ML20206C923
| ML20206C923 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 02/03/1987 |
| From: | Baranski J, Czech L, Papile J LONG ISLAND LIGHTING CO. |
| To: | |
| References | |
| CON-#287-3045 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8704130193 | |
| Download: ML20206C923 (234) | |
Text
-
soc /S mew ORIGINAL
- h TRANSCRIF1 _USNhC i U l OF PRDCEEDINGEAPR-8 A9:54 UNITED STATES OF AMERICA OCMET i G YEP /lbf NUCLEAR REGULATORY COMMISSION BRANCH Before the Atomic Safety and Licensing Board
____________________+
In the Matter of: : _
- Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY : (EP Exercise)
(Shoreham Nuclear Power Station, : (ASLBP No. 86-533-01-OL)
Unit 1) :
-___________________+
Deposition of:
JAMES C. BARANSKI '
JAMES D. PAPILE O* LAWRENCE B. CZECH Albany, New York f
Feb,ruary 3, 1987 ACE-FEDERAL REPORTERS, INC.
Stenotype Reporters 444 North Ca i O wesaiestee. 6.tolStreet C. 20001 (202) 347-3700 Nationwide Coverage g D9, 800-336-6646 8704130193 870203 PDR ADOCK 05000322 PDR
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D position of JAMES CONRAD BARANSKI, JAMES DOMINIC PAPILE and LAWRENCE BRUNO. CZECH, Albany NY, 3 February 1987. LILCO, NRC ASLB 50-322-OL-5.
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4 651 01.01 1 marysimons 1 UNITED STATES OF AMERICA 2 NUCLEAR REGULATORY COMMISSION' ,
3- BEFORE THE ~ ATOMIC SAFETY AND-LICENSING BOARD
, 4 ___-___--__----x .
5- In the Matter of: :
6 LONG ISLAND LIGHTING COMPANY : Docket No. 50-322-OL-5 7 (Shoreham Nuclear Power : (EP Exercise) ,
8 Station, Unit 1) :-
9 ---------------X i
10 Albany, New York
. O 11 Tuesday, February 3, 1986 i
12 Deposition of 13 A PANEL OF WITNESSES CONSISTING OF:
b p( '
14 JAMES CO AD BARANSKI Li V*
- Q.
15 JAMES DO IC'PAPILE (
16 and
.-d-17 LAWRENCE BRUNO CZECH fg f
l 18 the deponents, called for examination by counsel for-LILCO ,
19 in Conference-Room 131, State' Capitol Building, Albany,'New 20 York 12224, beginning 'at 9:10 o' clock a.m., before, by 21 stipulation of. counsel, before Mary C. Simons, a Notary 1
22 Public in and for.the District of Columbia, when were 23 .
ACE-FEDERAL 202-347-3700 REPORTERS /INC.
Nationwide Coverage 800 336- % 86
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msrysimons 1 present on behalf"of=the. respective-parties:
2 .On Behalf ofLLong Island: Lighting Company 1
3 DONALD P. IRWIN, ESO. I i ,
j 4 KAREN L. DONEGAN, ESO.
S Hunton &~ Williams i.
6 707 East Main Street s 7 P. O. Box 1536 i ,
i- 8 Richmond, Virginia 23212 r
! 9 On Behalf of Suffolk County:
I, 10 LAWRENCE COE LANPHER,ESO.-
() 11 Kirkpatrick & Lockhart-I, -
! 12 South Lobby, 9th Floor
- 13 1800'M Street, N.W. :
i 14 Washington, D.C. 20036-5891) i 15 On Behalf of the State of New York:
i
- . 16 RICHARD J. ZAHNLEUTER, ESO.
i 17 Special Counsel to the Governor-1 . .
18 Executive Chamber 19 Room 229 20 State Capitol
-i 21 Albany, New York 12224
( }-
22 . ;
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C)000 01 01 3 marysimons 1 C O N T E NLT S-2 . WITNESS PANEL EXAMINATION BY PAGE
- 3. < James C. Baranski 4 James D. Papile~ ,
5 -and-6 Lawrence B. Czech: By Mr. Irwin 5,220 7 By Mr. Lanpher -197 8 By Mr. Zahnleuter 219 9 EXHIBITS -
10 PANEL DEPOSITION EXHIBITS MARKED AND SUBMITTED 11 Exhibit No. I 12 12 Exhibit No. 2 52-53 13 Exhibit'No. 3 71-14 Exhibit No. 4 79 15 Exhibit No. 5 3136 16 Exhibit No. 6 155 17 Exhibit No. 7 179 18 Exhibit No. 8 182 19 Exhibit No. 9 185-20 .
21 Cl) l
- 22 i
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- D V 000 01 0'1 4 marysimons 1 PRO'CEEDINGS 2 Whereupon, 3' JAMES CONRAD BARANSKI 4' JAMES DOMINIC PAPILE 5 'and 6 LAWRENCE B. CZECH.
7 were called as a panel of witnesses on behalf of LILCO and, 8 having been first duly sworn.by the Notary Public, were 9 examined and testified as follows:
10 M R .' -IRWIN: Gentlemen, my name is Donald Irwin.
O 11 I represent Long Island Lighting Company and I will be-doing 12' the questioning of you today.' -
13 If I fail to address a question to any individual i
I 14 on this panel, you may assume that that is directed to the 15 panel as a whole and can be answered with whomever has
, 16 knowledge and.is interested in answering it.
17 If I ask a question of~an individual' witness, I 18 would ask that witness to answer first, and thenlif anybody.
19 else on the panel hac information--toL contribute af ter :that, 20 you may do so.
21 Finally, if I ask a question,.I will assume you
-{
. 22- understand it unless you say I don't understand the. question ACE-FEDERAL REPORTERS, INC.
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f3 L OOO 01 01- 5 marysimons 1. or words'to that'effect.- ,
[ 2 Are you all clear? -
, 3 (Witnesses nodd'ing in the affirmative.)
'4 I have just one'other.' background no'te. -Everybody- -
5 except you-guys.has got planes to catch'home. . (I very much ;
6 like..to catch mine, and so I'll try not to waste anybody's 7 time. !
8 EXAMINATION .
9 BY MR. IRWIN:
10 0 -General Papile, let-me find out a lititle bit
- O j 11 about your background. Will you state your' current
- 12 position, sir?
13 A (Witness Papile) I am the Director-of the
~
i 14 Radiological Emergency Preparedness Group.
F 15 O How long have you been in that position?
l 16 A A little over a year.
17 0 What was your position before that?
18 A~ I was the: Associate Planner for the group-and 19 Associate Planner in'the' group.
20 0 And Associate Planner in the' group?
- - 21 A Yes.
22 O One of how many?
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, 000 101LO1. 6 marysimons'1- A- One of three.: -
l 22 O How long have you been involved in.the-- +
[. .3_ Radiolog'ical Emergency.PreparednessiGroup?-
4 ~A I have been on the payroll'since 1980.1
~
- 5 0 And what was your position =from
- -- :
17
- . 6 A' I was Associate Planner from April--1980'until:-I-
. ,7 : assumed my current posit $1on.
i .
8 0 ,
As an' Associate PlannerLwhat were your areas of.
9 responcibility?
10 A My specific areas o'f : responsibility were Oswego yo 11 County, Monroe County and Westchestor CountyiandJthen i 12 ' assistance to the State plan.- That is the. portion of the.
I
! 13 State plan that concerned.the State.itself..
i l- '14 O And for what plant or plants.does Oswego County
., 15 relate?
i j 16. A To'Nine Mile 1 and Fitz.-
17 0 How about Monroe County?
i-18 A Monroe CountyLto Ginna and Wayne County =is also l
2 19 to Ginna, but another man ha'd _ Wayne County.
20 0 Right. And Westchester County relates to which 21 plant?
4 22 A Westchester? Indian Point 2'and.3.
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Emsrysimons 1 0~ Did you..have a'ny-particular. subject matter 2' jurisdiction',' sir?~
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3 A -No, no-particular' subject matter.-
'4. O Was your role with respect ~to planning'in=those
- 5. counties then one of general jurisdiction,Jin Lother- words,,
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6 one covering all issues, or what were your areas of~
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7: . responsibility?
8 'A All issues pertaining to that county.
. 9 MR. ZAHNLEUTER: Jim,-let him-finish his:
4 10 question, first. -
! 11 BY MR. IRWIN:-
i
- 12 0' Mr. Baranski, what is your current job title,;
b
{ 13 sir?
14 A (Witness Baranski) My job ~ title.isiNuclearl 15 Facility Specialist, and I~am currentlyLthe Exercise-16 Director.
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17 0 How long have you held this'particular: job title? I!
18 A Which one,. sir?
19 0 Nuclear Facility-Specialist. ,
. .l
)
20 A Since 1981. I 21 0 How long have you-been Exercise Director?
i 1 1 22 A Since January.1985. i
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marysimons 1 O What does the job of Exercise-Director involve?
2 .A I am primarily responsible for the offsite 3 conduct of the exercise.
4 0 Before January.1985 did your job include any-5 responsibility for offsite' exercises?
6 A Yes, sir, it did.
j 7- 0 What was-that area of responsibility?
8 A I was the REPG technical liaison to the EOF's.
9 0 You were the REPG offsite representative to the 10 EOF's?
11 A Right.
12 O When did you assume that position?
13 A In 1981 when I came onboard with REPG.
14 0 In your capacity as Nuclear Facility-Specialist 15 could you describe your responsibilities?
16 A During drills, exercises or'real events I was.
17 dispatched to the EOF to be a liaison with the State to 18 provide additional technical information or explanations as 19 needed.
20 0 So you are a technical resource to 21 representatives of other areas of the State government 22 during a radiological event; is that an accurate summary of ACE-FEDERAL REPORTERS; INC.
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(_);000 01 01 9 marysimons'1 what you do?
2 A Okay. Let me explain that further. I was in 3 contact with the State _ Dose Assessment Group providing 4 information1as needed:to that' group.
5 0 Now th'is is for offsite monitoring, or when you 6 say you provide information to the. Dose Assessment Group, 7 what does that involve?
8 A This is accident analysis and interpretation type 9 of information.
10 0 would this involve projections of dose i
() 11 assessments?
12 A My job did not include projection of dose 13 assessments.
~
14 0 What did your job involve with respect'to the 15 Dose Assessment Group?
16 A Providing reactor plant status so that the Dose 17 Assessment Group could factor that into their decision-18_ making process.
19 0 What exercises have you been responsible for the
- 20. planning of?-
21 A All federally evaluated exercises since January
)
22 of 1985.
I i
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- (J00001-01 11 marysimons 1 the radiological emergency preparedness plan. 'The State 4
2 portion has all the parts that pertain to all of our State 3' . agencies.
4 In addition, I have the responsibility as-the 5 liaison or planner with our group who works with Orange f
6 County to ensure that the county procedures and. plans are 7 prepared and maintained up to date.
8 O- Do you have any responsibilities with respect to 9 exercise preparation-or conduct?.
10 A I do not presently have' any responsibility for O_
11 exercise preparation. The only exercise would be exercise 12 participation as a participant.
~
33 0 How long have you held your current position, 14 sir?
15 A I've been in the group since its' inception in -
16 1980, and I believe that I actually took this title on in.
17 January of '81.
18 MR. IRWIN:. Let me give you a document entitled 19 "The State of New York's Response to LILCO's First Set of 20 Interrogatories and Request For Production of Documents To 21 New York State," dated January 20, 1987.
}
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22 I would ask the reporter to mark it as Exhibit 1.
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U 000 01 01 10 marysimons 1 0 So that would include, as I understand it, an 2 exercise at Ginna in September of~1985, correct?
3 A That's-affirmative.
-4 0 An exercise a't. Indian Point 3 in April of '857 5 A That's affirmative.
6 0 An exercise at Nine Mile' Point in November of-7 19857 8 A That's correct.
I- 9 0 An exercise at Indian Point 2 in June of '867 10 A That's affirmative.
U 11 0 Any others?
12 A (Witness Papile) What's the question?.
13 0 Whether there were any other exercises since Mr.
14 Baranski became the head of exercise planning that he would 15 have been responsible for.
16 A (Witness Baranski) That's_a-correct list.
17 0 Mr. Czech, what is your current position, sir?
18 A (Witness Czech) I am Chief of Nuclear Protection J
19 Planning with the Radiological Emergency Preparedness Group.
20 0 What does that job involve,. sir?-
21 A I am responsible for the preparation and
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22 maintenance revision and oversight of the State portion of ACE-FEDERAL REPORTERS, INC.
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marysimons 1 (The document referred to was 2 marked Deposition ' Exhibit 1 for 3 identification and I submitted 4 for the record.)
-5 BY MR.-IRWIN:
6 0 General Papile, were you responsible for the 7 preparation of this-document?
8 A (Witness Papile) Yes, I was, not for the 9 document itself, but the information in the document.
10 0 In other words, you are substantively aware of 11 the-content of.all the answers?
12 A Yes.
13 0 Mr. Baranski, did you work at all on the
.14 preparation of this document or on the compilation of 15 information for it?
16 A (Witness Baranski) Yes, I did.
.17 0 Mr. Czech, did you, sir?
18 A (Witness Czech) No, I did not.
19 0 Would each of you, including Mr. Czech, look at 20 the answer to Interrogatory 1 at the bottom of page 2 and 21 the top of page 3, specifically the paragraph beginning with
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22 the words "The State of New York answers portions.1 and 2 of' ACE-FEDERAL REPORTERS, INC..
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'(V 000.01 01 13 merysimons 1 ' Interrogatory 1 as follows."
2 M R .' LANPHER: Excuse me, Mr. Irwin, is there 3 something that the witnesses are supposed to be looking for-4 'or do you just-want them to refresh their memory?
5 MR. IRWIN: I just want them to refresh'their 6 recollection.
7 BY MR. IRWIN:
8 0 I am about to ask General Papile, since he 9- compiled the information for this document, whether the list 10 of exercises in this paragraph is, to your knowledge, a
)
11 complete list of the federally evaluated radiological' 12 emergency planning exercises conducted In New York State 13 since 1982?
14 MR. ZAHNLEUTER: I would like to mention that 15 that question as you posed it, Mr. Irwin, wasn't exactly the 16 question that is posed in the interrogatory.
17 MR. IRWIN: Well, the witnesses can answer the 18 question as they understand it. I am not trying to inject 19 any confusion.
20 MR. LANPHER: Don, excuse me, the question is, ,
1 21 I'm trying to write it down, is a complete list of the
} 1 22 federally evaluated exercises in New York State since 19827 l l
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- 000 Ol'01 14 marysimons 1 MR. IRWIN
- In which New York State 2 participated. Does that clear up the confusion.-
3 WITNESS PAPILE: I want thefquestion again, 4 please.
5 MR._IRWIN: Let me.-try the question in a 6 different fashion.
7 BY MR. IRWIN:
8 0 What does this list purport to you to represent?
9 A (Witness Papile) Five years.-
10 0 Five years of what?
.O v 11 A Of exercises for the last five years.
12 0 What kinds of exercises?
13 A In some way where-FEMA was involved in the 14 evaluation.
15 0 And the State was participating?
16 A Yes, sir.
17 0 And this is a complete list as far as you know?
18 A To the best of my knowledge, yes.
19 0 Mr. Czech, is this a complete list as far as you 20 know?
21 A (Witness Czech) Of federally evaluated,-yes.
22 0 Mr. Baranski, is it complete as far as you know?
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7-V 000 01 01 '15 marysimons-1 A (Witness Baranski) For the previous five years 2 from the date of this document.this is a complete list of
- 3 exercises.
4 0 General Papile, did you participate in' the 5 preparation of the objectives for, and'let's take these 6 exercises one by one. Did you participate in the 7 preparation of objectives for the January 21, 1982 Ginna 8 exercise?
9 A (Witness Papile) I did not.
10 0 Did you participate in the preparation of this 11 scenario for that exercise?
12 A I did not.
13 0 Did you particip$E in any pre-exercise 14 negotiations with FEMA concerning exercise: objectives or 15 scenario?
16 A To the best of my knowledge, I did not.
17 0 Were you a participa$ in that exercise?
f.
18 A Yes, I was.
19 0 Did you participate in any post-exercise 20 -evaluation process, either in negotiations _with FEMA:or 21 ' discussions with FEMA concerning the exercise?
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22 A I don't understand your question.
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V 000 01 01 16' merysimons 1 0 Did you-have any interaction with FEMA concerning 2 their evaluation of the exercise after it was conducted, to 3 your recollection?
4 A I sat at the meeting.
5 0 Which meeting?-
6 A The meeting which FEMA held after the exercise.
7 0 This is the public post-exercise meeting?
8 A No. I sat at the meeting that FEMA had-with-the 9 evaluators after the exercise.
10 0 When you participated in the exercise, what was 11 your role, sir?
12 A When I was the County Planning Liaison, my role 13 would be as State Liaison to the. Count'y.
14 0 In the Ginna exercise in June of '83, again did 15 you participate in the preparation of objectives there?
16 A The same answer for June '83.
17 0 In other words, you were a participm&e as State d #t
/u~
18 Liaison to the County and you were present at the post-19 exercise briefing or meeting with FEMA but no other 20 involvement?
21 A Yes.
22 O Would your answer be the same for the September ACE-FEDERALiREPORTERS, INC.
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lOh00001--01 ~17 marysimons 1- 1985? exercise for the Ginna plant?
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- 2. A. Yes.
3 0- In other words,.no scenario or objectives 1 -4 ' involved?
5 A No.
6 0 Referring to the Indian' Point 3 exercises, did.
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7 . you participate in the preparation of objectives for 1 that !
8 exercise?
9 MR. LANPHER:- Excuse'me,'which one?
10 MR. IRWIN: I'm sorry, March 3rd, '82.
11 WITNESS PAPILE: No, I did not.
4 12 BY MR. IRWIN:-
j 13 0 Did you participate in the development of the 14 scenario for that exercise?
15 A (Witness'Papile) No, I did n'ot.
16 0 Did you participate:in~ pre-exercise negotiations 17 with FEMA concerning'the objectives?:
18 A I did not.-
19 0 Were.you a-participant in that' exercise?
20 A Yes, I was.
21 0 What was the nature ofLyour participation?
- 22 A Again, a County Liaison from the State.
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- marysimons-1 0 .And that would have been to Westchester county?
2 A To Westchester County.
3 0 Did you participate in.any post-exercise 4 evaluation process, including meetings with FEMA or ---
.5 A I participated'in a meeting with FEMA after the 6 exercise.
7 MR. ZAHNLEUTER: Jim, let him finish his question 8 so that I can hear the full question.
9 BY MR. IRWIN:
10 0 Would you answer be the same, General Papile, O 11 with respect to the August 24th and 25th exercise of the 12 Indian Point 3 plant?
13 A (Witness Papile) Yes.
14 0 Would it be the same with respect to the November 15 28th, '84 exercise at that plant?
16 A Yes.
17 0 And would it be the same with respect to the 18 April 10, 1985 exercise at that plant?
19 A Yes.
20 0 Turning to Indian Point 2, in the March '83 21- exercise did you participate in the development of 22 objectives for that exercise, sir?
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000 01-01 '19 marysimons l' A No.
2' O How about the scenario?
3 A 'No.
0 -Were you a participant in that exercise?
, 4 5 A Yes, I was.
6 0 What was the nature of your' participation?-
7 A Again, as a liaison to the County from the State.
8 0 Which-County would this have been?
9 A Westchester County.
10 0 And following the exercise again what would have O 11 been your involvement?
12 A At a meeting with FEMA.
13 0 Would your answer be the same with respect to the 14 June 4th, 1986. exercise at Indian Point 27 15 A No.
16 0 Did you participate there in preparation of 17 objectives?
18 A I participated in the objectives.
19 0 How about in their translation into a scenario?
20 A Not actually in the scenario, no.
( 21 0 Did you participate in pre-exercise negotiations 22 or discussions with FEMA?
1 1
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!s ,j000 01 01 20 marysimons:1 A I don't think I did.
'2 O How about in the conduct of the exercise itself?
At that time I was at the State - ; qqqC-__ ting the
'3 A jf 4' ' Command Room.
5 0 What was your role there?
6 A I was assisting.the State representative.
7 0 Who was the State representative whom you were 8 assisting?
9 A I believe nem for that one it was Don Davidoff.
h' 10 0 Had you left your role as County' Liaison to O 11 Westchester County at that point?
12 A At that point I had achieved my new position.
13 O Following the exercise did you participate in any 14 evaluation or meeting process?
15 A Following the exercise I participated again in 16 listening to FEMA give its debriefing.
17 0 Would you describe your role in the development 18 of the' objectives for that exercise, sir?
19 A It was a very limited role in that I would. sit 20 down with the Exercise Director after he had worked with 21 FEMA on it.
22 O That was Mr. Baranski-you sat with?
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BOO L O1. 0'12 21 imarysimonsil' A Yes,Jand-I.would. work withthim and say haveDthe:
'2. counties ~' agreed to this~and so forth.- It was'more.of an- -
31 Loverseeing view 1rather thanHan initiating.
4- 0 What were the kin'ds-of things;.you wereireviewing 5 with-Mr.'Baranski with. respectSto the Co'unty's areas of ,
6 agreement?'
i E7 .MR.-LANPHER: I would likelto interpose.an
- , - 8 objection,-and.I'll just do it once,nof-relevancy to this.
4 9 entire line of questioning. I won't interrupt you :again.
]
10
. - -BY MR. IRWIN:
11 0 Do you understand the question, General Papile?
f 12 A' (Witness Papile) Would.-you repeat the question.
l 13 , (The pending question was read by theDreporter.)
! 14 WITNESS PAPILE: Mainly what we would call the'
~
'15 demonstrative activities, such as.the number of buses to be
! 16 used in'actually-testing and so forth, those-itemsLthat- +
i p 17 would be. tested.
j 18 BY MR. IRWIN::
19 0 That'would include, for example, the number of:
- l
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t- 20- buses, as you said and it-would Anclude, for instance, the-21 number.of-ambulances or'ambulettes to be run?
, 22 A (Witness Papile) Yes.
r ~
ACE-FEDERAL REPORTERS, INC.
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- 000 01 01 22 Earysimons 1 0 The. number of' schools to participate?'
2 .A' Yes.
3 0 ~The. number of. hospitals, if any, to be contacted?-
4 A Yes.
Whether the-Coast Guard was to be notified or.
~
5 0 6 asked to participate?
7 A That would come under notification.
4 8 0 Why was it necessary to obtainEcounty. agreement 9 with respect to the number of each of these types of say 10 buses to be run?
O 11 A I didn't necessarily say I obtained county
- 12 agreement.
13 0 What was the nature of the discussions then?
14 A For my end was just to see how many the County
~
15 would have to do. We didn't necessarily have to reach 16 agreement with the County.
17 0 Who determined how many the County would have to 4
18 do?
19 A FEMA mainly.
20 0 Entirely?
, 21 A Mostly because if they didn't get what they 22 wanted, they would then grade us accordingly.
- ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage - 80433M646
(3 23 v 000 01 01 marysimons 1 O But thereLwas, I take'it, a process of.give and 2 take between FEMA and the counties with respect to the 3 number of buses to be run and'so'forth?
4 A Not FEMA and the County, but FEMA-and the State.
5 0 With the State acting as agent for the County to 6 FEMA I take it?
7 A The State acting for itself.
8 0 What was the. State's independent role then?
. 9 A Making sure we had a good exercise, ensuring.that 10 the safety of the public was adhered to in our exercises.
11 0 When you were-talking with FEMA about say the 12 number of buses, how did you ensure the adequacy of the 13 exercise?
14 A Well, really to tell you the process, FEMA gave 15 us a number first and we worked from there.
16 MR. LANPHER: Can I ask for a clarification, Mr.
17 Irwin. Are all these questions that you are directing right 18 now pertaining to the June '86 exercise?
19 MR. IRWIN: These questions are since the-witness
, 20 has indicated this was the exercise in which he was involved rS 21 in this process.
, (_)
22 MR. LANPHER: All right.
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coserage 80 4 336-6646
- x,,,000-01 01 '24 marysimons.1 BY MR. IRWIN:
2 0 General Papile, if FEMA said we want to run say 3 500 buses, would~you simply go to Westchester County and say 4 be prepared to run 500 buses?-
5 A- (Witness Papile) No. I would argue with them on 6 that one.
7 0 Why?
8 A That's just too many buses.
9 0 What's a reasonable number?
10 A A reasonable number? I've got to say I. don't O 11 know.
12 0 How would you go about telling them whether it 13 was reasonable?
14 A I don't know.
15 0 Then'why would you argue with FEMA if you don't-16 know what a reasonable number is?
17 A. Well, because I would think of what inconvenience 18 it would be to the bus company. My Exercise Director has 19 past experience on it.
20 0 If the health and safety of the public is the 21 only relevant consideration, of what relevance is 22 inconvenience to the bus company?
l ACE-FEDERAL REPORTERS, INC. I 202-347-3700 Nationwide Coverage 800 336-6666-
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- marysimons 1 A The volun'teer1their buses'and.I like to--keep'them' J' 2 on_the good side. They're. volunteers.
3 0 _You're talking about' general evacuation' buses 4- here or school buses?
i 5 A I'm talking about-both kinds of buses.
l l 6- 0- Is, to your knowledge,.the process which you i
.followed with respect to thel June '86 exercise ath Indian 7
8 Point unique in terms of the. negotiations with FEMA?
9 A I have no idea. I didn't.-negotiation with_ FEMA e .
10 prior to that.
11 0 Do you have any' reason to believe that it was a-12 different process?
s 13 A I won't venture to guess.
l
~14 0 Mr. Baranski, were you involved in.any of these 15 discussions on the June '86 exercise?'
l 16 A (Witness Baranski) I was.- ,
1 17 0 Was it different in any fundamental way-from the l l
18 process of negotiation followed in earlier exercises?
19 A I have no experience in earlier exercises.
i l
20 0 In other words, that was the only exercise you l l
- 21 yourself have participated in negotiations on?
22 A No, sir. If you recall, I became_ Exercise 1
l ACE-FEDERAL REPORTERS, INC. l 202-347-3700 Nationside Coverage 800 336-6646 1 i _l
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j l
/~T 26-
- V 000 01 01 marysimons 1 ' Director in January of '85. So-any exercise prior' toil 985 I 2 was not involved in'the~ negotiations.:
3 'O How about in the other exercises in-1985, such as-4 Ginna, was the' process which. General Papile has, described at.
~5 Indian Point, wa's it:different in'any; fundamental way.frome 6~ the process followed at Ginna in ?857 7 A. No, sir ~.-
l -E. O- Was it different'in any fundamental way from the 4
9 negotiation process followed at Nine Mile Point in November-6 10 '857 1.- 11 A No. 3 i .
- 12 O In other words, so'far as you can tell it was a 13 fairly typical negotiation process?-
14 A That is correct. 4 15 0 Mr.'Baranski, let's go through these exercises s
16 for your involvement in them.
17 Turning first to Ginna~in:the January '82 18 exercise,.did you participate in' development of obje'ctives 19 for that exercise?
i 20 A No, sir, I did not.
21 O How about the preparation of their translation 22 into a scenario?
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A No, sir,-I did not..
2 O 5
Were you a participate in that exercise? / -
3 A Yes, sir,' I wa's.
4 '0- In what fashion?
5 JL The EOF Technical Liaison at the EOF.
6 0 Did you participate in any kind of post-exercise 7 evaluation or critique process?
8 A' I sat in on the post-exercise debriefing by FEMA.
9 9 0 Would this-have been the same post exercise 10 debriefing that General Papile typically' described as being O 11 the one he sat in on?
- 12 A That's correct.
13 0 Was your role the same in the June '83 Ginna 14 exercise, sir; in other words, no involvement in scenario or 15 objectives, an exercise participant at the EOF and a 16 participant in post-exercise debriefing by FEMA?
4 17 A That is correct.
18 0 would your' answer be the same'with respect to the 19 November '85 Ginna exercise?
20 , MR. ZAHNLEUTER: Excuse me, September '85?
21 MR. IRWIN: September '85.
~
I'm sorry, yes.
)
22 WITNESS BARANSKI: In September I-was the-ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800-336-6M6
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-(,j000 28 marysimons.1 Exercise Director.
2' BY'MR. IRWIN:. _1 3 .O~ So what~.was your role there? What did that'
'4 involve?'
That' involved ~-negotiations 5 -A-~ (Witness 5Baranski) ,
i 6 with FEMA for the objectives, participating inothe scenario 7 development group, State Exercise Director (ar execution- of 8 the exercise and that was the extent up thecage the i 9 exercise.
t
-~
1 10 0 During the exercise what was the-nature of your l
() 11 participation?
12 A During.which exercise?
13 0 I'm sorry, during the September 26, 1985 Ginna 14 exercise.
15 A I was the lead offsite controller for the State 16 at the EOF.
J 17 0 And after the exercise, sir, what was'the nature i
18 of your involvement?
19 A Participating in the' post-exercise debriefing.by 20 FEMA.
-21 0 Any other contacts with FEMA in:the. post-exercise' 1~
22 period, in other words, the period between the. exercise.and I
ACE-FEDERAL REPORTERS, INC. -
2 202-347-3700- : Nationwide Coverage - 800-336-6646 -
, -,a-- . ., , . _ . . , _ - - . . . . . ~ . - - . _ . - . . . .
i(~)000 m, 01 01 29 marysimons.l. the issuance of the post-exercise assessment other than 2- participation in that one meeting?
3 A Reviewing the post-exercise assessment, the draft ,
- 4. exercise assessment report prior to the issuance-of the 5 final report..
6 0 You were provided a copy of the-draft post-7 exercise assessment by FEMA?
8 A That is correct.
9 0 How many drafts did you review, sir?
10 A I don't understand the question.
O 11 0 Well, was there more than one draft that.you 12 reviewed?
13 A To the best of my recollection,.there was one 14 draft that we reviewed.
15 0 And you provided comments on that to FEMA?
16 A That is correct.
17 0 Do you recall participating in response to a 18 request for production of documents by Long-Island Lighting 19 Company concerning exercises, including this' exercise, in -
20 connection with these interrogatories?-
21 MR. ZAHNLEUTER: I don't understand the question.
22 MR. IRWIN: I don't recall seeing a copy of any ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage : 800 336-6646
000 01 01- 30
~
marysimons I written comments sent by the State of New York concerning 2 the post-exercise assessment on.the-Ginna exercise and'I
~
3- think they would have been fairly within the scope of1our 4 discovery ~ request.and I would-like a copy of:those comments.
5 MR. ZAHNLEUTER: I'll take your request under 6 advisement.-
7 (Pause while the_ witnesses consult.with Counsel 8 Zahnleuter.)
9 (Discussion off the record.)
10 BY MR. IRWIN:
O 11 O Mr.LBaranski, I noticed you consulted with your 12 counsel and co-witnesses after I asked the last question.
13 Was the problem caused by some question as to whether or not 14 any written ccaments existed?
15 MR. LANPHER: I object to the question. It 16 assumes there is a problem.
4 17 MR. IRWIN: I infer there is a problem any time 18 there is an unscheduled huddle.
19 MR. LANPHER: That is not a proper assumption.
20 The witnesses can consult any time they want.
j-] 21 MR. IRWIN: Are there written comments ---
w/
22 WITNESS BARANSKI: Excuse me one minute.
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.31 amarysimons.1 MR.s IRWIN: I' 'think 1that'. question 'can ' be.. answered.
2 yes or;no.
. 3 .(Pause whilerthe witnesses. consult'with Counsel 4 Zahnleuter.).
i 5' . WITNESS-BARANSKI: Please restate the question.
6 BY MR. IRWIN:
7 O Are'there any writt'en. comments on the draft FEMA 8 post-exercise assessment for the September '85EGinna i
9 exercise?
10 A (Witness Baranski) To'the'best of my
.'( 11 recollection I do not recall any written avaluations' ofothe 12 draft report.
13 0 How were your comments' transmitted,isir?-
3;
- . 14 i A Verbally to FEMA?
15 O To whom?
4 16 A To the RAC Chairman.
17 O Mr. Kowieski?
18 A That is. correct.
19 0 over the telephone or in a' meeting, if you 20 recall?
