there are. 18 Q Other than what you have described this morning? 19 A Other than what I have described this morning? 20 Yes. It is very closely related to what I have described so 21 far this morning, and that is that, what I was trying to 22 convey there in that paper, that paper is the text of a talk /^N V ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-66*6
- 30072.0 1KSW 78 i
v i that I gave for the Health Physics Society, a short course on 2 emergency planning, and one of the things that has always 3 disturbed me is that there are some engineers and some health 4 physicists that don't see the connection between citizen 5 activism in support or opposition to nuclear power and 6 concerns about health and safety risks, and they talk about 7 it as if some people -- there's an extreme group of intensely 8 pro-nuclear people who think that the public is irrational 9 and they don't understand why these anti-nuclear groups 10 emerge or why citizens groups emerge and take the actions (~} 11 _that they do. \\ _./ 12 What I wanted to do was -- actually, the title was 13 somewhat dictated by the people at the conference. They 14 wanted somebody who would deal with social and political 15 aspects. And I said here's what I can do, and I related some 16 of the ideas of public perceptions of the characteristics of 17 radiation hazard, to various kinds of contentions that were 18 put forth in the Indian Point licensing board hearing, and 19 the contentions there were somewhat similar to or were 20 consistent with the kinds of things that were identified by 21 our data on perceived characteristics or the perceived threat 22 of nuclear power. { ~ (V h ACE-FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6646
m r 4 230072.0
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- 1 Now I pointed out that there were'-- those are not
.2 '.the only' data >I looked at'..'There were some.other thingsion, .3 as I' recall, at least oneTor two' articles aboutDcitizen. 4 action groups or' community action-groupsfaroundi.the'Three; S ' Mile Island area and'the kinds of concerns-thattthey had 6 about nuclear power plants and nuclear power plant emergency 7 planning,.and tried to.make it -- what I was..trying to do'was. 8 make the whole. idea of citizen activism a little more 9 comprehensible to the health physicists and-nuclear-. engineers 10 so they.could.see how this all comes about, that~these people (#3 11 .have different or that the general public does have %) 112 perceptions of the characteristics of-nuclear power that are- ~3 different from the results of technical analyses. And that's 1 14 >what the technical experts pay attention to are the reactor 15 . accident consequence analyses. And-that if you have 16 different information you take different actions. You may 17 take action to oppose nuclear power but that's not different-18 from a lot of other technologies and societal activities. So 19 it was just kind of Social Psychology 101 for engineers and-20 health physicists is basically what it was. 21 Q Prior to reading Dr. Cole's deposition transcript, i..(:) 22 did you know or hear of him? i t /\\CE FEDERAL REPORTERS,1NC. 202-347-3700 Nationwide Coverage 800-336-6M6
y .x. .+ ,4 ~ ~9(lf'0072[0? 3 e f1 f KSW ' ~ 80' - , c.; > %s ' y 1- .A-I-think heiwas; mentioned'in CharlesL.Perrow's 2 .. transcript. 3' Q Was that the'only time thatlyou:ever heard of- '4 Dr. Cole?: 5 -A-I can't remember-if I might not -- theiname, I-6 think,;was recognizable at the time, and I-think he.might 7
- have'been cited by Siegler and Johnson.in one of:their-in a footno'te or-something liketthat.
His:name. J 8 . studies -9 sounded -- his name was recognizable when-I read 1Dr. Perrow's-
- 10 deposition.
f' ill Q-How about Dr; Susan Saegert,-have you ever heard-b 12 of-her?' 13 A-Never heard of'her. I think there was-a mention 14 Lof'her in a transcript. I think it was-in Cole's 15 transcript. The nameLhas been mentioned before just now,- but -16 prior to that time, prior to the last, say, two weeks, I had 17 never heard of the name before and I don't know anything 18 about her. 19 Q From reading Dr. Cole's transcript, could you 20 ~ provide me with a brief synopsis of what his opinion of l 21 evacuation shadow and the number of people that would show up j' 22 at centers would be? i ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 .,. _, _ -, =. _ -
,_ n - 30072.0 KSW 81' ) u 1 A Scads of people running around frightened and -2 blocking highways. He claims at least hundreds of thousands, 3 and he may have used the figure millions or a million, 4 something like that. 5 Q Are there any particular aspects of his 6 conclusions that you disagree with? 7 A Yes, the conclusion. 8 Q So you disagree with the conclusion,_but not the 9 steps that he used to arrive at the conclusion? 10 A Well, the conclusion for starters. I skimmed 11 through the deposition, and so I don't want to go -- I (')s Q 12 haven't studied it thoroughly so I don't want to attribute 13 things to him or to act as if I am attributing things to him 14 that I'm not sure about, but my general recollection is that 15 the basis that he uses for coming up with the numbers that he -16 comes up with are or is -- it is hard when you are talking to 17 remember what's singular and plural in the subject that you 18 use. 19 The basis is the survey that he conducted in the 20 vicinity of the -- I think one group was in the EPZ and there 21 were two other groups that were outside the EPZ -- but in the 22 general area, that had to do with behavioral intentions in a (~O i. ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646
30072.0 KSW 82 m 1 reactor accident. And then I guess he alluded, I think he 2 alluded to some focus groups that he had conducted as 3 supporting that as well. 4 Q Can you specify the particular points of 5 disagreement that you have with him? 6 A I don't think you can come up with any accurate 7 projections based on the kinds of behavioral intentions data 8 that.he collected. 9 Q What is deficient about his data? 10 A Well, in order to come up with projections of how ( '; 11 many people would evacuate or take protective action in a ',.J 12 nuclear power plant accident, if you try to predict actual 13 behavior from only behavioral intentions, I think you are 14 skating on thin ice. 15 I don't know of anybody that does research on the 16 relationship, the general area known as attitude-behavior 17 relationships that would claim there's a perfect 18 correspondence between behavioral intentions and behavior, 19 that there are a number of factors that intervene, and that 20 the kinds of behavioral intentions measures that he used, 21 recognizing that you are dealing with a situation in which 22 you are asking somebody to speculate on what they would do in rs N-] ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 800-336-6M6
y-I 30072.0- -KSW 83 l.) 1 an event that you have not~ described perfectly or you haven't 2 -- that you haven't described perfectly, you haven't 3 described completely with respect to all of the factors that 4 would influence behavior, and we know from disaster research 5 a lot about what factors influence behavior in an emergency 6 -- given that you have very incompletely represented the 7 situation, it is very difficult to have much confidence in 8 the numbers that are arrived at, and it is basically that 9 simple. 10 Q Can you recall at this time what specific pieces. /~T 11 of information were omitted from the survey that rendered it L) 12 incomplete? 13 A Well, what happens is that he is asking people 14 first of all to -- he gave them three options. He gave them 15 a description, and I think the descriptions of events are not 16 too bad. They are incomplete, but they are not too bad, but 17 that the respondents were given three options. I can't 18 recall -- there were " continuing your normal activities, stay 19 indoors or leave your home and go to another location" were 20 the three options. 21 Well, that doesn't really completely represent the 22 options that are available to people in an emergency, and as (n.) ACE. FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coserage 800-336-6M6
C -30072.0 KSW 84 i w/ 1 a matter of fact, it kind of stacks the deck by -- staying 2 indoors doesn't suggest much of anything. What happens is 3 that when people get a message they try to confirm a 4 warning. You can't say confirm a warning within the context' S of the three options that were given. The closest you can 6 come that shows some degree of activity, pro-active behavior, 7 is to say leave and go someplace else. So what happened was 8 by the choice of alternatives, acting as if these are a 9 mutually exclusive and exhaustive set of response 10 alternatives, that in effect there's a potential for him, and /~'T 11 anybody else who takes those data at face value, to be misled V 12 into thinking that those are the only things that people 13 would consider. 14 So that's one aspect of it. Another aspect is 15 that it doesn't say when would you, and a big factor in 16 evacuations is not just who evacuates but when they evacuate, 17 or when they take various kinds of actions, and that makes 18 all the difference in the world as far as evacuation 19 transportation is concerned, because it is the loading 20 function. It is how many people are on the road at any 21 particular time, not how many people are ever on the road, 22 but how many are on the road at a particular time which (- V ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 80t>33MM6
~n I30072.0_ ~ KSW- .85 ~ . gg. . N_] ^ .1~ ' decides;whether.~ evacuations go smoothly or1whether 2 obottlenecks' occur. That's'not"ad' dressed'in whether or.not 3 peopleLactually evacuate. 4 Family circumstances'. If families are together, 5 Ethey'have.the potential ~for evacuating [ fairly promptly. If-6 they are separated at the time of a~ warning, they usually" 7 make.an attempt to reunite-and travel together. That's 8 another fac' tor that's not addressed there. There's a range 9 of factors th'at one'can. identify, either from general social .10 psychological theory on attitude-b'ehavioral relations, and . /~% - 11 specifically on evacuations in emergencies that are simply 1(_) 12 not addressed in there an'd really reduce your basis'for 13 making specific predictions about how many people would 14 evacuate in an emergency and drawing conclusions on who would-i 15 .go to -- how many people would go to reception centers at any ~ l. 16 .particular point in time. I just think it would be - I 17 -think there isn't any question about the statistical accuracy-18 in terms of proportions of people. 19 As far as the survey methodology is concerned, I j. 20 think that the survey is just fine. It looks like a very. 21 well done study methodologically, and I think there may be 22 some useful information in there, suggestive information, but a.- /\\CE. FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
