ML20206H075
| ML20206H075 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/24/1986 |
| From: | Alexandra Smith ARGONNE NATIONAL LABORATORY |
| To: | |
| References | |
| CON-#287-3100 86-533-01-OL, 86-533-1-OL, OL-5, NUDOCS 8704150248 | |
| Download: ML20206H075 (146) | |
Text
gd
& ci. AT Eo c.-eeAr.r Pavb ErccE TIMN~ SCRIPT o
ORIGM-OF PRCCEEDINGF 37 APR 13 A8 :4 UNITED STATES OF AMERICA 0FFICE CF SichTAFy NUCLEAR REGULATORY COMMISSf@,ETjNG A SE?V Cf.
cRANCH ATOMIC SAFETY AND LICENSING BOARD
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x In the Matter of:
Docket No. 50-322-OL-5 LONG ISLAND LIGHTING COMPANY (EP Exercise)
(ASLBP No. 86-533-01-OL)
(Shoreham Nuclear Power Station, Unit 1)
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _x DEPOSITION OF ALBERT E.
SMITH Washington, D.
C.
Monday, November 24, 1986 ACE-FEDERAL REPORTERS, INC.
Stenotype Reporters 444 North CapitolStreet O
w>eatestee. o c.:ooot (202) 347-3700 Natienwide Coverage S00-336-6646 8704150248 861124 PDR ADOCK 05000322 T
1 CR 29004.1 11
/86 1
UNITED STATES OF AMERICA J
alsh NUCLEAR REGULATORY COMMISSION 2
ATOMIC SAFETY AND LICENSING BOARD 3
4
X 5
In the Matter of:
6 LONG ISLAND LIGHTING COMPANY
- Docket No. 50-322-OL-5 (EP Exercise) 7 (Shoreham Nuclear Power Station, Unit 1)
- (ASLBP No. 86-533-01-OL)
~~----X 8
9 10 DEPOSITION OF ALBERT E.
SMITH 11 Washington, D.C.
O(-)
Monday, November 24, 1986 12 13 14 Deposition of ALBERT E. SMITH, called for examination 15 by notice of counsel, at the law offices of Kirkpatrick &
16 Lockhart, 1900 M Street, N.W., Washington, D.C.
20036, at 17 2:05 p.m.,
before GARRETT J. WALSH, JR., a Motary Public in 18 and for the Conmonwealth of Virginia at Large, when were 19 present on behalf of the respective parties:
20 KARLA J. LETSCHE, ESQ.
GEOFFREY KORS, ESO.
21 Kirkpatrick & Lockhart 1900 M Street, N. W.
22 Washington, D. C.
20036 O-On behalf of the Intervenor, Suffolk County ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage M33MM6
2
"'s 1
APPEARANCES:
(Continuing)
(d 2
JESSINE A. MONAGHAN, ESO.
LEE B.
ZEUGIN, ESQ.
Hunton & Williams 3
707 East Main Street Richmond, Virginia 23212 4
On behalf of the Applicant, Long Island Lighting Company WILLIAM R.- CUMMING, ESO.
6 Regional Counsel Federal' Emergency Management Agency 7
Washington, D. C.
Gn behalf of FEMA 8
ORESTE RUSS PIRFO, ESO.
9 Office of Executive Legal Director Nuclear Regulatory Commission 10 Washington, D. C.
On behalf of the NRC 11 12 13 14 15 16 17 18 19 20 21
(~%
22
\\)
ACE-FEDERAL REPORTERS, INC.
M.347 3700 Nationwide Coverage 80433M646
3
.f' 1
CONTENTS
- Q].
2 3
Albert E. Smith Examination by Ms. Letsche Page 4 4
Examination by Ms. !!onaghan Page 120 5
6 7
EXHIBITS 8
FOR IDENTIFICATION 9
10 Smith Deposition Exhibit Number 1 Page 15 11 Smith Deposition Exhibit Number 2 Page 22 12 13 15 16 17 18 !
19 20 21 22 ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Coverage 800 336-6646
P 4
PROCEEDINGS 2
Whereupon, 3
ALBERT E.
- SMITH, 4
was called as a witness, and having personally affirmed, 5
was examined and testified as follows:
6-EXAMINATION BY MS. LETSCHE:
7 O
Thank you, Mr. S mith.
My name is Karla J.
Letsche.
I am with the Law Firm of Kirkpatrick & Lockart.
9 We represent Suffolk County, which is one of the Interveners 10 in the Operating License proceeding before the Nuclear 11 Regulatory Commission concerning the Shoreham Nuclear Power (j
12 Plant.
13 I am going to be asking you several questions 14 during this deposition this afternoon.
If at any time you 15 don't understand my question or you wish me to clarify it 16 for you, please let me know and I will be happy to do that.
17 will you please state your name and address 18' f r the record?
i A
My name is Albert E.
Smith.
My home address is 4517 Florence Avenue, Downers Grove -- that is two words, Illinois, 60515.
21 Q
And you are currently employed by Argonne National s
22 l
+
v ACE-FEDERAL REPORTERS, INC.
m.347 3700 Nationwide Co.aage 80 4 336-6646
5 l
Laboratory, is that right?
A That is right.
3 0
Can you tell what position you serve, please?
4 A
I am an environmental engineer.
5 0
And how long have you been with Argonne?
6 A
I have been employed by Argonne National 7
Laboratory since October 20th or 21st, 1974, I think.
O Q
And have you been an environmental engineer 9
from the beginning of your employment with Argonne?
10 A
No.
11 Q
Nhat other positions have you had with them?
12 A.
My entry position was assistant environmental i
"9 "*
3 Q
According to information provided by counsel for FEMA to other parties in this proceedings, one of your 15 responsibilities with Argonne is to provide technical support 16 to the FEMA Radiological Preparedness Program, is that 17 correct?
18 A
Could you explain what you mean by, ' technical 19 support?'
20 0
Let me rephrase the question.
Let me ask this 21 question:
Do you, in your position with Argonne, perform any c'
22 ACE-FEDERAL REPORTERS, INC.
m 347 3700 Nationmde Cowage M3M
6 work for FEMA?
A Yes.
3 Q
Can you describe that for me?
4 A
Yes.
I have been used, or I have been associated 5
with the Federal Emergency Management Agency in the capacity 6
of an observer at radiological emergency preparedness exercises.
7 I have assisted in the preparation and dissemination 8
of materials prior to drills, and I have been involved in the p9 post-exercise analysis procedures, and in preparation of g y "
0 o,wewmeds goo 10 second draft and final post-exercise assessmone.
W g
11 Q
Have you done this for exercises other than for 12 the Shoreham exercise?
A Y s.
13 O
And --let me focus on your participation in the Shoreham exercise.
I know that with respect to that exercise 15 you were an evaluator, is that correct?
16 A
Yes.
17 O
Did you assist in the preparation or dissemination 18 of materials prior to that Shoreham exercise?
Could you 19 answer the question, please, before you consult with your 20 counsel?
21 A
Before I --
22 ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.erage 800 336 66:6
7
{~~~~
~
MR. CUMMING:
You can answer the question.
THE WITNESS:
Do I have to answer it before I 3
consult with you?
4 MS. LETSCHE:
I would like you to.
THE WITNESS:
Well, you are not my attorney.
6 MS. LETSCHE:
Well, unless your attorney instructs 7
you not to answer, I would like you to answer my question.
8 THE WITNESS:
I will.
9 MR. CUMMING:
I would like you to answer the 10 question.
THE WITNESS:
Would you repeat the question, 7-please.
12 j MS. LETSCHE:
Do you want to read it back to him?
13 (Reporter reads back the last question.)
14 THE WITNESS:
I am not absolutely certain.
That 15 is my answer.
16 BY MS. LETSCHE:
(Continuing) 17 O
Do you recall assisting in the preparation of 18 any materials prior to that Shoreham exercise?
19 A
No, I don't.
May I clarify that?
The first 20 question consisted of two parts; one, related to my preparation 21 I believe, and the other the dissemination of material.
I am 22
,r -n, ACE-3EDERAL REPORTERS, INC.
I 202 347 3'00 Nationwide Co.erage 800-336 4 646
)
8
)
certain that I was not involved in the preparation in the terms of determining what words were used, what the objectives 3
were.
4 I may in fact at some point in time assisted in 5
stapling material, or delivering material to another observer, 6.
but I am not certain of that with respect to Shoreham.
7 O
Let me follow up a little bit.on that.
You said-8 that you were not involved in the preparation of specific 9
words or objectives.
Were you involved at all in reviewing 10 any drafts or proposed ob ectives prior to the Shoreham s
11 exercise?
()
12 A-To the best of my knowledge and belief, I was not.
0 Were y u nv lved in reviewing any_ draft or 13 post-exercise scenarios prior to that Shoreham exercise?
4 A
No.
15 Q
Did you participate in any meetings at which 16 proposed or draft objectives for scenarios for that exercise 17 were discussed?
18 MS. MONAGHAN:
I am going to object to this 19 line of questioning.
As I understand the position that 20 Suffolk County has taken in its filings with the Board, there 21 is no issue in this litigation which concerns the drafting or S
22 (J
ACE-FEDERAL REPORTERS, INC.
202-347-M00 Nationwide Co. case 80633M64
)
9 preparation of either objectives or draf t exercise scenarios, and I am going to object on the basis of relevancy.
MS. LETSCHE:
Could you answer the question, 4
Mr. Smith?
5 MR. CUMMING:
Answer the question.
6.
THE WITNESS:
Will you repeat the question, please?
7 BY MS. LETSCHE:
(Continuing) 0 Q
I will just repeat it.
I think I remember it.
9 Did you participate in any meetings at which proposed or 10 draft versions of exercise objectives or exercise scenarios 11 for the Shoreham exercise were discussed?
A.
No.
I l
12 Q
With respect to the Shoreham exercise, were you g
t involved in any post-exercise analysis of the proceedings that went on?
15 A
Yes.
16 Q
And were you involved with respect to the Shoreham 17 Exercise in the preparation of any draft post-exercise 18 assessment?
19 A
Yes.
20 0
And were you involved in the preparation of any 21
-- were you involved in the preparation of the final post-n.
22
(
)
ACE-FEDERAL REPORTERS, INC.
m.347 3700 Nationwide Ce. cage 80433666 4 d
10 exercise assessment for the Shoreham exercise?
A Yes.
3 Q
We will come back to that.
I just want to get 4
now the parameters of your involvement set out.
5 When did you first learn that you were going to 6'
be a~ participant in the Shoreham exercise?
7 A
I don't remember.
8 Q
Do you recall how you found out?
9 A
No.
10 Q
You don't recall who told you?
11 A
No -- I do not.
(' '!
12 Q.
Your assignment, as I understand it, was to be evaluator of evacuation operations at the EOC, is that correct?
14 A
Yes.
15 l
Q And do you have any knowledge as to why that was 16 the particular assignment you were given?
17 A
(Pause.)
I was never told why I was chosen for 18 that position.
19 O
But do you have an understanding as to why you were?
20 A
Yes.
21 Q
Why was that?
22
!o l
l s
ACE-FEDERAL REPORTERS, INC.
3)2-347-3700 Nationwide Co.ange 800-33(H5646
11 A
Because Region II personnel had quite a bit of 2
respect for my abilities as an observer.
Q Have you participated in other Region II exercises?
4 A
Yes.
5 Q
Prior to your being informed about your Shoreham 6.
exercise assignment, had you had any other contact or involve-7 ment with matters relating to the Shoreham plant?
8 A
Not officially involved, no.
9 Q
Had you had any unofficial involvement?
10 A
Yes.
11 O
Will you describe that for me?
I
)
12 A
I. knew the exercise was coming up.
I read several articles in the newspaper about it, and for some time 13 had known this event would occur.
74 Q
A rd that is what you meant by.,
' unofficial involvement,' prior to the exercise?
16 A
Yes.
17 Q
I take it you had not --
18 A
I mean I knew it.
19 O
Did you prior to the exercise see any portions 20 l
of an emergency response plan for the Shoreham plant?
21 A
Do you mean had I read the plan, or had I seen em 22 ACE-FEDERAL REPORTERS, INC.
2 2-347-3700 Nationwide Co'.erage 80 4 336-6646
12 it sitting in a room somewhere?
Q Had you read it?
A I don't think I read anything -- could one of.
4 you please repeat the question?
5 Q
I think my question was unclear.
Let me rephrase 6.
it for you.
Prior to your being given the assignment to be 7
an exercise evaluator, had you read any Shoreham-related 8
material?
9 A
I don't believe so.
10 Q
And prior to your being given that assignment, 11 had you ever been to the Shoreham plant or the vicinity of
. (~)
(_
12 the plant?
13 A
I had been to New York City, and I had been to 74 Port Washington, I think, prior to that time, yes.
Q Were those just social vacations?
A No.
I was at Region II, FEMA, in New York City, 16 I was at Argonne Support, Washington Office on FEMA business, I
17 not related to Shoreham.
18 Q
Once you got the assignment to be an evaluator 19 at the Shoreham exercise, were you provided with materials 20 to review in preparation for that?
21 A
Yes.
(:)
ACE-FEDERAL REPORTERS, INC.
g.347 3700 Nationvnde Co.erage M3M
13 lll 0
And what materials were you given?
A I can't give you a complete list at this point 3
in time.
4 0
Can you give me the best one you can?
5 A
Yes.
I was given a set of the exercise evaluator 6.
form's.
I was given an itinerary which is the schedule which 7
the observer is supposed to follow during.the exercise week.
8 I was given my assignment.
I wa's given a cover letter which 9
listed all the attachments.
10 I was given the information related to accommo-11 dations.
I was given the -- forgetting my own list at this
( ).
12 p int.
I was given the OPIP's which related to my spec..fic points of review, and there may have been other ancillary materials which I can't recall right now.
15 0
And did you review those materials before you 16 went to Long Island?
17 A
Yes.
18 Q
Let me just s how you what has been marked as 19 Lane Exhibit No. 2, and ask you if that is a copy of the 20 itinerary to which you referred?
21 A
It appears to be.
l (1) l l
ACE-FEDERAL REPORTERS, INC.
- D2-347 3700 Nationwide Cowage 800 336-6646 I
14 0
Was it your understanding, Mr. Smith, that you received complete copies of all the OPIP's that were related to your points of review prior to the exercise?
4 A
No.
In fact, it was explicitly stated on some 5
of the -- and I may have the name wrong -- evaluator critique 6.
forms, that under the points of review that only certain pages 7
of some of the OPIPs were being given to the observers.
8 Q
I see.
So you were just given portions of things 9
that were listed on your points of review?
10 A
Y,s.
11 Q
Were you provided with any portion of the LILCO 12 Plan itself, other than the OPIPs which you mentioned?
13 I w uld have to have my memory refreshed on --
A everything I had was not from an OPIP.
I got come things 4
from Appendix.
15 l
My understanding is that the OPIPs refer to the 16 plans, and the answer to your question is, yes.
17 Q
But my question was other than the OPIPs.
18 A
Oh, okay.
I am sorry.
19 Q
That is all right.
20 A
Yes, I received part or all of Appendix A, and 21 my recollection is that the OPIPs occur in Volumes 2 and 3 rw 22 ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co cerage 800 336-6646
'15 of the' Plan, and I got also some material from Volume 1 of the Plan.
3 Q
Seeing that on the counter behind you is a 4
series of five notebooks.
One of them is Appendix A.
Did 5
you review a document of that length when you are talking 6.
about Appendix A?
That is a roughly three or four inch binder.
7 A
Yeah.
I can't remember which parts of Appendix A I reviewed.
I reviewed -- all of Appendix A is not relevant 9
to every position, and I looked at the relevant portions of 10 Appendix A.
11 Q
And, I take it, you determined what was relevant
()
12 based on the points of review that you had been given, is that right?
13 w
A You mean -- I don't remember the specific portion 4
of Appendix A listed under the points of review was given, or whether it was listed as Appendix A.
16 0
All right.
Let me have marked as Smith Exhibit 17 No. 1, Group Evaluator Critique Form, of which it has at the 18 top right hand corner an evaluator's name:
A. Smith.
XX INDEX (The above referenced document
~
20 is marked Smith Exhibit No. 1, 21 for identification.)
(^)
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Naticamde Cowage 804336e646
l 16 There are twelve forms in what has been marked as Smith Exhibit 1.
3 Mr. Smith, do you recognize what has been marked 4
as Smith Exhibit No. l?
5 (Witness peruses document.)
6 A
Yes.
Wait a minute.-
I am going to clarify that.
7 0
Okay.
O A
Yes, I remember.
9 Q
Are these the exercise evaluation critique forms 10 which you received prior to the Shoreham exercise?
11 A
To the best of my knowledge and belief, they are.
J 12 Q.
Well --
A or at least they have my name on them.
13 O
To the best of your recollection, there weren't 4
additional ones other than the ones that are in this package?
15 A
No.
16 Q
And I take it that in general the portions of OPIPs 17 and other plan in Appendix A references listed under points 18'l l
of review on these forms which make up Smith Exhibit No.
1, 19 I are the portions of the Plan which you reviewed prior to the i
20 exercise, is that right?
In general?
21 A
(Pause.)
No.
m 22 i
1 ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co.aage 804336 6646
17 How did you determine which portions of the Plan Q
2 to review prior to the exercise?
3 I used this, and I went to the Plan, and I reviewed A
4 additional material.
5 Mr. Smith, did you attend a joint training Q
I see.
6.
session held in Long Island on February lith, for all the FEMA evaluators, controllers, and simulators?
7 O
A Yes.
And is the descriptions on pages 1 and 2 of 9
Q 10 Lane Exhibit No. 2, the itinerary, accurate to the best of your recollection as to what went on during that joint training 11 session?
12 A
(Witness. confers with Mr. Cumming)
To the best 3
of my knowledge and belief it is accurate.
Q Do you recall -- strike that.
In terms of your 15 for reviewing assignment at the exercise, were you responsible 16 any free-play message responses?
17 A
Within the LERO EOC, yes.
18 And I take it based on your objectives, that you Q
also were reviewing the EOC activation staffing and operation, 9
20 I is that right?
21 A
Yes.
r" 22 l
ACE-3EDERAL REPORTERS, LNC.
E - M -3700 Nationwide Co'.. rage 800 33 %
18 Q
Did you also observe any field activities during the exercise?
3 A
No.
4 O
I notice there is an item on page 2 of the 5
Exercise itinerary which talks about, under the heading:
6.
Interaction of FEMA Evaluators or Control Plan Overview, 7
FEMA Controllers and Simulators.
O Do you recall what was discussed on that subject 9
during the training session?
10 A
My understanding of the way -- the rules under 11 which this procedure is conducted would allow me to make
'i 12 either an affirmative or a negative answer to that question, because it is true in part and false in part.
13 Q
Okay.
Why don't you just tell me which part is true and which part is false.
15 A
I don't remember the specific instructions for 16 controllers, but for simulators my conclusion from what 17 was said that my position, I should not interact with 18 simulators.
19 Q
I see.
And your position was as an evaluator, 20 is that right?
21 A
My position where I was.
I was not a player.
I e'
22
)
ACE-FEDERAL REPORTERS, INC.
'02-347-3700 Nationwide Courage 80 4 336 % 4
19 was not to interact with simulators.
2 O
I take it you were expected to interact with the players though, is that right?
4 A
Yes.
5 Q
And you did that during the exercise?
6.
A Yes.
7 Q
At either that training session, or --
8 A
Can I clarify that answer.
9 Q
Certainly.
10 A
I don't think it was ever explicitly stated that 11 you are expected to interact with players.
12 Q
But you understood that that was something which 13 w s part of your role?
A Yes.
It is at every exercise.
74 O
In any of the pre-exercise training sessions that were held, did you receive any particular instructions that 16 were said to be applicable to you about your performance during 17 the exercise?
18 A
The procedures which I was -- yes.
19 Q
Can you describe them for me?
20 A
Yes.
We went over -- this will not be a complete 21 list.
We went over the procedures for handling free-play 7x 22 1
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nathnwide Co.ange 80433MM6
20 messages, which are part of my assignment.
There were descriptions of certain of the LERO procedures which I was supposed to -- whose implementation 4
I was supposed to observe.
That is it.
5 Q
What were the procedures about handling free-6 play messages that you referenced?
7 A
The free-play message was to be injected by the 0
lead FEMA controller, and it was then my job to essentially 9
track the flow of play from that, and in the messages for 10 which I was responsible, to essentually close the loop by 11 reporting at the conclusion of the free-play back to the 12 FEMA communicator at the LERO EOC.
0 Now, the lead FEMA Controller was Mr. Donovan, 13 is that right?
4 A
Yes.
15 Q
So, he injected the free-play messages to LERO 16 players at the EOC, is that right?
17 A
Yes.
18 Q
And then you would track the flow of play I think 19 is what you said.
How did you go about doing that?
If you 20 can give me a general description.
I know it varied from 21 incident to incident.
e 22
)
i ACE-FEDERAL REPORTERS, INC.
1 202 347-3700 Nationwide Co.erage 8043364;646
21
~
A Free-play messages were injected.
They were physical pieces of paper, and they were -- in my case they 3
were given to a player, who then proceeded to take certain 4
actions based on the information on that piece of paper.
5 I would observe what the player's reactions were, 6.
what' acts he took, and where the information went, and the 7
messages were set up so that certain specific actions were 8
to be looked for.