1 21 A I do not recall which' method was used.
2l2 O Do you recall any'of the substantive areas'of i
ACE-FEDERAL REPORTERS, INC.
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C,6 000 01-01 32 marysimons'1' comment at this point?
2 A 'No, sir, I,do not.
3- O Do you possess a copy of the' draft-on^which you 4 were commenting?
. A' No, sir, I do not.
6 0 With respect to the' Indian Point 3 series of 7 exercises, let's go to the first one, the'one in March of 8 1982, did.you participate in the development of' objectives 9 for that' exercise, sir?
10 A No, sir.
O 11 O How about the scenario?
12 A No, sir.
13 0 Were you a participant in that exercise?
14 A Yes, sir.
15 0 In what capacity?
16 A EOF Technical Liaison at the EOF.
17 0 And after the exercise did you participate in any 18 other evaluative process?-
19 A I sat-in on the post-exercise FEMA debriefing 20 meeting.
21 O With respect to the August.24/25 exercise at
. 22 Indian Point 3 would your answer be the same?
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'mirysimons 1. A That is correct.
2 -0 ~With respect to-the November.28,11984' exercise at-3 ' Indian Point 3lwould yo'ur. answer be the same?;
4 A That11s correct.
- 5. 'O And'with-respect ~to the April:10, '85 exercise,t 6 'did you participateLin:.theldrafting of or-preparation of 7 ' objectives for that exercise?
8 A -.Yes, sir, I did.
'9 O 'And the scenario?
10- A Yes, sir.
4 O 11 O Were you a participant in that exercise also?
12
~
A I was the~ Exercise Director for that exercise.
r 13 0 What would the Exercise Director's< job.actually 14 have involved as a participant?
. 15 A As the Exercise-Director I was responsible for 16 ensuring that the exercise offsite was conducted-in 17 accordance with our agreed upon schedule of activities, and 18- if'there were any problems that developed offsite I was the' 19 person that was contacted to reconcile these discrepancies 20 with the onsite controller and'the lead' FEMA controller.
21 0 Is that a reasonable description of your--
22 involvement in the actual conduct of offsite exercises, in t
+
- - ACE-FEDERAL REPORTERS, INC.
(202-347-3700 Nationwide Coverage 800-336-66M
(j00001'01 34 marysimons 1 other words, as a participant at every exercise since you 2 assumed your current job? I don't want to ask any extra 3 questions if I don't have to.
, 4 MR. ZAHNLEUTER: I object-to form.
5 If you can answer that, Mr. Baranski, go ahead.
6 WITNESS BARANSKI: Since I have become E:;ercise 7 Director, in general that is a correct statement.
8 BY MR. IRWIN:
9 0 Post-exercise, what was your participation with 10 respect to the April 10, '85 Indian Point exercise?
11 A (Witness Baranski) This again was participating 12 in the meeting and reviewing the draft report prior to 13 issuance of the final report.
14 0 FEMA provided you.with a draft of that exercise 15 report?
16 A They allowed us that, yes, sir.
17 0 Do you recall whether you commented on that 18 report to FEMA?
19 A I do not recall the comments on that report.
20 0 Do you recall whether you gave any comments at l l
21 all?
22 A I do not recall. l l
ACE-FEDERAL REPORTERS, INC. !
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-. . . _ _ . . ~ . , .
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j3 V 000 01 01 35 marysimons 1 O Let me come back to the. Indian Point 3, April 10, 2 '85 exercise. Was that a remedial exercise, sir?'
3 A. That is correct.
4 0 At Indian Point 2-in.the1 March '83 exercise, did 5 you participate in the development of exercise objectives I
6 for that?-
7 A No, sir, I did not.
8 0 Did you participate in their translation'into a 9 scenario?
10 A Speaking of the March 9th ---
11 0 '83, yes, sir.-
12 A I did not participate in that.
13 0 How did you participate in thel exercise itself?
14 A I was the EOF Technical Liaison at the EOF.
15 0 And post-er.ercise, I take it you sat in on the 16 FEMA debriefing of exercise players?
17 A 'That is correct.
18 0 And that was the extent of your post-exercise 19 involvement.
20 A That is correct.
21 O At Indian Point 2 in June of '86, I take it you 22 participated in the aevelopment of exercise objectives?
i ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Cowrye 800-336 6646
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' . A ': That is correct..
2 0' For that: June '86= exercise,II..take.it you1also 3, participated j in 'theE developmenti of : the! scenaria?
Y
{ - _4 ?A v That.is correct.
, '5 0 -. I take it~you?were.also overall~in. charge of the- -
6 exercise from the State's' standpoint Las a> participant?. .
i
-7 A- That is correct.
8' :0- I'm sorry,_what was that title again?'
9 A Exercise Director.
10 0 And post-exercise, I take it you_ participated-in O 11 the debriefing'of the players by FEMA?
, 12 A That is correct.
13 0 And you also commented on a draft FEMA i-14 assessment?
a.
5 15 A That is correct.
16 0 Do you recall whether you provided any comments 17 to FEMA on that draft assessment?-
18 A We did provide comments-to FEMA on that,~ verbal 19 comments to FEMA on that draft report.
20 0 Do you recall any of the subject matter of those-21 comments? ,
22 A Yes, I do.
. ACE-FEDERAL-. REPORTERS, INC.
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.mcrysimons 1 0 Will you tell.me.what you remember?
2 A The incidents'in particular that I remember that 3 we-commented on were the deficiencies that resulted in the 4 Orange County field monitoring teams.
0 Any'other areas?
5
'6 A That 1 particular issue is the only one that I can
, 7 remember that we provided comments on.
O What was the FEMA deficiency with respect to 9 Orange County field monitoring teams?
10 A That the field monitoring teams did not meet-the
' O 11 objectives.
! 12 O What was the reason given for their not having 13 met the objectives?
FEMA's comments were in essence that more 14 A 15 training was needed for the field monitoring _ teams.
16 0 More training of what kind?
l 17 A Training _on equipment and their own particular 18 procedures.
19 0 What was the nature of your comments to FEMA 20 concerning those observations?
21 A That training had been provided and that these l 22 were people that had been evaluated previously by FEMA and ACE-FEDERAL REPORTERS, INC.
202-347 3700 - Nationside Coverage 8 @ 336-6646 -
I )000 01 01 38 marysimons 1 had been found satisfactory.
2 0 Did FEMA's deficiencies suggest that' FEMA 3 considered there to be any deficiencies in the training
- 4. program for these people?.
5 A Restate the question, please.
6 MR. LANPHER: I would like a clarification. When 7 you use the word " deficiency," are.you using that just-in a 8 general sense or are you using that in a technical sense 9 like FEMA uses. I'm familiar with FEMA's use.
-10 BY MR. IRWIN:
O 11 0 Mr. Baranski, you used the word " deficiency" a 12- few minutes ago. I was using it in the same sense that you 13 were using it, and I understand that you have been answering 14 me back in the same sense; is that correct?
15 A (Witness Baranski) That is correct.
16 0 And you were using it as a FEMA term of art?
17 A That is correct.
18 0 Did the deficiency which FEMA found with respect 19 to the training of these people suggest in your mind any 20 problems or shortcomings in-the process or program for 21 training of'the Orange County field monitoring teams?
22 A No, there was nothing wrong with the process of ACE-FEDERAL REPORTERS, INC.
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39 marysimons 1: .the program.
4 2 O Then why-didn't'they_ perform ~ adequately?~
3~ A I have no information on why they didn't-meet the v
- _ '4 objective.
5- 0 In other words, you agreed?with FEMA.that they 6 ~ did; not meet ~ tihe. objective . that _ day? "
7 A <We agreed with FEMA.that'the objective _was notu 4
8 met.
+
9 O But the failure to meet an objective did'not.in 10 itself imply a problem with the. process or. program by;which LO i 11 these people had been trained'to perform their jobs; is_that i
12 correct?
13 (Witnesses confer.)
l 14 MR. IRWIN: Let me note for the record that the 4
- 15 witnesses are_ conferring on this answer.
1 - -
j 16 WITNESS BARANSKI: I mentioned it before, but.
! 17 what I would like to bring up again is_this-was the same
- 18 team that had been evaluated by FEMA in previous exercises-19 and had performed satisfactorily.
20 BY MR. IRWIN: i
- 21. O So I take it that the answer is that a deficiency 1 l 22 in the performance of an objective doesn't necessarily imply 4
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Tj% 000
. 01 01 40 marysimons'l ~ a' problem'in a training: program?'
'2 A. (Witness Baranski) It.does not necessarily. imply' 3 that.
4 -0 This is the June 4th, '86 Indian' Point ~2 5- exercise; is'that' correct?.
6 A Yes.
7 0- How long'had it been since this team had been 8 previously. evaluated by FEMA, this Orange County offsite 9 radiological monitoring team?.
10 A The previously full-scale Indian Point site O 11 exercise.
12 0 That would have been by my chronology the 13 November '84 oxercise?
14 A That's correct. ,
~
15 0 Turning to Fitzpatrick, the August '82 exercise, 16 I take it you would not have been involved in the 17 preparation of either scenario or objectives for that 18 exercise; is that correct?
19 A That is correct.
20 0 You would have participated in the exercise in
-rg 21 what capacity, sir?
l k) 22- A As the EOF Technical Liaison at the EOF.
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.morysimons'1 0 And post-exercise you would have been present at 2 -the.' debriefing of players,Lbut-had no other' post-exercise 3 involvement; is that correct?
4 A Thatti:s' correct.
5 0 At Nine-Mile 1, the November '83 exercise, I take 6 it you would not have been involved 'in either-scenario'or-7 objective preparation?
8 A That is correct. l 9 0 You would have participated'in-the exercise at' 10 the EOF I take it?
O 11 A That is correct.
12 0 And you would have been present at the post-13 exercise assessment, but had no other' post-exercise 14 involvement?
i 15 A That is correct.
16 0 Nina Mile Point, November '85, I take it you 17 would have participated in the developmentLof objectives for
, 18 that exercise?
19 A That is correct.
20 0 And you would have participated in their 21 translation into a scenario?
22 A That is correct.
1 ACE-FEDERAL REPORTERS, INC.
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mtrysimons 11 0 You would have_ participated in that exercise?
2 A' As the Exercise Director.
-3 0 And-post-exercise you-_would have been present at 4' the debriefing of players?
5 A That is correct.
6 0 And you would have also commented on a draft 1 FEMA 7 post-exercise assessment?
8 A 'That is correct.
9' 0 Do you recall wh' ether you provided any comments-10 in fact to FEMA?
- O 11 A .I do_not recall whether we provided comments to 12 FEMA on that draft report.
13 0 Mr. Czech, let's go through the same five-finger 14 exercise if we could.
i 15 In the Ginna January 1982 exercise, sir, were you 16 involved in the preparation of objectives for that exercise?
17 A (Witness Czech) I believe I was. ,,
18 0 Were you involved in their translation into a 19 scenario, sir?
20 A I believe so.
21 0 Did you participate in that exercise?
22 A As State Exercise Director.
I L ACE-FEDERAL REPORTERS, INC.
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.43 marysimons.1- 'O 'Is that the same job that Mr. Baranski~is now i
2' performing linexercises?
3 A .That's essentially correct.
4 0 So you were his predecessor in that job of being 5 the head coordinator of the exercise during the actual 6 exercise?
7 A During the '82 and some of the earlier exercises; 8 that's correct.
9 0 And post-exercise, what would your involvement 10 have been?
11 A It would have been to review the exercise 12 critique from PEMA, to look for shortcomings and that would 13 be one of the things we would have to look at for the next 14 series of exercises to factor in those -- or objectives 15 would be included that would test the areas that were found 16 to be weak. ,
17 0 Would you have commented toF 'EMA on their post-
, 18 exercise assessment for that exercise, do you think?
19 A I don't recall.
-20 0 But you would have seen a draft of FEMA's r~ 21 exercise assessment?
U) 22 A That is correct.
ACE-FEDERAL REPORTERS, INC.
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()00001.01 44 merysimons 1 0 With' respect to.the Ginna exercise in June of
?2 '83,1would you involvement have been the same as that which 3 you have just described for the' January '82 exercise?;
4 A I believe that's true.
5 O. I take it with respect to comments on>the draft:
6 post-exercise assessment you did. review a draft of that 7 assessment?
2 8 A That is correct.
9 0 Do you recall whether you provided comments to 10 FEMA on it?.
O 11 A I do not.
12 0 But you would have had the opportunity had you 13 chosen to?
14 A That's true.
15 0 With respect to the September '85 Ginna exercise, 16 would you have participated in the development of objectives 17 for that exercise?
18 A No, I would not have.
19 0 How about the scenario?
20 A No.
21 0 What would your role have been in the actual 22 conduct of the exercise?
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'f'yJ00'0.01 01 .45 marysimons 1 A h
I'would have been a participa&e as the State's 9
b '
2 lead technical representative ~at the'Ginna EOF.
3 0 Post-exercise, what.would your role have been, 4 sir?
5 A Primarilyft o review the-draft:as'it pertains to 6 any. shortcomings that would have been identified at'the 7 emergency operations facility.
8 0 In other words, when FEMA distributed the report 9 back to the State, I guess by this time Mr. Baranski, he 10 would have sent a copy to you and asked you to comment on O 11 your area?
12 A Are you talking of the draft?
13 0 Yes, of the draft post-exercise assessment.
14 A No, that-is not true.
15 0 How did you come to be reviewing it?
16 A I was primarily talking about their reviewing the 17 final FEMA evaluation.
18 0 I see. In other words, you're talking about the l
19 final and not a draft? i 1
20 A I may have seen the draft. I don't remember. )
rx 21 0 Let me see if maybe I can do some shorthand
(_) ,
22 here.- Would there have been a time of transition in your l 1
ACE-FEDERAL REPORTERS, INC. l mm. y m7m7_. l
, ,s (nj000 01 01 46 marysimons 1 'j ob such that prior to this time of transition you would 2 have. typically been involved in-the' development of-an 3 objectives-scenario with participation as the State Exercise 4 Director and comment on post-exercise assessment and' 5 thereafter not been involved in scenario or objective 6 development with participation as State lead technical 7 representative at the EOF and not participating thereafter 8 in comment on draft post-exercise assessmeats?
9 I'm just trying to see if there:is some clear 10 dividing line here.
11 MR. ZAHNLEUTER: I object to the form,.but-you 12 con answer if you know how to.
13 WITNESS CZECH: Post November 1984, and that's 14 the Indian Point 3 full-scale exercise on November 28th, 15 1984, following that exercise I had no.further role with 16 development of objectives, review and/or preparation of 17 scenarios and acting in any capacity as an Exercise 18 Director. I was primarily involved as a participant at the 19 respective emergency operating facility of the utility 20 having the drill.
I 21 Prior to that time, and including the 1984, I was 22 involved with most of the exercises with some part of the ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 80433MM6
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- 4 7-j marysimonsf' l :' obj ectives . . There. Care 'a'- couple , -L and I 'm '; having ~ aihard .~ time 2' remembering which._ones1specifically"that?I was.not Exercise 13 : Director..
- 4. ~ 0: . General Papile,-_'looking'at~the list of exercises:
'5
. #at the' bottom of.page'2 and the top of page-3'of these-6 ' interrogatories, which,-if3any, of these exercises'were not-
~
7 . full-participation exercises?-
8 MR. LANPHERt. I. object to the-question. It calls 9- .for a legal conclusion.
10 MR. ZAHNLEUTER: That was an objection that'I'
.O 11 wished to pose, but-I also wished a clarification of the 12 term " full-participation exercise."-
13 BY MR. IRWIN:
14 0 General Papile, are you~ familiar with the term 15 " full-participation exercise"?
16 A (Witness Papile) I am.
17 0 What does it suggest to you?:
18 A It suggests to me that exercise where we at that 19 time put the State agencies and the County agencies at the 20 EOC's, at the EOF in full strength and at the. joint news
, 21 center at full strength ready.to participate in the event of 22 an emergency.
ACE-FEDERAL REPORTERS, INC.
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( ,,000 01 01 48 merysimons 1 0 Does it suggest anything to'you about the scope 2 of county _or other_ local involvement?
3 A The_ scope of county? I would imagine that the 4 full participation would be notification to the county, as 5' I've stated, and then full participation and activation of 6 the EOC. In so doing that, they in turn would do their job, 7 whatever they had to do according to their procedures.
8 0 Is there any particular substantive set of 9 objectives or criteria which these organizations must a
10 fulfill in order for an exercise to be considered a full-O O
11 participation exercise?
12 A I know of none. As you stated, I know of none in 13 that respect except that they should be at their stations.
i 14 0 Are you familiar with a FEMA document entitled
, 15 FEMA Guidance Memorandum 177 16 A Yes, I am.
17 0 Do you use that in your process of planning i
18 exercises?
i 19 (Witnesses confer.)
20 MR. ZAHNLEUTER: Mr. Irwin, it would be helpful 21 if you would identify the particular GM 17.
22 MR. IRWIN: I'm sorry. I am referring to ,
1 ACE-FEDERAL REPORTERS, INC..
202-347 3700 Nationwide Coverage 80 4 336 4 646 L
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- m.
1 ,;000 01-01' 49 m rysimons 1 Revision _1, and it's-dated ---
2 WITNESS PAPILE:- Until yesterday I had never seen 3 that.
4 MR. LANPHER: Don, are you going to mark that as 5 an exhibit?
i y 6' MR. IRWIN: I can_ mark-it.
7- WITNESS ~PAPILE: Until yesterday I'had never'seen 8 that.
9 MR. LANPHER: General Papile, no question is l 10 pending.
'( 11 WITNESS PAPILE: I just repeated it.
12 MR. IRWIN: I don't have a lot of copies of 13 this. It's a document which.is in the open literature and 14 has been referred to. I'can provide this copy to General 4
15 Papile. I'm referring to Revision 1 dated February 16, l
16 1984.
4 17 MR. LANPHER: Excuse me. I've got a copy and I 18 want to make sure I've got the same thing. Where is it=
19 dated? My copy is not.
20 MR. IRWIN: Mine bears a handwritten date in the 21 upper-right-hand corner.
[ )
22 MR. LANPHER: Handwritten 2/16/84?
ACE-FEDERAL REPORTERS, INC.
202 347-3700 - Nationwide Coverage 80l)-33MM6
000 01-01 50 marysimons 1 MR. IRWIN:' Right.
2 MR. LANPHER: Thank you.--
'3 BY MR. IRWIN:
4 O General'Papile, is this the document which you 5 . reviewed yesterday'for the first time?
6 A (Witness Papile) Yes, sir.
7 0 If you look in this document, sir, you will 8 notice'that there'is a list of objectives and that there are 9 some 36 objectives for exercises. Did you review that list 10 of objectives yesterday as you' reviewed this document?
O 11 A No, I did not.
12 O In other words, you have never used this 13 particular document in deciding what is an adequate exercise 14 in determining what is a full participation exercise?
15 A Restate'that question.
16 0 When you looked at this document yesterday you
, 17 did not look at the list of objectives in it?
18 A No, I did not.
19 O Do you use in your own planning with FEMA any 20 list of objectives for purposes of determining what is a i
21 full participation exercise?
22 MR. LANPHER: Can I have the question read back, ACE-FEDERAL REPORTERS, INC.
202-347-37(H Nationwide roverage 800-33MM6
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) \
(_j000 01 01 51 marysimons 1 please.
2 (The pending question was read by the reporter.)
3 WITNESS PAPILE: FEMA provides us with 4 objectives. We sit down with FEMA and determine the 5 objectives. We don't determine whether it'c a full-6 participation exercise. FEMA does. We sit with FEMA. My 7 Exercise Director will sit with FEMA and determine the 8 objectives to be used during the exercise for a full 9 participation.
10 BY MR. IRWIN:
A U 11 0 General Papile, let me show you another document 12 which is marked " Draft." It called " Guidance Memorandum EX-13 3, Conducting Pre-Exercise Activities and Post-Exercise 14 Meetings" and it is dated 8/15/86. I do happen to have 15 extra copies of this. I think everybody is familiar with 16 that document and I don't see any need to mark it as an 17 exhibit.
18 MR. LANPHER: Don, for ease of reviewing the 19 deposition later, since you have the extra copies, do you 20 object to marking it as an exhibit? .
r~s 21 MR. IRWIN: No, I don't object to marking this as U
22 an exhibit.
ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 80fA33644
()00001Ol' 52 -53 marysimonssi (The document referred to was
.2 marked' Deposition Exhibit .2 for :
3 identification and submitt'ed
~
4 for the-record.)
4 5 (Discussion off the-record.)
3 ..
6 .MR.-IRWIN:: Let's go back on-the record.
7 BY MR. IRWIN:
8 0 General Papile, have you ever. laid eyes'on this 9 document, Guidance Memorandum'EX-3,1before this morning?. I
~
10 A (Witness Papile) Yes, I have.
11 0 When was the first time you laid eyes on this 12 document?
13 A I'm going to say about three weeks ago.
14 0 In what connection did you happen to' review it?
15 A I am reviewing it. It's a draft document. We 16 are reviewing it.
17 0 Have you yourself' reviewed it at all 18 substantively?
19 A I have not. It is out to my staff right now for 20 review.
21 0 Mr. Baranski, were you familiar with FEMA
).
22 i
ACE-FEDERAL REPORTERS, INC.
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. merysimons~1 Guidance Memorandum 17, Revision 1 prio'r to yesterday?
2 A (Witness Baranski) -No, sir, I was not.
3 0 Mr. Czech, were you familiar with FEMA Guidance 4 . Memorand'. .n 17, Revision l ~ prior to yesterday?
5 A (Witness Czech)- Not Revision 1.
6 0- Are you familiar with another revision?
7 A Just Guidance Memorandum 17.-
8 O' Mr. Baranski, have you seen FEMA Guidance i
9 Memorandum, draft memorandum that is, EX-3 eve'r before this 10 morning?
11 A (Witness Baranski)- Yes,-sir, I have.
12 O When did you first see it?
13 A Approximately three weeks ago. .
14 0 Okay, about the.same time General Papile did. 1 15 How about you, Mr. Czech?
. 16 A (Witness Czech) I have seen it.
l 17 0 When did you become familiar with it first? l 18 A Probably about a week ago.
- 19 O General Papile, is it a fair summary that'when 20 you are planning an exercise-it-is FEMA which originates the pg 21 objectives and you simply-try to see that they are
%)
22 translated then? !
4 4
ACE-FEDERAL REPORTERS, INC.
. 202-347 3700 Nationwide Coverage 800 33M646
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, v t iOOO 01.01- 55 marysimons l' A (Witness-Papile) They have the starting point in
.2 initiating the objectives. Then we meet with them and 3 discuss the. objectives.
4 0 What's your basis? You don't use either of these 5 documents and there is noLother particular document you use 6 as a reference point?
7 A We use 0654.
8 0 What are your reference points in your 9 negotiations with FEMA about the suitable scope and nature 10 of an exercise? In other words, if FEMA says we want to do 11 "X", do you refer them to 0654 if-you think 0654 doesn't 12 justify what they want?
13 A That's absolutely right.
14 0 Are there any other bases on which you ever tell f 15 them what they want is not appropriate?
1 16 A Not myself, no.
17 0 Well, how about anybody else?
18 Mr. Baranski, what basis do you use for 19 negotiation of objectives with FEMA?
20 MR. LANPHER: I object to the question. It r" 21 assumes that they are involved in negotiations with FEMA,
. \_)N 22 and I don't believe that has been established.
. ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 80 4 336-6646
n U 000 01 01 56-mnrysimons 1 BY MR. IRWIN:
2~ 0 Mr. Baranski, you do have discussions with FEMA 3 concerning the definition and statement of objectives for an 4 exercise before they are finalized?
5 A (Witness Baranski) That is correct =.
6 0 without' referring to them necessarily as 7 negotiations, discussions or anything else, how does that 8 process work?
9 A When we discuss exercise objectives with FEMA 10 they will provide us an initial set of objectives. We then n 11 in turn review those objectives to see whether we agree with 12 those objectives, and primarily our negotiations with FEMA 13 involve the scope and content of that particular objective.
14 0 And when you are negotiating or discussing with 15 PEMA the scope of a particular objective, can you give me an 16 example of a discussion of that kind?
17 A Certainly. For instance, one of the objectives 18 may be to test and verify the alert notification system.
19 Now my objective scope would be that, for instance, we 20 actually sound the sirens, we inject an EBS message into the l gs 21 radio station to get a test message broadcast and that we ;
( - ;
22 simulate subsequent EBS messages to have a clear ;
ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide roverage sm3E(M6 .
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/. 1 V 000 01 01 57 marysimons 1 understanding between us and FEMA on what we'are testing 2 under that objective.
3 0 And I take it with respect to say buses'that_the 4 objective would' involve how many buses were to be run?
5 A That is correct.
6 0 would it involve agreement on which companies 7 they were to come from?
8 A That is correct.
9 0 would it involve agreement on routes which they 10 were to run?
O 11 A The routes to be run historically have been free 12 play by FEMA.
13 0 Has that always been the case?
14 A Since I have been Exercise Director, that is 15 correct.
16 0 was that always the case when you were Exercise 17 Director, Mr. Czech?
18 A (Witness Czech) The bus routes have always been 19 free play, but in at least one of the earliest exercises I 20 believe it was like a choice of 5 out of 25 or something, 21 but after that anything in the plan was fair game as long as 22 it's a bus run for that bus company.
ACE-FEDERAL REPORTERS, INC.
202 347 3hD Nationwide Coverage R(Xk336-6646
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, V 000 01 01 58-marysimons 1 0 In other words, you know that bus company "X" 2 will be assigned to run "Y" number of buses? You know that 3 in advance?
4 A That's in the plan.
5 'O Exactly which routes though will be. chosen for 6 the exercise are not designated until the day of the i
7 exercise; is that correct?
8 A That's correct, and it's actually injected during 9 the process of the exercise.
10 0 With respect to early' notification in the water
() 11 portion of the plume exposure pathways, is that an area 12 which would be the subject of discussion with FEMA in terms l 13 of exercise objectives?
14 A (Witness Baranski) Yes, that would be.
i 15 0 Not including Shoreham, how many plants in New 16 York State are on bodies of water in which there would be 17 the possibility of having a notification process?
18 A All of them.
19 0 In how many of the exercises conducted to date 20 has there been notification of persons on the water portion 21 of the EPZ?
22 MR. 2AHNLEUTER: Objection to the form of this ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage NXb31MM6
,s C0000101 59 merysimons 1 question, and I would like to have a point of 2 clarification. We are talking about plants in New York 3 State; is that correct?
4 MR. IRWIN: Yes.
5 WITNESS BARANSKI: Please restate the question 6 again.
7 (The pending question was read by the reporter.)
8 (Witnesses conferring.)
9 WITNESS BARANSKI: I don't understand the 10 question.
11 BY MR. IRWIN:
12 0 How many exercises can you recall, Mr. Baranski, 13 in which one of the objectives has been to notify persons in 14 the water portion of the EP2?
15 A (Witness Baranski) The exercises that I have 16 been responsible for as Exercise Director, excluding April 17 10, '85 at Indian Point 3, have included notifications to 18 the Coast Guard.
19 0 Notification to the Coast Guard by what means?
20 A By the means outlined in the specific plans.
21 0 Actual notification?
q's.)
22 A Actual notification.
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationimide Coserage mn)h6M6
O 60-(_,000 01 01 m2rysimons 1. 0 And actual response by the Coast Guard in 2 addition?
3 A In some exercises.
4 0 can you give me an example?
5 A Ginna.
6 0 Which one?
7 A The September 26th exercise at Ginna. September 8 26th, 1985 at Ginna.
9 0 Would that have been stated as an exercise 10 objective?
O 11 A The guidelines written for the objective would 12 have included notification of the Coast Guard and 13 dispatching of a Coast Guard vessel.
14 0 Any other exercises in which the Coast Guard 15 would have actually dispatched a vessel since you took over?
16 (Witnesses conferring.)
17 A Also exercises at the Nine Mile Point site in 18 Oswego County.
19 0 That actually involved dispatching of the Coast 20 Guard vessel?
21 A That is correct.
22 0 Were there any exercises during your tenure in ACE-FEDERAL REPORTERS, INC.
202 347 370) NatiotswWe coverage sak34te
s (j000 01 01 61 marysimons 1 which there was not a Coast Guard vessel dispatched?
2 A I do not recall.
3 0 You do not recall, does that mean it's your 4 belief that there were none, or you just don't recall 5 whether there are any?
6 A I just don't recall whether there were any for 7 other exercises other than the two I described.
8 0 would it be fair to say that you would be able to 9 find information on that in the FEMA post-exercise 10 assessment?
11 MR. LANPHER: I object to the question.
12 WITNEOS BARANSKI I believe that information 13 would be cited in the post-exercise assessment.
14 BY MR. IRWIN:
15 0 Mr. Czech, during your period as State Exercise 16 Director were there exercises during which notification to 17 the public on the water portion of an EPZ was not an 18 exercise objective?
19 A (Witness Czech) None that I can recall that was 20 not a part of the objectives.
21 O Ilow were the objectives realized in the exercises 22 for which you were responsible? '
ACE-FEDERAL REPORTERS, INC.
202447.)No Nationwide Coverage mn)WMA6
,,000 01 01 62 merysimons 1 A Either no,tification of the Coast Guard or the 2 Coast Guard along with the respective Sheriff's Department 3 which has responsibility for notifying that are on the 4 waterways.
5 0 In other words, players would call the Coast 6 Guard or call the Sheriffs' offices?
7 A That is correct.
8 O And these would be calls to the actual Coast 9 Guard and Sheriff's offices and not simulated calls?
10 A These are actual calls, as well as tone alert o
11 radios in the areas that have tone alerts and on the NOAA 12 weather radio which many of the boaters would use also.
13 0 In the exercises for which you were responsible, 14 do you recall whether the Coast Guard actually mobilized or 15 actually dispatched a boat in every one or do you recall 16 whether there were any exercises in which they actually 17 dispatched a boat?
18 A I know there were some where boats were 19 dispatched, but which ones right now I couldn't recall.
20 0 Let me come back to the term " full-participation (S 21 exercise."
%i 22 Mr. Daranski, does that term have any meaning to ACE-FEDERAL REPORTERS, INC.
202 34717m N.uionwide rmerage mn136 fM6
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, marysimons 1 you?
2- A (Witness Baranski) Yes, sir, it does.
3 0 What does it mean to you?
l 4 A It means the same thing that it meant to Mr.
5 Papile, and that is a fell-participation exercise-involves 6 the activation and notification of the respective offsite 7 facilities and a demonstration of as many elements as 8 practicable for an exercise.
9 0 Mr. Czech, does the term " full-participation 10 cxercise" have any meaning to you?
O 11 A (Witness Czech) Yes.
12 0 Could you give me your understanding of it?
13 A I would say it's essentially the same as Mr.
14 Baranski's.
15 0 Now, General Papile, using the term " full-16 participation exercise" as you understand it, can you tell 17 me whether any of the exercises listed at the bottom of page l 18 2 and the top of page 3 of the Interrogatory Answers were ,
l 19 not full-participation exercises? l 20 MR. ZAHNLEUTER: Objection. That calls for a 21 legal conclusion.
22 MR. IRWIN: It's a term with which the witnesses 1
j ACE-FEDERAL REPORTERS, INC. l
- em.pm N.ioon.ia, coversee sun m<4m
h0000101_ 64 marysimons 1 are familiar and I would ask them to answer the question.
2 WITNESS PAPILE: The only one that I know of was 3 April 10th, 1985 at Indian Point 3.
4 BY MR. IRWIN:
5 0 And all the others, to your knowledge, and to 6 your belief, were full-participation exercises?
7 A (Witness Papile) That's right.
8 0 What was different about the April 10, '85 9 exercise?
10 A To the best I can remember, it-was remedial, as i
O 11 explained in the remedial exercise.
12 0 Mr. Baranski, do you agree with General Papile's 13 assessment?
MR. ZAllNLEUTER:
14 The same objection.
15 WITNESS BARANSKI I do agree with General 16 Papile's assessment.
f 17 BY MR. IRWIN: ;
18 0 Mr. Czech, do you agree with General Papile's s
19 assessment?