~ -., i k -1 30072.'0- _. cKSW: 86' , (x 'q)L 1-asifar as conclusions,= drawing the kinds:of conclusions'that.. .2 he says1.that he is going'to.try'to draw:from those data in- ~ ~ 3 the-deposition, I just think that it isrunwarra'nted. 4 Q
- Do you have any other criticisms or. comments?-
,5 A 'How about those.for starters?~ If-I sit down-and think for a while 'I t' ink'I may befable to come up with-- h 6 ~ ~/ others,.butithose are the ones-that strike me just off the- ~ 8 ' top of my head. 9
- Q ~
~So you can't recall any others at this time?- 10 EA; -No. ?(~'T - Lil -Q' -You used the term'"useful suggestive information"' ~
- ()
12 _ to.ref er ix) some points ofRDr. Cole's survey.. Could;you 13 eldborate what you meant by that? 14 A .Yes. It might'be that -- again,1considering the 15 . fact that in' dealing with people's perceptions of the 1 146 ~ characteristic of the hazard, that.if you-look.at'the I 17 differences in people's responses at various levels, and you i 18 look back to the messages, that that might-suggest what i 19 people are paying attention to, but as far as interpreting 20 those proportions, you know, the behavioral intentions and 21 applying that as a planning basis is inappropriate. 22 Q That's what you meant by useful suggestive LO 1 '~ ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 k:
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~ '3- {l/Q 't [a N y .KSW. ~ s. y '87' , 'y' .*f a.. t. L'9 [ 11; Jinformation?- . 8s --4. 3 < j f' L 1 4 'J '2 A-LI~said suggestive. They'are hsef uEinta l Maybethatwogldmake1[dlearer.' -3 theoretical sense.- I'm-s . l. k 14 dratJing the idistinction -- there.are 'somei things that; advance .5 theory, but may not be terrBly usqfulrin a practical e n 6 , planning" sense. So for. example, we.know f rom th'e warning ' g v-1 g. < t 7 . response literature'that-ifJyou,have a message that clearly x indicates kh'o-is 'at risk and 5:ho is no'h% tLrisk;. until: ~ 8 -r . (- w 9 . somebody has a'n accurate perception of their?wn personal. 10 . risk, then you can't really-predict their-behavior,h;dery well. .r? ~ i 'll- ' So if you say, for example, in a huhricire, Ilieopile in [J. y lowi-lying areas should evacuate, nobody,kn.ows what's a <12 1 + -13 low-iying area. What'do you mean by low-ly.ing. area? If you q 14 say people.thattare less than 15 feet above mean sea level,, s.o 15 that-may help.,_ ay< j' s 1 16 But it is"dependenf.' upon people knowing how'high ( a ,17 their dwelling is above.meani; sea level. If you'say evnrybody-I 1 3 along on the seaward side of,, Coast,al Boule 0a;rd shob1d 0 18 I o + e y 19 evacuate and everybody op the landward side need not h [ \\ o ~20 evacuate, people know'r.ew to' interpret that. We can say what-s -21 are the general p'tlydipi s that ouhht to be followed in s designing energehey'public informatiin d(elea$es, but to say, 22 A y . O.: 1 l M s ace. FEDERAL REPOhTERS, INC. 202 347-3700 Nationwide Coverage 800h.46646 a-. 3 ; -,._,, -_.,,_. >w
p' y-a c - i30072.0 .KSW-88 g_) f 'W [, J.h-l-i L1
- okay,.given that you'know that information or given that m
e ,s. 2 disaster research.has;s'hown that, how many people.on the 3 ' landward side would' evacuate, we-don't~have that kind of 4 ~ precision. 4 5 That's like asking somebody, you know,.it is-like [ } 6 asking the Weather Service to say, plus or minus one-7 . thousandth of an inch, how much rain will there be in my rain 8 meter tomorrow? - They can' t ; ell you, not because.they don't 9 understand principles that. govern weather generally,fbut in "^ ~'10 order to make.that specific prediction you.have to have more-s. n b
- 11 information'than is probably feasible or!even legall-to V7 i
12 collect. MR. ZAHNLEUTER: Thank'you very much, 13 14 Mr'. Lindell. I have no other. questions. 15 EXAMINATION 16 BY MR. CASE: 3
- 17.
Q' I have a few questions. .18 You indicated that in your professional judgment I - l 19 the location of -the reception centers would have - this is mh'Nord -- negligible effect on the number of people who 20
- 21 i would arrive at the reception centers?
22 A Yes. l ACE-FEDERAL REPORTERS, INC. n1 202-347-3700 Nationwide Coverage 800 336-6M6 .a .-w s
I.y t.. b-O 30072.0 KSW 89 1 Q IbelieveyouideNtifiedtworeasonsforthat. s Oneic[thenakOreofthepriorinformationthatwouldbe 2 3 given toJpeople, and the second reason is infornation that N f 4 will. accompany any evacuation. r 5 A Yes. s.;> i' t. 6 Q Are there any other reasons for your conclusions?. 7 A Sure. As a matter of fact, one other is that I 8 think anybody that's familiar with the history of the l ,1 9 location of the relocation centers and the fact that -- and 10 the county's role, apparent role in pushing them around, T'Y j? 11 would suggest that that's an extraneous cue. The location of w_.] y 12 the reception centers has nothing to do with anybody's l',n 13 assessment of risk. It has to do with.a whole host of other 14 factors. 15 0 . Anything else in terms of why you reach the 16 professional judgment you do about the location of the 17 reception ' centers ? s j. 18 A No, I think that pretty well takes care of it. 19 Q -li there any sort of literature, professional { 20 literature you tely on in reaching.your conclusion? Not).ing specifically other than the kind of work 21 A 22 that I have talked about today. There's nothing external to t c ACE FEDERAL REPORTERS, INC. .202-347-3700 Nationwide Coverage 800-336-6CC
i' e 130072.0 .90 KSW- -X,/. 1 myfown'research'and what I think are the implications.ofumy 2 own:research, and:that of others,-in-the general areas .3 characterized as,being risk perception or disaster-research. 4 'So outside those'two areas,.but if you mean can I trace a1 35 chain of thoughtfback to particular. articles,-I couldn't do .I '6 that on the spur of.the moment, no. 7 Q Are you aware of any. studies that_you could trace 8 your chain of-thought back to? 9 A I have:been on'the road for six days, I'm not sure f _ 10 I could trace any c;nain of thought at the present. The }a'~i[ 11 relevance studies would be - the ones that we've talked-12. ab'out today that are the ones that, I think, all of them are -13 contained within the personal qualifications. 14 Q ' Basically your own research and what you consider-15 the implications of that.research? 16 A Well, yes, but my own research is not completely a 17 figment of my own imagination. I wish I could take credit - 18 for.all the ideas, but I think my peers would become very 19 unhappy if I tried to, so there are some new ideas that I 20 have expressed. There are some ideas in what I have said 21 that I wish I could claim, but go back many years, but I 22 think the citations are ir the articles, n v ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6646 ,_--~..a
30072.0- - KSW 91 1 2.,.j' 1 Q I understand. 2 You also indicated that you believe 20 percent, I 3 think your figure was a little more 1oose than that,_20 to 30 ~ 4 percent was an accurate planning basis for the number of 5 people who would arrive at the reception center? 6 A 20 to 30 percent of the EPZ population. 7 Q It wasn't clear to me how you reached that figure. 8 A Okay, if you have an EPZ and there is an accident 9 that is likely to or could result in a release of radioactive 10 material, wind will carry that plume or carry the release, it (') 11 will form a plume that travels downwind. The question is (_ / 12 what is -- that plume defines the group of people that are 13 potentially at risk of contamination. That's assuming that 14 contamination would result-in the event of a release, and 15 that's not a foregone conclusion by any means. If the 16 release consists largely of noticeable gases and minimum 17 level of radioiodines and ion particulates there's no 18 contamination problem at all and no need for monitoring. 19 Q But we're working on a planning basis. 20 A What I'm saying is that, yes, so we have picked a 21 particular thing. We're saying okay, there could be a 22 release that involves the need for monitoring people for C\\ U ACE-FEDERAL REPORTERS, INC. 202-347-3700 Natiowide Coverage 800-336-6M6 e
5, 30072.0 KSW 92- _7-1 . contamination, although the source determination has not been 2 resolved yet, it is possible there would be no particulates. 3 That's outside my area. At any rate, assume that there are 4 particulates released and there's a potential for 5 contamination. The area under that plume or-the area in 6 which contamination could occur is the affected sector, that 7 is from the plant to the edge.of the 10-mile EPZ, the 8 affected sector plus the two adjacent sectors. That's common 9 practice to recommend evacuation of the affected sector plus 10 the two adjacent sectors. (~T 11 If the population is uniformly distributed, then \\_) 12 that's going to be something like 1/8 of the population of 13 the EPZ. Assume, you know, the population usually is not 14 uniformly distributed, so just kind of as a guess on a 15 general basis, it is going to be something like those people 16 who are going to need monitoring or whc should be monitored, 17 assuming that there's a release that involves particulates or 18 radioiodine, so the monitoring would be radiologically 19 appropriate, that it is probably going to be something on the 20 order of, for a planning basis, for planning purposes, 21 something on the order of 20 to 30 percent. So that's the 22 rationale there. (v) ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 800-336-6646