There were certain things that should have 9
happened when a message was injected.
I was supposed to 10 observe whether those things happened.
You signed the slip, and return it to the FEMA controller.
y1 O
Return it to Mr. Donovan?
A Excuse me.
Can I strike that?
13 Q
Sure.
14 A
To the FEMA communicator.
15 Q
That is fine.
And who was the FEMA communicator?
16 SA Ou, A
-Pattl--Cumat t ada.
I can spell it for you.
It is d4 V g
17 in the book.
18 Q
While we are on the same wave length here, let 19 me have marked as Smith Exhibit No.
2, a compilation of 20 documents headed Shoreham Exercise, and then various kinds 21 of messages which I will characterize as free-play messages.
r' 22 ACE-3EDERA.L REPORTERS, INC.
l 202 347-3700 Nationwide Coa.aage 804 33 6
22 ndex (The above referenced document 2
is marked Smith Exhibit No.
2, for identification.)
4 The compilation consists of nine such messages.
5 Mr. Smith, do you recognize the documents which comprise 6-Smith Exhibit No. 2?
7 (Witness peruses document.)
8 A
In part.
9 Q
In part.
Can you tell me which part you recognize?
10 A
I assume the fact that these have been redacted 11 does not intend to impinge upon my answer?
[
Q-That is correct.
12 !
A I recognize page 1, which I will call it, related 13 to the fuel truck impediment.
4 Q
Right.
l A
I recognize page 2, related to the loaded gravel 16 I truck.
17 Q
All right.
18 A
I do not recognize page 3, ambulette.
19 Q
okay.
O A
I do not recognize page 4, ambulette.
I do not 21 recognize page 5, route alert.
r^,
22
)
ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Co.erage M3%M86
23 6
l (p'2 I do not recognize page T, route alert.
I do Gtc.s l
not recognize page 7, route alert.
I don't recognize page 8, 3
route alert.
And I don't recognize page 9, ambulance.
4 That is true as of the day of the exercise.
5 Q
I don't understand what that means.
6.
A Well, I can't say right now that I didn't see some 7
of these post-exercise.
O Q
I see.
Okay.
The two that you recognized, the 9
fuel tank truck impediment message and the gravel truck 10 impediment message, were those free-play messages that you 11 evaluated the response to during the Shoreham exercise?
C
A-YU8*
12 Q
And are the forms which are the first two pages g
of Exhibit No.
2, the forms which you were given to fill out concerning your review of that response?
15 A
Yes.
16 Q
Now, were there any other free-play messages which 17 you were assigned to review the response to during tne Shoreham 18 exercise?
l 19 A
(Witness is conferring with Mr. Cumming.)
- Yes, 20 but I was not formally assigned to participate in the evaluation 21 process.
22 q
ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Co.ange 8 @ 336-66 4
24 h
Q Okay.
Can you tell me what they were?
A I am not absolutely sure.
It would be one or both; 3
I can't say for certain of the route alerting.
4 Q
There were actually three route alert messages 5
given out during the exercise.
I don't know if that would 6
have any influence in your answer.
7 A
Well, it might change both.
There are four here?
8 0
There were three sirens that were reported as 9
having failed to activate.
10 A
Let me look at this again.
Isn't this the same,
11 same message?
26, 45, and 89?
[ ')
12 Q.
I believe all the messages say the same thing, Y **
13 A
My best recollection is that there was only one set of siren failures, and I did observe some of the free-play 15 following the injection of the siren failure.
16 0
I see.
17 A
But I was not assigned to do that.
18 0
I see.
Okay.
19 A
To the best of my knowledge and belief at this time.
20 O
Let me just ask a question:
With respect to the 21 messages in Smith Exhibit ?Io. 2 that you don't recognize, for
-~.
22 I
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Co.aage 800 3W5646
25
)f instance, let's go to one on page 3, which is an ambulette message.
3 There is a space in Item Ho. 2 on that form for 4
the evacuation evaluator at the LERO EOC.
5 A
Yes.
6' 0
That was your title.during the exercise, is that 7
not right?
8 A
That is right.
9 0
But you did not fill out this form, to the best 10 of your recollection?
11 A
To the best of my recollection I did not.
yg 0
Do you know who did?
^
13 O
Was there any other person assigned to be an evacuation evaluator at the LERO EOC?
15 A
Not as far as I know.
16 0
Is your answer tne same, Mr. Smith, with respect 17 to the remainder of the forms in Smith Exhibit No. 2 which 18 you do not recognize, each of which has a space for the I
evacuator evaluator at the LERO EOC?
20 A
Well, based on the handwriting that is on the 21 forms, I think I am simply incorrect in my recollection about 22 c3 ACE-3EDERAL REPORTERS, INC.
202-347-3700 NationwideCo aage 800 336-6646
26 the route alerting message, because it looks like my handwriting.
2 But that is my recollection.
Q But you don't, even with respect to the handwriting, the second and third messages which have to do with ambulettes, 5
you did not review?
6 A
Dces not look like my handwriting.
Page 5 looks 7
like my handwriting, and it corresponds with my recollection 8
as to what I saw transpire.
9 Q
Right.
Okay.
10 A
Page 6 does not look like my handwriting, nor 7, 11 nor any of the others.
12 Q-Including the last one, which has to do with an 13 ambulance?
A Yes.
74 Q
Now, before we got off the track talking about these f ree-play messages, you were talking about what you would call the pre-exercise training session, and the second 17 thing you mentioned, I believe, was a description of certain 18 LERO procedures whose implementation you were responsible for 19 reviewing.
Do you recall that?
20 A
Yes.
21 Q
Can you describe for me what that session consisted n
22
+>
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co'.aage M 33 M
27 of?
A There were some slides, overheads, whatever you 3
would call them, view-graphs on which the procedures were 4
laid out, and whoever was giving the presentation at that 5
time described to us how 'the Plan was supposed to work.
6 Q
Was there a discussinn during that training 7
session of what would or would not constitute satisfactory 8
response?
9 MS. MONAGHAN:
I am going to object to this 10 line of questioning.
I don't believe there is any contention 11 at issue here which deals with the methods by which FEMA decided to evaluate performance of the LERO organization 2
on the day of the exercise.
That.is a continuing objection 13 to this line of questioning.
14 MR. CUMMING:
Instructed to answer.
15 THE WITNESS:
Would you repeat the question, 16 please.
17 (Repcrter reads back the last question.)
18 THE WITNESS:
My best recollection is that there 19 l were general instructions given as to what constitutes 20 satisfactory or unsatisfactory performance.
I simply 21 don't recall whether we were given absolutely specific
( '-
22
^
l ACE-FEDERAL REPORTERS, INC.
l 202 347 3700 Nationmde Co' ange 800-336 6646 n
r 28
}
instructions, for example, as to how many minutes things had 2
to be done.
Where there were minutes in the Plan, my best recollection is that we were told.
But I guess I am a little 4
bit at a loss to know what you mean by, ' specific instructions.'
5 Q
That is a fair comment.
Were you provided any 6.
materials in connection with this training session containing 7
the contents of those meetings or discussions?
A Partial contents.
9 Q.
Can you describe generally for me what those 10 materials were?
11 A
I believe we were given some xerox copies of
()
11 some of the' overviews, over-heads.
1-B Q
Anything else that you recall?
13 A
I am reasonably certain that there were additional y4 materials, but I don't recall what they were.
O These materials, though, either the copies of the 16 overheads, or the other ones you can't recall specifically, 17 did they_ contain whatever instructions that may have been 18' given to you concerning what would constitute satisfactory or 19 unsatisfactory response?
O A
I don't remember.
21 0
Did you retain copies of those materials, Mr. Smith?
(~)
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Courage 800 336 4646 t
29 A
Some of them.
Q Do you still have them in your possession?
3 A
No.
4 Q
What did you do with them?
5 A
I turned them over to my counsel.
6~
Q Is that Mr. Cumming?
7 A
Yes.
8 Q
When did you turn them over to him?
9 A
About an hour and a quarter ago.
10 Q
Did you review them before you came here?
11 A
Yes.
MS. LETSCHE:
Mr. Cumming, I would request that 12 those materials be produced.
MR. CUMMING:
Request noted.
Counsel for FEMA is reviewing them to determine if any are privileged.
As soon --
15 as soon as that review is complete, which we hope is soon, 16 we will respond to your request.
17 BY MS. LETSCHE:
(Continuing) 18'l' Q
Mr. Smith, did you review any other documents in 19 preparation for this deposition today?
20 a
- yes, 21 0
Can you tell me what they were?
22
^x, AG-3EDERAL REPORTERS, INC.
202-347 3700 Nat.onwide Co.ange 804 336 6646
30 h
A I reviewed copies of some of the OPIPs.
Q All right.
3 A
I reviewed my personal notes taken on the day of 4
the exercise.
5 0
All right.
6 A
I reviewed copies of my evaluator critique forms.
7 I reviewed the relevant -- what I consider to be the relevant 8
sections of the post-exercise assessment for the February 13th, 9
1986 exercise, dated April 17, 1996.
10 L reviewed a whole bunch of -- let's say I skimmed 11 through a whole bunch of material which had been generated by the lawyers for the parties in the case.
12 3
- in p rt, some of the material which I # vi w d' I assembled during post-exercise evaluation processes.
Without the list written down, I will not represent that that list 15 is complete.
16 0
All right.
17 A
Oh, yes.
I reviewed part of Appendix A, and I 18 reviewed part of the Plan.
I think that is appropriate since 19 we are making a distinction between those.
20 0
Do you have a copy of the LILCO Plan back in your 21 office in Chicago?
,r N 22 1
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationmde Co'.nage 8&3%%t6
31 A
No.
Q So, where did you go to review these pieces of 3
the Plan?
4 A
To Ed Tanzman's office.
5 0
And did you have discussions with Mr. Tanzman 6.
about this deposition, or the review of the Plan at that time?
.A Yes.
O Q
Can you tell me what the substance of those 9
discussions were?
10 MR. CUMMING:
Counsel for FEMA objects to this 11 line of questioning.
If you can expedite or fashion a 0
12 re9"e*
- " ' 9"e='t "
""ic" t
r *"er ve"-e"ded 9'e e
do so.
TIIE WITNESS:
I will respond.
I don't have any problem with it.
15 MS. LETSCIIE:
I don't have any problems.
I am 16 just asking the questions.
17 TIIE WITNESS:
Yeah.
We discussed what we thought 18 we should review in preparation for the deposition.
We had 19
-- we discussed when the depositions would take place, and 20 we discussed -- we went through what I would term a,
' dry run,'
21 of what a deposition might be like.
p 22 BY MS. LETSCi!E:
(Continuing) v ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide courage M3M
32 O
You and Mr. Tanzman did this?
A Yes.
3 Q
Was anybody else involved in that dry run?
4 MS. ?!ONAGIIAN:
I am going to object on the grounds 5
of relevance.
6~
MS. LETSCHE:
Go ahead, Mr. Smith.
7 TIIE WITNESS:
Mr. Cumming?
O MR. CUMMING:
You may answer.
9 Ti!E WITNESS:
Yes.
10 BY MS. LETSCIIE:
(Continuing) 11 Q
Who?
O 12 A.
Although all these people were not present at every one of the meetings we held, the total list would 13 include Christoper Saricks, Terry Searles, who was all of our Direct Supervisor, William Gasper, myself, Ed Tanzman, --
M Ken Bertrarwl may or may not have been present.
I am not A
16 certain.
17 Q
Was Mr. Baldwin involved in any of these discussions?
18 A
No, I don't think so.
MR. CUM 21ING:
Counsel for FEMA objects to any 20 of this line of questioning that gets into conversations 21 between any of those individuals and myself.
O ACE-FEDERAL REPORTERS, INC.
202 347.)?00 Nationwate Co.asse MJMM4
33 MS. LETSCIIE :
So far, you haven't been listed as 2
being present.
MR. CUMMING:
I was not present.
I was just 4
giving you advance notice.
5 Continuing the objection as to relevance.
6.
TIIE WITNESS:
I would like to confer with my 7
counsel a minute.
8 MR. CUMMING:
Wait until the next question.
9 MS. LETSCIIE:
No.
Ile can confer with you now.
10 (Witness confers with Mr. Cumming.)
11 MR. CUMMING:
Mr. Smith corrects me that I was m
12 on the phone end of several conversations.
BY MS. LETSCIIE :
(Continuing) 13 Q
Mr. Smith, during these dry runs, meetings that g
you had, or discussions I will call them, was there -- strike that.
16 l
You mentioned in connection with this deposition 17 that you reviewed your personal notes that were taken on the 18 day of the exercise, is that right?
19 A
Yes.
20 0
Were those notes of the factual observations that 21 you made during the exercise?
(';
22 ACE-FEDERAL REPORTERS, INC.
202-}47 3700 Nationwate Courage 800 336M46
34 A
Yes.
O And do you still have those notes with you?
3 A
No.
4 Q
Where are they?
5 A
I don't know.-
6-0 What did you do with them after you reviewed them?
7 A
I turned them over to counsel, Mr. Cumming.
8 MS. LETSCIIE :
Mr. Cumming, I request a copy of those notes.
9 MR. CUMMING:
Counsel for FEMA is reviewing the 10 notes.
As soon as he is out of these depositions, he will 11 determine whether or not there is anything to assert privilege
~
12 over.
If not, produce them.
13 BY MS. LETSCIIE :
(Continuing) 14 Q
Just to continue down this line, Mr. Smith, you 15 also indicated that you had copies of the evaluator critiaue 16 forms.
I take it these were copies that you had filled out, 17 had your filled out comments on them, correct?
18 A
yes.
19 0
Itave you also turned those over to Mr. Cumming?
20 A
Yes-21 Q
Did you just turn those over to him today also?
22 ACE-3EDERAL REPORTERS, INC.
202 347 3700 Nationwide Co'.erage KGJ3M/A6
35 A
Yes.
Q And is that true for the personal notes as well?
3 A
Yes.
4 MS. LETSCHE:
Mr. Cumming, I request copy of 5
those evaluation sheet forms --
6 MR. CUMMING:
FEMA counsel is reviewing those.
7 I note for the record they were produced post-exercise, and 0
are subject to deliberative privilege.
9 MS. LETSCHE:
Let's see whether that is true or 10 not.
11 BY MS. LETSCHE:
(Continuing) 7, 12 Q.
Mr. Smith, the evaluator critique forms which have your comments on them, they are copies of what has been 13 a
marked Smith Exhibit No.
1, but with handwritten notes on them, is that correct?
15 A
I don't know.
Let me see Smith Exhibit No. 1.
16 I
Q It is right here.
17 (Ms. Letsche hands the witness a document.)
18 A
No.
19 Q
They are not?
20 A
No, they are not.
21 Q
Can you describe them for me then?
22 O
Aa-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Co'.aage 8043366646
I j
36 A
They are copies of these with my comments on them, except I did not fill out Field 1, which is included 3
in Smith Exhibit No.
1.
4 Q
I see.
So, it is all except the last one, 5
right?
6 A
Yes.
And those -- well --
7 (Witness confers with Mr. Cumming.)
8 MS. LETSCHE:
Mr. Cumming, if you wish to 9
confer with your w'itness, that is fine, but I would prefer 10 that you do it either during a break, so I can hold off 11 on a question while you do that.
12 MR. CUMMING:
I thought you were holding off 13 l n a qu stion.
BY MS. LETSCHE:
(Continuing) 4 Q
Mr. Smith, when did you write the comments or observations on the exercise evaluation critique forms that 16 you gave to Mr. Cumming?
17 A
It depends on which one you are talking about.
18 Q
Okay.
Well, we can just go through them one by 19 one, if that is the easiest for you.
20 A
No, it wouldn't help me at all, because I don't 21 remember specifically, r^S 22 ACE-FEDERAL REPORTERS, INC.
202 147-3700 Nationwide Co.erage 8@3 m
37 k
Q Okay.
Can you tell me generally?
A Yeah.
Most of them I filled out -- all I can say 3
is I filled out all of them after the conclusion of the 4
exercise.
5 There may have been some very short comments that 6~
I filled out during the exercis,e, but most of them; to the 7
best of my recollection, all of them were filled out after 8
the exercise.
9 0
And how did you go about the process of filling 10 those out?
What did you do?
MS. MONAGHAN:
Object as to relevance.
11 as tersen8:
o eue a-
- J 12 MR. CUMMING:
Witness is instructed to answer.
THE WITNESS:
I had several sources of information.
14
- s The first source of information was my personal notice-relating A 15 to my factual observations during the course of the exercise.
16 The second source of information is my short-term 17 Third source of information would have been discussions memory.
18 with other observers.
19 BY MS. LETSCHE:
(Continuing) 20 0
Is that it?
21 A
I think that covers it, yes.
22
'El ACE-FEDERAL REPORTERS, INC.
M2 347 3700 Nationwide Courage 800 336-6646
38 O
All right.
The discussions with other observers that was one of the sources for you filling out your evaluation 3
critique forms, when did those discussions take place?
4 A
I can't say exactly in all cases.
5 0
All right.
6 A
These --
7 0
Have you finished your answer?
8 A
Yes.
9 Q
Did some of them take place during the exercise?
10 A
I don't remember.
11 Q
Why did you -- what was the purpose of the discussions with the other observers, from your point of view?
12 Why did you do that?
A To clarify, for example, what was observed --
for example, to clarify with the field observer that my 15 observations at the EOC were consistent with what his experience 16 l was.
17 0
I see.
So, -- am I right it was basically to make 18 sure that your observations were accurately recorded on your 19 evaluation forns?
20 A
No.
Because my observations are my observations, 21 and if they happen to contradict someone else's, it was simply 22 a
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co.erage M336464
39 to clarify and to know ahead of time whether what I had seen 2
fit in with the overall picture.
O I see.
Was the substance of your discussions, or' 4
whatever you learned during these discussions, reflected in the 5
comment that you wrote on your evaluator critique form?
6.
A I would have to go back and check on the exact form.
If it was, it would be noted as observed in the field, 8
or some comment if it were not a direct observation on my part.
9 Q
But sitting here today without having those filled 10 out forms in front of you, you really can't specifically say 11 everything that was on those forms, can you?
y 12 A
Would you rephrase the question, please?
13 0
Yeah, that was a terrible question.
Let me try it again.
74 A
No, I can't say everything was on those forms.
I don't have them memorized.
16 Q
Right.
You stated that among the things that you 17 reviewed before your deposition was a bunch of material 18 generated by the lawyers for the parties.
Can you be a little 19 more specific as to what you reviewed in that category?
20 A
I will have to sort of retract my affirmation 21 at this point, because I might get the names all screwed up, e-22 ACE-FEDERAL REPORTERS, INC.
M -347-3700 Nationwide Coverage 800 336-6 9 6
40 f
but I reviewed what I believe is the most current set of the revised standard version.
3 I looked over -- and I think these are two different 4
things -- the interrogatories, or affirmations, or denials, 5
or whatever they are called.
I looked at the Intervener's 6.
contentions.
I scanned very rapidly certain what I take to 7
be Motions before certain adjudicatory bodies which I don't 0
even remember, ASLB, and I don't know if there were any Court 9
Motions or not.
10 0
You also stated that you reviewed in part some 11 materials which you assembled during the post-exercise
()
12 assessment process.
Can you describe for me what those materials are 13 that you reviewed?
4 A
I looked over a schedule -- a time line, which 15 I developed for the two impediments.
16 Q
Anything else?
17 A
In fact, there were several copies of those that 18 I looked at in different stages of development.
19 Q
Anything else?
20 A
I think that was it.
21 Q
And do you still have these time lines which you--
n 22 l t_;
l
\\
ACE-FEDERAL REPORTERS, INC.
I
%)2-347-3700 Nationwide Co.erage 800 336-6646
41 A
No.
Q What did you do with them?
3 A
I gave them to counsel, Mr. Cumming.
4 Q
Was that this morning that you gave them to him?
5 A
I believe it was this afternoon.
6.
MS. LETSCHE:
Mr. Cumming, I would like to include 7
in my request these time lines which Mr. Smith prepared and 0
given to you.
9 Let me also just ask, for the record, Mr. Cumming, 10 you have all these documents which you are apparently planning 11 on reviewing, and I am talking about the personal notes, and
(
17, the evaluator critique forms, and the time lines developed by Mr. Smith.
13 When is it that you intend to make a determination as to whether or not you are going to produce them?
MR. CUMMING:
By COB Monday.
16 l
MS. LETSCHE:
Well, let me just make a suggestion.
17 Perhaps we can take a ten minute break, and you can look at 18 them now, because --
19 MR. CUMMING:
I don't have them with me.
O MS. LETSCHE:
You don't have them with you?
21 MR. CUMMING:
No, I don't.
' ~ '
22 ACE-FEDERAL REPORTERS, INC.
I M -347-r 00 Nationwide Co.erage 800-3W596
42 MS. LETSCHE:
Well, let me finish what my suggestion is going to be.
It is not the least bit productive to continue 4
with the deposition of Mr. Smith, and forcing him to have to 5
try to the best of his recollection to recall things, when you 6.
are in possession of documents which would enable him to 7
refresh his. recollection and answer questions, particularly 8
if you intend to produce them on Monday.