1 20 MR. ZAllNLEUTER: Same objection.
j 21 WITNESS CZECll I need a second to look at all 22 the dates.
ACE-FEDERAL REPORTERS, INC. ,
202 147 37(o Nationwkle Coserage *G))6t#4
7,
'(,'0000101
- 65 morysimons 1 (Pause.)
2 I brought up one which I couldn't remember the 3 date. I believe one of the exercises involved the Rockland 4 Compensating Plan. August 24, 1983 I believe was the date 5 for the Rockland Compensating exercise, and that would be in 6 present terminology what would be referred to as remedial.
7 BY MR. IRWIN:
8 O And that would not have been a full-participation 9 exercise?
10 A (Witness Czech) That is correct.
I '
11 MR. LANPilER : Excuse me. That is the August 24, 12 1983 Indian Point 37 l
i 13 WITNESS CZECII: Right, Indian Point 3.
l
- 14 MR. ZAi!NLEUTER
- Did you want to supplement your
(
l 15 answer, Mr. Papile?
16 WITNESS PAPILE: Yes, I did. I did not l 17 participate in the componnating exerciso, and that's why it i
18 slipped by me.
19 BY MR. IRWIN:
20 0 So with the exception of two exorcison at Indian n 21 Point 3 then, August 24, '83 and April 10, '85, is it tho l
V 22 opinion of each of you throo gentlemon that all of the ace-FEDERAL REPORTERS, INC.
3me., s m _ u , o ,,,,,, ,,o s,.
. . . ._. . . .- _ _ ~_ _ ..
' 'O
' y 000 01 01 66 e
j marysimons 1 exercises conducted:in New York State in the past five years 2 was a full-participation exercise?
3 WITNESS PAPILE: Yes.
4 WITNESS BARANSKI That is' correct.
- 5 WITNESS CZECH . Yes.
4 6 MR. IRWIN: This would be a good time to take a-7 break.
i 8 (Recess taken.)
{!
j 9 MR. IRWIN: Let's go back on the record.
l 10 BY MR. IRWIN:
lO
- . 11 0 Gentlemen, will you refer to Interrogatory Answer !
12 No. 4 on page 5 of t e answers, and particularly the first 1
13 sentence of that answer which reads: "The total number of i
j 14 hospitals, schools, nursing homes and adult homes located in I l l 15 the emergency planning zones for the plants identified in_
- i 1
16 response to Interrogatory No. I herein is the same as the
- i 17 total number of hospitals, schools, nursing homes and adult i
18 homes that participated in the exercises for'those plants."
f
^
i 19 Do you all see that sentence?
20 (Witnesses nodding affirmatively.) i 21 The question which that sentence answers requesta ,
i 22 the identification of the total number of hospitals, i
ACE-FEDERAL REPORTERS, INC.
m,. m, s. - . m ..... ..o m
G 67 C 000 01 01 ms:rysimons 1 schools, nursing homes and adult homes which actually 2 participated in emergency planning exercises for the various 3 New York State plants.
4 'My question to you is really'what this sentence 5 means. Does it mean that every hospital, for instance, and 6 referring only to hospitals, does it mean that every 7 hospital participated in every' exercise for every. plant?
8 MR. ZAHNLEUTER: I would like to reiterate my 9 objection on the grounds of relevancy to these questions ,
10 about other nuclear power plants, and I'll make it a O 11 continuing objection.
12 MR. IRWIN: And it's a continuing objection to 13 this entire deposition I assume?
14 MR. ZAHNLEUTER: That is correct, and I will not 15 state it any more.
16 BY MR. IIsWIN:
17 0 Now you can answer the question, General Papile.
18 A (Witness Papile) Are you asking me the question?
19 0 I don't understand your answer, General Papile.
20 Road literally it seems to me to say that every hospital in 21 the emergency planning zone around every plant participated l 22 in every exercise for that plant.
ACE-FEDERAL REPORTERS, INC.
m m., s.m - u. o>,,,,,, .,m -
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(,j0000101 68 merysimons 1 A Are you asking me the question?
2 0 Yes, sir.
3 A What do you mean by " participating"?
4 0 Well, I don't know. You answered the question.
5 A Okay. What is your definitior. of participating?
i 6 0 What did you mean by your answer to this 7 question?
8 A The hospitals are called during every emergency, 9 and if it became necessary, then they would receive further 10 instructions.
O 11 0 And that's the definition of participation?
12 A That is my definition of participation. They are
{
i 13 put on standby and notified that there has been an emergency 14 declared.
4 15 0 But no patients are moved, for instance?
16 A In compliance with FEMA, we don't move patients.
i 17 0 Let's turn to schools, for a second. What does
- 18 that first sentence in this answer mean with respect to the a
19 participation of schools?
. 20 A That's a two-pronged answer.
21 0 Okay. Give me prong one.
22 A Prong ore is that all schools are notified either ACE-FEDERAL REPORTERS, INC.
- m. ,. m, s.e_ u, m..., mn_
( )000 01 01 69 mnrysimons 1 by tone alert -- mainly by tone alert at all our 2 installations.
3 No. 2 is we do exercise some schools by sending 4 school buses to the school with a FEMA observer selected by 5 FEMA again and then showing where those buses would go after 6 they received their instructions.
7 0 With the exception of those schools to which 8 buses are sent, the participation you are referring to is 9 notification either by phone or by tone alert?
10 A True.
11 0 With respect to nursing homes, can you tell you 12 what you mean by participation?
13 A The same way. Nursing homes are called by either 14 the hospital coordinator or the MSC coordinator at the EOC 15 and given the information about the incident or the exercise 16 incident at that time.
17 0 And once again it is telephone notification ---
18 A Telephone notification or tone alert also la 19 nursing homes.
20 0 And that's the extent of participation?
~s 21 A That's right.
(b 22 O ilow about adult homes?
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(_)000 01 01 70 msrysimons 1 -A Adult homes would probably'be the same way, 2 depending again upon each county. Each county has either 3 the Commissioner for the Aged or'someone from his office, if.
4 they have such an office, in the. county EOC and they would 5 notify the county adult homes. Some of the adult homes have 6- tone alerta also. I can't tell you for each county.
7 0 But, again, the participation is notification 8 either by telephone or tone' alert?
9 A Right.
10 0 Mr. Baranski, do you have anything to add to that i
11 answer?
i 12 A. (Witness Baranski) No, sir, I do not.
13 O Mr. Czech?
14 A (Witness Czech) No, I do not.
15 0 General Papile, are school districts in New York 16 State separate political entitles from the State government?
17 A (Witness Papile) As described to me, yes, they 18 are.
19 0 Is planning for them not necessarily the 20 responsibility of local governments?
r~g 21 A Restate that question, please.
V 22 O Is emergency planning for school districts not ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 800 336-6M6
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i,gf 000 01 01 71 mtrysimons 1 necessarily, in other words, can it be anything other than 2 the responsibility of-the local governments?
3 MR. ZAHNLEUTER: I object to the-form of that 4 question.
5 WITNESS PAPILE: I don't understand the question.
6 MR. IRWIN: Let me'show you a letter to Mr. Roger 7 Kowieski dated February 12, 1986 signed by you, or signed.by 8 someone whose signature purports to be yours.
-9 BY MR. IRWIN:
10 0 Let me ask you, first, whether you have ever seen O 11 this letter, sir?
12 A (Witness Papile) Of course, I wrote it.
13 MR. IRWIN: Let me mark this letter as Exhibit 3.
14 (The document' referred to was 15 marked Deposition Exhibit 3 for 16 identification and submitted 1 17 for the record.)
18 BY MR. IRWIN:
19 0 What was the reason you wrote this letter? ,
20 A (Witness Papile) There were two reasons. One 21 reason is complaining that we don't get all the guidance 22 memorandums. The second reason is that they asked me to ACE-FEDERAL REPORTERS, INC.
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-morysimons 1 review Guidance Memorandum EV-2, the original draft form.
2 We were commenting on the draft of EV-2 which was written in 3 the early part of 1985, and these were the comments 4 accumulated, amassed and so forth from the different 5 counties and from my staff.
6 O And the comment beginning in the third paragraph 7 which reads: "In reviewing Guidance Memorandum EV-2 it is
( 8 evident that FEMA is not aware that school districts in New 9 York are separate political entities and the planning for l 10 the school districts is not necessarily the responsibility iO 11 of the local governments."
l l
- 12 That was one of your comments, wasn't it?
l l 13 A That is what I wrote.
14 0 And the next sentence which reads: "Although the 15 guidance addresses the local government responsibility for 16 coordinating with school officials, there is no assurance 27 that school officials will adopt recommended emergency 18 procedures."
19 A That's absolutely true.
i 20 0 That's true State-wide, isn't it?
21 A I guess, I said it.
22 0 You have no reason to doubt that it was true?
l l ACE-FEDERAL REPORTERS, INC.
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000 Ol'01 73 marysimons 1 A It particularly pertains to the counties that I'm 2 concerned with.
3 0 Which ones are they?-
4 A The-seven counties. '
5 0 The seven counties ---
6 A .The four counties at Indian Point and the two ,
7 counties at Ginna and the one county at Oswego.
8 0 Do you believe that those counties are different 9 from any other counties in New York?
10 A I wasn't interested in what they ---
0 11 MR. LANPHER: I object to the question.
12 BY MR. IRWIN: 1 13 0 Do you have any knowledge that suggests that 14 those counties are different in this regard from any other 15 counties? l 16 A (Witness Papile) No.
17 MR. LANPHER: I object to the question. I don't 18 understand what you mean by "in this regard."
19 MR. IRWIN: I think the question was clear, but i
20 unless there be any confusion, the regard I was talking 21 about was in the independence of school districts as ;
22 separate political entities and there being no assurance l l
i ACE-FEDERAL REPORTERS, INC. !
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,j 000 01 01 74 carysimons 1 that school officials will adopt recommended emergency 2 procedures as per the comment.
3 As I understand it, General Papile, you have no
, 4 reason to believe that the seven counties with which you are
! 5 concerned particularly are any different from any other i
j 6 counties?
l j 7 WITNESS PAPILE: I really have no opinion on it, l
8 to toll you the truth. I wasn't concerned with it.
9 BY MR. IRWIN:
10 0 You woro just collating comments from all other
( 11 the Stato, in other words?
12 A (Witness Papilo) No, no, just from the sovon l 13 countion.
14 0 In other words, this is purely your opinion with 15 respect to only the novon counties?
16 A Lot mo answer it this way. This was portaining 17 to a question that I asked the novon countion only.
18 0 Would you look at the attachment to thin letter.
j 19 A Yos.
l 20 0 It's headed " Specific ce)mmonto Pocoived Prom l
21 Local Governments."
(-
x_,
j 22 A Sovon local governmontn.
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)0000101 marysimons 1 0 In other words, you didn!t consult with anybody 2 else?
3 A No.
4 0 Mr. Baranski, are you familiar with'schoo1~
5 ' districts in the counties with which you have a concern in 6! the scope of your job with REPG7 ,
l 7 A (Witness Baranski) Yes.
I 8 0 Are the comments ~which General Papile has made 9 with respect to the independence of Iccal school districts-10 and there being no assurance that school districts will O 11 adopt recommended emergency procedures accurate for your 12 counties also?
13 A I concur with Mt. Papile's comments.
14 0 Mr. Czech, with respect to school districts in 15 the counties with which you are concerned, do you concur 16 with Mr. Papile's comments as to school districts there?
17 A (Witness Czech) That they are separate political 18 entities, yes; that the local governments are not 19 necessarily responsible for'their planning, yes. In the 20 county that I'm most directly involved with, Orange County, 21 the school districts there have cooperated with the local 22 government and have developed emergency procedures.
AcII-FIIDliRAL aww, RIII',ORTliRS,..oINC.
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'( 000 01 01 76 marysimons 1 A (Witness Papile) And I would like to also say, 2 if I may, that in the seven counties we have found that-the 3 school authorities have generally cooperated, and not 4 because they'are required to, have cooperated with the 5 County Execs in coming up with the procedures.
l 6 0 Why have they done that?
l MR. ZAHNLEUTER:
7 Objection, speculation.
l , 8 WITNESS-PAPILE: I have no idea.
9 BY MR. IRWIN:
10 0 But the fact is that what you're saying is that iO
- 11 they are not required to, but as a general matter they tend 12 to cooperate?
13 A (Witness Papile) Yes.
l l 14 0 Is that your experience also, Mr. Czech?
15 A (Witness Czech) Mine is limited to Orange County l 16 and that's true.
j 17 0 And yours, too, Mr. Daranski?
I l 10 A (Witness Baranski) That is correct.
l l 19 0 Conoral-Papile, in the sovon counties with which l
I 20 you are familiar, do you believe that the statement in the 21 fourth paragraph of this letter, namely, that "The State of 22 New York has no doubt that in the event of an emergency l ACE-FEDERAL REPORTERS, INC.
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( O'00.01 01 77 marysimons'1 local.and school officials will implement the protective
'2 action option most compatible with the protection of school ~
l 3~ children in a potential general population evacuation."
l l 4 Do you believe that is an accurate comment.with l
l^ 5 respect to all those counties?
l 6 A (Witness Papile) Absolutely.
I l 7 0 Is that true for your county, Mr. Czech?
8 A (Witness Czech) For Orange County, yes.
I 1
9 0 Is that true for your county also, Mr. Baranski?-
l l
10 A (Witness Baranski) I am not responsible for a lQ 11 county.
12 O You are not responsible for any counties?
13 A That is correct.
14 0 You were at one point responsible for ---
15 A No, sir, I was not.
i 16 0 Okay. You've never been a county man. All l
17 right. I get lost in the bureaucratic maze.
18 (Laughter.)
1 19 0 Would you all look at Interrogatory No. 5 at the 20 top of page 6, please.
I 21 General Papile, I take it that the answer to this l
22 interrogatory suggests that the extent of participation in ACE-FEDERAL REPORTERS, INC.
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.(, 01 01 78 marysimons 1 the ingestion pathway aspects of an exercise for each of the 2 exercises within the five-year period'of interest is 3 accurately stated in the FEMA post-exercise assessment?
4 A (Witness Papile) As stated, if we were involved 5 in the ingestion pathway at all, it would be in the FEMA 6 after-action report or post-exercise assessment.
7 0 You say if we were involved in the ingestion 8 pathway portion at all. Has ingestion pathway been tested 9 at every exercise?
10 A To the best of my knowledge, no.
( 11 0 Has it ever been tested fully?
12 A To the best of my knowledge, it has not been 13 fully tested.
j 14 0 Has New York State ever deleted, to your 15 knowledge, a proposal by FEMA to test ingestion pathway 1
16 participation at any exercise during the period of interest, e 17 the five-year period of interest?
18 MR. LANPHER: I object to the question.
19 (Witnesses conferring.)
, 20 WITNESS PAPILEt I don't recall. But standing in r- 21 my position now, I would say that I would not accept any V) 22 objectives for the ingestion pathway because we do not have ACE-FEDERAL REPORTERS, INC.
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( ,;000 01 01 79 marysimons 1 the guidance memorandum on ingestion pathway as yet. FEMA 2 has yet to publish it, although they keep promising it to 3 us.
4 MR. IRWIN: Let me ask you whether you have ever 5 seen this letter, General Papile.
6 Let's mark it as Exhibit 4.
7 (The document referred to was 8 marked Deposition Exhibit 4 for 9 identification and submitted 10 for the record.)
O' 11 MR. IRWIN: This is a letter dated May 28, 1985 12 from Bruce D. McQueen, Acting Director of REPG to Roger 13 Kowieski. The second paragraph states: "The ingestion 14 pathway objectives have been deleted since these issues will 15 be addressed during a future ingestion pathway exercise."
16 BY MR. IRWIN:
17 O Does this refresh your recollection, General 18 Papile, as to whether any exercise ---
19 A (Witness Papile) I can't remember this letter.
20 I was in a little old county at this time.
r3 21 0 You were just a little old county man at that U
22 point. I l
i 1
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.m rysimons 1 Mr. Baranski, are you familiar with the exercise 2 negotiations that.this letter addresses a part of?
3 A (Witness Baranski) Yes, sir, I am.
4 0 And is this letter accurate in stating that the 5 State deleted FEMA's proposal to test various ingestion o 6 pathway demonstrations during that exercise?
7 MR. ZAHNLEUTER: Objection.
8 MR. LANPHER: I object to the question. <The 1 g7, 9 letter does' state anything of the kind.
10 MR. ZAHNLEUTER: That's correct.
1
(~)
11 MR. IRWIN: I would prefer for objections to be i
12 stated by whichever counsel is representing these witnesses 13 and for objections to be made through one lawyer if we can.
14 MR. LANPHER: I'm not representing these 15 witnesses, but I have an independent. opportunity to object,
, 16 Don.
1 17 MR. ZAHNLEUTER: And I will make an objection 19 when I feel it's necessary, and it happened that at that 19 time we did it simultaneously.
t 20 MR. LANPHER: I was first let the record show. '
21 (Laughter.)
22 (Discussion off the record.)
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l 2 0 Mr. Baranski,.what does this letter. address?..
3 A (Witness Baranski) Based on my; recollection 1of.
4 th'e discussions with FEMA,.the origin 51 set-of objectives 5' provided by FEMA to us.for this exercise included an
- 6 ingestion pathway objective. With negotiations and ,
7 agreement by FEMA the ingestion pathway objective was.
8 deleted from the Ginna exercise.
9 0 What was the reason given?
4- _ .
10 A Lack of federal guidance by FEMA on :the conduct 11 and requirements and scope for an ingestion pathway 12 exercise.
13 0 And I take it that the. reference to a future ,
14 ingestion pathway exercise was premised on: the future 15 issuance of such federal guidance?
16 A And the time requirement'in.NUREG 0654.
l- . . ,
- 17 0 The time requirement being?
18 A' Stating that an' ingestion pathway exercise must.
19 be. conducted once every six years.
-20 _0 Lets turn to recovery and re-entry aspects.of-an
~g 21 exercise. How is recovery and re-entry typically exercised
.a 22 and-what recovery 1and re-entry functions are. typically:
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- marysimons 1 . exercised?
2 A (Witness Papile) . Are you asking-me?.
3 0 I'll ask any one.of-you all.
4 A I'll say.a statement and then1I'11l turn it over.
5 At.a recent meeting with FEMA ~we were told not to consider -
I
{ 6 recovery and re-entry.
E 7 0 Why not?
i' 8 A- Because the'resis no federal' guidance on the-
~
9 objectives or the steps to be taken'.in' recovery and re-
- f. 10 entry. Until such time as we receive that. guidance, we have LO~ 11 not taken any objectives as such, except in the.first few i-
! 12 exercises that we-had we did list a few objectives and we ;
13 performed and received no,-to thefbest of my knowledge, any.
14 shortcoming,.but we did that on our own1 based upon the' i 15 document that was -- not a document,Lbut-guidance-that we.
2 16 used of a. general nature, guidance'of a' general nature for i
e <
, 17 recovery and re-entry for any emergency. We1 stopped doing -!
18 that after a few exercises'because we did not receive a'ny 19- guid'ance from FEMA.
-1
- 20 I'll turn it over'to' Jim now.-
1
~ 21 O Mr. Baranski?
7 J.
4 22 A -(Witness Baronski)' ife do not include a-recovery. j l
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.. 1000 01-01 18 3 l-marysimons 1 and re-entry - objective again because' we do not ;h' ave: any l' ~2 federal-guidance on what is required for-recovery:and re-3 entry.and what will be-graded on' recovery and re-entry. .;So-
- 4. we do not. include it-in our exercises.
5- O How long has this pract' ice ofenot including 6 recovery and re-entry been Tin effect'approximately? .
7 A Since I-have been Exercise Director in-
) 8- discussions with FEMA on the objectives, it's'been'since 9 that period of time because we are still waiting for' EPA l
10 guidance on recovery and re-entry, and FEMA has agreed with
)O L
4 11 us on deleting those objectiv'es. ,
l 12 O Do you'have anything to add to that, Mr. Czech? !
i 13 A (Witness Czech) Yes, we did.do an ingestion as
- 14 well as recovery and re-entry at least at:each of nur sites 15 during the initial go-rounds of exercises. The recovery and 3
16 re-entry portion was primarily at the' State level, and:it-I 17 was very much patterned after the' State's response:to any I . -
l 18 major natural or man-made disaster, convening a.recoveryL 19 committee, whatever steps were necessary for appointingithe ,
20 lead agency and beginning the-ball rolling as far as the t
'21 types of activities that would have to be done, Small.
~
22 Business Administration type loans and all the types of
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gj000 01 01 84 merysimons 1 things that governments normally would have to ch3 in 2 recovery.
3 Those were done in the early exercises at each of 4 the sites._ There weren't any standards as to what really 5 would lus tested and how far we would go on that, and in 6 subsequent exercises that has not been tested.
7 0 In those early exercises was a committee actually 8 formed or did the formation of the. committee consist of 9 discussions of whom the committee should consist of, for 10 instance?
( 615.WY f 11 A Actually both parts. In the early there was 12 discussion of who should be there, and since the State 13 Emergency Operating Center is actually manned by'all the key 14 State agencies, that actual group was convened to discuss 15 recovery and re-entry.
d 16 0 These were people who were actually right there 17 on the scene at the time I take it?
18 A That is correct.
19 A (Witness.Papile) I would like to add there that 20 at the county, since I was at a county at that time, the 21 1 County Exec did convene }s recovery and re-entry committee 22 and actually gave them jobs to do and times to report back ACE-FEDERAL REPORTERS, INC.
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- ( ,)000 01 01 85 marysimons 1 to him on their findings such as social services'and so
.2 forth and so on. Each agency.was given their information, 3 given a scenario type mission and then the exercise ended 49 y 4 'but they were report to him at certain time intervals on 4k ,
5 what was going on.
6 O And again these were people who were actually 7 present?
4 8 A These were the Commissioners that he has under 9 him. These were the actual people who would be in the 10 recovery and re-entry positions of responsibility.-
() 11 O And these county level actions were based on 12 again general emergency response, information and knowledge?
13 A Basically, claims and so forth and so on.
14 0 In other words, nothing extraordinary related 15 specifically to radiological fallout?
16 A Yes, there was. Go ahead.- !
17 A (Witness Czech) In the early exercises the 18 Chairman of the Disaster Preparedness Commission always <
19 required that the scenario continued on to include if there 20 was any deposition; in other words, the reactor always had-21 to be brought back to a stable condition. We just couldn't 22 end and say this is it. We always had to assume that there ACE-FEDERAL REPORTERS, INC.
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(,)000 01 01 86 marysimons 1 were some so many days or so many weeks of post-exercise.
> 2 We used to have to require a pattern as to what deposition, 3 if any, had taken place that we had-to radiologically close 4 out, and all that was' factored into the recovery and re-5 entry discussions.
6 O At the State level if you were to try to perform 7 recovery and re-entry functions at an exercise again, are 8 these functions basically generic at the State level? In 9 other words, do they vary substantially from site to site?
10 A (Witness Papile) Not in all cases. As Larry O 11 just explained, we would have specific radiological problems 12 with recovery and re-entry. We think we would, but we don't 13 have the guidelines for that since the. EPA has not approved 14 their guidelines on the protective actions to be taken. We 15 are still waiting for the guidelines.
16 But we think the Chief of our Bureau would take 17 certain steps and advise the Governor or the Chairman 18 accordingly.
i 19 O And you would use the existing State 20 organizations to perform those functions, I.take it? -
l 21 A- State or federal if the federal would 22 participate.
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U,a 000 01 01 87 marysimons 1 0 In any of the State exercises where you did 2 perform any kind of recovery and re-entry functions, did any 3 other states participate?
4 MR. LANPHER: I object to.the question. You 5 referred to it as being State exercises. I believe these 6 were FEMA exercises.
7 MR. IRWIN: Right.
8 WITNESS PAPILE: I don't know.
9 BY MR. IRWIN:
10 0 But you have no recollection that other States 11 participated?
12 A (Witness Papile) I would ask FEMA. Since FEMA 13 has told us they are responsible for other State activities, 14 that would be a good question for FEMA.
15 (Laughter.)
16 0 Mr. Czech, do you recall any States other than 17 New York participating in recovery and re-entry aspects of 18 exercises?
19 ' A (Witness Czech) In recovery and re-entry '
20 aspects, no.
21 0 llow about you, Mr. Baranski?
22 A (Witness Baranski) No recollection.
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88 V 000 01:01 marysimons 1 0 Coming back to ingestion pathway aspects of-2 exercises, to the extent'they have ever been tested, are 3 there'any exercises with which you are familiar,' General 4 Papile, in which protective action recommendations have been 5 extended te areas beyond.the 10-mile EPZ?
4 6 A (Witness Papile) I have no recollection one way 7 or the other. All I was ever interested in was the EPZ.
8 0 Mr. Czech, do you recall whether there have been 9 any exercises in which protective action recommendations j
l 10 have been extended beyond the 10-mile EPZ?
' () 11 A (Witness Czech) I believe so, and I believe it 12 would have been in Oswego County, and this is one that I 13 have to go on recollection, but it would probably be August 14 11, '82 Fitzpatrick.
15 0 Can you recall any others?
16 A The only one I recollect would have been in the
- 17 Oswego area.
18 0 Mr. Baranski, do you recall any?
19 A (Witness Baranski) I do not recall any.
I Is there anybody else in -- go ahead.
20 0 21 A (Witness Czech) May I add to that?
lO 22 0 Certainly.
i l
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,m b':000 01 01 89 marysimons 1 A I do believe we did have a Ginna exercise that 2 also included beyond the 10-miles during the course of 3 actual exercise participation.
4 0 For the Fitzpatrick exercise that you recall, Mr.
5 Czech, if you recall, what would have been the nature of 6 that extension beyond Oswego County or beyond the 10-mile 7 EPZ in Oswego County?
8 A In mileage?
9 0 No, the nature of the participation or the nature 10 of the extension of protective action recommendations.
0) 11 A It would have been protective actions for putting 12 animals inside and on stored feed beyond the 10 miles.
13 There also was I believe a protective action for sheltering 14 somewhat beyond the 10 miles.
15 0 Sheltering of the general population?
16 A The general population, that's correct. We also 17 had, and it's not in our list, but we also had the Ginna 18 Jncident where there was talk of protective actions beyond 19 the 10 miles, particularly in the early stages of even 20 though it was wintertime ensuring that cattle were not
(' 21 outside but on stored feed.
22 A (Witness Papile) I would like to say also in the ACE-FEDERAL REPORTERS, INC.
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h0000101 90 msrysimons 1 Ginna incident we actually collected samples and we tested'
-2 the samples.
3 0 Beyond the 10-mile EPZ?
4 A I don't know if it was beyond the 10' miles. -All 5 I'm saying is we actually collected samples that could have 6 been beyond the 10 miles. I was not privy to how far out 7 they went.
8 0 In the Fitzpatrick exercise in Oswego County, Mr.
9 Czech, and the recommendation for putting animals inside and 10 on stored feed, was this a recommendation which was actually V 11 implemented out there in the real world, or was this a 12 simulation of some kind?
13 A (Witness Czech) That was a simulation, but all 14 the other steps, the decision-making, the preparation of 15 news releases, identification of which areas were actually 16 going to the joint news center, went as far as, but not 17 including actually transmission of the EBS message.
18 0 What would have been the purpose of going through 19 all those steps? Was there any reason to have gone through 20 all those steps and stopping short of actually broadcasting 21 a recommendation?
22 A Could you recharacterize ---
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()0000101 91 marysimons 1 0 Sure, let me recharacterize it.
2 Was there a reason for having stopped short of 3 actually broadcasting a recommendation as to putting animals 4 on stored feed once inside? i 5 A Yes, because the objectives of the exercise would 6 have called for the transmission of the initial EBS test 7 message and probably -- not probably, but would have been 8 coincident with the sounding of the public alerting 9 notification system. '
10 The objectives would have stated that all O 11 subsequent EBS messages would be prepared and simulated and 12 not actually transmitted.
13 0 I take it the purpose of taking it up to the 14 point of transmission would have been to test the capability 15 of the organization to assimilate information and make 16 decisions and so forth?
17 A That's true.
18 A (Witness Papile) I would like to add there that 19 one of the primary goals of FEMA in the exercises is not to 20 interfere in any way with the public or the every-day 21 occurrences or to disrupt any agency such as bus companies 22 and so forth. The purpose is not to interfere by making a ACE-FEDERAL' REPORTERS, INC.
202-347 3700 Nationwide roverage 80113 % 6646
(,;000 01 01 92 marysimons 1 bus company incapable of doing a normal day's work or making 2 the farmer incapable of doing something, and we looked for 3 that very carefully to protect our public in their everyday 4 work, and that's the reason. If we had made the farmers put 5 their animals inside, it would take away from their normal 6 day's work.
0 Continuing again with the Fitzpatrick exercise 7
8 and the recommendation for sheltering of the general 9 population, I take it that also was a recommendation which 10 included the assessment of information, decision-making and 11 stopping short of an actual broadcast recommendation?
12 A (Witness Czech) That's correct, but that one 13 probably had a little more thinking behind it because the 14 guidance that goes out typically has been for certain 15 defined areas within the 10 miles. So it had to be very 16 carefully worded, and it was a little bit different than 17 what was preplanned for it.
18 0 One of you, and I believe Mr. Czech mentioned 19 that there had been some extension of protective action 20 recommendations beyond the 10-mile EPZ at one of the Ginna r"T 21 exercises.
V 22 A (Witness Czech) My memory was jogged. It was at ACE-FEDERAL REPORTERS, INC.
202-347-37m Nationwide Coverag 8tn336 M 46
h0000101 93 marysimons 1 the Ginna incident when there were discussions about 2 protective actions'within and perhaps a need for beyond the ,
3 10 miles.
4 0 And so far as you can recall, the one Fitzpatrick (
5 exercise and the Ginna incident are the two only times 6 protective action recommendations have been extended beyond 7 the 10-mile EPZ during this period of interest so far as you ,
8 call can recall?
9 A (Witness Czech) As far as I can recall, that's
, 10 true.
1 ( 11 A (Witness Baranski) That's correct as far as I 1
j 12 can recall.
I
! 13 0 And I believe, General Papile, you have said 1
14 that's true?
15 A (Witness Papile) Yes.
l l 16 0 General Papile, do congregate care centers i
17 typically participate in exercises for nuclear power plants i
l l 18 in New York?
)
19 MR. LANPHER: I object to that question.
l 20 WITNESS PAPILE: There's one word in there that I 21 want you to clarify for me.
22 MR. LANPHER: Could I state my objection so it's I
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)0000101 94 mnrysimons 1 on the record?
2 MR. IRWIN: Sure.
i 3 MR. LANPHER: I object to the question because I 4 don't understand what you mean, Mr. Irwin, by congregate 5 care centers. So the question is vague.
6 MR. ZAHNLEUTER: I object on vague grounds, too, 7 because I would like to know which exercises in New York you
] 8 are referring to.
9 MR. IRWIN: Well, I'll tell you what I will do.
10 I will refer the witnesses to Interrogatory Answer No. 6, 11 subpart (b) on page 7.
, 12 BY MR. IRWIN:
13 0 General Papile, Mr. Czech and Mr. Baranski, do 14 you see the first paragraph of that answer?
15 A (Witness Papile) Yes.
1 16 A (Witness Baranski) Yes, I do.
i 17 A (Witness Czech) Yes.
l 18 0 Is it an accurate statement then that the number 19 of congregate care centers which have participated in 20 exercises in New York can be obtained from FEMA post- ;
21 exercise assessments?
22 A (Witness Baranski) Yes, that is correct. L
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(j0000101 95 marysimons 1 O How do you define congregate care centers as you 2 meant that term in this answer, General Papile?
3 A (Witness Papile) A congregate care center is 4 that area which has been designated to receive personnel who 5 have been evacuated or other people, but mainly the evacuees 6 who have been taken to a shelter where.they have no other 7 shelter to go to to remain possibly overnight, to be f
8 clothed,to be fed and to be bedded down.
9 0 Mr. Czech, is that a usual definition from your 10 standpoint?