'.30072.-0 .KSW 93 Lj' 1 Q Now you also -- I think you did indicate before 2 that there was one study, must have been the Trojan nuclear 3 reactor, you called it the Trojan study? 4 A~ Yes. Of residents of -- I generally refer to it 5 as the Longview study, but that area of Longview is right at 6 the edge, I think, between-eight and 10 miles of the EPZ of 7 the Trojan nuclear power plant. 8 Q And that study, as well, you used for your 9 planning basis of 20 to 30 percent? 10 A No, that doesn't have any connection really with 11 it. That study had to do -- the study of the risk perception b(~5 12 characteristics, that's my hat as a psychologist, and the 20 13 to 30 percent comes from my experience in emergency planning; 14 and so, based on my knowledge of emergency preparedness and 15 having spent more years of my life in contact with health 16 physicists and reactor engineers than I really care to 17 continue at Battelle, I think you can -- that strikes me as 18 being a plausible rationale for coming up with an estimate of 19 the number of people that would need to be monitored. 20 Q Are you aware of any studies supporting the 20 to 21 30 percent figure? 22 A No. / 1 \\_/ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800 336-6M6
( -30072.0-KSW 94 w 1 Q Anything in the professional literature that you 2 are aware of that would support that? 3 A Not that I know. 4 Q Now, maybe -- 5 A That's great. Maybe I could get an article out of 6 it. 7 Q I may have been out of the room, but what is your 8 professional judgment as to the role of the shadow phenomena-9 and the number of people who will arrive at the reception 10 centers for monitoring and possible decontamination? (~} 11 A The shadow, whether or not a shadow occurs, I v 12 don't think there's much debate about it. I think most 13 people believe that there will be at least some, at least 14 some minimal amount of shadow. The question is the extent, 15 and the extent depends upon the emergency public information 16 brochures, the information that's disseminated prior to an 17 accident, that is, and the information that's disseminated 18 during an emergency by authoritative sources. 19 Q Okay, and I think we -- not we, there was a 20 lengthy discussion about the information disseminated during 21 an emergency, and two important variables of that is the 22 accuracy of the information, and the other variable is the ~) (V ace-FEDERAL REPORTERS. INC. 202-347 3700 Nationwide Coverage 800-336-(M6
= i 30072.0 KSW 95 ? -J l credibility of the source or sources? 2 A Yes. 3 Q. You indicated you taught a class'at Washington on 4 the analysis of survey data. 5 A Yes. 6 Q What textbooke did you use? 7 A There wasn't really any satisfactory texts, so I 8 taught it all from notes. Well, that was the first year. In 9 subsequent years, I used a book that was done by James 10
- Mulaik, M-u-1-a-i-k, and Brett, and it is called " Causal
("'T 11 Models" -- or " Causal Analysis Assumptions, Models and Data," L) 12 I think, is the title. 13 Q Finally -- 14 A Good luck in trying to read it. 15 Q I have no urge, I assure you. 16 You indicated that people generally regard 17 radiation hazards as being more threatening than other 18 hazards. 19 A Yes. 20 Q You indicated you yourself had undertaken recent 21 studies to analyze why that is so. 22 A Yes. (D U ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 8(KL336-6646
30072.0 KSW 96 v 1 Q The results of those studies, have they been 2 published in any form? 3 A-Yes, one is published in Nuclear Safety. 4 Q What is that? 5 A It is a -- 6 Q Just the title of-the article, if you remember. 7 A Let's see. It should be on here. 8 Q Is that the protective response to technological 9 emergency, risk perception and behavioral intention? 10 A Yes, that's the one. 11 Q I believe you discussed that at some length in ~' . (a) 12 another deposition. 13 A Yes. 14 MR. CASE: If I could have this marked as Number 15 2. 16 (Lindell Exhibit 2 identified.) 17 BY MR. CASE: 18 Q What's been marked as Lindell Number 2 is a 19 10-page document entitled " Natural and Technological Hazards 20 Questionnaire." What is this document? 21 A Okay, this questionnaire is the second part of my 22 NSF grant, which was described here. It is pretty clear, I O Acn FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6M6
- 30072.0 KSW.
97 \\ 1 think. The data that served as the. pretest for this-2 questionnaire are reported in the Nuclear Safety article, and 3 these are -- this is the questionnaire that'was administered 4 subsequent to that, and this questionnaire was administered 5 to a group of psychology undergraduates -- the same kind of 6 sample as was used for the Nuclear Safety article -- and to 7 residents of Longview, approximately between eight and 10 8 miles from.the Trojan nuclear power plant. This 9 questionnaire was administered in November and December of 10 1985. (~} 11 Q So this is not the same questionnaire that was As 12 utilized in the article we have been alluding to here on -- 13 A It is not identical. It is similar but not 14 identical. 15 Q Have the results of the questionnaire Lindell 16 Number 2 been incorporated in any papers or talks you have 17 given? 18 A No, there are no published articles on that. 19 There's a manuscript that Valerie Barnes and I are working 20 on, but we have not completed it. There are a number of 21 projects that I have in progress that have not been completed 22 because my time schedule suddenly became filled up recently. (')/ \\_ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
30072.0 KSW 98 1 Q If we could turn to the seventh page of Lindell 2 Number 2, Figure 1, explain to me in your best professorial 3 manner what this means. 4 A I missed after professorial manner. I'm sorry. 5 Q What does this mean? 6 A What does this mean? 7 Q Yes. 8 A Okay, in this figure, there's reference to three 9 separate questions: " Likelihood of a major event," " risks 10 easily reduced," and " likelihood of release prevention." (U'] 11 Those are three separate questions on the questionnaire. 12 Each question has three references. Questions reference how 13 many people are going to Saint Ives, right? 14 okay, so at the left there, it says " likelihood of 15 a major event, MSH," which is Mount St. Helens, and " chlor," 16 which refers to a release of chlorine from a railroad tank 17 car accident, and the NPP is a release of radioactive 18 materials from an accident at the Trojan nuclear power plant, 19 and if you look back here, let's see, if you look back at 20 page 1 of the questionnaire, the question is "how likely is 21 it that, during the next five years, there could be a 22 major... volcanic eruption of Mount St. Helens? chlorine tank L.) ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800-336-6646 t_
30072.0 KSW 99 0 1 car derailment within Cowlitz county? reactor accident at the 2 Trojan nuclear power plant?" That's the question'and those 3 are the three references. 4 Now, there are two sets of lines. One refers to 5 students and the other to residents. The students were-6 members of the student sample, and the residents were nembers 7 of the resident sample. 8 If you look here at the left-most, you can see 9 that there's a black dot right above 3 and a white dot or 10 open dot right below 3, and that that shows the mean rating /~'T 11 by the student and resident samples, respectively, for the LJ 12 likelihood of a major event involving the eruption of Mount 13 St. Helens. If you look at 3 it is a sca.' ranging from very 14 unlikely to very likely, so it is moderately likely that 15 there would be a major event involving an eruption of Mount 16 St. Helens. 17 Q 5 is -- 18 A I can't use a professorial manner unless I can 19 keep going and not answer any questions. 20 Q I know. Sometimes you have slow students. 5 is 21 the most likely and 1 is least likely on the scale? 22 A Yes. r)T (_ ACE FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coserage 800 336-6M6
= 4 u ) , =: ~ ~ T30072.0~ 100 4.[pv.KSW W \\ g,i - 1 Q-Okay, thank you. J2 A !What you can see is that there's some difference ~ ~ ~ 7 3 .between the' students-and.the residents. That's'about 2.7 and 4 3.2; I think;that~ difference was7 statistically significant.. 5 The' difference between' students and residents was veryEsmall-6 with respectEto chlorine and nuclear power plant,yand that as 7 far.as the residents were concerned, you can see-that the 8 likelihood of a major event involving Mount-St.-Helens was 9 lower than it was for a chlorine tank car 'erailment, and a-d 10 nuclear powerLplant accident was also lowertthan the mean 1(~5 11 . rating for-a chlorine tank car derailment. !\\ f, ' 1:2 Q' -How was the -- if you can describe it, how was.the 13 mean rating defined? 14 A The sum of the rate is divided by the number of 15 the ratings. Just a simple arithmetic mean. 16 Q How many students was this distributed to 17 approximately, or how many students -- can you recall how 18 many students this was distributed to, the questionnaire? -19 A About between 125 and 150, I think. 20 Q And how many responded, if you can recall? 21 A These are students. This was in a mass testing n 22 class, and I think we probably had close to 95 percent good ACE-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336-6M6
r. 30072.0 KSW 101 (v 1 data out of the students. They had'nothing else to do that 2 day. 3 Q And with residents, the same question, can you 4 recall roughly how many residents the questionnaire was 5 distributed to? 6 A As I recall, it was a little over 200 that was 7 distributed to and we got a 65 to 70 percent response rate, 8 which is pretty good for a mail-out questionnaire, especially 9 one of this length. 10 Q If we could briefly -- I think I understand the (~) 11 general way this is structured -- identify the questions O 12 addressed at the bottom, " risks easily reduced." What 13 question is that? 14 A Okay, the question at the top of page 4, labeled 15 -- on the right-hand margin, labeled -- the keypunch code is 16 2:01, 02 and :03. "How easy do you think it would be for 17 government agenices or private corporations to reduce the 18 risks to safety and property of a..." 19 Q And "the likelihood of release prevention"? 20 A Okay, that's on page 1, keypunch code 1:04 through 21
- 06, "If a major event did occur, how likely would it be that 22 an environmental release could be prevented of..."