9 I gather that during the last deposition of 10 Mr. Saricks you actually did produce some document which he 11 had created, and it is just a waste of peoples time it seems r~s t, )
12 to me to go.through these things, and then have to re-notice 13 Mr. Smith, get him back out here again some time next week, so that we can, in fact, go into some details on the subject.
14 MR. CUMMING:
Well, I can represent in good faith that when the Board's Order was issued, FEMA counsel issued dutifully---request for production was furnished to all the 17 organizations we are representing.
Documents have taken a 18 long time getting in.
We have done the best we can.
If you 19 want to cancel the deposition, that is fine.
20 MS. LETSCHE:
No, no, I am not --
MR. CUMMING:
But counsel is not going to go through 22 tO-p ACE-FEDERAL REPORTERS, INC.
ll02-347-3700 Nationwide Co.erage 800-33(HW6
43 a massive amount of documentation as received from Argonne 2
National Laboratory in the last twenty-four hours spontaneously and produce it.
I leave it up to you.
If you think there is some 5
benefit to the deposition continuing, fine.
Otherwise, we can 6.
leave.
7 MS. LETSCHE:
Well, let me just understand.
8 MR. CUMMING:
I don't know whether I received 9
time lines or not.
I did receive a package of information 10 from Mr. Smith, 11 BY MS. LETSCHE:
-(Continuing)
)
12 Q-Mr. Smith, can you tell me roughly how voluminous 4
13 the information you gave to Mr. Cumming this afternoon was?
MR. CUMMING:
I have no objection to his answering g
that question.
THE WITNESS:
Two to three centimeters thick.
16 MS. LETSCHE:
Well, why don't we take about a 17 five minute break.
18 MR. CUMMING:
That is fine.
19 (Recess.)
20 MS. LETSCHE:
Mr. Cumming,-I am going to continue 21 with the deposition, but subject to my statement earlier which
/
22 a
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.erage 800-336-6646
I 44 lll is that it doesn't make any sense to continue when there is two or three centimeters of documents presumably somewhere in 3
this city.
You could review them and make this much more 4
expeditious, but I will do as much as I can with Mr. Smith 5
without his having the ability to refresh his recollection, 6
and then we will just have to return and continue after the 7
documents are provided.
O BY MS. LETSCHE:
(Continuing) 9 Q
Mr. Smith, let me direct your attention to what 10 has been marked as Smith Exhibit No. 1, which is the set of 11 exercise evaluation critique forms.
A.
- Okay, I
12 m
Q Now, going down this first form, Smith Exhibit 3
No.
1, relates to objective EOC No. 2.
There are a number of points of review under that objective.
Did you, in fact, 15 review each of the points that are listed on this form during 16 the Shoreham exercise?
17 A
No.
18 Q
Can you tell me which ones you did review?
MS. MONAGHAN:
Let me just, while Mr. Smith is 20 reviewing this, lodge an objection to the extent that this 21 objective also includes issues concerning mobilization of the 22 s
(>
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Coverage 801336-6646
45 (As)
EOC.
That is not relevant to the contentions.
2 THE WITNESS:
I can tell you what I believe my factual observations were.
I cannot at this point in time 4
relate to specific points of review.
5 BY MS. LETSCHE:
(Continuing) 6.
Q Okay.
Why don't you tell me what your factual 7
observations were?
O A
I observed when people began responding at the EOC, 9
and I observed when the official announcement was made at the 10 EOC that the facility was operational.
11 Q
Anything else?
/~D 12 A
That is all I can recall at this point in time.
Q 0
And am I correct that in making these observations, 13
-- strike that.
You say you observed when people began responding.
15 Does that mean you wrote down the times that people arrived?
16 A
All I wrote down and all I have any memory of is 17 the time of the, essentially, the first responder.
18' Q
So, you didn't keep track of when other people 19 arrived after the first one?
20 A
No.
There was -- no.
21 Q
I take it from your description of your factual 22
,_su ACE-FEDERAL REPORTERS, INC.
X'2-347-3700 Nationwide Coserage 800-336 4646
46 observations that you did not review pager activation', which is listed on this form, is that right?
3 A
I think the pagers -- I don't know where the 4
pagers were activated from.
I certainly did not see the 5
pyr p
activation of the -paper system.
6 Q
Right.
And am I correct that you also didn't 7
observe people being notified by telephone?
O MS. MONAGHAN:
I am going to lodge a continuing 9
objection to issues of mobilization notification.
It is not 10 an issue in this litigation, on the basis of relevance.
11 THE WITNESS:
I don't recall having -- under the assumption of what you mean by that is LERO responders.,
( )
12 and n t me d rs of the public?
13 MS. LETSCHE:
That is what I meant, yes.
THE WITNESS:
I do not recall having observed 15 any notification of LERO personnel by telephone.
16 BY MS. LETSCHE:
(Continuing) 17 Q
Did you observe any notification of members of 18 the public during the exercise?
9 I observed notification of simulated members of A
20 the public.
21 Q
Can you be a little more specific?
What was it 22
(
you observed?
ACE-FEDERAL REPORTERS, INC.
- m-347-3700 Nationwide Courage 300-336 6616 e
47 llh A
Can we go back to the previous question?
Two questions ago?
3 Q
What is it you want to know?
4 A
What I was asked.
5 Q
I wanted to know what you observed of notification 6'
of the public durin'g the exercise, and your answer was that 7
you observed notification of simulated members of the public, 8
and I asked you to describe what that meant, what you 9
observed?
10 A
I observed, for example, the home coordinator 11 calling simulated home-bound people.
Q Any ther public notification activities?
12 A
I observed calls being made for schools, whether they were simulated or not, I don't know.
14 I observed -- I assume are excluded from this 15 conversations with LERO personnel, since we are discussing 16 members of the public?
17 Q
Well, I think the last question was any notification 18 of the public activities observed.
19 A
By that, I assume you mean direct comraunication?
20 Q
Any kind of communication, Mr. Smith.
I don't 21 know what you observed.
I am trying to find out what it was.
rw 22 s
ACE-FEDERAL REPORTERS, INC.
202-347-3 3 Nationwide Courage 804336 6 4
48 I am n t trying to trick you here.
I am not 2
trying to ask tricky questions.
I just want to understand what it is that you saw.
However you characterize it, it is fine 4
with me.
5 2-A A
I think that will cover it.
6.
O Did you observe LERO r sponders -- strike that.
7 Did you observe calls made to LERO responders as part of the 8
notification process?
9 A
I think I have already answered that I didn't 10 observe that.
11 Q
Did you evaluate officially t'he notification of
,)
12 the home-bound, the notification of schools during the 13 exercise?
w 74 Everything I observed during the exercise was A
official.
15 Q
Okay.
Did your -- strike that.
Were your observations concerning the notification of the simulated 17 home-bound, and notification to schools recorded on any of 18 your evaluator critique forms?
19 A
Yes.
20 0
Okay.
Can you tell me with respect to which 21 objective those observations were made?
rx 22 i
w/
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co,aage 804336-664
49 A
Probably.
(Witness peruses document.)
3 Schools, and I am without the forms in front of 4
me, I admit, and I may be incorrect.
Schools was probably 5
in relation to EOC.18.
Home-bound, was probably under 6.
Eoc 16, 7
Q Okay.
Let's do the schools first.
What was 8
your evaluation of the school notification activities which 9
you saw?
10 A
My evaluation was that the calls were made before the schools were in session and, therefore, it is my recollection 11
~
[]
at this point in time that an early dismissal was not, in fact, g
required.
I can give you a better answer to that if I check 14 on the post-exercise assessment.
15 Q
You are free to refer to that if that will help 16 you.
17 (Witness peruses document.)
MR. CUMMING:
While witness is researching this 19 issue, it might be useful as counsel for FEMA suggested this 20 morning, the entire post-exercise assessment be admitted as 21 an exhibit so it can be referred to.
22 MS. LETSCHE:
I have no objection to that.
For ACE-FEDERAL REPORTERS, INC.
M.347-3700 Nationwide Cmerage m336 6646
/
50
)lf now, I think it would be sufficient if he just wants to refer to a page number.
3 THE WITNESS:
On page 35, it is stated by 10:23 4
telephone calls simulated were being made to home bound 5
individuals.
6' That is based on my. observation.
7 BY MS. LETSCHE:
(Continuing) 8 Q
Okay.
Well, let's talk about that for a second.
9 Did you evaluate whether or not making those phone calls --
10 A
Oh, I am sorry.
I was looking for the schools.
11 O
Why don't we finish up on the home-bound since we ar on that anyway.
You found that one first.
Did you
')
12 conclude that because by 10:23 simulated telephone calls were being made to home-bound individuals, that LILCO had demonstrated the ability to notify the home-bound appropriately?
15 A
(Pause.)
By the time of my observation, to the 16 best of my knowledge and belief, the procedure called for in 17 the appropriate OPIP was being implemented.
18 Q
Am I correct, though, that you did not make a 19 determination of whether the fact that the calls were being 20 made at that time constituted adequate or inadequate 21 notification?
(m 22
\\_/
i ACE-FEDERAL REPORTERS, INC.
3 2 347-3700 Nationwide Courage SO433M686
51 A
FEMA makes those determinations, I don't.
Q You just recorded your observation of what time 3
the calls were being made, right?
4 A
Yes.
5 Q
To your knowl' edge, did FEMA make the determination 6-which you just said you didn't make, which is whether or 7
not --
8 A
I am talking about final determination as to 9
whether this objective is met.
Is that what we are talking 10 about?
Are we talking about whether the objective was met or not met?
yy Q
I was talking about a determination of whether 12 or not there had been a demonstration of adequate notification 13 to the home-bound, a determination that notification was 14 adequate.
I believe you said that you didn't make that 15 determination, that FEMA did.
16 A
Yeah.
I think I am wrong.
17 Q
Would you like to correct yourself?
18 A
Yeah.
I don't know who made it.
I certainly did 19 not ever explicitly state that that was the case.
20 Q
Let's go back to the schools, since that is what 21 we were talking about a minute ago.
(' y 22
~,
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Courage M336-6M6
52 A'
Okay.
Let me direct your attention, Mr. Saith, since 3
it might be faster, to the top of page 38 of the FEMA Report, 4
which is the discussion of the EOC 18.
5 A
Yes.
At this point in time, I donf.t know what other input may have -- what other information may have been 7
input into that statement.
8 0
You mean on your form?
9 A
From anybody's form.
10 Q
Ugh --
11 A
That is consistent with my observation.
And to the best of 'my knowledge and belief without the form in front g
of me, it is consistent with what I wrote on the form under 13 what, under EOC 18.
14 Q
Right.
Now, just for the record state what it is 15 it consists of.
All I have done is directed you to page 38 16 Can you read into the record what it is on page 38 you are 17 referring to as being consistent?
1 MS. MONAGHAN:
I am going to object to this line 19 af questioning on the ground of relevance.
There is nothing 20 st issue here in terms of the' consistency of comments of individual 21 TMA evaluators with what actually ended up in the Report.
22 s
ACE-FEDERAL REPORTERS, INC.
l 3 3.s;.3700 Nationwide Courage 800-3M
V 53 MR. CUMMING:
Answer the question.
THE WITNESS:
To the best of my knowledge and 3
belief it is consistent with the information on my form, my 4
exercise evaluation from under EOC'18 to state, as post 5
exercise assessment does, a demonstration of the organizational 6.
ability necessary to affect early dismissal of schools within 7
the ten mile EPZ could not be observed.
Both public and 0
private schools were simulated to have been contacted prior 9
to 0845.
10 BY MS. LETSCHE:
(Continuing) 11 Q
What was it that you observed that constituted O
the 1=u1etio= or c tecti =9 erivete e=a e"a11c cao 1 -
waet 12 was a
y u saw aPPening?
13 A
I observed the two school coordinators making apparently simulated calls.
I cannot recollect exactly whether 15 I questioned them about the procedure they were using.
16 My best recollection at this time is that they 17 were using check lists, and I am not certain -- I know that 18 I made the observations when the schools were complete, but 19 I don't remember whether I obtained that information by 20 asking the personnel involved in making the calls, or whether 21 I checked their log books, or whether I checked the completed 22 forms, or whether the information is posted on the bulletin ACE-FEDERAL REPORTERS, INC.
E-347-3700 Nationwide Co.. rage 800-336 6646 k-
54 W
2 board, or whether I gleaned it from a briefing.
Q 3
Have we basically exhausted your recollection at this point of what it was that you filled out on the exercise evaluation critique form for EOC 18?
S A
I believe so.
No, that is not true.
6.
O Okay.
What else was there?
7 A
Under the rules governing the use of these forms, 8
the evaluator is supposed to check a box, and I believe on 9
this one I checked, Not Observed.
10 And the reason given in the first statement, which 11 I read into the record, from the post exercise assessment. I
[)
12 Q-I cm sorry, what were you going to say?
13 A
I am not going to say anything.
14 Q
Okay.
Let's go back to the objective EOC 2, which is the first page of Exhibit No. 1.
You told me factual observations were when people began responding at the EOC, and when there was an official announcement that the facility was 17 operational.
18 And you also mentioned your observation of --
19 A
I might --
20 0
Let me finish the question.
You also mentioned 21 your observations of simulated calls to the home-bound and 22 r~3, x_/
ACE-FEDERAL REPORTERS, INC.
m.347 3700 Nationwide Co.aage 300-33(H5646 L
55 simulated calls to schools.
Were there any other factual observations. relating to your evaluation of the EOC Objective 2 -
3-that are on your. evaluation critique ' form?
4 A
Unless you go back'and read my answer to the first 5
question, I think you misstated what I told you.
6.
Q I don't mean to misstate, but it is in the record 7
whatever it is, and what I say doesn't really matter, but if you O
want to restate it again, that is fine.
9 A
I don't think I made any observations to when the 10 facility was activated.
I observed a statement that it was 11 activated, bl 12-Q-
I believe you are right.
Even my notes say that.
%J 13 I take it from that that you did not determine whether or not
-- was there any other factual observations that you made concerning EOC No. 2 that you haven't stated to me today?
15 A
(Pause. )
Yes.
16 Q
Okay.
Can you tell me what they were, please?
17 A
Referring to page 27 on the post exercise 18 assessment.
19 Q
Yes.
20 A
I observed the evacuation coordinator contacting 21 the Staff to determine what their staffing level was.
I 22 ACE-3EDERAL REPORTERS, INC.
E -347-3700 Nationwide Courage 800 LM656 J
56 observed the establishment of communication capabilities between the EOC communicators and the Port Jefferson, Patchogue and 3
what is the other one, River something or other?
4 Q
Riverhead.
5 A
Riverhead staging areas.
I observed the briefing 6.
held by the manager of local response -- well, that is 7
irrelevant, it is not an activation activity.
8 I observed that the appropriate maps, status 9
boards in the areas for which I was responsible were, in fact, 10 set up according to the Plan and all maps and status boards 11 so required were present in the areas of my primary responsi-l
)
12 bility.
i b
1 Q
And what were those areas?
13 l
A Those would be the areas Uhat would be referred to 14 as the special facilities area.
The transportation area, and 15 I still probably get the official name wrong on this one -- oh, 16 yeah, the traffic area.
17 2-B Q
All right.
Let's go to objective EOC 3 Can 18 I
you tell me what you did in reviewing or evaluating activities r
19 relating to this objective?
20 A
Yes.
21 Q
Will you do so, please?
o 22 U
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.aage M3%664 n..;
57 A
Nothing.
~~
O Why is that?
3 A
Forgot to do it.
In saying that, let me point 4
out that the arrangement was that someone else could, and did 5
in fact, cover this area.
6.
Q Do you know who did?
7 A
I believe it was Herb Fish.
8 Q
That arrangement had been made beforehand?
A Inf rmally, yes.
Wait a minute.
No, I didn't 9
sene any rosters.
10 Q
Okay.
Let's go to EOC 4, the next page.
What did you do in reviewing the activities related to this objective?
(V.
3 12 A
(Pause. )
Okay.
I observed that each person had 13 a desk and a chair, and what I thought to be appropriate
~
14 communications equipment as required by the Plan.
15 Q
Yes.
16 I observed the copies of the Plan were available.
A Again, I observed that the observation I discussed before 17 18 relative to maps and status boards is relevant here.
19 Q
All right.
20 A
And I observed that the lighting was adequate.
That as near as I could tell, my primary area of responsibility 21 r-y 22 L)
CE-FEDERAL REPORTERS, INC.
1
'02-347-3700 Nationwide Co.erage 800-33 %
s
58
~
people can see.
I observed that the four -- three staging area 3
communicators and the communicator for the road crews and 4
route spotters -- yeah, route spotters -- were equipped with headsets to help keep the' noise levels down.
I observed that 6'
noise levels, based on my experi.ence in other EOCs, were 7
adequately controlled.
8 Q
I take it you did not review whether there was 9
an ability to have expanded operations?
10 A
That is true, Q
And you didn' t review the availability of back-up 17
/ '
power?
4
()
12 MS. MONAGHAN:
I am going to object to this 13 line of questioning.
It is not relevant to any of the issues 14 in controversy here.
15 MR. CUMMING:
You may answer the question.
16 THE WITNESS:
I did not observe that, but either 17 on the day of the exercise or previous to that, I had a 18 definite understanding with Herb Fish that he would, in fact, 19 pick that up at some time during the day.
20 My best recollection on that particular issue is 21 that we went down to the emergency power room and found it locked, n
22
(,,,/
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.erage 800-3366G16
59
~-
and we decided that he would be the one to pick it up later.
Q Did you do that some time prior to the exercise 3
that you went down to that room, or during the exercise?
4 A
It depends on how one defines the beginning of 5
the exercise.
If one counts the beginning of the exercise from 6.
the declaration -- I don't think it was the day before.
I think 7
it was the day of the exercise.
If one counts the beginning 0
of the exercise from declaration of unusual event, then it was 9
during the period of the exercise.
10 It may sven have been af ter the first response, 11 I just don' t remember.
It was very early in the day.
d7_
12 Q.
Let me go to Objective EOC 7.
This is one that y u revi wed, is that correct?
13 A
Yes.
O Mr. Smith, can you tell me what observations you made during the exercise concerning EOC 7?.
16 A
I observed some of the briefings in the operations 17 area, and found them to be in all matters of which I had a 18 personal knowledge at the time of their delivery, accurate.
19 I observed the use of the various maps and status 20 boards which had been placed in three functional areas which 21 were my primary responsibility.
I observed their use.
I 22
(~w]
L ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co.ange 800-33MM6
~ij
60 examined each of the status boards, and I considered them quite adequate for the purposes for which -- I considered them adequate, 3
I am not entirely certain at this point how much 4
of the information under EOC 7, post exercise assessment report 5
is directly based on my observations.
6.
Q Okay.
7 A
And I will -- I noted that the top coordinators 8
in the traffic transportation and special facility areas kept 9
logs.
I observed various LERO workers using form that are 10 contained in the OPIPs.
~
Q All right.
yy A
I observed the use of LERO message forms to f}
1 L
transmit information from point-to-point.
And I observed the free-play of the impediment messages.
14 Could I see you out of the room?
15 MR. CUMMING:
Could we go off of the record for 16 a minute?
17 MS. LETSCHE:
Yes, that is fine.
l l
18 (Off the record discussion between Mr. Cumming 19 and witness ensues outside the deposition room.)
20 MR. CUMMING:
Back on the record.
21 BY MS. LETSCHE:
(Continuing) c 22
\\
ACE-FEDERAL REPORTERS, INC.
'02-347-3700 Nationwide Co.ange 800-33(H5646
61 Q
Mr. Smith, you mentioned that you noted that the coordinators and the transportation special facilities in 3
traffic areas kept logs?
4 Did you review those' logs?
5 A
When?
6.
O At any time.
1 A
Assuming that a review means a line-by-line review 0
of the logs, no.
9 Q
Well, did you do anything other than just observe 10 that they, in fact, exis ted?
11 A
Yes, I looked at them.
O 12 o-
^=a --
A Yes, I looked at them during the exercise.
13 Q
And did you draw any conclusions or make any l
observations based on your look at those logs?
l 15 A
Yes.
In fact, I used some of the logs to -- I l
16 transcribed some of the information on some of the logs into my 17 personal notes..
18 And I determined based on some spot checks of those 19 logs, that they seemed to be a reasonable set of notes.
That 20 was a very spotty check.
21 Q
I take it that in reviewing the status boards that 22 Ae-FEDERAL REPORTERS, INC.
372 347 3*00 Nationwide Co'. cage 800 336-6646
~
62 you did not review any status boards in the dose assessment area, or at the dose assessment area?
3 A
That is right.
That was not my area of respon-4 sibility.
5 Q
And you also didn't review any in the command room, 6'
is that right?
7 A
Well, I was present in the command room.
I did 8
not pay any attention to what was on the status board there to 9
the best of my recollection.
10 Q
Now, you said you reviewed or evaluated the free-11 Play of impediment messages.
Can you tell me what it was --
what your factual observations were, either contained in your
(
12 personal notes, or on your exercise evaluation critique form, concerning the free-play of impediment messages?
14 A
The first message was transcribed by the evacuation 15 route coordinator.
This is the gravel truck and three cars, 16 from the IERO message form.
Excuse me.
I will retract that 17 last statement.
From the FEMA free-play message form.
18 I noted, and I don't know at what point in time 19 I noted this.
If I had my notes in front of me I could tell 20 you at what time I wrote the observation.
So, it --
21 Q
To the best of your recollection.