11 A (Witness Czech) That is the way I understand a 12 congregate care center.
13 0 Mr. Baranski, is that an accurate definition from 14 your standpoint?
15 A (Witness Baranski) That's accurate.
16 0 Using congregate care centers in that sense, and 17 based on your experience, General Papile, with exercises 18 conducted in New York during the past five years, how do 19 congregate care canters participate in exercises?
20 A (Witness Papile) Those congregate care centers 21 that do participate actually open and the Red Cross 22 appears. The Ped Cross either will show the evaluator what ACE-FEDERAL REPORTERS, INC.
M 347 37m Nationwide Coverage HaMh(M6
'(,,1000 01 01 96 merysimons I his plans are. The Red Cross will also show the entrance 2 and the exit, where the beds will be placed, how the food 3 will be received and the whole works. That is a matter for 4 the Red Cross. We leave that for the Red Cross. Our 5 evaluation is of the Red Cross.
6 0 Does the Red Cross require every congregate care 7 center designated for a given plant to participate?
8 A That is not a prerogative of the Red Cross.
9 That's FEMA again.
10 0 I'm sorry. Does FEMA require the Red Cross to O 11 open each congregate care center for a given plant or is 12 there a sampling?
13 A Up until this time they have not required the Red 14 Cross to open all congregate care centers.
15 0 You say up until this time. In other words, they 16 have never to date required ---
17 A That's what I say.
18 O To help me get an idea of how the Red Cross 19 operates, let me ask you all a couple of questions about 20 these congregate care centers.
21 Mr. Papile, in let's say the Indian Point 2 22 exercise in this year which is a recent exercise, can you ACE-FEDERAL REPORTERS, INC.
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.ig 000 01 01 97 marysimons 1 tell me how many congregate care' centers the Red Cross 2 opened in Westchester County?-
3 A I have no idea.
4 0 Do any of you have any idea?
5 A (Witness Baranski) I don't recall the exact 6 number.
7 A (Witness Papile) It is listed though.
8 0 In the FEMA post-exercise assessment?
9 A It should be. The reason is the ones required to 10 be opened had to have a FEMA evaluator there. It's up to A 11 FEMA again.
12 0 Is there any kind of rule of thumb or practice 13 with which you are familiar from FEMA?
7:
14 A FEMA does not have any simply & technique ,
15 whatsoever to the best of my knowledge.. They have no idea 16 and they do it based on some factors that I don't know, but 17 there is no sampling factor brought into it. When we 18 receive our replies it's usually an in toto-reply. The 19 sample that they use may be three or four, but there is not 20 a sampling technique, to the best of my knowledge.
21 So based on that, my answer on congregate care 22 centers, I don't now what system FEMA uses.
ACE-FEDERAL REPORTERS, INC.
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-(_)0000101 98 marysimons 1 0 In other words, I take it.your discussion of 2 FEMA's sampling techniques applies'to congregate' care 3 centers, but it's not limited to congregate care centers?
4 A- It's not limited to anybody.
5 0 Is that true in your experience also, Mr.
6- Baranski?
7 A (Witness Baranski) That's correct.
8 0 Is that true in your experience also, Mr. Czech, 9 with respect to FEMA's selection of sample sizes?
10 A (Witness Czech) I would say that's true.-
' O 11 (Witness conferring.)
12 A (Witness Papile) Jim just brought up something.
13 that I think I want to add to that.
14 0 Sure.
15 A FEMA endeavors to test different congregate. care 16 centers every exercise. Again, they endeavor to do it, and 17 they try to do it, but again it's not a sampling technique 18 to me. It's just that they like to get as many different 19 ones as possible.
20 0 Would it be fair to say that FEMA's process 21 involves common sense rather than statistical techniques? I 22 mean I'm just trying to get ---
ACE-FEDERAL REPORTERS, INC.
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99 h000101'01 marysimons 1 A I have no idea.
2 MR. LANPHER: .I object.to the question. I' don't 3 understand what you mean by common sense.- That' calls for 4 ' speculation.
5 MR. IRWIN: I-think common sense is a term we all 6 use in our everyday lives and'I'm not-sure it calls for any 7 speculation.
8 BY MR. IRWIN:
9 0 General Papile, does anybody from New York State 10 know before an exercise commences what congregate care O 11 centers will be activated by the Red Cross?
12 A (Witness Papile) I can't answer that question.
13 -I don't know.
14 A (Witness Baranski) Yes,.we do know which 15 congregate care centers will be' activated.
16 0 Does the Red Cross typically know also?
17 (Witnesses conferring.)
(Witness Baranski) 18 A Affirmative. The counties 19 and the Red Cross would be aware of which congregate care-20 centers are going to be opened, and_it's primarily a- ;
21 resource requirement.
l 22 0 How are they informed?
r . .
[
L ACE-FEDERAL REPORTERS, INC.
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Primarily through the county communication 2 chain. The county would notify'the Red Cross that we need 3 these congregate care centers activated for this exercise.
Co R ntW 4 O AndItakeitthecour.jpy would have communicated J 5 with FEMA beforehand or is FEMA aware of which' congregate 6 care centers will be opened?
7 A Yes, they are.
8 O So, in other words, FEMA and the county 9 -communicate and then the county communicates the information 10 to the Red Cross, or how does that ---
11 A Not correct. The State and FEMA communicate.
12 The State communicates to the county and the county 13 communicates to the Red Cross.
14 0 Typically how far before the exercise does the 15 Red Cross receive this information?
16 A They would have this information whenever we 17 receive confirmation from the number that FEMA has decided.
- 18 It varies in time based on FEMA's decision-making process.
19 0 Was that typically a matter of hours before the 20 exercise started?
21 A Oh, no. It's days. And I would like to add that 22 the reason for this during an exercise is the scheduling of ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800-3%M46
101 G 000 01 01 marysimons 1 the FEMA evaluators to monitor each one of these activities 2 as well as a State resource requirement for State 3 evaluators. And also we have to predesignate these 4 congregate care centers because of the impact on the normal 5 every-day activities.
6 0 With respect to reception centers used in 7 exercises can we look again at the answer to Interrogatory 8 6(b) on page 7, the second paragraph of that interrogatory.
9 There is a phrase there, "the theoretical capacity of 10 reception centers that participated in the exercises."
11 Do you all see that paragraph?
12 Now, General Papile, in that answer how did you 13 use the term " reception centers"?
14 A (Witness Papile) How did I use what? I didn't 15 hear you.
i 16 0 I'm sorry. How did you use the term " reception 17 centers"?
18 A A reception center in our definition is that 19 center location facility that would receive, register and 20 notify personnel who did not have a place to go which 21 congregate care center to go to. It's mainly to receive and 22 keep track of the people who have left the 10-mile EPZ.
ACE-FEDERAL REPORTERS, INC.
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marysimons 1 That reception center is only a staging area to forward
, 2 people either to congregate care or release.them to wherever 3 they wanted to.go, Aunt Mami's or any place they wanted to 4 go.
5 (Laughter.)
6 (Witnesses confor.)
l 7 In our reception conters this is the general 8 population only and not to include school children unless i 9 schools are out and they are going along with their 10 parents. Also, normally we co-locate the personnel
- (
)
11 monitoring contor at the reception center. We try to co- i c
l 12 locato it in order to clear the people before they left.
i 13 0 Mr. Baranski, is that a correct definition?
- 14 A (Witness Baranski) That is an accurate 1
5 i 15 statomont.
16 0 Is that accurato as far as you are concerned J
17 also, Mr. Czoch?
4 18 A (Witness Czech) Yes, it is.
19 0 In the answer to Interrogatory 6(b) there is a ,
j t 20 statomont that "The theoretical capacity of the reception
{
21 contors that participated in the exercisea identified in O 22 response to Intorrogatory No. 1 varied according to the ACE-FEDERAL REPOR1 ERS, INC.
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[v3000 01 01 103 mnrysimons 1 number of omorgency responso personnel deployed to the 2 reception contors."
3 What did you mean by that statomont, General 4 Papilo?
5 MR. ZAliNLEUTER: Excuse me, Mr. Irwin, if you 6 mean to explain what the meaning of that sentenco is, I
? think that's fair, but you misroad the first part.
8 MR. IRWIN: I'm sorry, I didn't mean to do that.
9 BY MR. IRWIN:
10 0 Taking those throo linos as they are written and 3
11 not as road by me ---
12 (Laughter.)
13 --- can you explain to me how tho theorotical 14 capacity of a reception contor varios according to the 15 number of personnel deployed?
16 A (Witnoss Papilo) Doponding on the number of 17 people that we havo working at the rocoption contor, if wo 18 have an influx of more people wo would put another team into 19 the rocoption contor. That's what our plan calls for.
20 Basically the rocoption contor will opon up with a team, and 21 lot's call it Team A, or Shift A. That team would arrivo.
22 If thoro was a backlog, then the county would have a ACE-FEDERAL REPORTERS, INC.
- x. >. ,,. s _ u. o_,. m ,-
l 3000 01 01 104 marysimons 1 supplementary means to put additional people in there to-l 2 take care of a mob situation or a crowded situation. That's L
- 3 what I mean by it.
I l 4 The theoretical capacity is based upon the' number l
l 5 of people that they can take, and that's exactly what I mean l
l 6 by that. >
t l
7 0 Lot me make sure I understand what you're talking 8 about. You're talking about the theoretical capacity being i 9 limited by the number ot monitors rather than by the l
10 physical capacity or configuration ---
11 A The physical capacity has nothing to do with it.
l 12 It has to do with the people who are working there, the l
l 13 registrar, the person who registors them, the person who .
l l 14 tells them where to go and different people within the i l
l 15 rocoption contor itself. The monitoring team, as I say, is ;
i 16 co-located, and that also. Wo can put another monitoring -
1
! 17 team in there. We could in a hurry put another monitoring i
18 team in thoro and have the monitoring team assist, or wo 19 could tell thom to go to another reception contor. We have l
20 communications with th* EOC.
l 4
l t 21 Normally tho' social sorvices will say we are l
l 22 getting crowdod, and wo would hope that they would tell the 1
l
! ACE-FEDERAL REPORTERS, INC. i 202 347 370) Naikinwkt,Coverase k n3 4 6646
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[j10000101 105 marysimons 1 traffic control point to tell.those people to have them to 2 another reception center that was not as crowded.
4 3 0 How would the general public be informed?
4 A They would be informed by the traffic. control q 5 point which we have located at the evacuation routes. We ,
4 6 would put it out in a message,_either a news release or more 7 likely an EBS message, either way.
8 0 Is there a rule of thumb you use'in relating the 9 number of emergency response personnel deployed at a given 10 reception center to the through put of evacuees coming i
! 11 through the center?
12 A We don't have a rule of thumb with the State, no.
I j 13 A (Witness Baranski) No, we do not.
I j 14 Q Do you understand what I'm getting to? In other l
] 15 words, do you assume that, for instance, a monitor can 16 monitor an evacuee in say 60 seconds or 5 minutes or any 17 given period?
18 MR. LANPHER: I object. Is that a question?
f 19 MR. IRWIN: I'm just making sure that they.
20 understood the concopt that I was trying to get at.
l 21 MR. ZAHNLEUTER: Is that your question, do you 22 understand the concept?
l ,
1 ACE-FEDERAL REPORTERS, INC.
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( $000:01 01 marysimons 1 MR. IRWIN: Yes.
2 MR. LANPHER: I object because they can't read 3 your mind.
4 BY MR. IRWIN:
5 0 Mr. Baranski, do you understand ---
6 A (Witness Baranski) Please restate the question.
7 0 Do you make any assumptions in determining the 8 number of personnel who must be dep'loyable at reception 9 centers about the rate at which they can process evacuees?
10 MR. LANPHER: I object to the question as vague O 11 because I don't know what you mean by " process."
12 MR. IRWIN: To satisfy Mr. Lanpher's objection, 13 although I'm not sure yours, I mean by " process".here 14 primarily monitoring.
15 MR. ZAHNLEUTER: Do you understand the question?
16 WITNESS BARANSKI: No, I don't.
17 BY MR. IRWIN:
18 0 How do you determine the number of people you" 19 need to monitor, the potential evacuees from any given power ,
20 plant site? What is the planning process involved with 21 that? Do you just cast a random number out in the air and 22 say that's good?
ACE-FEDERAL REPORTERS, INC. l 202 347 3700 Nationwide Coverage 2 336-6646
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107 marysimons 1 (Witnesses confer.)
2 MR. ZAHNLEUTER: Do you understand the question?-
3 WITNESS CZECH: I guess I'have a problem. You 4 are talking exercises or are you talking about planning 5 criteria?
6 MR. IRWIN: Let'sstartwikh'the~' planning 7 criteria and then I'll ask you if the exercises are any 8 different.
9 MR. LANPHER: I object in advance to questions 10 going to the planning criteria, and I won't interrupt you O 11 again.
12 BY MR. IRWIN:
13 0 With respect to meeting the planning criteria, 14 what factors are used in determining how many monitors'and' 15 other kinds of personnel you need at reception' centers to 16 handle the expected evacuee population?
17 A (Witness Czech) Your basis would be 0654.
18 0 And that includes what factors?
19 A That you have to monitor all potential evacuees 20 within 12-hour period.
21 0 How do you determine the number of potential 22 evacuees?
l ACE-FEDERAL REPORTERS, INC.
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%.)
merysimons l- A You would have to' determine the population within-2 the 10-mile emergency planning zone. That's your upper 3 limit.
4 0 Do you plan to be able to monitorL100 percent of 5 that population within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />? Is that your planning 6 basis?
~
7 A I would say that's our worst case.
8 0 Is that the case at Indian Point?-
f 9 A With four counties, I believe that's true.
10 0 What is the population approximately of the r'
11 Indian Point 10-mile EPZ?
12 A (Witness Baranski) About 270,000.
13 A (Witness Czech) Approximately.
14 A (Witness Papile) Yes, approximately.
15 0 Do I understand you then,-Mr. Czech, to be saying 16 that the planning basis for Indian Point is to be able to 17 monitor-270,000 persons within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?
18 A (Witness Czech) That's what .I said.
i 19 Q That's what I thought, and I just wanted to make 20 sure I understood. j
-l 21 A (Witness Papile) That's four counties.
7s O 22 Do you know whether that planning basis is in 0
l ACE-FEDERAL REPORTERS, INC. j 202-347 3700 Nationwide Coverage 800-336 6646
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r.
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llg00000101 109 marysimons 1 fact achieved by the resources which.are-stated.in the 2 Indian Point plan?
4 31
~,n
, A I can't answer definitely,:but we. hope'it' is.
4 O Is that the' planning basis you use at every E 5 plant, 100 percent'of the EPZ population.within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />?
6 A .I think the question is answered. We have to.
7-- '
plan on that, yes, but in the actual' thing'de:would only do
~-
8 those people who were in the plume, but we'still take the.
4 9 worst case planning.
10 0 In other words, you would have enough monitoring
/~')
k/ 11 equipment available to accomplish this?
12 A We hope.
13 0 Well, what do you mean when you say "we hope"?
7 14 MR. LANPHER: I'm sorry, I didn't hear the answer 15 to that question?
16 MR. IRWIN: He said "we hope."
17 WITNESS PAPILE: 'I'said it to myself.
18 ,1 .
(Laughter.)
e s 19 ,i WITNESS BARANSKI: I would just like to follow up 20 ,
with an additional piece of information that during the. FEMA 21 3 review process of the country plans they will look at the x> k;~ '
22' number that is available and give us feedback if there are 3
'i
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.'(o?000 01'01 marysimons l- insufficient numbers. So it's a FEMA review process as well 2 in' determining this capacity.
3 BY MR. IRWIN:
4 0 And your blans provide,;say again-at Indian 5 Point, an indication of the number of personnel who would be 6 available to perform monitoring for the Indian Point EPZ so 7 that you could make a evaluation, in your judgment?
8 MR. LANPHER: I object to the question. I don't 9 understand it.
10 MR. IRWIN: Does the witness understand the 11 question?
12 WITNESS BARANSKI: Please say it again.
13 BY MR. IRWIN:
14 O As I understand-your last answer, FEMA reviews 15 whatever information you provide and decides whether or not 16 you've got adequate resources.
17 Do the plans for Indian Point state, for 18 instance, the number of personnel who will be available for 19 monitoring of the four-county reception centers for Indian 20 Point?
21 A I can't answer that.
22 WITNESS CZECH: Could you rephrase that question l
l ACE-FEDERAL REPORTERS, INC.
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g0000101 111 masysimons 1 or restate it?
2 MR. LANPHER: ' Why doesn't-the reporter read it 3 back.
4 (The question was read by-the reporter.)
5 WITNESS PAPILE:- I'm going to say something now, 6 that I think the question is moot. I think that the 7 question you're asking, if the-occasion arose where we would 8 have to evacuate the whole EPZ, I don't know what protective 9 action would be recommended, whether it would be to evacuate 10 or not.
11 I'm not sure, also, whether if that protective 12 action is taken to evacuate the whole EPZ that the counties 13 can't take care of it.
14 BY MR. IRWIN:
15 0 So you are not sure they could?
16 A (Witness Papile) Can't take care of it.
17 0 Can or cannot?
18 A Cannot take care of it. FEMA has to look at.
19 this, and to the best of my knowledge, I have not received 20 any comments from FEMA on this issue that I know of. So I 21 stand by what PEMA says in this case unless they 22 specifically state that we can't handle it, but up until ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Coverage 8 @ 336-6646
g000-0101 112 marysimons 1 -this time I have not heard specifically, and'I may be wrong, 2 but-I have not heard'specifically that we can't-take care of 3 it.
4 0 In-short, unless' FEMA objects to the capacity or 5 resources that they can glean from your plans for taking 6 care of evacuees, your assumption is that they.are 7 satisfied?
8 A It's not an assumption. They have the authority _
9 for 350 approval which we look for. This is based on 350 10 approval.
11 O You infer from tho' absence of complaints that 12 they find your plan satisfactory in this regard?
13 A I don't infer from it. I can't infer from it. I 14 take it as fact if that comment isn't made that they are not 15 going to question us on the 350 approval.
16 0 Whatever the resources deployed in the plan may 17 be, if they buy off on it, that's acceptable; is that right?
18 A All I'm saying to'you is that if FEMA doesn't 19 question us on it, the facts that we have in the plan, which 20 should include the equipment and the personnel available, I 21 accept the comments by FEMA.
22 0 Do you know whether the Indian Point plans, for ACE-FEDERAL REPORTERS, INC.
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mnrysimons 1 instance, state the number of personnel, whether from the 2 county governments, from the utility, from resources 3 available through INPO or the Federal Government or anywhere i 4 else who are available to perform monitoring functions at 5 the reception centers located in the four counties?
6 MR. LANPHER: I object to the question. It has 7 already been asked in a different form.
- 8 MR. IRWIN
- I don't think it was' answered.
9 MR. ZAHNLEUTER: If you know.
10 WITNESS PAPILE: Ask the question again.
11 (The pending question was road by the reporter.)
! 12 (Witnesses confer.)
13 WITNESS PAPILE: To the best of my knowledge, the 14 counties do have a list of people who are available, the i
15 county's people who are available for monitoring.
16 BY MR. IRWIN:
17 0 When you say the county's people, you mean county 18 employoos?
I 19 A (Witness Papile) County people, volunteers or i
20 employees.
4
, 21 0 Is that list available to PEMA?
1 22 A To the best of my knowledge, FEMA has that list.
. . ACE-FEDERAL REPORTERS, INC.
202 347 37m Nationwide Coverage 80(k336 6M6
I'v3000 01 01 114 marysimons.1 To the best of my knowledge, I don't'know. To the best of.
2 my knowledge and in recollecting, I think FEMA has to have 3 the list.
4 0 Mr. Baranski,'do you'have.anything you can 5 contribute to helping me understand how FEMA decides whether 6 or not there are enough monitoring personnel available to 7 meet the planning basis for an accident for the population 8 of the EPZ surrounding a nuclear power plant?
9 MR. ZAHNLEUTER: Objection. ,
10 MR. LANPHER: I object to the question. . 'It calls O 11 for speculation. You have already had your opportunity to 12 - depose FEMA and you didn't ask those. questions then.
13 MR. IRWIN: That's fine. If the witness 14 understands the question he can answer it.
15 WITNESS BARANSKI: No, I do not have knowledge of 16 FEMA's criteria.
17 BY MR. IRWIN:
18 0 Do you, Mr. Czech?
19 A (Witness Czech) No, I don't.
20 0 Now let's go to the oxorciso since wo 21 distinguished a little while ago betwoon the planning basis 22 and the oxerciso.
ACE-FEDERAL REPORTERS, INC.
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'w; 01 01 115 marysimons 1 Is-there a distinction between the planning basis 2 and an exercise for purposes of deployment monitoring 3 personnel, Mr. Czech? You are the one who drew the 4 distinction.
5 MR. ZAllNLEUTER: A clarification. Which exercise 6 are we discussing?
7 MR. IRWIN: We are discussing exercisos 8 generically and we are discussing the distinction Mr. Czech 9 drew a few minutes ago.
10 MR. LANPilER: I object to the question as vaguo.
11 MR. IRWIN: All right. You can answer the 12 question if you can, Mr. Czech.
13 WITNESS CZECil I would say yes because one of 14 the things with an exercise and the guidelines from FEMA is 15 that wo don't disrupt normal government. So, for example, 16 if we take County "X" that has a radiological program within 17 their county there are certain jobs that have to be 18 ongoing. So to strip ovorybody out of that to participato 19 in an exercise would not be advisablo. So thoro has to be 20 some sort of a balance drawn betwoon what can bo dono during fs 21 an oxorciso and what you might do during an omorgency, that I i V
22 you have to allow for some of the ongoing programs to ACE-FEDERAL REPORTERS, INC.
202 347 37(X) ?eatkmmide Coverage 8@))MM6
116 h0000101 ,
marysimons 1 continue.
2 BY MR. IRWIN:
3 0 Are the number of personnel who are to perform .!
4 their roles at reception centers agreed upon prior.to an 5 exercise between State / Counties on the one side and FEMA on 6 the other? l 7 A (Witness Czech) The actual numbers, no, as far 8 as I know, but the functions that would be performed, yes.
9 0 At what point are the actual numbers datormined?
10 llow do you know whether an exercise is going to require zero O 11 monitors or 100 monitors?
l 12 A I don't believe that question has ever come up.
13 0 Well then how do you know that the' number of 14 people who happen to show up at a reception conter is 15 adoquato in an exorciso?
16 MR. LANPilER: Excuso me, " number of people"?
17 MR. IRWIN: I'm sorry, your right, number of 18 personnel.
19 MR. LANPilER: Can you start the wholo question 20 over.
21 BY MR. IRWIN:
22 0 llow do you know that the numbor of monitoring ACE-FEDERAL REPORTERS, INC.
202 347 37ts) NMionwide Coverage WN))M(iM6
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marysimons 1 personnel who participate at reception centers.as monitoring 2 personnel for an exercise is going to be considered adequate by FEMA? '
3 4 MR. LANPHER: I object to the question. It .
5 assumes that that is something that is being evaluated, that 6 the number are adequato.
7 WITNESS BARANSKI I would like to add something 8 to this. If the objective is written to demonstrate 9 staffing and adequacy of a reception center during an 10 exorcise, the FEMA ovaluator will go in and look at the 11 staffing and adequacy of that center and ask the questions 12 to the people at that reception centor about capacity, and 13 based on his or her ovaluation will make the determination 14 of whether that reception center is adequate or not.
15 (Discussion off the record.)
16 BY MR. IRWIN:
17 0 Mr. Baranski, lot me make sure I understand your 18 last answer. Look at the response to Interrogatory 6(c) for1 19 a second at the bottom of pago 7 and the top of page 8, the 20 sentonco that begins "Tho number of personnel that was used 21 during the oxorcise," et cetora, and continues down through 22 that carryover paragraph. That answer talks about ACE-FEDERAL REPORTERS, INC.
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carysimons 1 variations in the number of personnel varying with the 2 exercise objectivos.
3 Is that essentially the process you were just 4 referring to in your last answer?
5 A (Witness Baranski) That's part of it.
6 0 What also?
7 A Just to reiterate what I said, is that the FEMA 8 observor will go in and look at the staffing requirements at 9 the reception contor or reception contors being activated, 10 look at their rosters to see whether they have the b'
x- 11 capability of say 24-hour coverago if nood be and look at 12 the number of trained monitors for that particular f acility ,
13 trained registrars and so forth, and then mako the 14 datormination based on the exorciso scenario whether that 15 facility had the capability to process the people.
16 A (Witness Papilo) I would like to add that they 17 also look at the equipment.
18 0 Lot me ask you about the equipment in one 19 second. In looking at the same intorrogatory answer, 6(c),
20 the first paragraph refers to a particular kind of s 21 monitoring devico, the CDV-700 monitoring devico. I tako it b 22 that dovico is in uno in some plants at least in the Stato ACE-FEDERAL REPORTERS, INC.
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01 01 119 Carysimons 1 of New York?
2 MR. LANPilER: I object on the grounds of 3 rolovancy.
4 MR. IRWIN: Can you answer the question?
5 MR. LANPilER: I have a continuing objection on 6 relevanco.
7 WITNESS PAPILE: I don't know the question.
8 MR. IRWIN: I'm sorry. Wo koop getting 9 objections on ovory question and ono losos the thread after 10 a while. ,
b)
U 11 BY MR. IRWIN:
12 0 I tako it the CDV-700 monitoring devico is in uso 13 at least in some plants in the Stato of Now York?
14 A (Witness Czech) On sito?
15 0 No, for off-sito monitoring of ovacuoos.
16 A Oh, that's correct. For off-sito monitoring, 17 yes, that's truo.
18 0 It is in universal uso or are thoro other plocos 19 of equipmont that are also used?
20 A Universal in Now York Stato and I would say that c 21 that is protty much the standard instrumont of choico for 22 monitoring of personnel and vehiclos in the sovon countios ACE-FEDERAL REPORTERS, INC.
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2 0 In the sovon counties that you personally deal 3 with.
4 A And I should add the throo host counties of 5 Jefferson, Orango and Dutchoss.
6 0 Do you know how long that ploco of equipment has 7 boon in uso?
8 A Por many years, but exactly I don't know. They 9 also are calibrated. Tho ones that are used to support the 10 nucioar power plant omorgenclos are brought in and 11 calibrated on an annual basis by the Stato Emergoncy 12 Managomont Offico staff.
13 A (Witnoon papilo) That picco of equipment is 14 approved by FEMA.
15 A (Witnono Czoch) Right.
16 0 In tho gonoral population evacuation aspect of 17 omorgoney planning oxorcinos are evacuation bunos comotimon 18 run on routon through various portions of the CPZ?
19 A (Witnano Baranaki) That's affirmativo.
20 0 I recall you naying earlior in the day that tho 21 companion which are to provido thono bunos aro agrood upon k_)s 22 prior to tho oxorcino.
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t 3000 01 01 121 carysimons 1 A That's correct.
2 O Are the number of buses to be provided by each 3 company typically agreed upon prior to the exercise?
I 4 A That is correct, to minimize the impact on normal l 5 operations.
t l
i 6 0 It is not the case that all of the bus routes 7 designated in a plan are run during the course of an 8 oxercise?
l i 9 A That in correct. .
! 10 0 Either by busos or by other vehicles?
l ~
l 11 A That is correct.
12 0 In the exercisen with which you have involvement, 13 Mr. Baranski, have all of the bus drivers provided for in '
l I
j 14 the omorgency plan been mobilized as oligible to run bus.
i I 15 routes in just a sample of them mobilized?
{
16 A In the exercisos that I have been associated with 17 it has boon a sampling. However, the FEMA ovaluator will 18 look for the number of trained drivers, the list for ,
19 available drivers and so forth f ran each respective l 20 dispatcher at the facility that wo are involved with.
l o 21 22 MR. LANPilER:
You woro talking about general population bus drivers still Could I ask for a clarification?
1 l
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merysimons 1 in this line of questions?
2 MR. IRWIN: That's correct.
l 3 MR. LANPilER: Thank you.
4 BY MR. IRWIN:
5 0 So thoro might be a list calling for a rostor of 6 100 trained drivors and only say 20 of them might bo i
7 mobilized, but the FEMA inspector would look at the list to
(
8 mako suro that ---
l 9 A (Witnosa Baranaki) That is correct.
10 0 Whon are the 20 drivers who are in fact mobilized 11 told that they aro in fact going to be among the onon who 12 are mobilized?
13 A It han boon my experienco that they havo not boon l 14 pronolocted bocauno of the fact that it's a froo play for a l
15 particular routo and the availability of drivers at any l 16 particular timo, doponding upon whon tho oxorcino routon oro l
17 conducted during tho courso of a day, will datormino which 10 drivorn aro availablo, and to tho bont of my knowledge wo do l
l 19 not pronoloct driver A, B, C and D to participato tho day of 1
! 20 tho oxorcino.
l 21 0 llow than in a nampling arrived at? Do you just l
l 22 tako the fient 20 guys who show up? In other wordn, if you ace-FEDERAL REPORTERS, INC.
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marysimons I have a roster of 100 people and only a sample is to be 2 taken, how is that sample determined?
3 A FEMA will determine the number of buses to be t 4 dispatched and the number of. routes to be run. It is when 5 the responsibility of the participating bus company to 6 ensure that on the day of the exercise, that they are aware 7 that their bus resourcos are going to be committed for four ;
8 runs for an exorcise. So then their responsibility is to 9 onauro that when they are notified during the course of the 10 exciso that they are able to get bus drivers to drive the 11 busos that are qualified to do the runs.
12 0 The bus companies havo to ensure that they have ;
13 got ---
14 A Staff available. I I
15 0 That involvos some kind of assurance that they've 16 got "X" number of personnol not otherwise committed at a f
17 given timo, doesn't it?
10 A Yos, you have to have some. Not to interrupt i
19 normal day-to-day activities you have to have an excess. .
20 0 And that's not pronotification? l 21 A It's not prosolection of the drivers. .
O 22 0 ta it your testimony then that drivers have never ACE-FEDERAL REPORTERS, INC.
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l 124 C30000101 morysimons 1 been presolected for mobilization in exercises?
2 A To the best of my knowledge, I am not aware of 3 presolection of bus drivers by companies to perform specific 4 activities during an exercise.
5 0 Is that your experience also, Mr. Czech?
6 A (Witness Czech) That's true.
7 0 In other words, bus companies are simply told we 8 are going to need "X" number of drivers to run routes ---
9 MR. 2AHNLEUTER: Objection, asked and answered to 10 that question. You can answer it again.
11 WITNESS BARANSKI Again, the bus companies are 12 notified that they are going to be required to perform "X" 13 number of runs with "Y" equipment. During the course of an 14 oxorciso they would be notified to perform "Z" routes. So l
15 then it becomes the responsibility of the bus company to get 16 "X" driver into "Y" bus to run "Z" route.
17 BY MR. IRWIN:
18 Q And from within that samplo of "X" drivers, "Y" 19 oquipment and "2" routos PEMA then observes some subset 20 typically?
21 A (Witnoss Baranski) That is correct, which they 22 have dotormined by froo play.
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morysimons 1 0 Is that true also for ambulance'and ambulette l
2 drivers, the same selection process?
l 3 A We do preselect a company and depending upon the l
l 4 availability of personnel will determine. the people thati l
5 participate for that particular time-during an exercise.
l l 6 0 And again the company is told we will'need "X" l
7 number of pieces of equipment and it's their responsibility 8 to ensure that they have adequate drivers?
I 9 A You just threw in a little phrase here of
{
l 10 preselected equipment. We do not tell them which equipment 11 they have to run to perform that particular mission, but 12 they are aware that some of their equipment may be called-13 upon to perform a particular mission.
14 0 Are they instructed not to tell specific 15 personnel that they will be needed to perform this mission l 16 during an exercise?
l l
t 17 A I have no information on that issue.
I 18 0 Is that true also for bus companies? In other l
l 19 words, you have no information whether the bus companies 20 tell a given driver he is going to be needed for a FEMA l 21 exercise or not?
l (2) l 22 A I don't have any information on that.
l l
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.(~'/1000 01 01 126 marysimons 1 0 With. respect to school bus drivers:can you 2 describe for me the~ process by which the number of drivers 3 -who will be required and the. amount of equipment and so 4 forth is arrived prior to the exercise?