O ss ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coverage 8(XF336-6M6
30072.0 KSW 102 t Q,/ 1 Q If we could turn to figure 2 -- 2 A You want me to go through all of the figures and 3 identify the corresponding questions. 4 Q Before we do that, the mean rating is calculated 5 the same in all these? 6 A Yes. 7 Q MSH is -- 8 .A That's volcanic eruption of Mount St. Helens. 9 Chlor is tank derailment and the other is reactor accident at 10 the Trojan nuclear power plant. / 11 Q Let's go through each one of them. (.)' 12 A " Speed of onset" is question number 3 on page 1, 13 that is keypunch code 1:07 through 309. " Existence of 14 environmental cues" is the following question. " Scope of 15 impact" is -- on the following page, keypunch codes 1:43 16 through :45, "How many miles would you have to evacuate to 17 reach a safe location if there were a..." 18 " Duration of impact," the following page, 1:55 19 through 357, "How long would it be until you could return 20 home safely after evacuating because of a..." 21 Q Figure 37 22 A Same question? (O_) ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 8m3364M6
t' 30072.0 KSW 103 N- / 1 Q Yes. 2 A "Immediate death" is page 1, 1:13 through :15. 3 " Delayed cancer" is the following question, 1:16 through 4 1:18. " Genetic effects" is the subsequent question, 1:19 5 through 1:21. " Total property loss" is the last question on 6 the page, 1:22 through :24, 7 Q And finally, figure 4, if you could identify the 8 questions. 9 A Okay, " dread" is the last question on page 3, 10 keypunch codes 1:75 through 1:77. "Is each of these a risk ('T 11 that you can live with and can think about reasonably calmly, w/ 12 or is it one that causes great dread?" 13 "Think about frequently" is a previous question, 14 two questions up, codes 1:69 through 1:71, "How often do you 15 find yourself thinking about a..." 16 Q I notice you didn't put in a student response, or 17 was it exactly the same as the resident response? 18 A No, that question was not asked of the students 19 because it didn't make a whole lot of sense to ask that 20 question of the students since they were not in the location. 21 And then the last one is " talk about frequently," and that is 22 the one following that, "How often do you discuss with your l'. G ACE.FEnERAL REPORTERS, INC. 202-347-37(X) Nationwide Cmcrage 8(X)-3346646
i '30072.0 KSW 104 ,j 1 family and friends any concerns about a..." and that's 1:72 2 through 274. 3 Q Once again, this apparently was not asked of 4 students? 5 A Right. It was not, partly because they are 6 noncomparable situations. They don't have -- what happened 7 was that the students were asked to respond to a 8 questionnaire assuming that they were a resident of -- to put 9 themselves, given their knowledge of these hazards, but to 10 put themselves in the situation of somebody who lived in (~} 11 Longview, in the Longview, Kelso area, approximately 10 miles v 12 from the Trojan EPZ, approximately 40 miles west of Mount St. 13 Helens, and I-just felt that if we tried to ask them that 14 question, a self-report on behavior, that the results would .15 be noncomparable. It would just -- there wasn't any point to 16 ask the question. 17 Q Did you use a similar questionnaire in surveying 18 students, the results of which were incorporated in your 19 article " Protective response to technological emergency"? 20 A The one reported in the Nuclear Safety article was 21 much shorter. 22 Q We don't have a copy of that. IO) w, ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coserage 800-336-M46 w
30072.0 KSW 105 (n). L; 1 A I don't'have it with me. Because I am at Georgia 2 Tech, I don't have.the office that I had at Battelle, so I 3 had to pack up a lot of things, threw out a lot of stuff. I 4 know I have a copy of it. It may be in one of my boxes at 5 Battelle, and I have probably about 15 boxes of stuff and I 6 honestly couldn't tell you what's in the boxes; I just packed 7 them up. It may be that I have a copy of that questionnaire 8 at Georgia Tech. It may have been put in; I may have 9 included a copy of that questionnaire in the file folder that 10 I kept this one in, and because I took the old one and then I (~T 11 added on to it to make this one, revised it in some respects L./ 12 as well. 13 Q In analyzing the results of your survey, the one 14 that you used for the article in Nuclear Safety, did you make 15 graphs similar to the ones that are in Lindell Number 2? 16 A Yes, there are -- there are graphs, but they are 17 different kinds of graphs. What happens is here we have a 18 lot more questions that we are reporting, so we have just 19 reported mean ratings rather than cumulative frequencies on 20 each of the questions. In order to -- in order to analyze 21 the data or to report the data in the article that we are 22 preparing now in the same way that we did in the Nuclear O) \\_ ACE FEDERAL REPORTERS, INC. 202 347-3700 Nationwide Coverage 800-336-6646
30072.0 KSW 106 ,a. N] 1 Safety article, we would have to have a separate graph for 2 each of the questions, and here we can get three to four 3 questions on a graph, and we have just got a whole lot more 4 information to try to display on this, so there are some 5 differences. 6 On the Nuclear Safety article, we had, for each 7 question, there was a cumulative frequency distribution that 8 showed the cumulative proportion of responses for each of the 9 two hazards, radiation hazard and dioxin hazard. Here it is 10 a slightly different format, but we have basically the same 11 kind of data available; we're just summarizing them, the (v']. 12 data, a little more. 13 Q Do you have the graphs for the Nuclear Safety 14 article -- refer to it that way by shorthand. Do you know 15 what I mean? 16 A Yes. 17 Q Do you still have those in your files? 18 A They are in the article. 19 Q Finally, have you drawn any conclusions from the 20 survey, the results of the survey, tha t we have marked as 21 Lindell Number 2? 22 A Well, a few. What happens is that first of all, (/) Ace-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Cmerage 8043364M6
i r -J30072.0' m KSW; 107- ^
- (.v):
e 1 -the reason for doing.both stu ents and residents'in this' d 2 questionnaire,'thisLmay be telling you how a watch is 3 constructed rather than telling you:what time it is, and it-14 may be more detall'than you.want. LThe first thing isfthat 5 this questionnaire differed in sor.e. respects from the other 6 questionnaire, so what.we wanted to do was to have a student ~ 7 sample,.the same kind of: students, Universitysof Washington 8 psychology students, respond to the new questionnaire, so if 9 we'got any differences between the new questionnaire and a 10 different sample and,the old questionnaire with the student 11 sample, that we could try to trace it down. 12 So what happened is that what we found is that 13 there are some differences between students and residents of 14 ' an EPZ, but that in some respects they are small. In other 15 respects,.they are quite noticeable, as for example in the 16 scope of impact. If you look at Figure 2, the students think 17 that the scope of impact for all three hazards is much larger 18 than the residents believe it to be. On the other hand, if 19 you look at something like the likelihood of release 20 prevention they are incredibly similar. So what happens is 21 that what we want to do is look to see, are students 22 systematically different from residents, to find out if the O ACE FEDERAL REPORTERS, INC. 202 347 3700 Nationwide Coverage 800-334 & 46
30072.0 KSW 108 1 data that we got with the Nuclear Safety article would hold 2 up with a group of-actual residents; and what we found is 3 that '-- what we concluded is that there are no easy 4 conclusions. 5 In some respects they are the same and in some 6 respects different. They are not so terribly different as 7 people might think, saying, this is a student sample and they 8 say students don't have anything in common with local 9 residents. There's some similarity, but it is not -- they-10 are certainly not identical, so it is a difficult, (~] 11 complicated issue in trying to decide how to understand V 12 people's perceptions of risks. 13 If you look at trying to draw a simple conclusion t 14 across hazards, you have the same problem. Tnere are some 15 respects in which the perceptions of nuclear power plant 16 hazard are essentially no different from some of the other -- 17 one or more of the other hazards, and there are some in which 18 there are significant differences, and as researchers always 19 conclude, further research is needed. 20 Q Where would you be if you came to a final 21 conclusion? 22 A I would probably drift off into another area of O V ace-FEDERAL REPORTERS, INC. 202-347-3700 Nationwide Coverage 800-336 4 46