O 22 i
w/
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Natiorwide Co.aage 800 336-6o46 J
63 A
Okay.
I mean I determined at some point during the exercise that he had, in fact, not concluded on the message 3
form the fact that the LERO responder in the field was to 4
meet a Federal evaluator in the' field.
5 Q
All right.
6~
A This piece of information was also left off of 7
the -- this piece of information being that. the LERO responder 8
was supposed to meet the FEMA observer in the field, that 9
particular instruction, or piece of information, was also left 10 off of the message form that related to the fuel trick 'which 11 the evacuation route communicator filled out some tiine shortly
{
af ter eleven-hundred.
g O
Is that the end?
A Maybe I should ask that the question be repeated.
14 Q
I just asked what factual observations you made 15 in your personal notes or in your' evaluation critique form 16 concerning the free-play of impediment messages?
17 To the best of your recollection, because you are 18 here today without those documents in front of you.
19 (Witness confers with Mr. Cumming.)
20
.MR. CUMMING:
I think he has answered the question.
21 BY MS. LETSCHE:
(ContinuingJ O
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.ange 800 336 6646
64 Q
So, all that you observed was the one message transcribed by the evacuation route' coordinator concerning the 3
gravel truck impediment, and one message by that same person 4
concerning the fuel truck?
5 A
I think we are now talking about the impediment 6.
messages, aren't we?
7 Q
Yes, we are.
i 0
A I also observed these two message forms were 9
given to the appropriate -- to the road crew route spotter 10 communicator and that he attempted to communicate the information 11 to field personnel.
[h 12 Q
Did he do so?
^^
A He was for the evacuation for the gravel truck 13 and three cars impediment.
He was able to communicate the information.
When he received the message -- gravel truck 15 message -- he checked his -- he checked the evacuation route 16 map.
He checked the route spotter map sBased'on his actions 17 after that, I assume that he determined from that check which 18 route spotter he should contact, and communicated the contents 19 of the message.
20 With the fuel truck message, he was unable to 21 contact the spotter that he wanted to contact.
22 ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co'cange 800-336 6646
65 l
I want to go out.
MR. CUMMING:
Let's,go off the record for a second.
3 (Witness and Mr. Cumming depart deposition room.)
4 (Recess.)
5 MS., LETSCHE:
We are back on tha record.
Mr.
6~
Smith, I believe you were in the. middle of your answer 7
concerning what you recall that you observed with respect to 8
the free-play of impediment messages during the exercise.
9 THE WITNESS:
Will you read-the question back, 10 please.
11 MS. LETS CHE :
I will just ask the question again,
()
it is easier.
12 BY MS. LETSCHE:
(Continuing)
Q Mr. Smith, would you tell me anything else that 14 you recall concerning your factual observations on the day 15 of the exercise relating to the free-play of impediment 16 messages?
17 MR. CUMMING:
I believe the witness has testified 18 in response to that question.
19 MS. LETSCHE:
Well, I am just asking if his 20 answer is complete.
If it is, ha can tell me that.
21 THE WITNESS:
It is slightly different from the (1)
ACE-FEDERAL REPORTERS, INC.
'02-347 3700 Nationwide Co'.aage 800 336-6646
66 W
question I thought I was answering.
2 MS. LETSCIIE :
As I said before, Mr. Smith, 3
there is nothing tricky going on here.
4 THE WITNESS:
No, no.
5 MS. LETSCIIE:
I want to know what it is you saw, 6.
and what it is you evaluated, what you decided, what you 7
dete rmined.
It is a very straightforward question.
O And I know you don't have your notes, and you 9
don' t have your evaluation critique forms in front of you, 10 so I am only asking for the best of your recollection, 11 TIIE WITNESS:
The free-play of the impediment O
12 e
eee 1
e ter bro aer toeic thee aet heeeeeea e eae l
free-P ay message.
13 I am sorry if I didn't quite understand the question.
15 BY MS. LETSCIIE :
(Continuing) 16 Q
Well, if it would be easier for you to break it 17 down into those two parts, that is fine.
18 A
No, I th % Om lave covered the handling of the 19 message form.
Q Okay.
Well, what'else is there that you observed 20 21 concerning the free-play relating to those messages?
~
22 O.
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Courage 800 336 6666
67 A
Okay.
With respect to the fuel truck -- excuse me, with respect to the gravel truck -- what I observed was 3
that the road crew route spotter communicator called the 4
spotter 1004, and asked him to -- read him the message.
Part 5
of that message included the specification of the location.
6.
Then I observed -- and I don't know whether I 7
yes, that was probably about -- let's see, it went in at 0
10:40 -- that was -- I am reasonably certain that was within 9
ten minutes of time of injection.
10 My bedt recollection is that the route spotter 11 called back several minutes later and said there wasn't 12 any thing, or he couldn't find anyone, or there was nothing at that location.
13 At that point in time, I believe there was a several minute pause.
The -- I will just call this guy 15 communicator from now on.--
16 Q
All right, that is fine, 17 A
-- released the route spotter back to his route.
18 At that time my observation was essentially complete in the 19 sense that I had observed the flow of message through the 20 bottom of the part of whatever this exhibit is.
21 0
You are referring to Smith Exhibit No. 2 Page 2, f~s 22
\\'
/
ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Conme M33(H%46
68 which has the gravel truck.
A Yeah.
So, I believe I affixed my signature to the 3
bottom of that, noted the time, and returned it to the FEMA 4
communicator.
5 She said words to
- I told her that they had 6.
released the spotter.
Her reply. to me were words to the 7
effect of they can't do that.
O I don't remember the precise interchange following 9
that.
My recollection here is -- well, I.know for a fact that 10 I was told that there was some problem in the field.
Whether 11 at that point in time I knew the exact nature of the. problem in the field, I was told that Chris, who was the field observer
( )
12 who was supposed to be at the location in the free-play 13 o
message was, in fact, at a slightly different location.
He was supposed to be -- I think it is Miller 15 and Yaphank road, is it, north of the Y Intersection.
I may 16 not have determined that at that point in time, but I was given 17
-- I am not sure precisely what was written down on the piece 18 of paper I was given at that time, but it was essentially 19 instructions, or some. kind of definition, whether map or word, 20 I don't recall, of the location in which the FEMA field 21 evaluator was, n
22 u
ACE-3EDERAL REPORTERS, INC.
I 202 347-3700 Nationwide Co.aage 800 336-6686
.69 I went back to the communicator, and conveyed this new information to him, and at this point in time my 3
memory and probably-my notes may be 'somewhat confused.
4 My best recollection at this point in time is 5
that there may have been several trips back and forth.
I 6'
believe, but I am not certain, that we had some discussions 7
with FEMA communicators desk, and I finally was able to get 8
a little map drawn of where the FEMA field observer-was 9
actually located, and I don't remember in what form I took 10 that information back to the communicator, but that information, 11 to the best of my knowledge and belief, was essentially
(]y 12 communicated to the route spotter.
I. don't know what time x.
it was.
Q Did you follow any further the response to that, and I am talking about the gravel truck impediment again.
Let 15 me just see if I understand.
16 You gave the communicator at some point in time 17 a map which showed where the Federal evaluator is going to 18 be?
19 A
I am not sure I gave him a map.
I gave him 20 some kind of information.
I may have given him information 21 several times.
There may have been several communications
{
O ACE-FEDERAL REPORTERS, INC.
lm.347 3700 Nationwide Co.aage 8533MM6
70 between me and the communicator regarding the precise location of the FEMA field evaluator.
3 Q
Right.. And then what happened?
4 A
(Pause.)
Without my notes in front of me, I am 5
not sure that I remember.
6.
Q
- okay, In your review of the messages involved 7
in responding to the gravel truck impediment, did you observe 8
that at least one of those messages did not include the 9
information about three cars being involved in the accident?
10 A
I think I am going to decline to answer that 11
, question unless instructed by counsel, because I think it
[~,
may not. have come to my knowledge -- I am not sure when it 12 m-came to ny knowledge.
g MR. CUMMING:
Witness is instructed to answer 14 the question irrespective of when it came to his knowledge.
15 THE WITNESS:
What if it is post-exercise?
i 16 MR. CUMMING:
If you have some knowledge of the 17 answer, give the answer.
You can caveat it any way you want.
18 l
As long as you, in fact, do remember.
If you don't remember, 19 then you don' t remember.
20 THE WITNESS:
I don't have anything to hide.
- Yes, 21 I know that for a fact.
o 22 t >
ACE-FEDERAL REPORTERS, INC.
I E 347-3700 Nationwide Cowage 800 336 6646
71 BY MS. LETSCHE:
(Continuing) 2 Q
That the message did not include that information?
3 A
To the best of my knowledge and belief, I think 4
I have read a copy of the message, and it does not contain 5
that information.
6.
O Was there anything else that was omitted from that 7
message which, in your opinion, should have been included?
8 A
(Pause.)
I think that was the extent of the 9
omitted information from that internal message form.
10 Q
Okay.
Did you observe any other message forms 11 relating to the gravel truck impediment, other than the one
)
we have been discussing?
12.
A Yes.
13 O
Can you describe those to me?
A No.
15 Q
Do you remember generally what they were?
16 A
They were --
17 MR. CUMMING:
You are instructed to answer 18 if you know.
That you observed during the exercise, is that lo the question?
20 THE WITNESS:
No.
It is far more open ended 21 l than that.
<'s 22 i
(
)
i ACE-FEDERAL REPORTERS, INC.
I 202-347 3700 Nationwide Co;.: rage 804336-664
72 BY MS. LETSCHE:
(Continuing)
Q Let me first if you observed any during the 3
exercise; any others - than the one you mentioned?
4 A
I am not sure.
5 Q
I assume that your notes and critique forms would 6
refresh your recollection on that?
A That is not certain.
8 0
okay.
9 A
It may.
Let me think about it, okay?
I may 10 have observed some information on a log or a message form, but 11 I just can't be sure at this point, and the specific type of
'l inf rmati n that I would have observed would have been like 12 the time the responding vehicle arrived.
Whether it was in a log or message form, or it may have been even a verbal communication.
But to the best 15 of my recollection at this point in time, it was written down.
16 Q
And that information is also likely written down 17 in your notes or your evaluation --
18 A
It is likely to be in my notes.
19 Q
Mr. Smith, did you, in evaluating the response to 20 free-play impediment message regarding gravel truck, review 21 any actions or responses or communications with the evacuation 22
('):
i ACE-FEDERAL REPORTERS, INC.
I 202 347-3700 Nationwide Co.erage 800 336 4646
73 coordinator?
A (Pause. )
Yes.
3 Q
Can you tell me what those were.
What you 4
observed?
5 A
If.at the 12:13 -- the evacuation coordinator 6.
had not yet been informed of either of the impediments.
7 At about that' time, I believe, Mr. Donovan made a decision 8
that he should be so informed, and told him.
I then observed -- I think it was very shortly 9
10 thereafter that the evacuation coordinator met in the operations area with his three people who report directly to him.
rm No, that might not be true.
I don't remember 12 who was on that meeting.
And they discussed what the situation 13 was.
Requesting certain actions be taken.
14 Q
Were they taken?
15 A
The only one that I can recall at this point in 16 time not having been taken was that the road logistics 17 coordinator was not informed until some time after 1348 18 of the need to send equipment, and I don't remember whether 19 i the type was specified or not to the site of the fuel truck 20 impediment.
21 Q
Anything else that you observed concerning the r
22 (3)
ACE-FEDERAL REPORTERS, INC.
I 202-347-3700 Nationwide Co.nage 80 4 336-6646
74 2
response to that gravel truck impediment message?
A Well, I just broadened the scope of my immediate response.
4 I can gleam through this rather extensive 5
section of this post exercise assessment and see whether off-6.
hand I had given you most of what I have in my current 7
- memory, 8
Let's see if we can speed it up a little bit.
Q 9
Was it tour observation during the exercise that there was :
10 a lack of lateral and downward communication in the chain of 11 command in responding to some. aspects of the impediment?
12 A
Yes.
13 Q
And, was that true with respect to both of the b
free-play impediment messages?
4 A
The evacuation coordinator was not informed 15 until 12:13 of either impediment shows that there was some 16 problems going up.
17 The fact that the necessity of meeting the LERO 18 observer in the field was omitted from both of the message 19 forms shows that there was some problem.
I would call that
\\ 8E"N 20
-lataHn1 transmission, although it is not clear exactly where 21 in the heirarchy structure the communicators really live.
They 22 f~')
are in a box by themselves.
l ACE-FEDERAL REPORTERS, INC.
l M -147-3700 Nationwide Courage 80433(H5646
9 75 And the fact that the road logistics coordinator was not informed of necessity of -- potential necessity of 3
sending equipment to the fuel truck impediment until some 4
time af ter -- about some ' time af ter, I think, 134 8, even 5
though that situation had been discussed previously, indicates 6.
that'there were some problems on the downward flow.
Now, whether that --
8 Q
How about the fact that information was left 9
out of the gravel truck messages, the fact that there were 10 three passenger cars involved.
Is that indicative of.any 11 problems, in your opinion?
("'I A
Yes.
12 O
What is it?
A I think that is covered under EOC 7.
It is 14 a problem with making certain that all pertinent information 15 is included in the LERO message forms.
16 Q
Was there a similar problem of failing to include 17 all pertiment information in communication among the players 18 with respect to the fuel truck impediment?
19 A
At this point in time, I think the only thing 20 that was lef t off of that message was the necessity of meeting 21 FEMA Controller.
p 22 o
ACE-FEDERAL REPORTERS, INC.
202 4 7-3700 Nationwide Co,aage 800-336 4646
76 Q
To the best of your recollection there wasn't any failure to communicate information about fuel potentially 3
leaking, or the possibility of fire?
4 A
Now that you mention it, yes.
I can refer to 5
the report.
I think there was other information left off 6.
at that point.
The fact the fuel truck was leaking; the 7
fact that there was the possibility of fire; and the fact 8
that the whole road was blocked.
9 0
And would you characterize that also as being 10 another lateral and downward communication problem?
11 A
Well, not really, and I think I probably mis-1 spoke before.
The information which was on the forms was 12 transmitted, as far as I was able to determine, accurately.
The fact that the information was deficient is a totaly different question.
15 Q
I see.
16 A
And that --
17 Q
I understand the distinction you are making.
18 Let's talk about the lack of failure to communicate the 19 information rather than focusing on the messages.
In your 20 opinion, is the failure to communicate that information, and 21 I include the stuff that was left out with respect to the gravel n
22 i
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationvnde Co.ange 800-33M646
77 llh truck, as well as that left out with respect to the fuel truck, is that indicative of a problem of some sort in LERO response 3
to those situations?
4 MS. MONAGHAN:
I am going to object.
5
. Objection.
It calls for a conclusion.
MR. PIRFO :
6' MS. MONAGHAN:
It calls for a conclusion.
7 MR. CUMMING:
It is really beyond the scope of 8
this witness' testimony.
Are you asking during the exercise 9
did he assess it?
10 MS. LETSCHE:
I am asking for his opinion, 11 MR. CUMMING:
Do you want to state it as a
('~')
hypothetical?
12 MS. LETSCHE:
I don't think it is hypothetical.
I am asking him if, in his opinion, the failure which he observed to communicate the important information that he 15 has identified concerning the gravel truck impediment and 16 concerning the fuel truck impediment, is indicative of a 17 problem on the part of LERO in responding to those impediment 18 messages.
19 MS. MONAGHAN:
I am going to object to the question 20 l again as vague.
I think the witness has already indicated he 21 understands the word, ' communicate' to have two different
()
22 ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Co.erage 8 % 3366646
78 meanings, depending on the way communicating the information.
MR. CUMMING:
We both note an objection.
But go ahead and try to answer the question.
4 THE WITNESS:
(Pause)
Yes.
5 BY MS. LETSCHE:
(Continuing) 6.
O Can you describe it for me?
7 A
I think you have done a very good job of 0
describing it as related in the question.
9 That information was not accurately transcribed.
10 As far as I know, however, the sub-set of information that was 11 Put on the LERO message forms was accurately and completely
)
12 communicated.
And I would like to state that I have a personal g
objection to answering that question, because I personally think that it requires a conclusion that I am here to try as best I can to establish facts, and not to give expert 16 opinion.
17 Q
Am I correct, then, Mr. Smith, that in your 18 role as an evaluator of EOC evacuation activities at the EOC 19 during the Shoreham exercise, that you did not reach any 20 conclusions about whether responses were adequate or inadequate?
21 A
Whether responses are adequate or inaccurate can 22 ACE-FEDERAL REPORTERS, INC.
M347 3700 Nationwide Co.erage 800 336 6646
79
~
only be determined by the Federal Emergency Management Agency, after a process of evaluation and review, including review by 3
the regional assistance committee.
~
4 Q
So, on your evaluation review form concerning 5
EOC Objective 7, does that' mean that you did not check one of 6.
the little boxes under the heading:
Evaluation Scheme?
7 A
No, it doesn't.
8 Q
Which box did you check?
9-A I would have to see my form.to tell you.
10 Q
You don't recall?
A Nope.
yy Q.
All right.
f A
I can hazard a guess, but I don't recall which one I checked.
14 0
Well, if you are able to answer my question, 15 please do so.
16 A
Your question was: -Which one I checked?
And I am 17 just not sure, so I will have to leave it at that.
18 Can I clarify something here?
19 MR. CUMMING:
Certainly.
20 THE WITNESS:
Should I?
21 MS. LETSCHE:
Certainly.
Go right ahead.
O ACE-FEDERAL REPORTERS, INC.
202-347 3700 Nationwide Comase 80NEM46
80 THE WITNESS:
I think you should understand that my attitude -- what my attitude is when I fill out a form.
BY MS. LETSCHE:
(Continuing) 4 Q
Okay.
Why don't you tell me.
5 A
There were boxes, for example, on the next page 6.
which say deficiency, area requiring corrective action.
7 All those have been filled out by me, and there 8
was a problem.with that.
It is not a determination of 9
deficiency, or area requiring corrective action.
That is 10 FEMA's.
It is my conclusion based on limited observations of 11 my end of what went on, and that has to be evaluated in the i.
12 light of other evidence, the observations of other observers, and there is an evaluation process and a review process which 13
=
goes on before and after determination of inadequate or 4
adequate, or deficiency, or area requiring corrective actions made by the Agency.
16 Q
That is right.
Now, let me just be clear.
I 17 appreciate your clarification, now let me make one.
18 All I have been asking you, and all I intend 19 to ask you throughout the remainder of this deposition which 20 is going to continue for a while, as you have already gathered 21 since we are going through all these objectives, is for your r
22 x
?
~'
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.ange 80433MM6 j
4
81 evaluation, not FEMA's.
2 I am asking for yours.
What you observed and 3
your conclusion, as you just defined in the statement you 4
made.
That is all I am asking from you.
And your counsel 5
will I assume instruct you to provide that information based 6-on your factual observations.
7 MR. CUMMING:
Assuming the witness reached 8
conclusions, he can answer the questions.
9 MS. LETSCIIE :
That is right.
With that clari-10 fication, let me re-ask the question.
Do you recall what conclusions you reached concerning EOC Objective 7?
11
['%
TIIE ' WITNESS :
(Pause.)
I think --
MR. CUMMING:
Counsel for FEMA does state that 13 the question leaves open as to whether your question refers 14 to during the exercise, or the witness' present state of 15 his knowledge?
16 MS. LETSCIIE :
I am asking for Mr. Smith's 17 conclusions.
I can't tell you when he arrived at them.
I 18 am requesting his conclusions?
19 TIIE WITNESS:
The witness is aware of that 20 particular problem.
It was my conclusion that there was 21
-- that the omission of that information for both gravel 22 truck and fuel truck impediments were indicative of a Aa-7EDERAL REPORTERS, INC.
202-147 3700 Nationwide Co'.aage 800 336 6646
82 problem with initiation of message forms, and I think that is somewhat different statement than the question you asked 3
me.
4 BY MS. LETSCHE:
(Continuing) 5 o
Okay.
Let's move on to Objective EOC 9.
I 6.
just have a couple of questions about this one, Mr. Smith, 7
A Good.
8 0
Am I correct that in performing your review with respect to this objective, you did not evaluate any 9
rdination between LERO players and Nassau County officials?
10 A
I am not sure, 11 Q
That is fair enough.
12 A
It depends on the meaning of, ' officials,' I 13 guess.
Do you mean county executives?
14 Q
Nassau County.
15 A
At location in the reception center.
Involving 16 the Nassau County Coliseum?
No, I don't think I saw any 17 simulated activity involving Nassau County simulators.
18 Q
Okay.
Would you turn to EOC 11, exercise evaluation 19 critique form on that.
Am I corre ct, Mr. Smith, that in your 20 review of activities related to this objective, that you did nt bserve any actual communications with representatives of 21
~
22
(}
1 ACEUEDERAL REPORTERS, INC.
202-347 3700 Nationwide Co.ange 804336 6M6
83 l
l WALK radio?
A I think that is true.
3 Q
There was something I forgot to ask you about 4
the impediment messages.
Did you observe any communications 5
of -- by the LERO players', with any fire company in connection 6
with their response ",to that fuel truck message?
7 A
I have knowledge of such a communication, but 8
whether it was a direct observation on my part, I don't know.