~
5 A In our discussions with FEMA we determine the 6 number of bus routes to be run. We then determine the 7 . equipment that has to complete that run. The particular 8 . organization is made aware that their resources are going to 9 be tapped the day of the exercise and whether they-are going 10 to.have to run with a 60-passenger bus, a van or whatever.
11 0 And how many of them I take it?.
12 A And how many of them, and that FEMA will be there 13 observing these particular drivers.
14 Now on any given day you may have drivers that 15 are sick, that are on days off or on extra' runs. Fo it's 16 very difficult to try and preselect drivers, and we do not 17 preselect, to the best of my knowledge, preselect 'd rivers to 18 perform those particular runs. This is left up to the bus 19 company and the dispatcher on the day of the. exercise.
20 0 Do you have any procedures or practices with 21 respect to telling bus companies whether to preselect 22 drivers or not?
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g0000101 127 marysimons 1 A No, we have no procedures for that.
2 O With respect.to traffic control personnel, I take 3 it that a given number of personnel will be agreed upon to 4 man traffic control points typically within~an EPZ as part 5 of the exercise preparation? In other words, "X" number of 6 traffic control posts will'be designated to be manned in 7 advance; is that right?
8 A During my period of time, that is correct.
9 O And those specific points are agree upon in 10 advance?
(")
k' 11 A That is correct, the number of people that will 12 be deployed to establish traffic control points.
13 (Witnesses confer.)
14 Let me say that we will determine that we have to 15 establish a given number of traffic control points. The 16 particular control points to be established are free play by 17 FEMA the day of thc exercise.
18 0 When you mobilize personnel to man the traffic 19 control points during an exercise, do you typically mobilize 20 only that number of personnel required to man the number of 21 points designated by FEMA or do you mobilize personnel to p),
\m 22 man all traffic control points throughout the EPZ?
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/ 2000 01 01 128 marysimons 1 A We mobilize people to meet the number that was 2 required by the objectives by FEMA during an exercise.
3 (Witnesses confer.)
4 And basically the reason that that is agreed upon 5 with FEMA is to minimize the impact on routine activities.
6 I think you can see that if you started deploying the 7 resources from one particular law enforcement agency that 8 you could very easily deplete it down to the point of having 9 an impact on the public health and safety. That is not to 10 say that they are not capable of establishing these traffic n
11 control points if needed.
12 However, we normally just establish the ones that 13 FEMA has required to be established, and here again the FEMA 14 evaluator will check and ensure that if we have a number of 15 control points listed in the plan that there are resources 16 available to man them.
17 0 So just to take a hypothetical example, if you 18 have 100 traffic control points within an EPZ and FEMA has 19 told you that they wish 20 of them to be manned during an 20 exercise, the number of personnel who will be mobilized will 21 be only those necessary to man those 20 points; is that 7-)
(_)
22 right?
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1 2000 01 01 129 marysimons 1 A That is correct.
2 A (Witness Czech) May I add to that?
3 0 Certainly.
4 A I don't think that is quito correct. It would bo 5 at least 20 and probably more because you may have more than 6 20 law enforcement agencies within an EPZ that aro 7 responsible for manning the traffic control points. Wo 8 don't know ahead of time which traffic control points. Wo 9 know the number. So you are going to have to have at least 10 the 20 team of law enforcement peoplo to do, but as I say, 11 you don't know which -- if thoro are 50 law enforcement 12 agencies, you're not sure which ones are going to be i
13 selected by FEMA. So it would be at least 20 and probably 14 much more.
15 0 Okay. But you don't automatically mobilize all 16 the personnel necessary to man all the traffic control 17 points throughout the EPZ?
18 A That's correct.
19 MR. IRWIN: I said 12:30 would be a good timo to 20 break for lunch. It's exactly 12:30 and this would be a 7, 21 good time to break for lunch.
(
22 (Whorcupon, at 12:30 p.m. the deposition ACE-FEDERAL REPORTERS, INC.
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130 (v' 000 01 01 Carysimons I recessed, to reconveno at 1:30 p.m., the same day.)
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17 10 19 20 l
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c rynimons 1 AFTERNOON SESSION 2 (1:35 p.m.)
3 Whorcupon, 4 JAMES CONRAD HARANSKI 5 JAMES DOMINIC PAPI!E 6 and 7 LAWRENCE B. CZECil 0 ronumod the ntand and, having previously boon duly sworn, 9 woro oxaminod further and tontifiod as follown:
10 EXAMINATION (Continuod) n v 11 IlY MR. IRWIN:
12 0 Contiomon, would you all look at the annworn to 13 Intorrogatory 60, roforring to monitoring and 14 docontaminating ovacuuon from nurning and adult homon. In 15 the ftrat nontonco of that annwor thoro in tho ntatomont 16 that, "New York Stato pornonnol did not monitor or 17 docontaminato ovacuoon from nurning and adult homon." Do 10 you noo that ntatomont? Wan thoro monitoring or 19 docontamination of ovacuoon from nurning and adult homon 20 conductod by anybody during any of tho oxorcinon during tho 21 porlod of intoront; in other wordn, pornonnot olhor than 22 ntato pornonno17 AcII-Fl!Dl!RAl. Ri!PoRTlias, INC.
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IV'2000 01 01 132 carysimons 1 A (Witnons Papilo) Wo do not ovacuato anyono in an 2 oxorcino from olthor a nursing homo -- FEMA doon not requiro 3 us to evacuate from a nursing home or a hospital during one l 4 of our exorcinou. To the boat of my knowledgo, wo havo l 5 nover had to do that.
l 6 0 All right. In tho exorcinos conducted during tho l
l ,
7 fivo-yoar portod of interest, gontlemon, havo impodimonto to I
0 ovacuation routon over boon required to bo or han tho 9 ability to don 1 with impodimonto to ovacuation routon over 1
l l 10 boon requirod to bo demonntratod?
) 11 A You.
! 12 A (Witnoon Barannki) Yon.
13 0 llow havo thono demonstrations boon mado? What 14 han boon the nature of the ronponno requirod? l 15 A In the oxorcinon that I havo boon conponniblo 16 for, our traffic impodimonts havo, number ono, occurrod in a 17 timo naquonco nuch that the gonoral population was boing 10 ovacuated on a particular routo bocauno of the neonario.
19 Humbor two, wo woro requirod to domonntrato runourcon That 20 actually boing doployod to that traffic impodimont.
1 21 monnn polico, firo, ambulanco, public works. l 22 0 llan rorouting of traffic from one ovacuation ace-FliDERAL Rl! PORTERS, INC,
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corynimons 1 route to another because of the impediment ever been l 2 required to be demonstrated, to your knowledge?
3 A That, that particular function, the rerouting has l 4 never been an objective. But it- follows that if there is an I
l 5 impediment on an evacuation route, good decision making l
6 would consider that and, if necessary, reroute it, and in 7 fact that has occurrod.
8 0 You say in fact that has occurred. How has that 9 occurrod?
10 A In the Indian Point oxorcise June 4, we had a 11 traffic impodimont on a major ovacuation route. The 12 ovacuation was blockod. The decision makers evaluated that 13 tiipedimont and rorouted the traf fic, and through the EBS 14 notwork and the drint news center, alerted the public and 15 put out information to coroute that flow of traffic.
16 0 Han corouting of traffic occurred prior to that I
17 oxercito and any of the other oxercisos during the period of F
18 intorost, to your knowledgo? ,
i 19 A Yos, it han. ,
20 0 What other oxorcinos?
21 A Tho Ginna oxorcise. I
!(
i
! 22 0 Would you doncribe what happened thoro?
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! COrysimons 1 A I do not recall the exact rerouting process that 2 took place, but those exercises did include traffic 3 impediments on the major evacuation routes that were being 4 utilized as part of the scenario.
5 0 Was the rerouting reself a portion of the 6 objectivos of the exercise at Ginna?
7 A I did not have a specific objective to say 8 demonstrate the capability to reroute traffic because-of a 9 trafftc impediment.
I 10 0 I'm sorry. You're referring to the Ginna 11 exerciso?
! 12 A Right. At the Indian Point exerciso in 1986 was 13 that rorouting the result of an exercise objective?
1 l 14 A That's affirmative. It was.
l 15 0 At that oxorciso it was?
l 16 A Right.
l 17 0 That's the only exorciso, I take it, at which you la are awaro that thoro was such an objectivo?
19 A Lot mo mako it clear. At the Indian Point l 20 oxorciso the traf fic impodimont required rorouting. Thero l
21 has novor boon an oxorcino that I havo boon responsibio for 22 that has had a specific objectivo that says demonatrato the ACE-FEDERAL REPORTERS, INC.
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01 01 135 merysimons 1 capability to reroute traffic because of a traffic.
2 impediment.
3 MR. ZAHNLEUTER: Off~the record.
s 4 -
MR. IRWIN: Yes.
~
5 (Discussion off the record.)
6 BY MR. IRWIN:
l 7 0 Let's try it again.
8 A (Witness Baranski) There have been objectives to 9 demonstrate the capability to deal with a traffic 10 impediment. It follows that dealing with'a traffic 11 impediment, if it involves a major evacuation route, that 12 the decision makers would consider that and establish a 13 rorouting of the traffic ~ flow. That has occurred'at the 14 Indian Point exercise and at the Ginna exercise that I am 15 aware of.
l l 16 What I said was that there never has been an i
17 objectivo that specifically states demonstrates the 18 capability of rerouting of traffic because of a traffic 19 impedimont. Ilowever, there have boon objectives to 20 demonstrate the capability to deal with a traffic
- 21 impodimont.
22 0 Do you know whether FEMA has ovor requested'New
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marysimons 1 York State to_ include _as part of an: objective the capability 2 to reroute' traffic explicitly from an evacuation route?;
3 A (Witness Baranski) We have.never been required 4 to write a specific objective that would demonstrate the s
5 capability of rerouting. . However, it follows from every
,6 . traffic impediment that that would occur'in the normal 7 decision-making process.
8 0 Have you ever been requested by FEMA -to include 9 such an objective?
10 A No.
O 11 0 Let me ask you if you are familiar with a letter 12 dated May 24, 1983, from Mr. McQueen to Mr. Kowieski, which 13 will be Exhibit 5.
14 (The document referred to was 15 marked Deposition Exhibit 16 No. 5 for identification and 17 submitted for the record.)
18 (Pause while witnesses examine the document.)
19 BY MR. IRWIN:
20 0 Have you all heard a chance to review the 21 document?
22 (No response.)
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. o, merysimons 1 Q Hearingtnobody say no, I assume that everybody ry x y- 2 has had a chhnce t'o look .at _this letter.
3 Mr. Pah[13,haveyoueverseen'thisletterbefore h -
- '[
.4 today? i x -
No, I haven't.
5 A r (Witness Papile) s, 6 0 Have you,'Mr. Baranski? ~~
7 A (Witness Papile) Not to the best of my 8 knowledge.
9 0 okay.
J 10 A (Witness Baranski) No, I have not.
11 0 How about you, Mr. Czech?
12 A (Witness Czech) Yes, I have.
13 0 Whan did you see it before, Mr. Czech?
14 A Probably about the time-it was prepared.
15 0 Turning your attention to the third paragraph of 16 the first page of the letter, there is a discussion of 17 broadcasting or demonstrating the capability to' broadcast an 18 EBS message to reflect' changes in traffic patterns which 19 might be caused by an impediment to an evacuation route, and 20 the state's response to that from FEMA.
21 Do you recall the discu,ssion with FEMA that 22 concerned this request by FEMA at that time, Mr. Czech?
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g0000101 138 mnrysimons 1 A I believe I do.
2 O As I understand this letter, the state declined 3 -tx) agree to make this particular-EBS broadcast or to 4 demonstrate the capability for it because rerouting 5 evacuation traffic was not a favored strategy for dealing 6 with impediments to evacuation. Is that correct?
7 A I think you probably missed the point of the 8 paragraph.
9 0 Okay. Could you_ explain the letter to me, the 10 paragraph?
O N'
11 A The intent of this was not that the rerouting 12 would not be demonstrated. The objective would have 13 mandated that the local community automatically develop an 14 EBS message. The handling of-a traffic impediment is 15 basically a local option of law enforcement and othe'r local 16 officials. It could be conceivable that if an impediment 17 could be something that you get a bulldozer and push 18 something_to the side of the road, the police station there, 7 19 and moved it around, or, for example, in one of the 20 exercises -- and it may have been this one -- where the g~g 21 location was such that a simple stationing of police could V.
22 run traffic through a parking lot and around the impediment ACE-FEDERAL REPORTERS, INC.
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'IV'3000 01 01 139 nhrysimons 1 and then continue on without particularly a need for an EBS 2 message.
3 The objective that FEMA was looking1for would 4 have mandated that we would have to have an EBS-message. If 5 we did not meet the objective, then we could have gotten a somewhat unsatisfactory mark for our' demonstration.
~
6 7 0 And your complaint with FEMA's proposal was that 8 it would have required a response which in your judgment 9 should have been left to the informed judgment of the 10 exercise players at the time of the exercise, depending on O 11 the impediment that was actually injected into the-12 scenario? Is that the problem?-
13 A I would say that you were taking'away local 14 prerogative by mandating a certain course of-action.
15 0 When you say "a local prerogative," are you 16 talking about a political prerogative or'the. exercise of 17 informed discretion of the exercise players during the 18 exercise?
19 A Would you rephrase that a little bit?
20 0 Yes. You said that your objection, as I recall gg 21 your answer, you said-that your objection.was to FEMA's-V' 22 taking away a local prerogative and you explained the ACE-FEDERAL REPORTERS, INC.
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g000-01-01 140 marysimons 1 traffic control and direction is a local function. What I 2 am trying to understand is whether your objection was based 3 on some kind of political or' separation of powers and 4 responsibilities kind of notion or whether it was more that 5 the automatic nature of the FEMA objective would have 6 impeded the exercise of informed judgment by exercise 7 players at the time of the exercise.
8 A I would say that it was basically that we were 9 afraid that FEHA was mandating a certain course of action by 10 local authorities without having all the facts based on what p
\- 11 the hypothetical problem was and not knowing in detail 12 exactly how the local community would respond, what 13 resources they had; and they basically were prejudging the 14 response that they wanted.
15 0 I take it that you would have had the same 16 reaction even if the impediment had been injected on a state 17 road over which state resources were to deployed?
18 A It was not an action of state versus local 19 authority.
20 0 That's what I am trying to get at. In other 21 words, it was the automatic nature of the requirement rather 22 than permitting the players to-exercise their informed ACE-FEDERAL REPORTERS, INC.
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I g0000101 -141 marysimons 1 judgment at the time that you were objecting to?
2 A That's correct.
3 0 Okay.
4 A (Witness Papile) You're still missing an 5 important point.
6 0 Okay. Help me out there.
7 A The important point here is the notification. We 8 argued with FEMA previously and again on the notification.
9 Our information people and our public affairs people say to 10 us it doesn't necessarily take an EBS message;.I can give a
('\
11 news release.
12 What Larry said is perfectly right. If the 13 individuals themselves -- the police, the public works and 14 so forth and so on -- get around together and say we'll take 15 care of it, ten minutes; then the PIO will1say to-them, how j l6 do you want to notify the public, should we notify the 17 public? That's what Larry's talking about. They were 18 trying to demand that there had to be an EBS message. We-19 don't necessarily agree. EBS message means something to us 20 other than a news release.
1 21 0 All right.
22 A But our point here is EBS message, strictly EBS ACE-FEDERAL REPORTERS, INC.
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'marysimons 1 message. So to my knowledge on this one,_it had nothingito ut t, do with the type of impediment; it was.just th'at we didn't 2
, 3 agree on'the EBS message being the only means of notifying 4 the public.
5 0 I understand what you just said, but I understand 6 also you did not personally take part'in this discussion 7 with FEMA.
8 A But the question has come up again.since then.
9 0 okay.
10 A Many times.
11 0 Do you disagree with Mr. Czech's analysis or 12 recounting of the traffic control aspect of this?
4 13 A Absolutely not.'
14 0 Would you gentlemen-look'at the attachments to 15 this letter, please, the first page of which is entitled 16 " Monroe County." Item number 1 on this sheet appears to 17 convey the address of the Monroe County EOC, does it not?
4 18 A (Witness Czech) That's correct.
19 0 That should be publicly available information at 20 all times, should it not?
f3 21
, A That's correct.
V 22 0 The second item there refers to the Culver Road ACE-FEDERAL REPORTERS, INC.
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g0000101 143 marysimons 1 Armory. I take it that that is a designated reception-2 center within Monroe County; is that correct?
3 A That's not correct.
4 0 Well, what is it, sir, then?
5 A Culver Road Armory is a location for state 6 emergency workers to be monitored and decontaminated once 7 they finished their assignment.
8 0 Okay.
9 A Excuse me. If I said " state emergency workers,"
10 I meant county emergency workers.
O 11 O I believe it is also referred to as an " emergency 12 worker decontaminating facility." is that right?
13 A We refer to them as PMCs, personal monitoring 14 sites.
15 0 Okay. Now that is also, I take it, a publicly 16 notified or declared or listed facility; is that correct?
17 A That's a facility that is known throughout the 18 plan for emergency worker training, but not necessarily to f
19 the general public.
20 0 I'm sorry. But it's included in the plan?
21 A Definitely.
22 0 Okay. Is it the only such facility in Monroe
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g0000101 144 merysimons 1 County?
2 A It's their primary facility.
3 0 Item Number 3, TCP Number 1, U.S. 104 and Bay-4 Road. Do you know what that refers to?
5 A I would assume those are two traffic control 6 points in Monroe County.
7 0 "Those two," you're referring to --
8 A Items Number 3 and items Number 4, TCP Number 1 9 and TCP Number 4.
10 MR. LANPHER: I object to this line of
's 11 questioning unless you explain how this is at all relevant.
12 MR. IRWIN: Well, I don't need to explain that on 13 this record, but if the witnesses can understand the 14 questions, I can help them.
15 BY MR. IRWIN:
16 0 Would those be traffic control points which would 17 be expected to be activated during the exercise, I take it?
18 A (Witness Czech) Not having been involved with 19 writing this exercise, but looking at the cover letter that 20 appears -- this is one for the state and federal observers 21 to know which locations are going to be exercised.
22 0 I take it we can infer from the fact that one is ACE-FEDERAL REPORTERS, INC.
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'3000 01 01 145 marysimons 1 numbered 1 and one is numbered 4, they are not the only 2 traffic control points within Monroe County?
3 A That's correct.
4 0 Item Number 5 is Park Ridge Hospital, and the 5 address for Park Ridge Hospital. Within the context of this 6 letter, have you any basis for knowing what the purpose of 7 this listing would be here?
8 A Looking at this letter and the attachment, that 9 would imply to me that Park Ridge Hospital is the location 10 for the demonstration of a_ handling of an injured 11 contaminated individual.
12 0 Item Number 6, Sperry High School, what would be 13 the -- let's get back to this exercise number 6. But let's 14 go to Number 7, Mr. Czech, Schlegel and Salt Road, the site 15 of medical drill accident. I take it one would infer from 16 that, coupled with your previous answer, that probably a 17 medical drill accident would take place there and the victim 18 would be treated at --
19 MR. ZAHNLEUTER: Excuse me. I'm sorry, I didn't 20 mean to interrupt.
.gs 21 BY MR. IRWIN:
22 0 At Park Ridge Hospital?
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g000'~0101 146 mnrysimons 1 MR. ZAHNLEUTER: I object to this question-and 2 the other questions actually. It's going to more than just 3 preliminary matters. I might inquire how'much further you 4 intend to inquire into these attachments? I can't see any 5 relevancy to anything in this exercise proceeding or.
6 contentions or even the scope of-the interrogatories.
7 MR. IRWIT): Well, I am entitled to proceed. I 4
8 will tell you why I am asking, if that-is what you want to 9 know. But the witness was trying to help me identify 10 these. What I am interested in finding out is whether O
\l 11 Sperry High School is, with respect to Item 6, the only high 12 school in Monroe County -- or, excuse me, the only school in 13 Monroe County.
14 WITNESS CZECH: It is not.
15 BY MR. IRWIN:
16 0 Item Number 8, is Rochester Tranr,it Service the 17 only transit service serving Monroe County?
18 A I'm not sure of that.
19 0 Is there some information which is customarily 20 kept confidential during the exerciso preparation process?
21 A This material would be kept confidential. It's 22 only circulated to those who have a need to know.
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147 marysimons 1 0 All right. Is there any designation on this 2 letter which would suggest that it should be given 3 confidential treatment? How would one know whether this 4 letter was to be given confidential treatment?
5 A (Witness Papile) How would one know?
6 0 Yes.
7 A The author would be responsible to be sure.
8 0 But there is no marking on this letter.
9 A The author would be responsible to ensure that 10 this was kept confidential, and this in response to a FEMA 11 request. He would ensure, I am sure. I don't know whether 12 he did or not, but I am assuming that he did, and I ensure 13 now that we keep it confidential. It doesn't need a marking 14 on a piece of paper necessarily. We have no markings to 15 signify confidential for official use only or in that manner r
16 as you have in the federal government. This would have to 17 be on his part to be kept confidential.
18 0 Do you have in place any procedures that specify 19 procedures for retaining exercise information confidential i
20 prior to the conduct of the exercise?
- 21 MR. ZAHNLEUTER: Could you identify what 22 contention this whole line is relevant'to, please?
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\J marysimons 1 MR. IRWIN: .I am interested'in-the degree -- in 2 information relating to the degree of spontaneity of 3 exercises, and I am assuming that the.information is kept 4 properly confidential by the entities of New York State and 5 local governments. I am just trying to understand the 6 nature of the process by which they keep it confidential.
7 MR. ZAHNLEUTER: Well, as I understand the 8 board's ruling on the relevancy of your interrogatories and 9 indeed this deposition, the issue revolves around full-10 participation exercises. Whether or not in 1983 at this 11 exercise there was " confidential" written on top of the memo 12 has no relevance to those issues.
13 MR. IRWIN: Are you instructing your witnesses 14 not to answer this question?
15 MR. ZAHNLEUTER: I have allowed this line to go 16 on in more than a preliminary fashion, and I am getting to 17 that point very quickly.
18 MR. IRWIN: Well, you tell me whether you are 19 going to permit them to answer the question or not.
20 MR. ZAHNLEUTER: All right. I will not permit i
21 them to answer the question unless you make a better showing O 22 of relevancy here.
l l
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7 g0000101 149 marysimons 1 MR. IRWIN: Well, there have been a number of 2 depositions within the past two weeks which you have been 3 present at in which the confidentiality of the LILCO 4 scenario has been probed, and this is the opportunity -- and 5 the only opportunity which we have had -- to understand the 6 nature of the state's process for preserving 7 confidentiality.
8 We are being judged by standard which we believe 9 are at least as stringent as those which New York State and 10 its localities have been judged, and I am inquiring into 11 that process. It's a public process, and I don't see any l 12 reason why the witnesses can't answer it.
13 MR. ZAHNLEUTER: One difference is that at those
- 14 depositions the issue was the Shoreham exercise. If these 15 gentlemen have something to say about the confidentiality of 16 the scenario and the objective at the Shoreham exercise, it 17 might be relevant.
g 18 MR. IRWIN: The subject of this deposition is not i 19 the Shoreham exercise, Mr. Zahnleuter.
20 BY MR. IRWIN:
e 21 0 Do you gentlemen have in place any procedures 22 preserving the confidentiality of exercise information?
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marysimons 1 MR. ZAHNLEUTER: I will allow you to answer this 2 question, but if the line continues more in that manner, I
( 3 am going to have to cut it off.
l 4 A (Witness Papile) Since I have been the director,
! 5 I have instructed my exercise director that he will not
! 6 disclose any information and that it is close hold on his l
l dry 7 part and his part alone or any else I may designate as an (f 8 assistant to him.
9 As you could see, we keep confidentiality. And
! 10 as to this paper, if there was any disclosure made, FEMA
\
' ' rm This was an answer to FEMA, l (_) 11 should have reported it to us.
l 12 and it was accepted by FEMA. I am not speaking for the 13 gentleman that wrote it.
l 14 O Right.
15 A But I am saying this, FEMA did accept it. FEMA 16 understood the rules of confidentiality, and I am assuming 17 that this individual kept it to himself, other than Larry 18 probably who helped him. And you can see he's info, and l 19 Mr. Clemente, who is also information, they assisted him in 20 the exercise, I am sure.
21 0 Let me just say I have no reason at all to 22 believe that what you say isn't the' case. I was just ACE-FEDERAL REPORTERS, INC.
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151 lll00000101 mnrysimons I wondering whether there was in place any written procedure 2 which sets forth the state's policies for preserving 3 confidentiality of exercise. Yes, I understand your-4 answer. No, there is nothing written, but you give 5 instructions to the persons who are in charge of 6 orchestrating an exercise, to keep the s information i
7 confidential.
l l 8 A Absolutely right. And I have every faith in l
l 9 Bruce that he kept it confidential.
l 10 0 I have nothing of a basis on which to doubt that.
lC) l 11 Mr. Baranski, in exercises during the period of 12 interest with which you are familiar, are route alert 13 drivers tested?
14 A (Witness Baranski) Yes, route alert drivers are l
l 15 tested.
l l 16 0 How were they tested?
17 A The scenarios and objectives are written such 10 that a siren -- first of all, let me back up. During our 19 full-scale federally evaluated exercises, every exercise 20 that I have participated in has required the full activation
, 21 of the siren system with the appropriate EBS messages.
O, l 22 During that activation of the siren systems we, l
l ACE-FEDERAL REPORTERS, INC.
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'2000 01 01 152 morysimons 1 by controller's message,. fail.a siren. That failed siren;is 2 relayed back to the EOC and then the route alert procedures 3 are put in place, resources are dispatched. The route alert 4 routes are run. The messages of the drivers are. verified by 5 FEMA. And that's how we do a route alert during an 6 exercise.
7 0 The process you just described relates to the 8 zone of interest of the failed siren. In other words, the 9 route alert drivers whom you activate -are those, I take it, 10 within the zone of influence of the siren which has 11 hypothetically been failed?
12 A In accordance with the county plans, certain 13 agencies have responsibilities for route alerting. Okay.
14 In accordance with the plan, if the siren fails, then that 15 responsible agency is called upon to conduct route alerting.
16 0 For that area?-
17 A For that area, that's right.
18 0 Okay. But not necessarily elsewhere in the --
19 A That's correct.
20 0 All right. Typically, you do not activate route 21 alert drivers except in response to that hypothetically 22 failed siren; is that correct?
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.V marysimons 1 A That's correct.
2 0 'In.the exercises for which you have been 3 responsible, you say that full public -- full activation of 4 sirens up to the point of sounding has taken place?
5 A Not true.
6 0 Not true?
7 A I said in the exercises.that I have been 8 responsible for, we have actuated the siren systems in 9 accordance with the scenario as part of the exercises, 10 including the test broadcast of an EBS message. So that in 11 fact we can verify from the point of the decision making to 12 activate the sirens, the actual activation of the sirens, 13 the sounding of the sirens, the preparation of the EBS 14 messages of the joint news center, the insertion into the 15 radio station and the radio station's capability to take 16 those instructions and broadcast an EBS test message..
r 17 0 Are any of the three of you familiar with any 18 exercises during the period of interest when the sirens were 19 not in fact sounded at the time of the' exercise?
20 A (Witness Papile) Could I ask a question?.
21 0 Sure.
, 22 A I want to clarify the question.
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154 lll000001'01 marysimons 1 0 Sure.
2 A Full participation?
3 0 Full participation.
4 A Well, then, would you restate the question and 5 say " full participation"?
6 (Laughter) 7 0 Are there any full-participation exercises with 8 which you are aware in New York' State during the five-year 9 period of interest when the sirens were not sounded at the 10 same time as the rest of the. exercise?
11 A As far as I am concerned, I am not sure in the 12 early exercises, but I am sure in the late exercises that 13 the sirens were sounded. I am not sure on the first or 14 second exercise.
15 0 Let me provide you a memorandum on a form 16 entitled " Disposition Form." It's from A.G. Grushky to the 17 Record, dated February 11, 1982, concerning the Indian Point 18 RAP exercise then scheduled for March 2 or 3, 1982.
19 MR. LANPHER: Could we take_a' moment, please?
20 MR. IRWIN: Sure. Take a moment to take a look 21 at it.
22 (Pause while the witnesses examine document.)
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murysimons 1 MR. LANPHER: Will we mark'this?.
2 MR. IRWIN:- Let's mark this as Exhibit:6.
3 (The document referred to was 4 marked Deposition Exhibit .
1 5 No. 6 for identification and i
6 submitted for the record.)
i 1 7 BY MR. IRWIN:
i 8 0 Have you gentlemen each had an opportunity to I
9 review the document? Have any of you ever seen this 10 document before today?
O 11 A (Witness Papile) No, sir.
12 A (Witness Czech) No, sir.
13 A (Witness Baranski) No.
14 0 If you look-at che first page, the subject of the 15 memo is stated to be " Siren testing during March of 1982, 16 Indian Point exercise."
1 17 The first and second paragraphs, the block-18 indented paragraphs of the memo, are referred to, I guess, 19 as being FEMA's position, " FEMA proposes that if'the state 20 and utility do not want to test sirens during the March 2 or
~
21 3 Indian Point exercise, it is okay with FEMA provided that 22 at another appropriate time there will be a full test of ACE-FEDERAL REPORTERS, INC.
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j0000'0101 156
-marysimons 1 alert and notification procedures, including testing of 2 " sirens. FEMA suggests that in lieu'of. sirens during;the 3 exercise, a route alerting capability be demonstrated," et 4 cetera.
5 Mr. Czech, you had responsibilities in the March 6 '82 exercise at Indian Point,,did you not, sir?-
7 A (Witness Czech). I believe so, yes.
8 0 Was the procedure indicated here -- namely, 9 demonstration of route alert capability during the exercise 10 and subsequent testing of. sirens and early notification
/ 11 procedure -- the process that was followed at that exercise?
12 A I am trying to remember. It's a long time ago.
13 To the best of my recollection, the Indian Point siren 14 system was not 100 percent completed at that time. And I do 15 believe that, as a result of FEMA's written policy, that the M
16 sirens were sounded. But that would be agaTh the FEMA yd hC' 17 exercise evaluation.
18 0 You have nothing in your recollection that leads 19 you to indicate that this memo doesn't correspond with what 20 actually occurred in March of '82?
21 A That is to say that this is what FEMA --
22 MR. LANPHER: Excuse me. Could I have that ACE-FEDERAL REPORTERS, INC.
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m:rysimons 1 question read back, please?
2 (The reporter read the record as requested.)
3 WITNESS CZECH: My feeling is this is basically 4 stating what PEMA's position would be, and I believe the 5 state acted accordingly.
6 BY MR. IRWIN:
7 0 Gentlemen, would you take a look at Interrogatory 8 Number 7 and the answer thereto? That interrogatory 9 concerns hypothesized wind shifts during accidents and 10 responses thereto. The answer indicates that wind shifts 11 have occurred, with the exception of the January 21, '82, 12 exercise at Ginna. It also states, as I understand it, that 13 there have never been any rescissions of evacuation 14 recommendations as a result of wind shifts. Do I understand 15 the answer correctly?
16 A (Witness Papile) Yes.
17 A (Witness Baranski) That's correct.
18 0 Why would one not rescind an evacuation 19 recommendation as a result of a wind shift?
20 A (Witness Papile) That's not the question here 21 really.
22 O That's the question I asked, though.
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-v 0000 01 01 158 marysimons 1 A No, but I am going to tell you that' it's 2 irrelevant as far as I an concerned because you're saying 3 that a wind shift would cause a change in the evacuation l
l 4 order. That's not true.
-5 0 Why not?
l 6 A Because the win'd shift might be such a minute l
l 7 detail or minute wind degroes that it would not affect the 8 evacuation.
9 0 And in any of these exercisos, do'you know 10 whether ovacuation recommendations have had to be modified l 11 as distinguished from rescinded as a result of wind shifts?