k c30072.0 .KSW 109 t 1 research, where more research was still needed. 2 Q -Finally, do you expect to testify on any sort of 3 training issues concerning the reception centers? 4 A Training whom to do what? 5 Q -Training any employees, let's say monitors. 6 A I had not specifically focused on that, but -- I 7 guess I would have to leave it at that. Anything further 8 means discussing the preparation of testimony. 9 Q Have you focused on the training of any other 10 personnel connected with the reception centers? (~} 11 A I have not in my training testimony specifically v 12 addressed, to date, any personnel specifically or exclusively 13 -- well, not exclusively -- 14 Q Maybe this will clear it up. Training testimony 15 you referred to is that in the OL-5 proceeding? 16 MR. CHRISTMAN: That's the proceeding about the 17 emergency planning exercise. Does that help? 18 THE WITNESS: Is that what I'm doing for Jessine? 19 MR. CHRISTMAN: The exercice litigation is what 20 you are doing for Jessine. 21 BY MR. ZAHNLEUTER: 22 Q Is the testimony you are referring to the n Lj ACE FEDERAL REPORTERS, INC. 202-347 3700 Nationwide Coserage 8(M)-336-M46
.30072.0 KSW 110 ._j 1 . testimony you are doing for Jessine? l 2 A Yes. 3 Q It is in a proceeding other than this one?- 4 A Yes. 5 Q In this proceeding, do you anticipate testifying 6 about training? 7 A We haven't discussed it to date. It may be a good 8 idea. I don't know. 9 MR. CASE: I have no further questions. 10 MR. CilRISTMAN: I have no questions. }/'} 11 (Whereupon, at 1:30 p.m., the deposition was w-12 concluded.) 13 (READING AND SIGNATURE WAIVED.) 15 1 16 l 17 18 j 19 20 21 22 mb i l ace FeuenAi. REPonTens, INC. 202-347-3700 Nationwide Cmerage sxb33MM6
CERTIFICATE OF NOTARY PUBLIC & REPORTER ) 111 1 i ' C}/ r I, KATHIE S. WELLER the officer before whom 1 the foregoing deposition was taken, do hereby certify that the witness whose testimony appears in the foregoing deposition was duly sworn by me; that the testimony of said witness was taken in shorthand and thereaf ter reduced. to typewriting by me or under my direction; that said deposition is a true record i of the testimony given by said witness; that I am l neither counsel
- for, related to, nor employed by any of the parties to the action in which this deposition was taken;
- and, further, that I am not a relative or employee of any attorney or counsel
.O emetoved dv the vareies
- hereto, nor financia11v or otherwise interested in the outcome of this action.
i JN .) U Notary Public in and for the i District of Columbia 1 My Commission Expires NOVEMBER 14, 1989 I l i l l O l
M 1 m PROFESSIONAL QUALIFICATIONS d MICHAEL K. LINDELL Visiting Associate Professor of Psychology GEORGIA INSTITUTE OF TECHNOLOGY My name is Michael K. Lindell and my business address is School of Psycholo-gy, Georgia Institute of Technology, 225 North Avenue, Atlanta, Georgia 30332. Iam presently a Visiting Associate Professor of Psychology at the Georgia Institute of Tech-nology specializing in those areas of study dealing with complex organizations, hazards, and industrial / organizational psychology. I received the Bachelor of Arts degree in Psychology in 1969 from the Uni-versity of Colorado. I was awarded a doctorate of Social Psychology and Quantitative Psychology in 1975 from the University of Colorado, Boulder. I am a member of the () American Statistical Association, the Human Factors Society (Technical Groups on In-dustrial Ergonomics, Organizational Design and Management), the Society for Risk Analysis and the Judgment /Decisionmaking Society. Since receiving my doctorate, I have been engaged in teaching and as a re-search scientist. From 1974 to the present, I have been a Research Scientist at Battelle Memorial Institute, Human Affairs Research Centers. During my tenure at Battelle, I also have held various adjunct teaching positions. In 1981 I was a Visiting Lecturer in Educational Psychology at the University of Washington. From 1981 to the present I have been an Adjunct Assistant Professor of Psychology at the University of Washington. On the undergraduate level, I have taught Introductory Statistics, Psycholog-ical Testing, Industrial / Organizational Psychology and Social Psychology. On the gradu-ate level, I have taught Introduction to Research and Advanced Correlation / Regression b A nalysis. 2 paposITION EXHIBIT iL, eml 3,5 d
3tichael K. Lindell Page 2 V During my employment with the Battelle 5femorial Institute, I have been principal investigator / project director for several projects, related to emergency pre-paredness, evaluation of emergency organizations and the staffing of emergency orga-nizations including: National Institute of 51 ental Health. Consequences of natural hazards for mental health. Energy Research and Development Administration. Public perception and evaluation of risk associated with nuclear waste. Private Corporatica. Analysis of position evaluation system. Nuclear Regulatory Commission. Technical assistance in implementing emergency preparedness requirements. Nuclear Regulatory Commission. Evaluation of licensee emergency response facility designs. e Nuclear Regulatory Commission. Evaluation of emergency exercises at nu-clear power plants. Nuclear Regulatory Commission. Analysis of emergency staffing. Atomic Industrial Forum. Planning concepts and decision criteria for shel-tering and evacuation. National Science Foundation. Behavioral response to technological hazards. Westinghouse Corporation. Human factors assistance for the Hanford Emer-gency Control Center. Private Corporation. Toxic chemical emergency response plan. Department of Energy. Human factors assistance for the DOE headquarters l emergency operations center. Nuclear Regulatory Commission. Evaluation of licensee emergency response facilities. In addition to the projects just listed, I have authored the following books or chapters in books'. I i l 1 l l I
~ a g
- phael K. Lindell gage 3 perry, R. W., Lindell, M. K. and Greene, M. R. Evacuation Planning in Emergency Man-agement. Lexington, MA: Heath Lexington Books,1981.
perry, R. W. and Lindell, M. K. Handbook of Emergency Response Planning. Under con-tract to Hemisphere Publishing (a division of Harper & Row) to be published in late 1987. Stewart, T. R., Joyce, C. R. B. and Lindell, M. K. New analyses application of judgment theory to physicians judgments of drug effects. In K. R. Hammond and C. R. B. Joyce (Eds.) Psychoactive drugs and social judgment: Theory and research New York: Wiley Interscience,1975. Earle, T. C. and Lindell, M. K. Public perception of industrial risks: a free response ap-proach. In R. A. Waller and V. T. Covello (Eds.) Low Probability High Conse-quence Risk Analysis: Issues, Methods and Case Studies. New York: Plenum Press,1984. Perry, R. W. and Lindell, M. K. Communicating threat information for volcano hazards. In L. Walters (Ed.) Comunication in Disaster: Disseminating Bad News, in press. n(, The following is a list of journal articles I have written that relate to the is-sues about which I will testify: Perry, R. W. and Lindell, M. K. Psychological consequences of natural disaster. Mass Emergencies, 1978, 3, 105-115. Lindell, M. K. and Perry, R. W. Evaluation criteria for emergency response plans in ra-diological transportation. Journal of Hazardous Materials, 1980, 3, 335-348. Perry, R. W., Greene, M. R. and Lindell, M. K. Enhancing evacuation warning compli-ance: suggestions for emergency planning. Disasters, 1980, 4, 433-449. Greene, M. R., Perry, R. W. and Lindell, M. K. The March 1980 eruptions of Mt. St. Helens: Citizen perceptions of volcano hazard. Disasters, 1981, 5, 49-66. Drexler, J. A. Jr. and Lindell, M. K. Training / job fit and worker satisf action. Human Relations, 1981, 3_4, 907-915. Perry, R. W., Lindell, M. K. and Greene. M. R. Threat perception and public response to volcano hazard. Journal of Social Psychology, 1982, 1_16. 199-204. I.indell, M. K., Perry, R. W. and Greene. M. R. Individual response to emergency pre-paredness planning near Mt. St. Helens. D!saster Management. 1983, 3, 5-11.