9 Q
To your knowledge, was the decision to contact 10 the fire company one that was made by LERO or one that was Prompted by information from FEMA concerning that message?
11 A
My recollection at this point in time was that
'~'
the evacuation coordinator knew that there was a leaking fuel 13 truck.
I believe it was his direction for a fire vehicle, or 14 fire truck, should be dispatched to the location.
15 That is my recollection.
16 Q
That was one of the things that didn't get done 17 for a long time afterwards, wasn't it, after he had that 18 meeting?
19 MS. MONAGHAN:
Vague.
I object to the question 20 as vague in terms of what constitutes,
'a long time?' and 21 also as to what the meeting is to which you are referring p
22 LJ Aa-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co.aage 800 33&M46
84 in the question?
THE WITNESS:
I don't remember.
3 BY MS.'LETSCHE:
(Continuing) 4 Q
How about contact with Hess Oil Company?
Did 5
you observe any communications between LERO players and the 6.
Hess Oil Company with respect to that fuel truck impediment?
7 A
I believe I was told by the road logistics 8
coordinator that such a communication had taken place, but 9
I am not going to swear to that.
10 0
And I assume you don't recall when it was that 11 that communication suppcsedly took place, if it did.
O 12
^
we11, it =teht evee ae 1e the exerct e reeort-Q yu a
sene it would probably be 13 in your notes, or your evaluation critique form, right?
A Yes.
Probably.
l 15 Q
Okay.
Let's go to the form about EOC Objective 16 16.
Now, Mr. Smith, am I correct that your observations 17 concerning activities relating to this exercise objective 18 all took place at the EOC?
1' A
Yes.
20 Q
You did not make any observations concerning 21 activities which may or may not have been going on in the water 22 ACE-FEDERAL REPORTERS, INC.
20* 347 3700 Nationwide Cosnage 2 336-6646
9 85 portion of the EPZ, is that right?
A I did not observe any activities which werestaking 3
place in the water portion of the EOC -- EPZ.
4 Q
I notice that. one of the points of review on 5
this exercise critique' form refers to, I will just quote it:
6' consideration of relevant factors such as availability of 7
transportation resources, traffic volume, availability of 8
traffic control personnel.
9 Was that one of the points of review for you?-
10 A
No.
11 0
Well --
h A
Well, wait a minute.
I am going to ask you to 12 read the question back, please.
13 Q
Why don' t I just restate it.
A Maybe you can ask it one point at a time.
15 It would help me.
16 Q
All right.
Did your review include evaluating 17 whether LILCO considered availability of transportation 18 resources?
19 A
Yes.
20 0
And what did you review in making an evaluation 21 on that subject?
22 ACE-FEDERAL REPORTERS, INC.
M 347-3700 Nationwide coa.4 rase 800 336 6666
86 A~
.I observed that early in the exercise that the bus coordinators, the two bus coordinators, -- and this was 3
just after 8:00, I think, -- that the two bus coordinators 4
were calling bus companies to -- well, let me back up on that 5
one..
6~
It may'have been si,mulated bus companies, I don't 7
know.
8 Q
All right.
9 A
I will say they called the bus companies, to 10 determine how many buses would be available in the event --
11 how many buses would be available.
I --
9' I didn't want to interrupt your answer.
I thought 12 you were finished.
If you have more, go ahead.
A I observed people in the -- I observed -- I don'.t 14 i
l remember what time this was -- the evacuation coordinator came 15 around -- this was before -- this was still early in the 16 exercise.
I definitely place this as being prior to -- certainly 1
17 prior to 10:00 Maybe much earlier than that.
18 Let me lay the stage.
There was consideration at 19 one point being given to evacuation of -- yeah, zones A to G, 20 and at that time the manager of local response communicated 21 this to the evacuation coordinator, and the evacuation O
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Co'.asse 800 336 6 46
87 llk coordinatorfhad his staff develop preparatory lists of what particular traffic control points, evacuation routes, and 3
so on would need to be activated.
4 And I observed people involved in the process 5
3-B which looked like they were doing that.
6~
Q In terms of the information shortly after 7
eight o' clock which people were getting from simulated bus 8
companies or bus companies about potential numbers of buses 9
available, did you understand that to be real information about 10 actual availability of buses?
11 A
I d n't remember.
[";
Q Did you review whether LILCO considered traffic 12 volume?
13 A
I think it could be determined by looking in the 14 exercise report.
If athey were simulated bus companies, it 15 would almost certainly say so.
16 Q
Okay.
Did you review whether LILCO considered 17 traffic volume in its response to the exercise scenario?
18 A
There are two answers to that.
The first is that 19 consideration of traffic volumes, I think, is implicit in the 20 plan development that -- I guess that is something I have no 21 right to say.
I did not observe anybody talking about actual
(^)
22
+:
ACE-3EDERAL REPORTERS, INC.
2 347 3700 Nationwide Courage 80 4 336 6646
88 l
number of cars that would be going down different routes.
2 Q
Ilow about LILCO's consideration of the availability 3
of traffic control personnel?
Is that something that you would 4
review?
5 A
Not explicitly.
6~
Q Am I correct, Mr. S.mith, that you did not review any activities by the U. S. Coast Guard during the exercise?
O A
I was at the LERO EOC.
There was nobody there 9
from the Coast Guard that I saw.
10 Q
Now, did you --
11 A
Now, I will volunteer some information.. I did bserve, and I think this was by conversation, that special 12 facilities evacuation coordinator -- I think I have the right person identified -- he has a communication set on his desk.
15 No, I am wrong.
The communications set.with the 16 Coas t Guard, I believe, is on the evacuation coordinator's 17 desk.
And he did contact -- and my recollection was this was an actual contact with the Coast Guard -- requested a l
19 verification of that notification.
20 lie then left the special facilities evacuation 21 coordinator to take the verification call.
The special 22 D
ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Cr. erase 800 3366666
89 2
fa ilities evacuation coordinator's desk is immediately adjacent to that of the evacuation coordinator.
And I think I checked back later and probably checked in the log, although I am not certain, that that communication had been verified.
5 Q
Did you review coordination with reception 6.
congregate care centers?
7 A
No, I didn't.
8 Q
Do you know who did?
9 A
No.
10 0
Let's go to EOC Objective 17, which has to do 11 with the ability to deal with-impediments to evacuation, such h
12 as inclimate weather or traffic obstructions.
13 Am I correct, Mr. Smith, that the only impediments 14 to which the LERO players were expected to respond during the l
exercise were the two free-play messages involving gravel truck l
and fuel truck?
16 A
They are the only two in which I had any knowledge.
17 Q
Did you review LILCO's ability to issue an EBS 18 message, if appropriate, concerning impediments to evacuation?
19 A
I observed LERO personnel from -- I am not sure 0
about public information section discussing message content 21 related to the rerouting of traffic, and I am not sure which 22 ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Cmersee 800 3364M6
90 impediment -- that was my total contact with the preparation of EBS messages.
3 Q
Now, I take ~it that, given that total contact, 4
that you didn't make any determination or evaluation as to 5
whether such an EBS message was issued in a timely fashion?
6.
A You are correct.
7 Q
Did you review LILCO's ability to determine and 8
implement an appropriate rerouting of traffic?
9 A
would you repeat the question, please?
10 Q
Yes.
I am referring to one of the points of 11 review on the exercise critique form for EOC 17.
I am asking O
12 tr voe revie ea tco eettier to aeter 1ee -- tee breek it down.
To determine an appropriate rerouting of traffic?
13 A
I observed activities relating to that point of review, 15 0
What activities was it that you observed?
16 A
(Pause.)
It will take me a while to read through 17 this.
I don't remember the personnel who were involved in the 18 precise discussion, but the evacuation coordinator and some 19 other people, LERO personnel, got out the -- I believe this 20 is the time which they physically took one 'of the evacuation 21 route map and some other map and laid them side-by-side across 22 ACE-FEDERAL REPORTERS, INC.
202 347 3700 Nationwide Cm4 rage 800 33M46
91 w
some desks, and there was a discussion which ensued regarding 2
-- a d I am t even sure 'at this point which of the impediments 3
it was -- or maybe both~of them.
There was discussion about
-- well, I am just not certain.
5 But there was discussion as to what actions to 6.
be taken, and where traffic could be diverted around the 7
impediment, and how that traffic would then later be -- I 8
think they discussed it to the point of trying to get the 9
traffic back out the right route.
10 0
Okay.
I take it you did not observe any 11 implementation of rerouting the traffic?
O 12
^
r eh.4nk twee weu1d be enir esserved1e in the 13 field.
0 What was your conclusion concerning EOC 14 Objective 17, based on your observations?
A I believe that I gave them -- it was my opinion at the time that the performance was both deficient and 17 subject to corrective action.
18 0
I forgot to ask you.what your conclusion was 19 with respect to 167 20 A
I believe that my conclusion is the same as in 21 the report, on page 34, for this objective.
16 was met.
22 ACE-FEDERAL REPORTERS, INC.
2 347 3700 Nationwide Cm erage 2 336 446
92
~ ~
But I don't have my form in front of me.
Q Right.
I take it, Mr. Smith, that in your 3
review of EOC Objective 16, which is the ~ ability to manage 4
an orderly evacuation of all or part of the ten mile EPZ, you did not review evacuation activities related to the 6
mobility impaired, -is that right?
7 A
I am not sure.
8 Q
You don't recall?
I am just not sure at this point in time whether 9
A home bound includes mobility-impaired.
10 O
Okay.
Does that mean that you did review --
rN A
I oclieve I put on the record the fact that I
(
12 did observe the home coordinator calling home-bound 13
' individuals, or simulated home-bound individuals.
14 Q
Other than the observation of the phone calls, 15 which you already did state for the record, you didn't observe 16 any other evacuation-related activities with respect to the 17 home-bound, did you?
18 A
I can't recall any at this point in time.
19 Q
Let's move to Objective EOC 19, 20 MR. PIRFO:
It's now after five, and having 21 gone for some time, not withstanding it has not been since 22 r
i t
ACE-3EDERAL REPORTERS, INC.
202 347 3700 Nationwide Courage M3m
a 93 just two o' clock for the rest of us, Mr. Cumming, the reporter, and Ms. Monaghan, we have been sitting here since nine this 3
morning -- are we off the record --
4 (Off the record discussion ensues.)
5 BY MS, LETSCHE:
(Continuing) 6.
O Mr. Smith, let me direct your attention to the page of Smith Exhibit No. 1, relating to EOC Objective 19.
Is 8
this an objective which you reviewed?
9 A
Yes.
10 0
And in connection with your review, did you 11 evaluate any provisions by LILCO to control water traffic?
r~'s A
No.
12 Q
How about air traffic?
3
=
THE WITNESS:
I believe there is a knock at the 14 door.
15 MR. CUMMING:
It is probably my interruption.
16 MR. PIRFO:
Let's go off the record for a minute.
17 (Off the record.)
18 BY MS. LETSCHE:
(Continuing)
I 19 O
I think the question was, did you review any 20 provisions to control air traffic?
21 A
I have no knowledge of any air traffic control
,q 22 ms ACE-FEDERAL REPORTERS, INC.
E-347 3700 Nationwide Co.erage 800 336-6646
94 actions on the part of LERO during the exercise.
Q Okay.
Now, what -- strike that.
What did you 3
review in evaluating LILCO's performance with respect to 4
Objective EOC 19?
5 A
I reviewed -- what I saw, near the end of the 6'
exercise, simulated police assistance, County police 7
assistance was made available, and the evacuation coordinator 8
was working on a number of simulated County police that would 9
be needed, and my recollection is that that is about the time 10 the exercise terminated.
11 I was also -- I also knew that there were several alls d.uring the day, and I don't remember who made~them to 12 determine whether simulated County police assistance would be made available.
I don't remember the times of those 14 calls.
15 I think that is all I have that is relevant.
16 Q
So, am I correct then that you did not observe 17 any activities by LILCO employees, LERO personnel, to control 18 access to evacuated areas?
19 A
I think that is true, yes.
To the best of my 20 belief at this time, that is correct.
21 I would like to make a clarification on that.
22 ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Ce.ange 800 336 6646
95 llk Q
Well, I am trying to sort of move forward.
Maybe your counsel can ask you a clarifying question on redirect, 3
and you can get it in that way.
4 MS. MONAGHAN:
Ms. Letsche, I think we ought 5
to let the witness clarify anything that is not clear.
6' THE WITNESS:
I would like to qualify my answer.
7 I really would.
I am not certain at this point in time as 8
to the total function of traffic control points.
9 I am not sure whether those on the periphery 10 of the EPZ are also suppose to function as access control points, so I would have to make that caveat because I did, 11
-( )
in fact, observe people determining which traffic control points needed to be activated.
Q And I take it that was in --
A That was EOC 19.
15 Q
EOC 19, okay.
Let's move to EOC 20.
Now, I 16 notice that the -- we have already discussed this, haven't 17 we?
18 I notice in the FEMA Report it is noted that 19 activities related to this objective could not be observed 20 at the EOC.
21 I take it that was your input that resulted in
()
CE-FEDERAL REPORTERS, INC.
l N2-347-3M Nationwide Co.aage 800-336-6646 l
96 that statement?
A Are you referring to the statement --
3 Q
Page 38, of the FEMA Report.
4 A
Fourth paragraph?
5 Q
Yes.
6~
A Yes, I think -- I.believe that coincides, or 7
is consistent, with the statement on my completed evaluation 8
form.
9 Q
We have talked about early dismissal of schools, 10 and we have talked about evacuation of schools.
I take it that you, Mr. Smith, did not evaluate LILCO's ability to 11 implement a sheltering recommendation for school children, t ' ')
'm_
12 is that right?
13 A
I have no knowledge of such a recommendation.
14 Q
Did you do any evaluation with respect to the 15 Shoreham - Wading River School District activities during the 16 exercise?
17 A
No, I didn't.
18 Q
Cid you do any evaluating of LILCO's response 19 to a free-play message regarding the Ridge Elementary School?
20 MS. MONAGHAN:
Just as a point of clarification, 21 that would be LERO's response, I think.
TN 22 THE WITNESS:
No.
(
)
ACE-FEDERAL REPORTERS, INC.
E-347-3700 Nationwide Co. : rage 800 336 4646
97 BY MS. LETSCHE:
(Continuing)
Q Let's go to Field No.
1.
Did you actually evaulate this objective?
4 A
No.
5 Q
Do you know why there is an evaluation critique 6.
form with your name on it for this objective?
7 A
I believe I do.
Q What is it?
9 A
I believe that somebody at the EOC was supposed 10 to take -- keep exposure records on field workers, 11 Q
You mean a LERO person at the EOC?
(a) 12 A
- Yes, 0
But you didn't review any such exposure records?
13 A
No.
O Do you know if any other evaluator did review 15 the Field Objective No. l?
16 A
At the EOC?
17 Q
Yes.
18 A
I don't know.
I can try to refresh my memory I
19 from the report.
20 Q
No, that is all right.
Mr. Smith, I would like 21 you to look at Smith Exhibit No. 2, and that is the free-play 22 7 w)
,tj l
l ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Coverage 800 336-6646
98
~~
message collection.
Now on the first form, which is about the 3
fuel tank truck message, I notice 'under Item No. 2, there 4
are four times listed.
5 A
Yes.
6 Q
That is your handwriting, right?
7 A
I believe so.
8 Q
And what do those times represent, to the best 9
of your recollection?
If you don't recall, it is perfectly 10 all right.
A I am trying to recall, okay?
77 0
I know.
)
12 A
I realize that it is okay.. I believe the first 13 one was when the evacuation route coordinator either began 14 transcription or received the injection of the message, and 15 the others, I am just not certain enough to hazard a guess, 16 Q
Okay.
Now, is the communications evaluator, 17 this Item No. 3, would that have been filled in by Mr.
18' Baldwin?
19 A
Let's back up just a minute, in the sense that 20 I don't know whether Mr. Baldwin filled it in or not.
That 21 particular notation, even though it has his name attached to it, 22 o,.
ACE-FEDERAL REPORTERS, INC.
M-347-3700 Nationwide Co.: rage 800 336 6686
99 g~~
was filled in by me. simply as an indication, and probably than I was done with it, although it does have his name and his 3
function as an evaluator, I will say incorrectly, I filled 4
in that blank.
5 Q
When you say filled in the blank, you mean this 6.
12:28 time?
7 A
I think it is 12:23, and I believe that would 8
be mine.
9 Q
Did you also put comments next to Numbers 2 and 3 10 on this form, to the best of your recollection?
g I probably put some comments under No. 2, so that A
/N
)
12 I would _later know what the time stood for, but I am not certain, since they have been redacted.
13 Q
Right.
Did forms such as these
- were forms such 14 as these among the ones you gave to Mr. Cumming today; filled 15 out forms?
16 A
Yes.
17 Q
Would you turn please to the next free-play 18 message in Smith Exhibit No. 2, which has to do with the 19 loaded gravel truck.
Did you fill in any blanks on this 20 form, to the best of your recollection?
21 A
Yes.
22
^u l
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwice Cowage 800-336-6646
100 i
~~
Q Can you tell me what you filled in that you recall?
3 A
I probably filled in 2 and 3.
4 Q
Sitting here'today, do you recall what you filled 5
in there?
6 A
You mean specific numbers?
Well, I signed in 7
the appropriate and the inappropriate space, under evaluator 8
sign-off, and I put some times down.
Whether there was 9
additional notations, I don't remember.
10 Q
would you turn to the fifth page of Smith Exhibit No. 2, which is the first of several messages relating to the g
~
Marketing Evaluations, Inc., report that the three sirens have failed.
13 I believe this is one of the one's you said you 14 recognized the handwriting on, is that right?
15 A
Oh, I had the wrong page.
It is Page 5, I think.
16 Q
It is five by my count.
17 A
Well, I was on page six.
Yes, I believe the 18 writing under No. 2, on page five, is mine.
19 Q
Does this -- does it look to you like the hand-20 written note under the signature block-says:
Requests i
l 21 verify dispatch and completion of route?
O ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co..nge 30 4 336-6646
101 A
Yes.
O What does that mean?
3 A
It means that when the 'special facilities 4
evacuation coordinator, and I think I have the person right, 5
made the calls to the staging areas to convey the information 6-that the sirens had failed, that he requested that the call 7
be verified, and that the completion of route alerting be 8
verified back to him.
9 Qq I see.
And did that happen?
10 A
I don'.t remember.
Q What is the significance of the times that are 11
'- i written over there?
(,-
12 A
Without my notes, I don't remember.
MS. MONAGHAN:
Let me just lodge an objection 14 to this line of questioning on route -alerting.
It is not 15 relevant to any of the issues in litigation.
16 j
BY MS. LETSCHE:
(Continuing) 17 Q
Mr. Smith, do you recall any of the comments 18 that you may have written on this form concerning Item No. 2?
19 A
To the best of my knowledge and belief, each of 20 these times was associated with a specific -- or a sub-set of 21 three of these times was associated with either the time which 22
\\_J ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co'.aage 800-336-6646
102 he began the communication to a specific staging area, or the time at which that communication was completed.
3 Q
And this is focusing on what the special facilities 4
evacuation coordinator did at the EOC?
5 A
Yes.
6.
Q You weren't in communication yourself with any 7
of the field evaluators who were watching the other end of 8
this communication, is that right?
A We are only talking about route alerting?
9 Q
Yes, these communications.
A That is true, 11 (m
Q Let's move on to the next page.
This is another d
12 siren activation page.
It has up at the top right hand 13
' corner:
Port Jeff Staging Area -- Field, something.
14 Do you recognize the handwriting on this form?
15 A
No.
16 Q
Okay.
Let's go to the next one.
This is another 17 Marketing Evaluations, Inc.
It only has one time, 8:34 18 listed next to Item 2.
Do you recognize that handwriting?
19 A
No.
20 Q
Do you recognize any of the writing on this page as yours?
21
^
22 ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co'.erage 800-336-6646
103
~jg[~~~~
Q Okay.
How about the next one?
A No.
Now we are at the last page?
3 O
At the last page, which is send an ambulance 4
to Our Lady of Perpetual Help Convent.
And I think you 5
said before that you had' not filled this out, is that right?
6-A I don't think so.
7 Q
And you didn't evaluate any of this activity 8
-- ambulance activity during the exercise?
9 A
No.
10 0
Mr. Smith, af ter the exercise, did you prepare any summaries of your observations or conclusions?
f^
A Yes.
(,)
12 Q
And what did you do with those summaries?
13 A
I believe I turned them over to my team leader?
14 Q
That would be Mr. Connolly?
15 A
fes.
16 Q
When did you do that?
17 A
No later than the time specified for that activity 18 in the itinerary.
19 Q
Did you turn over any other documents to Mr.
20 Connolly after the exercise?
21 A
I don't believe I did.
,c 22
\\ >x ACE-FEDERAL REPORTERS, INC.
E347 3700 Nationwide Co. cage M 33 N
104 Q
All right.
A Let me ask a clarifying question.
Do you mean i
3 did I turn them over into his possession, or did I turn them 4
over for his review?
5 0
Well, did you turn over any for him to review?
6.
Did you give him any to review?
7 A
Yeah, I think I turned over to him my critique 8
forms, although I am not certain of that.
9 Q
All right.
Anything else that you might have given him for review?
10 A
I don't think so, 11 r,
Q Did'you eventually give him the critique forms?
(j 12 A
To the best of my recollection they were not given 13 Into his personal custody.