12 A I can't remember, but I can't remember -- I can't 13 remember any one that I participated in at the county that 14 it had to be done. If it had to be done, if not rescission, 15 itcouldbechangebateron. But it's not in any sense a
[
16 roscission to a previous order.
17 0 All right. We're distinguishing betwoon 18 rescission and modification; right?
19 A Not even modification. A change.
20 0 All right. Is there any difference between a 21 change -- in other words, you're saying no changes have ever 22 occurred in any ovacuation recommendations --
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, marysimons 1 A To the best of my knowledge.
2 0 To the best of your knowledge?
3 A To the best'of my knowledge.
4 0 Is your memory consistent with Mr. Papile's --
5 A May I finish that, though?
J 6 0 Cortainly. I'am sorry.
7 A Add to it. That's not a change. Change is
! 8 saying, " Don't do this one that I. told you to do before." .
9 What we have done, we have added to it, but not necessarily 10 changed or modified. So to answer your question, I have i 11 added.
t 12 0 But never modified an existing recommendation?
13 A We have never told one, " Evacuate now," and then i 14 repealed it and said, " Don ' t evacuate. " No, to the best of 15 my knowledge, we have never done that.
l 16 0 Would that be bad practice?
17 A Would it be bad practice?
18 0 Well, why don't you --
19 A I don't know. That's up to the decision makers.
20 0 Mr. Czech, is your recollection consistent with 21 Mr. Papile's with respect to rescission, modification, in c 22 addition to --
i i
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,.lll00000101 160 carysimons 1 A (Witness Czech) We have-added emergency response 2 planning areas to evacuation orders.as a result of projected 3 or actual exercise wind shifts.
l l 4 O But never rescinded a recommendation.
l 5 A If we have ordered an evacuation for a particular
! 6 area and the wind has shifted, that order has not been I
j 7 rescinded.
8 0 Is that consistent with --
l l 9 A (Witness Baranski) That's correct.
l 10 0 okay. Could we turn to Interrogatory Number 9 l
() 11 and the answer to it. This interrogatory deals with 12 training and the state's training program.
l 13 Mr. Papile, were you the person solely 1
14 responsible for preparation of this answer? :
l 15 A (Witness Papile) No.
l 16 0 Who assisted you?
17 A Mr. Baranski.
i 18 O Anybody olso?
f 19 A On this answer hero?
i 20 0 Yes, sir.
21 A I don't know. That's all I had to deal with.
22 0 Aro the sampling criteria used for training N
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- 161 U)00000101 mcrysimons 1 different categorios of emergency response personnel the 2 same for all categories of personnel, or do they vary 3 depending on the job being performod?
4 MR. ZAHNLEUTER: I object as to form.
5 BY MR. IRWIN:
l 6 0 Do you understand the question, Mr. Papile?
l j 7 A (Witness Papilo) Yes.
8 MR. ZAHNLEUTER: You can answer.
l 9 WITNESS PAPILE: Okay. My evaluation technique,
- 10 our evaluation technique is the exorciso and the drills that l 11 we hold. Liko a school teacher, the test la the critoria 1
l j 12 that we uso, and the ovaluation has to do with validity, l 13 rollability, and all those good educational terms. We uso 1
14 the oxorcise of the drill to dotori.ine wnother our training, l
15 the county's training, the other stato department agency f
l 16 training, or the utility training when they assist us, is l 17 adequato.
l j 18 I havo no sampling technique por so, but I do l 19 have a technique of checking drills out, checking classes l
20 out, and so forth and so on. I l
- gS 21 BY MR. IRWIN
- l L-) l 22 Q Do you have any techniques that you exorciso in l ACE-FEDERAL REPORTERS, INC.
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llg00000101 162 marysimons 1 advance of the exercise to ensure that your training program 2 is on track?
3 A We have practice, we have drills, and we have 4 classes that I attend myself or other people attend and 5 watch what's going on. But we do have drills during the i
6 year, and we also have -- before an exercise to be graded by j 7 FEMA, we may have one or two full-scale, what we call. full-I
- 8 scale state exercises in which we would put up state l
l 9 ovaluators. Our state evaluators make the same type of i
10 report to us, and we make it to our superiors the same as 11 the federal government does. Now, I will say we're probably 1
12 more stringent than FEMA.
13 Q Do you any means of deciding whether your program 14 for training, say, bus drivers in understanding dosimetry is l
l 15 adequate? Ilow do you know?
I
- 16 A FEMA tells us in a hurry.
( 17 0 Well, how do you know?
l 18 A We test them during the classroom work.
19 0 Do you test 100 percent of the drivers all of the 20 time?
l
! 21 A I can't say that, no.
l 22 0 The answer is no, you don't test 100 percent?
l l
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f I0000 v 01 01 163 marysimons 1 A No, I can't say it.
2 O In other words, you don't know?
3 A I don't know.
4 0 Do you know, Mr. Baranski?
5 A (Witness Baranski) No, I do not.
6 0 Well, if you don't know what size you use, how do 7 you know it's working?
7 8 A. (Witness Papile) Well, I'd be h mm it both 9 by the size we use during what we call our. practice drills 10 and also the size used by FEMA during their evaluations.
O 11 O In your practice drills, do you normally test 100 12 percent of your bus drivers, for instance?
13 A No, no.
14 Q Do.you select a smaller sample?
15 A We test.about the same as FEMA requires.
16 0 Which is what?
17 A Oh, maybe 10, 12, 14, depending on what size 18 county and who we're testing.
l 19 0 How do you decide whether to test 10, 12, 14,-2, 20 or 30? l l
21 A Well, that gets back to a question I answered j O 22 this morning. The main question is we try to do as much as 1
1 ACE-FEDERAL REPORTERS, INC.
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'0000 01 01 164-marysimons 1 we can in the period of time that we have.
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2 0 But you have no formal criteria?
3 A There are no statistical bases for it, no.
-4 s Neither does FEMA, neither do we.
5 0 Are the people who conduct your training program 6 professional educators?
7 A We would_have to go through each one. Like Larry.
8 and myself, we are. Jimmy's qualified to teach. The 9 -people that I have teaching'are qualified, I consider to be 10 qualified.
11 0 Qualified by dint of what?
12 A Well, experience is one.
13 0 Experience as teachers or experience in emergency 14 planning?
! 15 A Emergency planning and Emergency Worker Handbook, I
16 which we have published, an Emergency Worker Handbook which 17 we use as our guide, as well as we use another document that 18 was prepared by a consulting firm specifically on bus 19 drivers, which we teach from that. !
i 20 We also have previous information that was i
21 developed for us by Stone & Webster that we use as ;
22 background. We have a text on that. That has been ACE-FEDERAL REPORTERS, INC.
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I'v.'0000 01 01- 165 r 4
3 r
marysimons 1 developed virtually in our new handbook.
2 Q. This is the~new emergency work'er handbook?-
3 .A Well, we-haven't'got it yet. LAs soon,-as I get'~my 4 workers, and I'm short, I am' going to. We are in._the s!
5 process of revising.the handbook, yes, Emergency Worker.
6 Handbook.
7 0 Is the bus drivers handbook a publicly available 8 document, sir?
9 ( A (Witness Papile) I can't answer-that. It was a 10 TSPG study and whether it has' proprietary rights or.not I 11 don't know.
12 Q But it's.given to all bus drivers?
13 A .We do, yes. We have the authority because it was J.
\
14 written for the bus drivers.
15 MR. IRWIN: Could I have a copy of that, 16 Mr. Zahnleuter?
17 MR. ZAHNLEUTER: I will look into that and find
. - ?
18 out what it is.
19 WITNESS PAPILE: It may have proprietary rights 20 though for outside agencies. I'm not sure. It.was written 21 by what they call TSPG.
0 22 I will be honest with you, I think we have a good ACE-FEDERAL REPORT $RS, INC.
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-0000 01 01 165
- mnrysimons 1 . developed virtually in our new handbook.
2 O T s is the new emergency worker handbook?
3 A Well we' haven't got.it yet. As soon as I get my 4 workers, and I'm ort, I am goin to. We are in the 5 process of revising he han o es, Emergency Worker 6 Handbook.
7 0 Is the bus !i ers handbook a publicly available 8 document, sir?
9 A (Witnqs I can't answer that. It was a J(Papile)
O 10 TSPG study and .
ether it ha proprietary rights or not I 11 don't know.
12 0 But it's given to al bus drivers?
13 A We do, yes. We have t e authority because it was-14 written for the bus drivers.
15 MR. IRWIN: Could I have copy of that, 16 Mr. Zahnleuter?
17 MR. ZAHNLEUTER: I will look - to that and find 18 out what it is.
19 WITNESS PAPILE: It may have prop etary rights n 20 though for outside agencies. I'm not sure. It was written V
21 by what they call TSPG.
22 I will be honest with you,'I think we have a good ACE-FEDERAL REPORTERS, INC.
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I 198 (O"'3000 01 01 marysimons 1 emergency plan, a utility emergency plan?
2 A (Witness Papile) No.
3 0 Can you tell me whether, if you were'to prepare 4 for the exercise of such an emergency plan, whether.you 5 would f.ollow exactly the same procedures las you have 6 described in answer to Mr. Irwin's questions in terms of the 7 selection of objectives, the development of the scenario, 8 citing how many buses to run, and that kind of thing? Would 9 the same procedures necessarily apply?
10 (Witnesses conferring.)
(,
' 11 A (Witness Baranski) We have no basis to make a 12 determination whether they would be the same or not.
13 0 So then it would be fair to state, gentlemen, 14 that you are not in a position today to say whether 15 procedures you have followed over the past five years at the 16 plants would be discussed --
17 A (Witness Papile) We have no way of --
18 0 Let me finish the question, would be the same 19 procedures that would be followed in the exercise of a 20 utility plan?
21 A (Witness Papile) We have no way'of knowing. We 22 don't know what that would entail.
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g0000101 199
'marysimons 1 0 .Now, gentlemen,.Mr. Irwin also asked you s'ome 2 questions regarding what your understanding of a full-3 participation exercise was, and a number of times I think 4 you, Mr. Baranski, also used the term " full-scale 5 exercise." In your vocabulary, do they mean the same thing?
6 A (Witness Baranski) Yes. " Full-scale" and " full-7 participation" mean the same thing.
8 0 Fine. And you testified also'with respect to the 9 exercises listed on pages 2 and 3 of Exhibit 1 that those 10 constitute full-participation exercises except for the one 11 or two which were identified as remedial exercises; is that 12 correct?
13 A That's correct.
14 0 Now,-I don't know exactly how to ask this. Does 15 the fullness of a full-participation exercise. vary depending 16 on any factors such as the location of the plant,'the 17 population, whether there has been previously an exercise at 18 that plant or any other factor?
19 A FEMA has allowed during our discussions of the 20 development of objectives for sites that have had previous 21 exercises to not demonstrate a particular activity if it has 22 been shown to be demonstrated successfully in the.past.
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go000101 200 marysimons 1 However, all of the first-time exercises strive 2 to demonstrate as much as practicable.
3 0 When you use the term "first-time exercise," that 4 means that for a particular facility, the first time you 5 have a full-scale or full-participation exercise you would 6 strive to make it as complete as possible?
7 A That's correct.
8 0 Now, you testified also in response to Mr. Irwin 9 that you did not have a set of objectives -- or I believe 10 you used the word " criteria" -- to determine what l
11 constituted a full-participation exercise. Is that correct?
12 A (Witness Papile) Yes, that's correct.
13 0 I would like to discuss a number of potential 14 elements in an exercise that could be be included in an 15 exercise for the purpose of finding out whether these are 16 the kinds of activities you would expect to occur or take 17 place in what you consider to be a full-participation 18 exercise. Would you expect the sirens to be sounded in a 19 full-participation exercise?
20 A (Witness Papile) Absolutely.
21 O Why is that, sir?
il- <
22 A It's the only way we can really get with the ACE-FEDERAL REPORTERS, INC.
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mnrysimons 1 public and let the public know that we have a system in 2 being for notification of the-public as well as. assure 3 ourselves that some type of verification that the sirens are 4 working.
5 0 And if the sirens were not sounded in an 6 exercise, would that be an indication to you that it was not 7 a full-participation exercise or a factor to be considered?
8 A It would be a factor in my estimation, yes, that 9 it was not a full exercise or a full participation.
10 0 In your' experience, are test EBS messages P
kJ ,
11 something that you would expect to have at a full-12 participation exercise?
13 A An important element, yes.
14 O And would you expect that the emergency broadcast 15 radio station would actively participate in the exercise?
16 A Absolutely.
17 0 For a full-participation exercise?
18 A Yes, sir. l l
19 0 Why is that?
1 20 A Well, that's the only way we know that the j l
21 engineer or the operator at the radio station knows what 22 he's doing.
1 ACE-FEDERAL REPORTERS, INC.
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m rysimons 1 In fact, just to bring this point out, at one of 1
2 our exercises at Oswego, this is one of the things'that FEMA
~3 looked at specifically to determine whether the radio 4 station was capable of taking'and producing the EBS 5 message. They've done it at other stations, too, but that 6 one comes to my-mind.
7 0 The Oswego exercise, is that one of the exercises 8 that you discussed earlier today?
9 A Yes, sir, that's the exercise. I'm going to say 10 the one uhat I was referring to, and let me look at-the 11 dates again.
12 (Witneses conferring.)
13 Okay. Jim refers to that as-the first exercise.
14 That was the exercise in '81, and I guess it's out of the 15 bailiwick here, but it was the exercise in '81, prior to the 16 five years.
17 0 Okay. So it wasn't one of'the ones you 18 discussed?
19 A No. Just a minute, please.
20 (Witnesses conferring.)
-- 21 A (Witness Papile) I'm not sure which one. It 22 could have been the one in August of '82, also. I mean it ACE-FEDERAL REPORTERS, INC.
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g0000101 203 marysimons 1 could have been.
2 0 All right. Thank you.
3 A But I want to bring up the point th'at they do 4 look at that as a criterion themselves.
5 0 And it~would be fair to say that you believe it 6 is important for a full-participation exercise to have the 7 EBS radio station participate?
8 A Absolutely. We have a criteria. If I may add 9 for you, we have a criteria. We have a 15-minute time 10 limitation on that that they say is of utmost importance to 11 us. We have a 15-minute time limit in which we have to make 12 a decision. A protective action decision is made by the 13 decision makers. We have 15 minutes to get that message 14 out, and they time us every exercise from now on. We're 15 timed on it. If we don't make the 15-minute window, we get 16 a deficiency.
17 0 And included in that 15 minutes is whether the 18 radio station, once it gets the proposed message, can in 19 fact get it on the air?
20 A That's right.
21 0 You testified earlier concerning, I believe, the 22 '85 exercise at Ginna and at least one exercise at'Nine Mile ACE-FEDERAL REPORTERS, INC.
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go000101 204 morysimons 1 Point which involved the actual notification of the Coast 2 Guard in a water portion of the EPZ for those plants and 3 also involved the Coast Guard dispatching a vessel. Is-that 4 correct?
5 A (Witness Papile) That's right.
6 A (Witness Baranski) That's correct.
7 0 Am I correct that this was part of the exercise 8 objectives for those exercises, that'the Coast Guard would 9 be notified and that the Coast Guard would dispatch a 10 vessel?
C' 11 A (Witness Papile) Yes.
12 A (Witness Baranski) That's correct.
13 0 And PEMA evaluated the notification of the Coast 14 Guard and their ability to dispatch a vessel in a timely 15 manner?
16 A (Witness Papile) They have a Reserve and a 17 retired Coast Guardsman do it. In most of our exercises 18 both individuals have been there to check the Coast Guard 19 out.
20 0 These are FEMA personnel?
21 A FEMA personnel.
22 0 Thank you.
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E g00001.01 205 corysimons 1 Gentlemen, I was out of.the room for a,few
, 2 minutes this morning. I looked over some notes on the l
3 questions that Mr. Irwin pursued, and I apologize in advance 4 if anything is repetitive. But I believe you. testified this 5 morning that it's normal practice in New York State 6 exercises with which you are familiar for actual telephone 7 calls to be made to each of the hospitals in the EPZ? Is 8 that correct?
9 A (Witness Papile) Yes, that's correct.
10 0 And is it also normal practic.e in these exercises
!O
}
11 for each of the school districts within the ten-mile EPZ to 12 be contacted during the exercise?
l 13 A Yes.
14 0 Would it be adequate, in your opinion, if only 15 one or two school districts out of, say, ten school l
l 16 districts were contacted during the exercise?
17 A No. It would not be acceptable.
18 0 Why not?
' 19 A Well, for many reasons. One reason is to put 20 them on standby at least that there is something happening, i
21 because if they heard it by other means, it would put the i (/
i 22 county exec as well as the state officials into a bad light ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coveras,e 804336-6M6
(v3000 01 01 206 rarysimons I with the school officials.
2 I could explel.n an actuality that happened 3 there. In Monroe County we've learned our lesson. The-t 4 incident at Monroe County caused us great consternation because the school superintendent at Webster was told ta/ one
~
5 1
6 of the students that there was an incident at the plant and l
7 he had learned it on the little radio that he had in the j 8 study hall over the NOAA station, the weather station. And ,
l l 9 the county exec, I'd say for a year, we had to convince that i
- 10 school superintendent that we had a means of notifying him.
l (~%
l 11 We learned a dire lesson on that one, because i
l 12 what had happened, the EBS message -- what happened was the l 13 school was not notified until the EBS message went out, and i
14 the school superintendent said, "Weren't you notified j 15 before that? So we've changed our procedures now where the j 16 school coordinator at the EOC, we require him to call each i 17 of the schools in the ten-mile EPZ to let him know he's at I 18 the EOC and there is an incident.
- 19 O Each of the schools or each of the school l
r l 20 districts?
l
- 21 A The school districts.
22 i
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rarysimons 1 0 And these are actual notifications to each of 1
2 those districts?
'3 A Yes, sir.
4 0 Generally I think it was, you, Mr. Czech, who 5 testified concerning testing for the . ingestion of exercises 6 involving the ingestion pathway EPZ. And I,believe it's a 7 fair characterization of your testimony that you said in 8 some of the early exercises, or at least in one early 9 exercise, you did ingestion pathway testing and in more 10 recent exercises you have not done so because FEMA does not 11 have any grading criteria. Is that an accurate summary?
12 A (Witness Czech) We would have done ingestion 13 sampling and discussions on each of the early exercises. I 14 am talking at Nine Mile, Fitzpatrick, Ginna, and Indian 15 Point.
16 One thing that slipped my mind, this one 17 attachment, and I don't remember what number it.was, the May 18 24, 1983, letter to the attention of Paul from Bruce 19 McQueen, and this was confidential information for exercise 20 observers.
21 If you look, and it's towards the back, but it's 22 after the maps, and it's then entitled, page 2 of 2, ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 8 @ 336 4646
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' g 000 01 01 208 morysimons 1 " Exercise Observer Assignments." This is referring to an 2 early Ginna exercise. You will see at 1500 one of'the 3 demonstrations was to be ingestion exposure pathway 4 sampling, including vegetation, milk and fruit by the state.
5 0 For the record, I believe Mr. Czech is referring l
6 to Exhibit 5, which has been previously marked.
7 A (Witness Papile) And that's under the state, l 8 page 202.
l 9 0 Am I correct then that each of the initial 10 exercises involving New York State plants, ingestion 11 pathway preparedness has been tested?
12 A (Witness Czech) That's correct.
13 0 Is it your opinion, gentlemen, that in the l 14 initial full-participation exercise for a nuclear power 15 plant that ingestion pathway testing should be included?
16 A (Witness Papile) Yes.
17 0 Do you feel similarly about recovery and reentry 18 testing?
l 19 A Yes.
20 0 Gentlemen, now you also testified regarding 21 congregate care centers and the numbers of congregate care 22 centers which should be activated or demonstrated during an i
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( 2 000 01 01 209 v-ccrysimons 1 exercise. Leaving aside the question of the numbers of 2 congregate care centers that ought to be demonstrated during 3 an exercise, do you believe that the facility or facilities 4 which are included in the exercise should be centers which 5 have previously been identified in the emergency plans?
6 A (Witness Papile) Would you repeat that, please?
7 0 Let me phrase it another~way.
8 Would it be acceptable to you if the facilities 9 that are demonstrated as congregate care centers happened to 10 be facilities that are not identified in the' emergency plan?
11 A Absolutely not.
12 0 Why is that?
13 A Well, if it's not in the plan, how do they make 14 plans to get the people there and put the notification out 15 to the public?
16 0 Gentlemen, you talked also concerning reception 17 centers. You mado a point, and I forgot exactly what the 18 question was, but you were talking about the general 19 population reception conters. Are thoro also reception 20 contors for school children?
21 A Yes, there are.
22 ACE-FEDERAL REPORTERS, INC.
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L g0000101 210 mnrysimons 1 Q Are these reception centers separate f rom the 2 reception centers for the general' population?
l l 3 A Yes, they are.
4 Q And in a full-participation exercise would you 5 expect that at least some of the reception centersfor 6 school children would be activated to demonstrate it?
7 A Yes.
8 0 Why is that?
9 A Just to prove to us and to prove to them that we 10 are pretty well set up and to give the social services 11 people a chance to exercise.
12 0 In your experience in New York State are there 13 also facilities for the relocation of special-facility 14 populations such as adult homes or nursing homes?
15 A We leave that to the individual in charge of the
( 16 adult home to make agreements with people outside the ten-l 17 mile zone, yes.
18 0 So your answer is there are such facilities which l 19 need to be identified?
20 A Yes, sir.
21 0 Do you have any procedures for ensuring that i
O 22 those facilities are in fact are available?
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(~M000 01 01 211 ci COrysimons 1 A Again, it is up to the county as well as the 2 local health department as well as the regional health 3 department to get together with these people and ensure that 4 they have some place-to take their~ people. I will say that-5 most of the health facilities that we have, and I am talking 6 about nursing homes now, would rather shelt'er their people 7 and have plans for sheltering their people.
8 The five that I am concerned with up'in Oswego 9 County that I work directly with, they mostly would like to 10 go ahead and shelter and they have plans for sheltering.
11 0 You say they have plans.
12 A Yes, sir.
13 0 llave you reviewed those plans?
14 A I have reviewed one of those plans, yes.
15 0 Would it be acceptable, in your opinion, if the 16 facilities did not have written plans for sheltering but 17 attempted to do so on an ad hoc basis in an emergency?
18 A I think that would be dangerous.
19 0 Why?
20 A Well, there is no way of knowing where they would 21 take the people or how they would handle the people even if G
22 they sheltered. I'm talking now of food, water, so forth ACE-FEDERAL REPORTERS, INC.
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,{lgD0000101 L212 marysimons 1 and so on.
! 2 0 Do you feel, gentlemen, that schools'should have f-i 3 sheltering plans as well?
I 4 A We advise all schools to have sheltering plans,
(
5 yes, sir. That is one of their. alternatives, one of their- ,
6 protective-action options. That's one of their options.
l l
7 0 During the exercises with which~you are familiar 8 in New York State has the simulated evacuation of school 9 children to school relocation facilities been demonstrated?
10 A We have never actually moved school children.
- 11 0 I said simulated.
! 12 A I know, but we have used the buses going to the 13 schools where the students would be taken and so forth and 14 so on, with the FEMA observer there, asking that school what-15 takes place once the students arrive.
16 0 I believe you testified in response to Mr. Irwin 17 that you would not require all the school bus drivers within 18 the EPZ to actually make such runs; is that correct?
19 A That's true.
20 0 You also testified, I believe, that it is' normal l
'( 21 22 practice in a full-participation exercise to check the lists of bus drivers to attempt to gain assurance that there are 1
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g, g000'01'01 213 marysimons 1 adequate bus' drivers ~ available; is that correct?
2 A That's true.
3 0 Does that go for both general population bus 4 drivers and school bus drivers?-
5 A That's~true.
6 0- Now is one of the objectivesfthat typically.is 7 included in a full-participation exercise:that FEMA will 8 check to' determine whether there is adequate staffing for 9 more than one shift?
10 A True.
r~3 U 11 0 And how, in your experience, has FEMA generally 12 gone about checking to find out whether there is adequate 13 staffing for more than one shift?
14 A There is two ways. We have actually made a shift 15 change, people have changed, and the other, when they do 16 not require that, they will check to see if we have a roster 17 of the second shift.
18 0 In your experience with New York State exercises 19 has it been usual for at least some actual shift changing to 20 be demonstrated in a full-participation exercise?
~
21 A Did you say the word " actual"?
22 0 Yes.
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g000'0101 214 marysimons'l A I would say that I have observed at least.five 2 counties.that have actually made shift changes.
3 0 Do you recall any full-participation exercises 4 where offsite emergency personnel never demonstrated any 5 actual shift changing?
6 A I can't answer that on'e-because I --
7 0 Let me ask it a different way.
8 There are many different functions that are 9 performed like traffic control functions, notification 10 functions, emergency news room functions and that' sort of 11 thing. I am not asking whether it-was a 100 percent shift 12 of personnel.
13 A I understand now.
14 0 But are you familiar with any exercises which you 15 consider to be full-participation exercises in which there 16 was no demonstration of actual shift changes of any kind?
17 A At least one change or two' changes were made in 18 every exercise that I can remember; maybe more, but at 19 least. We do endeavor to get the county exec to change if 20 we can.
f3 21 MR. LANPHER: Off the record a moment.
V 22 (Discussion off the record.)
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( N 000 01 01 215 corysimons 1 MR. LANPHER: All right. Back on the record.
2 BY MR. LANPHER:
3 0 Gentlemen, just prior to lunch Mr. Irwin asked 4 you some questions about the number of traffic control 5 points which generally are activated during an emergency.
6 I believe your testimony, Mr. Czech, was that the j 7 normal practice was to have at least 20 traffic-control f
8 points activated, and probably more. Is that accurate?
{ 9 A (Witness Czech) No, I don't believe that is 10 accurate.
11 A (Witness.Papile) That's not accurate.
l 12 0 In the general course for a full-participation 13 exercise, and let's take an Indian Point exercise as an 14 example, how many traffic control points would you expect 1
j 15 to have activated?
l
! 16 A (Witness Czech) I want to make it clear here 17 that in the later exercises fewer traffic control. points 18 were needed to be demonstrated because of prior successes.
19 For instance, early Ginna exercises required five por 1
i
! 20 county, for instance. Oswego had as many as five or six in 21 the earlier exercises. As we got later into the exercises, 22 fewer were required to be demonstrated.
l ACE-FEDERAL REPORTERS, INC.
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(~'2000 01 01 216 wi marysimons 1 0 Am I correct that a significant limiting factor 2 on the number of traffic control points that you would have 3 activated was the threat of impacting the routino polico 4 functions of the particular counties?
5 A That's correct.
6 MR. LANPHER: Off the record a moment.
7 (Discussion off the record.)
8 MR. LANPHER: Back on the record.
9 BY MR. LANPIIER:
I l
10 0 Gentlemon, Mr. Irwin asked you somo questions 11 about the training of emorgency workers. Is it fair to 12 stato that when problems ariso during an exorciso, whether l
l 13 they be ARCAs, deficiencies, or things that FEMA may even l
l 14 overlook but you noticed them yoursolvos, any problems that 15 ariso during the oxorciso, you attempt to tako a look at 16 from a training perspective after the oxercise?
l 17 A (Witness Papilo) Yes, wo do.
18 0 Thus it's fair to stato that any problems that l 19 ariso may be a signal that tiero could bo deficienclos in l
20 the training program?
g 21 A Yes.
U 22 0 Now, gentlemon, in the full-participation ACE-FEDERAL REPORTERS, INC.
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% ) 000 01 01 l terysimons 1 exercises with which you are familiar in New York State has l
2 it been generally the case that there has been a testing or 3 an attempt to test the adequacy of the public information j
4 program?
5 A Yes.
l l 6 0 llow is that tested?
7 MR. IRWIN: That'r, outside the scope of my ,
8 0:camination, Mr. Lanpher.
9 MR. LANPIIER: Fine. i 10 WITNESS PAPILE: By survey, usually.
l 11 BY MR. LANPi!ER:
l 12 0 By survoy, what do you mean by, survey? '
13 A (Witness Papilo) FEMA will have some people, 1
l 14 some ovaluators walk around to the public and ask them if 15 they've heard tho strons or if they know what the sirens 16 moant and what to do and so forth and so on.
17 0 Would that survey by FEMA only involve the sirens ;
18 or would it also --
19 A No, they would ask them if -- ;
I 20 0 Lot me finish the question.
1 21 A Oh, I thought you did. You paused.
l O 22 (Laughter.)
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{20000101 corysimons 1 0 or would it also involve other aspects of public 2 information activities?
3 A Yes, it would include whether they received the 4 booklets, a booklet, an information booklet, and also if 5 they're in a motel, whether they have any transient 6 information on the motel.
7 Q Any transient?
8 A Transient information posted on the bulletin 9 board and so forth and so on.
10 0 Do you consider that to be an important part of 11 the full-participation exercise?
12 A Yes, wo do.
13 0 Why?
14 A Decause the transients that we have within the 15 population may be the ones that we really have to take care 16 of in the end that are in motels and hotels. We especially 17 look out for people in summer camps, especially up in the 18 lake area, children's camps and so forth and so on.
19 0 Gentiomen, at one time during the discussion thin 20 morning I believe thoro was some discussion of the term 21 "doficioney" an used in FEMA assessment reports. What doos 22 the term " deficiency" mean to you?
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g0000101 219 corysimons.1 A It means a remedial. '
i 2 0 A remedial?
l 3 A A deficiency means to me that FEMA has found that l
4 it cannot assure the safety.of the public around that plant ,
5 and it requires a remedial drill to be held within a certain 6 number of days.
i 7 0 That is the normal practice after a full-8 participation exercise?
9 A That just happened to us, yes. :
10 0 In your experience is a remedial exercise more or
,O 11 loss automatic when deficiencios are identified? ;
l i 12 MR. IRWIN: Objection, vague. I don't know what 13 "more or loss automatic" means.
14 BY MR. LANPilER: ,
l 15 0 Do you considor thom to be automatic?
16 A (Witness Papilo) So far we have, yes. :
17 MR. LANPilER: Thoso are all of my questions.
10 Thank you, gentlomon.
19 MR. 2AllNLEUTER: I havo ono question. !
I 20 I EXAMINATION 21 11Y MR. 2AllNLEUTER:
lO l 22 0 For tho full-participation exercises in Now York l l
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{',0000101 220 rarysimons 1 State with which you are familiar have the corresponding 2 objectives included a test of the public alert notification 3 systems?
4 A (Witness Baranski) All of the full-participation 5 exercisos have included the ability to demonstrate the alert 6 notification system, which includes actual activation of the 7 sirons in sequenco with the scenario, a preparation of the 8 appropriate EBS message, insortion of that EBS message into 9 the station, and an airing of that test message.
10 Alao, as part of the alert notification 11 activationwouldbetheactivationoftheton[ radi .**
12 0 llavo each of the exorcisos included a test of 13 systems that havo boon approvod by FEMA beforehand? By 14 " systems" I moan alort notification sets.
15 A Affirmativo. All sites that have had approved 16 alort notification systems havo been testod during the full-17 participation oxercises.
18 HR. ZAllNLEUTER: No further questions.
19 MR. IRWIN: I havo just got a couple of 20 questions.
21 FURTilER BXAMINATION 22 BY MR. IRWIN:
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(] ';000 01 01 221 carysimons 1 0 Mr. Czech, you referred to Exhibit 5, the letter 2 from Mr. McQueen to Mr. Kowieski of May 24, 1983, to page 2 3 of 2 of the state exercise observer assignments and noticed 4 that it included a demonstration of. ingestion exposure 5 pathway sampling. Do you have that notation in front of you 6 yet, sir?
7 A (Witness Czech) Yes, I do.
8 0 Do you know whether that was a free-play 9 demonstration or whether it was predesignated?
10 A The person who was going to gather the sample did 11 not know ahead of time what location it would be. So that 12 was, in that respect, froe play.
13 0 Woll, what does it mean by " predesignated" here?
14 A A prodosignated location for the evaluatort in .
15 other words, a place for them to moot. FEMA had presolected 16 the location that they wanted to find. '
i 17 0 What would that demonstration have consisted of 18 for that exerciso?