y a 4 F t.s \\ I e, y '+ 's gichael K. Lindell '[3 r l s page 4 N q/ { 's >) t / y-perry, R. W., Lindell, M. K. and Greene, M. R. Crisis communications ethnic differen-tials in interpreting and Iasponding to disaster, warnings. Giocial Behavior , ~ and Personality, 1982, 10, 97-104. / \\ \\i i, \\ Lindell, M. K. and Perry, R. W. Nuclear power plant emergency narning: how would the public respond? Nuclear News, 1983, 26, 49-53. Lindell, M. K. and Earle, T. C. How closeb$loye enough: public perceptions of the risks of industrial facilities. RMk AnalW131933,3,245-253. .x e x gouts, P. S., Lindell, M. K., Hu, T. W., Cleary, P. D., Tokuhata, G. and Flynn, C. B. Thg protective action decision model applied to eyacuation during the Three Milo Island crisis. International Journal of Mass Emer:nncifs and Disaster::, 1984, 2, 27-39.' t i t Lindell, M. K. Review of Warning and R'sponse to the Mt. St. Helens Eruption by e Saarinen and Self. Disasters,1985, g 230-232. ( Lindell, M. K. and Barnes, V. E. Protectiveirecponse to technological emergency, risk perceptien and behavioral intention. Nuclear Safety.'D86, 21, 457-4,67, s s Kartez, J. D. and Lindell, M. K. Planning for ungertainty: the case of local disaster ( ) planning. J_qurnal of the American Planring Associatipg, in p ess. c ( ii I have written approximately forty techt.ical re'por't( for governmental and corporate sponsors. Those which are releva'nt to the issues in this litigation are.' Nealey, S. M., Thornton, G. C., Maynard, W. S., and Lindell, M. K. Defining research needs to insure continued job motivation of air traffic controllers in future air traffic control systems. Battelle Human Affairs Research Centers,1975. l Maynard. W. S., Nealey, S. M., Hebert, J. A., and Lint.ellq '4.X. Public values associated with nuclear waste disposal. BNWL-1997 UC-11, Battelle Pacific Northwest Laboratories,1976. ( Lindell, M. K., Earle, T. C. Hebert, J. A. and Perry, R. W. Radioactive wastes: Public attitudes toward disposal f acilities. B-{MRC-411-004,1978. Schilling, A., Harris, A., Lindell. M., Marcus, A., Perry, R4 and Selvin, M. Emergency response in transportation of radioactive materWls: An evaluation method-ology. BHARC-311-004.1979. Earle, T. C. and Lindell, M. K. The role of the nawsmedia in the pasoline crisis. BH A RC/411-80-002. l I S, l
J g y hael K. Lindell I p. O Undelt, M. K., Rankin, W. R. and Perry, R. W. Warning mechanisms in emergency re-sponse systems. BHARC-411/80/003. pra, M. R., Perry, R. W. and Lindell, M. K. The March 1980 eruptions of Mt. St. Helens: Citizen perceptions of volcano hazard. BHARC-400/80/021. Lindell, M. Ki, Walsh, J. T., Drexler, J. A. Jr. and Lawler, E. E., III. Effects of technol-ogy on experienced job characteristics and job satisf action. BHA RC-422/80/019. L'rbatik, T., Desrosiers, A., Lindell, M. K., and Schuller, C. R. Analysis of techniques for estimating evacuation times for emergency planning zones. SHA RC-401/80-017. N U REG /CR-1745. gotton, P. A., Greene M. R., and Lindell, M. K. Public information programs accompa-s nying emergency plans at nuclear power plants: Issues for consideration. BHARC-400/80/025. Lindell, M. K'., and Earle, T. C. Comparative analysis of risk characteristics of nuclear waste repositories and other disposal facilities. BHARC-411/81/005. s Earlo. T. C., Lindell, M. K., and Rankin, W. L. Risk perception, risk evaluation and { human values: Cognitive bases of the acceptability of a radioactive waste repository. BHARC-411/81/007. Lindell, M. K., Perry, R. W., and Greene, M. R. Public response to evacuation warnings: Imp!! cations of natural hazards evacuations for nuclear emergencies. BHARC-411/81/032. Earle, T. C.,'Southwick, L. L., and Lindell, M. K. Newspaper coverage of Mt. St. Helens: Patterns of content and information sources. BHARC 411/81/035. Desrosiers, A. E., Hickey, E. E., Lewis, J. R. and Lindell, M. K. Criteria for evaluation of emergency response facilities,1981(published as NUREG-0814). Lindell, M. K., Wise, J. A., Desrosiers, A. E., Griffin, B. N. and Meltzler, W. D. Design basis for the NRC Operations Center. BHARC-400/82-005. Lindell, M. K. Analysis of emergency staffing for nuclear power plants. BH A RC-400/83/032. Lindell, M. K., Bolton, P. A., Perry, R. W. Stoetzel, G. A., Martin. J.B., and Flynn, C. B. Planning concepts and decision criteria for sheltering and evacuation in a nuclear power plant emergency. Atomic Industrial Forum / National Environ-mental Studies Project. AIF/NESP-031. If 1 l l l i
i ~ ,1g.Lindell @gij, M. K. Communicating risk information to the public: a review of research on natural hazards. BHARC-400/84/026. Lgett, M. K., Martin, J.B. and Stoetzel, G. A. A protective action decision procedure using radiological relei.se date and of fsite response times. BHA RC-400/85/007. Undell, M. K. Functional analysis for the Hanford ECC. BHARC-400/85/009. unde!!, M. K. Social and political aspects of nuclear power plant emergency planning, i BHARC/400/85/012. Undell, M. K. Analysis of information flow within the Hanford Emergency Control Center. BHARC-400/85/018. perry, R. W. and Lindell, M. K. Twentieth century volcanicity at Mt. St. Helens: Routinization of life near an active volcano. BHARC-400/86/003. undell, M. K. and Barnes, V. E. Comparative perceptions of characteristics of natural and technological hazards. BHARC-400/86/007. { } I have also made presentations at various professonal meetings that relate to I the issues in this litigation. To the extent that these presentations did not become the subject of journal articles or technical reports, they are listed below. Lindell, M. K.,1876.. Assessment of social values in nuclear waste disposal. Western Psychological Associatiori. Lindell, M. K. and Maynard, W. S.,1976. Interchange of technical information and pub-lic beliefs in energy decisionmaking. Western Psychological Association. Perry, R. W. and Lindell, M. K.,1979. Predisaster planning to promote compliance with evacuation warnings. National Conference on Hurricanes and Coastal I Storms. Lindell, M. K., Perry, R. W. and Greene, M. R.,1980. Race and disaster warning re-l 9 sponse. Pacific Sociological Association. 1, Lindell, M. K., Perry, R. W. and Greene. M. R. 1980. Consistency of attitudes and be-havior related to nuclear power. Western Psychological Association. Greene, M. R., Perry. R. W. and Lindell, M. K.,1981. Qtizen perception of public ac-tions. Western Political Science Association. O t
S phael K. Lindell pge7 V LIUdell,51. K., Perry, R. W. and Greene, M. R.,1981, Individual response to emergency preparedness planning. Western Social Science Association. LIndett, M. K., Perry, R. W. and Greene, M. R.,1981. Social and psychological f actors affecting evacuation decisionmaking. American Psychological Association. l>erry, R. W., Greene, M. R. and Lindell, M. K.,1981. Evacuation behavior during the May 18th eruption of Mt. St. Helens. Pacific Sociological Association. golton, P. A., Perry, R. W., Lindell, M. K. and Greene, M. R.,1981. Hazard experience and warning response of older persons. Gerontological Society of America. Lindell, M. K.,1982. Judgmenf. values and the management of conflict over nuclear waste. First International Conference on SocialImpact Assessment. Lindell, M. K.,1982. Development of a design for the Nuclear Regulatory Commission's emergency operations center. Human Factors Society. Lindell, M. K. and Southwick, L. L.,1982. An analysis of information integration using free response data. American Psychological Association. Southwick, L. L., Lindell, M. K. and Earle, T. C.,1982. Attitude polarization in public (Oj issues the roles of cognitive complexity evaluative consistency and issue im-portance. Washington State Psychological Association. Hanswick, C. Archea, J., Hanson, H., Keating, J., Lindell, M. K. and Wise, J. A.,1983. Designing for personal control in hazards and disasters. Environmental De-sign Research Association. Lindell, M. K.,1983. Analysis of emergency staffing for nuclear power plants. Human Factors Society. Lindell, M. K., Moeller, P. A. and Renner, M. S.,1984. Offsite response consideration for appropriate protective actions. American Nuclear Society. Lindell, M. K. and Perry, R. W.,1984. Social psychological processes and personal risk assessment. Society for Risk Analysis. Lindell, M. K.,1984. Communicating risk information to the public: a review of re-search on natural hazards. NSF/ EPA Workshop on Risk Communication. Lindell, M. K.,1985. Decision criteria for sheltering or evacuating medical f acilities in radiological and hazardous materials incidents. Association for the advance-ment of MedicalInstrumentation. o