14 Q
Who were they given to?
Into anyone's personal 15 cus tody?
16 A
Yeah, I kept them.
And then they were turned 17 over to, I believe, Tom Baldwin, before the conclusion of 18 the exercise week.
19 I believe I turned them over to Tom Baldwin.
It 20 is possible that I kept them in my own possession.
Q Is it your understanding that the exercise 21
(~w, 22 o
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.,: rage 800 336- % 4
105 of critique forms, or the comments in those critique forms, would be used in the' post exercise ' assessment report?
3 A
It was my understanding during the period of the 4
exercise'that the comments in the critique forms would be 5
one of the basis upon which the post exercise evaluation 6.
process was based.
7 Q
Now, Mr. Smith, am I correct that you have not 8
reviewed the summary that you prepared and turned over to 9
Mr. Connolly since the time you gave it to him?
A Yes.
10 Q
You didn't make any copies for yourself?
p A
No, I am pretty sure I didn't.
Q 12 MS. LETSCHE:
Mr. Cumming, along with the 13
' documents I w'buld like to request is the summary prepared by 14 Mr. Smith, of his observations and conclusions during the 15 exercise.
16 MR. CUMMING:
It is objected to as far as the 17 deliberative process, but if we find the document we will 18 consider re-reviewing it.
19 THE WITNESS:
I would like to make a statement.
20 MS LETSCHE:
Well, this is not the time for you 21 to make a statement, Mr. Smith.
If you wish to do that, O
ACE-FEDERAL REPORTERS, INC.
- E!.347 3700 NationwideCo case M33(H686
106
~~
perhaps your counsel can ask you on redirect.
We will continus with the questioning.
3 BY MS. LETSCHE:
(Continuing) 4 Q
Did you attend exit meetings, or any exit meeting 5
l held after the Shoreham exercise?
6.
A If it was required of me on the itinerary, I 7
was there.
8 Q
Do you recall attending any?
9 A
No.
10 Q
Did you attend any LILCO briefing following the-exercise?
A I ' don't remember.
12 O
Did you attend any press conferences after 13 the exercise?
14 A
(Pause)
I am not sure.
15 Q
Did you attend any exercise critiques by FEMA 16 or the NRC?
17 A
Oh, I thought that is what you meant by the 18 press briefing.
The answer to both of those questions is I 19 don't remember.
20 0
Let me direct your attention to the itinerary, 21 which is Lane Exhibit No.
2.
On page 6 of that itinerary --
22 go back to page 5, and start there.
ACE-FEDERAL REPORTERS, INC.
3 2-347-3700 Nationwide Co..nge 800 336-6646
107 4-A Q
There is an indication there that there was
-~
2 a meeting of evaluators with the RAC Chairman and the lead 3
controller.
Did you attend such a meet'ing?
4 A
Yes.
5 0
And do you recall what happened during that 6.
meeting?
7 MR. CUMMING:
Object to this line of questioning.
8 It is part of the deliberative process, and I instruct the witness not to answer.
g BY M. LETSCHE:
(Continuing) 10
~
Q Mr. Smith, did you participate in the development of an energency ' classification and event time line?
A I attended th'e meeting.
13 Q
Do you recall --
14 A
I believe I had some contributions to make.
15 Q
Do you recall what they were?
16 A
No.
17 Q
Did you -- were any of the major exercise events 18 that were discussed during that meeting events that you had 19 observed during the exercise?
20 MS. MONAGHAN:
I am going to object to the question on the grounds of relevance.
21 O
ACE-FEDERAL REPORTERS, INC.
E-347 3700 NaticnwideCo, rage 800-336-6 666
108
~)lh THE WITNESS:
What do you consider a major exercise event?
3 MS. LETCCHE:
I am just referring to what 4
was apparently discussed at that meeting.
It says discussion 5
of major exercise' events.
6.
Were any of the exercise events that were 7
discussed there ones that you had observed?
O THE WITNESS:
(Pause.)
There are some of 9
which I have knowledge.
At this point in time, I can't 10 say whether I would classify them as observation or not.
11 BY MS. LETSCHE:
(Continuing)
(;
12 Q
What were the events that were discussed?
v A
The ones that I can recall are time that the various stages of the exercise were declared by the utility.
Times at which that information was transmitted to -- or 15 l
received at the EOC, and the time which the various LERO 16 locations received communications to the declaration of 17 those emergency states.
18 I believe we also at that meeting talked about 19 the content and timing of -- well, I am not sure it was at 20 this meeting or a later one.
21 but my recollection is that that meeting also 22
(
ACE-FEDERAL REPORTERS, INC.
E 347 3700 Nationwide Co'.erage M 33(H5646
109 covered protective action recommendations, EBS message ejection times.
That is my best recollection.
3 Q
Okay.
Was the're 'any discussion at that meeting 4
of the response to the impediment free ~-play messages?
5 A
MS. MONAGHAN:
Object again on the grounds of 6.
relevance.
THE WITNESS:
I don ' t re call any.
8 BY MS. LETSCHE:
(Continuing) 9 Q
Mr. Smith, at any time during the exercise did 10 you place any calls to the LERO Rumor Control phone numbers?
11 A
No, t
.0 The -- would you turn to page 6 of the itinerary 12 for me, please.
There is a reference there to meetings between team leaders and their team members.
Did you participate in such a meeting after the exercise, that you recall?
15 A
Yes, I believe I did.
16 Q
And did you prepare approximately one paragraph, 17 some sort of a summary, to provide to the team leader in 18 connection with this meeting?
19 A
I don ' t really remember having done it.
I think 20 it is a reasonable conclusion that I did.
21 Q
Did you -- do you recall having reviewed any
,e~'s 22 Aa-FEDERAL REPORTERS, INC.
E-347-3700 Nanonwide Co.aage 800-336 6 %
110 kind of highlight summary prepared by Mr. Connolly, the EOC Team Leader?
3 A
I don't recall having reviewed such a document.
4 Q
Do you recall having ever seen' such a document, 5
separate and apart from when you reviewed it on that evening?
6' A
No, I do not recall.
7 0
Other than the meeting --
0 A
It might be that we, as a team, had this meeting 9
at a different time than is stated here.
I just don't 10 remember.
11 Q
Okay.
Other than the meeting earlier in the vening, which was all evaluators, controllers, and 12 simulators with the RAC Chairman and lead controller, 13 did you have any other meeting subsequent to the exercise with the RAC Chairman, Mr. Kowieski?
15 MS. MONAGHAN:
Object on the grounds of 16 relevance.
17 c,
THE WITNESS:
I don't remember.
18 BY MS. LETSCHE:
(Continuing) 19 Q
Did you have any meetings following the exercise 20 with -- at which Mr. Patrone was in attendance?
21 MS. MONAGHAN:
Same objection.
,o 22 O
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nanonvnde Courage M 336-6646
111 THE WITNESS:
My recollection is, no.
BY MS. LETSCHE:
(Continuing) 3 Q
Mr. Smith, you stated back at the very beginning 4
of this deposition, that you were involved in post exercise 5
analysis processes, and in the preparation of draft and 0'
final versions of the Shoreham. Post-Exercise Assessment, and 7
I would like to talk just a little bit about that now.
8 MR. CUMMING:
FEMA counsel objects to.this 9
line of questioning with respect to all its witnesses.
We 10 will review each question, and instruct the witness whether or not to answer.
7~
BY MS. LETSCHE:
(Continuing) 12 Q
Mr. Smith, can you describe.for me what your 13 activities were following the Shoreham exercise, and related 14 to the analysis of those exercise results?
15 MS. MONAGHAN:
Object to the question on the 16 grounds it is vague.
I MR. CUMMING:
The witness is instructed to answer 18 to the extent that he had involvement as to the dates of 19 i nvolvement.
20 THE WITNESS:
Would you repeat the instruction, 21 please?
22 a
ACE-FEDERAL REPORTERS, INC.
m.347 3700 Nationwide Cca.erag:
S @ 33 W
112 g-~
MR. CUMMING:
The witness is instructed to answer to the extent that he remembers the dates of his involvement, 3
post-exercise.
4 THE WITNESS:
I deciline'to answer.
5 MS. LETSCHEi Hold it.
You have just been 6.
instructed to answer.
If the answer is you don't remember, 7
that is fine.
8 THE WITNESS:
Very good.
I stand corrected.
9 I don't remember.
10 BY MS. LETSCHE:
(Continuing)
~
Q Okay.
You don't remember the dates at.which rN you participated in activities related to the Shoreham
~V 12 exercise subsequent to the exercise, is that a correct state-13 ment of your answer?
14 A
Yes.
15 Q
Now, would you -- will you describe -- you 16 stated to me earlier that you were involved in post-exercise 17 analysis procedures.
What was it you were referring to?
18' MR. CUMMING:
The witness is instructed to 19 answer.
20 THE WITNESS:
I was involved in the analysis 21 of the section relating to LERO EOC, I was involved in the p
22 o
ACE-FEDERAL REPORTERS, INC.
E-347-3700 Nationwide Co'.: rage 800 33 & % 86 i
RF 113 drafting of that section.
I was possibly involved in the analysis and drafting of other sections, which I don't recall 3
at this point in time.
4 Q
Now, going back to the' analysis of the section 5
regarding the LERO EOC, w!iat was it that you analyzed as part 6.
of th~at activity?
7 MR. CUMMING:
To the extent witness remembers, O
he is instructed to answer.
9 THE WITNESS:
I analyzed exercise evaluation 10 critique forms which had been, completed by Federal evaluators, I analyzed copies of LERO message forms which had been 11 submitted, and I think that covers it.
()
12 BY MS. LETSCHE:
(Continuing) g Q
And what did you do after you analyzed those materials?
15 A
Well, I would say contemporaneously with the 16 analysis is involved the writing of the first draft of the 17 post-exercise assessment.
18 Q
The EOC portion of that?
19 And what other portions I may have been responsible A
20 for writing, if any.
21 Q
And af ter you wrote the first draft, who did you
(~',
22 send it to, if anybody?
U ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Co.erage 300 3h
114 MS. MONAGHAN:
Object as to the relevance.of this line of questioning.
3 MR. CUMMING:
I have~no objection to your 4
answering, if he in fact sent it to someone.
5 THE. WITNESS:' I am not sure that I did.
6.
BY MS.~LETSCHE:
(Continuing)
~
7 Q
What happened to that first draft after you 8
wrote it?
9 A
I don't remember.
My recollection is -- let's 10 see if L can remember.
I am just not certain, so I am going to say I don't remember.
11 Q
Did you review any drafts other than that first draft that you prepared?
13 MR. CUMMING:
The witness can answer the 14 question.
15 THE WITNESS:
I didn't review any drafts.
16 BY MS. LETSCHE:
(Continuing) 17 0
Did you -- strike that.
I believe you said 18 earlier that you were involved in -- no, strike that.
Did 19 you do any other analysis or drafting related to the post-20 exercise assessment for the Shoreham exercise, other than 21 the preparation of the first draft that you just described?
p, 22 V
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Cobrage 800 336-6686
115 MR. PIRFO:
Objection.
The question is repetitive.
Asked and answered.
3 MR. CUMMING:
You may answer as you answered 4
previously.
5 THE WITNESS:
I assisted in the preparation of 6
the first draft, an'd putting together the final report.
7 BY MS. LETSCHE:
(Continuing) 8 Q
What did you do in putting together the final 9
report?
10 MR.
PIRFO:
Objection.
That has been asked 11 and answered.
I think it is highly repetitive.
MR. CUMMING:
If the witness think s he can add 12 to his previous comments, he is instructed to answer.
MS. LETSCHE:
None of the other questions have been with regard to the final report document.
15 THE WITNESS:
Well, that is distinct in my mind.
16 I am not certain how many drafts there were.
I just don't 17 remembe r.
Whether there was the initial, and then directly 18 to this April 17th document, or whether there was another, 19 but I was involved as an author at each stage, to the best 20 of my recollection.
21 BY MS. LETSCHE:
(Continuing) f7 22 L._,)
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.erage 800 33(H%s6
1 116 Q
You said before that you assisted in the preparation of the first draft.
Who was it that you were 3
assisting?
Who else~was involved in that?
4 A
I have --
5 MS. MONAGHAN:
I object.
6.
MR. CUMMING:
Witness may answer.
7 THE WITNESS:
I have not prepared on my exact 8
activities post-exercise.
I just don' t remember.
9 BY MS. LETSCHE:
(Continuing) 10 0
Mr. Smith, to the best of your recollection, were there comments or revisions made to, at least the first g
draf t that you prepared that you know existed, by persons other than yourself?
13 A
I believe there were.
14 0
Were any of those comments or revisions made 15 by -- let me rephrase that.
Do you know who made such 16 comments or revisions?
17 A
You mean specific individuals?
18' Q
Yes.
l 19 A
Not at this point in time I don't recall.
20 0
Can you describe generally who they were, or 21 where they were from?
l lO ACE-FEDERAL REPORTERS, INC.
E347-3700 Nationwide Conrage 80 4 336- % 46 L
~
117 2
I believe~we got some comments -- my recollection A
is that we'got commen'ts back from FEMA; we got comments back from some'of the RAC members.
4 Q
Were there any comments from LILCO?
5 A
I don't remember.
6.
Q Were there'any comments from FEMA Headquarters in 7
8 A
I don ' t remember.
9 0
Were there any comments from any other evaluators 10 during the exercise?
11 A
I don' t think the report was reviewed by
~O 12 eve 1ueter
- raet 1 r de e x o 1ea e e=a de11er o enee -
e 13 O
S A
I will clarify that, because some of the evaluators 14 were writers.
O Who were they?
16 A
I don't remember.
I already said that I don't 17
- remember, 18
.Q But you were one of those?
19 A
Yes, I was in that category.
20 0
Right.
Mr. Smith, were you -- did you participate 21 at all in any conversations or discussions concerning the 22
~
ACE-FEDERAL REPORTERS, INC.
E.347-3700 Nationwide Co.4 rage 2 336 4646
118 resignation of Mr. Patrone?
MS. MONAGHAN:
Object to the question.
It 3
is irrelevant.
4 MR. CUMMING:
I object to relevancy, but 5
witness may answer the' question.
THE WITNESS:
Yeah, it was a hot topic of 7
discussion.
8 BY MS. LETSCHE:
(Continuing) 9 Q
Who did you have those discussions with?
10 MS. MONAGHAN:
I note a continuing objection t
this line of questioning on the basis of relevancy.
11 MR. PIRFO:
As does the NRC Staff.
C]
12 THE WITNESS:
What is your instruction?
MR. CUMMIN 8:
To the extent that you have 14 personal knowledge, you may so state.
15 THE WITNESS:
I talked about it with Tom Baldwin.
16 That is the only one I can be certain of at this point in time.
18 BY MS, LETSCHE:
(Continuing) 19 Q
And what was-the discussion with Mr. Baldwin?
20 A
I don't recall.
21 Q
Was there any discussion about the reason that 22 e
ACE-FEDERAL REPORTERS, INC.
E347-3700 Nationwide Cohme 800 3 % 4646
119 Mr. Patrone resigned?
A My recollection is that there was some speculation 3
about a number of reasons.
They seemed to vary over time.
4 Q
Mr. Smith, since the exercise, have you reviewed 5
any proposed corrections or plan revisions by LILCO?
6' A
I don't believe I have been involved in any 7
revisions of the plans.
Again, I don't believe.
I am not 8
absolutely certain, but I don't think I have.
9 Q
Have you participated in any of the reviews of the 10 LILCO Plan that took place prior to the Shoreham exercise?
11 MS. MONAGHAN:
Object.
It is not relevant.
Reviews.of the Shoreham Plan that took place prior to the 12 exercise were litigated fully during the exercise plan hearings.
MR. PIRFO:
NRC Staff has the same objections.
It is not relevant, nor do we believe it is calculated to 15 lead to admissible evidence.
16 MR. CUMMING:
Witness may answer the question.
17 THE WITNESS:
To the best of my knowledge and 18 belief at this time, no.
19 MS. LETSCHE:
Thank you.
That is all I have 20 at this point.
Let me just restate for the record that I 21 want to reiterate my request for the documents that Mr. Smith
(~3 22 V
ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co.nage 800 336-6 4 6
120 has identified as having been turned over to you, Mr. Cumming, and -- as well as documents which have not been identified 3
as having been turned over to you, but which exist, such as 4
the summary which he' prep ~ared of his observations and 5
conclusions during the accident -- during the exercise.
6 This'was apparently turned over.to Mr. Connolly.
7 Let me also state for the record that upon 8
production of those documents, we might very well need to bring 9
Mr. Smith back to continue this deposition in light of his 10 inability to recall any of the items noted on this document.
M. CUMNG:
Counsel for FEMA recognizes the 11
('
various_ requests of Interveners.
MS. LETSCHE:
Does anyone else --
13 MR. CUMMING:
I have no questions.
Does anyone 14 else have questions?
15 MS. MONAGHAN:
I have one question, Mr. Smith.
16 XX INDEX EXAMINATION 17 BY MS. MONAGHAN:
18 Q
Is your recollection of what occurred on the 19 day of the exercise clear in your mind?
20 MS. LETSCHE:
Is his recollection clear?
21 BY MS. MONAGHAN:
(Continuing) 22 O
ACE-FEDERAL REPORTERS, INC.
202 347-3700 Nationwide Cowage M336-6686
121 Q
Is your recollection of the events which occurred
~-
on the day of the exercise a clear recollection?
3 A
Partially.
4 MS. MONAGHAN:
I have'no further questions.
MR. PIRFO:
The NRC Staff has no questions.
5 6.
MS. LETSCHE:
Let me just make one other 7
statement for the record.
Mr. Cumming, we are scheduled to 8
depose Mr. Tanzman beginning at ten o' clock tomorrow morning.
Since this has now happened in a couple of depositions in a 9
row where witnesses have indicated that they have given you
- 10 documents prior to the deposition, but which you nonetheless have not been in a cosition to determine whether or not you
(
(./
12 are going to turn them over, I would like to request that' 13 you make that determination with respect to any documents
~
14 Mr. Tanzman has already given you, or any that he' may be 15 planning to give you this evening or tomorrow morning, prior 16 to the beginning of his deposition tomorrow, so that we can 17 conduct the deposition in an efficient. manner.
18 We are not starting until ten o' clock in the 19 mo rning.
MR. CUMMING:
To the extent that counsel is 20 Mr. Tanzman able, we will try and accede to your request.
21 n
22 L)
ACE-FEDERAL REPORTERS, INC.
I 202-347 3700 Nationwide Co.ange 800 336-St6
122 has not given me any documents at this point.
Whether he has documents with him, I don't 3
know of their volume, or wha ~tever.
4 MS. LETSCHE:
Let me just remind you of 5
something, which I presume you already know, which is the 6~
outstanding document request.
For Mr. Tanzman's documents, 7
as well as for those other witnesses we have already deposed, 8
includes his filled out exercise critique forms, summaries 9
that he may have prepared, filled out forms concerning free-i 10 play messages, documents that he may have received during 11 training sessions, such as those mentioned by Mr. Smith.
MR. CUMMING:
Counsel for FEMA --
are you done?
(
)
12 MS. LETSCHE:
No.
As well as any other personal notes or other documents relating to the exercise involvement.
14 Whether you already have them, or are given them, 15 I request you make a determination before we begin the 16 deposition.
17 MR. CUMMING:
Well, counsel for FEMA will state 18 that all documents prior to the exercise have been objected 19 to as irrelevant, and not material to the contentions as 20 currently admitted under the October 3rd Order, regardless of 21 whether the Board reviews or modifies such order.
Events during o.
22 ACE-FEDERAL REPORTERS, INC.
3)2-347-3700 Nationwide Co'.erage 800-336-6616
123 the exercise, we are conducting good-faith review to determine 2
which documents can, in f act, be ' turned over, and do not 3
compromise what we believe is deliberative privilege process, 4
and with respect to post-exercise, we believe 'they all clearly 5
fall within the deliberative ' privilege 'and; therefore, covered 6.
by ALAB 773 and its logical extension to this exercise proceeding.
7 So, given that, I think you are well aware of our claims. You have a Motion to Compel pending.
We will 9
respond to that Motion to Compel by Wednesday.
So, that 10 is where we stand at this point, 11 MS.,LETSCHE:
I just want the record to be clear that we object to this piecemeal decision to review documents, 13
.and to make those-decisions as to.whether or not you are 14 going to produce them after we have gone through the exercise 15 of deposihg your witnesses, and inconveniencing all counsel 16 to this proceeding, as well as the FEMA witnesses.
)
Thank you very much, Mr. Smith.
/
17 g -
(Whereupon, the taking o e de ositi$n concluded at 6:00 p.m.)
- fj 19 y
vvw 20 cnted and San t0 W " wy, 21 guy,f::; G1h z.g~ppqdr O
m" W
,, c,. w ACE-FEDERAL REPORTERS, INC.
202-347-3700 Nationwide Co'.erage 800-3 5646 9
124
.y _ _
2 CERTIFICATE OF NOTARY PUBLIC 3
I, Garrett J. Walsh, Jr., the officer before whom 4
the foregoing deposition was taken, pages 1 through 123, do hereby certify that the witness whose testimony appears in the foregoing deposition duly personally affirmed; that 7
the testimony of said witness was taken by me and thereafter 8
reduced to typewriting by me or under my direction; that 9
said deposition is a true record of the testimony given by 10 the witness; that I am neither counsel for, related to nor 11 employed by any of the parties to the action in which this
(
12 deposition was taken; and further, that I am not a relative 13 or employee of any. attorney or counsel employed by the 14 parties hereto, nor financially or otherwise interested in the outcome of the action.