19 A That would have boon the notification of the 20 appropriate person, probably from agricultu[6h arkets, to 21 go and collect the samplo. Ilo would have to find tho 22 particular f arm or f arms, collect tho appropriato samplos ACE-FEDERAL REPORTERS, INC.
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1 go0001.01- 222 m rysimons 1 and mark them as to what they were, where they were 2 - collected, and the appropriate time has to be~ filled out on 3 that.
4 They were actually -- if-I. remember right'.on'this 5 one -- brought to an airport and delivered by Civil' Air-6 Patrol to Albany.- There'was no actual. laboratory anal'ysis;.
7 however, there was data available for the dose assessment 8 people at the Albany EOC that would have related back to -
9 samples that were collected.
10 I might add that there was no wait for the actual 11 sample to arrive in Albany before that-data was given f6rth 12 because that would have been a considerable time frame.- So co e t)-d 4nC 13 that at some time af ter this was culled- the actual data was 14 available for the dose assessment. Otherwise the exercise 15 would have gone on for hours and hours.
16 0 When would this person who took the samples have 17 taken them?
18 A When?
19 0 Yes.
20 A Well, it called for the starting time at 3 21 o' clock in the afternoon. So exactly what time and how long 22 would it take to go to the location, they were supposed to ACE-FEDERAL REPORTERS, INC.
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t g00001'01- 223 merysimons 1 meet, apparently by this, at Lakeside Road and' Route 104 in 2 the town of Ontario, then given directions as to where to 3 proceed.
(
4 0 I can't tell from this attachment what the 5 starting and ending times of the exercise were. -Do you have 6 any idea?
7 A No, I don't, but we would have certain activities 8 sometimes that would go on, for example, after the EOCs
\ .
9 might be terminated. -
10 A (Witness Papile) 8:00 o' clock it would be g 11 ; because that's when the inspector got to the state EOC, the 12 vguator.
13 s Q With respect to the number of traffic control 14 points actually staffed during exercises, is it the practice 15 in New York State in exercises with which you are familiar 16 to staff more traffic control. points, to actually man them 17 thaq are going to be evaluated by FEMA?
e .
18 A (Witness Baranski) No. We try and establish the l 19 ones that FEMA is going to evaluate.
l 20 0 And then man only those points?
21 A That's correct.
22 A (Witness Papile) We wouldn't know, but there I
l ACE-FEDERAL REPORTERS, INC.
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4 llg00000101 -
2207 morysimons 1 might be some police departments or some state polico-that 2 may want to do.it, but we wouldn't, no. We don't-know, but 3 they could do it.
a r .
4 A (Witness Czech) If I may add, we~do know -- or I 5 know that in some of the Indian Point exercises that I have.
6 been involved in.that state police have set up extra traffic-7 control points and have also set up forward command posts 8 with their mobile communications on both sides of the Hudson 9 River, which was not part of the scenario, and got'us l'nto a 10 little bit of trouble because they were hoping:for a federal-O 11 evaluator to come and do it. But they set this up on1their.
~
12 own. They were free-playing the scenarios. This is :what 13 their procedures would have called for, and they did that.
14 A (Witness Papile) ThatwasinCoytlandh[You're 15 right.
16 0 That was not a universal --
17 A (Witness Czech) Well, owe also know, for example, 18 the the Department of Transportation in the Ginna exercises s, ,
19 has gone above and beyond and done things in accordance to 20 .procecures which were not necessarily called for-in the FEMA
~
g~s 21 evaluations. So we have had agencies that have done that on 0
22 their.own.. And to the extent that's done, we don't ACE-FEDERAL- REPORTERS, INC.
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3 ,;
g000101.01 2251
. 'marysimons 1 necessarily get all the feedback. 1 2 0 With respect-to the'. training-program,'you 3 indicated th'at whenever you have an' indication of a problem,:
.4 'whether an.ARCA or a-deficiency,-you examin'e'.bdth the -
.i~
l5 problem and-~the program to ensureithat you:know what's .
6 wrong.
7 How' frequently'in'your experience have you found 8 th'at a' problem indicated by . an ARCA or a deficiency.
9 indicates a substantial problem in the training program as 10 ~disting'uished from a problem.with the training of particular .
O f 11 individuals?
12 A (Witness Papile') Gee, I really don't5know. I 13 couldn't even judge.
t 14 0 Well, is it frequent?
< .15 A It's not for me to-tell.
16 0 Well, has it happened every time you've- had - an j p.
17 .ARCA or a deficiency?
18 .A No, it uses not happen every time.
. V.
19 'O Has it happened most of the times you've had :
- x '
20 ARCAs or deficiencies?
'21 A No.
. ~O-22 - MR. LANPHER: I object to'the question. He has
-l ACE-FEDERAI REPORTERS,:lNC.,
202-347 3700 Nationwide Coverage ; 8043 % 6646
. s g000'0101 '226 marysimons 1 attempted to answer it.
2 WITNESS PAPILE: I can't tell because the-ARCAs 3 are so varied. I can't tell.
4 BY MR. IRWIN:
5 0 In other words, when you have a deficiency or an 6 ARCA, it doesn't necessarily mean there.is'a problem with 7 the training program?
8 A (Witness Papile) It'doesn't necessarily.
9 0 Isn't it true that when you have a deficiency, 10 there are remedial actions short of another full-scale 11 exercise that may be used to remedy that deficiency?
12 A That's the absolute truth. They call it a 13 remedial drill.
14 0 That's right. And that can_ include a. partial 15 exercise, couldn't it?
16 A Well, that's pretty tough.~ We have to write 17 objectives for them, we have to rewriteLthe objectives and 18 we have to have observers. It's a specific part.of'the full-19 scale exercise. But that drill is specifically done for I
20 objectives.
21 0 Right. !
)
22 A It takes time. I
-ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336 4646
t
. - ce g0000101 227 marysimons 1 0 But it doesn't require a full-scale exercise?
2 A Oh, no. ,
3 0 In fact, there are some kinds of deficiencies 4 which can be remedied by a Tabletop, can't'there be?
5 A Not that.I know of.-
6 A (Witness Papile) I was going to'say not-that I 7 know of.
8 A (Witness Baranski) According to EX-3 --
9 A (Witness Papile) Right.
10 A (Witness Baranski) -- which is the guidance for 11 remedial exercise conduct, that option.is available.
12 However, FEMA has not granted us that option to date for 13 conduct of remedial exercises.
14 A (Witness Papile) And that's my answer, not that 15 I knor of, and I know what EX-3 says.
16 0 In other words, you're basing your answer on your 17 recollection of experience to date in New York State?-
18 A Absolutely.
19 MR. IRWIN: I have no further questions.
20 EMR. ZAHNLEUTER: No questions. l 21 MR. IRWIN: Thank you, gentlemen. l 22 (Whereupon, at 4:05 p.m., the deposition i
i ACE-FEDERAL REPORTERS, INC. ,
202-347-3700 Nationwide Coverage 8043364646 m . . , - .- m - -
g0000101 228 marysimons-1 concluded.)'
2 * *****
3 I have read the foregoing pages 4 through , inclusive, which 5 contain a correct transcript of-6 the answers made-by me to_the 7 questions therein recorded.
8 Signature'is subject to 9 corrections 10 /Aeg $ ide NSKI-O 11
~- AMESC.SBs- &
PAPILE 12 BNE 13 * *****
14 .
15
'16 17 18 19 20 21 Os v
22
. ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 800-336-6646
ri
_( 0000'01 01 229 marysimons 1 * *****
I 2 I, , Notary Public in
-3 and for th'e State.of New York, do hereby certify that I-am 4 notarizing and witnessing signatures'for the. Deposition _of 5 JAMES.'C. BARANSKI, JAMES PAPILE-AND LAWRENCE C. CZECH on. _
6 this , day of , 1987.
7 ~ Notary Public in'and for the 8 State of New York 9 My Commission expires 10 * *****
11 12 13 14 15 16 17 18 19 20 21 22 ACE-FEDERAL REPORTERS, INC..
202-347-3700 Nationwide Coverage . ~ 800-336-6646
CERTIFICATE OF NOTARY PUBLIC & REPORTER 230
.. s I, NJ . / ON , the officer before. whom the fore ing 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 thereafter reduced to typewriting by me or under my directlon; that said deposition is a true record of the testimony given by said witness; . that I am 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 employed by the parties hereto, nor financially or otherwise interested in the outcome of this action.
Notary Public in and for the District of Columbia My Commission Expires O
I' 6:C#M i CIT
- 3 ~ - 35n =:n :
Rcv By:xEPOx TELECCPIER 7010 ; 1-20-87 P.I
- JAN 21 '87 18:04 UDC DEC CH 2N ,
DATE: January 20,1987 Ihhhn-UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMI5SION Before the A tomic Safety and Licensina Board
)
In the Matter of
)
) Docket No. 50 322-OL-J LONG ISLAND LIGHTING COMPANY
) (EP Exercise)
(5horeham Nuclear Power Station, )
Unit 1) )
)
o
~
. STATE OF NEW YORK'5 RESPONSE To "LILCO'S PIRST SET OF INTERROCATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS TO NEW YORK STATE" The State of New York objects to LILCO's first set of interrogator!as and document requestsl on relevancy grounds and on other grounds that have been set forth previously.2 The Shoreham exercise, which took place in the absence of the execution of state and local governments' sovereign powers,is , by definition, Insufficient to satisfy regulatory requirements. Therefore, no comparisons with other exercises may be made.
1 LILCO's First-Set of Interrogatories and Requests for Production of Documents to New York State (November J,1986).
2 State of New York's Respont.e to LILCO's First Set of Interrogatories and Q Requests for Production of Documents (November 19,1986): 5 tate of New York's opposition to LILCO's Motion to Compel (December 4,1986): State of New York's opposition and Response to L1LCO's Motion to File a Reply (December 19,1986).
9
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0 Nevertheless,in compilance with the Board's Memorandum and Order of December 19,1986, the State of New York, without walving its objections, responds as follows.
LILCO Interroaatory No. !
- Please Identify by (1) plant, (2) date, (3) scope (10-mile, 30-mile EPZ, both), (4) rale (fnllevale ne partial), and (1) nature (regular, remedial. stc.) gegh FEMA-graded emergency planning exercise for nuclear power plants in which New York State personnel have participated (by developing, reviewing, or approving emercise scenarlos and/or objectives, or by participating in the exercise itself) during the last five years.
Response
, This Interrogatory seeks information about exercises that occurred in New Yoris-State in the last five years. In the Governments'second set of Interrogatories too. e -
Q LILCO, dated December 19,1986, the Governments asked LILCO to identify non-Shoreham exercises upon which LILCO intends to rely, and to identify exercise participants and facts relating to the exercises upon which LILCO Intends to rely. In its response (dated January 5,1987 - well after the Board's December 19,1986 Memorandum and Order), LILCO identified several exercises but did not identify exercise participants and facts relating to the exercises upon which LILCOintends to 1
rely. LILCO stated on page three: " Participants in any given exercise are plainly )
identifled in the FEMA post-exercise reports which are publicly available in the NRC Public Document Room. This information is as readily available to Intervenors as it is to LILCO."
The State of New York answers portions (1) and (2) of Interrogatory No. I as follows:
Ginna (January 21,1982, June 22,1933, September 26, 1983)
O radi a i== > (u rch 2. i>>2. ^#i
- 2*.1**>. s April 10,1985)
-* 28. t'**.
Indian Point 2 (March 9,1983, June 4,1936) l l
t -
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D*e M 21 '87 13:05 2C EvEC CH
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Pitzpatrick (August 11,1982) i Nine Mlle Point 1 (September 28,1983, November 13, 1985)' i Concerning portions (3), (4) and (5) of Interrogatory No.1, this Information is plainly identlfled in the PEMA post-exercise reports which are publicly available in the NRC Public Document Room. This Information is as readily available to LILCO as it is to the State of New York. Furthermore, the depositions of Messrs. Daverlo (January 3,1987), Weismantle (January 9,1987) and Behr (January 13,1987), all of whom are LILCO employees or consultants, make it clear that LILCO has access to and already has possession of all of the FEMA post exercise assessments correspnnding to the plants identified above. This is also in accord with LILCO's statements on pages three and two, respectively, of its 3anuary 5,1987 response to the Governments' December O 19,1984 second set of laterrosatories to titCOs "c^)t the pressat tim. it (LiLCO) intends to rely on PEMA post-ewerelse reports as the source of information about other exercises" and "(F)or plants located in Region 2, LILCO has examined all' full participation'exerc!ses." $1nce both the State of New York and LILCO possess the FEMA post exercise assessments In question. and since the hurden of determining the content of these documents is the same for LILCO as it is for the State of New York, the PEMA postatxercise assessments require no explanation.3 LILCO Interroaatory No. 2 Please identify all New York State personnel who have been involved, at any time in the last five years, in the development, revlew, or approval of scenarins and/or utdeutives fur PCMA stad*4 exercises for nuelear power plante in New York State.
I 3
'!his response is analogous to LILCO's statement on page eight of its January 5,1987 response to the Governments' December 19,1986 second set of O Interrogatories to LILCO seeking the texts of EB5 messagest "Both parties possess the documents in question, and the burden of determining the content of these messages is the same for Suffolk County as it is for LILCo. Many of the E55 messages have no additions or deletions at all and therefore require no explanation. The rest are clearly marked and again require no explanation."
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4 The following Individuals have, at some time over the last five years, had some involvement in the development, review, or approval of scenarlos and/or objectives for FEMA-graded exercises for nuclear power plants in New York State:
James D. Pap!!e James Baranski Lawrence B. Czech Donald 5. Davidoff Bruce D. McQueen Stephen M. Clemente I.!LCO's counsel has indicated to the State of New York's counsel that the purpose of this Interrogatory is to identify for possible deposition New York State -
personnel knowledgeable on the subject of scenarios and objective development, review and approval for FEMA-graded exercises for nuclear power plants in New York State. Because the extent and nature of the " Involvement" and knowledge of the O above listed Individuals has varied widely and, in some Instances, ilas been minor and duplicative, the State of New York particularly identifies James Paplie as a person who could be available for deposition by LILCO, although the State of New York does not by this act walve it relevancy and other stated objections. Mr. Paplie la currently serving as the Director of the New York State Radiological Emergency Preparednesa Group ("REPG") andhe has been involved in all FEMA-graded exercises for nuclear power plants in New York State for the last five years. He has extensive knowledge concerning the exercises ident!!!ed in response to Interrogatory No. I herein and the subject of Interrogatory No. 2 herein.
In an effort to faci!! tate deposition scheduling in conformance with the current discovery schedule, the State of New York's counselhave determined that Mr. Paplie could be available for a deposition in Albany, New York, on February 3,1987, provided l
that LILCO formally notices his deposition and that the deposition of Mr. Kessler, l
l currently tentatively scheduled for February 3,1987, is moved to an open date in the schedule agreed upon by all parties.
Pcu. sy:,gPcx TELEccP!so 7C10 ; 1-20-97 i:OiP" ; q ;l 7 g,
O 3
LILCO Interromatory No. 3 Please provide copies of all(1) final scenarlos,(2) final objectives which were developed, reviewed, or approved by the New York State personnelidentified in response to the previous interrogatory, (3) a!! documents prepared by New York State
! personne!!denstsled by response to the previous interrogatory as part of their development, review, or approval of those scenarlos and/or objectives, and 4) PEMA ,
post-exercise assessments for each such exercise.
l Seasonant Documents responsive to portions (1), (2), and (3) of this Interrogatory w111 be provided promptly under separate cover.
l Concerning portion (le), these dwumvi:L. . e 61:eady in the possession of LlLCO.
jeg,the response to Interrogatory No. I herein.
LILCO Interrosatory No. 4 O r < =a r==^-ir o d rcis < r n=ci 9 r ei a' ta N vara s*= ia which New York State personnel have participated or have developed, reviewed,'or approved the scenarlo and/or objectives, in the last five years please Identify (1) the total number of hospitals located in the emergency planning zone and (2) the number of hospitals that participated in the exercise. Please provide the same information for schools (public, prlyste, parochial and nursery), and for nursing homes and adult homes.
Responsel The total number of hospitals, schools, nursing homes and adult homes located in l
L!iv amassem.y pl.nninaz unes foe the plants identified in response to Interrogstory No.
I herein is the same as the total number of hospitals, schools, nursing homes and adult homes that participated in the exercises for those plants. The total number of hospitals, scheels, nursing homes and adult homes that participated in tnose exercises can be obtained from the corresponding PEMA post exercise assessments, whicit already are in the possession of LILCO. Seg,the response to Interrogatory No. I herein.
4 O
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LILCO Interroaatory No. 5 Please Identify all PEMA-graded exercises, within the last five years, for nuclear power plants located in New York State as well as those located In other states, In which New York State personnel have participated in the ingestion pathway portion of the exercise. Please identify all New York State personnel who participated in those exercises.
Ressonse Information regarding participation in ingestion pathway, portions of exercises identitled in response to Interrogatory No. I herein can be obtained from the corresponding PEMA post-exercise assessments, which already are in the possession of LILCO. hthe response to Interrogstory No. I herein. New York State personnel have not participated in the ingestion pathway portlen of any PEMA-graded exercises, within the last five years, for nuclear power plants located in other states.
O ut = in rroaator,No..
For each PEAM-graded exercise for nuclear power plants in Ne York State in the' last five years in which New York State personnel have participated or have developed, reviewed, or approved the scenario and/or objectives for the exercise, please provide the fo!!owing information:
tL L(4 S. '
- a. d the number of buses, ambulances and ambulettes that participated in the Q % Q f , e,,, L exercise, m %' b. the number of reception centers and congregate care centers that participated in the exercise and the theoretical capacity of those fac111tles,
- c. a description of the equipinent, number of personnel and facilitics that were used during the exercise for the monitoring and decontamination of evacuees and vehicles at reception centers, w
- d. a description of the equipment, number of personnel and facilities that i
were used during the exercise for the monitoring and decontamination of evacuees from nursing and adult homes,
- e. the number of traf fic impediments that were posed to the emergency response organization, 1
- f. the number of traf fic posts that were staffed, the number of traffic O control personnel that staf fed them, and the number of traffic posts that were observed by FEMA, I
- g. Whether rumor control capab!!ltles were tested and the snethod used for i testing.
4 L ,
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- 7010 : 1-10-57 i:c en : .::t ri r- 533 ;3:= 3 y,:n n '9713:s dc E Ec CH =.5
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Response
- a. The numbers of buses, ambulances and ambulettes that participated in the exercises identifled in response to Interrogatory No.1 herein can be obtained from the corresponding PEMA post-exercise assessments, which already are in the possession of LILCO. jgg,the response to Interrogatory No. I herein.
- b. The number of reception centers and congregate care centers that participated in the exercises identitled in response to Interrogatory No.1 herein can he ehentaed s sh. co..n. pen,Has stia a pnet nwnecien ,reernmente, mhleh strearty are in the possession of LILCO. jgg,the response to Interrosatory No.1 herein.
, The theoretical capacity of reception centers that participated in the exercises identified in response to Interrogatory No. I herein varied according to the number of
'O emerge-y res,onse ,e, sonnet de,ioxed to .e ,ece, tion centers.
The theoretical capacity of the congregate care centers that participated in the exercises identified in response to Interrogatory No. I herein is as follows:
Ginna (January 21, 1982) 4,348 Glnna (June 22,1983) 1,373 Ginna (September 26,1983) 3,970 Indian Point 3 (March 3,1982) 8,033 Indian Point 3 (August 24,1983) 2,367
, Indian Point 3 (November 28,1984) 4,642 l Indian Point 3 (Apell 10,1955) - no congregste care centers participated
- Indian Point 2 (March 9,1983) 6,210
- Indian Point 2 (June 4,1986) 8,193 ;
Fitzpatrick (August 11, 1982) 700 l
, Nine 1911e Point 1 (September 28,1983) 1,300 '
Nine Mlle Point 1 (November 13, 1983) 800 l c. The equipment that was used during the exercises identitled in response to Interrogatory No. I herein for the monitoring and decontamination of evacuees and ;
vehicles at reception centers was the CDV-700 monitoring device. !
The number of personnel that was used during the exercises identifled in response to Interrogatory No. I herein for the monitoring and decontamination of r ._ _ ___ __
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evacuees and vehicles at reception centers varied according to the nature of the exercise objectives. Further information regarding the number of personnel is not in the possession of the State of New York.
The facilities that were used during the exercises identified in response to
. Interrogatory No. I herein can be obtained from the corresponding PEMA post-exercise assessments, which already are in the possession of LILCO. Sgg,the response to interrogatory No. I herein.
- d. In the exercises identified in response to Interrogatory No. I herein, New York State personnel did not monitor or decontaminate evacuees frein nursing and adult homes. Further Information regarding the equipment, number of personnel and-facilities that weto used during the exercises identifled in response to Interrogatery
_O No.1 he,ein eithe, is not in the ,ossession of the st.,e of se. Yo,w o, con obtained from the corresponding FEMA post-exercise essessments, which already are in the possession of LILCO. See the response to Interrogatory No. I herein.
- e. The number of traffic impediments that were posed to the emergency response organization in the exercises identified in response to Interrogatory No.1 herein can be obtained from the corresponding FEMA post-exercise assessments, which already are in the possession of LILCO. Sge,the response to Interrogatory No. I herein.
- f. The number of traffic posts that were staffed, the number of traffic control personnel that staffed them, and the number of traffic posts that were observed by PEMA in the exercises identifled in response to Interrgotory No. I herein can be obtained from the corresponding FEMA post 4xercise assessments, which already are in the possession of LILCO. 533,the response to Interrogatory No. I hereln.
.. x .
pe; ev: co Ts'_enP :s= o c . 1-Ic-r s:caes . ::: gse ;3;,a l y a w u:c w. :.. v. m ,w O
- g. Information regarding whether rumor control capabilities were tested and the method used for testing in the exercises identifled in response to Interrogatory No.
I herein can be obtained from the corresponding FEMA post-exercise assessments.
l.. which already are in the possession of LILCo. Sg,the response to Interrogatory No.1 herein. ,
l
- LILCO Interroaatory No. 7 l Did any FEMA. graded exercise conducted in the last five years in which New
' York State personnel participated include a hypotheslaed wind shift during the accident? If yes, please identify each such exercise. During any of those exercises, was an evacuation recommendation rescinded as a result of a wind shift? If so, please describe and identify and provide copies of pertinent documentation.
t l Responset With the exception of the January 21,1982 exercise at G1nna; every exercise O *ntad in respea- = inteno8atory No. i hereia inciudad - hre.*esiaod wind .
shift. An evacuation recommendation was not rescinded as a result of a wind shift In
~
any of those exercises.
LILCO Interronatory No. S Please Identify all New York State personnel who have been involved in the development of programs to train and evaluate New York State personnel who are to respond to an emergency at nuclear power plants in New York State.
Responset This interrogatory seeks the names of Individuals who have been involved in the training for exercises that occurred in New York State. In the County's first set of Interrogatories and document requests to LILCO, dated Octobe.r 10,1986, the County l asked LILCO to identify the names of certain LERO and non LERO LILCO employees as well as certain non LILCO LERO members. In its response (dated October 27, i
1986), LILCO did not reveal the sought-after names. LILCO stated on page two
"(D)lsclosure of such information would constitute an Invasion of privacy of those Individuals, which may subject them to harassment and intimidation."'
- kaahnLn.cos ocsoner 27,19:a reeense. to interrosaneri.e men s. a l .
c . - - - . . - -
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In addition, this Interrogatory has no time period for which it seeks Information.
'there are numerous indiv! duals scattered throughout assorted state agencles, some of whom are ne longer employees of the State of New York, who ar namn time, may have had some " Involvement," of one kind or another, in the development of " programs" to train and evaluate New York State personnel who are to respond to an emergency at
' nuclear power plants in New York State.
.Nevertheless,In a good faith effort to comply with the Board's Memorandum and Order of December 19,1986, such Individuals include James D. Paplie Barbara Thomas Noble 3ames Baranski Susan Carden Stephen Clemente Lawrence Czech 3.R. Dillenback George Estel Bruce McQueen Marvin $11verman
,m Donald 5. Davidoff Karim R!mawl, Ph.D.
U .
Edward Smith William Acquario Robert Knighton Richard Ahola Henry Binzer May Timer Brian Walsh Gene Milgram John DINuazo Anthony Germano Jerry Heltaman Kevin Neary Robert Lowery Linda Buss Susan Rutledge LILCO's counsel has ind!cated that the purpose of this Interrogatory is to identify for possible deposition New York State personnel knowledgeable on the subject of training New York State personnel who are to respond to an emergency at nuclear power plants in New York State. In light of the above discussion, the State of New York identitles James Paplie as a person who could be available for deposition by LILCO, although the State of New York does not by this act walve its relevancy and other stated objections. Mr. Papite has extensive knowledge concerning the subject of this Interrogatory and his experience and availabil!1ty for deposition has been discussed I Q In response to Interrogatory No. 2 herein.
yy - _ , . _ , _ , ~ , . . . . . . _ . . , _ . _ _ , . _ - - . . . . - ,.m. _- , ,
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LILCO 'hterroastory No. W Wiat sample groups, sample sizes or sampling criterin are used by the persons identified in Interrogatory 8 to evaluate the abl!!ty of New York State personnel to .
respond to an emergency at a nuclear power plant or to evaluate the effectiveness of a training program.
R,,,gggggggg Evaluation techniques used by New York State personnel vary widely, depending bpon the, functions, experience, personnel, and type of training being evaluated, as well as the plant, location, type of emergency, other entitles involved in the emergency response, and myriad other factors.
+
Fabian G. Pat .
Richard 1 r Special Counsel to the Governor ~
O- Executive Chamber State Capitol, Room 229 Albany, New York 12224 l
\
l l
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JfN 21 '5~ 15:10 LD: E EC CH _~#',~~~
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VERIFICAT!6N James Pap!!e, being duly sworn, deposes and says: that he is currently serving as the Director of the New York State Radiological Emergency Preparedness Groups that he has been involved in FEMA-graded exercises for nuclear power plants in New York State for the last five years; that he has read the answers and knows the contents theresfl and that based upon such Information of which he has perunal knowledge and with which he has been provided, he is informed and believes the matters stated i therein to be true to the best of his knowledge and belief, and on these grounds alleges
.that the matters stated therein are true and therefore verifles the foregoing on behalf of the State of New York. j i
I b pile M
State of New York ) 55: .
County of Albany
)
O Sworn to before me this A. _ day of January 1987. .
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No.4764948 <
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Federal s oEmGeneralming, Esq.
Wa hingto rge,e Cou nsel n D.C. 20472ncy Manageme nt Agenc y e
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DATE: January, 3,1987 UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensina Board In the Matter of )
)
LONG ISLAND LIGHTING COMPANY ) Docket No. 50-322.oL-5
) (EP Exercise)
(5horeham Nuclear Power Station, )
Unit 1) )
) -
O CERTIFICATF, OF SERVICE I hereby certify that copies of the State of New York's Response to LILCO's First Set of Interrogatories and Requests for Production of Documents to New York State have been served on the following this 20th day of January 1987 by U.S. mall, first class, except as otherwise noted.
John H. Frye, !!! Dr. Oscar H. Paris Chairman Atomic Safety and Lleensing Board Atomic Safety and Licensing Board U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory Commission Washington, D.C. 20535 Washington, D.C. 20535 -
Mr. Frederick 3. Shon Spence W. Perry, Esq.
Atomic Safety and Licensing Board William R. Cumming, Esq.
U.S. Nuclear Regulatory Commission Office of General Counsel Washington, D.C. 20$55 Federal Emergency Management Agency Washington, D.C. 20472 0 -
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Anthony F. Earley, Jr., Esq. Joel Blau, Esq.
General Counse! Director, L'tllity Intervention Long Island Lighting Company N.Y. Consumer Protection Board 175 East Old Country Road Suite 1020 Hicksv!!!a, New York 11801 Albany, New York 12210 Mr. William Rogers W. Taylor Reveley,111, Esq.*
Clerk Hunton de Will!ams Suffolk County Legislature P.O. Box 1J33 Suffolk County Legislature 707 East Main Street
' office Building Richmond, Virginia 23212 Veterans Memorial Highway -
1 Hauppauge, New York 11788 Stephen B. Latham, Esq.
Twomey, Latham & Shee Mr. I., F. Beltt 33 West Secoc4 Street Long Island Lighting Company Riverhead, New~ York 11901 !
Shoreham Nuclear Power 5tation i North Country Road Docketing and Service Section Wading River, New York 11792 Office of the Secretary U.S. Nuclear Reguletory ('nmmigelen Ms. Nora Bredes 1717 H. Street, N.W4 Executive Director Washington, D.C. 2033S' ~
O sa ar a = o ne a a c a tistaa 195 East Main Street Hon. Peter Cohalan Smithtown, New York 11787 Suffolk County Executive H. Lee Dennison Building
- Veterans Memorial Highway Mary M. Gundrum, Esq. Hauppauge, New York 11788 New York State Department of Law 120 Broadway,3rd Floor Dr. Monroe Schneider
, Room 3-116 ' North Shore Committee New York, New York 10271 P.O. Bus 231 Wading River, New York 11792 4
' MHB Technical Associates 1723 Hamilton Avenue Lawrence Coe Lanpher, Esq.
Suite K Kirkpatrick & Lockhart
- San Jose, California 9J123 1900 M. Street, N.W.
Suite 800 Martin Bradley Ashare, Esq. Washington, D.C. 20036 Suffolk County Attorney Building 138 North County Complex Bernard M. Bordenick Esq.
t Veterans Memorial Highway U.S. Nuclear Regulatory Commission llauppauge, New York 11788 Washington, D.C. 20353 Mr. Jay Dunkleburger New York State Energy Office Agency Building #2 Empire State Plaza O- ^>>anr. New vork 12222 l
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David A. Brownlee, Esq. Mr. Stuart Diamond Kirkpatrick de Lockhart Business / Financial 1500 Oliver Building NEW YORK TIME 5 Pittsburgh, Pennsylvania 15222 229 W. 43rd Street New York, New York 10036
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' Richard J I n . psf r sq.
Deputy Spec 'o I to the Governor Executive Chamber Capitol, Room 229 ;
Albany, New York 12224
- By telecopy.
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8/15/86 Guidance Memo'randum EX-3 CONDUCTING PRE-EXERCISE ACTIVITIES AND POST-EXERCISE MEETINGS Purpose This Guidance Memorandum (GM) provides guidelines for conducting pre-exercise activities and post-exercise meetings in support of the Federal Emergency Management Agency's (FEMA) Radiological Emergency Preparedness (REP)
Program.
HAchkaround Under 44 CFR 350, it is the responsibility of a State and its local governments to conduct joint exercises as a condition of initial and continued FEMA approval. The predecessor Guidance Memorandum (GM) 17, dated January 8, 1981, provided O procedural guidance intended to improve the conduct of exercises and to establish greater uniformity among the FEMA Regions in this activity. While progress has been made, there is still diversity among Regions in the uniformity and quality of exercises conducted. This revision is a further effort at achieving greater uniformity in preparing for and conducting exercises. It supersedes the January 8, 1981, GM 17.
Guidelines I. Pre-exercise Activity Past experience has shown that joint exercises must be planned considerably in advance and each step scheduled. In order to ensure optimum results, the following milestones should be met, at a minimum. These milestones are predicated ;
on the biennial exercise frequency; if exercises are conducted more frequently than biennially, the milestone time I frames placed in parentheses should be used. l MILESTONES IDE EXERCISE OBSERVATION AND EVALUATION No Later Than Day.g Prior ig Exercise 120 days State and licensee jointly s
1
. (75) develop and submit exercise
!Q i
objectives to FEMA and NRC Regional Offices.
105 days FEMA and NRC Regional Offices l
- (60) complete reviews of objectives and withextent licensee of p/ State,1 flay after meeting necessary.
90 days State and licensee submit j (45) exercise scenario to FEMA ,
i and NRC Regions for review. ;
60 days FEMA and NRC Regions contact or
! (35) meet with State and licensee to
- discuss modifications and complete the scenario.