~ gichael K. Lindell 0 gate 0 The following is a list of Scientific Journal ad hoc reviews I have been in-g;yed with: Academy of Management Review, Risk Analysis, Disasters, and Interna-tional Journal of Mass Emergencies and Disasters. I have served as a member of the following Scientific Peer Review Panels: National Science Foundation, Community Water Management Program National Science Foundation, Applied Science and Research Applications Directorate National Science Foundation, Earthquake Hazards Mitigation Program National Science Foundation, Decision and Management Science Program Brookhaven National Laboratory, Department of Nuclear Energy University of Washington, Department of Family Medicine Pennsylvania State University College of Medicine, Department of Behavioral Science { l University of Pittsburgh, University Center for Social and Urban Research University of Southern California, Institute of Safety and Systems Management National Science Foundation, Geography and Regional Science Program Argonne National Laboratory, EES Division I have given expert testimony for the Public Forum on the Operation of the Shoreham Nuclear Power Plant sponsored by Scientists and Engineers for Secure Energy and the Public Hearing on the Operation of the Pilgrim Nuclear Power Plant sponsored by the Plymouth Board of Selectmen and the Boston Edison Company. In addition, I have served on a professional committee for the American Na-tional Standards Institute /American Nuclear Society Standards Committee Criteria for establishing emergency response facilities and am currently Conference Chair of the American Society of Civil Engineers Specialty Conference on Planning for Hazardous facilities. l I
,gichael K. Lindell page9 Not only have I taught university students, but I have taught professionals in i the field of emergency preparedness. The following is a list of short courses I have l taught and lectures I have given. Lindell,51.K.,1983. Perception of risk at nuclear waste disposal sites and power plants. Lecture for Pacific Lutheran University Center for the Study of Public Poli-cy. Lindell,51.K.,1983. Emergency preparedness at nuclear power plants. Lecture to Uni-versity of Washington Department of Environmental Health and Nuclear En-gineering. Lindell, 31.K.,1983. Design of emergency response f acilities. Pacific Northwest Labo-ratory Short Course in Emergency Planning. Lindell, 31.K.,1983. Emergency public information. Pacific Northwest Laboratory Short Course in Emergency Planning, Lindell, 31.K.,198 4. Emergency staffing. Pacific Northwest Laboratory Short Course qg in Emergency Planning. Lindell, St.K.,1984. Emergency public information. Pacific Northwest Laboratory Short Course in Emergency Planning. Lindell, 31.K.,1985. Protective action decisionmaking. Pacific Northwest Laboratory Short Course in Emergency Planning. Lindell, 51.K., 1985. Emergency public information. Pacific Northwest Laboratory Short Course in Emergency Planning. Lindell, 51.K., 1985. Social and political aspects of nuclear power plant emergency planning. Health Physics Society Short Course on Emergency Planning. Lindell, bl.K.,1985. Social response to the Nit. St. Helens eruptions. University of Washington Short Course on alt. St. Helens. Lindell, SI.K., 1985. Emergency management: planning principles for large-scale emergencies involving technological and natural hazards in developed and developing nations. Administrative Staff College of India Workshop in Risk l Analysis in Developing Countries. l Lindell,31.K.,1986. Concerns about offsite response in a nuclear power plant emergen-c_v. GPU Nuclear Annual Training Workshop for T311 Area Emergency Re-sponse Agencies. l l l l
i 4 NATURAL AND TECHNOLOGICAL HAZARDS QUESTIONNAIRE ~ I Very Very How likely is it that, during the next 5 years, there Unlikely Likely ( 1 2 3 4 5 s (1:01) could be a saint. (1:02) vokanic eruption of Mount St. Helens? 1 2 3 4 5 chlorine tank car derailment within Cowlitz county? (1:03) 1 2 3 4 5 reactor accident at the Trojan nuclear power plant? Very Very If a major event did occur, how likely would it be that an Unlikely Likely envuonmentai release could be prevented of (1:04) 1 2 3 4 5 (1:05) vokanie materids erupted from Mt. St. Helens? 1 2 3 4 5 (1:06) chlorine gas released from a raihood tank car? I 2 3 4 5 radioactive materials released from the Trojan plant? Less 1/4 1/2 1 More than to to to than How many houn do you think it would be until 1/4 1/2 1 4 4 there was a significant increase in the risk to personal safety in your neighborhood after the start of a. (1:07) 1 2 3 4 5 (1:08) volcanic eruption of Mt. St. Helens? 1 2 3 4 5 (1:09) release of chlorine gas from a ralhoed tank car? 1 2 3 4 5 release of radioactive matenals from the Trojan plant? Not Very To what extent could you use environmental cues such as at great sights, sounds or smells to determine for yourself when all extent (1:10) to take protective action following a. 1 2 3 4 5 (I:II) volcanic eruption of Mt.St.Helens? 1 2 3 4 5 (1:12) release of chlorine gas from a ralhoad tank car? 1 2 3 4 5 release of radioactive matenals from the Trojan plant? If you were out of doors when a selease reached your home, you would be unprotected. How likely is it that immediate con-Very Very sequences such as death within one month would result from Unlikely Likely (1 I3) an unprotected exposure 80. 1 2 3 4 5 (I:I4) volcanic materials erupted from ML St. Helens? 1 2 3 4 5 (1:15) chlorine gas released from a raihund tank car? 1 2 3 4 5 radioactive matenals released from the Trojan plant? Very Very How likely is it that delayed consequences such as cancer Unlikely Likely (1:16) would result from an unprotected exposure to... 1 2 3 4 5 volcanic materials erupted from Mt. St. Helens? 1 2 3 4 5 (I:I7) I 2 3 4 5 (I:18) chlorine gas released from a raihoad tank car? radioactive materials released from the Trojan plant? Very Very How likely is it that genetic effects such as birth defects Unlikely Likely 1 2 3 4 5 (I:19) would result from an unprotected exposure to. volcanie materials erupted from Mt. St.Helens? 1 2 3 4' 5 (1:20) chlorine gas released from a railroad tank car? I 2 3 4 5 (1:21) radioactive materials released from the Trojan plant? Very Very How likely is it that total loss of your property would Unlikely Likely result from. I 2 3 4 5 (1:22) p vokanie materials crupted from Mt. St. Helens? 1 2 3 4 5 (1:23) V chlorine gas released from a raihond tank car? 1 2 3 4 5 (1:24) radioactive matenals released from the Trojan plant? 2 DEPOSITION EXHISETg v g imoac &