15 16 17 gg
, t V
JR. /
18 GARRETT J.
- WALSH, i
Notary Public in and for the 19 Commonwealth of Virginia at Large 20 -
My Commission expires:
January 9, 1989 21 t
22 U'
ACE-FEDERAL REPORTERS, INC.
N2-347-3700 Nationwide Co'.erage 800 336-6646
EXERCISE EVALUATION CRITIQUE FORM Team: Incal Fmergency Operations Center Evatustor's Names
._A. Smith EXERCISE 08JECTIVE AND POIIIT5'0F EEVIEW IDCATIOll/
EVALUATOR (3)
ASSIClelENT C0pelENTS 'AND REcoleEleATIOlis OBJECTIVE:
ECO 2 Demons tra te the ability to ebillae statt and activate m Local (Cood Performance or Deficiency --
000elGITS Emergency Response Orgentiation ILER03 EOC le e timely meaner XX LERO EOC EA seINTs Or azVIm:
XX XX Activation of Pegers lusing Group Tone system) by Supervisin XX e
Operator la Hlchsville.
g Shlst Nottfleetion of personnel e
via swclel telephone IF NOTlFICAil0N or l@lvlDUAllS3 85 NOT VERIFIED WliHIN TlHE FRAE PRESCRIBED
~
THI PLAN.
IN Group Tone Minutes s
I IS 2
30 3
30 4
nae Orcup Tone 4 personnel do not verity notIfIcetIon.
EVALUATIOlt SCIIDGE
,,,,,,, 3 j** """
verification of peger mottlication Isoe CPIP 3.3.5).
e ae
- ~
o Activation of Local ECC lsee sectica 3.3, (PIP 3.3.3 and CPIP e
....... ::'."*;'r 4.9.9).
m e= =* * -
etsbilization of response personnel Isee OPlP 3.3.$3 e
e es.ce.e.me ae
{
' 7,,.",77,' * ~
e.o.gmemuevee e
Ivuuaraa.csr soc =nev OEriciEucyleES Ca coantenvf
'acn0nis, situ Rccascoar.0=ls, On ratoninc Paa <s t Y,..
w
l Ii.,
1
~w z
=,
e r
2 Er?
c
.f 4
e
^
ll O
a f
f.i e!
E e e
c SE a
~c
~
1 Er i
9 8
e sg 2
N n
- E a
e u:E si
~
l g.
e=
e vs y!
U r
ke a
n
=
g
~
2 Et
~
y w
2 t'
,I j
j
~
gc a
e n
8 I
I r
?r
!d
~
l l
l 2-5 jj l l,i!. l! '11 11
-~
~
5n a
g s
Eg
~ u!l!
1 c
s !!
l n
1 E
$ ~~n,<
~~
n i :
i I
fln
~~n r
e i
u j
I a I az a
~ ---
~~~
c!
.a 4 2 :.
~2 Jg;g O
2 P
y~
f i 23:1 E~t B
a
-l
,,)
~
t y
1 g f~I 2
)
i 8
5<52 C
% Pf m
(
M y'
g 2
45*
y 4 :" 2
~
S 3
.'.e %
3 5
b.
e s;!
l 5
.f **
u l a! ! =r' S i
,?
~
2 1 ",i~$
E ll c
t a
i $ 8" i8 i
y to b %
E N' i j*!'1 1
~
l
?
~8$
O 2
t E,
n
~
a I
3-2
?
s m
9 1
2 ea S
E $p T
l I
l E
A t C C A E P 1
i h
f C 5
s t
oel a
i C
P m
S
)
u R o S
N n
0 l O
io L
3 O
A.
I 5
T t
E F
A ya i O D
cv l
N T
N nr C
s E
ee N $$
e 1
l s E
(
0 m
eb I
N 3
C N
C f
I 0
t J o t
a F t E
er E A s
R Du D )d o
Y p
'r D
ry Fl (
o N
o e
i t
A e
N D a
eb C
E u
5 cJ O S
.T nr S
E l
8 a
ac f N v
D ms 5 t J
E 1
re 8
W 0
4 i 0
od 0
f R
)
C ry TO $I el A N Pl U 0 a
L 4
d u A T V C ot E A oc Ca
( (
6 57 8
8 9
D 1
10 0
3 00 1
M y R r O g
- ' e F
s a
/f r
t E
N U t OD I
Tl E,
E s *==
- w
- e Q
I I C
' w e
F e
O s..
', o..
.c T
AC o
D G
- e.
.e I
CI n
l I
R E DS E
Q
.*.e.. g* n..
e
.e
.e e
.w C T L S L
N A A
S
' w s
o e
O D N.",w
- o n
c I
O
- =
e e
T
)
m I
e*
e e
M 5
s T
(
e.
es l
s e
l R
X A
O X
p o
V m T
X 8
e e.
X A
e E a A
h U
V s
s E
e e
E e
L S
r A
m IC g VE R
e e*e
,ee S
EX d
L E
n s
C 3E a
k E
n S
u g
I b
a t
C l
n u
R e
e o
E m
r h
X*
ip e
s h
E u
t
)
qe s
e
(
r d
a r
e a
W c
o E
a b
p e.
s I
s V
u t
E e
ll ta R
ta s
s F
uq n
e o
e O
r d
i lb
.s S
a t
is n
a e
T o
r e
t l
af s
p s
s f
sl e
n v
I e
F e
l o
p t
O h o e
f C
r s
ta f
o e
d C p e ).
r o
s D
C o l
e e
f p
o y
il d s w
c o
n E
N n e o
n s
g c
A c
a ei p
a y A s n i
o n f
t t n
c P
l t
p e m io n
l k
lat q
A s in i t
E ne si p
e.
el r
a E g s
el o
t s uE
)
o V
L r n
ot r
I e
e e
n e gP s( pt t
l T
o e
c a e d nl er n
r f
a m v aiE t el o C
h e t
is o
b e
w ut os C
a E
t p
d d oy on r t
r s
n p
J r
e e
e f
nt n h b r et y
B t o p
r sh o
a n a s c n l
u a
c O
a p o
a p
c e
nn oc n
h p e e p
t y
y c yZ o onci e
E t u f
r n g u oi t
t i t Pii o g
g s
o u on co r
e o y eipti s t k i
l n
il a et e
C t t v
c c n eh s y s il i if i E t t i il S
t h I
e i g b m ucef le sl upf b
t m
a a a rl gi i r l
led e
u p u ei o e
s l
p ec ad t
a a u E
t e i
q SF T L N l
o l
lei l PPE f Tf E
r s s
R w
l le r le ov X
si v
e e
E nl E
d i h v
v n v
l b
a ep a
A - - - - =
A s A
A a A - - - - - -
c
= p
- e u o
ED S r e o
e e
e l
V O
{
I T
S g
Cd T
m E
m C
a J O e
BE 0
T O
r J'
i
Fas2 A2I ca 2:en EXERCISE EVALUAT1001 CRITIQUE FORM Te es, Local Emergency Operations Center Evaluator's Name8 A. Satch LDCATIOll/
EXERCISE OeJECTIVE AalD POINTS OF REVIEW EVAISATot(s)
ASSICatlENT 0 0 068017 5 AND REcolelEMETI0 tis OsJECTIVgg C00elENT5 (cood Performance or DeficJency --
factually describe your observation) 1 EOC 7 Demonstrate that sessages art "sasmitted le en occurate and fleely XA LERG EOC menner, messages are properly logged, that statue boerde are accurately malatelned and espdated, that oppropriate briefings are gg held, and that incoming personnel are briefed.
s 1
ICINT5 0F REVIEW e Timeliness and ocevracy of Information transeltted to emergency response locations from the local EOC (f.e.,
Steging Areas and Emergency hows Center).
e Malatenance of message logs by emergency coordinators (see CPIP 4.1.23 use of message forms by LERO local EOC statf (see OPIP 4.1.23.
e e Malatenance of Status Boards within the EOC (see (PlP 4.1.2,
,sectlon 5.23.
e Periodic briefings of key orgenlaations on the status of LERO WMTW BWWE emergency operations ey Olrector of Local Response or designee (see OPIP 3.l.1. Attachment 3. Page top, mace.ee ms e ====
e==-e e s-one===
..ee.
m g
-.e
-8 Briefing of Incoming personnel es appropriate.
e e
esce.e emi., se e.. s. e e
esteene.0 er _
e 81Respesum.
edC9ed et gf.eme.eesses,eesseng w est e
sum e
sses.
. eeee.t er eyese*
1 s
e Sd(Its W MOSe W ^
. SeeeBS
. sees eeene..my avawaroR nusi locari,, ou cssacyossI OR cm,ucrin p.e.e...,-
'actio,.is, sire. Arco.w.eationes, on rQuos..c Pact is,
.e.e.
een.
se. -
,/
g
%sst W
reti a vi. ' _ _.
EXERCISE EVALUATI0el CRITIQUE FORM EXERCIS2 Shorthase DATEI F:brscry 13, 1986 Team: teca! Emergency Cparations Center Evaluator's llamel A. Smith IRCATIOll/
EXERCISE OBJECTIVE AleD P0118T3 0F REVIEW EVALUATOR (5)
ASSICletENT CDettENTS:AND REcolemmATIous W ECTIVEI COlelENTS (Cood Performance or Deficiency -
Ecc,
o stret. th. ebility 1 coords t.
th. e cg cy r.spons..ith yy teRo r<c
(*** V d***
V" **dd county sad State of ficials. tRole of State and/or county of ficials will be simulated by FEMA designated personnel.3 gy ebte: The demonstretton of this objective is ef fected by the legal authority issue.
Ih.
Foruts or azVIEw yy e All protecttwo actica decisions should be coordlasted alth State end county of ficials (simulators).
Ref erence plan sectione 3.4 (p. l.4-lel, 2.2 (p. 2.2-4g-hl, 3.1 (p.
e 3.1-13. and 4 (p. 4.1-13.
EVALUATICII BCNEME e.
esco.e ee e =
m um.
ano
.a e = e== a==e-e
.=.m=,
.e amo.e.esu as e * =e.*. _ **
me=me e ^
\\
e.
e.
ence.e we as.-=====
e e
.. a.-=-
e
.e
==
eso.e.se me.ee c*.
=e EVALUATOR #suST IDENilFF DEFICIENCYlIE510R C0fulECTavE esco.e e m.sms e=c ACfIoss($ 3 mefM RECope(DOATloss($3 ON FOtLouiesF, PAG $ p b
D
.. ~.
~l' c
i t
x
=2
=g
)
%[v e
3 5
i si a
3:
l :t El E 5 t
g-
_e a
a: :s 4,8 El
=
g a=
sr 4
.2 18 2
c v2 e=
a au
-s
=
n 84 Is 8
t, s:
2:
si
=1 8%
OW 34 E
e I
)
He
- l!
l l
1' 1
3 EE je g!,' l 2 f'
o
!}.'eiI'?
11 l
as a
a 5e M:
d.
,ll in 11 11 a i sa 11 1,,1!
i 1
I a
g I
i a
p I
j c
-- e x l
x I
e a
1 B
l 3
i I
i w
a o
h g.
C-
=
a
_5 5
h.
3 a
2 I
=
g a
.a =
x x
k
=
g u
i 1
1 5
E... E
'1 1
~
1 E
,= 1
=
g 1
0 g
T
. !l3 a
8 8
5 8a o
8 2.g.
2 W
8 2
3=
g w
E
- T 2
,U i
a o
x 2
8*
7 5
- 1
-s a
5 u
3 6 Mg
=
=
.s.:
ak.y. *d 3
W 338 -5
~=
E s; sl
- -) 3 a.:
w
.o 3
- ~
g 623 e
C=
C
~
3 48 5
a 8*
2 i
E'_
EXERCISE IVALUATION CRITIQUE FORM T2 ems local Emergency Operation. ' enter Evaluator's Names a_
- o.,, h IACATIOll/
EItacISE OSJECTIVE AalD FOINTS OF REVIEW EVALUATOR (S)
ASSICleqE3lT (DetE3lTS AND RECGOElmATIOllS gg Cole lEntTS (Cood Performance or Deficiency --
strate the organisational ability to manage en orderly evacuation LES EOC actua))y descrJbe your observation) of all or part of the to-elle EPZ including the seter portion, esote: The demonstreflon of this objeCilve is ef fected lpy the legal kN sotherity issue.
89I1173 OF REVIEW e lief erence s Appendia A Evacuation Plan, implementation of CPIP 3.1.1, Attachment 4 e
e implementation of (PlP 3.6.l.
I Knowledge of preset locations for traffic control, e
e Consideration of relevant factore such as evellebility of a
transportetten resourc.s. traf fic volume, evellability of traffic control personnel, Coordination with Recepflon and Congregate Core Centers, o
EVAIJ34TIOli BQlEME GA.144 40 0 ED pees eeensteeg.ersespous apetse e
9 h pset feestr886 ^
O t
e h esees. sense e h
e ed. sed et 48 enemmeeresse e
e Goossemessesse er apres =
g e#ee WDemment muss SS.I*G W Mme Dest ^
. 98eams g
es.se essaan ey ETAtuArm Must t0ENitFT DEF8CIENCTilE55 OR CORRECilVE r-
'aCno s eira wCo.wicario lsf on rouosi.c P crisi e,
2 i
Pasi A'S cl y _
EXERCISE EVALUATI0ld CRITIQUE FORM Tame: Local Emergency Operatione Center Evaluator's Names A. Smith IACATIOlff ExtaCISE OBJECTIVE AND POINTS OF RIVIEW EVALUAlt)R(5)
ASSICletG T EDielEllT5 AllD RECOMMENDATIO115 e
DeJEcTIVE:
oneenTs (cood restormance or Deffe4ency -
Ecc It Demonstra's the orgentsetional ability to deel with Impediments to IX LERG ECC tactually descrJbe your observation) evecuation such as inclement eeether or traffic obstructions.
sente: ine demonstretton of this objective is ef fected by the legal autherlty Issue.
ICINTS OF REVIEWS o References Appendte A. Evacuation Plea.
implementaflon of CPIP 3.6.3 e
Prompt dispatch of appropriate equipment to clear the lepedimeet.
e e Ability to determine and laptement en appropriate re-routleg of traffic, if appropriate.e Ability to Issue en EB5 message. it appropel.te.e e
seter Re-rowflag of evecwetion traffic is contrary to the LERO pies and LILCO.s testimony concerelag traffic control.
EVALUATIOl1 ScalDat eme e me.e..w
= e me e
.e
- ===*e-(
e me m.a. o e n.e m.
e man.e== e. e e
.w e
ew....
e
- 8***"'"""*'***^
e.
E VA!UATOR NU$T IDENisF T CEFICIENCTilES) OR COWCilvE eso.e mm e.
ACis0N($ 3 WITH REC 0pedIDOATIONi$) ON FOLLOulNG PACE ($1 J
W
W
.e
- S mue i n
E; a v" h
._.k 9
5 l
i g
ia E's 4
.4 IN
~E 9
2:
E:
I a il
- i
=
t%
48 U$
52
.2 E8 C
8%
EW 5
it
-a 1
84 IE 8
t.
5:
$5
=3 80 0W 34 i
E 5
d
)
Ie
' t i,, !'
i
~5 i
E 8
=3 8
I.
r h-I,s l
..I Es 5
Sil I i][ [':! ji H
sa 11,1 !
I c
E e a.
8 5
U xx i-i I
I g
g i
i i
DE l
ay g
n I
i i
i c.
e i
g 5_
r E
! I 1
x s 2
=
w 2
i I
2 8
i i
E
=%
)
4 e.:
- J E.
=:i o
2 21 1
c
- -i r
a 22-
.n i
g g*.
ec 4
5 338 i
t y
175 b
y S
4 E#$
1 8
I8.
8 s
f a
!:J:
W e
3 ?2 n
y 2'f-3 w
a
.'
- 3 5 3 5
sl13}- g -I di M
58:
3 a-l U2 p
I M8 E
a 8*
E
i l
_o e
yC 59fi
)
I
.3 si A
en Es y-I 22 er!
U. ".
2 a
a8 El
=
I t=
=r s
.2 58 2
n 82
!=
=
a na
-z
=
s 84 Is 8
t.
s:
2:
ii
,1 x=
8%
OW sc 5
E I
a g5 M
)
~I
'l
[
1'
-s Ee B
I.
l An M
l il'l' >r;.
l:llit 1
2 a
5 e
3:
.o l.
11
' l.
n x
g ga 1,,,1,1
- i. l i
=
8 i
i 3
I 5
A l
5 I
I g!
g e
l.
I l
O d
M gg g-t i
a a
a E$
C W
[I "c
[.
k i -
i g a W
i ;
$ ]a b
i k
- / $
t 1
- =
{ 3 U
l e*
3 8
B 2 :
- 5 E.I
_k E
.b
=
a a
k.
I I
1
$[
)
6 5
3
[
3 l
t 1 E
j I i*
x2
- s 8
g 2
2 2
I 3
-I u
.E.
E
_I ;
a 7 _
.h a
3 7 ;
e~t 5
8 E
3 h t !
E j i h b 3V I ; i
=
'8 8
2 8 8 g h*
E 4
2 3 E
I*n 3
n a
N
=
5:
- I g
2 2-U y.s)- B g l -l 22 u
- r 3
s, w
=
-$a
-I
! en ses sis 3
g B
ti :
b
..I 48 8"
2
~_W c
Im'
^4 g
15 9
s lW e
f i
E 7
55
\\
a la
=
4 4
4
==
8 !:
Es
\\
an g-c I
at 93
=
to a8 gI w
a
~ :n
=Y 5
3 El t,
ar 2
-l
- t
-s a
e is
-[
e' s:
ii_
=~
,a g.
v 50 I '! I< 1,
-i l
~5 I
se 8;:g a
I rr in' i
=
- 2-a l) i1i,
!,it 11 5
v.I I
ve 8a 11:1,:
!.I g i
c a ggig g
5 I
[
i i
i
$ i I
i il :
E'
~~
- e 5
a a
i I
I i
gj c
i
=
ii
'i s, t i i i
3 m
n3:
U
..d. ~)
j
=
z s
y 6
.- r x
8 2
3.:
.i I
I a
a i.
s E
filg
-r 3
8 8 s :
6
=
- 1 :. _ -
o n 3 E
12! a1 E
I
- -le s
- e i
c 2-ag gj g j
1, j i
!iIy e
-1
.r!
.,s 8
3
-:3...
-1 g-
. =. =1 1:g.::g:~
12: -
- e U
j
{ ; 31 2 1 :, a s
c 4
s t
8
-g3 8.
- 8 ff j 5 -12
\\
eialel!
8 8
=
-s n
e
!.---5 1.:
u
- i s e. :
1 [ss 81.;
=
=3 B6 g:
[ :
g 3
-I t 5 & 2 d5
=j!.,il2
~
s)
= 2
(
c..
3 t
U2 h
3 4g 3-2
i
,1 si E
rt-6I J
c gs O
e 8!
g 5 8 si Es I
U2 W
E:g A
C*
ai El a
4
~
t=
El
.2 D
8%
it I
a 32 34 j!
g is 2~9 f%
wC E
a 4
5b
-i
[ l I,e l,
~5 ge 8
- n 3
l
.I U
h.
e 9
' gl.
g 11 s
$3 I
E
' i g{
ga
. lg!t 1
=
8 !!
i i
5 i
f i
i i
N 5
I i
I I
a,e 9
e yj C
W"c
(
We b
14 k t 53 3
I!
l C
b i
a I
E 5
t
(
$1 I
I 2 I
e a
E
_8 =
_! -[ i s
I
}I i
g 2
t
^ t 5
a g
e
,r t
- i 6 i 8 3
=
C 4
!I I
- l. I j 3
x II i 1 I
w e
- g ai i
i 3
i a
i U
W
~
}
r 4 j
gly W
3 _ t & 2 i
3 O
5 8!
45 a
2 e
THis ao..
g a
i SHOREttAM EXERCISE E
IMPEDIMENT TO IVACUTION ROUTE MESSAG
- .Q
g 13, 1986 C.
4.,
February Dates I
County, New York
~M..
d Impediment - Fort Jefferson es C. Cocoolly, EOC Team Lander EOC Evsevation Route Coordinator at LERO t
via Esercise Controller been leeued to After E5S assease to evacuate has r (E. Bertree) the public and FEMA field evaluato
/h le in
' 23% (
.ating Events has notified EOC Team Leader that he s e position to evaluate field response.
EAST OF TBE INTER-CN BOUTE 25A, AFFROIIMATELT 75 TARDS AD. (IN THE VICINITY l
SECTION WITH NMER FLACE - TAPRANK RO TANK-TRUCK SAS JACE-5 sges OF TRAFFIC WNTROL FOST del), A FUF,LKNIFED A 1DCKING BOTH IAST50tBID TANK WAS AND WESTBOUND TRAFFIC LANES, AS WELIN THE CDU
(
1HERE 15 NO FIRE THE ROAD.
RUFTURED AND !$ LEAKING FUEL.