4
! 40 days Controller's raweting to develop l (30) coordination of exercise.
l 30 days FEMA and NRC Regions develop i (25) specific post exercise activity i schedule for debriefings and i
! meetings with the State.
- U 15 days (Optional) The RAC Chairman and NRC team leader meet to develop
! observer action plan (where
- stationed, how many from each organization, what to look for).
I day All Federal observers, both ,
onsite and offsite, meet in the
! exercise area to receive assignments and instructions.
Whenever an exercise is scheduled, the Region should promptly assure construction of a time line based on the above milestones and make it available to the State, Regional Assistance Committee (RAC) Members, NRC Region, and FEMA Headquarters. Where a plant is located on a Regional ,
boundary, the Region in which the plant is actually located 1 is considered the lead Region for purposes of scheduling, i coordination and establishing the time line. Adhering to the
! time line should permit ample time to review and negotiate
, any changes to the exercise objectives and the exercise
! scenario. However, should delays occur which may aff l scheduled exercise date, the Regional Director shall ,ect so the l
advise the State, the NRC Region, the RAC Members, and FEMA i
Headquarters. The FEMA Regional Office should make every
- effort to rectify slippage in the timetable to avoid j s rescheduling the exercise date.
! 2 i
l*
i l
The basic objectives for the exercise should be taken from l
Ot the list of 35 in section III. The objectives have been developed to generally correspond to the observable elements l
of NUREG-0654/ FEMA-REP-1, as well as the the modules contained in the " Modular Format .for Uniformity of Radiological Emergency Preparedness Exercise Observations and Evaluations." The objectives should be selected in order to l
test a significant portion of the emergency response capabilities. The selection of objectives should also ensure
- that all major elements of the plans and preparedness i organizations are tested at least once every six years as set j forth in GM PR-1. Some objectives, because of their
- fundamental nature to emergency response, are to be included i in each biennial exercise. This set of exercise objectives is to be referred to as the " core objectives." These core objectives are listed in section III (Emergency Objectives) as group A.
The objectives for each exercise shall be reviewed by both the FEMA and NRC Regional Offices before specific scenarios are written. Once reviewed, the State and licensee shall develop a scenario for submission which will include, at a minimum
- The exercise objectives,
({) The date (s), time pe riod, place (s),
participating organizations and extent of State l participation (i.e., full or partial),
- A time schedule of all key events,
- Identification of simulated events and activities,
- A chronological narrative of exercise events and activities,
- Appropriate radiological offsite release data
. with appropriate values for dose calculations, ;
. dosimetry and field monitoring and ;
meteorological data.
FEMA and NRC Regions will coordinate review of the scenario and notify the State and licensee of any necessary modifications. If necessary, a meeting to discuss modifications should be held. If agreement cannot be reached, FEMA and NRC Headquarters assistance should l be sought.
1 l II. Post-exercise Debriefings and Meetings f) 2.,
A. Three audience groups may post-exercise meetings:
be involved in i
i 3
! l i
- observers / evaluators,
[)
- exercise participants, and
(
- public/ media.
The timing and intent of the meetings may vary depending upon ,
whether the exercise is conducted in advance of FEMA 350 approval (qualifying exercise), for continued 350 approval or after a remedial exercise.
B. The following chart illustrates post exercise meeting requirements for qualifying exercises and exercises for continued FEMA approval.
OUALIFYING EXERCISE CONTINUED APPROVAL EXERCISE Observer / Evaluator Observer / Evaluator Debriefing Debriefing
! Observer / Evaluator Observer / Evaluator Exit Interviews Exit Interviews f
Exercise Participants' Exercise Participants' Briefing j Briefing s
() Public Meeting Meeting to which public and media are invited.
C. Guidance on each type of debriefing / meeting follows.
- 1. Observer / Evaluator Debriefina Jf2I analifyina l
And continued accroval exercises) l a. Observer / Evaluator Debriefinar Immediately following the conduct of the exercise, an exercise observer / evaluator debriefing should be held at assigned observer locations, as appropriate, to briefly-provide a preliminary assessment of the exercise participants' strengths and weaknesses. No attempt should be made to
- categorize exercise performance inadequacies as
" deficiencies" or " areas requiring corrective actions."
Also, no indication of a " bottom line" finding should be made i
as to whether State or local preparedness is adequate. The
- observer / evaluator debriefing is not specified under 44 CFR 350, but should be incorporated as standard procedure.
- b. Observer / Evaluator 3311 Interviewst Boon
- af ter the exercise, the RAC Chairman should effect exit interviews for all observers / evaluators. These interviews may be conducted by team leaders selected by~the RAC 7
O Chairman. The purpose of these interviews is to debrief the l t observers / evaluators to secure accurate and complete 4
i -
__.I
information per their assignments prior to their departure.
.(]) Exit interviews are not specified under 44 CFR 350, but t
should be incorporated as standard procedure. During this same period, the NRC team leader will conduct a parallel meeting with the NRC observers / evaluators of onsite performance in the exercise.
- c. As soon as possible af ter their independent debriefings, the RAC Chairman and the NRC team leader should meet to coordinate and arrange for Federal participation in the joint exercise participants' briefing.
- d. If exercise inadequacies are indicated, *:he RAC Chairman shall report same to FEMA Headquarters by telephone, per GM EX-1. Following the RAC Chairman's telephone contact with FEMA Headquarters, this debriefing can serve as the initial step in the consultation. process required in GM EX-1.
- 2. Exercise Particicants' Briefina 112I aualifyino And continued-acoroval exercises)
- a. Within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> of the completion of an exercise, a briefing involving the exercise participants, RAC Chairman, NRC representative and other RAC members and Federal observers / evaluators, as appropriate, should be held
' Ov to discuss the preliminary results of the exercise. This ~
briefing should be held in accordance with 44 CFR 350.9(a) and (d).
- b. Recommended agenda to be used is as follows
i Review of onsite actions presented by NRC, Licensee presents their views (clarifying questions or comments),
- Review of offsite actions by RAC Chairman, State and local governments present their views (clarifying questions or comments),
Review of Federal response (if applicable) by RAC Chairman, and
- Opportunity for clarifying questions or comments by licensee, State and local
,t governments.
c.The presentations should be a brief, integrated overview covering the highlights of the exercise.
Included in the presentation should be a commendation for
() good performance, where appropriate, and a preliminary assessment of the participants' strengths and weaknesses. At
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performance inadequacies as " deficiencies" or " areas
{
requiring ' corrective actions." Also, no-indication of a
- bottom line" finding should be made as to whether State or local preparedness is adequate.
- d. As soon as possible af ter this briefing, the RAC Chairman, through the consultation process, should.
Provide the state with a tentative identification of the exercise inadequacies, if any, by classification, i.e.
" deficiencies" and " areas requiring corrective ~ actions."
Again, no indication of a " bottom line" finding should be made as to whether State or local preparedness is adequate.
- 3. Public Meetina JfgI cualifyina exercises)
- a. Prior to the submission by the Regional Director of the evaluation of the plan and exercise to FEMA Headquarters, a public meeting in accordance with 44 CFR 350.10 should be held as soon as possible after the exercise in the vicinity of the nuclear power facility. Exercise participants, representatives f rom the NRC and other -
appropriate Federal, State and local- agencies should attend.
. b. The meeting should acquaint members of the public with appropriate State and local emergency plans and the results of the exercise, including strengths and weaknes-ses observed. The meeting should also answer any questions about FEMA's review and evaluation, and receive suggestions from the public for improvements or changes.
- c. During this Public Meeting an assessment of the exercise participants' performance should be made. The :
timing of the Public Meeting with relation to the post-exercise evaluation procedures will dictate the degree to which the RAC Chairman can address the exercise participants' performance. When the consultation process has progressed to the point of agreement on the degrees of inadequacies in the
- exercise participants' performance, these inadequacies can be
, discussed in their proper categorization, i.e..
" deficiencies" and " areas requiring correctAT: actions."
When an agreement'on the inadequacies in t'e c :ercise participants' performance has rot been r< ttbs discussions should be more general, i.e., in terms e; mLs.egths and i
weaknesses. Whether a " bottom line" finding is made will also depend on the status of the post-exercise evaluation process.
! d. For $4tuations in which a Public Meetlng has been held during the 350 approval process and,'thereafter, a i plan amendment is submitted which significantly changes the r Q context 'or nature' of' the planning (e.g., a chan e in the emergency planning zone that results in the inc usion of i additional jurisdictions), the FEMA Regional Director shall i
6
, 1 l
1 x
n determine whether the amendment necessitates holding another U_ ;
. Public meeting.
- 4. Meetina 12I continued IEH4 ADproval Exercises i
j ~
- a. Following an exercise for continued FEMA I
-< approval, a meeting involving exercise participants, representatives from the NRC, other appropriate Federal i agencies, the public and the media should be held in accordance with 44 CFR 350.9(e) in the vicinity of the nuclear power facility. At the discretion of the Regional Director, this meeting may be combined with the exercise participants briefing.
1-
. - b. The public and media may attend the meeting ,
as observers. However, at the discretion of the Regional Director, written questions from the public and media may be l
submitted at or after the meeting for consideration in the-exercise evaluation. Also, the Regional Director may further use his/her discretion to solicit and respond to oral questions and comments during this meeting. Under 30 circumstances should it be indicated whether State or local preparedness is adequate or inadequate. ,
- c. During the meeting, the RAC Chairman should offer an overview of the exercise and should provide his/her observations. Comments from the RAC members and FEMA
({} observers may be solicited at the discretion of the RAC Chairman.
- 5. "Meetinos" 12I exercises conducted during 21A aooroval process Requirements in 44 CFR 350 do not address the conduct of
! " meetings" for exercises, held after the initial, qualifying exercise but before the completion of the' 350 approval
. process. For such exercises, a meeting as described in 350.9(e) should be held (the context of this ' meeting in the rule is for exercises conducted for continued FEMA approval).
FEMA's evaluation of such " interim" exercises is an integral i
part of our overall 350 approval process; therefore, an i opportunity should be provided to the exercise participants, i the public, media, and other Federal agencies to discuss the
- performance of~the exercise and the preliminary evaluation.
- 6. "Meetinas" afinI remedial exercises Af ter remedial exercises required under 44 CFR 350.9(a) and 9(c) (5), it is necessary to hold a debriefing (item 2 above) and may be necessary to hold a meeting (item 3 above).
Because remedial actions may vary from remedial exercises involving many organizations to drills involving only one or two organizations, discretion is given to the Regional l
s Director to determine the need to convene a meeting to which l
7
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the public and media are invited, in accordance with 44 CFR 350.9 (e) .
O[. .
i III. Exercise Obiectives The following list of 35 exercise objectives is to be incorporated into the design of radiological emergency preparedness exercises. These objectives are presented in two groups. Group A, numbers 1 - 13, are core objectives j that are to be demonstrated in each biennial exercise. Group !
B, numbers 14 - 35, are to be included in at least one exercise during a six-year period per guidance provided in GM PR-1.
GROUP A - SQEE OBJECTIVES CORRESPONDING OBJECTIVE PART(S) QE MODULAR FORMAT NUREG-0654
- 1. Demonstrate ability EQC Sec. I E.1.,
to mobilize and EQE Sec. I E.2.
activate facilities HERIA Sec. I promptly. RELOC Sec. I :
EH Sec. I '
- 2. Demonstrate ability EQC Sec. II~ A . I . d . ,_
(]) to make decisions and to coordinate emergency A.2.a.
l activities.
- 3. Demonstrate adequacy EQC Sec. III G.3.a,H.3.
of facilities and HEDIA Sec. II displays to support emergency operations.
' 4. Demonstrate ability EQC Sec. IV F. !
to communicate with EQE Sec. III all appropriate HEDIA Sec. III locations, organ- EELQC Sec. III izations and field EA Sec. I,II J personnel. EH Sec. IV 1
- 5. Demonstrate ability EQC Sec. V I.10.,
to project field data EQE Sec. II J.10.m.
and to determine approp-riate protective measures, based on PAG's, available shelter, evacuation time estimates and all other -
appropriate factors.
- 6. Demonstrate ability EQC Sec. VII.A J.9.,
eO t
to implement protective EA Sec. I J.10.g.
actions for plume 8
i pathway hasards.
- 7. Demonstrate ability EQC Sec. VI E.6.
to alert the public ZA sec. III within the 10-mile EPS and disseminate an initial instructional message within 15 minutes.
)
- 8. Demonstrate ability EQC sec. VI E.5. l to formulate and . i distribute appropriate instructions to the public in a timely fashion. ,
- 9. Demonstrate the EQC Sec. VII.A J.10.K.
organizational ZA sec. I !
4 ability and resources j necessary to deal with j impediments to evacuation, ,
including weather or traffic obstructions.
I
- 10. Demonstrate ability EQC Sec. VIII K.3.a.b. 1 4
to continuously ZA sec. IV monitor and control ZH Sec. V -
O emergency worker exposure.
- 11. Demonstrate ability EQC Sec. II G.3.a.,
to brief the media in HEDIA sec. IV G.4.a.
a clear, accurate and EQZ Sec. IV timely manner.
- 12. Demonstrate ability to EQC Sec. IX G.4.b.
provide advance MEDIA Sec. IV coordination of infor- ,
nation released. l
- 13. Demonstrate the ability EQC sec. V J.10.e.
to make the decision, EQC sec. VIII J.10.f. ,
based on predetermined EQZ Sec. VI i criteria, to supply Z& Sec. IV l and administer KI to ZH Sec. Y emergency workers. ,
l SEQQZ A - SIREE OBJECTIVEB
- 14. Demonstrate the ability EQC sec. V J 10.e.
to make the decision, EQZ 8ec. VI J.10.f.
based on predetermined EQC sec. VIII criteria, whether to ZA Sec. IV issue KI to the general Z3 Sec. V l 4[ )
.. population, and supply I
i h and adsinister KI, once the decision has been made to do so.
(
- 15. Demonstrate the ability EQG Sec. VIII J.10.e.
i to supply and adminis- ZA Sec. IV ter KI, once the ZH Sec. Y decision has been made to do so. .
- 16. Demonstrate ability EQE Sec. II G.4.c.
to establish and HERI& Sec. VI operate rumor control in a coordinated fashion.
- 17. Demonstrate ability EQG Sec. I A.2.a.,
to fully staff EQZ Sec. I A.4.
facilities and maintain HERI& Sec. I
! staffing around the RELOC Sec. I clock.
- 18. Demonstrate ability IM Sec. I E.2.,
to mobilize and deploy ,
I.8.
field monitoring teams in a timely fashion. --
(])
- 19. Demonstrate appropriate IH Sec. II, III I.8.,
equipment and procedures I.11.
for determining ambient radiation levels.
- 20. Demonstrate appropriate EH Sec. II, III I.9.
equipment and procedures RADLAB Sec. I, II for the measurement of airborne radiciodine concen as10-grationsaslow uCi/cc in the presence of noble gases.
- 21. Demonstrate appropriate ZH Sec. II, III I.S.
equipment and procedures RADLAB Sec. I, II
, for collection and
- transport of samples of soil, vegetation, snow, p water and milk.
- 22. Demonstrate appropriate RADLAB Sec. I, C.3.
, lab operation functions Sec. II for measuring and analyzing all types of samples.
(
l 10 1
\ - 1
i'
]
1
- 23. Demonstrate ability to EQC Sec. V I.10.,
4
()
.i project dosage to the public via ingestion J.11.
pathway exposure, based on plant and field data, i and to determine approp-4 riate protective measures, based on PAG's and other relevant factors.
4 24. Demonstrate ability to EQC Sec. VII.C :J.9.,
- implement protective J.11.
actions for ingestion pathway hazards.
- 25. Demonstrate the organ- EQC Sec. VII.A J.10.j.
i izational ability and ZA Sec.-I 2
resources necessary to control access to an evacuated area. .
- 26. Demonstrate the organ- EQC Sec. VII.B- J.10.d.
izational ability and I& Sec. II.B resources necessary to 4 effect an orderly evac- '
untion within the plume O EPE of these groups: -
i transit-dependent, special needs and institutionalized.
- 27. Demonstrate the organ- EQC Sec. VII.B. J.9.,
izational ability and IA Sec. II.A. J.10.g.
resources necessary to effect an orderly evac-uation of schools within
, the plume EPI.
- 28. Demonstrate adequacy RELOC Sec. II J.12.
of procedures for the registration and radiological monitoring of evacuees.
I
- 29. Demonstrate adequacy BELQC Eec. III J.10.h.
i of facilities for mass l care of evacuees.
l
, 30. Demonstrate adequate DECQH all K.5.a.b.
equipment and procedures for decontamination of emergency workers, equip-9 ment, and vehicles.
11
.2 1
- 31. Demonstrate adequacy of MEDIC Sec. III L.4.
ambulance facilities and i
and procedures for handling contaminated, injured and exposed individuals.
- 32. Demonstrate adequacy of HEQlg Sec. II L.l.
hospital facilities and procedures for handling contaminated, injured and exposed individuals.
- 33. Demonstrate ability to To Be Developed C.1.a.b.
identify need for,
, request, and obtain-Federal assistance.
- 34. Demonstrate ability to EQC Sec. V M.4.
estimate total EQE Sec. VI population exposure.
35.* Demonstrate ability to EQC Sec. X M.l.
determine and implement appropriate measures for
, controlled recovery and reentry.
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12
STATE OF NEW YORK DEPARTMENT OF HEALTH CORNtNG TOWER e THE GOVERNOR N ELSON A. ROCKEFELLER EMPIRE STATE PLAZ A e ALB ANY, N.Y.12237
""',I,",,,,,*,"'~
c 3 paposeTeoes eXB40Bf7 YE
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, February 12, 1986 Mr. Roger B. Kowieski, P.E.
RAC Chainnan FEMA-Region II e Natural & Technological Hazards Division i
26 Federal Plaza New Yoric, NY 10278
Dear Mr. Kowieski:
Since writing to you on January 28, 1986, reference Guidance Memoranda (GM), I received a copy of Draft E1 dance Memorandum EV-2,
" Evacuation and Early Dismissal Options for School Children." This is another case of the GM being sent to licensees by other agencies and we in the State and local governments not having prior knowledge of the document.
After receiving the Draft GM-EV-2, I sent a copy to each County 4
involved in emergency planning for nuclear power plants and requested their comment. Before summarizing their comments, I want to once again re-emphasize that we need your assistance to insure that the State and the counties be requested by FEMA Regions 1 Offices to comment on any draft Guidance Memoranda before publication of the Memorandum.
in reviewing the Guidance Memorandum EV-2, it is evident that the FEMA is not aware that school districts in New York are separate political entities and the planning for the school districts is not necessarily the responsibility of the local governments. Although the guidance addresses the local government responsibility for coordinating with school officials, there is no assurance that school officials will adopt recommended emergency procedures. The issuance of EV-2 guidance by FEMA indicates that the schools in New York, as part of the State School System, should be required by law to cooperate with local government officials. In the past six years, local officials have worked closely with school officials and they have reached agreements on risk assessment.
The State of New Yort has no doubt that in the event of an energency, local and school officials will implement the protective action option most compatible with the protection of the school children and l potential general population evacuation.
O
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Mr. Kowieski February 12, 1986 We have and will continue to include local school officials in our planning process but as previously stated tnere is no guarantee tnot enir school officials have to abide by a FEMA Guidance Memorandum. The Department of Education at Federal and State levels have certain authorities. FEMA snoula explain wnat tnese autnorities are oerore putting out guiuance. su attempt to mandate is not the solution. The hands of the Emergency Manager at local.and state levels are tied unless cooperation is guaranteed.
a Attached are specific comments received from local governments.
Sincerely,
~
'v s James'D. Pfpile Directbr/
Radiological Emergency Preppredness Group JDP/sm Attachment cc: Mr. Brower Maj. Bates Mr. McGuire Mr. McBride REPG
('
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SPECIFIC COMENTS RECEIVED FROM LOCAL GOVERWlENTS
- 1. "The evacuation of schooi cniiaren unaer the continuous supervision of teachers and administrators from a school to a relocation center is a valuable and reasonable approach when confronted with a radioloofcal ;
e m yency." '
The wording on this is weak and its meaning debatable. It is imperative that the evacuated school children be under constant supervision and
. control . This applies for both the transportation phase and the i reunification phase. The schools responsibility ends only when the school reception center has been closed and the children reunited with their -
] parents, or transferred to a congregate care center.
- 2. " School officials may select one of the three options for protecting their students including: etc."
While GM-EV-2 deals with evacuation and early dismissal options for school children, it is necessary to maintain that school-officials have four options. The additional option is SHELTERING. In order to maintain continuity when discussing the plan I strongly suggest that this paragraph be amended to include " sheltering".
. 3. Early dismissal criteria should not be restrictive. Some Counties have agreements with school officials that all school options will be discussed at .the alert stage,'early dismissal at this stage is a viable and necessary alternative. Other counties make provisions to release their children at early stages and send their students to other schools or shelters outside the ten mile EPZ where they may-be picked up by parents at a later time. The guidance must pemit the local official in ennedinatinn w h e,haal arri,4=le =ad tha ?+.+a << - :::j., t: ;
detemine the optimum choice for each individual case.
- 4. " Evacuation Combined with Early Dismissal". The combining of both options (Early Dismissal and Evacuation) can best be described as " Pandora's
..," naciaac a.M. .
en -,-hon 1 ~4 ni stra to r. the plan i has pit falls. For example: A) Improper communications with the schools and the EOC. B) Children leaving school with friends and entering exposed areas.
I This combined option should be stricken and the control and integrity of
, the entire school district maintained. The option of sheltering may be preferred.
I
- 5. It is not necessary for schools to be contacted by local government at specific times.
County Executive should evaluate conditions within EPZ by receiving i
recommendations from the Emergency Operations staff and then conferring l
/- with the school superintendent in regards to evacuation. Evacuation could be earlier than Site Area Emergency depending on weather and road O coaditica=. tc-
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- 6. The problem of evacuating all or part of the student population in the 10 mile EPZ should be left to the local authorities. First, you have to remove the anxiety of the parents and school officials regarding the safety of the children with the proper education of parents (public) and school admini uso w... tri. r e>icerits woulu di reauy know triot triei r-children would be loaded on to buses and taken to a predesignated school reception center outside the EPZ where they could be picked up and taken wI LiI LlaW91.
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STATE OF NEW YORK DEPARTMENT OF HEALTH l CORNING TOWER e THE GOVERNOR N ELSON A. ROCKEFELLER EMPIRE STATE PLAZ A e ALB ANY, N.Y.12237 D AVIO A XELROD, M.D. <
Commissioner 2 DR j E4H8Sf7 May 28, 1985 _ ,pe y j 2h/F 7~ \
Mr. Roger B. Kowieski, P.E.
RAC Chairman Federal Emergency Management Agency 26 Federal Plaza New York, NY 10278
Dear Mr. Kowieski:
Attached are the revised exercise objectives for the 1985 d.E. Ginna Exercise. These revisions include the comments from our May 21, 1985 meeting with the-State, Counties, FEMA and RAC.
The ingestion pathway objectives have been deleted since these issues will be addressed during a future ingestion pathway O exercise.
If you have any additional questions, please contact James Baranski of my staff at 518-473-3393.
S~ cerel
/
Bruce D. cQ een Acting Director Radiological Emergency Preparedness Group Attachment V01612 O
i- , C.t. Uu "
4 *
. ,, J. . gq
STATE OF NEW YORK DEPARTMENT OF HEALTH tower SUILDING e THE GOVERNOR NELSON A. ROCKEFELLER EMPIRE STATE PLAZA o ALB ANY, N.Y.' 12237
(_/
onvio axci.noo. u.o.
c- . .,.a .'
2 espoSITION EXM8SBT
$6 ji May 24, 1983
,77 Mr. Roger B. Kowieski, P.E.
Chairman Regional Assistance Committee Federal Emergency Management Agency Region II 26 Federal Plaza New York, NY 10278 Attention: Mr. Paul Weberg
Dear Mr. Kowieski:
Enclosed, as requested, please find revised Exercise-Observer assignment sheets, maps on which the locations of activities and State or County facilities are identified, and
{} keys to the maps.
At our meeting on May 19, 1983, Mr. Weberg indicated a desire to attend a debriefing of State observers. After careful consideration, we have concluded we cannot agree to this request.
During the May 19 meeting, Mr. Weberg suggested that the State and County demonstrate an EBS message to reflect changes in traffic patterns which might be caused by an impediment to an evacua-tion route. After a thorough review of State and County plans and procedures, and after consultation with involved State and County -
officials, I find that although we have the capability to generate the type of EBS message Mr. Weberg referenced, this is not the preferred method for dealing with impediments to evacuation. There-fore, neither the State nor the counties will demonstrate such a message on June 22.
I have been informed by the Wayne County Disaster Prepared-ness Director that arrangements have been completed for use of the Wayne County Court House in Lyons, New York for the public critique at 10:00 a.m. on June 24, 1983.
., '* .i .
Mr._. Roger B. Kowieski, P.E.
May 24, 1983 ;
Page 2
- V' O I had hoped to have the names of the mobility impaired in Monroe and Wayne Counties. Unfortunately, I have not yet received this information from the counties yet. In order to move this project along, I. am sending you the information I do have now. I will send you the rest as soon as I get it.
Sine rely yours .
- 74(s." !. l$N/'j' U f
/ Bruce D. Mc ueen i
/ Executive Officer-Radiological Emergency Preparedness Group Attachments bc: Mr. Czech N Mr. Clemente
- O l
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MONROE COUNTY
-1. Monroe County EOC, 111 Westfall Road, Rochester ,
I (716) 473-0710 i 2. Culver-Road Armory, 145 Culver Road, Rochester
.; Monitoring Teams (716) 271-0450 j PMC
, 3. TCP #1 -
US'104 and Bay Road
- 4. TCP #4 - - US 104 and Holt Road
- 5. Park Ridge Hospital, 1555 Long Pond Road, Rochester (716) 225-7150
- 6. Sperry High School, Lehigh Station Road, Henrietta (716) 334-5440
- 7. Schlegel & Salt Road - Site of Medical Drill Accident
- 8. Rochester Transit Service, 1372 East Main-Street,. Rochester 4 (716) 288-6050 e
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- 1. Wayne County EOC, 7370 Route 31 (Behind County Jail)
Lyons, NY (315) 946-4878 i.'
- 2. TCP #4 - Lake Road a d County Line Road
- 3. TCP #11 - US 104 and Route-350-
- 4. TCP #12 - US 104 and Knickerbocker-Road
- 5. TCP #14 - US 104 and Fisher Road i
- 6. TCP #30 - Walworth-Ontario Road and Marion Road
- 7. Wayne County Highway Garage, Rte. 31, Lyons, NY Wayne County PMC i
() Wayne Area Transportation Service
- 8. Lyons Elementary School (Site of Reception / Congregate Care Center), Rte. 14 and Williams St., Lyons, NY .
i
- 9. Lake District EOC and State PMC, Rte. 31, Newark, NY (315) 331-4880 i
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Nesty DISPOSITION FORM e - h r 1 2/3/ g7 7 -
CFFICE svuaob om FILE mEFERENCE SU SJE C T --
MNDP Siren Testing During March.1982 Indian Point Exercise '%~~[
70 the Record FROM A. W. Grushky DATE llFeb82 CMT i As a result of a telephone request on 9 Feb 82 from Dr. Stasiuk, and a '
telephone conversation on 10 Feb 82, I spoke on 11 Feb 82 with Philip McIntire, Chief, Natural and Technical Hazards Division, FEMA Region II, about their position on the sounding of sirens as part of the Indian Point REP exercise scheduled for 2 or 3 Mar 82.
The following is FEMA's position as stated by Mr. McIntire:
FEMA proposes that if the State and the utility do not want to test sirens during the March 2 or 3 Indian Point exercise it is OK with FEMA, provided that at another appropriate time there will be a full test of alert and notification procedures, including testing of the sirens.
FEMA suggests that in lieu of sirens during the exercise, a route alerting capability may be demonstrated. The more extensive the route alerting, the better position we will all be in to defend the valid'ity of the capability to implement the plan.
If neither sirens nor route alerting is demonstrated, FEMA will have to comment that the public warning capability was not demonstrated, and such capability then could be in question.
This information was relayed orally to Dr. Stasiuk and Mr. Davidoff, with confirming copy of this memorandum.
A D W. GRUSHKY Director Disaster Preparedness Program egp CP: Dr. Stasiuk Mr. Davidoff CSG I -
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- --' . ^c.ec.s w. wn MIBIT Attachmsnt 3
.., . D2 -f STATE bF NEW YORK DEPARTMENT OF HEALTH '
TOWER SulLOINs
- THE GOVERNCR N Eb5ON A. AccMEFEbbEM EM*tRE STATE PLAR A e Ab S AN Y, N.Y.132FF
't . '
- Davis annmee, u.0, ;
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August 29, 1993
.- O g w SEP 1 1983 "
grngt gf gattatsti PitPAullIE y:
Mr.. George Brower Director -
Disaster / Emergency Preparedness 200 North Second Street Fulton, NY 13069 ,
f
Dear'Mr. Brower:
Referring to your question today on 'the decontamiriatiert '
of vehicles leaving the 10 mile IPE as to what problems may arise from water us'ad to wash off a. vehicle that may become contaminated, we believe that this is not a problem that creates ,
any major concern. ,
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(
It is believed that tho'small amount of contamination 1 that ray settle on a car will be diluted to a great extent by washing and that this water can either seep into the ground or enter the sewer system. Care should be taken to see that the wash i l
water does not enter the area where people gather. ,
, The ' major concern with contamination is still with human l
/ beings firsteand equipment second. I hope this information gives '
- you*enough.g61dancesto answer your questione.
I 81poorely you ,
a f p MW nald D. Davidoff f
Director l Radiological Emergency Preparedness Group
.h co: Mr. Nowieski, FEMA 1
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3 espoemon ex .e t MY .
y STAT OF NEW YORK DEPART ComMING 70944 o TMs GOVERNOR MSLSON A. ReCMEPELLER saspeng STATE PLARA e ALS ANY, N.Y. II2F LT t
DavisassLN.u.a.'
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, c- November 16, 1983 3L ,
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k my 3 . g W y 5 Mr. George Brower f "m a muun n.= ::,_,i ,
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5 Disas / Emergency Preparedness *fY. gf. .:; -
200 N Second* street '- . . 2 C.,
Fuito NY 13069 '
4 Dear . Brower -
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' The question of what to do with weste shower water g tHat a become contaminated due to the cleansing of a -
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i contaAinated L individual hea been asked.
'. In consultation with Dr. Karim Rimawi, Director, Bures of Environmental Radiation Protection, it has been ,
date ned that such waste water should be allowed to flow I -
dirac y into.the normal. sewer system since it would be , . ' 'g gras diluted by the volume of water in the eyetsim and f! f,Y ~
ther re pose no health problems. . .
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sincerely yours, [,,.g f
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nald . Dav d gu ,
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irector y,g y y, dialogical Emergency Preparedness Group
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J STATE OF NEW YORK M., DEPARTMENT OF HEALTH CCRNING TOWER e THE GOVERNOR N ELSON A. ROCKEFELLER EMPIRE STATE PLAZA e ALB ANY N.Y.12237 1 OAvtoAXELROD.M.D.
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September 11, 1985 Mr. Roger B. Kowieski, P.E.
RAC Chairman Federal Emergency Management Agency 26 Federaf Plaza '
New York, NY 10278
Dear Mr. Kowieski:
This letter is confirmation of our agreement of September 9,1985, regarding the revision to the objectiive for staffing and. activation of the Ginna Joint News Center in a timely manner. The phrase "in a timely manner" shall be deleted from th,e objective. This deletion will allow prepositioning of JNC staff at the Center for the September 26, 1985 Ginna Exercise, c~' if desired. .
If you should have any questions on this issue, please contact me at your convenience.
i Sincerely, James Baranski Exercise Director Radiological Emergency Preparedness Group cc: Mr. Weberg Ms. Jackson Maj. Dates Ms. Wideman Mr. Papile Mr. Lowery yG{$77 Ms. Carden #
%o'[C l.c.Gesy. '.e. e* ~ i. ~ ~ .Q ~ N e.
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