s Very Very Hsw likely is it that by stayir.g to ;=*ct your property, you Unlikely I.ikely $would be able to significantly reduce any losses resulting from 1 2 3 4 5 (1:25) i-volcanic materials erupted hem Mt. St. Helens? 1 2 3 4 5 (1:26). chlonne gas released from a radioed tank car 7 1 2 3 4 5 (1:27), + radioactive materials released hem the Troja plant? \\ In an energency, the county shenffs office might advise everyone in you neighborhood to " shelter" by remammg indoors, shutting Full No all doors and windows. Compared to standing outside unprotected Exposure Exposure (100% exposure), how much exposure would you get by staying inside your home with all doors and windows shut in a. 100 % 75 % 50 % 25% 0 (1:28-30) volcanic eruption of Mt.St.Helens? 100 % 75 % 50 % 25 % 0 (1:31 33) release of chlonne gas from a railroad tank car? 100 % 75 % 50 % 25 % 0 (1:34-36) release of radioactive matenals fmm the Trojan plant? Very Very How likely is it that you would evacuate rather than Unlikely Likely shelter in your home, as requested, durmg a. 1 2 3 4 5 (1:37) volcanic eruptionof Mt.St.Helens? 1-2 3 4 5 (1:38) I release of chlonne gas fmm a redroad tank car? 1 2 3 4 5 (1:39) release of radioactive materials from the Trojan plant? Vay Very If an evacuation was ordered while you were away from Unlikely Likely home, how likely is it that you would try to return home to. 1 2 3 4 5 (1:40) help others who could not evacuate? 1 2 3 4 5 (1:41) conect important personal possessions and papers? 1 2 3 4 5 (1 42) protect your property? i l O Iess 10 20 30 40 i than to to to or 10 20 30 40 more How many inilca would you have to evacuate to reach a safelocation if there were a 1 2 3 4 5 (1:43) volcanic eruptionof Mt.St.Helens? 1 2 3 4 5 (1:44) release of chlorme gas from a radroad tank car? 1 2 3 4 5 (1:45) release of radioactive matenals from the Trojan plant 7 i How likely is it that you would encounter problems such Very Very as traffic jams or flooded roads that would preverg you from Unlikely Likely reaching safety during a. 1 2 3 4 5 (1:46) volcanic eruption of Mt.Sc.Helens? 1 2 3 4 5 (1:47) release of chlonne gas from a railroad tank car? 1 2 3 4 5 (1:48) release of radioactive materials fmm the Trojan plant? 14ss 1/2 1 2 3 l l-than to to to or 1/2 1 2 3.more f How many bolus would it take for you to evacuate to a safe l } location during a.. 1 2 3 4 5 (1:49) volcanic eruptionof Mt.St.Helens? 1 2 3 4 5 (1:30) release of chlorine gas imm a railroad tank car? 1 2 3 4 5 (1:51) release of radioactive materials fmm the Trojan plant? O
Very Very How likely is it that looters would steal your property Unlikely Likely while you was evacualed from a (1:52) 1 2 3 4 5 (1:53) vokanic eruption of Mt.St.Helens? 1 2 3 4 5 - (1:54) w nicane of chlorme gas fmm a railroad tank car? I 2 3-4 5 release of radioactive matanals hem the Trojan plant? More. One One Gne One than How long would it be until you could return home safely Day Week MonthYear ayear (1:55) after evacuating because of a 1 2 3 4 5 (1:56) voksnic eruption of Mt.St.Helens? 1 2 3 4 5 release of chlorme gas from a radroad tank car? (1:57) 1 2 3 4 5 release of radioactive materials from the Trojan plant? Less 100 250 500 More than to to to than 100 250 500 1000 1000 What would be the total slalla cost to you and your family of an evacuation in response to a 1 2 3 4 5 (1:58) volcanic eruption of Mt.St. Helens? I 2 3 4 5 (1:59) release of chlorine gas from a radroad tank car? 1 2 3 4 5 (1:60) release of radioactive materials from the Trojan plant? Would you or anyone in your household need special assist-- No Yes . ance in evacuating due to. 1 2-(1:61) lack of transportation during allor part of the day? 1 2 (1:62) hmed mobility, such a confinement to a wheekhair? 1 2 (1:63) special medical needs, such as oxygen? se ves O Have reu made anx ef the feiiewin evacuatien ore,aracens. 1 2 (1:64) keep clothing and blankets packed in case you had to evacuate? 1 2 (1:65) keep an emergency supply of gasoline? 1 2 (1:66) know two different routes to evacuate your area? selected a place to meet your family if evacuation is 1 2 (1:67) necessary during working or school time? I 2 (1:68) made arrangements for a place to stay while away from home? Daily Monthly Never Weekly Yearly How often do you find yourself thinkmg about a 1 2 3 4 5 (1:69) volcanic eruption of Mount St. Helens? I 2 3 4 5 (1:70) chlorme tank car derailment within Cowlitz county? 1 2 3 4 5 (1:71) nuclear reactor accident at the Trojan nuclear power plant? How often do you discuss with your family and friends Daily Monthly Never Weekly Yearly any concerns about a 1 2 3 4 5 (1:72) vokanic eruption of Mount St. Helens? I 2 3 4 5 (1:73) chlorine tank car derailment within Cowlitz county? 1 2 3 4 5 (1:74) nuclear reactor accident at the Trojan nuclear power plant? t is each of these a risk that you can live with and can think Calm Dread 'about reasonably calmly, or it is one that causes great dread? 1 2 3 4 5 (1:75) volcanic eruption of Mount St. Helens? 1 2 3 4 5 (1:76) chlorine tank car derailment within Cowlitz county? 1 2 3 4 5 (1:77) nuclear reactor accident at the Trojan nuclear power plant? O (1:78-80) '+*-wt m_, 4,.--* ---,y,a m--,___y--,,, w-i- e --- -, - - -, - - - - - - - ---.--._.,%,y-g. w -w,-,--g, rw--v.y-wv-yw--- eg----mi-wy-v-g-yy-y y-
How easy do you think it would be for government agencies or private corporations to reduce the risks to Very Very safety and property of a Difficult Easy ( (2:01) volcanic eruption of Mount St. Helena? 1 2 3 4 5 s chlorine tank car derahnent within Cowlitz county? 1 2 3 4 5 (2:02) nuclear reactor accident at the Trojan nuclear power plant? 1 2 3 4 5 (2:03) Not Very To what extent do you think that your personal safety at great in an emergency would be determmed by the actions of. all extent yourself and yourimmediate family? 1 2 3 4 5 (2:04) friends, relatives and14ighbors? 1 2 3 4 5 (2:05) local newsmedia? 1 2 3 4 5 (2:06) = local government agencies? 1 2 3 4 5 (2:07) state or federal government agencies? 1 2 3 4 5 (2:08) luckorchance? - 1 2 3 4 5 (2:09) God's will? 1 2 3 4 5 (2:10) To what extent do you think each of the following has sufficient knowledge about the nature of the hazard and Not Very appropnate protective actions for a volcanic eruption of at great Mount St.Helens? all extent yourself andyourimmadiate family? 1 2 3 4 5 (2:11) friends, relatives and neighbors? 1 2 3 4 5 (2:12) local newsmedia? 1 2 3 4 5 (2:13) local government agencies? 1 2 3 4 5 (2:14) state and federal government agencies? 1 2 3 4 5 (2:15) To what extent do you think each of the following has ~ sufficient knowledge about the nature of the hazard and Not Very appropriate protective acnons for a chlonne tank car at great dera1 ment within Cowlitz county? all extent yourself and yourimmediate family? 1 2 3 4 5 (2:16) friends, relatives and neighbors? 1 2 3 4 5 (2:17) localnewsmedia? 1 2 3 4 5 (2:18) localgovemment agencies? 1 2 3 4 5 (2:19) state and federal government agencies? 1 2 3 4 5 (2:20) i To what extent do you think each of the following has sufficient knowledge about the namre of the hazard and Not Very appropriate protective actions for a nuclear reactor at great accident at the Trojan nuclear power plant? all extent yourself and yourimmediate family? 1 2 3 4 5 (2:21) friends, relatives and neighbors? 1 2 3 4 5 (2:22) locai newsmedia? I 2 3 4 5 (2:23) 1 2 3 4 5 (2:24) local sovemment agencies? state and federal government agencies? 1 2 3 4 5 (2:25)
9 What would be the nest important factors you would q consider in deciding what protective actions to take dunns a y< volcanic eruption of Mt.St.Helens? release of chlorine gas fmm a railroad tank car? g (2:28-29) release of radioactive materials from the Trojan plant? (2:30-31) Male Female Q:32) Whatis your sex? 1 2 (2:33-34) What yearwere you born? 19_ _ (2:35-36) How many years have you lived in Cowlitz County? Are there children living in your household that are. No Yes (2:37) under the age of 67 1 2 (2:38) between 6 and 167. 1 2 Have you attended any community meetings that involveddiscussionsof a. No Yes (2:39) volcanic eruption of Mount St. Helens? 1 2 chlorine tank car deralment within Cowlitz county? I. 2 ) N;dII nuclear reactor accident at the Trojan nuclear power plant? 1 2 Have you contacted officials of any govemment O agenciesforinformationabouta No Yes (2:42) volcanic eruption of Mount St. Helens? 1 2 (2:43) chlonne tank car derailment within Cowlitz county? 1 2 N#3 nuclear reactor accident at the Trojan nuclear power plant? I 2 Have you been a member of a community organization that has taken an official position supporting action regarding the risks of a. No Yes (2:45) volcanic eruption of Mount St. Helens? 1 2 (2:46) chlorme tank car deralment within Cowlitz county? 1 2 (2:47) nuclear reactor accident at the Trojan nuclear power plant? 1 2 Have you written a letter to a newspaper or a govern-mental official supportmg action regarding the risks of s No Yes volcanic eruption of Mount St. Helens? 1 2 (2:48) (2 49) chlorine tank car deralment within Cowlitz county? 1 2 nuclear reactor accident at the Trojan nuclear power plant? 1 2 G:50) Do yot have any additionalcomments? (2:51-53) O ,,..,.---ena-.,-
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