THE FUEL COULD IGNITE CAUSING A FIRE.S TO ANY IN AT FRESENT AND WERE ARE NO INJURIE 13 IMPEDIMENT 1HE LERO RESPONDER TO THE $1TE WILL BE VEARING f
A COLORED ARM BAND.
Commenta i
Evaluator line Signoff
_ G JZ l
Message given to
[ 'Atd IOC _[
l controller by team leader at LERO EOC han Lyad f f
at LER046C) f Message dispatched to
$ne YOT,f 2.
the road crew / fuel JX truck responder from p g, "
XI l
(Eva'c. Ops.
f the EOC Evaluator at LERO EOC)
.N Verification of Message gy
! b.-
f to road crew responder 3
.s -
l EOC lCommunicat tons received at evaluator at LERO N'
EOC)
J f
Road crew unit q$
the
.f 4.
evaluated at iField Evelvator )
field location
[h%
L
~
l
. ;..... i t t
.'i
~~
- i,,,p
.- 9 E
- g v.-i
,. ', y.,.
f f
n y
I
~.. -
- _ - _. - _. _ -. _ _ - -. _ _ _ _ -. - - - - - ~. -. --
THIS IS AN EXERCISE SROKEKAM EXERCISE IMPEDIMENT TO EVACUT10N ROUTE MESSACE County, New Yoth Date: February 13, 1986
't Impediment - FatchoSue gg+
,,,fCTeseLeader "o
Evacuation toute coordlestor at LERO E0C via Esercise controller
.ing Event: Af ter ESS assesse to evacuate has been seemed to the public and FEMA field evaluater (C. Sarriche) has motified EOC Tese Leader that he/she is le position to evaluate field resposes.
.J A 14ADED CRAVEL MUCE WITH A BROKEN DRIVESRAFT, Wu1CE IS UFRICET, SUT TURNED SIDEWAYS IN TWE ROAD IS BIACEING THE NORTH AND SOU111RotMD LANES AND 3075 SHOULDERS OF YAPMANE - MIDDLE 181AND ROAD. APPROEDIATELY FIFTY (50)
YARDS NORTM OF THE CAUTION LIGHT AT TWE "Y" INTERSECTIDW 0F YAPEANE - MIDDLE ISLAND ROAD, MAIN STREET AND MILL ROAD (IN WE VICINITY OF TCP #124). THIS IS A MULTIPLE VEHICLE ACCIDENT ALSO INVOLVING NREE PASSENGER CARS THAT ARE SIDCIING BOTH THE NORTH AND SOUTMBOUND SEOULIERS OF THE ROAD.
THERE ARE,N,0, INJURIES TO ANY INDIVIDUALS.
0 THE LERO RESPONDER TD THE SITE OF THIS DtPEDDtENT SHOULD LOCATE THE TEMA EVALUATOR WHO WILL BE WEARING A COLORED ARM BAND.
Evaluator Sianoff Time Comments
. sage given to
. troller by team
. der at LERO EOC (Team Leader at LERO EOC) isage dispatched to
- e road crew / fuel
.ack responder from
(
(Evac. Ope.
Evaluator at LERO E0C)
Pification of Message road crew responder
'eived at EOC (Commun tca t ion s evaluator at LERO EOC) ad crew unit
.aluated at the
.41d location de' alt Fwaluator) 8 THIS IS AN EXERCISE
(
J 1
4000MS9
i-I 8 f t e en f
SRORERAM EXERCISE SPECIAL FACILITT EVACUATIOQ MES$ ACE
- . y Ambuletto l
13, 1986 Dates February l
Suf folk CountF, New York hw l
i t
Ambulet te f
I Messager C. Connolly, EOC Teen Leader j
l From:
RO EOC Special Facility Coordinator at LE j
f wie Esereise Controller To Decision to evacoste Zones A-E, F, C.
4%-
AL PALST RESIDENCE AT s%
Initiating Events SEND A REAL AMBULETTE TO UNITED CEREBR r
442 RANDAL E0AD, RIDGE, itEW YORE.
ECAUSE THAT FACILITY'S 1
Wessages BLE, AND THEY RAVE REQUES f
CUE FATIENT REQUIRES AN AM8ULETTE R l
l TRANSPORTATION RESOURCES ARE VNAVA j
WIS ADDRESS, DE VEHICLE 18 TO CO TO TOOK, NEW Y
'l ASSISTANCE.
(
RESIDENCE AT 4 MEDIA' LANE, STONY BR Commente l
Evaluator M
Signoff i
Nessage given to 1.
controller by team leader at LERO E0C TTeam Leader at LERO EOC)
XI
'"N Message dispatched to 2.
Ambulance / Ambule e te 010 1 Company from the IEva'c3 valuato I ~
~
f Field Evaluation of g
l l
3.
Ambulance / Aabulet te (FieldEvalusto3 4
Company V
f*
I M _..
$1 l
arrives at EWDF/EOC g
Vehicle a.
l l
4
// / b,
[
II k
Vehicle dispatched from EWDF/EOC b.
(
f
/J)
I Evetuation route completed c.
/ D Ct r
Vehicle arrived at reception cente d.
s i
- No,'
seoet -
~
..~
i V.M 51. Q... P f, -
I i
e 1
1 s.
. v.- +t a ;: ;
. o'.
f a
J
(*Jo l1 -
THis so..
g SHOREHAM EXERCISE E
IMPEDIMENT TU EVACUTION ROUTE RESSAG lQ' I
13, 1986
~:.; g.
February Date:
a County, New York tapediaant - Fort Jef ferson es C. Connolly, EOC Tesa Laeder EOC i
Evacuation Route Coordinator at LER0
- ~-
via Exercise Controller been issued to After ESS message to evacuate hastor (E. Bertram) l the public and FEMA field eva ua
/ he la la
' y< yo r
.aring Event:
has notified EOC Team Leader that he s
% 5m position to evaluate field response.
EAST OF HE INTER-ON ROUTE 25A, AFFROZIMATELY 75 TARDS (IN THE VICINITT D
SECTION WITH MILLER FLACE - TAraANE ROA,,TANE= TRUCK MAS JA age:
OF TRAFFIC CJNTROL FOST #41), A FUFJ,ENIFED A CEING BOTH EAST 30tRID i
l EL TANC VAS AND WESTBOUND TRAFFIC LANES, AS WELIN THE COUR
(
THERE IS No FIRE THE ROAD.
RUPTURED AND 15 LEAKINC FUEL.
E THE FUEL COULD ICNITE CAUSING A FIR.S TO ANT INDIVID AT FRESENT AND THERE ARE g INJURIE IS IMPEDIMENT THE LERO RESPONDER TO THE SITE WILL BE WEARING i
A COLORED ARM BAND.
Consents Evatustor Time Sicnoff
)
_ 6/E
~
Message given to
[ Mtj 2
Ood controller by team 1eader at LERO EOC hasLy%cC) edpi st LER0 l
1 l
Massage dispatched to
&5;#
the road crew / fuel JX II#,/
f 2.
7
/
truck responder from pg.
II the EOC (Evac. Ops.
{
Evaluator at
[
LERO EOC)
.N Verification of Message gg l
to road crew responder 3.
,e -
received at EOC lCommuni, cat tons evaluator at LERO EOC)
/
Road crew unit the
.c 4.
evaluated at field location IField Evelget
$ 4. r.
- % 4, o,,
W 7,
g 1
j p a ;,.
- ,Y,& ' A '
.. ', t.,
l l
I i
I l
~
f w,,--
ww n--
n -
THIS IS AN EXERCIS'$
SROREHAM EXERCISE IMPEDIMENT TO EVACUTION ROUTE MESSAGE County, New York Date: February 13, 1986 Impediment - Patchogue g;
,,,fcTessLeader Evacuation Route Coordinator at LIRO EOC o
via Esercise Controller
- sing Event: After ESS message to evacuate has been issued to the public and FEMA field evaluator (C. Sarticks) has actified IOC Teen Leader that be/she is in position to evaluate field respoese.
- r
.a :
A IAADED CRAVEL TRUCK WITH A BROKEN DRIVESEAFT, WEICE IS UFRICET, SUT TURNED SIDEWAYS IN THE ROAD IS SIACKINC THE NORTH AND SOUTH 90tBID 1 ANES AND BOTE SEOULDERS OF t
YAPHANK - MIDDLE ISLAND ROAD, APPROIDtATELY FIFTY (50)
YARDS NORTH OF THE CAUTION LIGHT AT TWE "Y" INTERSECTION OF YAPHANK - MIDDLE. ISLAND BOAD, MAIN STREET AND MILL ROAD (IN THE VICINITY OF TCP #12A). THIS IS A MULTIPLE VEHICLE ACCIDENT ALSO INVOLVINC THREE PASSENCEE CARS TRAT ARE BLOCKING BOTH THE NORTH AND SOUTMBOLRID SEOULIERS OF THE ROAD.
THERE ARE N0 INJURIES TO ANY INDIVIDUALS.
0 THE LERO RESPONDER TO THE SITE OF THIS DtPEDINENT SHOULD LOCATE THE FEMA EVALUATOR WHO WILL BE WEARINC A COLORED ARM 8AND.
Evaluator Sianoff Time Co - nts
+ sage given to
. troller by tese
. der at LERO EOC (Team Leader at LEto EOC) seage dispatched to
- a road crew / fuel
.ack responder from
(
(Evac. Ops.
Evaluator at LERO EOC)
?ification of Message road crew responder eived at EOC (Commun sca t tons evaluator at LERO EOC) ad crew unit
.aluated at the
. eld location f*'ald Fweluator)
,e*
I THIS IS AN EXERCISE J
1 400CW 39
s answ.
SRORERAM EZERCISE SPECIAL FACZLITT EUACUATION MESSACE
.*.,.,Q Ambulette 13, 1986 Date: Tebruary i...,
Suffolk County, New York
- q h
I Ambulette j
Messaget C. Connolly, EOC Team Leader e
LERO E0C From:
Special Facility Coordinator at i
via Exercise Controller Tot Deciolon to evacuata Zones A-E, F. C.
MQ-AL PALSY RESIDENCE AT 1
Initiating Events SEND A REAL AMSULETTE TO UNITED CEREER AA2 RANDAL ROAD, RIDGE, NEW YORE.
BECAUSE H AT FACILITT'S Message i
ABLE, AND TREY RAVE REQCTS CNE FATIENT REQUIRES AN AM8ULETTT.
TRANSPORTATION RESOURCES ARE QNAVAIL 4* '
THIS ADDRESS. THE VEHICLE IS TO C0 TOOC ASSISTANCE.
(
RESIDENCE AT A MEDIA' LANE STONT BR Consents Evaluator M
Signoff Message given to 1.
controller by team leader at LERO EOC at LERO EOC)
$I
'*d Message dispatched to 2.
Ambulance / Ambule e to Ig
_OfMd.
Company from the LERO EOC (Evac. Evaluator at LERO EOC)
Field Evaluation of p
3.
Ambulance / Ambule t te
,(Field Evaluator)
Company f
15 arrives at EVDF/EOC Vehicle a.
/ / [
5 Q
Vehicle dispatched from EWDF/EOC n
I b.
/d) 5%
i.
Evacuation route completed c.
l
/ _D CA 15 reception center Vehicle arrived at d.
- Nw.e. p R
.~
ihWA-.
.. :THk'R.j*1,yj,
+
. *. ' L;;
, p'.,s
- ~
.. 1
,.4 3
f,*
(,..wnt N>
f t
j i,,
a vd.
t i
1 l
g, :.
e....
b y c,,
i SHORERAM E2ERCISE SPECIAL FACILETT EUACUATION MESSACE Ambulette Date: February 13, 1986 Suffolk County, New York I
Message:
Ambulette l
3 From:
C. Connolly, E0C Team Leader To Special Facility Coordinator at LERO EOC f
via Exercise Controller Initiaties Event: Decielos to evacuate tones A-E, F. C.
SEND A REAL AMBULETTE TO UNITED CERESEAL FALST RESIDENG AT f
j Message A42 RANDAL 30AD, RIDGE, NEW TORE.
ONE FATIENT REQUIRES AN AMBULETTE BECAUSE TEAT FACILITT'S TRANSPORTATION RESOURCES ARE UNAVAILABLE, AFD TEET EATE REQUESTED LERO I
ASSISTANCE. VREN SIMULATED FICEUF OF INDIVIDUAL BAS BEEN COMPLE k
THIS ADDRESS, T 3 VERICLE IS TO C0 TO THE tRIITED GRESEAL P&LST RESIDENCE AT 4 MEDIA'IANE STONT BROOK, NEW TORE RECEPTION CENTER.
I' Evaluator J
Slanoff Time Commente 1.
Message given to I
I controller by team MI
~
leader at LERO EOC
~
( eseLeaderf a LERO EOC)
N'"
i i
N 2.
Meenage dispatched to
\\0.S' O I
1 Ambulance /Ambulette i
1 Company fron the gg f(T, i
//'N LERO EOC
)
l E c'. Evaluator at LERO EOC) i 3.
Field Evaluation of Ambulance /Ambulette Company (Field Evaluator)
(
7 Vehicle arrives at EWDF/E0C s.
1
'8 b.
Vehicle dispatched free EVDF/EOC l
~
Ig Evacuation route completed c.
.5 I
I d.
Vehicle arrived at reception center N
- 4...THIS'; lb. A i
a, l h,g.![] W'hu
.. w I
' '1 I
~..%,.
'N *,.." ' "
g
- *j s$
os
THib 13 m ca s n w.w-9 SHORERAM EXERC15E
/ C 7C g
ROUTE ALERfDC MESSACE
,z (Simulated Sireo Failure)
Date: February 13, 1986 Suffolk County, New York I,
Message:
Route Alert.
From C. Connolly, E0C Tese Leader i
To Coordinator of Public Informatios l
at 12R0 EOC via Esercise Controller Initiating Event: Approximately 20 minutes af ter sires activation.
i MAREETING EVALUATIONS, DC. RAS CALLED AND REPORTS TEAT Message SIREN NUustas 26, 45 AND 89 RAVE FAILED TO ACTIVATE.
Evaluator Sianoff Time Comments f
(
1.
Message given to controller by Tese p+
f,*g Leader at LERO EOC
//
i
'(qm Leaderf i
NO
Massage dispatched from C[..,yg.
,j g g,
!;h Special Facilities Evacuation Coordinator.
(f.r.. C.
o f 2 A.
XI 097f i
to Lead Traffic Guide s
j at Staging Areas g3,
o$2 Y
)
( _ Evac. Ops.
483 i f
Evaluator at 1220 EOC) i Evaluator's Name Siren #
Time Comments 3.
Route Alert Driver (s)
I deployed from Staging Area 4
Route Alert Driver (s) completed Route.
a (Enter time
'f route was
(
completed.)
THIS IS AN EXERCISE l
i 1
t
[
v l.;
- 2. - $5MX'..S
=
l
~
.,U.",.,..
sO f
'?
.i,
..a Mi,
{
Q j
3 *
.'# f
[
-l 1
1,
.e, t
e e
l
THIS IS AN EXERCISE 5& /
C*f y a
l 580tERAM EXERCISE N'.#
ROUTE ALERTING MES$ ACE
[7 -
)
(Simulated Siren Failure)
'Suffolk County, New Tork Date February 13, 1986 Message:
Route Alert From:
C. Connolly, EOC Team Leader To:
Coordinator of Public Information at LERO EOC via Exercise Controller Initiating Event: Approximately 20 minutes after siren activation.
Massage MARKETING EVALUATIONS, INC. RAS CALLED AND REPORTS THAT,
SIRIN NUMBERS 26, A5 AND 89 RAVE FAILED TO ACTIVATE.
Evaluator Sianoff Time Comments
{
1.
Message given to controller by Team Leades at LERO EOC (Tese Leader at LERO EOC) 2.
Message dispatched from special Facilities Evacuation Coordinator to Lead Traffic Culde at Staging Asees hI 4n (Evac. Ops.
Evaluator at LERO EOC)
Evaluator's Name Siren #
Time Comments M,,
3.
Route Alert Driver (s) 1.-
deployed from Staging
</ f e 7 Area 4
Route Alert Driver (s)
XX M
//fon completed Route.
[
(Enter time YX route was completed.)
s THIS IS AN EXERCISE t'
[ '
psao
. a. s' '*4
. _ g%
4 q.,.* c p,ajhug W.p~"
, ' Ent
. t,.*;;.
,? a 6-
?*.., y -
1;-
o
.7 p L'
)'.
=.
._______.__._____________.______.__..________m..
i SQOR.EBM EXERCISE ROUTE ALERTDC MESSACE (Simulated Giren Failure)
Suffolk County, New York Date February 13, 1986 i
Messages Route Alert i
l l
From:
C. Connolly, EOC Team Leader l
To Coordinator of Public Information
'l at 12R0 E0C via Isercise Controller
'1 I
Initiating Event: Approximately 20 slautes after aires activation.
f Messager MAREETMC EVALUATIONS, NC. NAS CAL 12D AND REF0tTS NAT l
sIRan wtataEts 26, 45 AND 89 NATE FAII2D TO ACTIVATE.
i l
Evaluator Sirnoff Time Commente
}
1.
Nessage given to j
{
controller by Tese Leader at LERO EOC i
,1 (Teen Leader at LERO EOC) 2.
Massage dispatched from Special Facilities Evacuation Coordinator to Lead Traffic Guide at Staging Areas M
083Y I
' "< f
,f (Evac. Ops.
Evaluator at LERO EOC) gg3t/ y gg Evaluator's Name Siren #
Time Comments 3.
Route Alert Driver (s) p
@9 OfM ld y
i i
deployed from Staging I
Area I
4.
Route Alert Driver (s) 31
$7 09U i
completed Route.
XI (Enter time route was d
I completed.)
I v.
y l
THIS IS AN EXERCISE
.W EUe'
- L*.
, %Mf e g
'*=~~-~_m._
' el* *^ M j i
- t ; f.'ted
- ,. 1 J,$ y;;d I
,.;j I
r=
i
.9.b 4.v
\\-
_j
THIS id = ---
SHOE QAM EXERCISE ROUTE ALERTDC KESSACE
,.[,.
(Simulated Siren Failure)
Date: February 13, 1986 Suf folk County, New York Route Alert Messaget C. Connolly, EOC Team lander From:
Coordinator of Public laformation at 1210 EOC via Esercise Controller To Approximately 20 minutes af ter sires s.ctivation.
N Initiating Event:
MAREETUC EVALt!ATIONS, DC. RAS CALUD AND REPORTS TEAT SIREN WVKBERS 26, 45 AND 49 RAM FAI12D TO ACTIVATE.
Messaget Evaluator Coenene a_
S1seoff*
Time _
1.
Message given to 4
f' controller by Team Leader at 12RO EOC lTeam Leader at LERO EOC)
Message dispatched free 2.
Special Facilities Evacuation Coordinator to Lead Traffic Culde at Staging Areas (Evac. Ops.
Evaluator at LERO EOC)
Siren # Time Catwents _
Evaluator's Waee I
XX I
45 p T 4 O_ J1..,
f Route Alert Driver (s)
_iS 3.
deployed from Staging r
Area I
a S DU-I II Route Alert Driver (s)
]
l 4.
completed Route.
(Enter time
{
rcute was completed.)
THIS IS AN EXERCISE
-. + +
S0000003 ll..
, Y
. -.,., -n
,gL. ' i* [ k t
('
s
THIS is Are s.a-....
/#
SHORERAM EEERCISE SPECIAL FACILITT EVACUATION MESSACE Asbulance Date: February 13, 1986 Suffolk County, New York Ambulance Message:
C. Cocoolly, EOC Team Leader
^
From:
N '*
Special Facility Coordinator at LERO EOC Tot via Exercise Controller Decisioe to evacuate Ecoes A-E, F. C.
Initistlog Event RILLTOP SEND A REAL AMBULA;tCE TO CUR LADY OF PERFETUAL RELF CO k
Message DRIVE, SOUND BEACE. NEW TORK.
1, '
WHEN SD(ULATED FICEUF OF S TO C0 TO ONE FATIENT REQUIRES AN AMBULANCE.
INDIVIDUAL RAS BEEN CONFLETED AT THIS ADDRESS, THE VEEIC ICIAL (SINCE THE RECEPTION CENTER ASSICNED BY THE AFFROPR
)
.. 4 THE PLAN SPECIFIES RECEPTION CENTER IS TO BE ARRAN
{
,1,' -
Evaluator Comments Time Signoff pre m;
1.
Message given to h
_[
controller by team 1eader at LERO ECC TTeam Leader at LIRO EOC)
Message dispatched to 2.
Ambulance /Asbulette 1
Company from the IIRO EOC lEvac. Evaluator at LZRO EOC)
Field Evaluation of 3.
Ambulsace/Ambulette p
Company (Field Evaluatus)
_d 7 6[_
A*6 444, VeM+1e arrives at EWDF/EOC s.
l e.
hA f*
e o k 6 / W JNt ched f rom EWDF/ EOF
- gsfjt, ek % Q A-r sVo NNlosr My ~ gj~
V J~
h Vehicle dis ffeb
~
b.
othes a o *s
'VA Evacuation route completed p
c.
.3
/3J6__ _
tj
.. m
~
Vehicle arrived at m.y.....
w d.
.~
.[ Gg.h y 9;
t;